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Differences in Labour Law Between Germany and the United Kingdom

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Release : 2024-07
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Kind : eBook
Book Rating : 500/5 ( reviews)

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Book Synopsis Differences in Labour Law Between Germany and the United Kingdom by : Ralph Lang

Download or read book Differences in Labour Law Between Germany and the United Kingdom written by Ralph Lang. This book was released on 2024-07. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Differences in Labour Law between Germany and France

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Release : 2024-09-02
Genre : Law
Kind : eBook
Book Rating : 889/5 ( reviews)

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Book Synopsis Differences in Labour Law between Germany and France by : Klaus Degenhardt

Download or read book Differences in Labour Law between Germany and France written by Klaus Degenhardt. This book was released on 2024-09-02. Available in PDF, EPUB and Kindle. Book excerpt: 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.

The Sources of Labour Law

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Release : 2019-12-06
Genre : Law
Kind : eBook
Book Rating : 045/5 ( reviews)

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Book Synopsis The Sources of Labour Law by : Tamás Gyulavári

Download or read book The Sources of Labour Law written by Tamás Gyulavári. This book was released on 2019-12-06. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Differences in Labour Law between Germany and Sweden

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Release : 2024-09-04
Genre : Law
Kind : eBook
Book Rating : 943/5 ( reviews)

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Book Synopsis Differences in Labour Law between Germany and Sweden by : Tilmann Ehrlicher

Download or read book Differences in Labour Law between Germany and Sweden written by Tilmann Ehrlicher. This book was released on 2024-09-04. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Differences in Labour Law between Germany and Canada

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Release : 2024-09-07
Genre : Law
Kind : eBook
Book Rating : 001/5 ( reviews)

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Book Synopsis Differences in Labour Law between Germany and Canada by : Thomas Murrhardt

Download or read book Differences in Labour Law between Germany and Canada written by Thomas Murrhardt. This book was released on 2024-09-07. Available in PDF, EPUB and Kindle. Book excerpt: 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.

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