Dutch restrictions


- a 'Freelance Informer' legal article from Roger Sinclair


‘I’ve worked for 3 years for a Client through an agency.  Initially, the contract was through my own company, in the UK .  Then it was through the Agency’s Dutch subsidiary as an employee – my company was not involved.  That contract has ended and the Client now wants me to come back to the UK – but without the agency.  I’m concerned about restrictions in the contracts.’

 

The initial contract, through your company, ended early by mutual agreement, when you moved to take up the contract in the Netherlands.  That contract (between your company and the agency – you yourself were not a party to it) contains a term under which your company undertakes that neither you nor your company will supply your services (other than through the agency) to the Client within one year of the end of that contract.  If that contract had run its full term, it would have ended 4 months ago – in which case the one-year period would still be current. 

 

However, whilst nothing was expressly said about it, even though both parties to the Dutch employment contract were different (on the agency’s side it was their Dutch subsidiary, and on yours it was you personally), it is clear from all the circumstances that there must have been agreement between the UK agency and your own company that that first contract would end early – your company ceased over 12 months ago to provide your services.  The restriction in that contract was worded in such a way as to run from the end of that contract, and so the period covered by it has now also ended, and you need not worry any more about that.  If that had been less than 12 months ago however, we would have had to consider whether cooperating with the Client’s plan would also have put you in breach of the term in that contract, and (if so) whether that term would have been enforceable.

 

So far as the second (employment) contract is concerned, it is in English but states that it is governed by Dutch law, and that only the Dutch courts are to deal with any matters arising under it.

 

The restriction in that contract provides that your services will not, without the (Dutch) agency’s consent, be made available to the Client during the 12 months after the end of that contract.  You are within that 12 month period, and since this contract is between you and the Dutch agency, it is you yourself (and not your UK company) who is at risk, in the event of any breach of the term.

 

I can tell you that in a temporary ‘contract of assignment’ under Dutch law (worded in a particular way, and lasting no more than 6 months or 1000 hours – and which your contract was NOT), such restrictions are not enforceable.  However, in a contract of employment (which yours was) such restrictions ARE capable of being enforceable.  It is beyond my own sphere of expertise to say whether or not the particular term in your contract is or is not in fact enforceable.  So the best we can do is to assume that it may be, and examine what your situation will be if you cooperate with the Client’s plans.

 

The Client for the proposed new UK contract is the same company as the Client for the Dutch contract.  It therefore follows that if your company were to enter a contract with the Client for the provision of services to the Client, and if you yourself provide such services, then you would appear to be placing yourself in breach of this restriction.

 

So what are the risks?  First, there is always the risk that where you place yourself in a position which the other party believes to be in breach of contract, then (whether they are right or wrong in that belief) if at that time they still owe you money, they may withhold it.  I do not say that they are entitled to do so – but as a simple fact of life, where someone feels they have been wronged, then the first avenue they are likely to turn to is to exercise self-help.  And that means you risk them hanging onto money they owe you, because they feel it will be some compensation for your breach.  In this case there is actually a term in the contract which if valid) would appear to entitle them to do so.  I do not express a view on whether or not that particular term here is enforceable (Dutch law would decide this question) – but whether or not it is, if the Dutch agency find out what you are planning before you have been fully paid for the work you did under your contract through them, then that money is at risk.

 

Any legal action they were to take would have to be taken in the Netherlands – but if they were to take such action and succeed in getting an award of damages for your breach, then there are procedures whereby they could register that judgment in the UK courts and enforce it over here.  My crystal ball does not tell me whether or not they in fact would do so – but they could.

 

All in all, to cooperate with the Client here would not be without personal risk.  I would suggest that you think very carefully before doing so – and (if you are willing to cooperate) then since the desire to take your services direct appears to come from the Client, I would suggest that you indicate that you are only willing to do so if the Client gives you a full written guarantee to cover you against any losses you may suffer as a result – whether that is income the Dutch agency withhold from you, or damages you have to pay, or legal costs of protecting your position. 

 

I wonder if they will then be so keen on the plan…

 

27th October 2000


I'd really appreciate your feedback on this FAQ - so mail me and tell me what you think of it, if it's been useful to you, or let me know of any specific problem you have where I may be able to help.

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