Complainant

Respondent

Parties

Alison McDonnell

VMware International Unlimited Company

Representatives

Mr. James McConnon B.L. on the instructions of Moran and Ryan Solicitors

Ms. Sarah Daly B.L. on the instructions of Lewis Silkin Ireland

Act

Complaint Reference No.

Date of Receipt

Complaint seeking adjudication by the Workplace Relations Commission under section 77 of the Employment Equality Act, 1998

CA-00032781-001

06/12/2019

The Complainant was employed by the Respondent as a Senior Analyst on a fixed term contract from 3 December, 2018 until 29 November, 2019 when her employment was terminated. The Complainant, who is a black woman and originally from the USA, claims that she was subjected to discrimination by the Respondent on the grounds of race in relation to promotion and the provision of training during her period of employment contrary to Section 8 of the Employment Equality Acts, 1998 to 2015. The Respondent disputes the Complainant’s claim of discrimination in relation to promotion and the provision of training.

The Complainant is legally qualified with law degrees from the USA and the UK and is fluent in French, English, Spanish and German. She was contracted by the Respondent to work as a Senior Analyst on the Deal Collaboration Team which was subsequently renamed the Deal Management Team (hereinafter the “DMT”). However, the Complainant claims that she was not involved, in any substantive way, in the role as set out in her employment contract. The Complainant submits that she fulfilled the duties of her role to the best of her ability and her performance was not called into question by the Respondent at any point during her period of employment.

The Complainant submits that she was informed by the Respondent’s HR Manager (Mr. A) and Senior Manager of the DMT (Ms. B) that her role would involve acting as an intermediary of sorts between the DMT and legal team. It was explained to the Complainant that on foot of her qualifications and skills that the Respondent wished to use those skills in relation to the translation of contracts. The Complainant submits that she was tasked with mundane administrative duties despite her qualifications such as creating presentations, proof-reading e-mails on behalf of non-native speakers on the team and transcribing interview questions.

The Complainant claims that non-Irish nationals employed by the Respondent in this country seemed to reach a certain point in the hierarchy within the company and then went no further in terms of career progression. The Complainant submits that this was due to their nationality and/or race and that she encountered such issues during her period of employment with the Respondent.

The Complainant submits that she had a meeting with her then supervisor Ms. B (Senior Manager of the DMT) and the Head of the DMT (Ms. C) on 7 February, 2019. The Complainant contends that she was requested by her superiors to come up with a job description and the reasoning behind same was to apparently justify her value to the DMT. The Complainant submits that she was surprised by this meeting and the manner in which it developed as she had been initially informed by Mr. A (HR Manager), that the Respondent planned on her role being one where she initially provided legal advice, and the Respondent would thereafter train her how to do deals.

The Complainant submits that the management structure of the DMT was reorganised in February, 2019 and Ms. C was allocated the role of Senior Director at the top of the hierarchy followed by three others below her who were Regional managers and six-sub-Regional Managers. The Complainant claims that prior to the appointment of the Regional Managers a non-Irish national candidate (Ms. D) was strongly discouraged from applying for the position. The Complainant submits that this person had previously applied for several positions internally and was told by her manager that “management and even HR does not take you seriously”.

Promotion/Getting a Job

The Complainant submits that on 20 May, 2019 she had a meeting with a Director regarding a Senior Contracts Negotiator position within the Respondent company which was about to be filled in Germany and that Ms. B (Senior Manager of the DMT) was also present at the meeting. The Complainant claims that Ms. B stated at this meeting that “there is no place for [the Complainant] on the team”. The Complainant submits that the DMT was known to have challenges in retaining multilingual employees and she contends that this statement by Ms. B was peculiar in the circumstances as she had a background in contract law and was a multilingual candidate.

The Complainant claims that she was discouraged by the Respondent from applying for this role and another Senior Contracts Negotiator role which became available in the UK on account of her race and she contends that this treatment amounted to discrimination on the grounds of her race.

The Complainant submits that Ms. F was appointed to a Senior Manager role on 14 May, 2019 and was chosen for this position over other more qualified and in particular, Ms. G, who was a non-Irish national. The Complainant submits that Ms. F, who was an Irish national, was only fluent in English and had no knowledge of the role and did not possess the required experience.

