Dismissal by demotion; employers on notice

The Fair Work Commission has determined that a unilateral requirement by an
employer that an employee accept a 20% reduction in remuneration constituted a
constructive dismissal when the employee refused to accept it.
“Having considered the facts of this application I am satisfied that the demotion of
Mr Fields involved a 20% reduction in his remuneration. I am satisfied that this was
a significant reduction. I am satisfied that the respondent’s unilateral reduction of
the applicant’s remuneration by 20% was a dismissal of the applicant from the
respondent’s employment at the respondent’s initiative or, in the alternative, a
cessation of employment by way of a resignation forced by the conduct of the

Fields v Moscou Holdings Pty Ltd ATF The Penguin Trust (2015) FWC 6878
delivered- 16 October 2015 per Drake SDP