Differences in Labor Law Between Germany and the USA PDF Download

Author: Michael Siegle
Publisher:
ISBN: 9783689045067
Category :
Languages : en
Pages : 0

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Author: Seyfarth, Shaw, Fairweather & Geraldson
Publisher:
ISBN:
Category : Industrial relations
Languages : en
Pages : 646

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Book Description
Comparison of labour relations in the manufacturing industry of Germany, Federal Republic and the USA and commentary on relevant labour legislation - covers membership and legal status of trade unions, collective bargaining, collective agreements, labour contracts, dispute settlement, labour costs, wage payment systems, wage structures, wage incentives, social security, workers participation, working conditions, hours of work, personnel management, occupational health, etc. Bibliography pp. 591 to 606 and statistical tables.

Author: Kirsten S. Wever
Publisher: W.E. Upjohn Institute
ISBN: 0880992166
Category : Business & Economics
Languages : en
Pages : 184

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Book Description
Comprises five papers which compare industrial relations in Germany and the USA. Focuses on the intersection between the strategies and practices of employers, unions, and employer associations and the cultural and institutional frameworks within which they operate. Includes a general comparison of employment relations in the two countries.

Author: Klaus Degenhardt
Publisher: BoD – Books on Demand
ISBN: 3689047889
Category : Law
Languages : en
Pages : 210

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Book Description
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.

Author: Tamás Gyulavári
Publisher: Kluwer Law International B.V.
ISBN: 9403502045
Category : Law
Languages : en
Pages : 608

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Book Description
Labour law has traditionally aimed to protect the employee under a hierarchy built on constitutional provisions, statutory law, collective agreements at various levels, and the employment contract, in that order. However, in employment regulation in recent years, ‘flexibility’ has come to dominate the world of work – a set of policies that reshuffle the relationship among the fundamental pillars of labour law and inevitably lead to degrading the protection of employees. This book, the first-ever to consider the sources of labour law from a comparative perspective, details the ways in which the traditional hierarchy of sources has been altered, presenting an international view on major cross-cutting issues followed by fifteen country reports. The authors’ analysis of the changing hierarchy of labour law sources in the light of recent trends includes such elements as the following: the constitutional dimension of labour rights; the normative intervention by the State; the regulatory function of collective bargaining and agreements; the hierarchical organization of labour law sources and the ‘principle of favour’; the role played by case law in both common law and civil law countries; the impact of the European Economic Governance; decentralization of collective bargaining; employment conditions as key components of global competitive strategies; statutory schemes that allow employees to sign away their rights. National reports – Australia, Brazil, China, Denmark, France, Germany, Hungary, Italy, Poland, Russia, Spain, Sweden, South Africa, the United Kingdom and the United States – describe the structure of labour law regulations in each legal system with emphasis on the current state of affairs. The authors, all distinguished labour law scholars in their countries, thus collectively provide a thorough and comprehensive commentary on labour law regulation and recent tendencies in national labour laws in various corners of the globe. With its definitive analysis of such crucial matters as the decentralization of collective bargaining and how individual employment contracts can deviate from collective agreements and statutory law, and its comparison of representative national labour law systems, this highly informative book will prove of inestimable value to all professionals concerned with employment relations, labour disputes, or labour market policy, especially in the context of multinational workforces.

Author: Thomas Huber
Publisher:
ISBN: 9783689044947
Category :
Languages : en
Pages : 0

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Author: Roger Blanpain
Publisher: Aspen Publishing
ISBN: 1454822619
Category : Law
Languages : en
Pages : 1040

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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

Author: Seyfarth, Shaw, Fairweather & Geraldson
Publisher:
ISBN:
Category : Industrial laws and legislation
Languages : en
Pages : 0

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Book Description
Comparison of labour relations in the manufacturing industry of Germany, Federal Republic and the USA and commentary on relevant labour legislation - covers membership and legal status of trade unions, collective bargaining, collective agreements, labour contracts, dispute settlement, labour costs, wage payment systems, wage structures, wage incentives, social security, workers participation, working conditions, hours of work, personnel management, occupational health, etc. Bibliography pp. 591 to 606 and statistical tables.

Author: Thomas Murrhardt
Publisher: BoD – Books on Demand
ISBN: 3689048001
Category : Law
Languages : en
Pages : 246

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Book Description
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.

Author: Vera Karpuschkin
Publisher: GRIN Verlag
ISBN: 3656863660
Category : Business & Economics
Languages : en
Pages : 31

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Book Description
Seminar paper from the year 2014 in the subject Business economics - Business Management, Corporate Governance, grade: 1,3, Pforzheim University, language: English, abstract: This paper gives a brief overview about essential differences between the German and American business culture. Nowadays business is run globally and does not know any barriers. Trade and access to new markets are expanding, international mergers and acquisitions or joint ventures are increasing, business relations are getting strongly interconnected worldwide. Therefore, managers have to take into account national and international regulations. Employees of multinational companies work in various countries for a certain period, students go abroad as interns in order to gain work and intercultural experiences. Countries all over the world are involved in business issues, includ-ing the differences regarding cultures, societies, and the way of doing business, that creates not only opportunities but represents challenges as well. Through globalization business faces many workplace related cultural differences.