In Person For the v Respondent — 2025

Dr L Carty was employed by Man Group Services Ltd from 2016, became Global Head of Talent in 2018, and was promoted to Chief People Officer on 1 March 2023. The tribunal found that the People/HR function was then integrated into one People team led by her. Two external investigations followed: Project Kregel into complaints about the reorganisation of the People function, and Project Sartre into the concerns she later raised about Kregel and related issues.

On the pleaded protected disclosures, the tribunal accepted that on 28 June and 11 July 2023 she voiced strong objections to the HR email monitoring system and may have referred generally to GDPR, but it found she did not clearly communicate that the system was unlawful and did not actually or reasonably believe that she was disclosing a breach of legal obligation. The tribunal found that her evidence was that the system was unethical, culturally inappropriate, and not fit for purpose. On Disclosure 4, about an alleged whistleblower being subjected to a detriment, the tribunal held that she did not raise health and safety or miscarriage of justice concerns and did not plead or evidence a GDPR-based disclosure in that context. Disclosure 5 on 20 December 2023 repeated the earlier points and did not alter the analysis.

The whistleblowing detriment claim under s47B ERA 1996 failed. The tribunal found that Project Kregel was prompted by genuine complaints from staff about the reorganisation, not by the email monitoring dispute, and that Project Sartre was a separate investigation into the Claimant's grievance. The pleaded detriments linked to the initiation and conduct of the investigations, the without prejudice meeting, the dismissal letter, the lack of appeal, and the insurance cancellation were either not causally connected to any protected disclosure or, in the case of the benefit issues, were explained by a systems error and salary-sacrifice arrangements.

For the dismissal claims, the tribunal held that the principal reason for dismissal was loss of trust and confidence in the Claimant's ability to perform the Chief People Officer role, described as some other substantial reason. It relied on the interim findings from Project Kregel, the later Project Sartre conclusions, and the Claimant's responses to the investigations. Although no formal process or appeal was offered, the tribunal held that, in the unusual circumstances of this senior executive role and the investigations already undertaken, dismissal without further procedure was within the range of reasonable responses under s98(4) ERA 1996. The automatic unfair dismissal claim under s103A failed because none of the pleaded disclosures was found to be the principal reason for dismissal. No monetary award or recommendation was made.