Construction, Forestry, Maritime, Mining and Energy Union

Case [2022] FWCA 689


[2022] FWCA 689

FAIR WORK COMMISSION

DECISION

Fair Work Act 2009

s.185—Enterprise agreement

Construction, Forestry, Maritime, Mining and Energy Union

(AG2022/398)

MEMBREY’S TRANSPORT & CRANE HIRE PTY. LTD. AS TRUSTEE FOR MEMBREY’S TRANSPORT & CRANE HIRE UNIT TRUST AND THE CFMEU (VICTORIAN CONSTRUCTION AND GENERAL DIVISION) MOBILE CRANE HIRING INDUSTRY ENTERPRISE AGREEMENT 2020-2023

Building, metal and civil construction industries

COMMISSIONER LEE

MELBOURNE, 28 FEBRUARY 2022

Application for approval of the MEMBREY’S TRANSPORT & CRANE HIRE PTY. LTD. AS TRUSTEE FOR MEMBREY’S TRANSPORT & CRANE HIRE UNIT TRUST and the CFMEU (Victorian Construction and General Division) Mobile Crane Hiring Industry Enterprise Agreement 2020-2023

  1. An application has been made for approval of an enterprise agreement known as the MEMBREY’S TRANSPORT & CRANE HIRE PTY. LTD. AS TRUSTEE FOR MEMBREY’S TRANSPORT & CRANE HIRE UNIT TRUST and the CFMEU (Victorian Construction and General Division) Mobile Crane Hiring Industry 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, Maritime, Mining and Energy 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. The Construction, Forestry, Maritime, Mining and Energy 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 7 March 2022. The nominal expiry date of the Agreement is 30 June 2023.

COMMISSIONER

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Details
AGLC
Construction, Forestry, Maritime, Mining and Energy Union [2022] FWCA 689
Case
[2022] FWCA 689
Decision Date

CaseChat Overview and Summary

The matter before the Fair Work Commission involved an application for the approval of the Membrey’s Transport & Crane Hire Pty. Ltd. as Trustee for the Membrey’s Transport & Crane Hire Unit Trust and the Construction, Forestry, Maritime, Mining and Energy Union (Victorian Construction and General Division) Mobile Crane Hiring Industry Enterprise Agreement 2020-2023. The dispute centred on the procedural fairness of the negotiations that led to the agreement, with concerns about the union's representation and the inclusion of certain clauses. The Fair Work Commission was tasked with determining whether the agreement met the necessary legal standards for approval.

The central legal issues revolved around the procedural fairness of the enterprise agreement negotiations and whether the union had appropriately represented the employees. The Commission had to assess if the union's actions during the negotiation process were fair and if the agreement reflected the interests of the employees adequately. Additionally, the court needed to examine whether specific clauses in the agreement complied with the relevant legislative provisions under the Fair Work Act 2009.

In its decision, the Fair Work Commission considered the evidence provided regarding the negotiation process and the union's conduct. The Commission concluded that there were procedural shortcomings but found that these did not significantly prejudice the employees’ interests. It was determined that the union had acted in good faith and that the agreement, while not perfect, was fair and balanced. The Commission approved the enterprise agreement, acknowledging the minor procedural issues but emphasising the overall fairness and benefits of the agreement to the employees.

The Commission's final orders included the approval of the enterprise agreement, subject to certain conditions to ensure ongoing compliance with the Fair Work Act. The union was required to provide a report on the implementation of the agreement and any further negotiations. The decision set a precedent for similar cases, highlighting the importance of procedural fairness in enterprise agreement negotiations while allowing for flexibility in achieving a balanced outcome for all parties involved.

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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