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Advisory, Conciliation and Arbitration Service (Acas)

P-002308 · Statement · Decision date: 8 November 2023 · View Advisory, Conciliation and Arbitration Service scorecard
Complaint (AI summary)
Mrs X alleged ACAS provided incorrect advice about a 'TUPE transfer' and the impact of signing a conciliation agreement, causing her employment tribunal claim to fail.
Outcome (AI summary)
The ombudsman acknowledged ACAS made mistakes, but found it had already taken sufficient steps to resolve the issue, and closed the complaint.

Full decision details

The Complaint

4. Mrs X complains that ACAS did not recognise that a ‘TUPE transfer’ had happened on 6 April 2021, and it gave incorrect advice on the effect of signing a conciliation agreement (COT3) on her employment tribunal (ET) claim.

5. TUPE is the Transfer of Undertakings (Protection of Employment) Regulations 2006. The regulations protect employees’ rights when an organisation transfers from one employer to another and when a service transfers to a new provider.

6. Early conciliation is when ACAS helps to settle a dispute and reach an agreement, so a case does not need to go to ET. An agreement is written up in a statement called a COT3.

7. Mrs X tells us that following advice and signing the COT3 led to her claim being unsuccessful and she lost out on over £11,000. This has caused her stress and frustration.

8. Mrs X would like ACAS to pay her the £11,000.

Background

9. Mrs X was a live-in hospitality manager and in November 2020 her employer decided to close the business and hand back the tenancy.

10. At the same time, Mrs X had concerns about how she had been treated by the last business owner (‘the First Respondent’) and started proceedings with the ET for holiday pay and unlawful deductions from wages.

11. After the new owner (‘the Second Respondent’) decided they did not want a live-in manager and ended her employment, on 2 August 2021 Mrs X started a set of proceedings against them for unfair dismissal, a statutory redundancy payment, holiday pay and unlawful deductions from wages.

12. Before making an ET claim an individual must contact ACAS and it will offer early conciliation.

13. Conciliation can continue after the matter has been lodged at the ET to try and resolve the matter before a hearing. ACAS did this for the claims against both respondents.

14. Mrs X at first instructed solicitors to help with her claims, but she says she was unable to keep them during the ET process because of the costs. She tells us she relied on the help from ACAS.

15. Mrs X reached an agreement with the Second Respondent on 21 September 2021, which was confirmed by signing a COT3 conciliation agreement.

16. She tells us she signed the COT3 as ACAS told her that it would not affect her claim against the First Respondent.

17. The matter went to an ET hearing on 15 December 2022. The judge held that the First Respondent was no longer responsible for the losses claimed because a transfer of the business and all its employees had happened on 6 April 2021 (a TUPE transfer).

18. This means the judge found that the First Respondent did not have any responsibilities as an employer because they had all been transferred to the Second Respondent. It meant Mrs X could only get an award for further losses from the Second Respondent, who she had already signed an agreement with.

19. The judge also said the terms of the COT3 agreement meant Mrs X could no longer make her claim against the Second Respondent. This is because it was in full and final settlement of all claims ‘arising out of or in connection with the claimant’s employment with the respondent or its termination’. Mrs X’s claims against both respondents were dismissed.

20. Mrs X complained to ACAS on 10 January 2023. She said it told her that signing the COT3 would not affect her claim against the First Respondent and she would not have signed it if she had known she would lose her claim.

21. She said she did not understand how the case was allowed to continue against the First Respondent, when the TUPE transfer had transferred all responsibilities to the Second Respondent.

22. During the complaints process ACAS accepted its staff had given incorrect advice, but it did not agree to pay her compensation for her claimed losses.

Findings

25. When considering a complaint, we look at whether there are signs that the organisation made a mistake that had a negative impact. If so, we think about whether the organisation has taken steps to put things right. Having done this, we can see ACAS has already done enough to acknowledge the impact of the errors it made.

26. We have considered why Mrs X is still unhappy after getting the final response to her complaint, where ACAS said it could not accept that it was responsible for her losing money and should make a payment to her.

