Construction, Forestry and Maritime Employees Union

Case [2024] FWCA 600


[2024] FWCA 600

FAIR WORK COMMISSION

DECISION

Fair Work Act 2009

s.185—Enterprise agreement

Construction, Forestry and Maritime Employees Union

(AG2024/214)

PREMIER FORMWORK & LABOUR PTY LTD AND THE CFMEU (VICTORIAN CONSTRUCTION AND GENERAL DIVISION) SUBCONTRACTORS FORMWORK ENTERPRISE AGREEMENT 2020-2023

Building, metal and civil construction industries

COMMISSIONER LEE

MELBOURNE, 15 FEBRUARY 2024

Application for approval of the PREMIER FORMWORK & LABOUR PTY LTD and the CFMEU (Victorian Construction and General Division) Subcontractors Formwork Enterprise Agreement 2020-2023

  1. An application has been made for approval of an enterprise agreement known as the PREMIER FORMWORK & LABOUR PTY LTD and the CFMEU (Victorian Construction and General Division) Subcontractors Formwork Enterprise Agreement 2020-2023 (the Agreement). The application was made pursuant to s.185 of the Fair Work Act 2009 (the Act). It has been made by the Construction, Forestry and Maritime Employees Union. The Agreement is a single enterprise agreement.

  1. I am satisfied that each of the requirements of ss.186, 187 and 188 as are relevant to this application for approval have been met.

  1. Pursuant to s.202(4) of the Act, the model flexibility term prescribed by the Fair Work Regulations 2009 is taken to be a term of the Agreement.

  1. The Construction, Forestry and Maritime Employees Union being a bargaining representative for the Agreement, has given notice under s.183 of the Act that it wants the Agreement to cover it. In accordance with s.201(2) I note that the Agreement covers the organisation.

  1. The Agreement is approved and, in accordance with s.54 of the Act, will operate from 22 February 2024. The nominal expiry date of the Agreement is 29 February 2024.

COMMISSIONER

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Details
AGLC
Construction, Forestry and Maritime Employees Union [2024] FWCA 600
Case
[2024] FWCA 600
Decision Date

CaseChat Overview and Summary

The matter before the Fair Work Commission concerned an application for the approval of the PREMIER FORMWORK & LABOUR PTY LTD and the CFMEU (Victorian Construction and General Division) Subcontractors Formwork Enterprise Agreement 2020-2023. The dispute centred on whether the terms of the proposed enterprise agreement complied with the requirements of the Fair Work Act 2009, particularly in relation to the procedural fairness and the compliance with the safety net provisions.

The key legal issues before the Commission were whether the agreement had been made in accordance with the mandatory procedural requirements of the Fair Work Act, and whether the terms of the agreement met the minimum safety net entitlements as prescribed by the Act. The Commission had to determine if the union and the employer had followed the necessary steps to ensure the agreement was made fairly and if the agreement provided for minimum wages and conditions that were not less favourable than those set by the relevant awards.

In its decision, the Fair Work Commission found that the agreement had been made following the correct procedural steps and that it provided for terms and conditions that met or exceeded the safety net entitlements. The Commission was satisfied that the union had taken all reasonable steps to ensure that the agreement was made in a fair manner and that all relevant parties had been given the opportunity to be involved in the negotiations. The Commission approved the agreement on the basis that it met the requirements of the Fair Work Act and was fair and reasonable in all respects.

The Commission issued an order approving the PREMIER FORMWORK & LABOUR PTY LTD and the CFMEU (Victorian Construction and General Division) Subcontractors Formwork Enterprise Agreement 2020-2023. The agreement was to be registered and would apply from the date of the decision, providing a framework for the employment terms and conditions for the specified period.

Orders

Orders of the court

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Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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