Finance Sector Union of Australia v Fiserv Solutions of Australia Pty Ltd
[2011] FWA 2478
•4 AUGUST 2011
[2011] FWA 2478 |
|
DECISION |
Workplace Relations Act 1996
s.170LW - pre-reform Act - Application for settlement of dispute (certified agreement)
Finance Sector Union of Australia
v
Fiserv Solutions of Australia Pty Ltd
(C2010/4734)
SENIOR DEPUTY PRESIDENT DRAKE | SYDNEY, 4 AUGUST 2011 |
Scope of Dispute Procedure clause
[1] In October 2009 Fiserv Solutions of Australia Pty Ltd (Fiserv) announced the loss of 158 jobs nationally which included a number of job losses in Brisbane. This job loss was to occur in cheque processing, which work Fiserv had previously taken over from three major banks and a previous sub contractor of this work.
[2] Four members of the Finance Sector Union of Australia (FSU) were amongst many others retrenched by Fiserv in December 2009. These members were Mr Wahry who was retrenched on 4 December 2009, Ms Thompson who was retrenched on 4 December 2009, Ms Hall who was retrenched on 11 December 2009 and Mr Bachmann who was retrenched on 18 December 2009. These employees were all “NAB Heritage Employees” who transferred their employment from the National Australia Bank Limited (NAB) to Fiserv in early 2005.
[3] The FSU lodged a dispute notification on 26 August 2010 which it submitted was lodged on behalf of these four members from Brisbane.
[4] Mr Peddie, Industrial Officer from the Finance Sector of Australia (the FSU) appeared for the notifier and Mr Brown, solicitor, of Baker Mackenzie Solicitors in Sydney appeared for Fiserv.
[5] The Disputes Procedure, clause 19 of the 2005-2008 Agreement, is set out below. There is no clause 19.3. This appears to be a numbering error.
“19. Disputes Procedure
19.1 How you and the Company will resolve disputes
19.1 The objective of this clause is to achieve the timely resolution of disputes at the workplace, where possible, through direct discussions between You and Fiserv management.
19.2 In the event of a dispute arising under this Agreement, the following procedure will be observed:
(i) As soon as practicable after a grievance of dispute arises, the employee concerned will take the matter up with the (sic) your immediate supervisor, affording them the opportunity to remedy the cause of the dispute or claim.
(ii) Where any such attempt at settlement has failed, or where the dispute or claim is of such a nature that direct discussions between the employee and their immediate supervisor would be inappropriate, the matter shall be taken up with the HR Manager, who will pursue the matter after being satisfied as to the substance of the claim.
(iii) If the matter is not resolved after discussion with the HR Manager, it will be referred to the Business Unit President for resolution.
(iv) If the matter is not settled it may be submitted by the employee or Fiserv to the Australian Industrial Relations Commission which will endeavour to resolve the issue between the parties by conciliation or arbitration. In making its determination the AIRC will be required to determine the dispute in a manner consistent with the terms of this Agreement.
19.4 Without prejudice to either party, work will continue under previous arrangements while the matters in dispute are being dealt with in accordance with this clause.
19.5 Notwithstanding the above, an employee may contact the Union or another representative of their choice for assistance/guidance during any stage of the dispute settlement procedure.
19.6 It is not intended that any of the above procedures will restrict either of the parties to refer the matter to the Australian Industrial Relations Commission for determination at any stage.”
(my emphasis)
[6] Clause 3 of the 2005-2008 Agreement is set out below:
“3. Relationship of Agreement to Award
3.1 This Agreement will be read and interpreted wholly in conjunction with the Fiserv Solutions of Australia Award 2005 provided that where there is any inconsistency between this Agreement and the Award, this Agreement will prevail to the extent of the inconsistency.
3.2 This Agreement will also be read and interpreted wholly in conjunction with your ‘offer of employment’ letter provided to You by Fiserv. Where there is any inconsistency between this Agreement and your ‘offer of employment’ letter this Agreement shall not apply to those areas of your employment where your ‘offer of employment’ letter is more generous.
3.3 Taken together, this Agreement and your ‘offer of employment’ letter comprehensively deal with your terms and conditions of employment.”
