FEDERAL COURT OF AUSTRALIA
Wollermann v Fortrend Securities Pty Ltd (No 2) [2025] FCA 443
File number(s): VID 209 of 2024 Judgment of: O’CALLAGHAN J Date of judgment: 6 May 2025 Catchwords: INDUSTRIAL LAW – final orders – pecuniary penalties – contraventions of ss 323 and 536 of the Fair Work Act 2009 (Cth) (FW Act) – scope of serious contravention under s 557A of the FW Act – consideration of principles relating to imposition of pecuniary penalties – penalties imposed Legislation: Crimes Act 1914 (Cth) s 4AA
Fair Work Act 2009 (Cth) ss 323, 324, 536(1) and (2), 539(2), 546, 550, 557 and 557A
Trade Practices Act 1974 (Cth)
Long Service Leave Act 2018 (Vic)
Cases cited: Ahmed v Al-Hussain Pty Ltd t/as The Cheesecake Shop (No 3) [2019] FCA 848
Australian Building and Construction Commissioner v Pattinson (2022) 274 CLR 450
Australian Securities and Investments Commission v Wooldridge [2019] FCAFC 172
Construction, Forestry, Mining and Energy Union v Cahill [2010] FCAFC 39; (2010) 269 ALR 1
Fair Work Ombudsman v Australian Workers’ Union [2020] FCA 60
Fair Work Ombudsman v Foot & Thai Massage Pty Ltd (in liq) (No 8) [2024] FCA 483
Fair Work Ombudsman v Grouped Property Services Pty Ltd (No 2) [2017] FCA 557
Fair Work Ombudsman v Tac Pham Pty Ltd [2018] FCA 120
Fortrend Securities Pty Ltd v Wollermann (No 2) [2025] FCA 96
Kirwan v Fortrend Securities Pty Ltd [2019] FCCA 3119
National Tertiary Education Industry Union v University of Sydney (Relief) [2023] FCA 537
Trade Practices Commission v CSR Ltd [1990] FCA 521; (1991) ATPR ¶41-076
Division: Fair Work Division Registry: Victoria National Practice Area: Employment and Industrial Relations Number of paragraphs: 56 Date of last submission/s: 15 April 2025 Date of hearing: Determined on the papers Counsel for the Applicants: M Minucci Solicitor for the Applicants: Seyfarth Shaw Counsel for the Respondents: J Francis Solicitor for the Respondents: Cornwalls ORDERS
VID 209 of 2024 BETWEEN: CHRISTOPHER JAMES WOLLERMANN
First Applicant
STEPHEN MATTHEW LYLE
Second ApplicantAND: FORTREND SECURITIES PTY LTD
First RespondentJOSEPH BURKE FORSTER
Second Respondent
ORDER MADE BY:
O’CALLAGHAN J
DATE OF ORDER:
6 MAY 2025
THE COURT DECLARES THAT:
1.The first respondent contravened:
(a)s 323 of the Fair Work Act 2009 (Cth) (FW Act) by:
(i)failing to pay to the first applicant, in full and at least monthly, his commission on sales earned in May, June, July, August and October 2022 (Wollermann Bonus Payment Contravention);
(ii)failing to pay to the second applicant, in full and at least monthly, his commission on sales earned in May, June, July, August and October 2022 (Lyle Bonus Payment Contravention); and
(iii)deducting, from on or about 16 March 2015 until the cessation of the first applicant’s employment on 16 December 2022, $500 per month from the first applicant’s gross salary (Wollermann Deduction Contravention);
(b)s 536 of the FW Act by:
(i)failing…
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- Case
- [2025] FCA 443
- Decision Date
CaseChat Overview and Summary
The court found that the respondents had contravened the Act by withholding bonus payments from Mr Wollermann and Mr Lyle, unilaterally deducting amounts from Mr Wollermann's pay, and failing to provide pay slips to both employees. The court also found that Mr Forster was liable as an accessory for the Bonus Payment Contraventions and the Wollermann Deduction Contravention. The court considered the seriousness of the contraventions, the respondents' conduct, and the need to deter future breaches when determining the appropriate penalty. The court found that the penalties should reflect the gravity of the contraventions and the need to ensure compliance with the Act.
The court ordered that the respondents pay pecuniary penalties to the applicants for each contravention. The penalties were calculated based on the seriousness of the contraventions, the respondents' conduct, and the need to deter future breaches. The court also ordered that the respondents pay the applicants' unpaid commissions and long service leave entitlements, along with interest. The penalties imposed were intended to reflect the seriousness of the contraventions and to deter future breaches of the Act. The court emphasised the importance of compliance with the Act and the need to protect employees' rights.
Orders
Orders of the court
4. Pursuant to s 545 of the FW Act, within 28 days of the date of these orders, the first respondent is to pay to the first applicant the following sums:
(a) in respect of the Wollermann Bonus Payment Contravention, the sum of $66,313.58 comprised of the following:
(i) $55,396.80 in unpaid commission on sales; and
(ii) $10,916.78 in interest; and
(b) in respect of the Wollermann Deduction Contravention, the sum of $37,839.83 comprised of the following:
(i) $29,500 as compensation for the deductions made between 16 February 2018 and 16 December 2022; and
(ii) $8,339.83 in interest.
