“91. Turning to the second allegation relating to failure to make reasonable adjustments, we considered with the claimant what the provision, criterion or practice might be, particularly as the claimant had relinquished her former role, making her an employee without a role. Having discussed matters with the claimant and the respondent we are not able to conclude that there was any PCP in place that would require a full ergonomic workstation assessment to be carried out. We are aware of the claimant’s desire to have a workstation assessment carried out, and the respondent’s view that they would carry out such an assessment once the claimant found a role so that they could tailor the assessment to the role she found. In the absence of a role being found, and therefore the absence of a PCP, this allegation of failure to make reasonable adjustments does not have a foundation upon which it can be based so it fails.”
“(1) Where this Act imposes a duty to make reasonable adjustments on a person, this section, sections 21 and 22 and the applicable Schedule apply; and for these purposes, a person on whom the duty is imposed is referred to as A. (2) The duty comprises the following three requirements. (3) The first requirement is a requirement, where a provision, criterion or practice of A’s puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to avoid the disadvantage. (4) The second requirement is a requirement, where a physical feature puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to avoid the disadvantage. (5) The third requirement is a requirement, where a disabled person would, but for the provision of an auxiliary aid, be put at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to provide the auxiliary aid. (6) Where the first or third requirement relates to the provision of information, the steps which it is reasonable for A to have to take include steps for ensuring that in the circumstances concerned the information is provided in an accessible format. (7) A person (A) who is subject to a duty to make reasonable adjustments is not (subject to express provision to the contrary) entitled to require a disabled person, in relation to whom A is required to comply with the duty, to pay to any extent A’s costs of complying with the duty.”
“34. In our experience the phrase still sometimes causes problems, as to some extent it appears to have done in this case. It is, we think, important to keep in mind the whole of section 20(3). The elements within it are designed to link together. The purpose of identifying a PCP is to see if there is something about the employer’s operation which causes substantial disadvantage to a disabled person in comparison to persons who are not disabled. 35. The PCP must therefore be the cause of the substantial disadvantage. Wide though the concept is, there is no pint in identifying a PCP which does not cause substantial disadvantage.” 38. It is for a Claimant to identify and prove the PCP. It is sufficient on this question to cite Latif at paragraphs 44 to 45: “ Burden of Proof 44. We turn to the final ground. Ms Clement [for the Appellant] submits that the tribunal erred in its approach to the burden of proof. This was specifically considered by the tribunal who were persuaded by Mr Epstein [for the Respondent] that the proper approach was as follows (para 4.11): ‘(a) Has the claimant proved facts from which it could be inferred that any provision, criterion or practice has placed her at a substantial disadvantage? If so, (b) Has the respondent on cogent evidence proved that (i) there was no such provision, criterion or practice, or (ii) the claimant was not at a substantial disadvantage; and (iii) that there were no further or other steps that it could reasonably have taken in order to reduce or eliminate any such disadvantage?’ (Mr Epstein accepts that the word ‘and’ emphasised in that paragraph must be an error: even on his approach, it ought to be an ‘or’. This is because the duty to make an adjustment does not arise if the other two conditions are not satisfied.) 45. We observe in passing that we very much doubt whether the burden shifts at all in respect of establishing the provision, criterion or practice, or demonstrating the substantial disadvantage. These are simply questions of fact for the tribunal to decide after hearing all the evidence, with the onus of proof resting throughout on the claimant. These are not issues where the employer has information or beliefs within his own knowledge which the claimant cannot be expected to prove. To talk of the burden shifting in such cases is in our view confusing and inaccurate.” 39. There will, of course, be times when a claimant, who is a litigant in person, can and does establish a PCP without appreciating that such a concept even exists. The PCP may be obvious from the disadvantage described (see Harvey at paragraphs 17 and 18). It may be, and often is, a quite basic feature of the employment (see, for example, Griffiths at paragraph 47, where the PCP was the requirement of maintaining “a certain level of attendance at work in order not to be subject to the risk of disciplinary sanctions”). It may be a written rule of some kind, obvious on the papers. It is good practice for an Employment Tribunal to consider with a claimant, particularly a litigant in person, what the PCP is, when at a Preliminary Hearing or the start of a final hearing, it is confirming the issues to be determined. If this has not happened it may not be too late for it to be identified during final submissions, though at this stage the Employment Tribunal must be alert to ensure the process is fair to both sides. There are times when the PCP is obvious to both claimant and respondent and set out in the papers even if it is not labelled as such. 40. There will, however, be cases where the claimant does not successfully identify or establish a PCP. I have reached the conclusion in respect of this ground that the Claimant did not establish a PCP and that the Employment Tribunal made no error of law. My reasons are as follows. 41. It is, I think, clear that the Claimant was seeking to put forward the case that a “full ergonomic workplace assessment” should have been carried out before she could consider redeployment. This was the Employment Tribunal’s understanding and it is consistent with the schedule where she describes her claims. 42. In my judgment, there was a fundamental internal inconsistency in the way in which the Claimant was seeking to put her case. She had latched on to the Occupational Health advice that there should be a “full ergonomic workplace assessment” in the broad sense in which that was described in the report, which I have already quoted. However, such an assessment can only be carried out if there was a potential workplace to assess. If one posits as the PCP that when an employee is on redeployment a full ergonomic workplace assessment will only be undertaken when the employee has obtained a role, that PCP could not possibly place the Claimant at a disadvantage, for such an assessment can only be carried out in respect of an actual workplace, whereas the Claimant did not respond to any of the jobs suggested during redeployment or suggest any of her own. It would not assist the Claimant to formulate a PCP which involves a failure to do that which is impossible. 43. Recognising this difficulty, Mr Alford took instructions and put his case in the following way. What the Claimant required prior to considering alternative jobs, was that there should be a preliminary assessment to check, in particular, whether voice recognition software would function with the Respondent’s systems. Only this would give her the confidence to engage in a redeployment process and seek specific jobs. The PCP applied by the Respondent was that it would only undertake this limited assessment when she had obtained a role. 44. This alternative formulation will not suffice for two reasons. Firstly, it was not the way the case was put below. The Claimant was given every opportunity to define the PCP relied on and she did not do so; the Employment Tribunal did its best to assess her case by reference to the schedule which she had provided, which had referred to a full ergonomic workplace assessment, and it cannot be criticised as making an error of law because it did not formulate her case in this alternative way. Secondly, the Employment Tribunal’s Reasons show that the Respondent was prepared to engage in assessment as far as possible before a workplace was established - by undertaking an assessment at home or a nearby office of the Respondent where she might use a desk (see paragraphs 45 to 48 of the Employment Tribunal’s Reasons). The factual basis for the PCP was not established. 45. I, therefore, reject ground 2. I would add for the sake of completeness that there is a line of authorities, of which the best known is Tarbuck v Sainsbury’s Supermarkets Ltd[2006] IRLR 664 , holding that failure to carry out an assessment does not, in itself, constitute a failure to make a reasonable adjustment. This is a further problem with which the Employment Tribunal would have had to grapple if it found a PCP to exist. Mr Alford suggests that Tarbuck might be distinguishable on the basis that in this case the assessment was required to enable the Claimant to have the confidence to apply for a job on redeployment. That faces both factual and legal difficulties, not least factual difficulties given findings of the Employment Tribunal to which I have already referred about the Claimant’s reason for not cooperating with redeployment, but while noting this difficulty I need express no further view about it. Ground 3: Pensionable Salary, Reasonable Adjustment and Indirect Discrimination The Employment Tribunal’s Reasons 46. The sixth heading in the Claimant’s schedule complained that if she found a role through redeployment paying less than her previous role, her pension would accrue at a lower rate. She wished to retain the rate of accrual appropriate to her previous salary. She said that a role with a lower salary would have a huge impact on her final salary at retirement. This type of discrimination was said to be indirect discrimination and failure to make a reasonable adjustment. The Employment Tribunal dealt with this complaint in paragraphs 99 to 100. It said: “99. With regard to the sixth allegation, this alleges indirect discrimination and failure to make reasonable adjustments in terms of pensionable salary. The claimant accepted that the final salary for the purposes of pension would be the best earned in the last ten years of employment, but she pointed out that that salary would of itself have [increased] by whatever percentage general salaries within the Bank increased over that ten year period, thus giving her a higher final salary. If she was in a lower paid job then in all probability she would not ever reach the highest final salary that she was paid in the old role. 100. As regards indirect discrimination and the duty to make adjustments, there are for both requirements for a provision, criterion or practice. With regard to this allegation the claimant is referring to what might have happened had she found an alternative role with a lower salary. Given that she did not then we are unable to support this prospective claim for indirect discrimination and/or failure to make reasonable adjustments.”
“(1) A person (A) discriminates against another (B) if A applies to B a provision, criterion or practice which is discriminatory in relation to a relevant protected characteristic of B’s. (2) For the purposes of subsection (1), a provision, criterion or practice is discriminatory in relation to a relevant protected characteristic of B’s if - (a) A applies, or would apply, it to persons with whom B does not share the characteristic, (b) it puts, or would put, persons with whom B shares the characteristic at a particular disadvantage when compared with persons with whom B does not share it, (c) it puts, or would put, B at that disadvantage, and (d) A cannot show it to be a proportionate means of achieving a legitimate aim.”
“I was a member of my employer’s Share Save Scheme and in March 2009 purchased a five year share option with the ability to purchase shares at a favourable rate at the end of the five year period. Payments were taken directly from salary but as I have been on a zero ill health scheme since August 2012 and have not received a payslip since April 2013, payments have not been deducted from my salary. The scheme allows six missed payments with the ability to make any missed payments within the six month period. Because I have suffered financial hardship by being on the zero ill health scheme I have missed seven payments and have been unable to make up the missing payments so therefore my contract has been cancelled. Because I have no employment or pay I am unable to contribute to the Share Save Scheme. I have received a cheque with a small amount of interest but have lost the ability to purchase shares in March 2014 at a favourable rate which may later increase in value if I had kept them as an investment. My Share Save contract should have been frozen and I could have made up the missing payments when I obtained a role and started receiving a salary. My employer should have asked if I wished them to contribute the amount per month on my behalf to be repaid once I had a role. My contributions would continue and enable me to participate in the Share Save Scheme.” 53. The Claimant also said that she had made 48 out of 60 payments but she had lost the right to acquire shares at a favourable rate because of the payments she had missed, although she had received the return of the payments she had made with some interest. She has, therefore, on her case, lost out on some element of profit. 54. The type of discrimination was said to be indirect discrimination and failure to make a reasonable adjustment. The Employment Tribunal dealt with it in paragraphs 101 to 104 of its Reasons: “101. With regard to the seventh allegation of indirect discrimination and failure to make reasonable adjustments to the Share Save Scheme as regards the indirect discrimination claim, the claimant has not dealt with the question of how “A” might apply the PCP to persons without a monthly salary with whom the claimant does not share the characteristic of disability. In simple terms there is nothing before us to enable us to conclude that there was [an] act of indirect discrimination with regard to this scheme and its application to the claimant. 102. As to a failure to make reasonable adjustments, we ask ourselves what the PCP is and we presume that the PCP is the requirement on behalf of a member of a Share Save Scheme to make monthly payments into the scheme for each month that the scheme endures, in this case a five year scheme. 103. The claimant complains that she suffered financial hardship having come off the LTD scheme, but the lack of an income would not necessarily preclude her from making payments under the Share Save Scheme whilst she remained an employee. We are aware that the claimant was not well placed financially because of the unfortunate circumstances surrounding both her and her husband but we have referred above to a letter dated15 October 2012 in relation to the Share Save Scheme. There was the possibility to make alternative arrangements as to payment, thus suggesting that any payment does not need to be made out of income. Had the claimant had money available then she could have applied it to the Share Save Scheme had she so chosen. 104. In these circumstances we conclude that those employees of the Bank who were in the situation of the claimant in not being paid, for whatever reason, would not be in a position to make payments into the Share Save Scheme unless they had alternative resources. Comparing the claimant with someone who does not have a disability, we cannot see that the claimant is at any greater or lesser disadvantage than any other employee who is for whatever reason without pay.”