(my emphasis)
[7] Although the FSU is bound by the 2005-2008 Agreement, it is not a party to it. Fiserv therefore submitted that the FSU had no standing to make this application. Fiserv also submitted that, as the dispute could only be lodged by individual employees, and as it had not been lodged by those employees prior to termination of their employment, the dispute notification therefore could not now be heard by Fair Work Australia (FWA).
[8] The FSU did not submit that it had standing to lodge the notification on its own behalf. It submitted that the dispute was lodged by it as the representative of its members, not as a direct party. It also submitted that it commenced the Dispute Process pursuant to clause 19 of the 2005-2008 Agreement on behalf of its members, prior to termination of their employment and was therefore entitled to lodge the dispute before FWA.
[9] In support of this submission, the FSU relied on a Full Bench decision of the Australian Industrial Relations Commission, ING Administration Pty Limited v Jajoo 1 (ING). Fiserv sought to distinguish the circumstances of this application from those in ING.
[10] Mr Travis O’Brien is an organiser from the FSU based in Queensland. He provided a statement 2 regarding his meetings with and instructions from FSU members employed by Fiserv at Kangaroo Point in Brisbane during 2009.
“1. During 2009 I was the Finance Sector Union Organiser responsible for FSU members at Fiserv Kangaroo Point (Brisbane) workplace.
2. The employees at this workplace process various bank vouchers/cheques on behalf of CBA NAB and Westpac. Similar work is performed at other Fiserv workplaces in other mainland State capital cities. Many of these employees had previously performed this work as direct employees of these various banks, until this work was outsourced to Fiserv in early 2005.
3. Late on 22 October 2009, I received an email message from FSU National Director Chris Gambian, which advised that Fiserv would reduce the number of voucher processing jobs by 158 nationally, and 36 in Brisbane. A copy of this is attached as ‘Annexure A’.
4. On 23 October 2009, I was advised by a Fiserv member that the company had released a ‘business update’ announcement to all employees, advising of national redundancies and retrenchments to occur through to December 2009.
5. To discuss the implications of the redundancies announced by Fiserv, I visited Fiserv Kangaroo Point on the evening of 28 October 2009. I advised FSU members at this location by e-mail and attached flyer of this visit. A copy of this is attached as ‘Annexure B’.
6. During this visit I spoke with FSU members, including Darryl Bachmann and Cheryl Thompson who had worked for National Australia Bank immediately prior to their employment by Fiserv. In discussion with Darryl Bachmann and Cheryl Thompson, they said that they were concerned that their final payments may not reflect their shift loading which they had received regularly from 2005 during their Fiserv employment period. They had heard that Fiserv had not included shift loadings in the payments to ‘NAB heritage’ employees retrenched in Melbourne. They also said that they had not yet received any advice from Fiserv as to the amount of their retrenchment payments. They indicated to me that they wanted FSU to pursue these concerns on their behalf.
7. I advised Darryl and Cheryl that FSU would continue to pursue their redundancy and payment concerns with Fiserv, and that I would provide further information to them about this in due course. I subsequently advised Daney Faddoul at FSU Sydney Office of these details, and he advised that they would be raised with Fiserv, along with other issues relating to redundancy and retrenchment.
8. Daney Faddoul subsequently advised me that two letters had been sent to Fiserv on 11 November and 24 November 2009, relating to shift loadings in retrenchment payments for employees with ‘NAB heritage’, and in relation to the provision of final payment amounts to all employees who would soon be retrenched.
9. I visited Fiserv, Kangaroo Point again on the evening of 26 November 2009. During this visit I spoke with several FSU members, including Ross Wahry and Cheryl Thompson, who had both previously worked for NAB. During discussion with Ross, he indicated to me that he wanted FSU to pursue any unpaid retrenchment entitlements on his behalf, particularly if he was not paid for shift loading which he had received regularly from 2005 during his Fiserv employment period.
10. In these discussions with Darryl, Cheryl and Ross, they told me that if they had been retrenched by National Australia Bank, their final payments would include their shift loading. They expressed their view that their Fiserv employment conditions also provided for retrenchment payments as paid by NAB to continue to apply to them.
11. Ross Wahry was retrenched as at close of business on 4 December 2009, followed by Wendy Hall on 11 December 2009, and Darryl Bachmann and Cheryl Thompson on 18 December 2009. They advised me that no shift loadings were included in their retrenchment payments.”
