Australian Fire Services Pty Ltd

[2025] FWC 2565

FAIR WORK COMMISSION

REASONS FOR DECISION

Fair Work Act 2009

s.185 - Application for approval of a single-enterprise agreement

Australian Fire Services Pty Ltd

(AG2025/1988)

AUSTRALIAN FIRE SERVICES ENTERPRISE AGREEMENT 2025

Plumbing industry
COMMISSIONER THORNTON	ADELAIDE, 29 AUGUST 2025

Application for approval of the Australian Fire Services Enterprise Agreement 2025

Australian Fire Services Pty Ltd (the Applicant) sought the approval of the Australian Fire Services Enterprise Agreement 2025 (the Agreement) by filing a Form F16 and F17B on 24 June 2025. The Agreement is a single enterprise agreement and is not a greenfields agreement.

The documents filed by the Applicant declared that no employee organisation had been involved in the bargaining and that no employee had appointed the Communications, Electrical, Electronic, Energy, Information, Postal, Plumbing and Allied Services Union of Australia (CEPU) as their bargaining representative.

The CEPU filed a form F18 on 4 August 2025 seeking, pursuant to section 183 of the Fair Work Act 2009 (Cth) (the Act), to be covered by the Agreement.

There is no dispute that the CEPU has members employed by the Applicant.

Section 183 of the Act provides:

183 Entitlement of an employee organisation to have an enterprise agreement cover it

(1)After an enterprise agreement that is not a greenfields agreement is made, an employee organisation that was a bargaining representative for the proposed enterprise agreement concerned may give the FWC a written notice stating that the organisation wants the enterprise agreement to cover it.
(2)The notice must be given to the FWC, and a copy given to each employer covered by the enterprise agreement, before the FWC approves the agreement.
Note:The FWC must note in its decision to approve the enterprise agreement that the agreement covers the employee organisation (see subsection 201(2)).

The Applicant opposed the application for coverage of the Agreement on the basis that the CEPU was not a bargaining representative for the proposed agreement. The Applicant says the CEPU is not a bargaining representative because employees who are members of the CEPU revoked the CEPU as their representative in accordance with section 178A of the Act.

The matter proceeded to hearing on 18 August 2025. The Applicant Employer was represented by Mr Carnelutti, Industrial Relations Manager of the National Fire Industry Association and the Respondent Union by Mr Fox, Employment and Industrial Lawyer at the CEPU.

I issued a decision on 29 August 2025 approving the Agreement. In doing so, I noted that the CEPU would be covered by the Agreement as I am required to do by the note at the end of section 183 and the operation of section 201(2) of the Act.

These reasons for decision set out why I have reached the view that the CEPU is entitled under section 183 to be covered by the Agreement.

Factual background

The relevant facts in this matter are largely uncontested.

The Applicant Employer employed twelve employees during the bargaining process. All twelve employees voted to approve the Agreement. Subsequent to the Agreement being made, one employee resigned. Eight of the twelve employees were members of the CEPU.

Four employees of the Applicant provided statements to the Commission, essentially in identical terms, confirming that a meeting of employees was held on 7 May 2025, at which the employees “discussed removing the CEPU as our bargaining representatives, all the employees at this meeting decided we did not want the CEPU to represent us as part of the bargaining for our next enterprise agreement. At this meeting we also elected bargaining representatives that would represent us in negotiation.”[1]

At 10:48am on 13 May 2025, Mr Bettineschi, an employee of the Applicant, sent the following email to Mr Adrian Valente, an organiser at the CEPU:

“I’m writing to you to convey a message from our group of employees to let you know we’ve undertaken an in house vote and have decided to represent ourselves in our agreement negotiations. The group believes but this will give them the best opportunity in their unique situation. … Included are the emails of voting employees.”

Eight of the Applicant’s twelve employees who were to be covered by the Agreement, were copied into the email, and their email addresses are evident in the email details.

This email was then forwarded, without any further commentary, to Mr Bennett, a Director and part-owner of the Applicant at 11:53am, also on 13 May 2025.

On 16 May 2025, the Applicant Employer initiated bargaining by providing its employees with a Notice of Employee Representational Rights (NERR) by email.[2] Providing the NERR was the notification time and in this case, the commencement of bargaining.

