In Midland Bank plc v McCann (1998) IDS 623 EAT, the Employment Appeal Tribunal held that with regard to a discretionary bonus the employer had not exercised its discretion in such a way that it could be said to be in breach of the implied term of mutual trust and confidence.
An employer was contractually entitled to make changes to an incentive bonus scheme without the consent of employees individually or their trade union representatives, holds the EAT in Airlie and others v City of Edinburgh District Council.