These limited submissions are filed pursuant to the direction of the Fair Work Commission (FWC) of 8 March 2022 that the parties file, if they wish, written closing submissions of no more than 30 pages.

The ACTU has already filed and served three sets of written submissions. During the hearing on 1 March 2022, the ACTU delivered an oral opening submission. A fourth set of written submissions will be filed on 28 March 2022 addressing the conclusions to be drawn from the evidence. The ACTU will also file a response to the Background Document prepared by the Commission. The ACTU relies on its submissions contained in these documents, and at the hearing on 1 March 2022.

In addition, the ACTU files this short written submission which addresses the operation of the ACTU’s proposed clause, and the proposed removal of the model term providing for five days unpaid family and domestic violence (FDV) leave.