Atlas African Industries Limited (ATLAS.ke) listed on the Nairobi Securities Exchange under the Industrial holding sector has released it’s 2014 prospectus For more information about Atlas African Industries Limited (ATLAS.ke) reports, abridged reports, interim earnings results and earnings presentations, visit the Atlas African Industries Limited (ATLAS.ke) company page on AfricanFinancials.Document: Atlas African Industries Limited (ATLAS.ke) 2014 prospectus Company ProfileAtlas African Industries Limited, formerly Atlas Development & Support Services Limited, is focused on utilizing its African operational expertise to build a business based on the provision of support services and the investment in and development of industrial projects with a focus on Ethiopian consumer market. The Company’s subsidiary, East Africa Packaging Holdings, is focused on building a bottle manufacturing facility approximately 45 kilometers north of Addis Ababa, Ethiopia (the Chancho Project). The Company was engaged in providing development and support service solutions across Africa.
Stanbic IBTC Bank (IBTC.ng) listed on the Nigerian Stock Exchange under the Banking sector has released it’s 2015 presentation results for the half year.For more information about Stanbic IBTC Bank (IBTC.ng) reports, abridged reports, interim earnings results and earnings presentations, visit the Stanbic IBTC Bank (IBTC.ng) company page on AfricanFinancials.Document: Stanbic IBTC Bank (IBTC.ng) 2015 presentation results for the half year.Company ProfileStanbic IBTC Plc is a financial services company in Nigeria offering banking products and services for the retail, corporate, investment and wealth management sectors. The Personal and Corporate Banking division provides a full-service offering ranging from transactional accounts to residential accommodation loans, vehicle and equipment finance and instalment finance. The Corporate and Investment Banking division offers products and services for foreign exchange, fixed income and equity trading as well as transactional banking, corporate and property lending and custodial and trade finance services. The Wealth Management division provides services for investment management, pension management, portfolio management, unit trust/fund management and trusteeship services. Stanbic IBTC Holdings Plc undertakes venture capital projects and private equity investments; acts as an executor and trustee of wills and trusts; and provides agency, insurance brokerage and stockbroking services. Founded in 1989, Stanbic IBTC Holdings Plc is a subsidiary of Stanbic Africa Holdings Limited. Its company head office is in Lagos, Nigeria. Stanbic IBTC Plc is listed on the Nigerian Stock Exchange
Family Ministry Coordinator Baton Rouge, LA In-person Retreat: Thanksgiving Trinity Retreat Center (West Cornwall, CT) Nov. 24-28 An Evening with Presiding Bishop Curry and Iconographer Kelly Latimore Episcopal Migration Ministries via Zoom June 23 @ 6 p.m. ET TryTank Experimental Lab and York St. John University of England Launch Survey to Study the Impact of Covid-19 on the Episcopal Church TryTank Experimental Lab Associate Rector Columbus, GA Posted Oct 18, 2017 Remember Holy Land Christians on Jerusalem Sunday, June 20 American Friends of the Episcopal Diocese of Jerusalem Join the Episcopal Diocese of Texas in Celebrating the Pauli Murray Feast Online Worship Service June 27 Rector Albany, NY Curate (Associate & Priest-in-Charge) Traverse City, MI Associate Rector for Family Ministries Anchorage, AK Rector Washington, DC Submit an Event Listing Rector Knoxville, TN [Anglican Communion News Service] The bishop of Jabalpur, Prem Singh, has been elected as the new moderator and Anglican primate of the united Church of North India. The church’s recent synod also elected a new deputy moderator: Bishop Probal Kanto Dutta of the Diocese of Durgapur. A new treasurer, Jayant Agarwal, was also elected. Alwan Masih will continue in his role as general secretary.Read the entire article here. Rector (FT or PT) Indian River, MI Canon for Family Ministry Jackson, MS Inaugural Diocesan Feast Day Celebrating Juneteenth San Francisco, CA (and livestream) June 19 @ 2 p.m. PT Bishop Diocesan Springfield, IL People Director of Music Morristown, NJ New Berrigan Book With Episcopal Roots Cascade Books Rector Tampa, FL Asia, Assistant/Associate Rector Washington, DC Seminary of the Southwest announces appointment of two new full time faculty members Seminary of the Southwest Rector Belleville, IL Curate Diocese of Nebraska Tags Anglican Communion, Rector and Chaplain Eugene, OR Featured Jobs & Calls Associate Priest for Pastoral Care New York, NY Assistant/Associate Rector Morristown, NJ Ya no son extranjeros: Un diálogo acerca de inmigración Una conversación de Zoom June 22 @ 7 p.m. ET Rector Bath, NC The Church Investment Group Commends the Taskforce on the Theology of Money on its report, The Theology of Money and Investing