On 19 May 2025 Mr Ben Shaw, an employee of the Applicant, sent an email to Mr Bennett of the Applicant, which said:

“I am writing to formally notify you that Todd Bettineschi, Ben Shaw and Mario Farkas who is currently employed at Australian Fire Services have been elected by their fellow employees as representatives in the agreement process.”

Neither Mr Bettineschi or Mr Farkas were copied into the email, nor were any of the ‘fellow employees’ that Mr Shaw purported had elected him and his co-workers as their bargaining representatives.

The bargaining proceeded without the involvement of the CEPU and culminated in an application to the Commission to approve the Agreement with unanimous support from employees.

Submissions of Applicant

The Applicant submits:

(a)When the employees agreed at the meeting of 7 May 2025 that they did not want the CEPU to represent them in bargaining, they had determined to revoke the CEPU as their bargaining representative.
(b)The revocation was communicated in writing to the CEPU on 13 May 2025 and the Applicant later on the same day.

(c)The employees revoked the CEPU as their default bargaining representative by written instrument when Mr Bettineschi sent the email on their behalf to the CEPU on 13 May 2025.

(d)The Act and the Fair Work Regulations 2009 (the Regulations) do not require that each individual employee is to provide an instrument of revocation to the union and to the employer.

(e)It is sufficient for the purposes of section 178A of the Act that the employees who were members of the CEPU communicate the revocation in writing through a representative.

(f)The employees in this matter intended to, and did, meet their obligations under section 178A and, as people not experienced in industrial relations, their efforts to revoke the CEPU as their bargaining representative should be accepted, even if the revocation did not strictly meet the requirements of the Act.[3]

Submissions of the CEPU

The CEPU submits:

(a)Section 176 of the Act ensures that, if the CEPU has members at the Applicant’s enterprise it is a default bargaining representative, unless each of its members appoints a different bargaining representative or their status as a bargaining representative is revoked pursuant to section 178A of the Act.
(b)Section 178A provides a right to individual employees to extract themselves from having the union as their default bargaining representative, but the right operates for an individual employee.
(c)The Act provides that a revocation can only be effected by the specific mechanism of a written instrument, given by an individual employee. Any revocation pursuant to section 178A cannot be given by one employee on behalf of another.
(d)The email of 13 May 2025 cannot be a written instrument as required by section 178A of the Act. The email does not make clear what it is, it is only from one employee, does not set out how it purports to represent the group, how the group is composed, and it does not clarify if all of the employees in the undefined group unanimously agreed to revoke the status of the CEPU as a default bargaining representative.
(e)The Act requires a level of clarity and formality in revoking a default bargaining representative which the email correspondence does not provide.
(f)It accepts that the email was provided to the employer as required by the Act, and it is unlikely that it needs to be formally addressed to the employer to meet the requirement under the Act that it be given to the employer.

Consideration

The CEPU as a default bargaining representative

Section 176 of the Act sets out who can be a bargaining representative for a proposed enterprise agreement and relevantly provides:

176 Bargaining representatives for proposed enterprise agreements that are not greenfields agreements

Bargaining representatives
(1)The following paragraphs set out the persons who are bargaining representatives for a proposed enterprise agreement that is not a greenfields agreement:
(a)an employer that will be covered by the agreement is a bargaining representative for the agreement;
(b)an employee organisation is a bargaining representative of an employee who will be covered by the agreement if:
(i)the employee is a member of the organisation; and
(ii)in the case where the agreement is a multi‑enterprise agreement in relation to which a supported bargaining authorisation is in operation—the organisation applied for the authorisation;
unless the employee has appointed another person under paragraph (c) as his or her bargaining representative for the agreement, or has revoked the status of the organisation as his or her bargaining representative for the agreement under subsection 178A(2); or
(c)a person is a bargaining representative of an employee who will be covered by the agreement if the employee appoints, in writing, the person as his or her bargaining representative for the agreement;
(d)a person is a bargaining representative of an employer that will be covered by the agreement if the employer appoints, in writing, the person as his or her bargaining representative for the agreement.

…

(3)Despite subsections (1) and (2):
(a)an employee organisation; or
(b)an official of an employee organisation (whether acting in that capacity or otherwise);

cannot be a bargaining representative of an employee unless the organisation is entitled to represent the industrial interests of the employee in relation to work that will be performed under the agreement.
Employee may appoint himself or herself
(4)To avoid doubt and despite subsection (3), an employee who will be covered by the agreement may appoint, under paragraph (1)(c), himself or herself as his or her bargaining representative for the agreement.

