Decision

Bargaining Unit Decision

Updated 29 May 2026

Applies to England, Scotland and Wales

Case Number: TUR1/1522(2026)

28 May 2026

CENTRAL ARBITRATION COMMITTEE

TRADE UNION AND LABOUR RELATIONS (CONSOLIDATION) ACT 1992

SCHEDULE A1 - COLLECTIVE BARGAINING: RECOGNITION

DETERMINATION OF THE BARGAINING UNIT

The Parties:

United Voices of the World

and

WGC Ltd

1. Introduction

1)         United Voices of the World (the Union) submitted an application to the CAC dated 29 January 2026 that it should be recognised for collective bargaining purposes by WGC Ltd (the Employer) in respect of a bargaining unit comprising “employees of WGC Ltd who work within the housekeeping department who work at Radisson Blu Hotel, London Euston Square,130 Tottenham Ct Rd, London W1T 5AY.” The location of the bargaining unit was given as “Radisson Blu Hotel, London Euston Square, 130 Tottenham Ct Rd, London W1T 5AY.” The application was received by the CAC on 29 January 2026 and the CAC gave both parties notice of receipt of the application on 30 January 2026. The Employer submitted a response to the CAC dated 5 February 2026 which was copied to the Union.

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 Professor Alan Bogg, Panel Chair, and, as Members, Mr Martin Kirke and Mr Nick Childs. The Case Manager appointed to support the Panel was Kate Norgate. 

3)         By a decision dated 5 March 2026 the Panel accepted the Union’s application.  The parties then entered a period of negotiation in an attempt to reach agreement on the appropriate bargaining unit. As no agreement was reached, 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. A bargaining unit hearing was held by virtual means on 8 May 2026 and the names of those who attended the hearing are appended to this decision.

4)         The Panel is required, by paragraph 19(2) of Schedule A1 to the Act (the Schedule), to decide whether the proposed bargaining unit is appropriate and, if found not to be appropriate, to decide in accordance with paragraph 19(3) a bargaining unit which is appropriate. Paragraph 19B(1) and (2) state that, in making those decisions, the Panel must take into account the need for the unit to be compatible with effective management and the matters listed in paragraph 19B(3) of the Schedule so far as they do not conflict with that need. The matters listed in paragraph 19B(3) are: (1) the views of the employer and the union; (2) existing national and local bargaining arrangements; (3) the desirability of avoiding small fragmented bargaining units within an undertaking; (4) the characteristics of workers falling within the bargaining unit under consideration and of any other employees of the employer whom the CAC considers relevant; and (5) the location of workers. Paragraph 19B(4) states that in taking an employer’s views into account for the purpose of deciding whether the proposed bargaining unit is appropriate, the CAC must take into account any view the employer has about any other bargaining unit that it considers would be appropriate.

2. Background

5)         WGC Limited is a facilities management company that provides housekeeping and related services to hotels and other hospitality establishments. The Employer holds the housekeeping contract at the Radisson Blu Hotel, London Euston Square. The housekeeping workers at the site are therefore employed by WGC Limited. The Employer also holds contracts at eight other Radisson Blu hotels in London.

3. Summary of the Union’s submissions

6)         The Union said that its proposed bargaining unit comprising the housekeeping employees at the Radisson Blu Hotel, London Euston Square was appropriate.

7)         The Union explained that the Panel had to decide whether the Union’s proposed bargaining unit was appropriate under paragraph 19(2) of the Schedule and, only if it was not, to determine a different unit under paragraph 19(3). The Union maintained that paragraph 19B gave primacy to compatibility with effective management, with the paragraph 19B(3) matters taken into account only so far as they did not conflict with that need.

