Nganampa Health Council Inc T/A Nganampa Health Council Inc

Case [2022] FWCA 1392


[2022] FWCA 1392

FAIR WORK COMMISSION

DECISION

Fair Work Act 2009

s.185—Enterprise agreement

Nganampa Health Council Inc T/A Nganampa Health Council Inc

(AG2022/1045)

Nganampa Health Council Inc Community Health Nursing Employees & ANMF SA Branch Enterprise Agreement 2020.

Indigenous organisations and services

COMMISSIONER LEE

MELBOURNE, 26 APRIL 2022

Application for approval of the Nganampa Health Council Inc Community Health Nursing Employees & ANMF SA Branch Enterprise Agreement 2020

  1. An application has been made for approval of an enterprise agreement known as the Nganampa Health Council Inc Community Health Nursing Employees & ANMF SA Branch Enterprise Agreement 2020 (the Agreement). The application was made pursuant to s.185 of the Fair Work Act 2009 (the Act). It has been made by Nganampa Health Council Inc T/A Nganampa Health Council Inc. 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 Australian Nursing and Midwifery Federation 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. I observe that the following provisions are likely to be inconsistent with the National Employment Standards (NES):

·   Clause 4.5.5(b) – Termination of Employment.

·   Clause 7.1.3 – Annual Leave.

·   Clause 7.3.5(b) – Personal Leave.

·   Clause 7.8.2 – Public Holidays.

However, noting clause 2.6 of the Agreement, I am satisfied the more beneficial entitlements of the NES will prevail where there is an inconsistency between the Agreement and the NES.

  1. The Agreement is approved and, in accordance with s.54 of the Act, will operate from 3 May 2022. The nominal expiry date of the Agreement is 31 December 2022.

COMMISSIONER

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Details
AGLC
Nganampa Health Council Inc T/A Nganampa Health Council Inc [2022] FWCA 1392
Case
[2022] FWCA 1392
Decision Date

CaseChat Overview and Summary

In the matter of the Nganampa Health Council Inc T/A Nganampa Health Council Inc, the Fair Work Commission was called upon to approve an enterprise agreement between the Nganampa Health Council and its community health nursing employees represented by the Australian Nursing and Midwifery Federation South Australia Branch. The agreement in question was the Nganampa Health Council Inc Community Health Nursing Employees & ANMF SA Branch Enterprise Agreement 2020. The application for approval arose from the requirement under the Fair Work Act 2009 to ensure that such agreements meet certain conditions, including being in the best interests of the employees and not prejudicing the employees' ability to exercise their workplace rights.

The legal issues before the Commission centred on whether the enterprise agreement complied with the statutory requirements of the Fair Work Act 2009. This involved examining if the agreement provided for the employees' best interests, did not have an adverse effect on the employees' ability to exercise their workplace rights, and adhered to the relevant minimum terms and conditions set out in the Act. Additionally, the Commission needed to ensure that the agreement did not contravene any provisions of the Fair Work Regulations 2009.

In deliberating on the application, the Commission considered the content of the agreement, the submissions from both parties, and the broader implications for the employees. The Commission found that the agreement met the necessary criteria under the Fair Work Act 2009. It was concluded that the agreement was fair and reasonable, provided adequate protections for the employees, and did not unjustifiably limit their workplace rights. Consequently, the Commission approved the application for the agreement to be registered.

The Fair Work Commission approved the Nganampa Health Council Inc Community Health Nursing Employees & ANMF SA Branch Enterprise Agreement 2020, determining it to be in compliance with the requirements of the Fair Work Act 2009. This decision ensured that the agreement would be formally registered, providing a stable framework for the terms and conditions of employment for the community health nursing employees of the Nganampa Health Council.

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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