ADJUDICATION OFFICER DECISION

Adjudication Reference:  ADJ-00051601

Parties:

Complaint:

Date of Adjudication Hearing:  29/08/2024

Workplace Relations Commission Adjudication Officer:  Gaye Cunningham

Procedure:

In accordance with Section 41 of the Workplace Relations Actand Section 79 of the Employment Equality Acts, 1998 - 2015,following the referral of the complaint to me by the Director General, I inquired into the complaint and gave the parties an opportunity to be heard by me and to present to me any evidence relevant to the complaint.

Background:

The complaints in this case are that the Respondent discriminated against the Complainant on grounds of disability, and they failed to provide reasonable accommodation and that the Complainant was subjected to victimisation. 

Summary of Complainant’s Case:

The Complainant gave evidence under affirmation summarised as follows:

He stated that he is autistic.  He was employed by the Respondent from 16th March 2022 and resigned his employment on 7th June 2024.  He referred to his autism on his application for employment but did not require special or reasonable accommodation at the time.

However, having worked in the environment and especially in the last number of months, his mental health deteriorated, and he was seeking reasonable accommodation from his manager.

He described the impact of autism on his life.  It is sometimes an invisible disability, the person can have difficulties with eye contact, can experience meltdowns and have symptoms of morbidity and depression.  He had meltdowns and significant deterioration of his mental health in the last months of his employment.  He contends that he told his manager on many occasions he was having severe difficulties and described episodes relating to the situation.  He had a particular difficulty on 22 October 2023 and had to leave his shift early.

On 24 October 2023, the GM (Ms S) sent an email to the Complainant expressing her concern about his well-being and seeking him to get medical help and provide information on what support could be provided by the Respondent.

The Complainant replied on 25 October 2023 addressing the performance issues raised (not being able to complete his shift).  He advised the GM of the deterioration in his mental health and the lack of support from the Respondent.

On 28th October 2023, the Complainant emailed the GM and HRM stating among other things, that he had been rostered for 5 closes, 4 consecutive closes and 1 day off between.  He again drew attention to his mental health decline and advised that he was going to his doctor and would be unable to come to work the scheduled shifts for 28th, 29th, 30th and 31st October 2023.

The GM responded on 28 October stating that she emailed him on 24th October to express her concern and that she would be happy to discuss his concerns on his return to work.

On 31st October 2023, he emailed with a doctors cert certifying him on sick leave from 28th October to 26th November 2023.

On 9th November 2023, he emailed the AM and HRM expressing his discomfort with dealing with the GM, that she had refused his reasonable accommodation requests and he requested a reply by 17th November to schedule a meeting to discuss.

The parties met on 17th November 2023.  There was some disagreement about the minutes and the Complainant issued his notes on it.

On 23rd November 2023, the Complainant emailed the HRM to say he was certified sick until 8th January 2024 and that he had not yet received the transcribed notes of the 17th November 2023 meeting.

In January 2024 there were emails exchanged between the Complainant and the HRM regarding return to work and a referral to Occupational Health. 

On 6th January the Complainant submitted a cert marking him unfit for work until 4th February 2024.

On 11th January 2024, the HRM emailed the Complainant confirming that an OH appointment was being scheduled for 29th January 2024.  This email also confirmed the Complainant’s grievances as outlined in the meeting of 17th November 2023, being:

Request for consistent scheduling

2 days off to rest and recover

Not being placed on exclusively closes.

On 2nd February 2024, the Complainant submitted a medical certificate certifying him unfit for work from 3rd February to 29th March 2024.  He expressed his frustration at the OH situation where he had to explain his situation again and the same to his GP and the same to the Respondent.  He expressed his concern at the length of time it was taking to address his requests.

Emails were exchanged between the HRM and the Complainant for over 6 months and at the end of which the Complainant felt that he was getting nowhere and he decided to take his case to the WRC.

The Complainant’s wife gave evidence under affirmation.

