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This book provides a comprehensive comparison of German and UK labour law, focusing on the fundamental differences between the two systems. It looks at the structured security and comprehensive protection that German labour law offers employees and contrasts this with the more flexible, less regulated approach in the UK. Topics such as company takeovers, home office regulations, vocational training and much more are analysed in detail. The reader is given an insight into the respective legal frameworks, the advantages and disadvantages of both systems and their impact on employee rights. This book is an indispensable reference work for anyone interested in the legal cultures of both countries and their consequences for the labour market. It also examines the consequences of Brexit.
There are significant differences between labour law in Germany and France that affect both employees and employers. In Germany, labour law is strongly influenced by the principles of the welfare state. It places particular emphasis on the protection of employees, especially through comprehensive co-determination rights of works councils and strict regulation of dismissals. The Dismissal Protection Act ensures that employees can only be dismissed under certain conditions, which guarantees a high level of job security. In addition, collective labour agreements are widespread in Germany and offer additional protection mechanisms. In France, on the other hand, labour law is more centralised and state-controlled. The ‘Code du Travail’ regulates many aspects of working life and provides for strict regulations in some areas, such as working hours and the minimum wage. French labour law is characterised by a high degree of state intervention, which is reflected in the traditionally high importance of trade unions and industrial action. The regulations on the dismissal of employees are also strict, but more flexible compared to Germany, especially after the labour law reforms under President Macron. These differences in labour law reflect the different historical, social and political developments in the two countries. While the principle of social partnership and decentralisation is paramount in Germany, French labour law is characterised by strong state regulation and centralism. An understanding of these differences is essential for companies and professionals operating in both countries in order to correctly fulfil the respective labour law requirements and avoid conflicts.
In a constantly changing global world of work, national differences in labour law are becoming increasingly important. This book offers a well-founded and detailed comparison between German and Swedish labour law, highlighting the central principles, structures and regulations of both countries. It analyses the role of collective agreements, protection against dismissal, employee co-determination and the flexibility of the labour market. While German labour law is characterised by strict regulation and comprehensive protection against dismissal, the Swedish model takes a more liberal approach with a stronger emphasis on social security and economic adaptability. This comparison makes it clear how two different legal systems in Europe react to similar challenges and what advantages and disadvantages result for employees and employers. The book is aimed at anyone who wants to gain a deeper understanding of the labour law systems in Germany and Sweden. It shows in a practical way how these two models are organised and what lessons can be learned from their differences.
This book offers a comparative insight into the labour law systems of Germany and Canada, two countries with different legal traditions and approaches. It examines how in Germany a highly centralised system with clear legal requirements offers employees extensive rights and protections, while Canada has a decentralised, more flexible structure of labour law due to its federal structure. Particular emphasis is placed on the federal principle in Canada, where the provinces and territories set their own labour law standards. This decentralisation leads to considerable differences in regulations on minimum wages, working hours, protection against dismissal and holiday entitlements - depending on the region in question. The book shows the consequences of this diversity and highlights the advantages, such as adaptability to regional needs, but also the challenges associated with this legal fragmentation, such as the difficulty of enforcing the law and the mobility of workers. The detailed comparison shows how strongly employee rights in Germany are protected by statutory regulations and collective co-determination, while in Canada greater flexibility for employers and a stronger role for individual employment contracts dominate. This work is aimed at those affected and anyone wishing to gain a sound understanding of the differences and similarities between these two systems - and how these differences influence the dynamics of labour markets, the relationship between employers and employees and social security in both countries.
The book ‘Labour Law Differences between Germany and Spain’ offers a comprehensive analysis of the labour law regulations in both countries in comparison. It takes an in-depth look at the main differences in all relevant areas, such as employment contracts, protection against dismissal, working hours and collective agreements, and also addresses the specific characteristics and challenges arising from the different national legal systems. In Germany, the labour market is highly regulated, with a particular focus on comprehensive protection against dismissal and strict regulations on working hours. In contrast, Spanish labour law is more flexible, particularly with regard to fixed-term employment contracts and the implementation of dismissals. This flexibility offers employers more room for manoeuvre, but often comes at the expense of job security for employees. The book also examines the social security systems in Germany and Spain and analyses their influence on the structure of labour relations. It becomes clear that German legislation is strongly orientated towards the protection of employee rights, while the Spanish system tends to focus more on economic flexibility. This work is therefore an indispensable reference work for anyone who needs an in-depth and lasting understanding of the differences in labour law between Germany and Spain. It contributes significantly to a better understanding of the complexities of the international labour law landscape and how to respond effectively.
