Complainant

Respondent

Parties

Darragh  O'Shea

Alucraft Limited

Representatives

Joanna Ozdarska, SIPTU

Graham Bailey, Construction Industry Federation

Act

Complaint/Dispute Reference No.

Date of Receipt

Complaint seeking adjudication by the Workplace Relations Commission under Section 8 of the Unfair Dismissals Act, 1977

CA-00059606-001

25/10/2023

The Complainant was employed by the Respondent as a Window Installer from 3 October 2016 until 17 July 2023. The Complainant’s duties also included being a banksman and general operative. In 2022, the Complainant was designated the site Safety Representative. The Complainant earned €20.47 gross per hour and worked approximately 39 hours per week.

The Respondent found that the Complainant had committed a serious Health & Safety breach when dismantling an alloy tower on 30 June 2023. The Complainant was suspended on full pay and following a disciplinary process, the Complainant was ultimately dismissed for gross misconduct on 17 July 2023.

On 25 October 2023, the Complainant submitted his Complaint Form to the Workplace Relations Commission (the “WRC”). The Complainant argues inter alia that he was not adequately trained to dismantle the tower as instructed; the investigation was not sufficiently thorough and fair; the decision to dismiss him was disproportionate; and that the disciplinary process was flawed. The Complainant submits that he was unfairly dismissed in violation of the Unfair Dismissals Act 1977 as amended. He is seeking compensation. The Respondent denies the allegations in full.      

The Respondent provided detailed written and oral submissions.

The Respondent submitted that it provides design, engineering, manufacturing, installation and maintenance of architectural glazing systems.

The Respondent submitted that the Complainant commenced work in October 2016 in the capacity of “Trainee Installer”. The Respondent submitted that throughout his employment, the Complainant was “subject to numerous training courses” for which he received various certificates, including a “working at height & harness awareness training course” in July 2021. This certificate was valid until July 2024. The Respondent submitted that the Complainant was considered a good worker and was the designated the site Safety Representative. The Respondent submitted that the Complainant had completed the Safety Representative course accordingly. The Respondent submitted that its Health & Safety Department sent out toolbox talks on 20 January 2023 and 8 May 2023 in relation to working at heights and that the Complainant signed for both talks.

On Friday 30 June 2023, the Respondent submitted that the Complainant stood on top of an alloy tower frame, without a guardrail, while dismantling it. The alloy tower was located outside on the eighth-floor balcony of the building. The Respondent submitted that the Complainant failed to use the “Through The Trapdoor Method” (the “3T Method”). The Respondent submitted that this was a serious Health & Safety breach as the Complainant posed a risk to himself and others. The Respondent submitted that a site employee took photos of the Complainant and reported the breach to the client, who immediately stood the Complainant down and notified the Respondent.

On Monday 3 July 2023, Mr. Thomas Hetherington, the Respondent’s Health & Safety Manager along with the Respondent’s Senior Contract Manager reviewed the photos and concluded that the Complainant could have slipped, resulting in his death. The Complainant was suspended with pay pending an investigation.

The Respondent submitted that on that same day, the Complainant was invited to an Investigation Meeting on 5 July 2023. The Respondent submitted that the Complainant was advised that the breach was being investigated as gross misconduct and that he could bring “representation”. The Respondent submitted that the Investigation Meeting took place on 5 July 2023 and the Complainant did not bring “representation”. At that same meeting, the Respondent submitted that the Complainant stated inter alia that: he had made a mistake; he wasn’t thinking when he decided not to follow the training; he had received adequate training; and that he had a lot on his mind and was under pressure as work colleagues had been let go recently. The Complainant signed this note of the meeting.

The Respondent submitted that on 7 July 2023, the Complainant was invited to a Disciplinary Hearing on 11 July 2023. The Complainant was informed that he was accused of gross misconduct, he had the right to “bring representation” and he was provided with details of the Employee Assistance Programme.

The Respondent submitted that the Disciplinary Hearing took place on 11 July 2023, and the Complainant confirmed that he was satisfied to proceed without representation. The Respondent submitted that during the Disciplinary Hearing, the Complainant was told that, by his actions, he could have caused his own or another person’s death.

The Respondent submitted that the Complainant was dismissed by letter dated 17 July 2023 and he was informed of his right to appeal. The Complainant’s Appeal Hearing was held on 1 August 2023 and he was represented by a SIPTU official. The Respondent submitted that on 9 August 2023, the Complainant was informed that the dismissal decision was upheld.