She stated that she had an interaction with the General Manager Ms S on ‘Batman Day’ in September 2023 during which they discussed the Complainant’s mental health.  She stated that Ms S expressed concern about the deteriorating situation over the previous 12 months.  She shared her own concerns with Ms S and emphasised that he needed accommodations he had been seeking for some months due to his disability and that he was not receiving adequate rest periods between shifts. She contended that Ms S remarked that she did not consider Autism a disability but a ‘superpower’.   The witness explained that, although she understood the GMs intention might have been to highlight positive aspects of autism (as she explained she has family members with autism and other intellectual disabilities), her comments were inappropriate given the context of the conversation and the challenges her husband was facing. She stated that this exchange highlights a concerning misunderstanding and unwillingness to acknowledge both her husband's disability, and the necessity of reasonable accommodations for him in the workplace, by his direct manager.

Summary of Respondent’s Case:

The Respondent strongly refutes the claim in its entirety. Firstly, the Respondent contends that the Complainant has failed to demonstrate that he was treated less favourably than a person of a different status as per the grounds of discrimination specified by the Complainant. Furthermore, the Complainant was not victimised as a result of pursuing or threatening to pursue a claim under the legislation. In addition, reasonable accommodations were indeed implemented by the Respondent. The Respondent respectfully requests that the claim fails.

The incorrect Respondent has been named on the complaint form for this complaint. The Respondent would respectfully request this be corrected on record to reflect the correct Respondent “Omniplex Cork Limited”.

Prima facie case

It has been the well-established practice of the Equality Tribunal and the Labour Court to require a Complainant to present, in the first instance, facts from which it can be inferred that he was treated less favourably than another person is, has been, or would be treated, on the basis of the discriminatory ground cited.

Section 85A of the Act provides that:

“where in any proceedings facts are established by or on behalf of a complainant from which it may be presumed that there has been discrimination in relation to him or her, it is for the respondent to prove the contrary”.

This requirement has been explored in a number of cases included the case of Melbury Developments Limited v Arturs Valpeters (EDA0917) wherein the Labour Court stated as follows:

“Section 85A of the Act 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”.

Case law was cited including Margetts v Graham Anthony & Company Limited, EDA038 the evidential burden which must be discharged by the complainant before a prima facie case of discrimination can be said to have been established was further outlined by the Labour Court. The Labour Court stated as follows: “The mere fact that the complainant falls within one of the discriminatory grounds laid down under the Act is not sufficient in itself to establish a claim of discrimination. The complainant must adduce other facts from which it may be inferred on the balance of probabilities that an act of discrimination has occurred.”

In the instant case, the Complainant has alleged discrimination on the grounds of disability and failing to provide reasonable accommodation for a disability but has hitherto produced not a shred of evidence to support this allegation. The Act under s2 (1) defined disability as follows:

“In this Act, unless the context otherwise requires— ... “disability” means —

(a) the total or partial absence of a person’s bodily or mental functions, including the absence of a part of a person’s body,

(b) the presence in the body of organisms causing, or likely to cause, chronic disease or illness,

(c) the malfunction, malformation or disfigurement of a part of a person’s body,

(d) a condition or malfunction which results in a person learning differently from a person without the condition or malfunction, or

(e) a condition, illness or disease which affects a person’s thought processes, perception of reality, emotions or judgement or which results in disturbed behaviour, and shall be taken to include a disability which exists at present, or which previously existed but no longer exists, or which may exist in the future, or which is imputed to a person;”

The Complainant has not produced any evidence that such discrimination occurred and has failed to name a comparator against which such alleged unequal treatment may be judged. Furthermore, he has not set out how this alleged unequal treatment influenced the behaviour and decision making of the Respondent such that it resulted in the Complainant being the victim of discrimination.

The Respondent submits that it is only when the Complainant has discharged this burden to the satisfaction of an Adjudication Officer that the burden shifts to the Respondent to rebut the inference of discrimination raised. The Respondent submits that the Complainant has failed to discharge this burden of proof and, consequently, the claim cannot succeed.

Reasonable Accommodation

Section 16 of the Employment Equality Acts requires an employer to take appropriate measures to facilitate persons with disabilities in accessing and participating in employment unless those measures would impose a disproportionate burden on the employer. The Act provides non exhaustive examples of “appropriate measures” which include the adaptation of premises and equipment, patterns of working time, the distribution of tasks or the provision of training.