As a starting point when considering the operation of the Act in these circumstances, it is evident that the CEPU is a default bargaining representative for its members employed by the Applicant Employer by operation of section 176(1)(b): the CEPU is an employee organisation who has members employed by the Applicant employer.

There is also no dispute in this matter that in satisfaction of section 176(3) the CEPU is entitled to represent the industrial interests of the sprinkler fitters who are covered by the Agreement.

However, in accordance with the Act, the status of the CEPU as a default bargaining representative can be displaced if:

(a) The CEPU member for whom the CEPU is a default bargaining representative appoints in writing, pursuant to section 176(1)(c) of the Act, another person as his or her bargaining representative; or
(b) Pursuant to section 178A(2) of the Act, the employee for whom the CEPU is the default bargaining representative revokes, by written instrument, the status of the CEPU as the default bargaining representative for the Agreement.

In this case, it would be necessary for the CEPU’s status as a default bargaining representative to be displaced for each of the eight members.

The Applicant made clear that it relies on what it says was a revocation of the CEPU as the relevant members’ default bargaining representative as its basis for opposing an order the CEPU be covered by the Agreement.

However, it is also appropriate to first consider whether the CEPU was validly displaced as a default bargaining representative by the appointment of other bargaining representatives pursuant to section 176(1)(c) of the Act. If the CEPU no longer held the status of a default bargaining representative for any employees, there may be no need to determine whether the status of the CEPU as a default bargaining representative was validly revoked in accordance with the Act.

Whether the Employee Bargaining Representatives were validly appointed under the Act

Section 176(1)(c) provides that “a person is a bargaining representative of an employee who will be covered by the agreement if the employee appoints, in writing, the person as his or her bargaining representative for the agreement”.

Section 178 of the Act provides further direction about how a bargaining representative is validly appointed under the Act:

178 Appointment of bargaining representatives—other matters
When appointment of a bargaining representative comes into force
(1)An appointment of a bargaining representative comes into force on the day specified in the instrument of appointment.
Copies of instruments of appointment must be given
(2)A copy of an instrument of appointment of a bargaining representative for a proposed enterprise agreement must:
(a)for an appointment made by an employee who will be covered by the agreement—be given to the employee’s employer; and
(b)for an appointment made by an employer that will be covered by a proposed enterprise agreement that is not a greenfields agreement—be given, on request, to a bargaining representative of an employee who will be covered by the agreement; and
(c)for an appointment made by an employer that will be covered by a proposed single‑enterprise agreement that is a greenfields agreement—be given, on request, to an employee organisation that is a bargaining representative for the agreement.

Regulations may prescribe matters relating to qualifications and appointment
(3)The regulations may prescribe matters relating to the qualifications or appointment of bargaining representatives.

Section 176(1)(c) requires an employee to appoint a bargaining representative (other than a default bargaining representative) in writing. Section 178 refers to the appointment of a bargaining representative in writing as an instrument of appointment. The section further specifies that an appointment of a bargaining representative comes into force on the day specified in the instrument of appointment and that the instrument must be given to the employee’s employer.

Justice Collier of the Federal Court of Australia in the matter of Jones v Queensland Tertiary Admissions Centre (No 2)[4] (Jones v QTAC), considered the meaning of ‘the day specified in the instrument’. Her Honour found that specification of a date in the instrument is “not a condition precedent to the effectiveness of the appointment itself. … [T]he terms of the legislation are met if, as a matter of construction of the instrument of appointment, the date on which the appointment comes into force is evident on the face of the instrument of appointment.”[5]

There are no other requirements for an instrument of appointment set out in the Act or the Regulations. The Federal Court considered the requirements under the Act for the valid appointment of a bargaining representative in Jones v QTAC:

“In my view the legislation referable to the appointment of a bargaining representative in these circumstances should be interpreted liberally. The Act is intended to be accessible to employers large and small, as well as to employees both in their own capacity and through union membership. It is intended to assist relevant parties and facilitate the processes contemplated by the Act, including negotiation of enterprise agreements. The role of bargaining representative is clearly significant, however I consider that, in relation to the circumstances relevant to such appointments, the key factor is that there be attendant certainty upon the creation of the role rather than a requirement of overt formality. … … Provided the appointment is made in writing, …and provided it clearly evidences the creation of the role, the appointment is effective.”[6]

In this case, the instrument of appointment is purported to be the email sent by Mr Shaw, an employee of the Respondent for whom the CEPU would otherwise be a bargaining representative, on 19 May 2025 (extracted in paragraph 17 above). The email formally notifies Mr Bennett, Director of the Applicant Employer, that Mr Shaw, along with Mr Bettineschi and Mr Farkas “had been elected by their fellow employees as representatives in the agreement process.” As I have noted, the email did not specify the names of the employees who had appointed their three co-workers as their bargaining representatives or copy them into the email correspondence.

