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403 Declaration. Parent Company’s Liability for Performance of Social Plan

A discussion of the judgment of the Court of Appeal of 's-Hertogenbosch, JAR 2009/126

403 Declaration
A 403 declaration (a term derived from Section 403 of Book 2 of the Dutch Civil Code ("BW")) is a declaration of a parent company in which it assumes joint and several liability for the debts arising from any legal acts of its subsidiary(ies).
When a 403 declaration is filed with the Trade Register, the subsidiaries are exempted from publishing and arranging their annual accounts in accordance with the normal provisions of the BW. All they have to do is to prepare a summary balance sheet and profit and loss account. The parent, however, is obliged to prepare and to publish a consolidated balance sheet. This way a subsidiary can swap its obligation to provide creditors with insight in its financial position through its annual accounts against the assumption of liability by the parent. As a result the administrative financial burden within the group is usually decreased.

The Facts
In the case at issue, a social plan was agreed in December 2003 between a private company (the "Employer") and the trade unions in connection with a reorganization. This social plan provided that the employees of the Employer would be awarded compensation and that holidays and leave days not yet taken would be paid out. On 21 December 2005 the Employer was declared bankrupt. At that time the above-mentioned compensation and payment of the holidays and leave days had not yet been fully completed.
In 1999 the parent company of the Employer ("the Parent") filed a 403 declaration, which was an assumption of joint and several liability for all obligations arising from any legal acts performed by the Employer during and after 1998. In 2001 the Parent replaced the 403 declaration by a similar declaration in somewhat different words, this time being an assumption by the Parent of joint and several liability for all debts arising from any legal acts performed by the Employer. Shortly before the bankruptcy, the Parent then withdrew the 403 declaration.

Despite demands made by employees, the Parent has refused to pay the remaining parts of compensation under the social plan, and has also refused to pay out the leave days and holidays.

The main ground for appeal of the Parent in these proceedings is the following:
The social plan must be seen in coherence with the employment agreements, and must therefore be deemed to "arise from" the employment agreements. All employment agreements were concluded before 1998, and the first 403 declaration states that liability applies only to legal acts performed during and after 1998. The Parent maintains that the second 403 declaration must be seen in the light of the first, and therefore the obligations arising from the employment agreements could not lead to the Parent's liability.
The Court of Appeal rejected this ground for appeal, considering inter alia that the contracting party (in this case the employees) of the subsidiary cannot derive any rights vis-à-vis the Parent from Section 2:403 of the BW, but can only derive rights from the declaration filed by the Parent. Interpretation of this declaration will have to establish what it means in a concrete case.
Subsequently, the Court of Appeal considered that the second 403 declaration constitutes, unlike the Parent thinks, an assumption of liability for all legal acts of the Employer performed before and at the time of the declaration. It is then irrelevant that the wording of the first 403 declarations had a more limited purport. After all it is only relevant how the creditors could reasonably interpret the declaration, in view of its contents and purport.

The Court of Appeal added the comment that the entry into a social plan creates direct obligations of the employer towards the employee. Therefore, even if the first 403 declaration would still have been in force, the Parent would still have been liable for the obligations arising from the social plan. Finally, the Court of Appeal pointed out that it is also important that negotiating trade unions may assume on the basis of the 403 declaration that the parent company is jointly and severally liable for the obligations of the contracting subsidiary.

The Court of Appeal therefore concluded that the Parent is both jointly and severally liable for the obligations of the Employer under the social plan and for the correct settlement of the obligations of the Employer as an employer arising from the employment agreements.

Tips
  • This judgment goes to show once more that it is worthwhile to examine whether a 403 declaration has been or had been issued with regard to a legal entity. Withdrawal of this declaration does not affect the liability for debts arising from legal acts that have occurred during the period of validity of the declaration or that became claimable during this period, as long as the legal entities remain part of the same group.
  • The next essential step is to become acquainted with the precise wording of the relevant 403 declaration, because, as the present case shows, this influences the scope of the liability.
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Maurits Bos

Tel: +31 20 5506 803
E-mail: maurits.bos@kvdl.nl

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