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What should an employer state in a reference when the employee is claiming constructive dismissal?

Do you have any information on giving a reference while there is an ongoing constructive dismissal claim.  The two issues are i) the duty to the prospective new employer; and ii) The employer's policy states that it will include a "reason for leaving" in a reference, what should the employer state as the reason for leaving when this is still in dispute (i.e. resignation or constructive dismissal). Any further guidance you may have is much appreciated.

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