Chapter
14
International and
Comparative Industrial
Relations
McGrawHill/Irwin
An Introduction to Collective Bargaining & Industrial Relations, 4e
Copyright © 2008 The McGrawHill Companies, Inc. All rights reserved.
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International and Comparative Industrial
Relations
• The U.S. has one of the lowest rates of unionization of any
advanced economy, and the rate of unionization has fallen
faster in the past 30 years than any other industrialized country
• American management opposes unionism more than most
other countries
• U.S. unions are less tied to politics than other western nations
• The trade deficit has emerged as a critical policy issue in light
of regional trade pacts in recent years
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Industrial Relations in Germany
The distinguishing feature is codetermination
• Mandated by German law and applies to all enterprises
whether or not they are union
Two key parts to codetermination:
• Employee representation on company boards and work
councils
• Provides a parallel form of representation to employees
that is in addition to the union representation
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Board Representation
• German law mandates employee representation on supervisory boards
• The number of representatives varies by the size of the firm
and industry, with special provisions for coal and steel
industries
• German firms have a twotiered board structure
The supervisory board (Aufsichtsrat) is the higher ranked board
• It has the responsibility to control managerial performance and
appoint top managers
The lower managing board (Vorstund) runs the firm on a dayto
day basis
Employee representatives to the supervisory board are elected
proportionately from the blue and white collar workforce
• The law reserves two or three seats for unions
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Work Councils
• Work councils are the second major component of the
German codetermination structure
• Mandated by law for private firms with five or more
employees
• Work councils have rights to information, consultation, and
codetermination
• The law requires negotiation with work councils for major
operational changes
• Works councilors are elected by all employees in a firm
regardless of union affiliation
• Works councilors cannot call a strike, but can sue
management in case of a breach of contractual rights
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Union Representation and Structure
• Unions play an important role in the German industrial
relations system
Unions represented 25% of the German work force in 2004
Union membership as a percentage of the workforce has been
steady since 1960
After unification, unions extended their jurisdiction to the former
East Germany
• Unions played a role in the restructuring of the East
• German unions are also active in political and social issues
• The largest federation of German unions, The Deutsche
Gewerkschaftsbund (DGB), is closely aligned to the SPD
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Collective Bargaining in Germany
Collective bargaining in Germany is highly centralized
• Most agreements are reached at the regional or industry level
• The most important unions in the private sector represent
workers in one or more industries
IG Metall represents metal working industries
Recently, a super union, Verdi, representing workers in the
service sector, was formed by amalgamation with a number
of private and public sector unions
German law does not give exclusive representation rights
• More than one union commonly represents workers
Employers commonly represented by associations in regional
bargaining
• Once an agreement is reached, the terms are extended by law to
other employees and firms in that industry
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Strike Rates in Germany
Over the postWorld War II period, Germany has had
a lower strike rate than other major industrialized
countries
• Some analysts argue that the low strike rate is a product
of the conflict mediation accomplished with
codetermination
• Others say the stability is due to the fear of returning to
the social instability that occurred before the rise to
power of Adolf Hitler
• The low strike rate could also be a product of
Germany’s huge economic success
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Vocational and Apprenticeship Training
Supporting German labormanagement relations is a very strong
vocational and apprenticeship training system
High schoolaged youth must choose among three educational
tracks at age 16:
• A collegebound program
• An apprenticeship vocational school program
• A general education program
Over 70% of high school graduates who don’t go to college
enter the vocational programs
• Overseen by joint businesslabor groups that set
qualifications for each program
• Provides highly skilled workers and cited for Germany’s
economic success
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Industrial Relations in Japan
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• Enterprise Unionism
The distinguishing feature of Japanese industrial relations is the
central role of enterprise unions
They represent both white and blue collar employees regardless of
occupation and include management staff
Only high level managers do not belong
New employees automatically become union members and pay
dues through a dues checkoff system
• Union and Employer Federations
Enterprise unions are commonly associated with federations, which
are affiliated with confederations
Employers commonly belong to counterpart federations
Bargaining is between the enterprise union and management of the
firm, but some industry level bargaining does occur
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The Lifetime Employment Principle
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• Japanese firms, particularly large ones, tend to hire new
employees upon graduation from either high school or college
Employees tend to stay until retirement
If a firm faces a financial crisis, it may try to shift workers to
other firms in their trading group, which are firms linked by
common ownership or business ties
Extensive cross training of workers facilitates these shifts
In addition, workers retire relatively early in Japan at the average
age 64
The use of many parttime workers help firms to keep the
lifetime promise
Wages are 1530% lower in smaller firms, and there is less
employment security
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Pay Determination in Japan
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Most pay agreements are set in annual negotiations
between a firm and the enterprise union
Many negotiations occur in spring offensive, or “Shunto”
Workers are typically paid a salary, plus a bonus of up to
five months pay
Seniority impacts pay (and thus age is a factor)
Performance appraisals up to twice per year with perhaps
a 10% annual bonus for good appraisals
Job definitions are broad and flexible in Japan
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The Role of Consultation in Japanese
Industrial Relations
• The labor relations system in Japan relies heavily on
consultation between labor and management to settle disputes
Grievance procedures are rarely used
Union membership (density) is falling in Japan
• 35% of the labor force from the 1950s1973
• 19.2% in 2004
Critics see enterprise unionism as the cooption of independent
unionism
Others see its success in conflict resolution, employee
commitment, and economic security
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Industrial Relations in Multinational
