Contracts of employment: Failure to provide grievance procedure is breach of contract

It is an implied term of every employee's contract of employment that their employer will reasonably and promptly afford them a reasonable opportunity to obtain redress of any grievance they may have, holds the EAT in WA Goold (Pearmak) Ltd v McConnell and another. An industrial tribunal was therefore entitled to find that an employer's failure to provide and implement a procedure that dealt with two employees' grievance promptly amounted to a repudiatory breach of contract, entitling them to resign and to be treated as constructively dismissed.