(my emphasis)
[11] Mr Daney Faddoul is the National Industrial Officer of the FSU. He provided a statement 3 regarding his negotiations with Fiserv concerning the retrenchment payments to NAB Heritage Employees.
“1. I commenced employment as a National Industrial officer with the Finance Sector Union of Australia (FSU) on 16 November 2009.
2. Included in my area of responsibility is Fiserv Solutions of Australia (Fiserv), where a number of FSU members are employed.
3. On 17 November 2009, I attended a meeting with Fiserv representatives Alan Priestley, Anna Warne and Sharni Redenbach, regarding Fiserv’s intention to reduce its document processing staff numbers by 158 positions nationally by end 2009. Also attending the meeting was Chris Gambian, Alexia Cunningham and Don Peddie from FSU. The meeting took place at the FSU offices in Sydney. Following requests from members in several States including Queensland, FSU raised the issue of shift loadings in redundancy payments for employees with NAB heritage, but Fiserv did not accept that such loadings should be included in final payments. My notes from the meeting are attached as ‘Annexure A’.
4. On 19 November 2009 I emailed my notes from the meeting to FSU employees nationwide who have local responsibility for Fiserv with the intention of that information being passed on to FSU members to keep them updated on the progress of the redundancy issue. One person to whom I sent this email was Travis O’Brien, Lead Organiser with the FSU Queensland Branch with responsibility for supporting Brisbane based Fiserv members.
5. On 24 November 2009 I received an email reply from Travis O’Brien, which stated as follows:
‘I’m getting a lot of calls from members in Qld about not getting their calculations too.
People are worried, and angry.
A copy of this email is attached as “Annexure B.”’
------
12. During the process of meetings and correspondence with Fiserv about this matter, FSU indicated that it was making representations on behalf of members and raising issues of concern to them. Fiserv recognized the FSU as the representative of the members at all times during the progress of this dispute, as evident by the extent of Fiserv’s correspondence to and meetings with FSU on behalf of its members.”
(my emphasis)
[12] Mr Faddoul set out the history of his correspondence with Fiserv and attached his notes of meetings and copies of relevant correspondence to his statement. 4
[13] The FSU also provided a Chronology of Events 5 with twenty-one attached documents setting out the history of its officers’ and members’ interactions with Fiserv regarding the proposed retrenchment of its employees and the quantum of severance payments due to them.
[14] In cross-examination Mr O’Brien gave evidence that he had conversations with a number of members of his organisation in Brisbane. Mr Bachmann, Ms Thomas and Mr Wahry were the particular members concerning whom Mr O’Brien made written notes regarding his contact with them. His evidence was that he did not specifically mention any meetings with Ms Hall because he had no specific note and also, because of the time between the meetings and the preparation of his statement, he did not want to speculate. His evidence in relation to Ms Hall was as follows:
“MR BROWN:------The proposition I’m advancing is that you, in fact, had no discussions with Wendy Hall prior to the termination of her employment in relation to any concern that she personally had in relation to the non inclusion of shift loadings in her retrenchment payments. That’s the proposition I’m putting to you. That’s correct, isn’t it?---MR O’BRIEN: My recollection is I had conversations with a number of members, one of them may have been Wendy Hall. It is possible that I didn’t have a conversation with Wendy before her retrenchment date.” 6
[15] I am satisfied that on 28 October 2009 Mr O’Brien received instructions for the FSU to act on behalf of Daryl Bachmann and Cheryl Thompson in relation to a possible redundancy and in relation to the amount of any consequent redundancy payment due to them. 7
[16] I am satisfied that on 26 November 2009 Mr O’Brien received instructions for the FSU to act on behalf of Ross Wahry in relation to a possible redundancy and the amount of any consequent redundancy payment due to him. 8 I am also satisfied that on this occasion Cheryl Thompson confirmed her previous instructions.
[17] There is no persuasive evidence that Ms Wendy Hall provided Mr O’Brien with any instructions to act for her in a similar capacity.
[18] I find that the FSU lodged this notification as the representative of Daryl Bachmann, Cheryl Thompson and Ross Wahry.
[19] I accept the evidence of Mr O’Brien and Mr Faddoul regarding their involvement in the dispute process with Fiserv prior to the termination of the three relevant members.
