Ireland: The Industrial Relations (Amendment) Act 2015

Last Updated: 12 October 2015
Article by Arthur Cox's Employment Law Practice
Most Read Contributor in Ireland, October 2018

 The Industrial Relations (Amendment) Act 2015 was enacted on 22 July 2015 and came into force on 1 August 2015.

The Act makes provision for three main areas, namely:

  • it creates a new regime for registered employment agreements ("REAs");
  • it makes provision for sectoral employment orders ("SEOs"); and
  • it adjusts the Labour Court's jurisdiction, created by the Industrial Relations (Amendment) Act 2001, to make legally binding determinations affecting employers who do not engage in collective bargaining with trade unions.

1. REGISTERED EMPLOYMENT AGREEMENTS

Why was it necessary to legislate for REAs?

The previous statutory regime governing REAs (Part III of the Industrial Relations Act 1946) was declared to be unconstitutional by the Supreme Court in 20131 and the 2015 Act accordingly creates an entirely new regime for REAs.

What are REAs?

An employment agreement ("EA") is an agreement made between a trade union(s) of workers and an employer(s) (or a trade union(s) of employers), relating to the remuneration or conditions of employment of workers of any class, type or group, that is binding only on the parties to the agreement. An EA becomes an REA when it is registered in the Labour Court's Register of Employment Agreements. 2

In what circumstances can an EA be registered?

Any party to an EA may apply to the Labour Court to have the EA registered, and the Labour Court must register the EA it if the statutory conditions are satisfied. Those conditions3 are:

  • all the union(s) and the employer(s) party to the EA must agree that the EA should be registered;
  • the EA must be expressed to apply to all the workers of a particular class, type or group and their employers party to the EA;
  • the trade union(s) party to the EA must be substantially representative of the workers in the class, type or group to which the EA is expressed to apply;
  • it must be normal and desirable practice or expedient to have a separate REA for these workers in that class, type or group;
  • registration of the EA must be likely to promote harmonious relations between the workers and their employer(s) and the avoidance of industrial unrest;
  • the EA must provide that, if a trade dispute occurs between the workers and the employer(s) party to the EA, industrial action or a lock-out shall not take place until the dispute has been submitted for settlement by negotiation in the manner specified in the EA;
  • the EA must specify the circumstances in which a party or parties may terminate the EA; and
  • the EA must be in a form suitable for registration.

Once registered, is an REA permanent?

The REA itself must specify the circumstances in which a party may terminate it. In addition, a party to an REA may apply to the Labour Court to have it cancelled or have its terms varied, either by agreement of all parties or, failing agreement, following a dispute resolution process and the involvement of the WRC. 4

How is an REA to be interpreted?

A party to an REA may apply to the Labour Court for an interpretation of the REA or its application to any person and the civil courts must have regard to any such interpretation. If a dispute regarding an REA comes before a civil court, it may refer an REA to the Labour Court for interpretation. 5

What is the effect of REAs on employers or workers who are not party to them?

In 2013, the previous REA regime (contained in Part III of the Industrial Relations Act 1946) was struck down by the Supreme Court in McGowan & Ors v Labour Court & Anor6 because an REA under the 1946 Act could bind employers who were not party to it. Accordingly, the REA regime represented an impermissible exercise of the legislative power of the State which is reserved to the Oireachtas. Under the 2015 Act, REAs will be legally binding only on employers and unions who are party to them and on relevant employees of those employers. If there is a desire to bind non-party employers the persons concerned will need to seek an SEO.

What is the effect of REAs on those who are party to them?

Any REA will apply to every employer of the class, type or group to which it is expressed to apply and to their workers party to the REA. If the contract of employment of an employee to whom an REA relates provides for a lower rate of remuneration, or less favourable conditions than those set out in that REA, the more favourable REA provisions will be substituted for the equivalent provisions in the contract of employment. 7

How are REA's enforced?

The Act requires employers to whom an REA applies, to keep employment records at the place of work to show compliance with the REA. These records must be kept for at least 3 years from the date of their making and an employer who fails to comply with this provision shall be guilty of an offence. A worker in respect of whom a claimed infringement took place may present a complaint to a WRC Adjudication Officer, from whose decision there is an appeal to the Labour Court. The Adjudication Officer may direct compliance and award compensation of up to two year's remuneration. 8

2. SECTORAL EMPLOYMENT ORDERS (SEOS)

What are SEOs?

