In the two previous videos been focused on US employment law and US labor law. Now, in other parts of the world, US employment law is referred to by many different names, for example, individual labor law. And US labor law in other countries might be called something like collective labor law. Now, they're really just different names for the same thing. Individual labor law, clearly focused on the rights of workers as individuals, collective labor law clearly focused on the rights of workers as groups. Now, a cautionary reminder before we begin. In this short video, we can really only scratch the surface of so many different countries. And so the focus here is just to give you a flavor through examples. Anybody managing in one of these countries really needs to do more research, talk with other people, get more expert advice and expert insight into the laws that affect the employment relationship in that particular locality. Again, I can only give you a flavor here. In doing so, though, I wanna focus on the things that are perhaps the most different from what we've already covered in terms of US employment law and US labor law, and really focus then on six things. Unjust dismissal, employment contracts, working hours and leaves. National, not organizational benefits, extension of collective bargaining agreements, and works councils. The first four are more out of the employment law domain, or the individual labor law domain, the last two more out of collective labor law. First, unjust dismissal. This is probably the single biggest difference between the United States and the rest of the world. The United States is unique among industrialized countries in the extent of at-will employment and the lack of just cause dismissal protections. I showed you this graph in a previous video, but I want to bring it up here again to really reinforce the extent to which the US stands alone for its lack of employees covered by unjust dismissal protections. Now as a reminder from that earlier video, the protections in these different countries can be quite different. In Canada, unjust dismissal protection consists of making sure employees are provided sufficient advance notice before they're fired. In France, the unjust dismissal protection might be a salary payment, and in some other countries like Germany, the unjust dismissal protection can be reinstated. Okay, a second difference is employment contracts. In the United States we see employment contracts as really focused on very special situations like top executives, professional athletes, actors, things of that nature. In many other countries, employment contracts are actually required for many employees. In China, an employer is required to give each full time worker a contract specifying the length of employment, the workers job description and some other details. In Great Britain, an employer must give employees a written statement of employment particulars, which gives the pay, hours of work, holiday entitlement, pensions, and other types of things. So this is a big difference between the United States and many other countries in the rest of the world. Turning to working hours and leaves, here again, there can be big differences between the United States and other countries. And also of course big differences just across other countries. Some countries have shorter standard work weeks before overtime kicks in. Many countries have mandated vacations. Most countries outside of the United States have paid sick leave. Many have maternity or parental leave benefits as well. Okay, and unlike in the United States where many benefits, like vacation or health insurance, are provided by organizations, in many countries outside of the United States these benefits are provided nationally. They're mandated by law. So for example, vacations, sick leave, other leaves. There can be excess vacations and other leaves granted by the organization, but there's often a healthy legislated amount mandated at the national level. There's also national health insurance found frequently in many countries outside the United States. Similarly for state run pension plans. And so again, the emphasis here is that in many other countries, benefits can be national, rather than organizational. In the European Union, there's also the additional fact above national level policies that there can be supra-national policies at the European Union level. So for example, the European Working Time Directive mandates 20 days of annual paid leave. Now, we saw on an earlier slide, Sweden requires 25, so countries are able to do more than this, but this provides a floor across the entire European Union. There's also a Framework Directive on Safety and Health at Work, which provides for minimum safety and health requirements across all of the European Union countries. Okay, sticking with Europe, many European countries allow for union-negotiated collective bargaining agreements to be extended to all employers in that industry. So, even if your own employees aren't unionized, you still might have to abide by collective bargaining terms. Now unlike in the United States, these terms are frequently more around minimum standards, but nevertheless, you need to pay attention that a collective bargaining agreement might apply even though you didn't directly negotiate with a union. A second note on unions in Europe and other countries, often they can be more political than US unions. So remember the importance of perspective taking and understanding the pressures on your counterpart that I highlighted in the video on being a front stage back stage manager in the previous lesson. A last difference I want to highlight is works councils. In Europe and other places such as Korea Nonunion works councils are entitled to receive information and must be consulted over various personnel and work related issues before managers can make changes. Again, these are nonunion. And they're formed typically within a workplace, sometimes even if only a very small number of employees want to form them. So in dealing with the works council, remember our video on managing in a unionized environment where you set the tone for a relationship, not only with unions, but also with works councils. So, a lot of information out there. A lot of differences in labor law and employment law across different countries. How do you find out more? Well, you can just Google it, of course, or I also recommend the ILO's website on labor law. You can find country profiles, search for specific policies, and find lots of great information that way. So again, in a very short video, we can only begin to scratch the surface on all of the differences across the world. But hopefully, this highlights that there are many different ways of managing people. And you need to understand the legal system that you are managing within.