The Respondent refers to the Supreme Court decision in Nano Nagle School v Daly [2019] IESC 63 at paragraph 84 where it confirms:

“But s. 16(3)(b) explicitly identifies the mandatory primary duty of an employer. He or she shall take appropriate measures where needed in a particular case to enable a disabled person to have access to employment, to participate and advance in employment, and to undergo training unless these measures would impose a disproportionate burden. Section 16(4) then goes on to identify what appropriate measures should be taken. Although the definition is somewhat repetitive and circular, what is identified are effective and practical measures, where needed in a particular place, to adapt the employers place of business, including the premises, equipment, patterns of working time, and distribution of tasks or the provision of training or integration resources, but does not include any treatment facility or thing that the person might ordinarily or reasonably provide for himself or herself.”

The Supreme Court in Nano Nagle School v Daly [2019] IESC 63, held that employers were obliged to consider all appropriate measures which could be undertaken to provide reasonable accommodation and to demonstrate, if no such measures were taken, that this was only because those measures would be disproportionate or unduly burdensome. The Supreme Court did accept that:

“The test is one of reasonableness and proportionality: an employer cannot be under a duty entirely to re-designate or create a different job to facilitate an employee” and that in most instances “removing all the duties which a disabled person is unable to perform” would inevitably become a disproportionate burden.

As soon as the Complainant completed an occupational health assessment which provided medical reasonable recommendations HRM Mr F communicated with the Complainant extensively with suggestions of how the accommodations could be facilitated in work and welcomed the Complainant’s feedback on same. Throughout the process the Complainant’s opinion and thoughts on the suggestions were valued and considered.

The Complainant was employed by the Respondent from 10th of March 2022 as a Supervisor and on the 1st of February 2023 he was promoted to Duty Manager.

In March of 2023, the Complainant made a request to use noise reducing earplugs called loops in work. He advised he used them at home already. The Respondent agreed to this request and the Complainant advised it helped with over-stimulation in work.

On the 24/10 /2023, following an issue involving the breakdown of a projector in the cinema the Complainant who was the Manager in charge at the time contacted General Manager Ms S who was working in another cinema by phone advising his shift was due to end soon and he would not be staying to assist resolving the issue. While not expected to stay beyond a scheduled shift, as the duty manager in charge if there was an issue of concern effecting trading it would be expected the most experienced and senior person onsite would provide support within reason. Any additional time worked would always be available to take at another time.  Ms S observed this decision to leave site in the middle of a serious issue was somewhat out of character for the Complainant. Ms S emailed the Complainant expressing her concern for his mental health and outlining the supports available through the employee assistance programme (EAP). Along with this Ms S asked for the Complainant to ‘’provide the company with the correct information on how we may best support you’’ and suggested he seek medical advice.

Mr F and the Complainant met on the 13/02/24. In this meeting the Complainant queried his right to SSP for 2024. The agenda for the meeting was to:

• To discuss the occupational health assessment.
• Update the Complainant on the on-going grievance process.
• Discuss recommendations made by Occupational Health.
• Suggest next steps.

On the 22/02/24, Mr F emailed the Complainant to further discuss the suggested reasonable accommodations made by the Occupational Health Assessor and to look for the Complainant’s feedback. Mr F provided the current Respondent opening times and asked “Can I ask is there particular days you would prefer as your days off? On a consistent roster is there a particular schedule you had in mind based on the current cinema opening hours?’’. In relation to the quiet space suggestion Mr F proposed the canteen as an acceptable quiet space or a room that is next to the Management office. In this email Mr F welcomed the Complainant’s feedback on the Respondent’s suggestions to accommodate the accommodations.

On the 26/02/24, the Complainant responded to Mr F and set out “In terms of a consistent schedule, I would initially suggest Tuesday-Saturday having Sunday and Monday off. This would allow for the delivery shift on a Tuesday morning as it is a quieter, less intense shift, closing Wednesday - Friday during shorter hours with the possibility for change during extended opening hours and the opportunity for morning/mid shifts on Saturday… The office next to the managers office is where I have been using as a quiet space so feel that would be best’’.