Firms
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• A multinational firm engages in economic activity in more
than one country
Multinational firms expanded greatly in the past 50 years
• Problems Created by Multinationals for Management and
Labor
The most important factors are cultural, legal, and institutional
differences, and the bargaining power gained by multinational
managements
• The Pressure of Diversity
The management of a multinational enterprise confronts cultural,
legal, and institutional diversity
Workers in different countries view work differently and place
different demands on their unions
European unions are often affiliated with political parties
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The Degree of Industrial Relations
Centralization
• The extensive diversity in culture, law, and institutions poses
coordination problems for the multinational firm
• Management’s problem is how to pursue company wide
objectives through industrial relations policies in the face of
this diversity
Response of multinational firms has been
decentralization of industrial relations
The expansion of globalization in recent years has
reversed that trend as firms sought global integration of
policies
• The challenge is that culture and law retain international
diversity while globalization increased the premium for
coordination
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The Power Advantage Provided to Management 17
by Multinational Operations
The expansion of economic activity across national
boundaries reduces the bargaining power of unions
Management can shift production and capital across borders
and raise competitive pressures
If faced with a strike, management can use alternative
production facilities
• Similar to the “competitive menaces” noted by John
Commons that occurred after the expansion of markets in
early industrialization and thence weakened the unions
• Management can move production to countries with weak
environmental and social rules; called “social dumping”
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Multinational Unionism
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In the United States at the start of the 20th century, unions
expanded their jurisdiction by shifting from local or regional to
national unions
Globalization has created strong incentives for unions to expand
beyond their boundaries
• But this has been infrequent
The Difficulties Unions Face
• Diversity, law and culture also make it difficult for unions to
expand their reach
• Diversity also reduces group cohesion
• Workers in low wage countries may not support demands for
higher wages for their global brethren
• Communications are difficult, and mergers are immensely
complex
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Examples of Multinational Unionism
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• Despite the impediments to international solidarity, some multinational
unionism has followed the multinational expansion of firms
• International trade secretariats provide information to member unions
and coordinate across national borders
These are autonomous agencies that cover particular
industries
• For example, the International Metalworkers Federation includes
members from less developed as well as highly industrialized nations
• The International Federation of Free Trade Unions (ICFTU) included
affiliated unions that represent 48 million workers, while the World
Federation of Trade Unions (WRTU) once represented 134 million
workers in Communist unions; coordination between the two was
impeded by politics
• The global expansion of trade is leading unions to communicate more
extensively with unions in other countries
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The Expansion of Intentional Trade
Through Trade Pacts
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The European Union (EU) and the North American Free Trade
Agreement (NAFTA) are examples of efforts to increase trade
NAFTA took effect in 1994, and removes tariffs and trade
barriers among the U.S., Mexico, and Canada over a 15year
period
• NAFTA is criticized by labor unions, claiming Mexico’s low
wages cause U.S. job loss
• NAFTA includes “Transitional Adjustment Assistance” to train
workers who lose jobs
• In 2005, the U.S. Department of Labor certified $165 million
for NAFTATAA worker benefits
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The International Labor Rights Movement
• A variety of organizations seeking to protect international
labor rights have been energized by the effects of
globalization
• Activists worry that globalization will create a downward
spiral in labor and social conditions
• Fair trade initiatives on coffee and other consumer goods
are increasing in order to support decent working
conditions, limiting child labor, and strengthening
unionism in developing countries
• Some U.S. unions are using political channels to reduce
outsourcing
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The European Union
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Formerly referred to as the European Economic Community
• Goals of Integration
• Eliminate trade barriers in the 25 member countries
The number rose to 27 in 2007 with the entry of Romania and
Bulgaria
• Allow free movement of workers, products, and investments
across national borders
• Labor relations are to be “harmonized”
• A single currency in most states
• PreIntegration Structure of Industrial Relations
• Unionization rates varied from about 10% in France to 79% in
Sweden
• Hourly labor rates range from about $29.91 in Germany to
$4.71 in the Czech Republic
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EU Regulation of the “Social Dimension”
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• The social dimension includes the regulations, directives, and
and laws that govern employment in the EU
The Social Charter was issued in 1989
• Gives workers the right to form and join unions and to strike
• Provides for freedom of movement and equal treatment for men
and women
• Member countries make specific policies
• Avoids full harmonization of labor regulations
Other directives were also adopted that address layoffs,
bankruptcies, and mergers
EU wide work council rule adopted in 1994
• But it does not provide for formal council power
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Labor’s Concerns about Integration
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Unions are concerned that harmonization of labor
standards will lower those standards
• Similar to what happened to American trade unionists as
they confronted the expansion of markets, transportation,
and communications systems across the U.S. at the start
of the 20th century
• As Commons noted, fears of competition from expanding
markets are well founded
At the same time, raising the standards of low wage
countries could help unions
• Even the U.K. unions want integration, to meet German
standards of representation
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Management Concerns over European
Integration
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• Managements tend to benefit from a reduction in trade
restrictions
Market integration can simplify the many regulations
and practices in different countries
• Integration could also ease industrial relations and
enhance management discretion
However, integration has simultaneously created a
centralized regulatory process that might give unions
more bargaining leverage to counter management’s
moves
• Management prefers that labor regulation be left to
member nations rather than the EU