Physically Slapping a Client May Not Constitute an Act of Gross Misconduct

Before dismissing an employee for misconduct, an employer must be attentive to the circumstances which led the employee to commit the alleged offense, especially when the individual concerned has seniority and has never before been subject to any rebuke or criticism by his/her superiors.

In a recent case, the French Supreme Court (Cour de cassation) ruled that slapping a client does not automatically justify a dismissal for gross misconduct.

In this case, the misconduct was rejected on the grounds that the employee who served as cashier had acted in "self-defense" against an aggressive and threatening client. The employee concerned didn't get any help, despite calling for that; her supervisor attended the scene without intervening.  As a result, the dismissal has been judged illegal.

This entry was written by Jean-Benoît Cottin.

Termination of Collective Bargaining Agreement with "Infinity Clause"

Many collective bargaining agreements contain a clause whereby even when they are terminated they continue to bind until a new agreement is entered into ("infinity clause"). Such a clause may be argued invalid. A provision of the Labour Code which used to contain a similar regulation applicable to collective bargaining agreements was claimed unconstitutional and in consequence abrogated by the Constitutional Tribunal. If the infinity clause in the respective agreement was a mere repetition of the said abrogated provision of the Labour Code and was not the subject of conscious negotiations, it may be claimed invalid.

Implied Amendment of Terms and Conditions of Employment

An amendment to an employment agreement may be implied from the mutual actions of the employee and the employer (judgment of the Supreme Court of 14 January 2010; I PK 155/09). When the employer delegates the employee to another job, which is allowed for up to 3 months in a calendar year (art. 42 §3 of the Labour Code) and upon the employee's consent the delegation exceeds the statutory period, it is possible that the parties have concluded an implied permanent amendment to the employment agreement. In such a case, the employee can refuse to go back to the original position. To reinstate the employee in the original position, the employer must ask him to conclude another amendment which will revert the employment agreement to its original shape or serve the so-called "notice of alteration of terms and conditions of employment". Nonetheless, the intentions of both parties must be examined in each case.
Tags: Amendment

Ontario Court Certifies Class Action for Unpaid Overtime

In McCracken v. Canadian National Railway Company (pdf), the Ontario Superior Court of Justice has certified a class action proceeding by 1,550 current and former front-line supervisors against Canadian National Railway ("CN"). The lawsuit alleges that CN improperly classified front-line supervisors as managers thereby depriving them of overtime and holiday pay.

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Federal Government to Regulate Immigration Consultants

The federal government has introduced Bill C-35, An Act to amend the Immigration and Refugee Protection Act, to increase regulation and oversight of individuals working as immigration consultants. According to a federal government press release, the Bill is intended to prevent the exploitation of potential immigrants to Canada. If passed, the Bill would require all immigration consultants to register and be certified by a newly created regulatory agency. It would also make it an offence for anyone other than certified immigration consultants, lawyers, or notaries to provide immigration advice or representation for a fee.
Tags: Migration

Enhanced Employment Insurance Benefits End

Two temporary employment insurance enhancements, introduced by the federal government to provide increased benefits to unemployed workers and stimulate the economy during the recession, have ended. The first measure, contained in Bill C-10 (pdf), the Budget Implementation Act, S.C. 2009, c.2, increased the maximum duration of employment insurance benefits from 45 to 50 weeks in high unemployment regions. The second measure, contained in Bill C-50 (pdf), an Act to amend the Employment Insurance Act and to increase benefits, S.C. 2009, c.301, provided up to 20 additional weeks of benefits to long-tenured workers who had not previously collected employment insurance benefits. Both measures ended on September 11, 2010.

Severance Pay for Dismissed Board Member

A Member of the Management Board whose employment is terminated solely because of his dismissal from the Board is entitled to statutory severance pay. It follows from one of the recent judgments of the Supreme Court (of 2 February 2010; II PK 184/09). The termination of employment of a Board Member because of dismissal from the Board is considered dismissal for reasons "not related to the employee" within the meaning of the Law on Special Principles of Dismissing Employees for Reasons not Related to Employees. According to this law, every employee dismissed for such a reason is entitled to severance pay. Its amount depends on salary and seniority but is subject to a cap of the equivalent of approx. EUR  5,000. In an individual case, the assumption that the reason for termination of employment is "not related to the employee" may be challenged by proving that the dismissal itself was due to reasons related to the employee and in consequence employment was terminated for the same reason.