Mr F contacted the Complainant on the 13/03/24 setting out some examples of rosters for the Complainant’s consideration. Mr F said “Regarding a consistent schedule, thanks for your initial suggestions. I see the logic in your proposed schedule from your perspective. To try and balance your request with maintaining adequate cover can you consider the following and let me know your thoughts’’

Friday & Monday - late shifts. Tuesday - Early shift as needed. Wednesday & Thursday - days off. Saturday & Sunday mix of early, mid & late shifts. Weekend shifts could be structured to account for such things as avoiding early opening after a late and possibly putting an agreed rotation in place repeating the same shifts over 2/4 weeks to give some predictability to shifts. Allowing for change maybe at peak times or covering leave/absence.

If splitting days off is an option - Monday & Wednesday - days off. This would remove issue of early opening after a late shift. Tuesday - Early. Thursday & Friday - late shifts. Saturday and Sunday as per above.

Mr F re-confirmed this would be under review and could be adapted in the future. The aim behind this was to find a working solution for both parties with an option to review recommendations.

On the 20/03/24, the Complainant replied to this email advising that one day off at a time is not sufficient for rest and recreation and that the suggestion of closing on a Monday and opening on a Tuesday due to the time limits between the shift would not be sufficient.

On the 27/03/24, Mr F replied to this email with a copy of the Complainant’s new occupational health report and setting out numerous options for his comments on requests for shift times, mixture of closing and opening shifts, a quiet space, short regular breaks and consecutive days off.

Mr F reminded the Complainant in this email of the Respondent’s intention in the process and an update on the employee’s grievance. “Omniplex is acting in good faith to find solutions to facilitate your return to work while looking into the issues you have raised. The grievance you raised containing approx. 15 extensive allegations/issues is being investigated in fully’’.

In this email Mr F also informed the Complainant he had looked into the Complainant’s other concerns. Mr F set out the below information.

• Breach of Right to disconnect Policy - This has been explained.
• Issue regarding a leak in the Canteen - This has been looked into.
• Expectation to complete work/training, specifically referring to online training (Learn Upon) - This has been explained.
• Issues you expressed around dealing with aggressive customers have been given feedback and new supports are in development.

Mr F closed the email with inviting the Complainant again to let him know about these considerations, as well as to let him know if he had alternative considerations and set out in the next meeting, he would like to discuss what the Complainant’s return to work may look like. This further highlights the Respondents continuous attempts to get the Complainant back to work and find a solution.

On the 01/04/2024, the Complainant emailed Mr F in response to his suggestions. He set out he was not happy with the scheduling options due to the limited time off between the shifts, he advised Monday and Tuesday as days off as agreeable but the fact it’s under review concerned him and frustrated him. In this email he also notified the Respondent he was lodging a claim to the WRC and sending a form ES1.

After the Complainant visited occupational health on the 14th of March 2024, Mr F again emailed him with some more options and considerations for the reasonable accommodations suggested by the occupational health assessment. ‘’Alternative suggestion for 2 Consecutive days and Mixture of closing and non-closing shifts. Monday & Tuesday off. Wednesday to Friday late shifts (open to change during fulltime opening hours). Saturday & Sunday at least one early shift and remaining mix of early, mid, or late if/as required. As Monday to Thursday are generally off-peak trading any combination of these days off could potentially be accommodated’’.

On the 30/04/24, the Complainant did not accept the invitation to discuss matters with Mr F but advised he thought his answers in the forms (ES1 forms had been sent to the Respondent) contradicted themselves and that because of this he was submitting a complaint to the WRC.

On the 22/05/24, Mr F emailed the Complainant advising it was regrettable both parties could not come to an agreement in resolving the issue but that the Respondent still remained committed to finding a solution and welcomed the Complainant’s engagement however noted in the emails on 01/04/24, 29/04/24 and 30/04/24 the Complainant had advised he would no longer engage with the Respondent and wished to go through the WRC. Mr F advised to avoid any possible misunderstanding of the Respondent’s desire to engage as harassment he would defer any further contact to such time as the Complainant would like to engage.

On the 23/05/24, the Complainant lodged a claim to the WRC under Section 77 of the Employment Equality Act 1998.

On the 04/06/24, the Complainant submitted medical certs for the 29/03/24 – 31/05/24 and 31/05/24 – 30/06/24.

The Complainant resigned from employment on 6 June 2024.

