Trade Union - Diversity of International Unions

Diversity of International Unions

Union law varies from country to country, as does the function of unions. For example, German and Dutch unions have played a greater role in management decisions through participation in corporate boards and co-determination than have unions in the United States. Moreover, in the United States, collective bargaining is most commonly undertaken by unions directly with employers, whereas in Austria, Denmark, Germany, or Sweden, unions most often negotiate with employers associations.

Concerning labour market regulation in the EU, Gold (1993) and Hall (1994) have identified three distinct systems of labour market regulation, which also influence the role that unions play:

“In the Continental European System of labour market regulation, the government plays an important role as there is a strong legislative core of employee rights, which provides the basis for agreements as well as a framework for discord between unions on one side and employers or employers’ associations on the other. This model was said to be found in EU core countries such as Belgium, France, Germany, the Netherlands and Italy, and it is also mirrored and emulated to some extent in the institutions of the EU, due to the relative weight that these countries had in the EU until the EU expansion by the inclusion of 10 new Eastern European member states in 2004.

In the Anglo-Saxon System of labour market regulation, the government’s legislative role is much more limited, which allows for more issues to be decided between employers and employees and any union and/or employers’ associations which might represent these parties in the decision-making process. However, in these countries, collective agreements are not widespread; only a few businesses and a few sectors of the economy have a strong tradition of finding collective solutions in labour relations. Ireland and the UK belong to this category, and in contrast to the EU core countries above, these countries first joined the EU in 1973.

In the Nordic System of labour market regulation, the government’s legislative role is limited in the same way as in the Anglo-Saxon system. However, in contrast to the countries in the Anglo-Saxon system category, this is a much more widespread network of collective agreements, which covers most industries and most firms. This model was said to encompass Denmark, Finland, Norway and Sweden. Here, Denmark joined the EU in 1973, whereas Finland and Sweden joined in 1995.”

The United States takes a more laissez-faire approach, setting some minimum standards but leaving most workers' wages and benefits to collective bargaining and market forces. Thus it comes closest to the above Anglo-Saxon model. Also the Eastern European countries that have recently entered into the EU come closest to the Anglo-Saxon model.

In contrast, in Germany, the relation between individual employees and employers is considered to be asymmetrical. In consequence, many working conditions are not negotiable due to a strong legal protection of individuals. However, the German flavour or works legislation has as its main objective to create a balance of power between employees organized in unions and employers organized in employers associations. This allows much wider legal boundaries for collective bargaining, compared to the narrow boundaries for individual negotiations. As a condition to obtain the legal status of a trade union, employee associations need to prove that their leverage is strong enough to serve as a counterforce in negotiations with employers. If such an employees association is competing against another union, its leverage may be questioned by unions and then evaluated in a court trial. In Germany, only very few professional associations obtained the right to negotiate salaries and working conditions for their members, notably the medical doctors association Marburger Bund and the pilots association Vereinigung Cockpit. The engineers association Verein Deutscher Ingenieure does not strive to act as a union, as it also represents the interests of engineering businesses.

Beyond the classification listed above, unions' relations with political parties vary. In many countries unions are tightly bonded, or even share leadership, with a political party intended to represent the interests of working people. Typically this is a left-wing, socialist, or social democratic party, but many exceptions exist, including some of the aforementioned Christian unions. In the United States, by contrast, although it is historically aligned with the Democratic Party, the union movement is by no means monolithic on that point; this is especially true among the individual "rank and file" members. For example, the International Brotherhood of Teamsters has supported Republican Party candidates on a number of occasions and the Professional Air Traffic Controllers Organization (PATCO) endorsed Ronald Reagan in 1980. In Britain the union movement's relationship with the Labour Party frayed as party leadership embarked on privatisation plans at odds with what unions see as the worker's interests. However, it has strengthened once more after the Labour party's election of Ed Milliband who beat his brother David Milliband, to become leader of the party after Ed secured the trades union votes. Additionally, in the past there, was been a group known as the Conservative Trade Unionists or CTU. A group formed of people who sympathized with right wing Tory policy but were Trade Unionists.

Historically, the Republic of Korea has regulated collective bargaining by requiring employers to participate but collective bargaining has been legal only if held in sessions before the lunar new year.