Legislative Update for the Week of September 20

Leg Roundup Image 132 by 140.jpgHouse Hearing Addresses Executive Compensation Oversight
The House Committee on Financial Services held a hearing on executive compensation oversight in light of new requirements imposed by the Dodd-Frank Wall Street Reform and Consumer Protection Act. Read the full post here. (September 24)

House Committee Holds Hearing on Bill Limiting Employment Credit Checks
The House Committee on Financial Services held a hearing on the Equal Employment for All Act, which would, with limited exceptions, make it unlawful to base adverse employment decisions upon consumer credit reports. Read the full post here. (September 24)

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Сriminal Cases are Initiated in Connection with Unjustified Refusal in Russia

According to Russian employment legislation, unjustified refusal may lead to criminal liability for the employer. The press centre of Investigation Committee of the Prosecution Office (SKP) of the Russian Federation informed, two criminal cases had been initiated in connection with unjustified refusal to hire pregnant women.

The Limited Liability Company "Nata" refused to hire candidates who applied for the vacant position of manager upon recommendation of the State Employment Centre. The motive for refusal was pregnancy of candidates. The cases were initiated in the Vologodskiy region in connection with material elements of offence stipulated by article 145 of the Criminal Code of the Russian Federation (unjustified refusal to hire).

Formal prosecution for such grounds is quite rare, so the cases are in the highlight of Russian media.

Conversion of Contract for Probation Period into Contract for Indefinite Period of Time

According to one of the recent judgments of the Supreme Court, it is possible to include a clause in a contract for probation period which states that when the probation period expires, the contract converts into an agreement for indefinite period (judgment of 4 November 2009; I PK 159/09). This solution is, however, not advisable. It may cause practical problems. For instance, if the outcome of the probation period is not satisfactory and the said provision is included in the contract, in order to terminate it after the probation period has expired it would be necessary to follow the procedure applicable to the termination of an agreement for indefinite period, including stating a justified reason for termination. It would not be possible to benefit from the "advantage" of the contract for probation period, that is, its automatic termination upon the lapse of the probation period. The said judgment does not address these problems sufficiently.

Legislative Update for the Week of September 13

Leg Roundup Image 132 by 140.jpgBill Would Target Independent Contractor Misclassification
The Fair Playing Field Act of 2010 would curtail the use of a federal "safe harbor" that allows businesses to treat workers as independent contractors for federal employment tax purposes, regardless of the employee's actual status under the common law test. Read the full post here. (September 16)

Obama Deems Chance of Employee Free Choice Act Passage Dim
President Obama acknowledged the political reality that the Employee Free Choice Act's prospect of passage this session is "not real high." Read the full post here. (September 15)

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Draft Guidance on Anti-Bribery Procedures Published

Bribery II.jpgThe UK's Ministry of Justice has published a consultation on draft guidance under the Bribery Act 2010. (For a summary of the Act, see our earlier note, New Bribery Act - Implications for Employers.) Specifically, the guidance concerns the procedures that commercial organisations will need to implement to rely on the statutory defence to a charge of failing to prevent bribery under the Act.

The consultation will close on November 8 2010. This will allow the final version of the guidance to be published early next year, in advance of the Act coming into force in April 2011.

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Legislative Update for the Week of September 6

Leg Roundup Image 132 by 140.jpgOSHA's National Advisory Committee to Address Injury and Illness Prevention Programs
OSHA's National Advisory Committee on Occupational Safety and Health will conduct a two-day meeting to discuss, among other initiatives, the agency's Injury and Illness Prevention Programs. Read the full post here. (September 9)

Image credit: slowgogo

Stricter Obligations Imposed by the French Supreme Court with Respect to Moral and Sexual Harassment Cases

In two recent decisions, the French Supreme Court established stricter obligations for employers when employees claim that they suffer from moral and sexual harassment.