It is the Respondent’s position that internal workplace procedures were not given time to conclude and the Complainant chose to not fully utilise them. The Respondent was fully committed to finding a workable solution guided by medical advice on how best to implement the reasonable accommodations. Throughout the process the Respondent made reasonable efforts to try find a solution.

The Respondent would rely on Sales Assistant v Retailor DEC-E/2016/119. In this case the company submitted that at all times they treated the worker reasonably in relation to her ailment. The Court outlined that it was clear that numerous interactions took place between the former employee and the company following her return from sick leave and that various adjustments to her working hours and conditions arose as a result of those interactions. In this case when the employee sought an accommodation other than an adaption to working hours the respondent sought medical advice. In addition to this, the company always responded to the medical advice supplied. In its decision, the Court found that “No failure of the employer to take appropriate measures in accordance with Section 16(3)(b) of the Act inhibited the capability of the worker to participate in her employment.”

It is evident from this case that an employer can only go as far as medical opinion will allow when putting ‘appropriate measures’ in place. Similar to this case the Respondent engaged extensively with the Complainant and been guided by medical guidance. At every stage of the process the Respondent consulted with the Complainant on the medical advice given and sought their feedback.

Conclusion

The burden of proof rests with the Complainant to show that he has been treated less favourably on the grounds specified. It is the Respondent’s position that the Complainant has failed to provide facts from which it may inferred that discrimination has occurred and has therefore failed to establish a prima facie case of discrimination. The Respondent engaged with the Complainant extensively in order to find a solution and get the Complainant back to work. After April 2024, the Complainant refused to engage with the Respondent on the matter. The Respondent respectfully submits that the claim must fail.

Evidence on affirmation was given by the GM Ms S.

She denied she ever used the term ‘superpower’ in relation to autism.  She stated that her only concern was for the Complainant and when she emailed him on 24 October 2023 this was her primary concern.  She said she had accommodated the Complainant on many occasions, for example by facilitating his day off to play dungeons and dragons.  She stated that she only ever had his welfare at heart.

Evidence was given on affirmation by the HR Manager (Mr F). 

He went through the efforts he made to accommodate the Complainant.  He stated that accommodating the rosters the Complainant wanted did provide some difficulties.  The Complainant was a Duty Manager.  Giving him every Sunday off would have an impact on another Duty Manager who would have to work every Sunday.        He agreed that a risk assessment was not carried out in relation to the Complainant.  He stated that the Complainant had 16 separate allegations in his grievance and the investigation took a huge amount of work.  The Complainant resigned before the completion of the grievance procedure.

Findings and Conclusions:

The complaints in this case are that the Respondent discriminated against the Complainant on grounds of disability, and they failed to provide reasonable accommodation.  There is also a further complaint of victimisation.  Section 98 of the Employment Equality Act provides for an offence where an employee is dismissed in circumstances amounting to victimisation. The complaint of victimisation is not well founded as the Respondent had not victimised the Complainant, he was not dismissed and he initiated proceedings in relation to his complaint at the end of his employment.

The applicable law

Section 6 (1) of the Act states:

“(1) For the purposes of this Act and without prejudice to its provisions relating to discrimination occurring in particular circumstances discrimination shall be taken to occur where—

(a) 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) (in this Act referred to as the ‘discriminatory grounds’) which—

(i) exists,

(ii) existed but no longer exists,     

(iii) may exist in the future, or

(iv) is imputed to the person concerned..

Section 6 (2) (g) states:

(2)  As between any 2 persons, the discriminatory grounds (and the descriptions of those grounds for the purposes of this Act are –

(g)   that one is a person with a disability and the other either is not or is a person with a different disability (in this Act referred to as “the disability ground”).

Disability is not in dispute.  The Complainant submitted a case that he was severely impacted by autism and this had negatively affected his working life.

Burden of Proof

In the first case, I will examine the issue of whether the Complainant has established a prima facie case, that is the establishment of facts from which the burden of proof, which lies in the first instance with the Complainant would shift to the Respondent.

Section 85A of the Employment Equality Acts 1998-2011 sets out the burden of proof as follows:

“(1) Where in any proceedings facts are established by or on behalf of a Complainant from which it may be presumed that there has been discrimination in relation to her or her, it is for the Respondent to prove the contrary.”

