Employment Law - The Enforceability Of Post Employment Restraints Of Trade (vic.)

ying highly intelligent and highly qualified employees inrestrictive. Any restraint which tries to prevent an
a range of sophisticated commercial businesses is aemployee from working not only in the particular
risky business for employers.business of the former employer but any other
To acquire competitive business advantage in anassociated or ancillary business is likely to be struck
increasingly globalized and networked world ofdown. Likewise, a restraint which seeks to prevent
pharmaceuticals, genetics, telecommunications, poweran employee from working for an excessively
supply and information technology requires thelengthy period (generally more than 12 months) is
employment of highly qualified, well educated,also highly likely to be struck down and declared
experienced and clever employees.unenforceable. To overcome these problems, lawyers
Potential employers and employees are both welldraft restraint of trade clauses to have a "waterfall"
advised to seek legal assistance when drafting oreffect. The clause contains a number of alternatives,
accepting terms of employment. Due to the seniorityfor example, starting from a very wide restraint and
of these employees, their employment contracts arethen proceeding to an increasingly narrow restraint in
less likely to be workplace agreements but moreterms of future employment activities or in terms of
likely to be private , one-off, contracts oflength of time. Each one of the alternatives is
employment.severable from the contract if declared
Often, employees in the pharmaceuticals, genetics,unenforceable by a court. Accordingly, a court might
telecommunications, power supply and informationreject a restraint which provided for former
technology industries will have access to secret andemployee X not to be employed in any
confidential information which is both price andpharmaceutical industry within South East Asia
market-sensitive. This information might be chemicalincluding Australia. The court, on the other hand, may
formulae, scientific and technological data, chemical,be prepared to enforce a restraint which prevented
electrical or manufacturing trade processes, hardwareemployee X from being employed in the field of
or software engineering designs, or a range of othermolecular genetic artificial-blood technology in either
sophisticated technological and scientific information.Melbourne or in Sydney for a period of one year.
The potential employee will need access to thisSuch a restraint is far more precise and reasonably
information to perform his or her anticipated role.protects the former employer's confidential
When the employment relationship ends, however,information whilst allowing the employee to seek
the employer is faced with a double problem. First,employment in the general field of molecular genetics.
the employee is leaving. Whether the departure isA court must also be satisfied that an employer's
voluntary or involuntary, it will be an inconveniencefears are genuine. For instance, is the information
and a disruption to the employer. Secondly, and morereally secret and confidential? If the information is
importantly long term, the departing employee willonly knowledge which an employee would obtain
take with him or her, knowledge of the secret andthrough the repetitive working of his or her ordinary
confidential information which may be the very basisjob, courts are less likely to regard this as secret or
of the employer's competitive advantage in aconfidential information. Other sorts of information
particular industry or market.which are publicly available (even such as client
To minimise this long term disruption, employerscontact details and price lists) may also not qualify. If
often include restraint of trade clauses in employmentthere is no secret or confidential information, then
contracts when employing people in these sensitivethere can be no restraint of trade.
areas. Commonly, the restraint of trade will preventCourts will also look to see whether the employee
the former employee from seeking employment withwas specifically compensated for the restraint when
any competitor of the former employer in thefirst employed. If an employee received a specific
particular market for a period of time.additional sum as a hiring incentive for a longer than
In current times, where there is a shortage of trainednormal restraint of trade, courts are more likely to be
staff, particularly in scientific and technological areas,persuaded that the restraint, when ultimately applied,
the reason why an employee departs is generallyis reasonable. The employee has accepted the
because he or she has received a better offer fromrestraint when first employed and has received a
a competitor.specific benefit for it.
In deciding whether or not to enforce the restraintAnother factor which courts will examine is the
of trade clause against a departing employee,seniority of the former employee. The more senior,
Victorian courts have to balance a number ofthe more likely it may be that the now departed
competing factors.employee may be capable of encouraging other staff
First, neither Australian nor Victorian general law willto follow him or her and more capable of influencing
restrain a former employee from seekingformer clients to switch allegiance. Alternatively, if the
employment with a competitor. Any such restraintformer employee was not employed in a managerial
must be found in an enforceable clause in theposition and was only employed at either a junior or
contract of employment with the former employer.specific technical level, courts may be less worried
Employers, therefore, should always ensure thatabout wholesale client or staff defections which
staff are employed pursuant to written contracts ofwould need to be prevented by the restraint of
employment which contain enforceable restraints oftrade clause.
trade.Until recently, courts seemed reluctant to enforce
Secondly, Victorian courts will not allow employers torestraints of trade for more than 3-6 months.
prevent former employees from conducting a livingHowever, recent New South Wales Supreme Court
by practising the skills which may have taken manyauthorities seem to be swinging the pendulum back in
years to acquire through university courses orfavour of employers where the balancing exercise
practical experience. However, this is only a generaloutlined above suggests that the restraint of trade
rule or starting point.does need to be enforced to reasonably protect the
Thirdly, Victorian courts will not allow formerformer employer's market and confidential
employees to obtain an unfair springboard into a newinformation interests. For instance, Brereton, J., in
career by abusing the trust of the former employer.John Fairfax Publications Pty Ltd v. Bert & Ors
Examples are where employees spend an entire[2006] N.S.W.S.C. 995 upheld a restraint of trade for
weekend photocopying price lists, formulae, client12 months in relation to a former employee who had
contact details and other confidential information andbeen employed at a senior level. The same judge, in
then resign the following Monday morning to set up aCactus Imaging Pty Ltd v. Peters [2006] N.S.W.S.C. 17
competitive business the following Tuesday morning.(18 July 2006) also enforced a restraint of trade for
Essentially, Victorian courts perform a balancing act12 months in a situation where the former employee
between the competing interests of the employeeoperated in a restrictive market or oligopoly.
to be able to continue to gain a living on the oneThis is a complex area of law. Contracts of
hand and the employer's interests of being able toemployment generally and restraints of trade
reasonably prevent the disclosure of confidential andparticularly need to be carefully drafted to have their
secret trade-sensitive information to competitorsintended legal effect.
when the employment relationship ceases.Employers and employees need to be carefully
The sorts of factors courts have taken into accountadvised on the range of tactics available in post
are as follows. First, Victorian courts will look to seeemployment scenarios.
whether the restraint of trade is reasonable or is too