[2013] FWCFB 1943

Download Word Document

FAIR WORK COMMISSION

DECISION

Fair Work Act 2009
s.604—Appeal of decision

Steri-Flow Filtration Systems (Aust) Pty Ltd
v
Craig Erskine
(C2012/6681)

SENIOR DEPUTY PRESIDENT ACTON
DEPUTY PRESIDENT SMITH
COMMISSIONER ROE

 

MELBOURNE, 24 APRIL 2013

Appeal against decision [[2012] FWA 10248] and order [PR532022] of Senior Deputy President O’Callaghan at Adelaide on 10 December 2012 in matter number U2012/7362 - Small Business Fair Dismissal Code - belief at dismissal - reasonable grounds.

Introduction

[1] Steri-flow Filtration Systems (Aust) Pty Ltd (SFS) has appealed a decision 1 and order2 of Senior Deputy President O’Callaghan concerning an unfair dismissal remedy application made to Fair Work Australia (FWA) by Mr Craig Erskine. On 1 January 2013 FWA was renamed the Fair Work Commission (FWC).

[2] In the decision the Senior Deputy President concluded that he was not satisfied Mr Craig Erskine’s dismissal by SFS was consistent with the Small Business Fair Dismissal Code. His Honour also found that Mr Craig Erskine’s dismissal was harsh, unjust or unreasonable, that his dismissal was unfair and that he should be paid four weeks’ pay less taxation by SFS as compensation in lieu of reinstatement. The Senior Deputy President made an order to that effect.

Relevant background

[3] SFS designs industrial filtration and separation systems and manufactures its patented systems.

[4] SFS was registered as a company by Mr Gilbert Erskine, the father of Mr Craig Erskine, in 1989. Mr Gilbert Erskine was Managing Director of SFS until he resigned on 31 August 2011.

[5] Around 2000, SFS suffered a major loss and sought an investor. In 2005, the Rosen Group (RG) invested capital into SFS becoming a 25% shareholder and appointing a Mr Ian Fong as a Director of SFS. Mr Gilbert Erskine’s other company, LGE Pty Ltd (LGE), became a 75% shareholder in SFS and Mr Gilbert Erskine remained as Managing Director of SFS. Over time RG invested more capital into SFS. By 2008, RG was a 75% shareholder in SFS and LGE a 25% shareholder.

[6] Mr Craig Erskine was first employed by SFS on 4 September 2003 and remained employed by SFS until his dismissal on 13 April 2012.

[7] On 10 February 2009, Mr Gilbert Erskine set up and registered a company named Steri-flow Technologies Pty Ltd (SFT). Mr Craig Erskine was made the sole shareholder and director of SFT. However, it was Mr Gilbert Erskine who was “effectively in control of [SFT] from the time of its registration”. 3 At the time Mr Craig Erskine was an employee of SFS. Mr Gilbert Erskine became a director of SFT in December 2012, resulting in Mr Craig Erskine being the sole shareholder in SFT and he and Mr Gilbert Erskine being its two directors.

[8] In January 2011, Mr Paul Draper, the General Manager of SFT, asked Mr Gilbert Erskine for permission to use a mould owned by SFS to manufacture separator plates for a Queensland customer of SFT to use in filtering lemon oil. Mr Draper had previously been an employee of SFS. The mould was physically held by a manufacturing company called Gadac Plastics Pty Ltd (Gadac) in South Australia. At the time Mr Gilbert Erskine was not only the Managing Director of SFS but also “effectively in control of SFT”. Mr Gilbert Erskine, as Managing Director of SFS, authorised SFT to so use the mould of SFS. However, the SFS mould was not actually used by SFT to manufacture the separator plates until after Mr Gilbert Erskine resigned as Managing Director of SFS. On becoming aware that Mr Gilbert Erskine had resigned as Managing Director of SFS, Mr Draper did not consider it necessary to confirm that SFT still had the permission of SFS to use the mould for the manufacture of the separator plates.

[9] Mr Fong became Executive Director and Secretary of SFS on 1 September 2011.

[10] On 13 February 2012, Mr Fong sent an email to Mr Craig Erskine asking him for the name of the supplier in Adelaide who manufactured the plates for SFS as SFS needed the mould for the plates. On 14 February 2012, Mr Craig Erskine sent an email to Mr Fong advising him that boxes of spare plates and the mould were at a store in Malaysia. Mr Fong had this investigated and ascertained that the mould was not at the store in Malaysia. Mr Fong subsequently discovered the mould was at Gadac and that the mould had been used by SFT to manufacture separator plates in October 2011.