The Respondent submitted that the nature of the Complainant’s Health & Safety breach was so serious, that it was reasonable to dismiss him. The Respondent also submitted that the disciplinary procedure was fair. The Respondent further submitted that even if there was a procedural flaw, the procedure as a whole was fair and the Complainant’s actions were “the sole determinant of the outcome”. The Respondent relied on Clancourt Management Ltd t/a Clancourt Management v. Jason Cahill, UDD2234; and Noritatke (Irl) Ltd v. Kenna, UD 88/1983.

Mr. Thomas Hetherington – Evidence:

Mr. Hetherington outlined that he has been the Respondent’s Health & Safety Manager since November 2016 and that he is responsible for a number of sites.

Mr. Hetherington outlined that on 30 June 2023, the Respondent was informed by its client that there was an issue on site and that the Complainant had been stood down. Mr. Hetherington outlined that the client informed the Respondent that the Complainant was photographed standing on top of an unguarded alloy tower with no protection, eight stories up. Mr. Heatherington outlined that the Complainant had failed to dismantle the alloy tower using the 3T Method, which requires only one person, who remains seated and therefore safe, throughout. Mr. Hetherington outlined that the Complainant’s actions had put himself and others in danger.  Mr. Hetherington outlined that the Respondent had to carry out an investigation into the matter and produce an improvement plan for the client.

Mr. Thomas Hetherington – Cross-Examination:

Under cross-examination Mr. Hetherington stated that the Complainant had put himself in a serious situation. Mr. Hetherington stated that in failing to follow the 3T Method, the Complainant had no protection.

Mr. Hetherington was referred to the relevant Risk Assessment Method Statement (“RAM”) and Safe Plan of Action (“SPA”).  Mr. Hetherington said that all operatives sign up to the SPAs on a daily basis, where applicable. He further stated that the client and not the Respondent has this documentation.

Mr. Hetherington was referred to the Near Miss Report Form dated 5 July 2023. This states “Pending the decision of a disciplinary panel it is also recommended that the [sic] Darragh attend an [sic] re-induction to the site”. Mr Hetherington outlined that any re-induction was subject to the finding of the disciplinary panel. Mr. Hetherington did not accept that this was an indication to the Complainant that he would re-enter the site.

Mr. Brian Nolan – Evidence:

Mr. Brian Nolan stated that he was the Site Manager since June 2020.

Mr. Nolan outlined that there are RAMs conducted for the site and that SPAs are conducted weekly or daily depending on the task(s). Mr. Nolan outlined that they, along with toolbox talks and ladder permits, are located at the whiteboard area, which can be accessed by all operatives.

Mr. Nolan outlined that the Complainant was a good employee and that he had no complaints about him. He outlined that while the Complainant never challenged him, he would say if he had an issue or grievance.

Mr. Nolan outlined that he asked the Complainant to disassemble the alloy tower on his own. He further outlined that the Complainant “had the ticket” and he asked him to go to the eighth floor. He outlined that if the Complainant needed help, he could have asked him. He outlined that the Complainant never asked for help or raised concerns when he asked him to disassemble the alloy tower.

Mr. Nolan stated that he does not have any training in relation to the alloy tower. He stated that he could not have instructed the Complainant on what to do. He further stated that it is for the Complainant to know how to assemble or disassemble an alloy tower. He stated that Complainant had received training for the task.

Mr. Brian Nolan – Cross-Examination:

Under cross-examination Mr. Nolan stated that alloy towers are not written into every SPA. He stated that if that were the case, a plasterer would have to do them every time they moved a tower.

Mr. Nolan stated that the Complainant’s task of disassembling the alloy tower on the eighth floor was not a high-risk task. He stated that the Complainant, by his own actions, had made the task high-risk.

Mr. Nolan stated that the Complainant could have disassembled the alloy tower on his own, it is not a two-person job per se. Mr. Nolan stated that having two operatives working on it, would have sped up the job as the second operative is another pair of hands.

Mr. Nolan accepted that he had not previously asked the Complainant to complete the task on his own.

Ms. Julie Lowrey – Evidence:

Ms. Julie Lowrey stated that she has been the HR Manager since November 2022.