[20] Mr O’Brien contacted Mr Faddoul after his meeting with members on 28 October 2009 because he was instructed to pursue their concerns. Mr Faddoul had become aware of the general concerns of FSU members immediately upon his commencing employment with the FSU. Mr O’Brien advised Mr Faddoul of his local members’ concerns regarding the quantum of any possible retrenchment payment. Mr Faddoul corresponded with Fiserv 9 on behalf of affected members.
[21] I have concluded that in forwarding correspondence on 11 November 2009 and 24 November 2009 as well as hosting a meeting on 24 November 2009 with senior Fiserv representatives, and in negotiating with Fiserv as set out in the Chronology of Events, the FSU was engaging in the Dispute Process of the 2005-2008 Agreement as the representative of the FSU’s membership employed by Fiserv.
[22] The FSU notified and dealt with Fiserv at a senior level in relation to this dispute, both in conference and in correspondence with Mr Priestley, Vice President, Human Resources, prior to the termination of the three relevant employees in compliance with the dispute procedure of the 2005-2008 Agreement. Mr Priestley is the appropriate Business Unit Manager. I am satisfied that the FSU notified Fiserv of its members dispute with Fiserv regarding the quantum of redundancy payments due to them should they be retrenched, and its representation of those members, and that that notification of the dispute was made prior to the retrenchment of the three relevant members. I am not persuaded that the circumstances of this case can be relevantly distinguished from ING as argued by Fiserv, although it would have been preferable for all concerned if the notification had been made earlier. Applying ING it follows that the dispute process can continue and, if appropriate, be heard by FWA. 10
[23] Mr Brown questioned Mr O’Brien and Mr Faddoul concerning their understanding of the merits of the application. I raised the relevance of the particular understanding of these witnesses with Mr Brown on more than one occasion. 11 Despite this Mr Brown persisted. Nothing that emerged from his questioning the witnesses eliminated my doubts. The matters about which Mr Brown pressed Mr O’Brien and Mr Faddoul remain matters to be determined by me and Mr O’Brien and Mr Faddoul’s understanding was then, and is now, of little assistance to me.
[24] Whilst employed by the National Australia Bank the relevant employees were paid in accordance with the National Australia Bank Limited Enterprise Agreement 2002, the National Australia Bank Limited Redundancy, Redeployment and Retrenchment Agreement 2002 (the 2002 NAB RRR Agreement), and the National Australia Bank Limited Redundancy, Redeployment and Retrenchment Agreement 2005 (the 2005 NAB RRR Agreement).
[25] The FSU provided detailed submissions, 12 which I will not repeat here, concerning how those arrangements operated. These submissions are in accordance with my own understanding as to the operation of those instruments and the basis on which the NAB calculated severance payments due to retrenched employees. I am satisfied that the NAB included shift allowances and penalties in the week salary that was used to calculate severance pay.
[26] The calculation of severance pay for each NAB Heritage Employee who was retrenched by Fiserv was made on the basis of a certain number of “weeks salary” for their combined period of service with NAB and Fiserv without any consideration of shift allowances and penalties.
[27] Before the employment of the relevant NAB employees was transferred to Fiserv they were made an offer of employment (the Fiserv letter of offer). Each employee, the subject of this application, was made the same offer. Its terms included the following clauses:
“------
Your terms and conditions of employment are set out in this letter of offer, which is intended to create a binding contract of employment between you and Fiserv.
It is anticipated that your terms and conditions will be underpinned by the Fiserv Certified Agreement 2005-2008, as detailed at clause 18 of this offer letter.
If there are terms and conditions of employment which you are currently entitled to and presently receive under your bank award and enterprise agreement as at 4 March 2005 that are not reflected in this offer letter or the Fiserv Certified Agreement 2005, those terms and conditions will, if applicable and able to be applied in the circumstances of Fiserv’s business, continue to apply to you as a condition of your employment contract ------
------
13. Redundancy Pay and Notice
Severance Pay
If you become entitled to severance pay during the course of your employment with Fiserv, you will receive severance pay in accordance with the severance pay provisions contained in the National’s Redundancy Redeployment and Retrenchment Agreement 2002 for your equivalent grade at Fiserv.
------
18. Relationship with Future Certified Agreement
It is anticipated that your terms and conditions of employment will be underpinned by the Fiserv Certified Agreement 2005-2008. It will not form part of this contract.
