ET3 grounds for resisting claim—Agency Workers Regulations 2010: breach of pay between assignments contract (Swedish derogation) (to 5 April 2020)

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  • ET3 grounds for resisting claim—Agency Workers Regulations 2010: breach of pay between assignments contract (Swedish derogation) (to 5 April 2020)

ET3 grounds for resisting claim—Agency Workers Regulations 2010: breach of pay between assignments contract (Swedish derogation) (to 5 April 2020)

[Insert in para 6.1 of claim form ET3:]

    1. 1

      It is admitted that the Claimant works as a legal secretary and it is admitted that the Respondent is a temporary work agency. It is admitted that the Claimant had a permanent contract of employment with the Respondent.

    1. 2

      It is admitted that the Claimant's contract contained the terms set out at paragraph [2] of the Grounds of Claim.

    1. 3

      It is admitted that the Claimant completed the assignments and had the gaps between assignments set out at paragraph [3] of the Grounds of Claim. It is admitted that she was paid at the appropriate rate during those gaps. It is denied that on any of her assignments, the Claimant was paid at a rate which was not equal to that which she would have received had she been directly recruited by the respective hirers at the time when she commenced each assignment. The Respondent relies on the following comparable employees in respect of each such assignment [insert

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