In 1994, the Labour Court rejected the Marine Port and General Workers Union’s appeal over a sales manager’s quarterly bonus at Irish Biscuits Limited. The decision was signed on 22 September 1994. The union said the worker had not received the proper bonus for the first three quarters of 1993. It cited the £500 quarterly bonus limit and said he received £200 after sales in his area rose by 17% in early 1994. Irish Biscuits Limited said the bonus depended on performance and the Leinster area fell below target in each of those three quarters. The Court upheld the Rights Commissioner’s recommendation that the worker accept that his bonus could vary and that he had not been unfairly deprived of an entitlement during 1993.