8)         The Union referenced several decisions within its written submissions.  The Union cited R (Kwik-Fit (GB) Ltd) v Central Arbitration Committee [2002] EWCA Civ 512, [2002] ICR 1212, [2002] IRLR 395. The Union stated that this was a case in which the Court of Appeal held that the question for the Panel was whether the proposed bargaining unit was appropriate, rather than whether it was the optimal unit. The Union cited R (Lidl Ltd) v Central Arbitration Committee and GMB [2017] EWCA Civ 328, [2017] ICR 1145. The Union stated that in this case the Court of Appeal confirmed that the matters in paragraph 19B(3) were factors to be taken into account rather than rigid criteria. The Union further cited the CAC’s decision in UNISON v We Are With You (formerly known as Addaction) TUR1/1144(2019), stating that once the Union’s proposed bargaining unit was found to be appropriate, the CAC should not reject it because another unit might be more appropriate. The Union also referred to the CAC’s decision in United Voices of the World v Service to the Aged (Sage) TUR1/1194(2020), where the CAC had accepted a single-site unit. And, finally, it referred to the CAC’s decision in United Voices of the World v Ecocleen Services Ltd TUR1/1207(2021). The Union stated that this was a case in which the CAC had accepted a workable site-based unit.

9)         The Union also submitted that the Panel should have regard to Article 11 of the European Convention on Human Rights. The Union said that Demir and Baykara v Turkey (2009) 48 EHRR 54 supported the proposition that collective bargaining formed an essential element of Article 11, and that Unite the Union v United Kingdom, Application 65397/13, 3 May 2016 reinforced the importance of effective collective bargaining rights. The Union explained that it relied on Article 11 as background context to the exercise, rather than as a separate and freestanding statutory factor. It maintained that the Panel should apply the Schedule in a way that did not unnecessarily impede the workers’ and the union’s right to bargain collectively.

10)       The Union said the workers in the proposed bargaining unit were located at a single site (the Radisson Blu Euston Square) and that the unit covered the whole housekeeping team at that hotel. The Union explained that these workers operated as one cohesive team: they were managed together within a unified management structure, were scheduled on the same rota, performed identical or substantially similar duties, and shared common terms and conditions and workplace concerns.

11)       The Union submitted that the proposed bargaining unit was compatible with effective management.  It comprised a single-site housekeeping team managed as one operational group, and therefore collective bargaining could be conducted efficiently without disrupting the Employer’s management arrangements. The Union maintained that single-site units were well established in other CAC decisions and explained that the CAC had previously accepted single-site units even where an employer operated across many locations.

12)       The Union submitted that it had secured substantial support within the proposed unit and maintained that this demonstrated a clear collective wish to be represented for collective bargaining. The Union said it had developed a close relationship with the housekeeping workers at the site and had actively engaged the Employer on their behalf about workplace concerns and grievances. The Union explained that the Employer had already engaged in negotiations on pay and related matters on more than one occasion, including in relation to the payroll cut-off change and productivity expectations at Euston Square. The Union maintained that this engagement supported its case that formal recognition for this discrete group was workable.

13)       The Union asserted the Employer’s own dealings had demonstrated practicality: the Employer had engaged in discussions with the Union on issues such as workload, productivity rates and pay arrangements, which the Union said showed that site-specific engagement had been effective. In answer to questions from the Panel, the Union explained that productivity rates were driven by operational differences between hotels, including room layouts, the number and type of rooms, footfall and staffing levels, and it maintained that these factors could vary materially by site. The Union also explained that productivity rates could affect hours worked in practice because workers might stay late or work extra hours to complete rooms if targets were not met, which it said could have a direct practical impact on pay and working time, although it said there was no special overtime rate per se. The Union further explained that negotiations at the Canary Wharf site had resulted in site-specific variation in productivity expectations and maintained that this example showed that the Employer had shown a willingness and ability to apply different terms and conditions at different Radisson Blu sites. In particular, it said that all housekeepers at Radisson Blu Canary Wharf had been offered 40-hour week contracts without conditions attached, whereas at other sites entitlement to a 40-hour week contract had been conditional on employees having transferred to the Employer under TUPE. The Union added that new employees at Radisson Blu hotels where the Employer held a contract were generally offered only flexi-hour contracts. The Union relied on those matters, and on previous negotiations or concessions at individual sites including Euston Square and Canary Wharf, to show that site-level outcomes could differ in practice and maintained that it was seeking to formalise an arrangement that already existed informally. The Union submitted that, in a facilities management model involving multiple client sites with distinct requirements, site-based bargaining reflected operational reality rather than creating an artificial fragmentation.