The relevant terms of sections 176(1)(c) and 178 make reference to a singular employee determining their bargaining representative:

an employee organisation is a bargaining representative of an employee who will be covered by the agreement unless the employee has appointed another person (s.176(1)(b));
a person is a bargaining representative of an employee who will be covered by the agreement if the employee appoints, in writing, the person as his or her bargaining representative for the agreement (s.176(1)(c));
a copy of the instrument of appointment of a bargaining representative must, for an appointment made by an employee who will be covered by the agreement, be given to the employee’s employer (s.178(2)(a)).

The Explanatory Memorandum to the Fair Work Bill 2009, in reference to section 176 and the appointment of a bargaining representative also says:

“There is no restriction on when a person may appoint a bargaining representative. This means, for example, that during bargaining, an employee who is a member of an employee organisation may appoint his or her own bargaining representative with the effect that the automatic appointment of the employee organisation as that employee’s bargaining representative will cease to apply.” (emphasis added.)

There is nothing in the language of sections 176 and 178 of the Act that suggest the appointment of a bargaining representative can be made other than by an individual employee nominating a bargaining representative on their own behalf.

The email sent by Mr Shaw on 19 May 2025 meets the requirements of an instrument of appointment to the extent that it is in writing and the date in which it comes into effect can be referenced to the date of the email. Further, the instrument was provided to the Applicant Employer as required by the Act when the email was sent to Mr Bennett. The instrument does not require any additional formality to be valid.

However, the instrument is not sufficiently certain as to which employees are nominating one of the three named employees as their bargaining representatives. The email from Mr Shaw purports to nominate himself, Mr Bettineschi and Mr Farkas as the bargaining representatives for their ‘fellow employees’. I do not accept, considering the language of the Act, that one employee can appoint any number of bargaining representatives on behalf of a group of employees that are not clearly identified in the instrument, as has occurred here.

If an employee wishes to appoint a bargaining representative to engage in the bargaining on their behalf, or otherwise nominate themselves as a bargaining representative, it appears necessary under the Act for each employee to appoint that representative in writing in order to give sufficient certainty as to the identity of the bargaining representatives and their authority to bargain on behalf of other employees. That is not to say each employee must provide a separate instrument, but it is necessary that each employee who wishes to appoint a bargaining representative identify the bargaining representative they wish to appoint and convey their personal decision in writing to appoint the bargaining representative.

As the Full Bench noted in the matter of Kaizen Hospitals v Australian Nursing Federation[7]: “it is clear that the Act adopts prescriptive and formal requirements for the appointment of bargaining representatives and that the power of a bargaining representative to represent the employer in negotiations for an enterprise agreement arises from the instrument of appointment. It is fundamental to the exercise of power by a bargaining representative that the appointment has been validly made.”[8] This applies equally to the appointment of bargaining representatives that represent employees.

The Applicant Employer submitted that, in circumstances of bargaining in large enterprises, involving significant numbers of employees, it could not be the case that each employee would be required to appoint a bargaining representative on their behalf in writing.[9] In my view that is precisely what is required if an employee wishes to appoint a bargaining representative,[10] rather than be represented by an employee association as a default bargaining representative should they be a member, or otherwise be unrepresented in bargaining. It is not necessarily the case that each employee has to create a separate written instrument but the instrument created must convey their individual decision to appoint a particular bargaining representative. Had the personal intention of each employee been conveyed in this matter, for example by each employee responding to the email confirming their decision, then this may meet the requirements of the Act. This did not happen here.

The email sent by Mr Shaw on 19 May 2025 could only be considered a valid instrument of appointment for himself as a bargaining representative. It is not a valid instrument of appointment in respect of other employees.

As there has been no valid appointment of a bargaining representative for any employee other than Mr Shaw, the CEPU has not been displaced as a default bargaining representative for other employees to be covered by the Agreement.