Ms. Lowrey outlined that she and the Contracts Manager held the Complainant’s Disciplinary Hearing on 11 July 2023. She outlined that the decision was made to dismiss the Complainant on the basis of gross misconduct. Ms. Lowrey outlined that they considered all sanctions as part of the process but due to the severity of the Complainant’s actions he was dismissed. She outlined that they were shocked by his actions especially in view of his training. She outlined that they expected the Complainant to be a role model. Ms. Lowrey outlined that they did ask the Complainant to produce mitigating factors for consideration, prior to a decision being made.

Ms. Lowrey stated that in line with the principles of natural justice, the Complainant was entitled to bring a representative with him. She outlined that when he arrived alone, she asked him if he wanted to postpone the Disciplinary Hearing, but he said that he was satisfied to proceed.

Ms. Lowrey outlined that the Complainant’s request for a second Disciplinary Hearing was refused as he had been given a fair opportunity to present his side. She further outlined that a second Disciplinary Hearing would have only prolonged the process and not produced anything else.

Ms. Lowrey stated that the Complainant brought a SIPTU official to represent him at the Appeal Hearing.

Ms. Lowrey stated that around this time, there were a number of layoffs as projects were winding down.

Ms. Julie Lowrey – Cross-examination:

Under cross-examination, Ms. Lowrey was referred to the Respondent’s “Disciplinary Rules and Procedures” and asked if the Respondent had a “zero tolerance policy” regarding misconduct matters. Ms. Lowrey stated that as part of the Disciplinary Hearing, the Respondent took on board what the Complainant said, including any mitigating factors, which he did not present.

Ms. Lowrey was asked how the other sanctions were considered. In response, she stated that the Respondent considered all of the evidence including the extent of the harm and the Complainant’s training and role. She outlined that the Respondent weighs up all factors, in line with its policy. She said that the Respondent had no alternative but to dismiss the Complainant based on the investigation outcome. She said that he could have lost his life or others could have lost their lives as a result of his actions. Ms. Lowrey stated that their trust in the Complainant was undermined.

Ms. Lowrey was referred to the Respondent’s “Disciplinary Rules and Procedures” which indicate that an employee can only be accompanied by an employee and does not indicate a representative. Ms. Lowrey stated that the Complainant “knew what his entitlements were” and that he was not denied representation. She said that the Complainant never asked to bring representation and they never refused him representation. Ms. Lowrey outlined that the Complainant stated that he wanted to proceed, and they relied on that.

Ms. Lowrey outlined that the suspension letter sent to the Complainant was an administrative letter from HR. She stated that she was the only HR person in the office at the time. Ms Lowrey stated that she was only involved in the Disciplinary Hearing on 11 July 2023, once the matter was passed to her following the Investigation Meeting on 5 July 2023.

Ms. Lowrey stated that the Complainant first mentioned the Site Manager during his interview and so a witness statement was then sought from the Site Manager. Ms. Lowrey stated that the Site Manager’s role is to instruct site operatives. Ms. Lowrey stated that the Complainant is the person who is trained in disassembling the alloy tower and he chose to do it in an unsafe manner.

The Complainant provided detailed written and oral submissions.

The Complainant submitted inter alia that he was not adequately trained to dismantle the tower as instructed; the investigation was not sufficiently thorough and fair; the decision to dismiss him was disproportionate; and that the disciplinary process was flawed.

The Complainant submitted that he was never trained to dismantle an alloy tower by himself and that two persons are required to do this task. The Complainant submitted that “despite acknowledging that the job required two people, he refrained from questioning his supervisor, apprehensive about potential repercussions….. just the previous day, three more colleagues had been given redundancy”.

In his written submissions, the Complainant took issue with a number of aspects of the investigation and disciplinary process, such as:

·                The Complainant was not provided with agreed terms of reference for the investigation process;

·                The Respondent’s “Disciplinary Rules and Procedures” exclude the right for an employee to be represented by a trade union official;

·                The Complainant was not provided with a formal complaint or witness statement;

·                The Respondent failed to interview the Site Manager;

·                The Complainant was asked to sign the minutes of the Investigation Meeting without being given a copy;

·                The Complainant did not receive the minutes of the Investigation Meeting prior to the Disciplinary Hearing;

·                The Complainant’s request for a second Disciplinary Hearing was refused;

·                The Respondent did not consider mitigating factors;

·                The Respondent never considered any other sanction; and

·                In light of the Near Miss Form, the Complainant had an expectation that he would be returning to site for re-induction.

