Introduction: internationally comparative approaches to studying employment relations

Employment relations is the study of the formal and informal rules and mechanisms governing relationships between workers and the organisations who employ or engage them. Historical, economic, social, technological, legal and political contexts shape these rules and mechanisms, which vary due to distinctive national and regional institutions and norms (Bray et al. 2018; Dunlop 1958; Gospel & Palmer 1993). The field of international and comparative employment relations involves studying employment relations systems in cross-national contexts (Kaufman 2011).
Researching employment relations in cross-national contexts has both intellectual and practical purposes, as well as challenges. On the one hand, it can help us generate theories to explain why outcomes may be different or similar in various contexts. In practical terms, studying other systems enables us to better understand employment relations where we work and live. According to Kahn-Freund (1979: 3):
if one's environment never changes, one tends to assume that an institution, a doctrine, a practice, a tradition, is inevitable and universal, while in fact it may be the outcome of specific social, historical or geographical conditions of the country.
On the other hand, researching employment relations in cross-country comparative contexts involves challenges. National systems are not static, with some institutions changing more rapidly than others. Moreover, each national system may carry its distinct characteristics and configurations within its historical traditions. This can make direct comparison challenging and attempts at categorisation imprecise, which we will illustrate.
Nonetheless, studying different employment relations systems can help us to identify better ways of organising and regulating work. This is especially important as we face global economic and political upheavals that are connected to work and employment relations. Financialisation and organisational fissuring have contributed to growing job insecurity (see Box 1.1 for explanations of such key terms). New technologies have destroyed jobs and also generated new forms of work. Climate change threatens livelihoods in some regions but creates new job opportunities in others. A resurgence of nationalism (e.g. Brexit in the United Kingdom (UK), the Trump presidency in the United States of America (USA)) has resulted in policies to tighten immigration controls and to try to ‘bring home’ jobs that had been offshored to other countries, trends that the COVID-19 global pandemic may have accelerated. Workers and their organisations have responded to these developments by campaigning for more secure work opportunities and higher pay, especially for precarious and low-paid workers.
COVID-19 is a pertinent example since it created significant labour market disruptions in most countries and many sectors, but there were variations in national and sub-national policy responses. To try to minimise business closures and job losses, governments in many countries – sometimes in cooperation with employer associations and unions – developed employment retention schemes in the form of wage subsidies, often combined with reduced hours, flexible work arrangements (see Box 1.1) and other schemes. National policy responses focused on expanded assistance for unemployed workers, tax relief for businesses and/or financial support for adversely impacted industries (ILO, 2020). These policy choices have had major implications for unemployment rates associated with the pandemic as well as the strategies of the various employment relations actors (see Box 1.1), which are further discussed in the country chapters and in Chapter 15.
Studying international and comparative employment relations is important for several other reasons. First, it can contribute to our knowledge of employment relations in different nations. The globalisation of business activity, through cross-border trade, global supply chains and technological advancements, means that practitioners and policy-makers increasingly require knowledge about employment relations systems across multiple nations, sectors and workplaces (Strauss 1998).