[11] On 13 March 2012, Mr Fong confronted Mr Craig Erskine about SFT using the mould of SFS to have the separator plates made for SFT. Mr Craig Erskine told Mr Fong he had no idea what Mr Fong was talking about.

[12] On 14 March 2012, Mr Fong sent a letter to Mr Craig Erskine as follows:

[13] The enclosed detailed note of the conversation between Mr Fong and Mr Craig Erskine was as follows:

[14] On 15 March 2012, Mr Fong sent a letter to SFT as follows:

[15] On 19 March 2012, Mr Craig Erskine sent an email to Mr Fong with a copy to Mr Gilbert Erskine which contained the following:

[16] Mr Gilbert Erskine also sent an email to Mr Fong on 19 March 2012 as follows:

[17] On 20 March 2012, Mr Fong responded to Mr Gilbert Erskine as follows:

[18] On 21 March 2012, SFT sent a letter to SFS as follows:

[19] On 22 March 2012, Mr Craig Erskine sent an email to Mr Fong and Mr Gilbert Erskine as follows:

[20] Mr Craig Erskine’s employment with SFS was terminated by a letter dated 13 April 2012. The letter was as follows:

Relevant law

[21] Section 385 of the Fair Work Act 2009 (Cth) (FW Act) provides that a person has been unfairly dismissed if the FWC is satisfied that:

[22] Section 387 of the FW Act concerns whether a dismissal was harsh, unjust or unreasonable and provides as follows:

[23] Section 388 of the FW Act concerns the Small Business Fair Dismissal Code (the Code) and provides as follows:

[24] The Code is as follows:

[25] The summary dismissal aspect of the Code was considered by a Full Bench of FWA in Pinawin T/A RoseVi.Hair.Face.Body v Domingo. 13 The Full Bench stated:

[26] Section 396 of the FW Act requires the FWC to decide whether a dismissal was consistent with the Code before considering the merits of an unfair dismissal remedy application.

Senior Deputy President’s decision

[27] In respect of whether SFS had complied with the Code in relation to Mr Craig Erskine’s dismissal, the Senior Deputy President said:

[28] The Senior Deputy President then turned to consider whether Mr Craig Erskine’s dismissal by SFS was harsh, unjust or unreasonable. The Senior Deputy President said:

Consideration of the grounds of appeal

[29] As we have indicated, the Code provides that it is fair for an employer to dismiss an employee without notice or warning when the employer believes on reasonable grounds that the employee’s conduct is sufficiently serious to justify immediate dismissal. In Pinawin a Full Bench of FWA held that this involves consideration of:

[30] SFS submits the Senior Deputy President erred in concluding that Mr Fong for SFS did not carry out a reasonable investigation into the matter. As a result, the Senior Deputy President erred in concluding that Mr Fong’s, and thereby SFS’s, belief at the time of the dismissal that Mr Craig Erskine’s conduct was sufficiently serious to justify his immediate dismissal could not be regarded as reasonable. Further, the Senior Deputy President’s failure to be satisfied the termination of Mr Craig Erskine’s employment was consistent with the Code was affected by error. SFS further submits that permission to appeal is warranted in the public interest because the Senior Deputy President’s error concerns the onus on small business in the application of the Code. Moreover, SFS maintains the Senior Deputy President’s error warrants the quashing of his Honour’s decision and order.

[31] Mr Craig Erskine opposes the granting of permission to appeal. He submits his Honour’s conclusion that Mr Fong did not carry out a reasonable investigation and his Honour’s finding that Mr Fong’s belief could not be regarded as reasonable in all the circumstances, as well as his Honour’s failure to be satisfied the dismissal was consistent with the Code, was amply justified on both the evidence and his Honour’s assessment of Mr Fong’s credibility.

[32] We turn to consider this ground of appeal.

[33] In our view the letter of termination dated 13 April 2012 from Mr Fong of SFS to Mr Craig Erskine provides the best evidence of Mr Fong’s belief at the time of Mr Craig Erskine’s dismissal and the grounds for that belief, as the letter is contemporaneous with the dismissal. It is apparent from that letter of termination that at the time of Mr Craig Erskine’s dismissal Mr Fong believed that Mr Craig Erskine had engaged in conduct amounting to serious and wilful misconduct warranting the summary termination of his employment. The grounds for that belief were that SFT had used property of SFS in October 2011 while Mr Craig Erskine was the sole owner and director of SFT and an employee of SFS. That the SFS property was used by SFT without the proper authority of SFS as its use was authorised by Mr Gilbert Erskine, the father of Mr Craig Erskine, who had a conflict of interest at the time. That he, Mr Fong, had been the sole executive director of SFS since 31 August 2011 and he had not been asked to and had not authorised the use of the SFS property by SFT. That SFT’s use of the SFS property was to the benefit of Mr Craig Erskine and the detriment of SFS. That Mr Craig Erskine had refused to admit his involvement in SFT when confronted by Mr Fong about it on 13 March 2012. And that, as a result, Mr Craig Erskine had breached his common law and statutory corporations law duties.

