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In the Common Law, Ford v A.U.E.F. [1969],[8] the courts once ruled that collective agreements were not binding. Second, the Industrial Relations Act of 1971, introduced by Robert Carr (Minister of Labour in Edward Heath`s cabinet), provided that collective agreements were binding, unless a written contractual clause explained otherwise. After the death of the Heath government, the law was rescinded to reflect the tradition of the UK`s labour relations policy of legally refraining from workplace disputes. The union can negotiate with a single employer (which usually represents the shareholders of a company) or, depending on the country, negotiate with a group of companies to reach a sectoral agreement. A collective agreement is a contract of employment between an employer and one or more unions. Collective bargaining consists of the process of negotiation between representatives of a trade union and employers (usually represented by management or, in some countries such as Austria, Sweden and the Netherlands, by an employers` organisation) on workers` conditions of employment, such as wages, working hours, working conditions, complaint procedures and the rights and obligations of trade unions. . . .