A Named Female Employee (Represented by Donal Taaffe & Co., Solicitors) V A Named Respondent (Represented by VP McMullin, Solicitors)
1. DISPUTE
1.1 This dispute concerns a claim by a named female complainant that she was discriminated against by a named organisation of which she is an employee in terms of Sections 6(1) and 6(2)(a) of the Employment Equality Act, 1998 and in contravention of Section 8 of that Act when she was subjected to harassment and sexual harassment. She also claims that she was victimised in terms of Section 74(2) of the Act.
2. BACKGROUND
2.1 The complainant was employed by the respondent organisation as an ambulance nurse. She alleges that she was subjected to both harassment and sexual harassment by male members of staff. The complainant also alleges that she was victimised by the respondent. The respondent denies the allegations.
2.2 The complainant was dissatisfied with the manner in which her allegations were being handled by the respondent. Consequently she referred a complaint to the Director of Equality Investigations on 7th January, 2002 under the Employment Equality Act, 1998. In accordance with her powers under Section 75 of that Act the Director then delegated the case to Gerardine Coyle, Equality Officer on 17th May, 2002 for investigation, hearing and decision and for the exercise of other relevant functions of the Director under Part VII of the Act. Submissions were received from both parties and a joint hearing took place on 9th September, 2002. Additional information was received from both parties and the final information was received on 9th December, 2002.
3. SUMMARY OF THE COMPLAINANT'S SUBMISSION
3.1 The complainant is employed as a ambulance nurse by the respondent. She alleges that she was severely sexually harassed by male members of the Ambulance Personnel and on one occasion was bullied by a member of the Ambulance Personnel. The complainant lodged a complaint with the respondent by letter sent towards the end of September, 2001. Her allegations are as follows:
9th June, 2001:
The complainant was in Dublin with Mr. A and Mr. B. On the complainant's return home she noted a personal envelope had been defaced with comments of a sexual nature. The complainant says that she approached Mr. B regarding this matter. He initially denied it but when the complainant asked him about it the following week he accepted responsibility.
28th June, 2001:
The complainant says that in St. James Hospital in Dublin a Mr. C of the ambulance personnel made a comment about her dress indicating that she wore nothing but trousers.
13th July, 2001:
According to the complainant Mr. C again approached her saying that he thought this matter was done and finished. It is the complainant's contention that he said that he did not want people asking him what he had done to the complainant. The complainant says that she told him to stop bullying her and that she would decide when this matter would be finished.
7th August, 2001:
En route to another Hospital with Mr. D and Mr. E the complainant was on the telephone to Mr. F regarding the rescheduling of the Dublin trip the following day. In the course of the conversation the complainant says that she mentioned that the ambulance was very busy. At the end of the telephone conversation the complainant states that Mr. E said that he would prefer if the complainant did not discuss him and his colleague (Mr. D) with that crowd over there. On their return home the complainant states that she said to Mr. E that he was not going to take away her freedom of speech.
28th August, 2001:
The complainant states that she had a meeting with the Ambulance Supervisor regarding her treatment by ambulance personnel. According to the complainant she was extremely upset and stressed by these episodes.
3.2 In addition the complainant alleges that she has suffered further discrimination at the hands of a fellow worker who shunned her since making the complaint. According to the complainant Mr. B called to her home during the months of October or November of 2001 ostensibly to make an apology but did so in a jocular fashion saying there was no need to take matters so seriously. The complainant says that she was intimidated by his presence at her home and felt there was no sincerity in this purported apology which was only made for tactical reasons on his part. According to the complainant Mr. B admitted writing the comments complained of on the envelope in question and she says that he seemed to be defending himself on the grounds that it should not be taken so seriously by her. The complainant says that she has been otherwise completely ignored by Mr. B who does not speak to her or discuss anything at all with her, even matters of an operational nature not touching upon the complaint. This is how he behaves on long journeys for example to and from Dublin (a journey of some five hours each way) escorting patients.
3.3 The complainant states that since making the complaint Mr. C made a genuine apology to her and has done his best to improve the working relationship between them. Following a recent serious accident in which the complainant was involved the complainant notes that Mr. C visited her in hospital and has been genuinely remorseful for the distress caused. The complainant submits that she has had no difficulties with any other worker with the exception of Mr. B since the time of the making of the written complaint. The remarks made by Mr. B are clearly of a sexual nature touching on the complainant's gender and, according to the complainant, are intended to suggest that she is excessively masculine or like a man. It is the complainant's contention that such comments would not be objectionable or hurtful if made to a man and, therefore, they turn on the gender ground.
3.4 It is the complainant's contention that the bullying aspect and victimisation stemmed directly from these gender based discriminatory comments. The complainant states that, because more than one person was responsible for making such comments regarding her femininity, she got the sense that she had been discussed in her absence and that a closed circuit of sympathy had developed amongst her fellow workers to the exclusion of her and she claims that, as a result of this, she had been victimised.
4. SUMMARY OF THE RESPONDENT'S SUBMISSION
4.1 The respondent notes that a formal complaint was received by the Chief Executive Officer of the respondent organisation on 2nd October, 2001 in the form of a letter from the complainant.
4.2 The respondent notes that Section 77(5) of the Employment Equality Act, 1998 imposes a strict time limit for a claim for redress in respect of discrimination under the section. According to the Act a claim may not be referred "after the end of the period of 6 months from the date of the occurrence or, as the case may require, the most recent occurrence of the act of discrimination or victimisation to which the case relates". According to the respondent the claim related to three separate incidents on 9th June, 2001; 28th June, 2001 and 7th August, 2001. As the claim was received by the Office of the Director of Equality Investigations on 7th January, 2002 it is the respondent's contention that the only incident which is within the six months period is that which occurred on 7th August, 2001. The respondent says that to meet the time limit that incident would have to be categorised as "the most recent occurrence of the act of discrimination or victimisation to which the case relates". The respondent makes the following points:
(a) The respondent questions whether this incident (i.e. the incident of 7th August, 2001) falls within the discriminatory grounds set out in Section 6 of the Act. Further the respondent notes that the incident is not referred to in the complainant's submission and the submission rules out difficulties with the employee concerned (Mr. E) since the
making of the written complaint.
(b) Notwithstanding (a) above the respondent states that even if what occurred on 7th August, 2001 was regarded as coming within the discriminatory grounds in Section 6 it was entirely unrelated to the previous incidents and totally different in terms of the nature of the complaint. According to the respondent the principal issue of concern to the complainant would appear to be the incident involving Mr. B on 9th June, 2001. The respondent contends that reliance cannot be made on the unrelated incident of 7th August, 2001 as "the most recent occurrence of the act of discrimination" to thereby meet the said time limit.
(c) The respondent says that in the event that the Director of Equality Investigations accepts its contention the complaint can only proceed in the event that "exceptional circumstances" were pleaded under Section 77(6) of the Act. The respondent states that it is not aware of any such exceptional circumstances in the present case.
4.3 The respondent notes that the complainant approached the Ambulance Supervisor about the complaints on 28th August, 2001. On hearing the allegations the Ambulance Supervisor acknowledged that they were serious and that there were a number of options available to the complainant in terms of pursuing same including through the respondent's formal grievance procedure. According to the respondent the complainant was told that by going through the respondent's formal grievance procedure an investigation would be initiated which would be carried out rigorously and fairly by the respondent and if upheld staff in question would be held accountable. The respondent says that the complainant stated that she did not want to get any staff in trouble and that Mr. B had come to her house almost in tears to apologise. According to the respondent says that the Ambulance Supervisor stated that this put him in a difficult position as he had knowledge of these allegations and he should refer them to his superiors and this could cause trouble for some of the named staff. The respondent states that the complainant repeated her desire not to get staff into trouble and the Ambulance Supervisor suggested that he would keep the conversation confidential and "on hold" until such time as the complainant decided if she wanted to pursue the matter further.
4.4 Following receipt of the letter of complaint from the complainant to the Chief Executive on 2nd October, 2001 the Assistant Chief Executive Officer on 22nd October, 2001 acknowledged receipt of the letter and indicated that he had asked the Chief Ambulance Officer to examine the matter and seek to have same resolved. The Assistant Chief Executive Officer wrote to the Chief Ambulance Officer in this regard on the same day. According to the respondent the Chief Ambulance Officer then contacted the complainant by telephone and arranged to meet her. The Chief Ambulance Officer met with the complainant on 24th October, 2001 at an independent location. According to the respondent the complainant told the Chief Ambulance Officer that Mr. B had been to visit her home to apologise but she had found this meeting intimidating and felt it was not an earnest gesture by Mr. B. The respondent says that the complainant told the Chief Ambulance Officer that Mr. C had apologised for the incident which occurred on 28th June, 2001. It is the respondent's submission that the Chief Ambulance Officer apologised to the complainant on behalf of the Ambulance Department for the hurt and upset caused to her and he asked her how she would like to see the matter resolved indicating that there were options available through the respondent's grievance procedure. According to the respondent the complainant stated that she wished to consult her Solicitor for advise and the respondent withheld further action pending the complainant's decision in that regard.
4.5 According to the respondent it deferred action on the formal investigation of the complaint by the complainant in accordance with her wishes following meetings with the Ambulance Supervisor on 28th August, 2001 and the Chief Ambulance Officer on 24th October, 2001. Following an internal investigation of the complaints (subsequent to the referral of a claim to the Director of Equality Investigations) which included discussions with the Chief Ambulance Officer, Ambulance Supervisor and Mr. B, Mr. C and Mr. E the respondent sets out the main sequence of relevant events as follows:
(a) The envelope addressed to the complainant was defaced with comments of a sexual/lewd nature following a discussion which took place in the canteen of Temple Street Hospital in Dublin on 9th June, 2001. This discussion centred around the meaning of different medical terms and Mr. B wrote the comments on the envelope while the
complainant left the table.
(b) The respondent says that Mr. B admitted to defacing this envelope one week after the incident had happened and apologised for the upset caused. According to the respondent Mr. B acknowledged the inappropriateness of his comments to the complainant and she
indicated to him that she was satisfied to let matters rest on foot of his apology.
(c) On 28th June, 2001 Mr. C and the complainant were discussing staff uniforms and Mr. C questioned the complainant as to why she had a preference for wearing trousers. Mr. C asserts that he did not intend to suggest that the complainant was excessively masculine or like a man and according to the respondent there was no connection whatever
between this and the incident involving Mr. B. On learning that the complainant was upset by comments of this nature Mr. C later apologised for the inappropriateness of his comments.
(d) The respondent says that Mr. C vehemently asserts that he did not pursue this matter further with the complainant and did not intentionally or unintentionally bully her in relation to these matters. Rather Mr. C contends that he advised the complainant to report the matter to the Chief Ambulance Officer and he genuinely attempted to repair the hurt and upset caused by his comments. The respondent says that Mr. C refutes the claim that these matters were discussed in the complainant's absence and that "a closed circuit of sympathy had developed to the exclusion of her among her fellow workers".
(d) The respondent says that on learning that the complainant was still upset by the incident in which her envelope was defaced Mr. B went to her home to apologise to her in person. According to Mr. B this meeting took place on 15th November, 2001. The respondent notes that in her meetings with the Ambulance Supervisor on 28th August, 2001 and the Chief Ambulance Officer on 24th October, 2001 the complainant had indicated that Mr. B had already come to her house to apologise. Mr. B contends that the only occasion he went to the complainant's house was on the above date. Furthermore the
respondent submits that Mr. B refutes the claim that he made his apology in a jocular or intimidatory fashion. Rather he says that he genuinely wanted to resolve the matter and contends that the assertion that his apology was made for "tactical reasons on his part" is an unfair imputation of his apology.
(e) The respondent states that Mr. B maintains that he worked with the complainant on only one occasion (after the incident on 9th June, 2001) on 9th February, 2002 and it involved a journey to Dublin. It is Mr. B's contention that he did not shun the complainant on this journey. The respondent says that he asserts that he engaged with her for operational issues but chose not to engage at a social level as he was aware that there was an outstanding complaint of sexual harassment against him. Mr. B felt that this would be the most appropriate course of action as social engagement with the complainant might be misconstrued and further add to the complaint against him. The respondent notes Mr. B's assertion that he did not subject the complainant to victimisation and Mr. B submits that he did not discuss this issue with other members of staff in the complainant's absence.
4.6 According to the respondent there are some disputed facts arising from its investigation and it says that these could have been clarified had there been recourse to the grievance procedure. Disputed facts include:
- Both sides version of the context and content of the discussion which took place in Temple Street Hospital on 9th June, 2001;
- The clarification in relation to the apologies made by Mr. B and the date that he attended the complainant's home.
4.7 In conclusion the respondent states:
- the fact that the complainant was aggrieved by members of staff in the Ambulance Services is acknowledged and staff members Mr. B and Mr. C attempted to resolve these matters with her.
- it is acknowledged that apologies were made and accepted by all parties involved in the dispute. The fact that the complainant refutes the genuineness of Mr. B's apology is also acknowledged. Mr. B asserts that the intention of his apology was sincere and genuine.
- it is contended that every effort was made insofar as it was acceptable and permissible to the complainant to acknowledge and address the stress and upset caused by the incidents outlined in the complaint made by the complainant.
- the contention that recourse should have been had to the respondent's grievance procedure is repeated and this may have permitted the respondent to effectively work towards resolution of the grievances. The respondent refutes the statement made by the complainant's representative in a letter dated 19th February, 2002 (see Appendix A) that no real effort had been made to investigate the matter between September and October, 2001 and the referral of the complaint to the Office of the Director of Equality Investigations. The respondent is unaware of anything which would justify the statements made by the complainant's representative in that same letter that "There were promises of meetings which were cancelled at the last moment" and that "The respondents appointed various members of staff to deal with the matter at various times, but no progress was made".
- the interpretation of events as contained in the complainant's submission (see paragraphs 3.3 and 3.4 above) is of its nature subjective. The respondent's investigation did not find evidence to support these contentions and they are not the only possible interpretation of the events that occurred. The respondent notes that they were not part of the original complaint made by the complainant to it.
- it is contended that the complainant is not being subjected to further discrimination since making her complaint.
- it is the respondent's policy that all employees must be free to perform their duties without threat of intimidation or of sexual harassment from other members of staff and it is committed to the continued implementation of such policies in line with the Equality Authority's "Code of Practice on Sexual Harassment and Harassment at Work".
5. CONCLUSIONS OF THE EQUALITY OFFICER
5.1 The first issue for consideration in this claim is whether or not the alleged incidents fall within the time limits imposed in Section 77(5) of the Employment Equality Act, 1998. In making my decision in this regard I have taken into account all of the submissions, both oral and written, made to me by the parties.
5.2 According to the complainant there are four alleged incidents of discrimination occurring on 9th June, 2001; 28th June, 2001; 13th July, 2001 and 7th August, 2001. The claim was referred to the Office of the Director of Equality Investigations on 7th January, 2002. On this basis the alleged incidents of discrimination which occurred on 13th July and 7th August, 2001 come within the six months time limit as set in Section 77(5) of the Employment Equality Act, 1998.
5.3 The complainant has argued that the 1998 Act requires cases be "referred" to the Director within six months of the date when the behaviour or act in question occurred (or, in the case of a repeated act, last occurred). It is the complainant's submission that the use of the transitive verb "refer" suggests an act done by the referrer and not the Director to whom the matter is referred. The complainant, therefore, considers it inherently unfair to treat the date of receipt of a case as the date of referral. Rather the date of communicating the existence of a grievance should be treated as the date of referral and the complainant notes that telephone contact was made with the Office of the Director of Equality Investigations prior to the formal written referral and the referral form was posted on 17th December, 2001 hence the complainant contends that this should be the date of referral.
5.4 The respondent disagrees with the complainant's contention that the date of referral should be 17th December, 2001 (the date the referral form was posted) and points to the explanatory notes from the Office of the Director of Equality Investigations which state:
"The date on which a claim is referred is taken as the date on which the office received a completed complaint form, or as a complaint made through appropriate arrangements as agreed with the office". The respondent does not concur with the complainant's submission that telephone calls to the Office of the Director of Equality Investigations prior to the formal written referral of the claim could constitute a referral of a claim for redress under the Act. It is also the respondent's contention that the date of posting cannot be considered the date of referral and it notes that the complainant has no evidence to substantiate her claim that the referral form was posted on 17th December, 2001 by way of registered or recorded post (i.e. a certificate of posting).
5.5 I am satisfied that the date of receipt of the referral form in the Office of the Director of Equality Investigations is the date of referral of a claim to the Director. In this case the date of referral of the claim is 7th January, 2002 and, therefore, the alleged incidents which occurred on 13th July and 7th August, 2001 fall within the time limits set out in the Act. I note that the respondent has argued that the alleged incident which occurred on 13th July, 2001 is not validly before me for investigation because the complainant did not specify this date on her referral form and she did specify the other three dates. I do not accept the respondent argument in this regard and note that, in her referral form, the complainant was only required to specify the date of first occurrence of discriminatory act and the date of most recent occurrence of discriminatory act. The complainant was not obliged to list all the dates on which alleged discriminatory acts occurred. I am, therefore, satisfied that I have the jurisdiction to investigate the incident which is alleged to have occurred on 13th July, 2001.
