In Procek v Oakford Farms Ltd, the EAT held that a grievance, even when stated by the employee not to form part of the statutory grievance procedure, is still a statutory grievance. In this case, Mr Procek (who was Polish) alleged that he was treated less favourably than other nationals. In a letter to his employer he stated ‘I wish to bring to your attention the following points which I suggest are dealt with in an informal basis […] failing which […] I will lodge my step 1 formal grievance of racial discrimination’. The employer contended that this could not be a statutory grievance because Mr Procek had clearly stated it was not. The EAT disagreed. An informal and non technical approach should be adopted towards the construction of grievance letters. The only question is whether it satisfies the requirements laid down for a step 1 grievance letter, which, in this case, it did.