The Complainant relied on a number of cases including Higgins v. Irish Rail, UD 480/2006; Maher v. Irish Permanent (No. 1) [1988] E.L.R.77; Bank of Ireland v. O’Reilly [2015] 26 E.L.R. 299; Samuel J. Frizelle v. New Ross Credit Union [1997] IEHC 137; and Bigaignon v. Powerteam Electrical Services Ltd [2012] 23 E.L.R. 195.

The Complainant – Evidence:

The Complainant submitted that on 30 June 2023, he was asked by the Site Manager to go to the eighth floor and disassemble the alloy tower. The Complainant submitted that the eighth floor was used as a “drop off” area and that when he was going up there, he did not know what he was going up to. He submitted that the Respondent should have had an SPA in place but he never saw nor signed it. The Complainant submitted that it is for the Site Manager to assess the hazards and talk to the team.

The Complainant submitted that as per his “Solas” documentation, his training was based on two people disassembling an alloy tower. He submitted that he was never asked to disassemble a tower on his own and that he does not know how to do so. The Complainant submitted that the usual procedure is that there is another operative on site, “with a ticket”, who can assist him. The Complainant submitted that the operative who usually helped him was dismissed the day before. The Complainant submitted that he did not question his Site Manager’s instructions and that he just did what he was told. He submitted that he was afraid of being let go if he did not follow the Site Manager’s instructions.

The Complainant submitted that while disassembling the alloy tower, he got a call from the Site Manager to stop working and to come down immediately. The Complainant submitted that he went to a meeting with the Health & Safety Manager and the Respondent’s Senior Contract Manager on Monday 3 July 2023. During that meeting he was asked about what happened on the previous Friday. The Complainant also submitted that during the meeting there “was talk of inhouse training.” The Complainant submitted that he then received a letter informing him that he was suspended.

The Complainant submitted that he also received emails from HR. He submitted that he was informed that he could have a colleague accompany him, but as his close friends had been made redundant, he did not think that anyone would assist him. He submitted that he was not provided with any documentation such as a witness statement.

The Complainant submitted that he attended the Appeal Hearing. He said that during the Appeal Hearing they discussed “other ways it could be sorted and other training”.

The Complainant submitted that he “knows what he did was wrong” and that he believed that “it was serious”. However, he submitted that the Respondent could have “gone a different way”, for example, he outlined that he could have been suspended without pay and retrained. He outlined that he is now seeking compensation.

The Complainant submitted that he was dismissed on 17 July 2023 and started a new job, involving metal work, on 24 July 2023. He is earning approximately €80 less per week. He has not looked for any other job.

Finally, the Complainant also submitted that he believed that he was also entitled to redundancy from the Respondent if they “had gone a different way”.

The Complainant – Cross-Examination:

The Complainant accepted that he was the designated site Safety Representative and that he was trained in Health & Safety. He accepted that if operatives had problems on site, they came to him. He accepted that he had to set a good example for everyone else.

The Complainant confirmed that he had disassembled an alloy tower previously. He also accepted that as a “banksman”, he installed glass and had bigger responsibilities.

The Complainant was referred to the “Solas Mobile Tower Scaffold” documentation that he had produced during the Hearing. The Complainant accepted that the practical test document indicated that the helper is only there for assistance and that the document does not state that a second person is required.  

The Complainant was also referred to the “Solas Practical Test Specifications Mobile Tower Scaffold” documentation which states that two persons are recommended but are not a requirement.

The Complainant stated that he was familiar with the 3T Method but that he has not used this method himself.

The Complainant stated that he could have done with assistance and that he always worked in pairs. He further submitted that he was not competent to disassemble the alloy tower by himself and only did it as the Site Manager told him to.

The Complainant accepted that as a trained Safety Representative, he deemed himself competent to dismantle the alloy tower on his own. The Complainant accepted that there were no hazards around the alloy tower on the eighth-floor balcony on 30 June 2023.

The Complainant accepted that he should not have stood on top of the platform without any handrails.

The Complainant submitted that the Site Manager has never asked another “subbie” to help him. The Complainant accepted that he did not ask HR or the Employee Assistance Programme or his Site Manager for help.