The Complainant submits that she applied for a Director role within DMT on 17 June, 2019 after Ms. C (Senior Director) had stated during a presentation at a summit meeting that: “people are promoted not only because of their background but because of their ability to find answers to questions, no one will meet all the qualifications for the role, but the person will know who to direct their questions to”. The Complainant, prior to applying for this role held five degrees, spoke four languages and held over ten years’ experience in the area, with over five of those years being in contract law and corporate law for large multi-national companies and law firms. However, she claims that an Irish candidate was selected for the position.

The Complainant claims that on or about 19 June, 2019 a sub-regional manager in the DMT stated in front of a senior analyst and the Complainant that Ms. B “warned her” that the Complainant was a black, non-national applicant. The Complainant submits that she received no feedback from the Respondent in respect of her application or any formal notification that her application had been unsuccessful.

The Complainant submits that she was subjected to discrimination on the grounds of race in relation to her application for promotion to the position of Director in June, 2019. The Complainant contends that an inference of less favourable treatment on the grounds of race can be drawn in respect of the fact that she applied for the role of Director and was warned she was a black applicant. Thereafter, she did not get the role despite being adequately qualified for same.

Provision of Training

The Complainant also claims that she was subjected to discrimination by the Respondent on the grounds of race in relation to provision of training during her period of employment. The Complainant stated that she only received one week’s training during her period of employment. The Complainant stated that other workers employed by the Respondent received specialised training which was relevant to their specific roles within the company. However, the Complainant contends that she did not receive any such specialised training in relation to her role.

Comments in relation to the Complainant’s race

The Complainant submits that a number of incidents occurred during her period of employment where derogatory comments were made to her by work colleagues in relation to her race. The Complainant submits that she did not report these incidents to management or raise any grievance under the internal procedures as she had no confidence that any actions would be taken to rectify the situation.

The Complainant relied upon the following cases in support of her claim, namely: UCD -V- Eleanor O’Higgins EDA131; Julia Schnorbus v Land Hessen C-79/99; Ntoko -v- Citibank [2004] ELR 116 and Minaguchi -v- Wineport Lakeshore Restaurant DEC-E2002-020.

The Respondent is a global organisation which provides cloud computing software, networking and digital workplace services to its customers. The Respondent submits that the Complainant was employed by the company as a Senior Analyst under a fixed term contract dated 21 November, 2018 with a commencement date of 3 December, 2018. The Complainant’s contract was not amended at any stage and the Complainant remained employed until it expired on 29 November, 2019.

The Respondent submits that prior to commencing employment on the basis of the fixed term contract, the Complainant initially applied for the role of Senior Contracts Manager and was interviewed on 7 November, 2018 by a three person panel which included the Senior Manager of the DMT (Ms. B). There were 21 applicants for the role and the Complainant made it to the final three candidates (which consisted of one Irish national and two non-Irish nationals). The successful candidate was a non-Irish national. The Respondent submits that while all three candidates were considered suitable for the role the successful candidate was chosen based on specific prior experience that she had with another software company.

The Respondent submits that Ms. B was impressed with the Complainant and made internal enquiries within the company to see if there were any other suitable roles for the Complainant given her legal background and the skills and experience, she had demonstrated at the original interview. However, due to headcount restraints in place at the time it was not possible to obtain approval to create an entirely new role for the Complainant.

The Respondent submits that approval had been granted for a fixed term hire into the position of Senior Analyst on the Deal Collaboration Team (which was subsequently renamed the DMT). This role was only available as a fixed term contract role to cover the period of maternity leave of another employee and the Respondent’s Senior Recruiter (Mr. A) contacted the Complainant to discuss the open role and ascertain if she would be interested in applying for the role. The Complainant indicated that she was disappointed not to have been successful for the Senior Contracts Administrator position but was happy to be considered for other opportunities within the company. After reviewing the job specification, she formally applied for the role on 9 November, 2018. There were 10 other applicants for the role and all the candidates were non-Irish nationals. The Complainant’s application was successful, and she commenced employment on 3 December, 2018.

The Respondent submits that there was no discrimination against the Complainant on the ground of race at the outset of her interactions with the company as she was encouraged to apply for the Senior Analyst role when she was not successful for the Senior Contracts Administrator position and was ultimately hired into the position following a successful interview process.