14)       The Union maintained that strong worker support and its established relationship with the workers supported the proposed unit. The Union explained that the Employer’s preference for a wider unit did not make the Union’s unit inappropriate, and the Union submitted that the statutory test did not require the Panel to choose between competing proposals once the Union’s unit met the appropriateness threshold. The Union also said there were no existing recognition or bargaining arrangements covering the workers in the proposed unit, so recognition would not cut across any existing structures.

15)       The Union submitted its proposed bargaining unit comprising the entire housekeeping team at a single hotel site was not unduly small or artificially fragmented. The Union explained that some fragmentation was inevitable where an Employer operated across dispersed client sites, and it maintained that the law did not require the Union to organise across multiple sites with distinct operations simply because they shared a common employer. The Union said the workers formed a coherent group for collective bargaining because they were housekeeping staff at the same hotel, who carried out identical or similar roles under the same management and rota. The single-site location supported efficient communication and consultation. In answer to questions from the Panel, the Union clarified that cleaners were currently on the same hourly rate of pay across the nine sites. There continues to be a different productivity rate at Canary Wharf. The Union said that the history of site-specific differences showed that managing variation between sites was not incompatible with effective management.

16)       The Union said that the primary place of work of the workers in the proposed bargaining unit was Euston Square. The Union said that it did not hold its own quantified mobility data for those workers, but it maintained that the Employer’s mobility data was insufficient and inconclusive because it did not identify which workers had moved between sites, to what extent, and did not show movement on such a scale that the proposed bargaining unit would not be appropriate. The Union added that by taking extra shifts elsewhere to earn more, it did not prevent workers from being predominantly identified with a specific site.

17)       In rebutting the Employer’s proposed wider bargaining unit, the Union submitted that a London-wide unit would have aggregated workers across different sites with different management structures, operational requirements and potentially different terms, making bargaining more complex. The Union said it had no relationship with many workers outside the site and maintained that requiring it to represent workers who had not sought Union representation would have been contrary to its member-led principles. The Union also maintained that the Employer’s larger proposed unit would have diluted the concentrated support within the proposed unit and would have frustrated the workers’ ability to secure recognition through the statutory process.

18)       In its closing statement the Union submitted that its proposed bargaining unit met the statutory threshold of appropriateness: it was a single-site unit comprising all housekeeping workers at the Radisson Blu Euston Square, it was compatible with effective management, and the paragraph 19B(3) considerations either supported the proposed unit or were neutral. Applying the Kwik-Fit approach, the Union maintained that once the Panel found the proposed unit appropriate, the Panel’s inquiry should stop there. The Union therefore invited the Panel to determine that the proposed bargaining unit was appropriate and to proceed to the next stage of the statutory procedure.

4. Summary of the Employer’s submissions

19)       The Employer said that the Union’s proposed bargaining unit, confined to the housekeeping employees at Radisson Blu Hotel London Euston Square, was not appropriate because it was not compatible with effective management. The Employer proposed a wider bargaining unit comprising all housekeeping employees employed by it across the Radisson Blu London hotels operated under its client relationship with Axiom Hospitality, excluding managerial and administrative roles.

20)       The Employer submitted that the Panel first had to decide, under paragraph 19(2) of the Schedule, whether the Union’s proposed bargaining unit was appropriate and, if it was not, to determine an appropriate unit under paragraph 19(3). It said that paragraph 19B required the Panel to give primacy to compatibility with effective management and to take the paragraph 19B(3) factors into account only so far as they did not conflict with that need. The Employer cited R (Kwik-Fit (GB) Ltd) v Central Arbitration Committee [2002] EWCA Civ 512. The Employer stated that this was a case in which the Court of Appeal held that the question was not whether Kwik-Fit’s own proposed unit was more appropriate, but whether the Union’s proposed unit was appropriate. The Employer also cited R (Lidl Ltd) v Central Arbitration Committee and GMB [2017] EWCA Civ 328. The Employer stated that it relied on this in relation to fragmentation, which it identified as a real risk in this case given a parallel statutory application involving the Union and the Canary Wharf site. The Employer further cited the CAC’s decision in CWU v Maintel Europe Ltd TUR1/1322(2023). The Employer stated that the CAC held that a specialist team within a larger engineering function was not an appropriate unit because it formed part of an integrated coherent whole. The CAC’s decisions in BuzzFeed (UK) Ltd TUR1/1000(2017) and Skanska TUR1/1023(2017) were also referred to. The Employer stated that these were cases in which the CAC treated bargaining units as inappropriate where pay and core employment matters were determined outside the putative bargaining unit. And, finally, the Employer referred to the CAC’s decision in United Voices of the World v OCS Group UK Ltd TUR1/1116(2019), which it sought to distinguish from this application on the facts.

