UKSC and JCPC electronic bundle sample - The Supreme Court

IN THE EMPLOYMENT APPEAL TRIBUNAL
UKEAT10377107/MAA
BETWEEN:
BRITISH AIRWAYS PLC
AppeUanta
MRS S. WILLIAMS and others
Respondents
AGREED STATEMENT OF EVIDENCE
The EAT asked the parties to agree a note ofthe evidence before the ET on two matters:
(i)
(ii)
the calculation ofholiday pay in airlines other than BA in relation to both flight
crew and cabin crew and the evidence as to unionised and non-unionised airlines;
the evidence as to whether pilots were required to take their annual leave and
whether they could elect not to take any part oftheir holidays.
Issue(i)
1. PAUL DOUGLAS, head of flight operations, gave evidence for BA about his
discussions and correspondence with BALPA (the pilots' union) and the grievance
process which bad been instituted. He bad cballenged the union to identifY a single
airline which paid variable pay (i.e. pay additioual to basic pay) for holiday periods:
e.g. notes of grievance hearing at p. 334 of ET bundle (the notes of the grievance
hearing are annexed to this statement of agreed facts). At paragraph 23 ofhis witness
statement he states:
"In response to a request from me BALPA were unable to identifY one other
airline that paid variable pay during periods ofholiday".
2. At pamgraph 6 of his Supplementary Statement, he adds that when asked whether
BALPA was aware
"ofany other airline that paid allowances during periods of annual leave; they
declined to answer the question".
I
116
MS MS Page Number 230 37