Recognition Decision
Updated 23 September 2025
Applies to England, Scotland and Wales
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Case Number: TUR1/1480(2025)
22 September 2025
CENTRAL ARBITRATION COMMITTEE
TRADE UNION AND LABOUR RELATIONS (CONSOLIDATION) ACT 1992
SCHEDULE A1 - COLLECTIVE BARGAINING: RECOGNITION
DECLARATION OF RECOGNITION WITHOUT A BALLOT
The Parties:
RMT
and
Amulet (Churchill Security Solutions)
1. Introduction
1) RMT (the Union) submitted an application to the CAC on 8 July 2025 that it should be recognised for collective bargaining by Amulet (Churchill Security Solutions) (the Employer) for a bargaining unit comprising of “Safeguarding Officers employed by Amulet on the Avanti West Coast Contract”. The CAC gave both parties notice of receipt of the application on 8 July 2025. The Employer did not submit a response to the application.
2) In accordance with section 263 of the Trade Union and Labour Relations (Consolidation) Act 1992 (the Act), the CAC Chair established a Panel to deal with the case. The Panel consisted of Ms Susan Cox, Panel Chair, and, as Members, Mr Alastair Kelly and Mr Steve Gillan. The Case Manager appointed to support the Panel was Kaniza Bibi.
3) By its written decision dated 24 July 2025 the Panel accepted the Union’s application. The Employer then failed to comply with its duty to provide specified information direct to the Union within the timeframe set by paragraph 18A (2) of Schedule A1 to the Act (the Schedule). The Panel therefore proceeded under paragraph 19 of the Schedule by moving to a hearing to determine whether the proposed bargaining unit was appropriate. The parties were invited to supply the Panel with, and to exchange, written submissions relating to the question of the determination of the appropriate bargaining unit.
4) A virtual hearing was held on 5 September 2025 and the Panel’s decision was that the appropriate bargaining unit was that as proposed by the Union, namely: “Safeguarding Officers employed by Amulet on the Avanti West Coast Contract”, which includes Safeguarding Team Leaders. The proposed bargaining unit was the same as that in the Union’s application.
2. Issues
5) Paragraph 22 of the Schedule provides that, if the CAC is satisfied that a majority of the workers constituting the bargaining unit are members of the union, it must issue a declaration of recognition under paragraph 22(2) unless any of the three qualifying conditions specified in paragraph 22(4) applies. Paragraph 22(3) requires the CAC to hold a ballot even where it has found that a majority of workers constituting the bargaining unit are members of the union if any of these qualifying conditions is fulfilled.
6) The three qualifying conditions are:
(i) The CAC is satisfied that a ballot should be held in the interests of good industrial relations.
(ii) The CAC has evidence, which it considers to be credible, from a significant number of the union members within the bargaining unit that they do not want the union to conduct collective bargaining on their behalf.
(iii) Membership evidence is produced which leads the CAC to conclude that there are doubts whether a significant number of the union members within the bargaining unit want the union to conduct collective bargaining on their behalf.
Paragraph 22(5) provides that “membership evidence” for these purposes is:
(a) evidence about the circumstances in which union members became members, or
(b) evidence about the length of time for which union members have been members, in a case where the CAC is satisfied that such evidence should be taken into account.
3. The Union’s submission that it should be recognised without a ballot
7) In a letter dated 10 September 2025 the Union was asked by the CAC whether it claimed majority membership within the bargaining unit and, if so, whether it submitted that it should be granted recognition without a ballot. The Union, in an e-mail dated 12 September 2025, stated: “Further to your correspondence of 10th September, please be advised that RMT is certain that we have a majority of the bargaining unit currently in RMT membership. Of the bargaining unit as adjusted by the CAC panel to 34, RMT has 20 members at date or 59% of the total. We would therefore like to request that the panel move forward to declare RMT recognised without a ballot”.
4. The Employer’s response
8) The CAC copied the Union’s e-mail of 12 September 2025 to the Employer and invited the Employer to make submissions in relation to the Union’s claim that it had majority membership within the bargaining unit and in relation to the three qualifying conditions specified in paragraph 22(4) of the Schedule.
9) No response was received from the Employer.
5. Considerations
10) The Schedule requires the Panel to consider whether it is satisfied that a majority of the workers constituting the bargaining unit are members of the Union. If the Panel is satisfied that a majority of the workers constituting the bargaining unit are members of the Union, it must declare the Union to be recognised as entitled to conduct collective bargaining on behalf of the workers constituting the bargaining unit unless it decides that any of the three qualifying conditions set out in paragraph 22(4) is fulfilled. If the Panel considers that any of those conditions is fulfilled, it must give notice to the parties that it intends to arrange for the holding of a secret ballot.
11) In its application to the CAC, the Union stated that there were 22 Union members in its proposed bargaining unit of 32 workers. The Panel was satisfied that, on the basis of the evidence available, the Union had 22 members out of 32 workers in the proposed bargaining unit. This gave the Union membership of 68.75% of the proposed bargaining unit. Accordingly, the Panel accepts that the majority of workers in the bargaining unit are members of the Union.
12) This is a case in which the Employer has failed to engage with the statutory process despite being invited to do so on a number of occasions. A representative of the Employer attended the hearing to determine the bargaining unit but made no submissions. In the absence of any submissions from the Employer the Panel has had to rely solely on the correspondence and submissions received from the Union in arriving at a decision as to whether any of the qualifying conditions laid down in paragraph 22(4) of the Schedule is fulfilled.
Paragraph 22(4) (a)
13) The first condition is that the Panel is satisfied that a ballot should be held in the interests of good industrial relations. In this case neither party has submitted evidence that holding a secret ballot would be in the interests of good industrial relations. The Panel is therefore satisfied that this condition does not apply.
Paragraph 22(4) (b)
14) The second condition is that the CAC has evidence, which it considers to be credible, from a significant number of the union members within the bargaining unit that they do not want the Union to conduct collective bargaining on their behalf. The CAC has no such evidence, and this condition therefore does not apply.
Paragraph 22(4) (c)
15) The third condition is that membership evidence is produced which leads the CAC to conclude that there are doubts whether a significant number of the union members within the bargaining unit want the Union to conduct collective bargaining on their behalf. No such evidence has been produced, and this condition therefore does not apply.
6. Declaration of recognition
16) The Panel is satisfied in accordance with paragraph 22(1)(b) of the Schedule that a majority of the workers constituting the bargaining unit are members of the Union. The Panel is satisfied that none of the conditions in paragraph 22(4) of the Schedule is met. Pursuant to paragraph 22(2) of the Schedule, the CAC must therefore issue a declaration that the Union is recognised as entitled to conduct collective bargaining on behalf of the workers constituting the bargaining unit. The CAC accordingly declares that the Union is recognised by the Employer as entitled to conduct collective bargaining on behalf of the bargaining unit comprising “Safeguarding Officers employed by Amulet on the Avanti West Coast Contract”, which, for the avoidance of doubt, includes Safeguarding Team Leaders.
Panel
Ms Susan Cox, Panel Chair
Mr Alastair Kelly
Mr Steve Gillan
22 September 2025