21)       The Employer said that the Euston housekeeping team was not a standalone workforce but formed part of an integrated grouping of housekeeping employees deployed across nine Radisson Blu London hotels that operated under a single client relationship with Axiom Hospitality. These hotels shared a common service specification and were supervised within a common management structure. The Employer said that management authority over pay, hours, contractual frameworks and policy sat above site level, through WGC’s cluster/London/central management, and that no site-level manager at Euston had autonomous authority over those matters.

22)       The Employer further explained that substantive employment decisions affecting the Radisson Blu London housekeeping workforce were taken at portfolio level, and that where housekeeping employees had retained TUPE-preserved legacy entitlements (such as additional length-of-service holiday entitlement), these were administered centrally and did not alter workforce governance, the Employer further adding that this did not justify carving out a separate bargaining unit. The Employer also relied in particular on the March to April 2025 consultation on proposed changes to contracted hours, which it said had been conducted on a single portfolio-wide basis using the same consultation notice, draft contract and process across the Radisson Blu London hotels, and maintained that the outcomes were the natural conclusion of that consultation rather than the product of any site-specific collective bargaining. It also relied on the October 2025 decision to increase hourly rates, make full-time contracted hours available and implement productivity adjustments across the Radisson sites. There continues to be a different productivity rate at Canary Wharf. The Employer said that the payroll-calendar issue raised by the Union had been a communication error at Euston Square resolved by a one-off advance payment and was not evidence of site-specific bargaining.

23)       The Employer said that housekeeping employees across the Radisson Blu London portfolio shared materially identical job roles, common contractual frameworks, common reporting lines and common mobility provisions permitting work at other sites within a reasonable geographical area. It said that employees had a base site but were expected under the standard contract to work elsewhere as required, and that cross-site deployment was an operational reality rather than a theoretical possibility. In that regard, it relied on evidence that sixteen of the thirty-three housekeeping employees based at Euston, approximately 48% of the workforce, had been deployed to work at other sites in the twenty-four months preceding the application, including other Radisson Blu London hotels and other London sites within the Employer’s operational cluster. It described most such cross-site working as deployment rather than the voluntary offer of extra work, said that the average period spent by an employee at another Radisson site was about eight days across a 24-month period, and accepted that it did not have data showing what proportion of workers had been offered work at another site rather than deployed there. The Employer said that this evidence nonetheless demonstrated a fluid and integrated workforce that was mobile between sites.

24)       The Employer said that rates of pay and hours were the same across all of the Radisson Blu London hotels and denied that there were site-specific differences in those terms. It said that productivity norms could differ between hotels because of physical layout and operational features but maintained that this did not reflect different contractual arrangements and mattered because it affected workload and pace of work, not  any separate entitlement to pay; employees, it said, were paid for hours worked. The Employer also said that the Canary Wharf episode relied on by the Union had been a dispute-resolution process rather than formal collective bargaining, although it accepted that an agreement had been reached with the Union to resolve the dispute. It maintained that a bargaining unit limited to the housekeeping team at Euston Square would cut across the level at which management authority was exercised and create a real risk of fragmented, site-by-site bargaining, particularly given the Union’s parallel application in respect of Canary Wharf. The Employer said that this would be operationally unworkable for a genuinely mobile workforce and incompatible with effective management. It therefore maintained that a bargaining unit aligned with the Radisson Blu London grouping would better reflect the way in which the workforce was managed, avoid unnecessary fragmentation, and place bargaining at the level at which employment decisions were actually taken.

25)       In conclusion, the Employer invited the Panel to determine that the Union’s proposed bargaining unit was not appropriate and to determine instead the wider Radisson Blu London housekeeping grouping as the appropriate bargaining unit.

