Adverse performance review is not constructive dismissal

“It is also noted that previous Commission decisions have determined that an employee who has resigned after being involved in a performance management process has not been forced to resign by their employer. I refer by way of example in this context to a decision of Commissioner Bissett in Ashton v Consumer Action Law Centre [2010] FWA 9356. In that matter the employee was placed under what were described as “additional supervisory arrangements” because of concerns about his performance. The Commissioner concluded at [48]:
“The existence of these processes, by themselves or together, is not enough to warrant a conclusion that the employer took action with the intent of bringing the employment relationship to an end.”
Iacono v Police Financial Services Limited (2017) FWC 465 delivered 20 January 2017 per Gregory C