As such, and in accordance with section 183 of the Act, the CEPU is entitled to be covered by the Agreement.

Whether the employees revoked the representation of the CEPU pursuant to section 178A of the Act

Given my finding that the CEPU was a default bargaining representative for the Agreement and not displaced by the appointment of other bargaining representatives by the relevant employee cohort, I now address the submission of the Applicant that the CEPU cannot be a default bargaining representative because their status as such was revoked by their members.

The Applicant submits that even if the CEPU were a default bargaining representative for the Agreement, they ceased to be so after their members revoked their appointment in accordance with section 178A of the Act. The Applicant filed witness statements from four employees, three of whom, in accordance with my earlier finding, had the CEPU as their default bargaining representative. The witness statements were in very similar terms, and included the following:

“I [insert witness name] Was at a meeting that took place on the 7th of May 2025, at this meeting we discussed removing the CEPU as our bargaining representatives, all the employees at this meeting decided we did not want the CEPU to represent us as part of bargaining for our next enterprise agreement. At this meeting we also elected bargaining representatives that would represent us in negotiation. Pursuant to section 178A of the Fair Work Act 2009 we asked one of our bargaining representatives Todd Bettineschi to inform the CEPU and AFS [the Applicant] on our behalf that we were revoking the CEPU as our bargaining reps for our upcoming negotiations this was provided in writing to the CEPU organiser Adrian Valente on the 13th of May 2025 and we informed Shayne Bennett from AFS on the 19th of May 2025.”[11]

Section 178A of the Act sets out how a bargaining representative can be revoked:

178ARevocation of appointment of bargaining representatives etc.
(1)The appointment of a bargaining representative for an enterprise agreement may be revoked by written instrument.
(2)If a person would, apart from this subsection, be a bargaining representative of an employee for an enterprise agreement because of the operation of paragraph 176(1)(b) or subsection 176(2) (which deal with employee organisations), the employee may, by written instrument, revoke the person’s status as the employee’s bargaining representative for the agreement.
(3)A copy of an instrument under subsection (1) or (2):
(a)for an instrument made by an employee who will be covered by the agreement—must be given to the employee’s employer; and
(b)for an instrument made by an employer that will be covered by a proposed enterprise agreement, other than a single‑enterprise agreement that is a greenfields agreement—must be given to the bargaining representative and, on request, to a bargaining representative of an employee who will be covered by the agreement.

(3A)A copy of an instrument under subsection (1) made by an employer that will be covered by a proposed single‑enterprise agreement that is a greenfields agreement must be given to the bargaining representative and, on request, to an employee organisation that is a bargaining representative for the agreement.
(4)The regulations may prescribe matters relating to the content or form of the instrument of revocation, or the manner in which the copy of the instrument may be given.

The email sent by Mr Bettineschi to Mr Valente of the CEPU on 13 May 2025 said:

“I'm writing to you to convey a message from our group of employees to let you know we've undertaken an in house vote and have decided to represent ourselves in our agreement negotiations. The group believes that this will give them the best opportunity in their unique situation. … Included are the emails of voting employees.”

As there was no attachment to the email, it is evident that Mr Bettineschi’s reference to the emails of other employees, refers to the copying in of eight other employees to the email.

I am satisfied that the email is a written instrument in accordance with section 178A(1) of the Act. Again, there is nothing in the Act or the Regulations that sets out the requirements for an instrument of revocation, other than it must be in writing.

I am also satisfied that in forwarding the email to Mr Bennett on 13 May 2025, a copy of the written instrument was given to the employer in satisfaction of section 178A(3)(a). I accept the submissions of the parties that no additional formalities are required to give the instrument of revocation to the employer.

However, the terms of section 178A also appear to limit an election to revoke the appointment of a bargaining representative to an individual employee. Section 178A(2) provides that the employee may revoke the person’s status as their bargaining representative for the Agreement. Section 178A(3) requires that a copy of the instrument of revocation be provided to the employee’s employer. The Act does not provide for a person to revoke a bargaining representative on behalf of other employees.

There is some evidence in the witness statements and correspondence of an intention by the relevant employees to revoke the CEPU as the default bargaining representative. But there is not an effective instrument of revocation in which each relevant employee conveys their intention to revoke the CEPU as their bargaining representative.