Box 1.1: Specialist terms mentioned in the text
Actors refers to the formal and informal institutions and collective organisations regulating work, including unions and other organisations representing workers, employer associations, as well as government agencies and tribunals (Heery et al. 2008).
Financialisation refers to the increase in size and prominence of a country's financial sector and its influence on wider business and non-commercial activities. In some countries, this has had a growing influence on employer strategies and government policy and has resulted in greater financial pressures and costs being shifted from enterprises to workers (Bryan & Rafferty 2018).
Flexible work arrangements include: (1) flexibility in the scheduling of hours worked, such as alternative work schedules (e.g. night or weekend working, ‘flexi time’ or compressed work weeks) and arrangements regarding shift and break schedules; (2) flexibility in the number of hours worked, such as part-time work, job shares or zero-hours contracts; (3) flexibility in the place of work, such as working from home or at a satellite location; and (4) flexibility in the type of work conducted, such as between different craft specialisations like mechanical and electrical engineering or production and maintenance work (Clarke & Holdsworth 2017).
The International Labour Organization (ILO) was founded in 1919, after World War It is now a specialised United Nations agency. The ILO is a ‘tripartite’ organisation that brings together governments, employers and workers of 187 member countries to set labour standards and policies and programmes to support these standards and its other objectives. The ILO's main aims are to promote rights at work, encourage decent work and employment opportunities, enhance social protection and strengthen dialogue on work-related issues (www.ilo.org/global/about-the-ilo).
Workplace fissuring occurs when, in pursuit of economic efficiencies, ‘lead’ enterprises devolve responsibility for certain workers to suppliers or subcontractors. This may be at the expense of workers as the employment arrangements are fragmented between different employers who may seek to win tenders by cutting their prices, based on offering lower-cost terms and conditions of work than competitors and the lead enterprise (Weil 2014).
Second, knowledge about different employment relations systems can generate awareness of policy innovations that may provide inspiration for practitioners and policy-makers elsewhere. For example, the ‘strategic enforcement’ approach to improving employer compliance with labour standards in supply chains, which was developed to address problems of ‘wage theft’ in the USA (Weil 2014), has inspired similar models in Australia, Canada and the UK (Brown & Wright 2018; Hardy & Howe 2015; Mitchell & Murray 2017). At various times, aspects of employment relations in the UK, USA, Japan, Germany and Nordic countries have been lauded as models to emulate. One reason for including Denmark in this book is its unique ‘flexicurity’ model, combining weak employment protections, active labour market policies and a ‘Nordic model’ of collective institutions for protecting workers (Bredgaard & Madsen 2018), which some see as a ‘best practice’ example for other countries (Scott 2014).
Third, the internationally comparative study of employment relations has the potential to provide theoretical insights into the factors shaping relationships between workers and their employers (Bean 1994). Employment relations has been criticised for being too ‘empiricist’ and descriptive as a field and insufficiently focused on developing theoretical explanations for the phenomena that it studies (Marsden 1982). Comparative research can help to address this criticism because of the abstraction required to compare concepts across multiple contexts. As Kochan (1998: 41) puts it:

Each national system carries with it certain historical patterns of development and features that restrict the range of variation on critical variables such as culture, ideology, and institutional structures which affect how … actors respond to similar changes in their external environments. Taking an international perspective broadens the range of comparisons available on these and other variables and increases the chances of discovering the systematic variations needed to produce new theoretical insights and explanations.

International and comparative employment relations scholars have tended to focus on the differences between national employment relations systems (Martin & Bamber 2004). However, many scholars have argued that these differences are becoming less important due to the erosion of unique features of national employment relations systems (Baccaro & Howell 2017), particularly those institutions designed to protect workers (Greer & Doellgast 2017). This reflects a shift in the literature from a focus on how national systems differ to how and why they are changing, as well as the economic and social consequences of these changes. In many contexts, the ‘standard employment relationship’, based on assumptions of full-time continuing contracts, has, to an extent, been supplanted by other, less secure arrangements. These include temporary employment, independent contracting, ‘gig work’ mediated through digital platforms, and other forms such as involuntary part-time, agency work, and dependent self-employment (Fudge 2017; Kalleberg 2018). Local actors (see Box 1.1) and institutions are finding ways to create and repurpose protections for workers engaged insecurely, which is inspiring actors in other local contexts and generating ‘policy learning’ where innovations developed in one context are being adapted in others (Dølvik & Jesnes 2018).
The dominant frameworks used in international and comparative employment relations have focused on the institutions and norms that influence the behaviour of employers, workers and the organisations that represent their interests. While these are important, they tend to be deterministic, in that they understate the potential of actors to shape institutions and the systems in which they work. The analytical framework we adopt in this book, compared to previous editions, seeks to give greater attention to the power of actors, whose activities are important for understanding the features of employment relations systems.

We aim, then, to provide readers with conceptual tools to study international and comparative employment relations. The following chapters, written by leading experts on each country, provide an overview of employment relations in 13 countries, as shown in Table 1.1. These include: (1) four ‘Anglosphere’ nations: the UK, the USA, Canada and Australia; (2) four European Union (EU) nations: Italy, France, Germany and Denmark; (3) three East Asian nations: Japan, South Korea and the People's Republic of China; and (4) two nations with emerging economies: India and South Africa.

This chapter provides an introduction to the study of international and comparative employment relations. It discusses some of the benefits and the challenges of adopting a comparative approach to work and employment. It also reviews influential conceptual frameworks to establish a foundation for analysing the issues discussed in the book.