The complexity of employment arrangements in various countries tends to make it difficult to understand them. Nevertheless, it is important to 'take stock' periodically, particularly from an internationally comparative perspective. This remarkable book is a giant step in that direction. It is especially valuable in the context of increasing globalisation. For each of nine key jurisdictions - the European Union, Germany, Sweden, United Kingdom, United States of America, Canada, New Zealand, Australia and Japan - experts present detailed information and analysis on key issues, shedding valuable light on trends in such specific areas of employment relations as the following: * atypical work and flexible work arrangements; * dispute settlement procedures such as negotiation, conciliation, mediation, arbitration and other forms of governmental or judicial intervention; * job security, anti-discrimination and gender equality; * recognition of unions and employers' associations and forms of employee representation; * how collective bargaining is regulated, whom the collective agreements cover and what they contain; * parental leave and childcare policy; * the capacity of individual agreements to override or not override collective agreements; * minimum wage levels; * overtime and shift work; and * paid leave entitlements. As a general framework, Part 1 offers an insightful summary of the underpinnings of current analysis of globalization, including discussion of the varieties of capitalism thesis, the divergence/convergence debate (with its models of bipolarization, clustering and hybridization), and elements of historical and political-economic path dependency in various cultures. The information gathered here furthers understanding of the increasing 'disconnect' between the prevailing institutional framework for employment relations and the sweeping changes that are taking place in the world of work. With this book's analysis, practitioners and policymakers will be able to overcome their dated assumptions and more effectively accommodate each others' interests in the face of the complex mix of continuity and change that they are confronting. The team of authors are experts in these countries. They are active in policy or legal analysis, business and/or scholarship.
Labour Law and Industrial Relations in Germany gives the reader a broad understanding of German labour law covering all important aspects. The book deals with the sources of labour law, individual employment relationships, collective bargaining, remuneration, working conditions, and dispute settlement.
The first casebook covering both international and comparative labor and employment law is characterized by its authorship by prolific, respected scholars, all of whom have taught law outside the United States. A solid conceptual framework compares national laws dealing with individual collective employment rights, including antidiscrimination law and privacy law, and considers the systems used to resolve labor and employment disputes in the context of international labor law. A sweeping coverage of international labor law considers the International Labour Organization, NAFTA and other bilateral trade agreements that include labor standards, and the European Union. In addition, The Global Workplace explores transnational corporations' self-regulatory efforts (or codes of conduct,) and the mechanisms for pursuing international labor standards in United States courts. Comparisons are drawn among the laws of the United States, Canada, Mexico, the United Kingdom, Germany, France, China, Japan and India. Exploring the similarities and the differences among various approaches to the employment relationship allows students to better understand and evaluate the approach each country takes, and helps them develop a normative approach to labor and employment law. National legal materials are presented within historical and cultural context. Hallmark features of The Global Workplace: International and Comparative Employment Law: First casebook covering both international and comparative labor and employment law Authorship o prolific, respected scholars o all of the authors have taught law outside the United States Conceptual framework o compares national laws dealing with individual collective employment rights o including antidiscrimination law and privacy law o considers the systems used to resolve labor and employment disputes in the context of international labor law Broad coverage of international labor law o International Labour Organization o NAFTA and other bilateral trade agreements that include labor standards o the European Union o comparison of the laws of the United States, Canada, Mexico, the United Kingdom, Germany, France, China, Japan and India o transnational corporations' self-regulatory efforts (or codes of conduct) o mechanisms for pursuing international labor standards in United States courts Explores the similarities and the differences among various approaches to the employment relationship o allows students to better understand and evaluate the approach each country takes o helps develop a normative approach to labor and employment law o national legal materials are contextualized with historical and cultural issues
Remarkably, the core element of labour relations?wage determination?has been excluded from the European social dialogue about harmonisation of working conditions and national systems of social security. The present study responds by analysing the prospects of building up structures of wage formation in Europe through a reevaluation of collective bargaining and collective agreements as they exist under the law of the most industrialized Member States. The impetus for the study is the widely debated crisis of the system of concluding regional collective agreements on wages. Social partners seem to have been trapped in fruitless conflicts on how the system must be reformed. It has become obvious that no party concerned employers, trade unions, the state has the capacity to resolve the growing difficulties of collective wage formation. In an introductory essay by the distinguished editors, this important study takes the situation in Germany, the most prominent manifestation of this European crisis, as its starting point. Then, academic experts from France, the United Kingdom, the Netherlands, and Sweden describe comparable problems in their own countries, detail approaches to dealing with them, and provide a critical commentary, including judgements and suggestions in relation to the German case. Then follows a reexamination of the situation in Germany in the light of the experience of the other countries. A final chapter outlines some preliminary interpretations of European prospects. Salient issues investigated include the following: the erosion of such ideological and legal categories and concepts as `dependent work, `solidarity', `subsidiarity' and `social self-regulation' as preconditions of traditional collective bargaining structures at national level; the decreasing membership of the bargaining partners on both sides; the shrinking rate of employees covered by collective agreements; attempts to establish a national social pact; increasing competition on global markets; decentralizing management strategies, including the abandonment of collective bargaining; and, individualized employees. The authors examine the various state structures to determine if the legal and institutional developments of the different national systems of collective bargaining constitute starting points for mutual learning in order to meet the new challenges. This leads to a discussion of which practices are successful in their original environment, and how these practices might adapt to other systems in other countries.