[34] Mr Fong’s belief amounted to a belief by SFS at the time of Mr Craig Erskine’s dismissal that Mr Craig Erskine’s conduct was sufficiently serious to justify immediate dismissal.

[35] The grounds for the belief of Mr Fong were directly supported by or reasonable inferences from the discussions and email exchanges between Mr Fong and Mr Craig Erskine, the email exchanges between Mr Fong and Mr Gilbert Erskine, and Mr Fong’s interactions with Gadac, as evidenced in the proceedings before the Senior Deputy President. For example, in regard to the property in question being the property of SFS, in his email of 19 March 2012 to Mr Fong, Mr Gilbert Erskine conceded he had put the patents to the SFS property in the name of SFS.

[36] Further, with respect to the conflict of interest, Mr Gilbert Erskine’s email of 19 March 2012 to Mr Fong revealed Mr Craig Erskine’s company, SFT, had asked Mr Craig Erskine’s father, Mr Gilbert Erskine, whether SFT could use SFS’s property and Mr Gilbert Erskine had alone authorised his son’s company to use the SFS property. SFT’s use of the SFS property confirmed that SFT’s business extended beyond the limits advised by Mr Craig Erskine in his email to Mr Fong of 19 March 2012. That email suggested that SFT was merely involved in purchasing equipment and engaging staff used by SFS. The advice in Mr Gilbert Erskine’s email to Mr Fong of 19 March 2012 that the SFS property was used in trials which if successful could have opened up a large market for SFS confirmed SFT’s business extended to at least part of the type of business engaged in by SFS and the SFS property was used by SFT in at least part of the type of business engaged in by SFS.

[37] In regard to the benefit and detriment to the respective parties, Mr Gilbert Erskine’s email of 19 March 2012 to Mr Fong confirmed that the SFS property was used by Mr Craig Erskine’s company and used in at least part of the type of business engaged in by SFS and there was no suggestion in any of the exchanges that SFS was compensated for SFT’s use of the SFS property.

[38] With respect to Mr Craig Erskine’s breach of his common law duties, in Concut Pty Ltd v Worrell, 16 Kirby J said:

[39] The grounds for Mr Fong’s belief at the time of Mr Craig Erskine’s dismissal that Mr Craig Erskine’s conduct was sufficiently serious to justify immediate dismissal included, in summary, that while an employee of SFS, Mr Craig Erskine was operating a company, SFT, of which he was the sole owner and director. During the time he was both an employee of SFS and the sole owner and director of SFT, SFT obtained from his father, Mr Gilbert Erskine, the Managing Director of SFS, authority to use SFS property, but did not seek to confirm that authority when his father resigned from SFS on 31 August 2011. In October 2011, while Mr Craig Erskine was still an employee of SFS and the sole owner and director of SFT, SFT used the SFS property to the detriment of SFS and to the benefit of Mr Craig Erskine, and Mr Craig Erskine was not honest with Mr Fong about the matter when confronted by Mr Fong about it in March 2012.

[40] The authority in Concut supports Mr Fong’s conclusion about Mr Craig Erskine’s conduct and the common law.

[41] Mr Fong’s belief, at the relevant time, that Mr Craig Erskine’s conduct was sufficiently serious to justify immediate dismissal was based on grounds directly supported by or reasonably inferential from the investigation he had conducted, including that he had conducted into the law. It is apparent from the letter of termination from Mr Fong to Mr Craig Erskine that Mr Fong understood that Mr Gilbert Erskine had authorised SFT’s use of the SFS property before he resigned from SFS. There is no sound basis for concluding that further investigation by Mr Fong would have revealed the grounds for his belief were mistaken. Mr Fong’s investigation was reasonable, resulting in reasonable grounds for his belief.

