Differences in employment law US/UK
#1
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Differences in employment law US/UK
This is a general "cultural interest" question- I'm American, not an expat--- I have recently entered the private sector workforce here after a number of years in the US military, and am encountering "at will" employment really for the first time. In our great land (though I guess laws vary by state) an employer can pat you on the back every day, say you're doing a great job, and then fire you just like that.
By contrast in the military it's really hard to get fired; leadership has to provide a paper trail showing continual misconduct or subpar performance. Am I right that most workers in Britain have employment contracts that place high barriers to termination? Does this lead to a lot of mediocre performance even in the private sector?
I tell people that being in the military gives you an idea of what it is like to live in a Communist country-- guaranteed employment, few incentives to work hard, drab buildings, gov't-run stores that run out of items for weeks at a time, etc. Though I can certainly appreciate the advantages of a more "social" system.
By contrast in the military it's really hard to get fired; leadership has to provide a paper trail showing continual misconduct or subpar performance. Am I right that most workers in Britain have employment contracts that place high barriers to termination? Does this lead to a lot of mediocre performance even in the private sector?
I tell people that being in the military gives you an idea of what it is like to live in a Communist country-- guaranteed employment, few incentives to work hard, drab buildings, gov't-run stores that run out of items for weeks at a time, etc. Though I can certainly appreciate the advantages of a more "social" system.
#2
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Re: Differences in employment law US/UK
It used to be.
Many people are now on short term contracts, and there is a 2 year limit before significant protection kicks in. Things have changed a lot.
Government partly excepted.
Many people are now on short term contracts, and there is a 2 year limit before significant protection kicks in. Things have changed a lot.
Government partly excepted.
#3
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Re: Differences in employment law US/UK
It is much harder to sack someone in the UK than the USA. The employment laws give a good degree of protection to the employee. There are steps that have to be taken - although the process can be applied loosely and inaccurately, and also completed in an expedited fashion if they are really keen to get rid of someone but if the employee sees through this and thinks they've been treated unfairly, they can take the employee to an employment tribunal.
#4
Re: Differences in employment law US/UK
Having decent laws to protect the worker isn't really a bad thing.
Sure you get a few lemons, but more people are likely to be more motivated to work more efficiently than going through the grind as in the US where appearances are more important at many places.
France has a much shorter work week, great holiday allowances and strict employment laws and they're not exactly a third world country. The US just needs to open the eyes a little and see that "different" doesn't mean bad just because it isn't understood.
Sure you get a few lemons, but more people are likely to be more motivated to work more efficiently than going through the grind as in the US where appearances are more important at many places.
France has a much shorter work week, great holiday allowances and strict employment laws and they're not exactly a third world country. The US just needs to open the eyes a little and see that "different" doesn't mean bad just because it isn't understood.
#5
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Re: Differences in employment law US/UK
Spain has hit 50%
There is a choice.
#6
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Re: Differences in employment law US/UK
Or may be things aren't that black and white and countries such as Germany - where workers have a lot more protections than in the US but less than in countries such as Spain - have a good balance? Also notice that the level of unemployment in the UK and the US is almost identical despite the former's greater protections for workers.
#7
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Re: Differences in employment law US/UK
I believe the youth employment is much higher in the UK than the US.
#8
Re: Differences in employment law US/UK
But is that because it is, or because of the numbers game?
Considering that even if someone works one hour a week in the US they aren't considered unemployed, nor are people who aren't claiming unemployment money counted, which really skews the figures.
Considering that even if someone works one hour a week in the US they aren't considered unemployed, nor are people who aren't claiming unemployment money counted, which really skews the figures.
#9
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Re: Differences in employment law US/UK
True, but it's at record lows in Germany and way lower than the US. So the idea that protections for workers necessarily means higher youth unemployment is clearly incorrect. After all, Germany has things like Works Councils that would be considered positively Communist by many on the right here.
#10
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Re: Differences in employment law US/UK
True, but it's at record lows in Germany and way lower than the US. So the idea that protections for workers necessarily means higher youth unemployment is clearly incorrect. After all, Germany has things like Works Councils that would be considered positively Communist by many on the right here.
Italy - 6 weeks a year hols, an allegedly utterly shagged economy but essentially happier workers... 'you do the math' as some here say...!!!
P.S. - it's MATHS - just 'cos you dropped the letter 'U' from a few words doesn't mean you can go dropping an 'S' here and there just because you think you have some kind of First Amendment thingy!!!
#11
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Re: Differences in employment law US/UK
By contrast in the military it's really hard to get fired; leadership has to provide a paper trail showing continual misconduct or subpar performance. Am I right that most workers in Britain have employment contracts that place high barriers to termination? Does this lead to a lot of mediocre performance even in the private sector?
It's generally not used well in the UK because, in my limited experience of only working for 20 years in the UK for only about 20 companies, that HR is generally shit - it's own worst enemy. Only beaten by inept line managers
Is there a lot of mediocre performance in the private sector in the UK? Depends on what you mean by performance, but that said, there are some excellent performers in the UK, and some utterly shit ones in the US. Delete 'UK' and 'US' from the last sentence and insert any other pair of countries and the sentence is still valid...
It's difficult to really compare 2 economies - even a measure like GDP doesn't tell the full story, even if defined the same way in both target countries - how do you measure the true size of workforce, legal and illegals for example?
You can also 'talk up' GDP by doing an awful lot of non-value-add financial activity. For example, all those bills in the US medical industry going backwards and forwards all get counted towards GDP, but it's really only one bit of real value-add activity per procedure. But each individual element is effectively added to the US GDP. That's not quite the case in the UK. On the flip side, an awful lot of volunteering gets done in the US that is perhaps covered by govt jobs in the UK, thus skewing the GDP number in UK's favour...
To one of your questions about high barriers to being terminated in the UK - perhaps relative to the US that's true in practice, but compared to the rest of the EU, it's very much lower - one reason EU companies tend to fire their UK workers first - it's easier, quicker and cheaper to do than elsewhere in the EU.
Remember that the UK isn't party to every aspect of the European DisUnion!
It'll be interesting to see what happens to the French economy given that Sarko looks like he's about to lose his job and there'll be a true blooded socialist taking over... I bet Angela Merkel must be doing her East German nut!!!