It is important to outline that under French law employers must take all necessary measures in order to protect employees' physical and mental health.

In the above-mentioned decisions, two employees terminated their employment contracts on the grounds of constructive dismissal. In the first case, one employee blamed her manager for, in particular, instructing other employees not to talk to her and for not paying her remuneration. In the second case, one employee claimed that she was a victim of sexual harassment carried out by her manager.

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As Germany Considers Restrictions on Use of Social Media for Recruiting, Multi-National Employers Need to Start Thinking About Social Media Policy 2.0

A bill approved on August 25, 2010, by Germany's cabinet for introduction to the German Parliament would restrict employers' use of social media in the recruitment process. Many multi-national employers are still struggling to implement a policy governing the use of social media in their U.S. workplace. Before multi-national employers even complete that task, or catch their breath from doing so, they need to confront the question, as the German proposal suggests, whether the version 1.0 social media policy addressing only U.S. employees can be lawfully applied to non-U.S. employees. To learn more about the bill and its implications for employers, please continue reading at Littler's Workplace Privacy Counsel blog.

Legislative Update for the Week of August 30

Leg Roundup Image 132 by 140.jpgNLRB Approves Stationary Bannering as Lawful Tactic in Secondary Boycotts
The National Labor Relations Board concluded that bannering, when conducted peaceably and independent of other, possibly coercive, conduct, does not violate the National Labor Relations Act. Read the full post here. (September 3)

NLRB Finds New York Law Barring Use of State Funds for Union Campaigns Non-Intrusive
The National Labor Relations Board did not invalidate an election based on a state law it concluded was preempted by the National Labor Relations Act. Read the full post here. (September 3)

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Equality Act Implementation Confirmed

Diversity DisabilityII.jpgThe UK's Government Equalities Office (GEO) has clarified the implementation timetable for the Equality Act 2010, which harmonises, consolidates and reforms all of the UK's existing anti-discrimination legislation. (See our earlier note, Equality Act Becomes Law, for a summary of the Act's main provisions.)

As expected, the GEO has confirmed that most of the Act will come into force on 1 October 2010. However, there are some significant measures over which the Coalition Government is still deliberating. These include:

  •  The duty on public authorities to take into account 'socio-economic' inequality when making strategic decisions.
  • The 'dual discrimination' provisions, which would introduce a right to bring discrimination claims combining two protected characteristics.
  •  The requirement for employers with 250 or more employees to publish information on their gender pay gap.
  • The provisions allowing employers to take positive action, in recruitment and promotion, in favour of members of an under-represented group.
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Procedure for Family Reunification for Registered Partners has been Relaxed as of 30 July 2010

Married and registered partners of foreign workers, who accompany their partner to Belgium, can obtain a residence permit by following a procedure for family reunification. The procedure relates to situations in which case a non-EU citizen applies for a family reunification with his/her partner, another non-EU citizen with a limited right of residence.

Contrary to married partners, legally registered partners (who are not married) have to prove that they have a long-lasting and stable relationship as defined by Royal Decree.

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Flemish Government Eases System of Individual Professional Training

Very recently, the Flemish government modified the regulation on Individual Professional Training (IPT).

The IPT permits a company, in consultation with the "Vlaamse Dienst voor Arbeidsbemiddeling en Beroepsopleiding (VDAB)" (the public employment service of Flanders, comparable with the FOREm in Wallonia and Actiris in Brussels), to train and employ a job seeker during a certain period of time under favourable conditions. As long as the IPT runs, the employer only pays approximately one third of the usual labour cost.

The employer is, however, obliged to enter into a permanent contract with the trainee immediately after the training. 

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Tags: Training

Ontario Government Announces Phase 2 of Pension Reform

The Ontario government has released a backgrounder outlining proposed measures for Phase 2 of its pension reform agenda.  The proposed reforms would add another layer of restrictive rules on private sector defined benefit pension plans and introduce favourable rules for pension plans in the broader public sector.