5. Pursuant to s 545 of the FW Act, within 28 days of the date of these orders, the first respondent is to pay to the second applicant, in respect of the Lyle Bonus Payment Contravention, the sum of $66,313.58 comprised of the following:
(a) $55,396.80 in unpaid commission on sales; and
(b) $10,916.78 in interest.
6. Pursuant to s 26 of the LSL Act, the first respondent is to pay to:
(a) the first applicant the sum of $149,667.02 comprised of the following:
(i) $122,954 in payment of the first applicant’s unpaid long service leave entitlement; and
(ii) $26,713.02 in interest; and
(b) the second applicant the sum of $120,083.37 comprised of the following:
(i) $98,650.53 in payment of the second applicant’s unpaid long service leave entitlement; and
(ii) $21,432.84 in interest.
7. Pursuant to s 546 of the FW Act, within 28 days of the date of these orders, the first respondent is to pay the following penalties to the first applicant:
(a) in respect of the Wollermann Bonus Payment Contravention, the amount of $13,320;
(b) in respect of the Wollermann Deduction Contravention, the amount of $133,200; and
(c) in respect of the Wollermann Pay Slip Contravention, the amount of $6,660.
8. Pursuant to s 546 of the FW Act, within 28 days of the date of these orders, the first respondent is to pay the following penalties to the second applicant:
(a) in respect of the Lyle Bonus Payment Contravention, the amount of $13,320; and
(b) in respect of the Lyle Pay Slip Contravention, the amount of $6,660.
9. Pursuant to s 546 of the FW Act, within 28 days of the date of these orders, the second respondent is to pay the following penalties to the first applicant:
(a) in respect of the Wollermann Bonus Payment Contravention, the amount of $2,664; and
(b) in respect of the Wollermann Deduction Contravention, the amount of $2,664.
10. Pursuant to s 546 of the FW Act, within 28 days of the date of these orders, the second respondent is to pay to the second applicant, in respect of the Lyle Bonus Payment Contravention, a penalty in the amount of $2,664.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011 (Cth).
Background
Background to the litigation
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Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
This relationship of “reasonableness” may be established by reference to the circumstances of the contravener as well as by the circumstances of the conduct involved in the contravention. See Pattinson at 472 [55]. CONSIDERATION OF PRELIMINARY ISSUESCourse of conduct Section 557 of the FW Act relevantly provides as follows:557 Course of conduct (1)For the purposes of this Part, 2 or more contraventions of a civil remedy provision referred to in subsection (2) are, subject to subsection (3), taken to constitute a single contravention if:(a)the contraventions are committed by the same person; and (b)the contraventions arose out of a course of conduct by the person. (2) The civil remedy provisions are the following:…(g) subsection 323(1) (which deals with methods and frequency of payment);…(o) subsections 536(1), (2) and (3) (which deal with employer obligations in relation to pay slips);… At [23]–[26] of its written penalty submissions dated 2 April 2025, the respondents submitted that, for the purposes of penalty, the court should treat both Bonus Payment Contraventions as constituting a single course of conduct and both Pay Slip Contraventions as constituting a separate, single course of conduct. Those submissions are misconceived for the reasons that follow. Dealing first with the Bonus Payments Contraventions, each of the Wollermann Bonus Payment Contravention and the Lyle Bonus Payment Contravention comprises the non-payment of commissions earned by an employee in May, June, July, August and October 2022. For each employee, each monthly non-payment of commission was sufficient to ground an individual contravention of s 323(1) of the FW Act. Fortrend committed each individual contravention against each employee, and those contraventions against that employee arose out of a course of conduct by Fortrend. Section 557(1) of the FW Act is therefore satisfied. It follows that the Wollermann Bonus Payment Contravention and the Lyle Bonus Payment Contravention should each be taken to constitute a single course of conduct — i.e. one in respect of Mr Wollermann and one in respect of Mr Lyle. However, it does not follow that those two courses of conduct — namely, the course of conduct which relates to the Wollermann Bonus Payment Contravention and that which relates to the Lyle Bonus Payment Contravention — should in turn be taken to constitute a single “Bonus Payment Contraventions” course of conduct. A critical feature of the contravening conduct was that it related to two distinct employees, and the penalties imposed on the respondents should reflect this fact. In any event, the single course of conduct principle is “a tool of analysis… which a court is not compelled to utilise”. See Construction, Forestry, Mining and Energy Union v Cahill[2010] FCAFC 39; (2010) 269 ALR 1 at 13 [41] (Middleton and Gordon JJ). “[E]ven if offences are properly characterised as arising from the one transaction or a single course of conduct, a judge is not obliged to apply concurrent terms if the resulting effective term fails to reflect the degree of criminality involved”. See Cahill at [42].