Alexander and Wall v Standard Telephones & Cables Ltd (No 2) [1991] IRLR 287 is a UK labour law case on when a collective agreement is incorporated into an employment contract.
‘It is undoubtedly primarily a policy document applicable to the relationship between the unions and the company.
It is also specifically concerned with procedure.’ Another clause referring to redeployment depended on another company division accepting the worker.
In this context, where none of the other clauses of the collective agreement are apt to be incorporated into the individual contract of employment, it would require some cogent indication in clause 6 that it was to have a different character… [Paragraph 6.2 was expressed] ... in policy terms having regard to inter-union relationships’.
[Paragraph 6.1] ... is expressed in terms which are capable of giving rise to individual rights… However, I consider that the wording of paragraph 6.1 is too weak, when considered in the context in which it occurs… Clear and specific express words of incorporation contained in a primary contractual document could displace this conclusion…