SEOs are orders made by the Minister for Jobs, Enterprise and Innovation, on the recommendation of the Labour Court and approved by resolution of both Houses of the Oireachtas, which set out the minimum rates of remuneration and the minimum pension and sick pay entitlements of workers of a particular class, type or group within a specified economic sector. They are similar to REAs but their application is not confined to employees of the employer(s) party to them and their scope is confined to pay, sick pay and pensions.

Why was it necessary to legislate for SEOs?

The SEO regime partially replaces the previous REA regime that was declared unconstitutional. SEOs will apply to all workers and employers within the relevant sector but the crucial difference is that they will be contained in a Ministerial order approved by both Houses of the Oireachtas, as opposed to an agreement between private parties registered by the Labour Court.

How can an SEO be obtained?

A trade union of workers substantially representative of workers of a particular class, type or group in an economic sector or a trade union of employers may apply to the Labour Court to have the Court review the remuneration and sick pay and pension entitlements of workers of that class, type or group within that sector. 9 A number of statutory conditions must be satisfied before the Court will engage in such a review. If the Labour Court deems it appropriate after carrying out its review, the Court can make a recommendation to the Minister with regard to rates of pay, sick pay and pension schemes in that sector, and in so doing it must have regard to certain matters 10 and it must be satisfied with regard to certain matters. 11 If the Minister is satisfied that the Labour Court has complied with the Act, the Minister must then make the SEO. 12

The SEO regime has a number of safeguards for employers as follows:

  • before the Labour Court can examine an economic sector, it must publish notice of the intended examination and hear representations from any interested parties from that sector;
  • prior to making a recommendation for an SEO, the Labour Court must consider its effect on employment and competitiveness levels within the sector; and
  • an employer may apply for an exemption from a specified SEO, although such exemptions are subject to onerous statutory controls. 13

What is the effect of an SEO?

An SEO will apply to every worker of the class, type or group in the economic sector to which it is expressed to apply and to their employers. If the contract of employment of a worker to whom an SEO relates provides for a lower rate of remuneration or less beneficial sick pay or pension entitlements than those set out in that SEO, the more favourable SEO provisions will be substituted for the equivalent provisions in the contract of employment. 14 In addition, an employer must not penalise an employee for relying on their rights in relation to the SEO system. 15

How are SEOs enforced?

The Act requires employers to whom an SEO applies, to keep employment records at the place of work to show compliance with the SEO. These records must be kept for at least 3 years from the date of their making and an employer who fails to do so shall be guilty of an offence. 16 A failure on the part of an employer to comply with the terms of an SEO can be the subject of a complaint to an Adjudication Officer (and an appeal to the Labour Court) and result in an award of up to 2 years remuneration together with an order directing the employer to comply with its obligations thereunder. 17

3. THE LABOUR COURT AND NON-UNION EMPLOYEES

What is the background to the new provisions?

The Industrial Relations (Amendment) Act 2001 created a regime enabling the Labour Court to make non-legally binding recommendations, and thereafter legally binding determinations, with regard to disputes regarding terms and conditions of employment and dispute resolution and disciplinary procedures affecting employees for whom their employer does not engage in collective bargaining negotiations, but the Labour Court could not thereby impose collective bargaining on such an employer. The 2015 Act amends the regime created by the 2001 Act (as previously amended by the 2004 Act).

Why was it necessary to legislate to amend the existing regime?

In Ryanair Ltd v The Labour Court18 the Supreme Court considered the meaning to be given to the term "collective bargaining" in the 2001 Act and concluded that in a non-union company, collective bargaining did not have to take the same form and adopt the same procedures as would apply in collective bargaining with a trade union, and that the term should be given its "ordinary dictionary meaning". The Court held that "If there is a machinery in [the employer] whereby the [relevant employees] may have their own independent representatives who sit across the table with representatives of [the employer] with a view to reaching agreement if possible, that would seem to be "collective bargaining" within the ordinary dictionary meaning. It would seem strange if definitions peculiar to trade union negotiations were to be imposed on non-unionised companies." Following the Ryanair decision, the 2001 Act fell into disuse and the 2015 Act includes amendments designed to make the 2001 Act regime more attractive to trade unions such that it might again be used by unions to intervene in support of their members in non-union employments. There are also provisions which compel the Labour Court to adopt a wider perspective in considering whether to make such a recommendation or determination.

