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EDA2647

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ADE/25/107

DETERMINATION NO.  EDA2647

SECTION 44, WORKPLACE RELATIONS ACT 2015

SECTION 83 (1), EMPLOYMENT EQUALITY ACTS, 1998 TO 2015


PARTIES:

GLOBOFORCE LIMITED T/A WORKHUMAN LTD.

(REPRESENTED BY MCCANN FITZGERALD LLP)

AND

LIZ KEATING



DIVISION:

Chairman: Ms O'Donnell
Employer Member: Mr Marie
Worker Member: Ms Treacy



SUBJECT:

Appeal of Adjudication Officer Decision No.: ADJ-00054347 (CA-00066104-001)

BACKGROUND:

The Worker appealed the decision of the WRC Adjudication Officer under Section 83 (1), Employment Equality Acts, 1998 to 2015 on 17 July 2025.

A Labour Court hearing took place on 6 August 2026.

The following is the Determination of the Court.

DETERMINATION:

This is an appeal by Ms Liz Keating (the Complainant) against Decision ADJ-00054347 CA-00066104-001 of an Adjudication Officer under the Employment Equality Acts 1998–2015 (the Act) concerning her employer, Globoforce Limited t/a Workhuman Ltd (the Respondent). The Adjudication Officer held that they did not have jurisdiction to hear the complaint.

Background

The Complainant was employed as a Finance Administrator from April 2015 until May 2023. It is her claim that she was discriminated against on the grounds of age, gender and disability, when she was selected for redundancy. The Complainant lodged her complaint with the WRC on 18 September 2024. The relevant period for the purposes of the Act is 19 March 2024 to 18 September 2024.

Preliminary issues

The Respondent raised the issue that the complaint was out of time. The Complainant’s employment came to an end on 8 May 2023. Her complaint was not lodged until 18 September 2024 and, even if the Court were to allow for the extensions provided for in the Act, that would only bring the relevant period back to 19 September 2023, while her employment had ended a number of months earlier. The representative for the Respondent submitted that the Court had no jurisdiction to hear the complaint.

The Complainant submitted that reasonable cause existed for the delay. She further submitted that, beyond the discretion provided for in the Act to extend the relevant period to 12 months, the Court had a duty to ensure that gender-based mistreatment was not ignored, and that she was prepared to bring the matter to the High Court to ensure that these concerns were addressed. In response to a clarification sought by the Court, she was unable to identify any statutory provision that would allow the Court to go beyond the 12-month period provided for in the Act.

Given that the Complainant’s employment ended in May 2023, she had until November 2023 to lodge her complaint or, where reasonable cause was shown, until May 2024. The Court does not have jurisdiction to consider complaints submitted outside that statutory period. On that basis, the appeal must fail.

Determination

For all the reasons set out above, the Court finds that the complaint under the Act is statute-barred and must therefore fail. The Court cannot proceed to hear the substantive matter.

Accordingly, the Complainant’s appeal is not allowed, and the decision of the Adjudication Officer is upheld.

The Court so Determines.

Signed on behalf of the Labour Court
Louise O'Donnell

ÁM

______________________
07/09/2026 Chairman



NOTE

Enquiries concerning this 
Determination should be in writing and addressed to Ms Áine Maunsell, Court Secretary.