7 May 2026

The Fair Work Ombudsman has secured a $14,554 penalty in court against a cleaning business operator in Sydney in a case involving “the exploitation of vulnerable workers”.

The Federal Circuit and Family Court has imposed the penalty against sole trader Nereshnie Pather, who has operated a business trading as ISHINE PTY LTD.

The penalty was imposed in response to Ms Pather breaching pay slip laws and failing to comply with a Compliance Notice, which required her to back-pay three migrant workers she employed as cleaners in May-June 2023.

The workers were in Australia on working holiday visas at the time. They included a Taiwanese national and a Chilean national.

In addition to the penalty, the Court has ordered Ms Pather to take the steps required by the Compliance Notice by back-paying the workers the amounts owing to them, plus superannuation and interest.

Acting Fair Work Ombudsman Rachel Volzke said employers that failed to act on Compliance Notices needed to be aware they could face court-imposed penalties on top of having to pay workers.

“Where employers do not comply, we will take appropriate action to protect employees. A court can order a business to pay penalties and to make payments to workers,” Ms Volzke said.

“All business operators should also be aware that taking action to protect migrant workers is an enduring priority for the FWO. Any employees with concerns about their pay or entitlements should contact us for free advice and assistance.”

Ms Volzke said non-compliance with pay slip laws was a serious issue.

“Pay slips provide employees with the clarity they need about their pay, and we expect every employer to follow laws requiring them to provide pay slips to their employees within one business day of them being paid,” Ms Volzke said.

The Fair Work Ombudsman investigated after receiving requests for assistance from the three affected workers, who were employed by Ms Pather on a casual basis.

Ms Pather employed two of the workers for less than a week and the other for about five weeks.

A Fair Work Inspector issued a Compliance Notice to Ms Pather in October 2023 in response to Ms Pather failing to pay the two workers employed for the shorter periods anything for the few shifts they worked, and underpaying the wages of the third worker over her employment.

The workers were entitled to receive the minimum casual hourly rate in the Cleaning Services Award 2020.

Ms Pather also breached the Fair Work Act by failing to issue pay slips to one of the workers.

Judge Mark Cleary found that Ms Pather had displayed “a complete disregard for legal obligations” and noted that “even small amounts of money can be significant to low-paid employees”.

Judge Cleary found there was a need to impose a penalty to deter cleaning industry employers and Ms Pather specifically from similar conduct in future, noting Ms Pather had recently been operating in the cleaning and real estate industries.

Judge Cleary said there was “a real risk that [Ms Pather] will employ people in the future and may contravene her obligations under the F[air] W[ork] Act again”.

“The need for deterrence is heightened in cases involving the exploitation of vulnerable workers, such as this case,” Judge Cleary said.

His Honour found that Ms Pather’s failure to issue pay slips to one of the workers was not a mere administrative oversight.

“The respondent's failure to issue pay slips to [the worker] meant that [the worker] was unable to monitor how her wages were calculated or to identify any underpayment at the time it was occurring,” Judge Cleary said.

Employers and employees can visit www.fairwork.gov.au or call the Fair Work Infoline on 13 13 94 for free advice and assistance. An interpreter service is available on 13 14 50. Employees can also seek information from their employer or their union, if they are a union member.

In 2024-25, the FWO secured total court penalties of more than $870,000 for failures to comply with Compliance Notices.

The Fair Work Ombudsman filed 171 litigations against employers involving visa holder workers, and secured $39 million in penalties in cases that have included visa holder workers, in the eight financial years to June 2025.

The FWO has an online anonymous report tool, including options to report in languages other than English, and information for migrant workers, including on protections for their visas, is available at our visa holders and migrants webpage.

The FWO provides a free online course to help employers understand what a Compliance Notice is and how to respond if they get one. The Compliance Notice course, among a suite of free interactive courses on offer for employers, managers and employees, is available in our online learning centre.

Employers can seek information from their employer association if they are a member, and also use the FWO’s pay calculator and Small Business Showcase.