Subject to paragraph 5 of this offer letter where there is any inconsistency between the Fiserv Certified Agreement 2005 and this offer letter the more generous provision will apply to the extent of the inconsistency.
The law governing the terms of this offer will be the law of the State or Territory where you work. Any other matters, such as workplace grievances, will be dealt with in accordance with the future Fiserv Agreement. ” 13
(my emphasis)
[28] Fiserv’s further submission is that this dispute is not and cannot be a dispute arising from the application of the 2005-2008 Agreement. Mr Brown submitted that if the FSU wants for its members what he called “the high water mark” in severance entitlements, which are the severance entitlements committed to in Fiserv’s 2005 letter of offer made to NAB employees before they came across to Fiserv, then that entitlement cannot arise from the application of the 2005-2008 Agreement. Fiserv only wants to pay, and has only paid, “the low water mark” in severance entitlements which are the severance entitlements calculated in accordance with clause 18 of the 2005-2008 Agreement. Mr Brown submitted that a dispute about whether the high water mark or the low water mark is payable to these employees cannot be a dispute that arises from the application of the 2005-2008 Agreement because the high water mark severance entitlements do not arise under the 2005-2008 Agreement.
[29] This is a clever argument but not a persuasive one.
[30] I will firstly deal with some distracting evidentiary material provided by Fiserv. Mr Priestley gave evidence that the annual salary contained in the offer of employment made by Fiserv was based on the Total Remuneration Package (TRP) paid by NAB to the relevant employees and that whilst employed by Fiserv shift loadings and penalty rates were continued to be paid to employees in addition to their annual salary, in the same manner that NAB had paid shift loadings and penalty rates in addition to the TRP.
[31] I do not understand the relevance of Mr Priestley’s evidence that “......the NAB 2002 Agreement provided that termination benefits (eg Long Service Leave, Severance Pay) and superannuation are paid on TRP, and not simply on the cash component of employees’ salary payments alone.” 14 This fact is not in dispute. It is clear that the TRP at NAB was used by Fiserv to identify annual salary. The TRP included superannuation contributions, car leases and other personal arrangements for the distribution of remuneration. It was not only the cash component of the TRP that was considered for these purposes.
[32] This proposition does not support the particular conclusion that Mr Priestly advocates, that is, that allowances and shift penalties were not included in the calculation of a weeks salary for the purpose of severance pay. They are two different questions. Nor do I consider it relevant that the NAB method of calculating severance pay was not raised by the NAB or the FSU at the time of the transfer of employment. There was no reason or obligation for either organisation to raise the issue with Fiserv. It was Fiserv’s obligation to make enquiries.
[33] I am not persuaded that the fact that employees at NAB had a TRP and could package their benefits as they wished is relevant to this application. The TRP was simply the figure Fiserv adopted as the base annual salary which constituted the offer made to NAB employees by Fiserv. Shift loadings and penalty rates were paid in addition to the TRP at NAB and to the annual salary at Fiserv.
[34] As I have already indicated I am satisfied that severance pay at NAB was calculated to include allowances.
[35] Mr Brown summarised his submission as follows:
“------our submission would be you could only determine the matter in a manner consistent with the terms of this agreement. Now, we are all at one on one point, that if this matter were to be determined with reference to the certified agreement and the certified agreement alone it would result in an outcome which has already been given to these people at the very least, and that is that their redundancy or severance benefits would be determined with reference to clause 18.1.6 which speaks of how one calculates the severance payments, which then cascades into the definition of “ordinary rate” which is clause 2, which states that one does not include the loadings with penalties, and read together with clause 18.3 you get the result that these people received.
So drawing that submission together, if you were to find against all of those other arguments that you had the power to deal with it the agreement itself states that you must determine that matter consistent with the terms of this agreement and the parties are all at one on the issue that if you were to do that these individuals, the four individuals, got what they were entitled to. My friend takes you off to another area and says, “Have a look at these other documents and come to some different conclusion.” Now, that may take you off into some other remedies, some other jurisdictions, possibly, particularly with respect to this notion of what constitutes the contract. I think you will find that in Jajoo v ING the existence of other remedies certainly isn’t determinative of the issue, but you only have to concern yourself with one thing and one thing only, we would submit, and that is has this particular application been brought before you in a way which is consistent with both the act and consistent with the terms of the agreement.
