Personnel Today
  • Home
    • All PT content
  • Email sign-up
  • Topics
    • HR Practice
    • Employee relations
    • Learning & training
    • Pay & benefits
    • Wellbeing
    • Recruitment & retention
    • HR strategy
    • HR Tech
    • The HR profession
    • Global
    • All HR topics
  • Legal
    • Case law
    • Commentary
    • Flexible working
    • Legal timetable
    • Maternity & paternity
    • Shared parental leave
    • Redundancy
    • TUPE
    • Disciplinary and grievances
    • Employer’s guides
  • AWARDS
    • Personnel Today Awards
    • The RAD Awards
  • Jobs
    • Find a job
    • Jobs by email
    • Careers advice
    • Post a job
  • Brightmine
    • Learn more
    • Products
    • Free trial
    • Request a quote
  • Webinars
  • Advertise
  • OHW+

Personnel Today

Register
Log in
Personnel Today
  • Home
    • All PT content
  • Email sign-up
  • Topics
    • HR Practice
    • Employee relations
    • Learning & training
    • Pay & benefits
    • Wellbeing
    • Recruitment & retention
    • HR strategy
    • HR Tech
    • The HR profession
    • Global
    • All HR topics
  • Legal
    • Case law
    • Commentary
    • Flexible working
    • Legal timetable
    • Maternity & paternity
    • Shared parental leave
    • Redundancy
    • TUPE
    • Disciplinary and grievances
    • Employer’s guides
  • AWARDS
    • Personnel Today Awards
    • The RAD Awards
  • Jobs
    • Find a job
    • Jobs by email
    • Careers advice
    • Post a job
  • Brightmine
    • Learn more
    • Products
    • Free trial
    • Request a quote
  • Webinars
  • Advertise
  • OHW+

Employment lawFranceHR practice

How I made a difference: European v US law

by Personnel Today 6 May 2009
by Personnel Today 6 May 2009

I became European HR director at BearingPoint in July 2004. I had a succession of global HR leaders as my bosses, all of whom were American, and none of whom had ever been to Europe. Nor did they understand anything about European laws and their impact on HR processes.


There was a huge gap caused by resentment of their lack of understanding of, or interest in, European HR issues. I decided that rather than make this gap any bigger, I would try to raise the level of the US executives’ understanding through education. I described it as needing to ‘build a bridge across the Atlantic’.


The first step was for the US bosses to get on a plane and fly to Europe. They then met with our leadership, most of whom were based in Germany and France, and with representatives of the workers’ council there, so that we could begin to get them to see the situation from both a leadership and an employee perspective.


When the global HR leader met the head of the workers’ council for Germany, he showed huge surprise at the impact of the laws, and asked: “Who invented these goddamn laws in the first place?” To which the council representative replied: “They were implemented in 1946, when the US, Russia and Britain occupied Germany – so the only people not responsible were the Germans.”


It took a lot of hard work, education and repeated messages, to get US colleagues to realise that redundancy processes differed to those in the US, where it’s ’employment at will’ – you can literally call a partner into your office and say: “Sorry, we need you to leave today.” Try to do that sort of thing in Germany or France, unless you can come to a compromise agreement, and you’re potentially looking at a three-year legal battle. A compromise agreement might cost you two to three years’ remuneration.


The gap between what you can do in the US and what you can’t do here is huge. When we had a redundancy programme in France and Germany, I asked my global HR leader to second one of his US team over here to work with me so that they could see what was happening on a day-to-day basis.


Sign up to our weekly round-up of HR news and guidance

Receive the Personnel Today Direct e-newsletter every Wednesday

OptOut
This field is for validation purposes and should be left unchanged.

Without having understood the laws and their impact, they saw us as barriers to change, whereas we were actually trying to implement it while upholding the law.


by Charlie Keeling, HR director, Field Fisher Waterhouse

Personnel Today

previous post
Analysis: HR demand and the recession
next post
Top job: Paul Moran, HR director, LG Electronics

You may also like

Bereavement leave to extend to miscarriages before 24...

7 Jul 2025

Company director wins £15k after being told to...

4 Jul 2025

How can HR prepare for changes to the...

3 Jul 2025

Government publishes ‘roadmap’ for Employment Rights Bill

2 Jul 2025

Employers’ duty of care: keeping workers safe in...

27 Jun 2025

When will the Employment Rights Bill become law?

26 Jun 2025

With HR absence rising, is your people team...

24 Jun 2025

Seven ways to prepare now for the Employment...

20 Jun 2025

The employer strikes back: the rise of ‘quiet...

13 Jun 2025

Lawyers warn over impact of Employment Rights Bill...

13 Jun 2025

  • Empowering working parents and productivity during the summer holidays SPONSORED | Businesses play a...Read more
  • AI is here. Your workforce should be ready. SPONSORED | From content creation...Read more

Personnel Today Jobs
 

Search Jobs

PERSONNEL TODAY

About us
Contact us
Browse all HR topics
Email newsletters
Content feeds
Cookies policy
Privacy policy
Terms and conditions

JOBS

Personnel Today Jobs
Post a job
Why advertise with us?

EVENTS & PRODUCTS

The Personnel Today Awards
The RAD Awards
Employee Benefits
Forum for Expatriate Management
OHW+
Whatmedia

ADVERTISING & PR

Advertising opportunities
Features list 2025

  • Facebook
  • Twitter
  • Instagram
  • Linkedin


© 2011 - 2025 DVV Media International Ltd

Personnel Today
  • Home
    • All PT content
  • Email sign-up
  • Topics
    • HR Practice
    • Employee relations
    • Learning & training
    • Pay & benefits
    • Wellbeing
    • Recruitment & retention
    • HR strategy
    • HR Tech
    • The HR profession
    • Global
    • All HR topics
  • Legal
    • Case law
    • Commentary
    • Flexible working
    • Legal timetable
    • Maternity & paternity
    • Shared parental leave
    • Redundancy
    • TUPE
    • Disciplinary and grievances
    • Employer’s guides
  • AWARDS
    • Personnel Today Awards
    • The RAD Awards
  • Jobs
    • Find a job
    • Jobs by email
    • Careers advice
    • Post a job
  • Brightmine
    • Learn more
    • Products
    • Free trial
    • Request a quote
  • Webinars
  • Advertise
  • OHW+