How does the 2015 Act change the 2001 Act regime?

It does so by:

  • defining the term "collective bargaining", with particular reference to non-union companies/employees; 19
  • providing for a wider range of factors that the Labour Court must take into account in making its recommendations and determinations; 20
  • possibly dis-applying the regime where the number of union members party to the dispute is insignificant; 21
  • restricting the making of multiple applications to the Court in respect of the same categories of employees; 22 and
  • extending the jurisdiction of the Circuit Court to grant injunctions to protect employees who may have been dismissed by reason of an application made to the Labour Court under the 2001 Act. 23

What is Collective Bargaining?

The Act defines collective bargaining as voluntary engagements or negotiations between any employer or employer's organisation on the one hand and a trade union of workers or an excepted body on the other hand, with the objective of seeking agreement regarding the working conditions or terms of employment or non-employment of workers. 24 The definition requires that there be more than consultation or the exchange of information. The purpose of the exercise must be to seek agreement on working conditions and terms of employment or non-employment.

What is an excepted body?

An excepted body, for the purpose of the Act, is a body that is independent and not under the domination and control of an employer or trade union of employers all the members of which body are employed by the employer and which carries on engagements or negotiations with the object of reaching agreement regarding the wages or other conditions of employment of its own members but of no other employers. 25 The 2015 Act seeks to restrict the circumstances in which an employee forum or works council can be considered to be an excepted body and thereby allow an employer to defeat an application to the Labour Court under the 2001 Act on jurisdictional grounds. There are a number of factors which the Labour Court must consider in deciding whether an arrangement should be considered to be an exempted body. An employer who asserts they have engaged in collective bargaining with an excepted body will bear the burden of proving this. The 2015 Act provides criteria which the Labour Court must take into account in making a decision on this jurisdictional issue, as follows:

  • how employees are elected to the elected body;
  • how often the elected body holds elections;
  • whether, and to what extent, the employer has funded or resourced the elected body beyond minimum logistical support; and
  • how long the elected body has existed and whether the employer had previously engaged in collective bargaining with that body. 26

What does the Act mean for employers who choose not to participate in collective bargaining?

The Act does not impose any obligation on employers to engage in collective bargaining. However the Act, by amending the 2001 Act, does broaden the circumstances in which workers, whose employers refuse to engage in collective bargaining, can have relevant disputes addressed.

What conditions must be satisfied before the Labour Court can intervene?

The conditions, with reference to a trade dispute relating to terms and conditions of employment and dispute resolution and disciplinary procedures, set out in the 2001 Act (as amended by the 2004 and 2015 Acts) are that:

  • The employer does not engage in collective bargaining in respect of the workers party to the dispute as a matter of practice and any internal dispute resolution procedures normally used have failed to resolve the dispute;
  • The employer has failed to observe a provision, either entirely or in good faith, of the Code of Practice on Voluntary Dispute Resolution or the WRC cannot advance the resolution of the dispute and reports same to the Labour Court. This failure must not have been because of the actions of the trade union or the employees; and
  • The trade union or employees did not have recourse to industrial action after the dispute in question was referred to the Workplace Relations Commission in accordance with the provisions of the Code. 27

How are disputes involving insignificant numbers of workers dealt with?

The number of workers party to the dispute must not be insignificant unless exceptional and compelling circumstances for investigating the dispute exist. In determining this, the Court must have regard to the total numbers employed by the employer in the grade, group or category to which the trade dispute relates and, if it establishes the numbers are not insignificant, the Court will then consider the total numbers of employees employed by the employer and involved in any related group, grade or category. The Act provides that a trade union may establish the numbers by way of a statutory declaration but an employer can then ask the Labour Court to examine the accuracy of the contents of this statutory declaration but the Labour Court may not disclose the identity of the union members. 28

What factors must the Labour Court take into account where the jurisdictional issues are satisfied?

Any review of the remuneration or terms or conditions of employment of workers must relate to same in their totality. This will involve the Labour Court comparing the situations of the workers involved with similar workers employed in similar employments. This may include workers of an associated company outside the State. Regard may be had to the comparability of skills, responsibilities, physical and mental effort required to perform the work involved. The Labour Court must consider the effect of any determination it might make on the maintenance of employment and the long term sustainability of the business involved. 29

How are multiple claims dealt with?