The Law:

Section 6(1) of the Unfair Dismissals Act 1977, as amended (the “UD Act”) provides that “the dismissal of an employee shall be deemed, for the purposes of this Act, to be an unfair dismissal unless, having regard to all the circumstances, there were substantial grounds justifying the dismissal.”

Section 6(4) of the UD Act states:

“Without prejudice to the generality of subsection (1) of this section the dismissal of an employee shall be deemed, for the purposes of this Act, not to be an unfair dismissal, if it results wholly or mainly from one or more of the following:

(a)   the capability, competence or qualification of the employee for performing work of the kind which he was employed by the employer to do,

(b)   the conduct of the employee,

(c)    the redundancy of the employee, and

(d)   the employee being unable to work or continue to work in the position he held without contravention (by him or by his employer) of a duty or restriction imposed by or under any statute or instrument made under statute.”

Section 6(6) of the UD Act states:

“In determining for the purposes of this Act whether the dismissal of an employee was an unfair dismissal or not, it shall be for the employer to show that the dismissal resulted wholly or mainly from one or more grounds specified in subsection (4) of this section or that there were other substantial grounds for justifying the dismissal.”

Section 6(7) of the UD Act states:

“Without prejudice to the generality of subsection (1) of this section, in determining if a dismissal is an unfair dismissal, regard may be had [….]

(a) to the reasonableness or otherwise of the conduct (whether by act or omission) of the employer in relation to the dismissal, and

(b) to the extent (if any) of the compliance or failure to comply by the employer, in relation to the employee, with the procedure referred to in section 14 (1) of this Act or with the provisions of any code of practice referred to in paragraph (d) (inserted by the Unfair Dismissals (Amendment) Act, 1993) of section 7 (2) of this Act.”

Section 14(1) of the UD Act refers to such dismissal procedure as was furnished to the employee upon entering the contract of employment.

Section 7(2) of the UD Act provides that an Adjudication Officer may consider “compliance or failure to comply by the employer in relation to the employee, with the procedure referred to in subsection (1) of section 14 of this Act or with the provisions of any code of practice relating to procedures regarding dismissal approved of by the Minister”.

The combined effect of the above provisions is to place the statutory burden of proof on the Respondent to show that: the reason for the dismissal was substantial and/or within the parameters of Section 6(4); and that it acted reasonably and in accordance with its disciplinary procedure or relevant code of practice.

Band of Reasonableness:

It is well-established that it is not the function of an Adjudication Officer to re-investigate disciplinary complaints or to substitute their view for that of a respondent employer. Rather the focus is whether the decisions arrived at are reasonable, based on the information available. The Labour Court summarised this rationale in Clancourt Management Ltd T/A Clancourt Management v. Mr Jason Cahill, UDD2234, 27 May 2022:

“In cases under the Unfair Dismissals Act where misconduct is stated as the basis for dismissal the test for this Court is that which was set by Lord Denning in the British case of British Leyland UK Ltd v. Swift (1981) IRLR 91, to determine if the dismissal falls into a ‘band of reasonableness’, a test which was confirmed in this jurisdiction in Foley v. Post Office (2000) ICR1283. Lord Denning stated that ‘If no reasonable employer would have dismissed him, then the dismissal was unfair. But if a reasonable employer might have dismissed him, then the dismissal was fair.’ He went on to describe ‘a band of reasonableness’, within which one employer might reasonably take one view; another reasonably take another view but ‘If it was quite reasonable to dismiss him, then the dismissal must be upheld as fair; even though some other employers may not have dismissed him’. Therefore, the test for the Court in cases where misconduct is stated to be the basis for dismissal is to ask does the decision to dismiss fall into this band of reasonableness? […] It is not the function of the Court to re-investigate disciplinary complaints. In looking at the outcomes of the investigations, the Court needs to consider if the decisions arrived at are rational, based on the information available to the investigators.”

Notably, as held in the same case, “a failure to adhere to proper procedures renders a dismissal outside a band of reasonableness”.

Fair Procedure:

The key purpose of a disciplinary procedure is to afford an employer the opportunity to set out the concerns it may have about the conduct or poor performance of an employee and at the same time, afford the employee the opportunity to answer the allegations and make representations as to why he/she should not be disciplined or dismissed. This is enshrined in S.I. No. 146/2000 - Industrial Relations Act, 1990 (Code of Practice on Grievance and Disciplinary Procedures) (Declaration) Order, 2000.