The Respondent submits that the role the Complainant was hired into initially reported into Ms. B (Senior Manager of the DMT). During the course of her employment, the Complainant’s line manager changed after Ms. B moved to a different role. Although the Complainant’s job title was “Senior Analyst” (because that was the title of the employee on maternity leave) this fixed term resource was hired at a time of significant change for the DMT. Therefore, it was not intended as a direct backfill replacement for the employee on maternity leave but was anticipated to provide support in respect of the transformation of the team. The DMT was undergoing a lot of change at this time with Ms. B’s manager, Ms. C only having been appointed to the role of Senior Director of the DMT in September 2018, shortly before the Complainant was hired.

The Respondent submits that the transitionary nature of the DMT and the potential for this role to change and evolve over the course of the fixed term were made very clear to the Complainant during the interview and that she was open to the opportunity to develop the role and provide the support required during the fixed term. The Respondent submits that the usual tasks and duties involved in a Senior Analyst role would not have been comparable or suitable for the Complainant’s qualifications and experiences. However, the intention had always been to create a new role that would utilise the Complainant’s legal skillset to add additional value to the team during the maternity leave period of the original holder of the Senior Analyst role.

The Respondent noted that the Complainant had referred to a meeting which took place on 7 February 2019 in her Complaint Form. The Respondent submits that the purpose of this meeting was to discuss how the Complainant could contribute further to the transformation of the DMT during her fixed term contract and the Complainant, Ms. B and Ms. C were all present at the meeting. The Respondent submits that the time at which the Complainant had been hired had been a particularly busy time in terms of deals involving the DMT. As a result, there were limited opportunities for Ms. C and Ms. B to discuss how the role could be developed with the Complainant when she joined the team. This discussion on 7 February 2019 took place at the start of a new financial year for the Respondent and so was an ideal time to discuss the proposed transformation and restructure of the DMT and how the Complainant’s legal skills and experience could be best utilised in this project. It was envisaged that the Complainant would help with building out the DMT’s contract expertise.

The Respondent submits that at that time a similar contracts workstream had been established in the Respondent’s US operations. It was discussed that the Complainant would develop into a contracts subject matter expert “SME” for the Irish based DMT based on her legal background and would then help train and coach other DMT members who did not have experience in contracts. It was submitted that the Complainant knew that her role was a developing temporary role to provide support to the transition project that was being undertaken in respect of the DMT.

Promotion/Getting a Job

The Respondent submits that during her period of employment, the Complainant expressed an interest in three other positions which became available within the company, namely: 1) Senior Contracts Negotiator - Munich, 2) Senior Contracts Negotiator – UK and 3) Director of the DMT.

The Senior Contracts Negotiator role which arose in May, 2019 was advertised internally as located in Germany and requiring strong German language skills. The Respondent submits that Ms. B discussed this role with the Complainant as she had expressed an interest in a Contracts Negotiator role should one become available during her fixed term contract. The Respondent contends that Ms. B was supportive in trying to help the Complainant find a permanent role within the organisation before her fixed term contract expired. Ms. B encouraged the Complainant to reach out to the hiring manager (Mr. G) for this role and made arrangements for a telephone call between the Complainant and Mr. G her to discuss the requirements of the role.

The Respondent submits that this role was intended to be based in Munich and the Complainant did not subsequently progress an application for the role. The Respondent submits that the Complainant expressed an interest in such a role should one arise in Ireland in the future and Mr. G confirmed he would keep her in mind if such an opportunity came up. The Senior Contracts Negotiation role in Munich which the Complainant had expressed interest in was ultimately filled by a German candidate and so was not filled by an Irish national. The Respondent submits that while no Contracts Negotiator role arose in Ireland during the Complainant’s employment, the Complainant was never at any point excluded from applying for any roles.

The Respondent submits that a Senior Contracts Negotiator role which was located in England also arose in May, 2019 and that the Complainant discussed this role with the company’s internal recruiter, by phone. However, this role was to be based in the UK and so the Complainant did not apply for the role, as like the above Contracts Negotiator located in Germany, the location did not suit her. The Respondent contends that the Complainant chose not to apply for this role due to its location and therefore she could not have been discriminated against in respect of access to this role.

The Respondent submits that the Director role became available within the DMT in June, 2019 and was a senior people management role involving the management of senior managers. The Complainant applied for this role along with a number of other candidates. The Director role as an Management level 5 role would have been three grades more senior than the Complainant’s role and required significant people management experience. The Respondent submits that the Complainant was not shortlisted for interview as she did not have the requisite experience (particularly for a people management focussed role which would involve the management of senior managers). The Complainant did not have the requisite level of industry experience gained within the information technology sector as was required for this very senior role.

