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An employer had a valid reason to dismiss an employee who breached its code of conduct, and its decision was fair regardless of whether she'd been specifically trained in the circumstances that led to her actions, the Fair Work Commission has found.

Further, in referring to the incident as "little" and "trivial", the employee showed she didn't fully accept the seriousness of her conduct, said Deputy President Alan Colman.

St Columba's College in Melbourne sacked the lab technician in February for breaching its 'Child Safe Code of Conduct', after she slapped the hand of an "unruly" student.

The employee claimed the dismissal was unfair, arguing it was a disproportionate response to her conduct, and that she didn't have a proper chance to respond to the allegations...