as Doing Theology Church Investment Group Rector Pittsburgh, PA Featured Events This Summer’s Anti-Racism Training Online Course (Diocese of New Jersey) June 18-July 16 Priest-in-Charge Lebanon, OH Rector Martinsville, VA Missioner for Disaster Resilience Sacramento, CA Assistant/Associate Priest Scottsdale, AZ Rector Shreveport, LA Rector/Priest in Charge (PT) Lisbon, ME New primate and leadership team for Church of North India Rector Collierville, TN Cathedral Dean Boise, ID Episcopal Migration Ministries’ Virtual Prayer Vigil for World Refugee Day Facebook Live Prayer Vigil June 20 @ 7 p.m. ET Youth Minister Lorton, VA Director of Administration & Finance Atlanta, GA Episcopal Charities of the Diocese of New York Hires Reverend Kevin W. VanHook, II as Executive Director Episcopal Charities of the Diocese of New York The Church Pension Fund Invests $20 Million in Impact Investment Fund Designed to Preserve Workforce Housing Communities Nationwide Church Pension Group AddThis Sharing ButtonsShare to PrintFriendlyPrintFriendlyShare to FacebookFacebookShare to TwitterTwitterShare to EmailEmailShare to MoreAddThis Submit a Job Listing Rector Smithfield, NC Press Release Service Course Director Jerusalem, Israel Virtual Celebration of the Jerusalem Princess Basma Center Zoom Conversation June 19 @ 12 p.m. ET Priest Associate or Director of Adult Ministries Greenville, SC Rector Hopkinsville, KY Submit a Press Release
ArchDaily Manufacturers: Arcelor Mittal, FRANCIAFLEXSave this picture!© Javier CallejasRecommended ProductsFiber Cements / CementsDuctal®Ductal® Cladding Panels (EU)Enclosures / Double Skin FacadesFranken-SchotterFacade System – LINEAWoodEGGERLaminatesMetallicsStudcoWall Stop Ends – EzyCapText description provided by the architects. A new social housing project in Saintes has totally reinvented what living together means. A seemingly inhabited cloud effortlessly signals the entrance to a recently rehabilitated working-class neighbourhood, known as ‘Les Boiffiers’, dating back to the 1970s. Landscape and architectural design come together in meaningful harmony, showcasing the new development. Save this picture!© Javier CallejasThe building is positioned in such a way as to respect the site’s quality, rather than merely colonise the given space. A sense of depth has been created, structured by footpaths and enticing visual perspectives, with the landscape slipping effortlessly in and around the architectural volumes, offering multiple orientations for the apartments, all of which are secluded, standing well back from the road and enjoying open vistas over the surrounding spaces.Save this picture!© Javier CallejasThe harmonious association of setting and architecture makes way for a design which, rather than closing in on itself and looking inwards, opens out to embrace the neighbourhood as a whole, while still providing protection from direct line of sight and noise thanks to its perforated cladding. Save this picture!© Javier CallejasThis building functions as a pivotal point and its strategic position means that the eye at once perceives it in its entirety. It has no main façade, and no front or back. The three volumes which compose it are compact and the amply proportioned exterior private spaces are grafted onto them in accordance with their internal spatial arrangement and specific needs, playfully disturbing the line of the building’s façades.Save this picture!© Javier CallejasSave this picture!PlanSave this picture!© Javier CallejasExit conventional balconies, terraces and loggias with their separating walls and shields of varying transparency, used to hide unsightly objects or provide a modicum of intimacy. In this design, the outside spaces are extremely secluded and provide genuine additional spaces, equipped with utility rooms for drying washing or storing bulky objects, just like garden sheds. The apartments flow out into these exterior facilities, thereby offering ample extra space. Save this picture!© Javier CallejasThese ‘additional rooms’ are the design’s main distinguishing feature and endow each apartment with some of the qualities inherent to detached homes. Pragmatism, experimentation and know-how.Save this picture!© Javier CallejasProject gallerySee allShow lessAD Classics: Millennium Dome / Richard Rogers (RSHP)Architecture ClassicsThe Unexpected Stories Behind 10 Skyscrapers That Were Actually BuiltArchitecture NewsProject locationAddress:17100 Saintes, FranceLocation to be used only as a reference. It could indicate city/country but not exact address. Share Photographs: Javier Callejas Manufacturers Brands with products used in this architecture project Year: CopyAbout this officePOGGI & MORE architectureOfficeFollowProductsGlassSteelConcrete#TagsProjectsBuilt ProjectsSelected ProjectsResidential ArchitectureSocial HousingSaintesFrancePublished on January 24, 2017Cite: “White Clouds / POGGI & MORE architecture” 24 Jan 2017. ArchDaily. Accessed 11 Jun 2021.
Senate Ag Chair Roberts to Retire in 2020 Facebook Twitter SHARE SHARE Previous articleUSGC Rolls Out Report Citing High Quality, Near-Record YieldNext article2019 Miss Indiana State Fair Queen from Benton County NAFB News Service Senator Pat Roberts of Kansas Friday announced he will not seek re-election to the U.S. Senate in 2020 and will retire at the end of this term and the 116th Congress. The current Senate Agriculture Committee Chairman has served eight terms in the U.S. House of Representatives and four terms in the U.S. Senate. Roberts has chaired six committees and is the only two-time chairman of both the House and Senate Agriculture Committees in congressional history.Making his announcement Friday in Manhattan, Kansas, the Senator said he’s “always proudly been a champion for agriculture.” Just last month Roberts helped pass a new farm bill, his eighth farm bill during his tenure on Capitol Hill. In a statement following the announcement, Senate Ag Committee Ranking Democrat Debbie Stabenow called Roberts a “true friend” who “always puts the needs of our farmers and ranchers first.”Source: NAFB News Service Home Indiana Agriculture News Senate Ag Chair Roberts to Retire in 2020 Facebook Twitter By NAFB News Service – Jan 6, 2019
News November 13, 2007 – Updated on January 20, 2016 Two Trabzon police officers who knew about plot to murder journalist are charged with “abuse of authority” Two police officers in the northeastern city of Trabzon have been charged in connection with their failure to report what they knew about plans to kill Hrant Dink, the Turkish-Armenian editor of the weekly Agos, prior to his murder in Istanbul last January, the Turkish press reported on 8 November. Trabzon is the city where most of the people on trial for Dink’s murder were from.The Trabzon prosecutor has charged Veysel Sahin and another police officer identified only by the initials O.S. with “abuse of authority” under article 257.2 of the criminal code. They are expected to respond to the charges before a local magistrate’s court soon and face a possible sentence of six months to two years in prison.Sahin is on the list of witnesses due to be heard in the Dink murder trial taking place in Istanbul. During the second hearing in the trial on 1 October, the Dink family’s lawyers asked for him to be added to the list of trial witnesses.The decision to charge Sahin and O.S. suggests that six other members of the Trabzon police force who allegedly knew about the murder plan are not to be prosecuted. They include Muhittin Zenit, who had a conversation with Erhan Tuncel, one of the murder’s alleged organisers, that was recorded.One of the Dink family lawyers, Erdal Dogan, has said he was not told about the decision to charge the two police officers. The next hearing in the Dink murder trial, which began on 2 July, is to be held on 11 February.Dink was gunned down on 19 January outside the Istanbul office of the Armenian and Turkish-language newspaper he edited. He had been prosecuted several times because of his comments about the massacres of Armenians in 1915. He was given a six-month suspended prison sentence in 2005 and, at the time of his death, he was facing a possible three-year sentence for describing the massacres as genocide in an interview for Reuters. Help by sharing this information Follow the news on Turkey TurkeyEurope – Central Asia Organisation News RSF_en to go further News Human rights groups warns European leaders before Turkey summit Turkey’s never-ending judicial persecution of former newspaper editor April 2, 2021 Find out more April 2, 2021 Find out more TurkeyEurope – Central Asia April 28, 2021 Find out more Receive email alerts News Journalists threatened with imprisonment under Turkey’s terrorism law
More Cool Stuff First Heatwave Expected Next Week With occurrences of violence on the rise, the urgent need for expert training in threat assessment and reaction protocol is being met by a new firm, Providers International, launched last summer. The firm may be called in to augment current security staff and to add a level of expertise in homeland security methodology.Heading up the company is Daniel Secundy, who has developed new proactive solutions for reducing the potential for violence at schools and businesses. He and his team can work one-on-one with key management or provide seminars of any length to educate staff.â€œThe barrier to contacting us is the false notion that ‘it canâ€™t happen here,’” says Secundy. â€œFor every shooting and act of violence that hits the media, there are 50 more around the nation that are not headline grabbers, but disrupt the safety of those we love.â€ He believes that â€œsituational awarenessâ€ is the key component to reducing violence in our society and teaches the tools that are effective in protection. This includes provisions that can be implemented effectively to assist companies with theft, incident management, workforce reduction issues, work strikes, and physical site security.â€œThe key is to assess and respond to issues far below the threshold of violence,â€ advises Secundy. â€œMy team and I will do that.â€He has spent the better part of a decade working in the security apparatus of the United States, becoming an expert in security and protection. Secundy holds a Masterâ€™s degree in National Security with an emphasis in terrorism Methodology and has certifications in both Executive Protection and Corporate Crisis Management.Providers International, 115 W. California Blvd., Pasadena, (808) 551-9858 or visit www.providers-international.com. Top of the News 7 recommended0 commentsShareShareTweetSharePin it Community News Community News Name (required) Mail (required) (not be published) Website Home of the Week: Unique Pasadena Home Located on Madeline Drive, Pasadena Subscribe Make a comment Business News Pasadena’s ‘626 Day’ Aims to Celebrate City, Boost Local Economy Get our daily Pasadena newspaper in your email box. Free.Get all the latest Pasadena news, more than 10 fresh stories daily, 7 days a week at 7 a.m. Your email address will not be published. Required fields are marked * HerbeautyA Mental Health Chatbot Which Helps People With DepressionHerbeautyHerbeautyHerbeauty11 Ayurveda Heath Secrets From Ancient IndiaHerbeautyHerbeautyHerbeautyWomen Love These Great Tips To Making Your Teeth Look WhiterHerbeautyHerbeautyHerbeauty10 Special Massage Techniques That Will Make You Return For MoreHerbeautyHerbeautyHerbeautyThe Most Heartwarming Moments Between Father And DaughterHerbeautyHerbeautyHerbeautyIs It Bad To Give Your Boyfriend An Ultimatum?HerbeautyHerbeauty EVENTS & ENTERTAINMENT | FOOD & DRINK | THE ARTS | REAL ESTATE | HOME & GARDEN | WELLNESS | SOCIAL SCENE | GETAWAYS | PARENTS & KIDS faithfernandez More » ShareTweetShare on Google+Pin on PinterestSend with WhatsApp,Virtual Schools PasadenaHomes Solve Community/Gov/Pub SafetyPASADENA EVENTS & ACTIVITIES CALENDARClick here for Movie Showtimes Business Districts News Providers International Offers Threat Assessment and Pre-Violence Training to Businesses and Schools From STAFF REPORTS Published on Monday, November 17, 2014 | 11:00 am Pasadena Will Allow Vaccinated People to Go Without Masks in Most Settings Starting on Tuesday
TO raise awareness among the public of how important it is to look after one’s hearing, the Hearing Awareness Week Road Show will be in the Crescent Shopping Centre on Thursday, January 29, between 10am and 5pm.Sign up for the weekly Limerick Post newsletter Sign Up Organised by the Irish Deaf Society, the event will present an opportunity to members of the public to meet with an audiologist to have their hearing tested, ipods checked and questions answered.Hearing Awareness Week is taking place nationally and to mark the week, Limerick’s Hidden Hearing Clinic on Catherine Street is making a special donation to the Irish Deaf Society for every person tested through their clinic, to help raise much needed funds.A special feature of the event will be a volume testing with a sound level meter, a device used to measure how high or low the output is from earphones. Linkedin Advertisement NewsLocal NewsTurning down the volumeBy admin – January 20, 2009 632 Twitter Previous article‘Carers must be protected’ claims cllr O’DonovanNext articleLimerick County Fire Stations rewarded admin Facebook WhatsApp Print Email
Pinterest Join Top Speakers and Industry Leaders Virtually at The National Forum for Black Public Administrators’ Winter Summit Twitter Facebook WhatsApp Pinterest WhatsApp Previous articleThe Joy Factory Rolls Out First Product in aXtion Extreme Series Designed for Hazardous Work EnvironmentsNext articleLBA Ware Issues Q4 2020 Loan Compensation Report, Includes Summary of 2020 Loan Originator Commission Trends Digital AIM Web Support TAGS Virtual event includes impressive 20+ panels, workshops and roundtable discussions – February 24-26, 2021 WASHINGTON, D.C., Jan. 27, 2021 (SEND2PRESS NEWSWIRE) — The National Forum for Black Public Administrators (NFBPA), an organization dedicated to the advancement of black public leadership in local and state governments, will feature an impressive roster of keynotes, presenters and panels for their virtual Winter Summit Building Blocks for a Better Future, February 24-26, 2021. NFBPA seeks to offer proven and creative solutions to the most relevant issues facing local, state, and federal governments. Building Blocks for a Better Future will provide a forum for public sector professionals to communicate during this challenging time. “It is important that local government leaders are effective in navigating today’s challenges while also, building the foundation for the leaders of tomorrow. The theme ‘Building Blocks for a Better Future’ was chosen with intent and a clear mission. NFBPA, along with its partners, have assembled an excellent group of thought leaders, local government executives, association leaders, and consultants to share best practices and resources necessary to succeed in this new norm,” said Anthony J. Snipes, NFBPA President. NFBPA welcomes Dr. Anthony Fauci, Director of the National Institute of Allergy and Infectious Diseases, who will have a candid conversation with Marlene McNeese, Assistant Director of Disease, Prevention and Control with the City of Houston Health Department. During the Fireside Chat, Dr. Fauci will share relevant data for the future of public health and safety. Other critical topics during the virtual event will be Public Policy Forums “Unfinished Business with Public Safety: Ensuring Justice & Protection for All” and “Racism is a Public Health Issue,” where moderators will lead Public Safety Officials, Academic, and Public Health experts through a series of discussions with the purpose of charting a course for the future of public safety and health. Other sessions will include topics ranging from: Innovation and the Changing Face of Government; Addressing Social Disparities in Health; 7 Steps to Creating an Influential Brand; How to Overcome Unconscious Bias in Decision Making and more. Registration and a complete schedule can be found at https://www.eventbrite.com/e/nfbpa-virtual-summit-building-blocks-for-a-better-future-tickets-131500338051 About the National Forum for Black Public Administrators National Forum for Black Public Administrators (NFBPA) is a 501(c)(3) nonprofit organization dedicated to the advancement of black public leadership in local and state governments. With over 2,500 members, NFBPA has established a national reputation for designing and implementing quality leadership development initiatives of unparalleled success. NFBPA members are leaders and managers of public programs and agencies in more than 350 jurisdictions nationwide. Thirty-six chapters support the growth of NFBPA at the local level. For more information, visit https://www.nfbpa.org/home Tweet: @nfbpa1 to hold virtual #BuildingBlocks Summit February 24-26, 2021 for #Public Administrators. Visit: nfbpa.org for more information. *LOGO link for media: https://www.Send2Press.com/300dpi/21-0127s2p-nfpba-bblocks-300dpi.jpg NEWS SOURCE: National Forum for Black Public Administrators This press release was issued on behalf of the news source (National Forum for Black Public Administrators) who is solely responsibile for its accuracy, by Send2Press® Newswire. Information is believed accurate but not guaranteed. Story ID: 67835 APDF-R8.2 © 2021 Send2Press®, a press release and e-marketing service of NEOTROPE®, Calif., USA. To view the original version, visit: https://www.send2press.com/wire/join-top-speakers-and-industry-leaders-virtually-at-the-national-forum-for-black-public-administrators-winter-summit/ Disclaimer: This press release content was not created by the Associated Press (AP). Facebook Twitter By Digital AIM Web Support – January 27, 2021 Local NewsUS News
Comments are closed. Previous Article Next Article Related posts:No related photos. Case round upOn 1 Apr 2004 in Personnel Today Our resident experts at Pinsents bring you a comprehensiveupdate on all the latest decisions that could affect your organisation, andadvice on what to do about them Harper v Virgin Net Limited, Court of Appeal No damages for lost opportunity to claim unfair dismissal * * * Harper was dismissed 33 days short of one year’s continuousemployment. Her statutory notice period was one week and her contract includeda three-month notice period. Harper successfully claimed wrongful dismissal. The tribunal awarded herdamages for the contractual notice period she had not received and for the lostopportunity to claim unfair dismissal. Had she been given contractual noticeshe would have been able to make such a claim. The tribunal ruled that herdismissal would have been clearly unfair and awarded a full compensatory award.Both the EAT and the Court of Appeal ruled that this approach was wrong. Key pointsThe Court of Appeal ruled that Harper had not lost the opportunity to claimcompensation for unfair dismissal as she never had the right to make such a claim.Her statutory entitlement was to one week’s notice and had she received thisshe would still have fallen short of the qualifying service to claim unfairdismissal. To allow employees to effectively access statutory rights via aclaim for contractual damages would expose courts and tribunals to chaos. What you should do – Include a payment in-lieu of notice clause in contracts to allow you tobring the contract to an immediate end. This provides greater flexibility whenterminating contracts – Remember that if you fail to provide statutory minimum notice this will beadded to the employee’s length of service. Ramsey v Walkers Snack Food, EAT Use of anonymous statements was fair * * * Ramsey and two employees were dismissed on suspicion of stealing moneyinserted into crisp packets as part of a sales promotion. Management invitedwitnesses able to identify those involved in the theft to come forward on ananonymous basis. The informants expressed a desire to remain anonymous. Theapplicants were dismissed for gross misconduct, primarily on the basis ofanonymous written statements. The applicants claimed unfair dismissal, arguing that the manner in whichthe statements were taken, their lack of detail, and the inability to questionwitnesses, rendered the whole disciplinary process unfair. Previous case lawguidance on the use of anonymous statements had not been followed. The tribunaland the EAT held that in the specific circumstances of this case, thedismissals had been fair. Key pointsThe EAT concluded that the tribunal’s ruling that the arrangements foranonymity were not unreasonable. Walkers genuinely and reasonably believed thatno information would be provided other than on a confidential basis. Theinformants would not sign any statement unless it was edited in such a way asto remove any risk of identification. Informants were not willing to be exposedto further questioning by managers during the investigatory and disciplinaryprocess and refused to answer questions raised by the accused employees. What you should do – Remember that using anonymous statements is undesirable and is legitimateonly in exceptional cases – Ordinarily investigators should meet with informants and take detailed statementsto be anonymised later. They should explore carefully the evidence given, lookfor corroboration and investigate why the informant desires anonymity – Managers hearing disciplinary cases should also meet informants to weighup their evidence – Remember that these standards can only be departed from in exceptionalcases. Collins v Royal National Theatre Board, Court of Appeal Failures to make reasonable adjustments unlikely to be justified * * * Collins, a carpenter’s labourer, injured his right hand at work. Herefused surgery on the advice of his GP. His employer set him some controlledtasks to assess his capability and determined that he could not workefficiently or safely with his injury. Collins was dismissed as there was noother job that he could do. Collins successfully claimed disabilitydiscrimination, in particular a breach of the duty to make reasonableadjustments. There had been insufficient attempts to see what adjustments couldhave been made to accommodate his disability. Key pointsThe issue in the Court of Appeal was a technical but important point – canan employer’s failure to make adjustments to accommodate a disabled employee beunreasonable but justified? The DDA prevents two forms of discrimination – less favourable treatment anda failure to make reasonable adjustments. Both forms of discrimination arepermitted when an employer can show justification. For less favourabletreatment, the justification test is easily satisfied. The employer must showthat the treatment concerned was taken on grounds that were ‘material andsubstantial’. If the employer can show that its action was taken on aconsidered basis and fell within the range of reasonable responses to the knownfacts, the treatment will be justified. The justification defence in reasonableadjustment cases is expressed with the same words. The difficulty is that ifthe same text is applied in less favourable treatment cases, the duty to makereasonable adjustments is easily bypassed. Tribunals must assess whether this duty has been complied with byestablishing what is reasonable for the employer to do on the facts of thecase. An employer found to have breached the duty will be found to have behavedunreasonably. The Court of Appeal ruled that any issue considered by the tribunalwhen deciding if the employer’s conduct was unreasonable cannot then be takeninto account as justification. In short, justification has to be based onsomething other than the conduct that has been found to be unreasonable. This decision makes justification of a failure to make reasonableadjustments exceptionally difficult. From 1 October 2004, the justificationdefence will be repealed in such cases, so that the issue will be whether theemployer has failed to take reasonable steps to prevent the disabilityresulting in a substantial disadvantage. What you should do – If a medical condition affects an employee’s ability to do their job,explore all possible adjustments or accommodation that could be made – Ensure you obtain medical advice to assist your assessment – Take the medical position into account when timing your assessment. Herethe employer’s assessment was carried out soon after the injury when theeffects had not settled down. Crossley v Faithful and Gould Holdings Limited, Court of Appeal No duty on employer to protect employee’s financial well-being * * * Crossley was on long-term sick leave and unable to return to work.Under his contract he was a member of the company’s disability insurancescheme. He submitted a claim under the scheme but resigned and took earlyretirement. As a result, he lost his entitlement under the scheme. Crossleyargued that his employer had breached an implied term of his contract to takereasonable care of his economic well-being by failing to warn him that hisletter of resignation would result in his loss of the disability benefits. Heclaimed damages for the lost benefits under the scheme. Key pointsRejecting Crossley’s claim, the Court of Appeal ruled that no such termcould be implied into the contract of employment. It would place an unfair andunreasonable burden on employers. The company was entitled to assume thatCrossley would have realised the implications of his actions or had the meansto find out what they were. What you should do – Ensure the terms of insurance schemes are clearly communicated andavailable to employees – Remember that the position in this case would be different had thedismissal occurred on the employer’s initiative. Case of the month by Linda JonesAgency workers are employed by agency’s clientBrook Street Bureau v Dacas, Court of Appeal Court of Appeal suggests that agency workers are employed by theagency’s client * * * * * Mrs Dacas was an agency worker supplied by an employment agency towork for Wandsworth Council as a cleaner. The council became dissatisfied withher performance and the agency terminated her assignment. Dacas claimed unfairdismissal against the council and the agency. To succeed, she had to show thatone of the two respondents had been her employer. An employment tribunal ruled that the council had no direct contract withher and so was not the employer. The contract between Dacas and the employmentagency was not a contract of employment as it lacked the necessary mutuality ofobligation and the agency had no direct control over the work carried out. Dacas appealed the decision relating to her claim against the employmentagency, but not the finding in relation to the council. The Court of Appealconcluded that the tribunal correctly found that no employment relationshipexisted with the agency. However, two of the three judges expressed the viewthat, on the facts, the council was the true employer. Key pointsNumerous cases have examined the employment status of agency staff, butthese have essentially been concerned with the relationship between agency andworker. In some cases, an employment relationship between agency and worker hasbeen established and so indicated that the risk of employment liabilities laysquarely with the agency. This case shatters those assumptions. First, the Court of Appeal rejectedthe possibility of an employment contract between Dacas and the agency,accepting the arguments that the agency is not obliged to provide work and theworker is not obliged to do any work offered and it is the client who hasday-to-day control over the worker. Second, the Court of Appeal ruled that the absence of a written and expresscontract between worker and end-user is not the determining factor as far as aclaim against the end-user is concerned. Tribunals should examine whether thereis an implied contract and whether that contract is a contract of employment.The end user’s day-to-day control over the work carried out will increase therisk of employment status being established by this route. There is now a real danger that those using agency staff are exposed to arange of employment liabilities, in particular claims for unfair dismissal. Theend-user will follow no procedure to terminate an assignment, on the assumptionthat doing so is unnecessary and that following any procedure could indicatethe existence of an employment relationship. This approach will result inunfair dismissal if the end-user is the employer. That position will beexacerbated under the new dismissal procedures introduced with effect from 1October 2004 where a failure to follow the statutory procedure will result inautomatic unfair dismissal and increased compensation. What you should do – If you use agency workers, you should review your arrangements,particularly for terminating assignments – Review your contractual arrangements with agencies to reduce risk, forexample through indemnities – Where agency staff have worked with you for more than a year, they may beable to claim unfair dismissal. Consider whether you need to use agency stafffor such long periods.