5. Considerations

26)       The Panel begins with the statutory framework. The Panel is required, by paragraph 19(2) of the Schedule to the Act, to decide whether the Union’s proposed bargaining unit is appropriate and, if found not to be appropriate, to decide in accordance with paragraph 19(3) a bargaining unit which is appropriate. Paragraph 19B (1) and (2) state that, in making those decisions, the Panel must take into account the need for the unit to be compatible with effective management and the matters listed in paragraph 19B(3) of the Schedule so far as they do not conflict with that need. The matters listed in paragraph 19B (3) are: the views of the employer and the union; existing national and local bargaining arrangements; the desirability of avoiding small fragmented bargaining units within an undertaking; the characteristics of workers falling within the bargaining unit under consideration and of any other employees of the employer whom the CAC considers relevant; and the location of workers. Paragraph 19B(4) states that in taking an employer’s views into account for the purpose of deciding whether the proposed bargaining unit is appropriate, the CAC must take into account any view the employer has about any other bargaining unit that it considers would be appropriate.

27)       We also have regard to paragraph 171 of the Schedule which provides that “In exercising functions under this Schedule in any particular case the CAC must have regard to the object of encouraging and promoting fair and efficient practices and arrangements in the workplace, so far as having regard to that object is consistent with applying other provisions of this Schedule in the case concerned”.

28)       In reaching its decision the Panel has taken account of the views of the Union and the Employer as expressed in their written submissions, responses to questions and oral submissions during the hearing.

29)       The Panel’s first responsibility is to decide, in accordance with paragraph 19(2) of the Schedule, whether the Union’s proposed bargaining unit is appropriate. That does not require the Panel to determine whether it is the most appropriate bargaining unit; only whether it is appropriate. This is the overriding requirement under 19B(2) and relates principally to the matters to be collectively bargained for under the statutory regime namely pay, hours and holidays. Against the background of that overall responsibility the Panel has to consider the matters listed in paragraph 19B(3) of the Schedule reminding itself that these matters must not conflict with the need for the unit to be compatible with effective management.

30)       We remind ourselves that the statutory  test  is  set  at  the  comparatively  modest  level  of  appropriateness, rather than of the optimum or best possible outcome (see R (on the application of Kwik-Fit (GB) Ltd) v Central Arbitration Committee [2002] EWCA Civ 512, [2002] IRLR 395, [2002] ICR 1212, CA, per Buxton LJ). We should not reject the Union’s proposed bargaining unit because we consider that a different unit would be more appropriate nor, in considering whether it is compatible with effective management, should we consider whether it is the most effective or desirable unit in that context.

31)       The Panel considers that the Union’s proposed bargaining unit is compatible with effective management. The proposed bargaining unit comprised the housekeeping employees at Radisson Blu Hotel London Euston Square, that the Employer had argued was one of 9 Radison Blu London hotels at which housekeeping employees were deployed by WGC Limited and that it was therefore not appropriate to recognise only those housekeeping employees as a collective bargaining unit. However, the Panel is satisfied that the Union’s proposed bargaining unit comprises a discrete, identifiable group at a single location which consists of around 33 employees.

32)       The Panel has also considered the matters listed in paragraph 19B(3) of the Schedule, so far as they do not conflict with the need for the bargaining unit to be compatible with effective management. The  Panel has taken into account the views of the Union and those of the Employer. These views were put forward in written submissions and presented orally at the hearing, and they have been given full and careful consideration by the Panel. The Panel has no evidence that there are any existing national or local bargaining arrangements in this case.

33)       In relation to the desirability of avoiding small fragmented bargaining units within an undertaking, the Union’s proposed bargaining unit would be the sole bargaining unit within the Employer’s Radisson London group. In R (Lidl Ltd) v Central Arbitration Committee [2017] ICR 1145, Underhill LJ considered the particular mischief that was encompassed by the statutory reference to the “desirability of avoiding small fragmented bargaining units”. At paragraph [36], Underhill LJ identified the particular risk as that presented by different collective bargaining arrangements with different trade unions. This could lead to risks of disruption between competing trade unions. It may also generate inefficiencies and frictions through proliferating bargaining units. The Panel accepts that there may be undesirable fragmentation even where the same union is negotiating across different bargaining units. That might support a finding that the proposed bargaining unit is not compatible with effective management in certain contexts. However, we agree with Underhill LJ that this is not the core mischief addressed by the “small fragmented bargaining units” criterion, which is specifically concerned with inter-union competition.

