Convergence in Industrial Relations Institutions: The Emerging Anglo-American Model?

Abstract

At the outset of the Thatcher/Reagan era, the employment and labor law systems across six Anglo-American countries could be divided into three pairings: the Wagner Act model of the United States and Canada; the Voluntarist system of collective bargaining and strong unions in the United Kingdom and Ireland; and the highly centralized, legalistic Award systems of Australia and New Zealand. The authors argue that there has been growing convergence in two major areas: First, of labor law toward a private ordering of employment relations in which terms and conditions of work and employment are primarily determined at the level of the enterprise; and second, of individual employment rights, toward a basket of minimum standards that can then be improved upon by the parties. The greatest similarity is found in Canada, the United Kingdom, New Zealand, and Australia. Ireland retains a greater degree of public ordering, while the United States diverges in favoring the interests of employers over those of employees and organized labor. The authors explore reasons for the convergence. The authors argue that there has been growing convergence in two major areas: First, of labor law toward a private ordering of employment relations in which terms and conditions of work and employment are primarily determined at the level of the enterprise; and second, of individual employment rights, toward a basket of minimum standards that can then be improved upon by the parties. The greatest similarity is found in Canada, the United Kingdom, New Zealand, and Australia. Ireland retains a greater degree of public ordering, while the United States diverges in favoring the interests of employers over those of employees and organized labor. The authors explore reasons for the convergence.

Beyond National Systems, Towards a ‘Gig Economy’? A Research Agenda for International and Comparative Employment Relations

“…They also lend support to Baccaro and Howell's argument that national systems 'are being transformed in a common [liberal] direction' (Baccaro and Howell 2011, 522; see also Colvin and Darbishire 2013). However, drawing on our analysis of 12 national systems (Bamber et al 2016), we conclude that this trend has not been uniform in either its speed or its scope.…”

Claiming too much, delivering too little: testing some of Hofstede’s generalisations

“…As Ragin (1987: 27) As even a preliminary combinatorial analysis of industrial relations in Ireland would need to consider multiple and interacting endogenous and exogenous circumstances and changes including: the strong sectorial distribution of trade union membership -some highly unionized, others scarcely so; the common educational background of many employees and managers; the dominant position of one trade union (SIPTU) in the unionized sectors with approximately 43% of the Republic's ICTU affiliated trade union membership; the power rivalry between that trade union and the ICTU; the frequency, content, and other features of training received by lay activists (shop-stewards) and full-time trade union officers; the decline in trade union membership; the proportion of the workforce which is not unionised; the complex consequences of co-existence unionized and non-unionised employees in the same location; the effects of the series of successive national pacts between government, employers, and trade unions; the rivalries between unions wholly based in Ireland (the Republic and/or Northern Ireland) and those with continuing affiliations to largely Great Britain based trade unions; trade union mergers; 22 the roles of formal and informal arbitration organizations; the extent and degree of implementation of employees' legal protections; the introduction of a statutory national 'minimum wage' in 2000; institutional influences, including those shaped by the European Commission and associated organizations; the scale and type of foreign direct investment; the comparatively low levels of trade union membership in multinational companies located in Ireland; the high membership level within the public sector; the scale and changes in the numbers of immigrant workers and their sectoral locations; the impact of fiscal policy changes on take-home pay; and so forth (Brown, 1981;Geary and Roche, 2001;O'Mahoney and Delanty, 2001;D'Art and Turner, 2005;Gunnigle, Collings and Morley, 2005;Collings, Gunnigle and Morley, B. McSweeney, et al 2008;Cooper, 2009;Colvin and Darbishire, 2013;Cowman and Keating, 2013;McLoughlin, 2013;Belizón et al, 2014;Geppert, et al, 2014;NERA, 2014).…”

The role of institutional and intermediary forces in shaping patterns of employee involvement and participation (EIP) in Anglo-American countries

“…This emphasises that financial and economic systems, government intervention, employment legislation and other institutions -such as trade unions and employers' organisationsinfluence employment relations and EIP in all countries, even liberal market economies (LME; Hall & Soskice, 2001) or AA countries. This paper adopts the latter terminology because, as Colvin andDarbishire (2013, p. 1049) argue, it provides greater precision about the countries under review than classing them all as LME. All four countries involved in this research put a primacy on the private ordering of employment relations which allows employers substantial freedom to choose EIP practices to maximise shortterm profit with relatively limited regulation by the state (Wailes et al, 2011).…”

“…While this is understandable given the choices open to employers in these countries (Brewster, 2007;Dundon, Wilkinson, Marchington, & Ackers, 2004;Kaufman, 2013), even the most lightly regulated economies do not operate in a complete institutional void because forms of EIP are either shaped significantly by legislation and deeply embedded national business systems (Colvin & Darbishire, 2013;Wailes, Bamber, & Lansbury, 2011) or promoted by permanent or temporary government-funded initiatives (Macneil, Haworth, & Rasmussen, 2011;Stuart, Martinez-Lucio, & Robinson, 2011). These are termed 'hard' and 'soft' institutional forces, respectively.…”

“…To do this, data were collected from four AA economies -the UK, Ireland, Australia and New Zealand -through interviews and documentary analysis at government level to identify the role of 'hard' and 'soft' institutional forces, at intermediary level to identify the role of intermediary forces and with HR and other respondents at organisation level to assess how EIP practices had been shaped by these three sets of forces. The countries were chosen because there are not only historical similarities in their employment systems but also differences in legislation, national institutional structures and the type of intermediary forces which provide an interesting context for the analysis; see also Freeman, Boxall, and Haynes (2007) and Colvin and Darbishire (2013) for studies of employment relations in some of the same AA countries.…”