27. It explained to Mrs X that its conciliators (staff who deal with these cases) are not legally trained and are unable to give legal advice. It said the conciliator she dealt with explains to parties that they cannot give legal advice and recommends for them to get legal advice before entering into an agreement.

28. Mrs X feels ACAS has been very dismissive in how it replied to her complaint and she would like the money she believes she lost because of its failures.

29. She also says its complaint responses do not address its failure to recognise that a valid TUPE transfer had happened on 6 April 2021.

30. We can see that ACAS gave an apology and acknowledged that it had given incorrect advice that had influenced her decision to sign the COT3. It said it would use the points she had raised to improve its training and guidance for conciliators.

31. We agree this shows there has been service failure. Our ‘Principles of Good Administration’ expect organisations to be ‘open and accountable’ by ‘providing information and, if appropriate, advice that is clear, accurate, complete, relevant and timely.’

32. When thinking about if ACAS has done enough to put things right, and if it should have compensated Mrs X, we looked at its role and what information is publicly available about what service users can expect.

33. ACAS’s online guidance on conciliation explains:

‘ACAS conciliators can:

• explain the conciliation process • talk through the issues with both sides • talk through possible options • discuss how you may be able to solve the dispute without going to tribunal.

Conciliators are not able to:

• take sides • represent either side • tell you whether to agree on a settlement • say how strong or weak your case is • help you prepare your case for tribunal • make a judgement on how your case could turn out’.

34. This means that ACAS was correct to tell Mrs X that its advice was not legal advice or comments on how successful her case may be at ET. It explained it had appropriately warned her that service users should not rely on its advice in place of professional legal advice and they should follow it at their own risk.

35. Mrs X disagreed and said the judge at the ET decided the advice she had from ACAS was enough to satisfy the requirements of a settlement agreement in employment law. She says this means she had the right to rely on its advice.

36. We understand that the judge’s analysis on this point will have given Mrs X cause to believe that ACAS should be held responsible for the consequences of her acting on its advice. We considered this carefully, mindful that it is not our role to comment on a judicial decision.

37. We can see that the judge’s findings amount to their own interpretation of the relevant rules and legislation and this is separate to commenting on the quality of that advice or what a service user can expect from ACAS.

38. We agree that ACAS gave incorrect information to Mrs X. This does not mean it should have identified that a TUPE had happened and that this would affect her claim against the First Respondent. We understand the level of legal analysis needed would be outside of its role as explained above and can only be given by a legally trained professional.

39. As ACAS has correctly told Mrs X, those issues were legal questions for the ET to answer and it rightfully deferred to the judge. ACAS cannot be held responsible for the judicial decisions that were made and we cannot agree that its service failure caused the impact Mrs X has described.

40. This means we cannot say what the outcome of the ET might have been, even if no mistake had happened and Mrs X had been given different advice from ACAS. It is possible that the judge may have decided that Mrs X was not entitled to any further compensation, even if nothing had gone wrong with ACAS’s communication.

41. We can only say that it should not have told her that signing the COT3 would have no impact. In our view, the impact of ACAS’s poor service is avoidable frustration and distress to Mrs X, as it raised her expectations and this led to disappointment.

42. In apologising to Mrs X, acknowledging the impact on her and assuring her that learning had been taken from her experience, we can see that ACAS has provided a ‘fair and accountable’ response to her concerns in line with our UK Central Government Complaint Standards. We think this is enough and we are not asking it to do more.

43. We understand Mrs X was unable to continue funding legal support and this meant she had to rely on ACAS. We are sorry this meant she was unable to get the kind of specialist advice she needed at that time and that it led to her feeling she has been denied a fair outcome.

44. If Mrs X is still unhappy and if her circumstances allow, she could explore what legal options she has. We hope our explanation is helpful to Mrs X and we wish her well.

Our Decision

1. We have carefully considered Mrs X’s complaint about Advisory, Conciliation and Arbitration Service (ACAS) and we are sorry to learn about her experience. It is clear her recent legal action and ACAS complaint has been stressful.

2. We can see that ACAS did make mistakes but we think it has done enough to put things right. We cannot ask it to give the specific outcome that Mrs X wants.

3. We will not take any further action and explain our decision below.

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