34)       The Panel notes that the Union in this case is also pursuing a statutory application for recognition in respect of Canary Wharf. The Panel accepts that this may present a risk of fragmentation but it is satisfied, on the balance of probabilities, that in the circumstances as they currently exist the Union’s proposed bargaining unit would not lead to “fragmented collective bargaining” between different competing trade unions.^{[footnote 1]} It is just as possible that the outcomes of any site-specific collective bargaining with the same union could lead to convergence and bargaining coordination across those sites.

35)       As stated in paragraph 31 above, the Union’s proposed bargaining unit comprises a discrete, identifiable group comprising 33 employees. The Panel considers that workers within the proposed bargaining unit have sufficient common characteristics to fall within the same bargaining unit. All the workers in the proposed bargaining unit are based predominantly at a single location. It also notes that there is some evidence of site-specific “dialogue” (including industrial action) between the Union and the Employer. While the Employer was reluctant to call this recognition or collective bargaining (hence the Panel has opted for the more neutral description as “dialogue”), preferring instead to describe it as “dispute resolution”, these events involved the negotiated settlement of a collective dispute at a specific location. The Panel also accepts that “pay, hours, and holidays” are dealt with at an organisational level above each individual site location. However, that is not incompatible with site-specific bargaining units. It simply determines how any negotiations will be conducted, and the likely identity of the negotiating party for the Employer. The Panel was also unpersuaded that the mobility of workers redeployed between hotel sites would be obstructed unduly by the existence of a site-specific bargaining unit (or bargaining units). The Panel also noted that employment contracts specified specific “home” locations for workers within the London Radisson group, rather than as a pool to be deployed across multiple sites. The Panel is also satisfied, on the basis of the evidence before it, that its decision is consistent with the object set out in paragraph 171 of the Schedule.   

6. Concluding observations

36)  The Panel reiterates the modest statutory level of appropriateness against which the Union’s proposed bargaining unit must be considered. The task is not to identify the best bargaining unit, or to determine which of the Union’s or the Employer’s proposed units is the most compatible with effective management. That would be a different statutory exercise to the one mandated by the statutory test in Paragraph 19(2). If the Union’s proposed bargaining unit is capable of co-existence with effective management, it will satisfy the statutory test. The Panel is satisfied that the Union’s proposed unit is capable of co-existence with effective management, while also recognising the virtues in the Employer’s proposed alternative unit.

37)       The Panel were not persuaded by the Union’s submission that Demir v Turkey was helpful or relevant to applying the statutory test for assessing the proposed bargaining unit to the facts in this case. In this respect, we agree with Underhill LJ’s assessment in R (on the application of Boots Management Services) v Central Arbitration Committee  [2017] EWCA Civ 66:  “But, at the risk of spelling out the obvious, it does not follow from that that article 11 confers a universal right on any trade union to be recognised in all circumstances. It is self-evident that any right to be recognised conferred by domestic law will have to be defined by rules which identify which unions should be recognised by which employers in respect of which workers and for what purposes.” (para 54). There can be no substitute for simply applying the statutory words to the industrial relations facts, drawing upon the industrial relations expertise of the Panel.

7. Decision

38)       The appropriate bargaining unit is the Union’s proposed bargaining unit, namely “employees of WGC Ltd who work within the housekeeping department who work at Radisson Blu Hotel, London Euston Square,130 Tottenham Ct Rd, London W1T 5AY”.  

Panel

Professor Alan Bogg, Panel Chair

Mr Martin Kirke 

Mr Nick Childs

28 May 2026

8. Appendix

Names of those who attended the hearing:

For the Union:

Abhijay Srekanth UVW           -         UVW Trade Union Representative

Gabriel Rahman                        -          UVW Organiser

For the Employer:

Toby Pochron                             -           Partner at Freeths

Magda Drwiega                        -          Operations Director (South Region)

Rob McKellar-McCarthy       -           People Director

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1. See Lidl Ltd v Central Arbitration Committee [2017] EWCA Civ 328 at [36]-[38]. ↩