I accept the submissions of the CEPU that the intention of each individual cannot be ascertained by an email that does not make clear that each person copied into the correspondence has determined to revoke the status of the CEPU. The email says that the employees undertook an “in house vote and have decided to represent ourselves in our agreement”. The email, nor the statements filed, confirm that all relevant employees were present at the time of the vote nor that the vote was unanimous. The evidence provided to the Commission of the decision making process of the employees was submitted by the Applicant as evidence of the intention of each employee. In my view, this evidence can only provide context to the written instrument that was subsequently provided. The validity of the revocation turns on the content of the instrument.

The email that is the instrument of revocation does not evidence each employee’s decision to revoke the CEPU as their bargaining representative as required by the Act. It is a communication by one employee representing the views of other employees. The copying of other employees into the email does not make it clear, on the face of it, that each of those employees agreed with the contents of the email or that their intention was accurately represented by Mr Bettineschi. Without some written confirmation from each employee regarding their personal decision to revoke the status of the CEPU, the instrument does not meet the requirements of the Act.

I have taken into account the practical circumstances that include what the Applicant submitted was their lack of relevant experience in bargaining and the operation of the Act. I have considered this in light of the comments of the Court in Jones v QTAC that the form of an instrument of appointment be approached liberally. However, in this matter, the written instruments relied on do not meet the requirements of the Act. The Act is prescriptive in its requirement that a formal act of creating a written instrument must be taken by each employee to revoke the status of a bargaining representative

Conclusion

The written instrument that purports to appoint employee bargaining representatives does not meet the requirements of the Act. This is because Mr Shaw, as the author of the instrument, confirms the appointment of bargaining representatives on behalf of a group of employees that have not otherwise individually communicated their appointment of a bargaining representative. For employee bargaining representatives to be validly appointed under the Act (and in this case to have the intended effect of displacing the CEPU as the default bargaining representative), the intention of each employee to appoint an alternative bargaining representative must be made clear in a written instrument. The instrument of appointment is only valid in respect of Mr Shaw, who appointed himself as a bargaining representative.

I am satisfied that Mr Shaw validly appointed himself as a bargaining representative and therefore, displaced the CEPU as his default bargaining representative. The remaining members of the CEPU employed by the Applicant did not validly appoint an alternative bargaining representative and consequently retained the CEPU as their default bargaining representative.

The written instrument purporting to revoke the status of the CEPU as the default bargaining representative also does not meet the requirements of the Act. Despite the employees who likely intended to revoke the status of the CEPU as their default bargaining representative being copied into the email, their inclusion in the email is insufficient to convey the intention of each employee to revoke the status of the CEPU. The written instrument of revocation is only valid as it relates to Mr Bettineschi because it conveys his intention to revoke the CEPU as his default bargaining representative and I am satisfied that Mr Bettineschi validly revoked the CEPU as his default bargaining representative.

As the remaining members of the CEPU employed by the Applicant did not validly revoke the status of the CEPU as their default bargaining representative, the CEPU remains the default bargaining representative for those members.

As the CEPU remains a default bargaining representative for their remaining members employed by the Applicant, and has provided the required notice, the CEPU is entitled to be covered by the Agreement in accordance with section 183 of the Act.

COMMISSIONER

Appearances:

R Carnelutti of the National Fire Industry Association, with S Bennett on behalf of Australian Fire Services Pty Ltd.

J Fox on behalf of the Communications, Electrical, Electronic, Energy, Information, Postal, Plumbing and Allied Services Union of Australia.

Hearing details:

Adelaide (Video by MS Teams)
2025
18 August.

[1] Statements of Ben Greutner, Mario Farkas, Ben Shaw and Todd Bettineschi.

[2] Form F17B at 18 and 19.

[3] Audio recording of the hearing at 14:39.

[4] [2010] FCA 399.

[5] Ibid at [28].

[6] Ibid at [26].

[7] Kaizen Hospitals (Essendon) Pty Ltd; Kaizen Hospitals (Malvern) Pty Ltd; Kaizen Hospitals (Mount District) Pty Ltd v Australian Nursing Federation[2012] FWAFB 8866.

[8] Ibid at [13].

[9] Audio recording of the hearing at 16:41.

[10] That could include themselves as a bargaining representative.

[11] The witnesses were not required for cross examination and their statements were accepted as evidence.

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[2025] FWC 2565

29 AUGUST 2025