In general, the Labour Court will not embark on an investigation where one was carried out within the previous 18 months. 30

What protections are there for a worker who participates in such an investigation by the Labour Court?

The Act provides that if a worker is dismissed by reason of their participation in the process this will constitute unfair dismissal and such a worker may apply to the Circuit Court for interim relief pending the determination of a claim for unfair dismissal. 31

What are the overall implications of the collective bargaining reforms introduced by the Act?

Employers who engage in collective bargaining with one or more trade unions in respect of workers with whom the dispute arises will not be affected. For non-union employers who engage with an employee forum/ staff representative group, it will be necessary to assess whether or not this employee forum/ staff representative group constitutes an excepted body for the purposes of the Act and whether an employer can prove that in accordance with the criteria given. Otherwise that employer will be vulnerable to a referral under the 2001 Act and a consequential Labour Court determination.

Footnotes

1. McGowan and Others v The Labour Court and Anor [2013] IESC 21

2. Section 6

3. Section 8

4. Sections 9 and 10

5. Section 12

6. [2013] IESC 21

7. Section 11

8. Sections 22 and 23

9. Section 14

10. Those conditions, which are set out in section 14(2), in summary are:

(i) where the request is made by a trade union of workers or jointly with a trade union of workers, the trade union of workers must be substantially representative of the workers of the particular class, type or group in the economic sector concerned; and

(ii) where the request is made by a trade union or an organisation of employers or jointly with a trade union or an organisation of employers, the trade union or organisation concerned must be substantially representative of the employers of the workers concerned.

11. Those matters, which are set out in section 16(2), in summary are:

(a) the potential impact on levels of employment and un­employment in the identified economic sector concerned;

(b) the terms of any relevant national agreement relating to pay and conditions for the time being in existence;

(c) the potential impact on competitiveness in the eco­nomic sector concerned;

(d) the general level of remuneration in other economic sectors in which workers of the same class, type or group are employed;

(e) that the sectoral employment order shall be binding on all workers and employers in the economic sector concerned.

12. Those matters, which are set out in sections 15 and 16(4), in summary are:

(i) the trade union of workers must be substantially representative of the workers of the particular class, type or group in the economic sector concerned, and in satisfying itself in that regard, the Court must take into considera­tion the number of workers in that class, type or group represented by the trade union of workers;

(ii) where the request is made by a trade union or organisation of employers (or jointly with a trade union or organisation of employers), the trade union or organisa­tion concerned must be substantially representative of the employers in the particular class, type or group in the economic sector concerned, and in satisfying itself in that regard, the Court must take into consideration the number of workers employed in the particular class, type or group in the economic sector concerned by employers represented by the trade union or organisation of employers concerned;

(iii) the request must be expressed to apply to all workers of the particular class, type or group and their employers in the economic sector concerned;

(iv) it must be a normal and desirable practice, or expedi­ent, to have separate terms and conditions relating to remuneration, sick pay schemes or pension schemes in respect of workers of the particular class, type or group in the economic sector concerned;

(v) any recommendation must be likely to promote harmoni­ous relations between workers of the particular class, type or group and their employers in the economic sector concerned;

(vi) the making of the recommendation must promote harmonious relations between workers and employers and assist in the avoidance of industrial unrest in the economic sector concerned;

(vii) the making of the recommendation must be reasonably necessary to:

(i) promote and preserve high standards of training and qualifications, and

(ii) ensure fair and sustainable rates of remuneration, in the economic sector concerned.

13. Sections 15, 16 and 17

14. Section 19

15. Section 20

16. Section 22

17. Section 23

18. [2007] 4 I.R. 199

19. Section 27

20. Section 28(b)

21. Section 28(b)

22. Section 28(b)

23. Section 34

24. Section 27

25. Section 27

26. Section 28

27. Section 2 of the 2001 Act

28. Section 29

29. Section 30

30. Section 28

31. Section 34

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
Similar Articles
Relevancy Powered by MondaqAI
 
In association with
Related Topics
 
Similar Articles
Relevancy Powered by MondaqAI
Related Articles
 
Related Video
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Registration (you must scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions

Mondaq.com (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of www.mondaq.com

To Use Mondaq.com you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.

Disclaimer

The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.

General

Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions