Research Handbook of Comparative Employment Relations
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Research Handbook of Comparative Employment Relations

Edited by Michael Barry and Adrian Wilkinson

The Research Handbook of Comparative Employment Relations is an essential resource for those seeking to understand contemporary developments in the world of work, and the way in which employment relations systems are evolving around the world.
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Chapter 14: Employment Relations in France and Germany

Stefan Zagelmeyer


Stefan Zagelmeyer INTRODUCTION France and Germany are two of the largest economies in Europe and are among the main driving forces of the European integration process. Despite their geographical proximity, marked differences in their historical, economic, political and social developments – associated with quite distinct institutional and cultural characteristics – have contributed to the development of two specific and different employment relations systems. Since the mid-1970s, the two countries feature prominently in crossnational comparative research related to employment relations, broadly defined. Many projects can be linked to the convergence-versus-divergence debate as well as to the discussion of employment relations models (Hyman, 1994; Freeman, 1998). In brief, the ‘convergence hypothesis’ claims that economic and/or technological pressures lead to a general trend towards the adoption of ‘best practices’ or global standards in management. This implies a trend towards convergence, which occurs irrespective of cultural and institutional factors; it is caused by such external contingencies as industry, size, technology and competitive imperatives. By contrast, the ‘divergence hypothesis’ suggests that management practices are embedded in cultures and institutions that are largely confined to geographical entities, such as regions and nation states, and that prohibit a rapid diffusion of ‘best practice’ across geographical and organizational boundaries. There is an abundance of research on different employment relations models. In an analysis of work structure and work relations in relation to education, business organization and industrial relations, Maurice et al. (1980, 1986) – and likewise Silvestre (1974), Maurice and Sellier (1979), Sorge and Maurice (1990) and Marsden (1999) – find little...

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