Legislation to protect employees in the UK was amended by Mr Grayling in 2018 so that the secretary of state does not have to be notified of mass redundancies on ships registered overseas.
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A letter to Mr Kwarteng from P&O's chief executive Peter Hebblethwaite written after the sackings says: "The very clear statutory obligation in the particular circumstances that applied was for each company to notify the competent authority of the state where the vessel is registered.
"All relevant vessels are registered outside the UK. Notification was made to the relevant authorities on March 17."
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The memorandum claimed the amendment had been supported by the unions who have led protests against P&O's actions.
"The UK Social Partners, Nautilus International (the officers union), RMT (the ratings union) and the UK Chamber of Shipping, have been fully supportive of the Seafarers Directive," it states.