The Respondent submits that the successful candidate for the Director of DMT role had significant relevant experience already gained within the Respondent’s organisation and had spent several years within the company leading on significant global projects at an equivalent level to that of Director and was the most suitably qualified candidate for the role. The Respondent submits that while the Complainant is clearly a very accomplished person, the simple fact was that her qualifications were not relevant for the Director role and she did not have comparable relevant experience at the senior level required for this role.

The Respondent totally refutes all allegations made by the Complainant that it engaged in a pattern of discrimination on the grounds of race. The Respondent submits that it has almost 1,000 employees in Ireland who come from a multitude of different ethnic backgrounds. The employee population in the location where the Complainant worked has 54 different nationalities speaking 46 different languages and is recognised for its cultural diversity. The Respondent submits that it is an international equal opportunities employer and is fully committed to providing equal opportunities to all its employees and to providing a workplace that is free from discrimination.

Provision of Training

The Respondent also disputes the claim that the Complainant was subjected to discrimination on the grounds of her race in relation to the provision of training during her period of employment. The Respondent submits that all relevant training was provided to the Complainant in relation to her role within the company during her period of employment. The Respondent contends that training was provided to staff of the DMT by way of “partnering” with a more experienced colleague and that this method of training was afforded to the Complainant in accordance with the established company practice. The Respondent submits that the Complainant was never denied access to training during her period of employment and that she did not raise any concerns with management in relation to this matter.

Comments in relation to the Complainant’s race

The Respondent submits that it was never made aware by the Complainant that the alleged derogatory comments had been made to her during her period of employment. The Complainant did not raise and concerns or grievances with management in relation to these allegations and therefore the company was not in a position to investigate of deal with the allegations.

The Respondent submits that the company has comprehensive policies in respect of Dignity in the Workplace and Grievances and that employees are regularly trained on these policies which are made available to employees both at induction and through the Respondent’s employee intranet. The Respondent contends that these policies were brought to the Complainant’s attention at an induction which she attended on 7 January 2019 and she was therefore fully aware of their existence.

The Complainant relied upon the following cases in support of her claim, namely: Southern Health Board v Mitchell DEE011, Melbury Developments Limited v Arturs Valpeters EDA0917 and 2 Nmaed Complainants v A Catering Company DEC-E2017-054.

Scope of the Complaint

At the outset of my deliberations in relation to this matter it is necessary to clarify the precise scope of the instant complaint. The Complainant, on her Complaint Form and her subsequent written submissions, referred to a number of specific incidents which she claims occurred during her period of employment where it was alleged that she was subjected to derogatory comments connected to her race by certain work colleagues. I noted that the Complainant had not indicated on the Complaint Referral Form that she was seeking to pursue a complaint of harassment within the meaning of Section 14A of the Employment Equality Acts in relation to these matters. In the circumstances, I sought clarification from the Complainant at the outset of the oral hearing in relation to the precise scope of the instant complaint. The Complainant’s legal representative confirmed that the Complainant did not wish to pursue a claim of harassment contrary to Section 14A of the Acts.

Therefore, the only issues which fall for investigation and decision by me in the context of the instant complaint is whether the Complainant was subjected to discriminatory treatment on the grounds of race in relation to promotion/getting a job and the provision of training contrary to Section 8 of the Employment Equality Acts.

Section 85A of the Employment Equality Acts sets out the burden of proof which applies in a claim of discrimination. It requires the Complainant to establish, in the first instance, facts from which it may be presumed that there has been discrimination in relation to her. If she succeeds in doing so, then, and only then, is it for the Respondent to prove the contrary. The Labour Court has held consistently that the facts from which the occurrence of discrimination may be inferred must be of “sufficient significance” before a prima facie case is established and the burden of proof shifts to the Respondent.

In deciding on this complaint, therefore, I must first consider whether the existence of a prima facie case has been established by the Complainant. It is only where such a prima facie case has been established that the burden of proving there was no infringement of the principle of equal treatment passes to the Respondent.  

