ECH22020 - Settlement: Culpability - Warning of Penalties

When all the facts are established the ECO should

  • form an opinion on culpability.

In cases of doubt or difficulty, the ECO should

  • discuss with the ECTM.

Warning the Employer or Contractor of Penalties

Where a penalty is appropriate, the ECO should

  • tell the employer that a penalty may be sought in any settlement
  • not
  • make firm predictions about whether a penalty will be sought

or

  • give any indication of the amount of the possible penalty
  • record in the notes of meeting that the employer or contractor has been warned that a penalty may be sought.