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Question:

Compromise Agreements:  What generally goes in a compromise agreement?               

 

 

Answer:

 

 

Compromise Agreements are prescribed by statute to bring to an end all and any statutory claims arising out of your employment or the termination of your employment. Those statutory claims generally have to be listed out in order to be settled by the agreement. Statutory claims will include for example unfair dismissal, sex discrimination etc.

 

Employers generally use compromise agreements to settle other claims arising as well, for example breach of contract claims and claims in tort (for example personal injury claims). There are limited circumstances in which a compromise agreement will not be effective to settle all claims arising, but this will be the exception and not the norm.

 

Once a compromise agreement is completed, assuming it is an effective agreement, then this will bring to an end your right to pursue any claims arising from your employment or the termination of your employment in an Employment Tribunal or elsewhere (including for example the High Court). It is therefore particularly important that we:

 

a)       Identify any claims arising. (Even if for example the compromise agreement is being offered to you as a result of a normal redundancy situation, the procedure adopted might give rise to a claim, or alternatively there may be (unconnected) personality clashes, or disputes regarding time off, pay, bonuses or other matters which also give rise to claims);

 

b)       Get an idea of the merits of such claims and their potential value; and

 

c)       Consider whether the sums offered are reasonable in the circumstances

 

...before you decide whether or not to sign away your rights.

 

In order for a compromise agreement to be effective, you the employee first need to obtain independent legal advice. Generally your legal adviser will be asked to sign a certificate at the end of the agreement to confirm:

 

a)       That they are a solicitor of the Supreme Court.

b)       That they a current practicing certificate.

c)       That they a relevant form of indemnity insurance in place.

 

Please note that some Trade Union representatives and other advisers can also provide advice on compromise agreements.

 

Employees are of course free to instruct whoever they wish to provide independent legal advice. The solicitors’ duty of course is to act solely your  interests and not that of the employer.

 

There are a number of issues which typically come up when reviewing the compromise agreement and which include:

 

·         It is important to understand that the compromise agreement will generally comprise the ‘entire agreement’, which is to say that everything agreed between the employee and  employer should be incorporated into the agreement. The employee may not therefore be able to enforce anything agreed informally on the side. Therefore if there is anything that has been agreed on the side which is not in the agreement, it should be brought to the attention of the independent legal adviser.

 

·         There should normally be a clause stating that they employee will be paid salary as normal up to and including the date your employment ends, less deductions of tax and national insurance.

 

·         One would normally expect to see a clause stating that the employee will receive a payment in lieu of any holiday accrued but untaken to the termination date. This will have to be taxed in the normal way.

 

·         One would expect to see a figure offered ‘ex gratia’ in addition to any payments the employer is obliged to give you anyway. This is often referred to as the Compensation Payment. Whatever it is, it is a good rule of thumb to calculate how many months net pay it represents. Employment Tribunals make their awards based largely on your loss of net earnings from the date of dismissal until the date you find suitable alternative employment. For most people it takes at least three to six months to secure suitable alternative employment, sometimes much longer.

 

·         The payment may not be as generous as it initially appears; for example it may incorporate your statutory entitlement to redundancy pay. Remember though, there is not normally any obligation on employers to offer enhanced severance in a redundancy situation. It is normally only if we can identify claims arising that we may be able to negotiate a bigger settlement on the employees behalf.

 

·         If the employee is entitled to commission or contractual bonuses, or if the employee has share options or vested shares in the employer, this should also be covered in the compromise agreement.

 

·         One would ordinarily expect the employee to have either worked their notice or to be receiving a payment in lieu of notice. If receiving a payment in lieu of notice, it may be possible for your employer to pay this in a tax efficient manner without deductions of tax and national insurance. This is something the independent legal adviser will need to check.

 

·         Under the Income Tax (Earnings and Pensions) Act 2003 ('ITEPA 2003')  tax is normally only payable on payments made in respect of “the termination of a person’s employment” insofar as they exceed £30,000.

 

·         However there are some exceptions to the £30,000 rule on tax; for example if the employee receives a payment in lieu of notice, and the employer reserves the contractual right to make a payment in lieu of notice. Alternatively if the employer habitually makes a payment in lieu of notice. Another example would be if the sum is paid in consideration for the employee agreeing to enter into certain post employment restrictions, in which case the sum would be taxable. This is something that the legal adviser would have to look at carefully.

 

·         Even when the legal adviser and the employer believe that the payment(s) can he paid without deductions of tax under the £30,000 rule under ITEPA, it is important for the employee to remember that there is always a residual risk that HM Revenue and Customs may consider that tax has to be paid.

 

·         In almost every compromise agreement, there will be a tax indemnity clause, stating that in the event that tax arises, it will be the employee’s responsibility and not the employers. The clause typically states that if the Revenue comes after the employer for tax, then the employer can in turn claw that sum back from you, together with any interest, penalties or associated costs. This is called a tax indemnity clause. From the employees point of view, it would be better if that clause was not in the agreement but employers seldom agree to it being removed. This is something the independent legal adviser will need to look at carefully

 

·         Although the idea of the compromise agreement is to settle all claims arising from your employment or the termination of the employee’s employment including specific statutory claims, breach of contract claims and claims in tort, one would normally expect to see certain claims excluded:

 

-          Claims with respect to accrued pension rights to the date of dismissal (if applicable)

-          Claims for the enforcement of the terms of the compromise agreement (though this may be implied)

-          Personal injury claims. Where this applies that would mean that if (say) after signing the agreement the employee develops a medical condition such as asbestosis, having been exposed to asbestos dust at work, he or she would still be able to bring a personal injury claim with respect to it. Sometimes employers will ask the employee to warrant (confirm) that he or she is  not aware of any such personal injury claims arising. So if for example the employee has tripped over a cable at work, done their back in lifting heavy boxes or developed pains in their fingers from typing, they should let the legal adviser know.

 

·         Employers will typically contribute to the cost of your obtaining independent legal advice up to a specified sum.

 

·         If the employee is a member of an occupational pension scheme, normally his or her pension rights would be frozen at the date the  employment ends until the normal retirement date.

 

·         The employee will probably be asked to return all property belonging to the employer in his or her possession. This will ordinarily include all documents in whatever format (including electronic). The employee may for example want to retain the laptop used by work for you or your mobile phone number, in which case this should be discussed with the adviser.

 

·          There is likely to be a clause preventing the employee from disclosing confidential information to third parties. Confidential information will be defined but is likely to cover commercially sensitive information which is not already known to the public.

 

·         The Employee will probably be asked to keep the terms of the compromise agreement confidential and you should not (for example) discuss the terms of the agreement with colleagues. The employee will probably be allowed to discuss the agreement with certain parties, including the legal adviser and potentially his or her immediate family.

 

·         The agreement may prevent the employee from making critical comments about your employer. It may be worth making this obligation reciprocal, particularly if the employee is leaving in unhappy circumstances.

 

·         One would normally expect the agreement to expressly incorporate the wording of a reference that the employer will provide any prospective employer that contacts them. It is increasingly common nowadays for employers only to give brief factual references, simply confirming job title and dates of employment, especially if the employee is  employed by financial or legal institutions. This is because the employer could be sued by a future employer if they say anything which is inaccurate or misleading. This can be a concern to many people, but the more common this practice is, the less that can be read into it by a future employer.

 

·         There may be a clause stating that if the employee is in breach of the compromise agreement, anything paid to the employee under it by your employer will have to be repaid to them and which can be recovered as a debt. The money offered therefore is the carrot, and the repayment clause is the stick. Arguably such a clause may amount to an unenforceable penalty clause. This may depend how it is drafted. However it is important that you are fully aware of such a clause if it is in the agreement and the employee should not in any case enter into an agreement in the expectation of breaching it in the future.

 

·         Occasionally the employee will be asked to confirm that they do not have new paid employment lined up before accepting the payment under the agreement.

 

·         There may be a clause either imposing certain restrictions on what work the employee can do after his or her employment ends, or reminding the employee that those restrictions are already imposed under your employment contract. It is important to ensure that the employee shows his or her legal adviser the  employment contract if they have one. Sometimes where such a restriction is imposed by the compromise agreement, there will be a separate payment (say £250 less tax an NI) for your agreeing to that restriction. The idea is to ring fence the taxable status of the ex gratia Compensation payment.

 

·         Finally, most compromise agreements are marked ‘without prejudice’ until signed. This means that they are off the record and cannot normally be referred to in legal proceedings unless signed off.

 

See also our page on compromise agreement breaches

 

Last updated: July 2010

 

 

 

 

James Carmody

Employment Solicitor

 

Reculver Solicitors

12-16 Clerkenwell Road

London EC1M 5PQ

 

www.reculversolicitors.co.uk

info@reculversolicitors.co.uk

Tel 0207 324 6271

 

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