Findings and Conclusion:

It was common case that on 30 June 2023, the Complainant sought to disassemble an alloy tower located on an eighth-floor balcony, by standing on top of the frame, without guardrails. He posed not only a risk of serious harm and/or death to himself, but also to those below him. It was also common case that the alloy tower could be disassembled safely by one person, using the 3T Method.

The Complainant’s Actions:

I note that the Complainant was the only person onsite “holding a ticket” concerning the assembling and disassembling of alloy towers. He was also the only person with the knowledge of his own capabilities and limitations. It was for the Complainant to tell his Site Manager that he could not complete the task alone and / or that he had not been trained in the 3T Method. Instead of doing so, the Complainant took serious Health & Safety risks for himself and others. The Complaint’s actions are even more concerning in view of his role and responsibilities as the designated site Safety Representative. In his own evidence, the Complainant stated that he “knows what he did was wrong” and that he believed that “it was serious”.

In terms of the Complainant’s proffered mitigating factors, I note that there was no evidence to suggest that he would lose his job if he did not complete the task alone, as he alleged.

Fair Procedure:

I also note that there are two particular shortcomings of concern regarding the fair procedure afforded to the Complainant. These shortcomings are in breach of S.I. No. 146/2000 - Industrial Relations Act, 1990 (Code of Practice on Grievance and Disciplinary Procedures) (Declaration) Order, 2000 (referred to above):

Firstly, the Respondent failed to put to the Complainant the full details of the charge against him, in accordance with S.I. 146/2000. In this regard, I note that the Complainant was not provided with a copy of the Investigation Meeting minutes or with the Site Manager’s witness statement in advance of the Disciplinary Hearing.

Secondly, in accordance with S.I. 146/2000, the Complainant was entitled to be represented by a colleague of his choice or a trade union official. I note that the Complainant waived his right to representation at both the Investigation Meeting and the Disciplinary Hearing. However, on the Complainant’s evidence, he believed that only a fellow employee could accompany him by way of representation. Moreover, I note that the Respondent’s “Disciplinary Rules and Procedures” refer to being accompanied during the Disciplinary Procedure by a “fellow employee”; the Respondent’s letter to the Complainant dated 3 July 2023 concerning the Investigation Meeting, refers to a “support person”; the Respondent’s letter to the Complainant dated 7 July 2023 concerning the Disciplinary Meeting refers to a “fellow employee”; and the Respondent’s email to the Complainant dated 12 July 2023 concerning the Appeal Hearing, refers to a “fellow employee”.

Additionally, I note that it is recorded in the Disciplinary Meeting minutes, that the Complainant sought clarification that he could “bring in anyone to represent [him]” at the Appeal Hearing, if there was one. The Complainant was subsequently represented by a SIPTU official at the Appeal Hearing.

While the HR Manager outlined in her evidence that the Complainant knew what he was entitled to, I do not accept that this was the case. In view of the gravity of the charge against him, it was incumbent on the Respondent to ensure that the Complainant knew that he could have been accompanied by a colleague of his choice or a trade union official, throughout the disciplinary process.

In the circumstances, I find that the Respondent failed to afford the Complainant fair procedure and that this failure rendered the dismissal outside the band of reasonableness and therefore unfair.

Conclusion:

In conclusion I find that the Complainant’s dismissal was unfair and therefore the complaint is well founded.

The Respondent did not afford the Complainant fair procedure. However, as outlined above, there was convincing evidence to show that the Complainant, through his own actions, contributed significantly to his dismissal.

Moreover, I note that the Complainant started a new job approximately one week after his dismissal. While the Complainant earns approximately €80 less per week in this job, I note also that he has not looked for any other job.

In the circumstances, I order the Respondent to pay the Complainant compensation in the amount of €1,597 (approximately two weeks’ pay).

CA-00059606-001 - Complaint seeking adjudication by the Workplace Relations Commission under Section 8 of the Unfair Dismissals Act, 1977:

For the reasons outlined above, I find that the Complainant was unfairly dismissed and that this complaint is well founded. I order the Respondent to pay the Complainant compensation in the amount of €1,597.

Unfair Dismissals Acts 1977 – 2015, Gross Misconduct, Fair Procedure.