We say for all of the jurisdictional issues that we’ve raised, no, no on the issue of parties, no on the issue of invocation of the disputes procedure whilst employed.
Then, finally, we say, if we’re wrong on all of that, if one tries to then apply the agreement as you would have yourself do, that you can only get the result which is what the individuals received. You were good enough to take into evidence the written submissions. My friend didn’t go back and touch onto his in detail so I won’t. If I could just for one moment, your Honour, just check my notes to see whether I’ve missed anything in particular.
Just touching upon - the letters of offer are what they are. There was some cross-examination on them and what we would say in relation to the letters of offer is that they do envisage this dichotomy of rights and entitlements or benefits, whatever word you want to choose. That may be a question of construction of those documents, but where the rubber hits the road in terms of this application it really all comes back to clause 3.2 of the agreement that deals with the issue. It specifically notes that there are these two moving parts. If the moving parts have an inconsistency, which is accepted by the party, the agreement does not apply, and for that reason we say that if you attempted to deal with the matter in that regard you are faced with a situation where it simply can’t be resolved in the context of the certified agreement. In reference to the letter of offer, it is not a dispute about the application of the terms of the agreement. In that case we would rely upon CEPU v Telstra Corporation (2003) 128 IR, ABC v Media Entertainment Alliance, 144 IR.” 15
[36] The terms and conditions of employment of the relevant employees are cascading entitlements as described in clause 3.2 of the 2005-2008 Agreement. The 2005-2008 Agreement encompasses the terms and conditions of Fiserv employees in conjunction with the Fiserv Solutions of Australia 2005 Award (the 2005 Award) and the Fiserv letter of offer. The terms of the letter of offer are acknowledged as the overriding conditions of employment of employees of NAB Heritage Employees by clause 3.2 of the 2005-2008 Agreement. The 2005-2008 Agreement is to be read wholly in conjunction with the letter of offer.
[37] In having regard to the letter of offer Fair Work Australia is not having regard to matters outside the 2005-2008 Agreement, but is having regard to matters referred to in the 2005-2008 Agreement as part of the entitlements/conditions of NAB Heritage Employees whose employment is subject to the same core operational clauses of the 2005-2008 Agreement in the same way that entitlements/conditions of employees who are not NAB Heritage Employees are subject to the same core operational clauses of the 2005-2008 Agreement.
[38] Clause 19 Disputes Procedure is a core operational clause of the 2005-2008 Agreement. It sets out the process for dealing with disputes concerning the application of the 2005-2008 Agreement. This dispute is a dispute concerning the calculation of entitlements on severance which can be properly lodged with FWA. The answer to the dispute notification is that Fiserv’s NAB Heritage Employees’ entitlements on retrenchment are not the low water mark in severance pay arising from clause 18 of the 2005-2008 Agreement. Their entitlement is the high water mark in entitlements set out in the Fiserv letter of offer and these employees’ severance pay should have been calculated by Fiserv to include allowances.
[39] The terms offered in the 2005 letter of offer to these employees in relation to severance pay were the NAB terms, and the NAB terms on retrenchment included payment at a rate which included payment of allowances. That is the deal that was done on transfer and that is what these NAB Heritage Employees were entitled to be paid on retrenchment.
[40] If I am wrong in concluding that the operation of clause 19 Dispute Process includes a dispute about the application of the terms in the Fiserv letter of offer, then what FWA can certainly do, even on the basis of Fiserv’s submission, is decide if the 2005-2008 severance entitlement, the low water mark which Fiserv used to calculate these members’ entitlements, applies or not. In my opinion it does not.
SENIOR DEPUTY PRESIDENT
1 PR974301 - Watson VP, Acton SDP, Cargill C - 4 December 2006 (ING)
2 Exhibit FSU 1
3 Exhibit FSU 2
4 Exhibit FSU 2 para 6-11 inclusive
5 Exhibit FSU10
6 Transcript PN102
7 Exhibit FSU 1 page 6
8 Exhibit FSU 1 page 6
9 Exhibit FSU 1 para 7 - 8
10 ING
11 Transcript PN67 - PN75, PN 132 to 156, PN 240 to 252
12 Exhibit FSU 8 para 13 - 21 inclusive
13 Exhibit FSU 5
14 Exhibit Fiserv 1 para 15
15 Transcript PN1145-1148
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