[42] With respect, in the circumstances it was not open to the Senior Deputy President to conclude Mr Fong did not carry out a reasonable investigation. The Senior Deputy President’s conclusion that Mr Fong did not carry out a reasonable investigation was critical to his Honour’s failure to be satisfied that the termination of Mr Craig Erskine’s employment was consistent with the Code. His Honour’s failure to be so satisfied was therefore affected by error. Given the nature and effect of the error made by the Senior Deputy President and the issues it has raised about the application of the Code, we consider it is in the public interest to grant permission to appeal. We do so. We will deal with Mr Craig Erskine’s unfair dismissal remedy application.

The unfair dismissal remedy application

[43] There was no dispute before his Honour or us, and we accept, that Mr Craig Erskine’s unfair dismissal remedy application was made within the requisite period, 17 that he was protected from dismissal,18 and that Mr Craig Erskine was dismissed.19 As to whether Mr Craig Erskine’s dismissal by SFS was consistent with the Code, immediately before the time of Mr Craig Erskine’s dismissal, SFS was a small business employer. Mr Craig Erskine’s dismissal was a dismissal without notice or warning. We have earlier indicated that at the time of Mr Craig Erskine’s dismissal, Mr Fong for SFS held a belief that Mr Craig Erskine’s conduct was sufficiently serious to justify his immediate dismissal and the grounds for that belief.20 We have also earlier indicated that the grounds for that belief were reasonable grounds, being directly supported by or reasonably inferential from the reasonable investigation Mr Fong for SFS had conducted, including that he had conducted into the law.21 Accordingly, we are satisfied that at the time of Mr Craig Erskine’s dismissal SFS believed on reasonable grounds that Mr Craig Erskine’s conduct was sufficiently serious to justify his immediate dismissal by SFS.

[44] We are, therefore, satisfied that SFS complied with the Code in relation to Mr Craig Erskine’s dismissal and his dismissal was consistent with the Code. Further, we are not satisfied Mr Craig Erskine’s dismissal was not consistent with the Code. Consequently, given the provisions of s.385 of the FW Act, Mr Craig Erskine was not unfairly dismissed.

Conclusion

[45] In this matter we have granted permission to appeal in the public interest. We have also found that Mr Craig Erskine’s dismissal by SFS was consistent with the Code and he was not unfairly dismissed. The granting of an unfair dismissal remedy is, amongst other things, dependent on an applicant having been unfairly dismissed. 22 As a result, we quash the Senior Deputy President’s decision and order concerning Mr Craig Erskine’s unfair dismissal remedy application and dismiss his application. An order23 giving effect to our decision is being issued at the same time as this decision.

SENIOR DEPUTY PRESIDENT

Appearances:

A Manos, of counsel, for Steri-Flow Filtration Systems (Aust) Pty Ltd.

R Harms, of counsel, for Mr Craig Erskine.

Hearing details:

2013.

Melbourne and Adelaide (video hearing):

March 1.

 1   Craig Erskine v Steri-Flow Filtration Systems (Aust) Pty Ltd, [2012] FWA 10248.

 2   Craig Erskine v Steri-Flow Filtration Systems (Aust) Pty Ltd, PR532022.

 3   Appeal book in C2012/6681 at p279.

 4   Appeal book in C2012/6681 at p361.

 5   Appeal book in C2012/6681 at pp362-364.

 6   Appeal book in C2012/6681 at p366.

 7   Appeal book in C2012/6681 at p369.

 8   Appeal book in C2012/6681 at pp390-394.

 9   Ibid.

 10   Appeal book in C2012/6681 at p381.

 11   Appeal book in C2012/6681 at pp383-384.

 12   Appeal book in C2012/6681 at pp397-398.

 13   [2012] FWAFB 1359.

 14   Craig Erskine v Steri-Flow Filtration Systems (Aust) Pty Ltd, [2012] FWA 10248.

 15   Ibid.

 16   (2000) 103 IR 160.

 17   Fair Work Act 2009 (Cth), ss.394 and 396.

 18   Fair Work Act 2009 (Cth), ss.389 and 396.

 19   Fair Work Act 2009 (Cth), s.385(a).

 20   Steri-Flow Filtration Systems (Aust) Pty Ltd v Craig Erskine, [2013] FWCFB 1943 at [33]-[34].

 21   Steri-Flow Filtration Systems (Aust) Pty Ltd v Craig Erskine, [2013] FWCFB 1943 at [35]-[41].

 22   Fair Work Act 2009 (Cth), s.390.

 23   Steri-Flow Filtration Systems (Aust) Pty Ltd v Craig Erskine, PR535579.

Printed by authority of the Commonwealth Government Printer

<Price code C, PR535262>