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Enforcement Action by Federal Trade Commission Highlights Importance of Social Media Guidelines for Employees

Employees who post reviews of their employer's products and services on social media sites, without disclosing their corporate affiliation, can land their employer in an Federal Trade Commission (FTC) enforcement action. The FTC's second enforcement action for violation of the agency's endorsement guidelines, announced on August 26, makes this point. To learn more about the guidelines, enforcement actions and their implications for employers, please continue reading at Littler's Workplace Privacy Counsel blog.

Immigration Update for the Week of September 20

Imm Roundup Image 134 by 131.jpgUnited States: Failed Defense Spending Bill Thwarts DREAM Act
A Senate cloture motion fell four votes shy of the 60 required to advance a defense spending bill; Democrats intended to include the Development, Relief and Education for Alien Minors Act (DREAM Act) as an amendment to the bill. Read the full post here. (September 24)

United States: 2012 Diversity Visa Lottery Opens October 5, 2010
The State Department announced that from October 5, 2010, to November 3, 2010, individuals may register for the 2012 diversity visa lottery. Read the full post here. (September 24)

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Tags: Migration

European Court of Justice Reaffirms that Communications with In-House Counsel Are Not Privileged in Europe

On September 14, 2010, the European Court of Justice ("ECJ") reaffirmed its long-standing position that under European Union law communications with in-house lawyers in antitrust matters are not protected by the attorney-client privilege (or the legal professional privilege as it is known in the European Union). The court's ruling in Akzo provides an explicit caution to all HR professionals and lawyers. Before undertaking any sort of investigation and to avoid potentially devastating disclosure of privileged communications, they must carefully consider the application of the attorney-client privilege in the jurisdiction in question. In many instances, the only effective means of protecting information from disclosure is to involve outside counsel. To learn more about the decision and its implications for employers and in-house counsel, please continue reading Littler's ASAP The European Court of Justice Reaffirms that Communications with In-House Counsel Are Not Privileged in Europe by Nick Linn.

Upturn in Chinese Labor Dispute Filings Continues

The global financial crisis, additional statutory protections, and heightened awareness of workers' rights have contributed to a rise in labor dispute case filings in China, The New York Times reports. Specifically, 295,000 cases were filed in 2008 (an increase of 95% from 2007); 318,600 in 2009; and 207,400 in the first eight months of 2010. Moreover, a judicial interpretation recently issued by the Supreme People's Court--its third in the last two years--expands the types of labor-related claims that courts must hear, increasing the likelihood of yet another surge in filings. Legal scholars have suggested that filings would decrease if China permitted truly independent labor unions to operate, thereby providing an additional forum for resolving workers' grievances. 

 

Photo credit: Aluxum

Immigration Update for the Week of September 6

Imm Roundup Image 134 by 131.jpgUnited States: Questions Raised About Immigration-Related Employer Audits
The Houston Chronicle is questioning the efficacy of immigration-related employer audits after obtaining documents concerning 430 "closed" audits conducted by U.S. Immigration and Customs Enforcement. Read the full post here. (September 10)

United States: Changes to U.S. Visa Application Process in Canada
The U.S. Mission in Canada has announced changes to the U.S. visa application process in Canada. Read the full post here. (September 10)

United States: Immigration a Hot Topic in Governors' Races
Politico reports that candidates in 20 out of 37 of this year's gubernatorial races favor tough anti-immigration measures. Read the full post here. (September 9)

Image credit: CDH Design

Tags: Migration

Immigration Update for the Week of August 30

Imm Roundup Image 134 by 131.jpgUnited States: 2009 Yearbook of Immigration Statistics Released
The Department of Homeland Security's Office of Immigration Statistics released the 2009 Yearbook of Immigration Statistics, which provides statistical data on U.S. immigration. Read the full post here. (September 5)

United States: Senate Democrat Says Comprehensive Immigration Reform Not Likely in 2010
Senator Jeff Merkley's (D-OR) statement that he did not expect action on immigration reform this year exemplifies the on-again, off-again relationship that legislators have with immigration reform. Read the full post here. (September 5)

Image credit: CDH Design

Tags: Migration