5.6 It is clear from the details of the alleged incident on 13th July, 2001 as set out in paragraph 3.1 above that it relates to the previous alleged incident which occurred on 28th June, 2001. As the alleged incident of 13th July, 2001 is the most recent occurrence of an alleged act of discrimination which occurred on 28th June, 2001 I am satisfied that I have jurisdiction to investigate the alleged incident which occurred on the earlier date of 28th June, 2001. In relation to the first alleged incident on 9th June, 2001 I am satisfied that it is an isolated incident and is outside the six months time limit as specified in Section 77(5) of the Employment Equality Act, 1998. I am further satisfied that the complainant has failed to show that there were exceptional circumstances which prevented her from referring her claim in relation to this incident within the time limit specified. Consequently I do not have jurisdiction to investigate the alleged incident which occurred on 9th June, 2001.
5.7 The three incidents which I have jurisdiction to investigate occurred on 28th June; 13th July and 7th August, 2001 and are detailed in paragraph 3.1 above. In relation to the first alleged incident on 28th June, 2001 the complainant alleges that Mr. C made a comment about her dress stating that she wore nothing but trousers. It is the respondent's contention that Mr. C was talking to the complainant about uniforms and made this comment in that context. The complainant has denied this. I note that the complainant in her submission stated that Mr. C apologised to her unreservedly for any offence caused and that she accepted his apology. From the complainant's submission it would appear that this comment was made by Mr. C for no apparent reason. While the comment may not have been appropriate I am satisfied that it did not constitute harassment or sexual harassment of the complainant by Mr. C. The complainant alleges that on 13th July, 2001 Mr. C approached her saying that he thought that the matter was over and he did not want people asking him what he had done to her. I am satisfied that the approach made by Mr. C to the complainant was done in a genuine effort on his part to resolve any problems (actual or perceived) between himself and the complainant. I consider that this is confirmed by Mr. C's concern for the complainant following her accident as detailed in paragraph 3.3 above. In conclusion I find that the complainant has failed to establish a prima facie case of harassment or sexual harassment as a result of these alleged incidents.
5.8 The alleged incident on 7th August, 2001 concerns the complainant mentioning to her colleagues in another Hospital that the Ambulance was very busy. Mr. E took exception to her passing this comment. I find that this alleged incident does not constitute harassment or sexual harassment within the meaning set out in Section 23 of the Employment Equality Act, 1998 which is as follows:
"For the purposes of this Act -
(a) any act of physical intimacy by B towards A,
(b) any request by B for sexual favours from A, or
(c) any other act or conduct of B ........ shall constitute sexual harassment of A by B if the act, request or conduct is unwelcome to A and could reasonably be regarded as
sexually or otherwise on the gender ground, offensive, humiliating or intimidating to A". In conclusion I find that the alleged incidences described by the complainant as occurring on 28th June; 13th July and 7th August, 2001 do not constitute harassment or sexual harassment of her within the meaning of the Employment Equality Act, 1998 and that the complainant has failed to establish a prima facie case in relation to these incidents.
5.9 The complainant has alleged that she was victimised and in this regard states that she "got the sense that because more than one person was responsible for making such comments regarding her femininity that she had been discussed in her absence and that a closed circuit of sympathy had developed to the exclusion of her amongst her fellow workers". The definition of victimisation is set out in Section 74(2) of the Employment Equality Act, 1998 and it is very specific as to the basis on which victimisation occurs. The complainant's claim of victimisation is based on a feeling which I find is inadequate to establish a prima facie case of victimisation.
5.10 While I find that the complainant has failed to make a prima facie claim of harassment, sexual harassment and victimisation I also find that the respondent failed to adequately respond by way of investigation to her complaints. The complainant met with her Ambulance Supervisor on 28th August, 2001 and informed him of her treatment by ambulance personnel. According to the Ambulance Supervisor he told the complainant that there were a number of options available to her through the respondent's formal grievance procedure. However the Ambulance Supervisor did not act on the complaint because the complainant told him that she did not want to get anyone in trouble. I find that this approach is not appropriate in circumstances where serious allegations are made and which affect, not only the complainant, but also the alleged harasser. Accordingly the Ambulance Supervisor should have directed the complaint to his superiors and the matters complained of should have been investigated.
5.11 The complainant also wrote to the respondent's Chief Executive Officer on 30th September, 2001 outlining her allegations and stating that she considered that she had been severely sexually harassed by male members of the ambulance personnel. Following this letter the respondent (represented by the Chief Ambulance Officer) met with the complainant. There is conflict between the complainant and the respondent as to the date of that meeting. According to the respondent the Chief Ambulance Officer apologised on behalf of the Ambulance Department to the complainant for the hurt and upset caused to her. He inquired of her how she wanted the matter resolved and he indicated that there were options available through the respondent's grievance procedure. As the complainant wanted to consult her legal advisor the respondent decided not to take further action in the matter. At the hearing of this claim I found it impossible to establish what was necessary to invoke the respondent's grievance procedure. I consider that it would be reasonable to assume that when a complaint of this nature is made, either orally or in writing or both, that the respondent's grievance procedures would be invoked immediately and that the complainant would not be asked if she wished to have the matters resolved through the grievance procedure. After the hearing of this claim the respondent submitted a copy of its Staff Handbook which included provisions for dealing with sexual harassment. In the Handbook it states as follows:
"Complaints of sexual harassment will be dealt with in a prompt and thorough manner".
In this case I find that the complaint of sexual harassment made by the complainant was not dealt with in either a prompt or a thorough manner by management in the respondent organisation.
6. DECISION
6.1 Based on the foregoing I find that the respondent did not discriminate against the complainant in terms of Sections 6(1) and 6(2)(a) of the Employment Equality Act, 1998 in relation to complaints of alleged harassment and alleged sexual harassment. I further find that the complainant was not victimised by the respondent in accordance with the provisions of Section 74(2) of the 1998 Act.
__________________
Gerardine Coyle
Equality Officer
14th January, 2003
APPENDIX A
Details of the Letter by the
complainant's representative
dated 19th February, 2002
19th February, 2002
LETTER FROM THE COMPLAINANT'S REPRESENTATIVE TO THE OFFICE OF THE DIRECTOR OF EQUALITY INVESTIGATIONS (EQUALITY TRIBUNAL)
Dear Sirs,
We refer to previous correspondence herein and confirm receipt of your letter of the 18th February last in which you suggest that the ODEI investigation would be put on hold pending the outcome of an internal grievance procedure. We are instructed that our client made the initial complaint to her employers regarding this matter towards the end of September, 2001. No real effort has been made by the employer to investigate the matter in the intervening period. There were promises of meetings, which were cancelled at the last moment. The respondents appointed various members of staff to deal with the matter at various times, by no progress was made. Therefore, we feel that there latest suggestion of dealing with the matter through the internal grievance procedure is only a reaction to the fact that these proceedings have been initiated by our client and is merely a delaying tactic by the Respondent. Notwithstanding the foregoing, you might let us know if the respondent provided you with any details regarding the format of the appeal process which they wish to commence at this juncture. We would need a clear commitment from them on a number of issues before recommending to out client that she put the ODEI case on hold pending the outcome of the internal investigation:
You might be good enough to ascertain:
1. The format of the proposed grievance procedure, i.e. whether there will be a formal hearing regarding the matters at issue herein;
2. If such a hearing will take place, whether a definitive hearing date has been set for same;
3. Who will be making the decisions following the internal process? Is it the respondent's intention to appoint an external arbitrator/adjudicator?
4. As regards the outcome of the internal process, what manner of disciplinary action may be taken against the gentlemen concerned?
5. Will our client be afforded the opportunity of being represented at the internal hearing, either by her Union Representative or her Legal Advisers?
6. Have a list of witnesses been prepared to attend at the hearing?
7. Have written statements been made by those witnesses, and if so will copies be provided to out client in advance of the internal hearing?
8. Will our client have the opportunity, either by herself, of through her representatives, to cross-examine witnesses at the hearing;
9. Will our client be permitted to bring her own witnesses to the hearing?
10. Will there be a further possibility of an internal appeal after this internal grievance procedure has been completed?
Upon receipt of full details regarding the above, we will take our client's instructions herein.