The Labour Court elaborated on the interpretation of Section 85A in the case of Melbury v. Valpeters EDA0917 where it held that Section 85A: "…. provides for the allocation of the probative burden in cases within its ambit. This requires that the Complainant must first establish facts from which discrimination may be inferred. What those facts are will vary from case to case and there is no closed category of facts, which can be relied upon. All that is required is that they be of sufficient significance to raise a presumption of discrimination. However, they must be established as facts on credible evidence. Mere speculation or assertions, unsupported by evidence, cannot be elevated to a factual basis upon which an inference of discrimination can be drawn. Section 85A places the burden of establishing the primary facts fairly and squarely on the Complainant and the language of this provision admits of no exceptions to that evidential rule.”

Section 6(1) of the Employment Equality Acts provides that direct discrimination shall be taken to occur where “a person is treated less favourably than another person is, has been or would be treated in a comparable situation on any of the grounds specified in subsection (2) …..”. Section 6(2)(h) of the Acts defines the discriminatory ground of race as follows – “as between any 2 persons …. that they are of different race, colour, nationality or ethnic or national origins”. As the Complainant has claimed that the alleged discriminatory treatment in the instant case occurred on the grounds of race, it will therefore be necessary for me to consider if the Complainant, as a black person of American nationality, was subjected to less favourable treatment compared to another person in similar circumstances because of her race, colour, nationality or ethnic or national origins.

In reaching my decision I have taken into account all of the evidence, written and oral, submitted by the parties. In this regard, I heard evidence at the oral hearing from the following witnesses, namely the Complainant and from Mr. A (Senior Recruiter), Ms. B (Senior Manager of the DMT) and Ms. C (Head of the DMT) on behalf of the Respondent. The legal representatives of both parties were afforded the opportunity to cross-examine the respective witnesses from the other side after they had adduced direct evidence.

Claim in relation to Promotion/Getting a Job

The first issue that I must consider relates to the claim that the Complainant was subjected to discriminatory treatment on the grounds of race in relation to promotion and getting a job contrary to Section 8 of the Acts. In considering this issue, I note that the Complainant indicated in her complaint that internal vacancies became available within the company in respect of three specific positions during her period of employment. The titles for the specific positions that became available were as follows: 1) Senior Contracts Negotiator – Munich, 2) Senior Contracts Negotiator – UK and 3) Director of the Deal Management Team (DMT). It was not in dispute between the parties that these three positions were graded at a higher level than the Complainant’s role of Senior Analyst and therefore, it would have resulted in a promotion for the Complainant in the event of her having successfully acquired any of the positions.

In relation to the first two positions (namely the Senior Contracts Negotiator – Munich and Senior Contracts Negotiator – UK), I note that it was common case between the parties that the Complainant initially expressed an interest in these positions but did not subsequently pursue an application in respect of either role. The Complainant has claimed that she was discouraged by the Respondent from applying for these two positions on account of her race and she contends that this treatment amounted to discrimination on the grounds of her race.

The Respondent emphatically disputes the Complainant’s claim in relation to this matter and contrary to her assertions claims that the Complainant was actively encouraged to apply for any promotional positions in which she had expressed an interest during her period of employment. The Respondent contends that the reason why the Complainant did not apply for either of these positions was because of her stated position that she did not wish to move to another country in pursuit of employment on account of her family ties to the region in Ireland where she resided at the material time in question.

On balance, I prefer the Respondent’s evidence in relation to the interaction that took place between the parties in relation to the vacancies for the two Senior Contracts Manager positions. I heard detailed evidence from Ms. B (Senior Manager of the DMT) in relation to her interaction with the Complainant in respect of the vacancies for these positions. I have found Ms. B’s evidence on this matter to be very compelling and I accept her evidence that she actively encouraged the Complainant to apply for these positions, particularly the position in Germany, and that she provided assistance to the Complainant in obtaining further information about the roles.

Having regard to the totality of the evidence adduced, I am satisfied that I have not been presented with any evidence from which I could reasonably conclude that the Complainant was discouraged from applying for these positions or that her race was in any way a material factor in terms of the interaction that took place between the parties in relation to this matter. Accordingly, I find that the Complainant has failed to establish a prima facie case of discrimination on the grounds of her race in relation to her interaction with the Respondent in respect of these promotional positions.

I will next address the Complainant’s claim of discrimination in relation to the third position (namely, the role of Director of DMT) which arose during her period of employment. It was common case between the parties that the Complainant did, in fact, apply for this position and that her application was ultimately unsuccessful. The Complainant claims that the reason why her application was unsuccessful was directly attributable to the fact of her race. The Respondent totally refutes this claim and contends that the reason why the Complainant’s application was unsuccessful was wholly related to the fact that she did not have the requisite experience and was not suitably qualified for the position.

In considering the alleged discrimination in relation to this matter, I am obliged to examine the manner in which the selection processes in relation to this position was conducted by the Respondent in order to establish if there is any evidence to suggest that this process was applied in a less favourable or discriminatory manner towards the Complainant on the grounds of her race. In this regard, I have taken cognisance of the case of Client Logic Logic t/a UCAL -v- Kulwant GillEDA0817 where the Labour Court held that "[T]he Court has previously held that in cases alleging an infringement of equality law in the filling of posts, it is not the function of the Court to substitute its views on the relative merits of candidates for those of the designated decision makers. Rather, its role is to ensure that the selection process is not tainted by unlawful discrimination. Consequently, the Court will not normally look behind a decision unless there is clear evidence of unfairness in the selection process or manifest irrationality in the result". Thus, it is a principle that has consistently been followed by both the WRC and the Labour Court that it is not the Adjudication Officer’s role to examine whether the most meritorious candidate was successful in a selection process. Rather, the Adjudication Officer’s role is to examine and decide whether or not the selection process is tainted by discrimination i.e. in this case on the race ground.

In considering this issue, I note the Respondent’s evidence that there were 41 applicants for this position of Director of DMT and that only 8 of these applicants were shortlisted for interview for the position. The Respondent adduced evidence from Mr. A (Senior Recruiter) and Ms. C (Head of the DMT) both of whom played an integral role in the selection process which was conducted in respect of this position. Both witnesses adduced evidence that the role in question was a senior management role within the company and was graded three levels higher that the role which the Complainant was undertaking at the material time in question. The Respondent also adduced evidence that one of the key requirements for the role of Director was senior management and leadership experience in a multinational organisation. The Respondent adduced further evidence that the Complainant did not possess these key requirements and therefore was not shortlisted for interview for the position.

Having regard to the totality of the evidence adduced, I have found the Respondent’s evidence to be very compelling in relation to the manner in which the selection process for the position was conducted. Furthermore, I am satisfied that I have not been presented with any evidence from which I could reasonably conclude that there was any element of unfairness or irregularity in terms of the manner in which the selection criteria was applied to the Complainant's application during the selection process that was conducted in relation to the position in question. I have found the Respondent’s evidence to be very credible in relation to this issue and I accept its evidence that the Complainant was not treated less favourably than any of the other candidates on the grounds of her race in terms of the manner in which his selection process was conducted. In the circumstances, I find that the Complainant has failed to establish a prima facie case of discrimination on the grounds of race in relation to the manner in which her application for the position of Director of DMT was dealt with by the Respondent.

Provision of Training

The final element of the complaint that I must consider relates to the Complainant’s claim that she was subjected to discrimination on the grounds of race in relation to the provision of training during her period of employment. The Complainant claims that she received only one week’s training in her role as Senior Analyst and was treated less favourably than other workers on the basis that she didn’t receive any specialised training relevant to her specific role. The Respondent disputes the Complainant’s claim on this matter and contends that she was provided with training by way of a “partnering” arrangement like all other workers who were engaged in similar roles.

Having considered the totality of the evidence on this matter, I am satisfied that the Complainant has failed to establish facts from which it could be inferred that she was treated less favourably than other workers on the ground of race in relation to the provision of training. I find that the Complainant has failed to adduce any significant evidence to support her claims of discriminatory treatment in relation to this matter but rather has essentially relied upon supposition and assertion, unsupported by evidence, in support of this claim. Accordingly, I find that the Complainant has failed to establish a prima facie case of discrimination on the grounds of race in relation to the provision of training contrary to Section 8 of the Acts.

I find that the Respondent did not discriminate against the Complainant on the grounds of race regarding promotion/getting a job and the provision of training contrary to Section 8(1) of the Employment Equality Acts. Accordingly, I find in favour of the Respondent in this case.

Employment Equality Acts, 1998 to 2015 – Discrimination - Section 8 - Access to Promotion – Getting a Job - Provision of Training – Section 6(2)(h) – Race Ground