Put simply, the onus in the first instance lies with the Complainant to establish the primary facts from which it may be inferred that discrimination has occurred.  If these facts are established substantiated by evidence, the burden of proof then shifts to the Respondent to prove that discrimination did not occur.

The extent of evidential burden has been established by the Labour Court in The Southern Health Board v Dr Teresa MitchellDEE 011 where the Court found that the Complainant must:

“establish facts from which it may be presumed that the principle of equal treatment has not been applied to them.  This indicates that a claimant must prove, on the balance of probabilities the primary facts on which they rely in seeking to raise a presumption of unlawful discrimination.             It is only if these primary facts are established to the satisfaction of the Court, and they are regarded by the Court as being of sufficient significance to raise a presumption of discrimination, that the onus shifts to the respondent to prove that there was no infringement of the principle of equal treatment”.

In Elephant Haulage Ltd v GarbacevsThe Labour Court stressed that facts based on credible evidence were necessary to prove a prima facie case of discrimination and that “mere speculation or assertions, unsupported by evidence, cannot be elevated to a factual basis upon which an inference of discrimination can be drawn.”  The Court observed that the language of Section 85A admitted of no exceptions to the evidential rule laid down.

In this case, the Respondent submitted that the Complainant has not produced any evidence that such discrimination occurred and has failed to name a comparator against which such alleged unequal treatment may be judged. 

On the question of a comparator, in cases involving less favourable treatment, a comparator can be actual or hypothetical. (Determination EDA1310, Henry Denny v Rohan, in which the Labour Court followed the decision of the House of Lords to that effect in Shamoon v Chief Constable of the RUC [2003] IRLR 258). A hypothetical comparator can be constructed by asking why the complainant was treated as he was. If the treatment complained of was because of a protected characteristic, a hypothetical comparator is a person who does not have that characteristic. The Complainant in this case could be said to have been effectively deprived of the opportunity to continue in employment because of his disability. It follows that an appropriate comparator is a person in a similar role who does not have a disability or a person who has a different disability. In this case no named comparator with a different disability was put forward for consideration and therefore it follows that the appropriate comparator in this case is a person in a similar role who does not have a disability.     In this instant case, it is common case that accommodation was provided for pregnant employees and students in relation to arranging suitable shifts.  It appears that these employees were facilitated with shifts that suited their circumstances. No such accommodation was afforded to the Complainant and some of the reasons given were on account of his position as fulltime duty manager.  I find that as accommodations were provided to others, the Complainant has established a prima facie case.  The burden of proof now shifts to the Respondent to prove that discrimination has not occurred.

I do note the efforts made particularly by the HRM during a lengthy period between November and April to reach some agreement with the Complainant.  I can see that the matter was made more complicated by the 16 separate grievances of the Complainant which required a significant amount of work as stated in evidence by the HRM.  However, I find that the point regarding the acute needs of the Complainant, given his situation was not fully addressed.  I particularly note that the absence of certainty in relation to 2 consecutive days off to allow for adequate rest in the circumstances caused a significant difficulty for the Complainant.  The Occupational Health Reports on the Complainant make the requirements for consistency and rest clear in that regard.

I find on the evidence and submissions, that the Respondent discriminated against the Complainant by failing to provide him with reasonable accommodation in relation to his disability.

I award the Complainant the sum of €12,000 compensation for the effects of the discrimination.

I further require the Respondent to engage awareness training or workshops in an effort to introduce a positive management approach to staff with neurological complex conditions such as autism.

Decision:

Section 41 of the Workplace Relations Act 2015 requires that I make a decision in relation to the complaint  in accordance with the relevant redress provisions under Schedule 6 of that Act.

Section 79 of the Employment Equality Acts, 1998 – 2015 requires that I make a decision in relation to the complaint in accordance with the relevant redress provisions under section 82 of the Act.

I have decided that the Respondent discriminated against the Complainant by failing to provide him with reasonable accommodation in relation to his disability.

I award the Complainant the sum of €12,000 compensation for the effects of the discrimination.

I further require the Respondent to engage awareness training / workshops for Management in an effort to introduce a positive management approach to staff with neurological complex conditions such as autism.

Dated:   29-10-24

Workplace Relations Commission Adjudication Officer:  Gaye Cunningham

Key Words: