Cet article a pour objet d'explorer et de faire comprendre les divergences entre les divers systèmes de relations professionnelles en Europe de l'Ouest, principalement entre les systèmes français et allemand.
This paper aims at exposing and clarifying the differences between various Systems of industrial relations in Western Europe, mainly between the French System and the German one.
Many aspects of these two Systems are common, even though the experience is pursued throughout various means and methods: defence of workers, quest for control on management powers to decide, influence to be exterted on the legislative and economic regime.
A closer approach is pursued between unions of France and Germany, and the latter is favoured by the actual economic crisis which bears on the economies and on the workers of both countries, and by the obligation of the unions to negotiate with multinational corporations. This effort is visible in France where the three main unions, CGT, CFDT and FO, in spite of certain differences between them, favour a trend towards widening European labour cooperation.
This widening appears on two particular grounds: the appreciation of claim applications of both movements and the question of participation in management.
On the first subject, it is obvious that the term "Collective bargaining" has a different meaning in France and in Germany.
Even if the actual economic crisis draws together both movements, the intervention from the administration into the bargaining process and the ratification of agreement are turned down by the unions and the employers in Germany. Whereas, in France, for the last ten years, many general settlements regarding reduced workweek, social securities in any case of layoff, vocational training, levelling of fringe benefits between white-collars and workmen have been endorsed.
Regarding wage-setting, things are different in both movements. Owing undoubtedly to the inter-union rivalry, french unions consider their System more beneficial than the German System, since their somewhat anarchical fight for wage increases enables them to consider at any time the workers' claims; whereas the German regime, more formal, implies a certain severity, some red-tape and an greater distance from a unions. In France, the plural unionism favours such procedure, but it does not mean that French unionsare not aware of that question of control of rank and file action, and there is no need for them to look after a more consistent union policy.
Conflict of opinions of both regimes is reflected upon the problem of participation in management.
The attitude of German unions towards co-determination raises at the same time interest and critic from French unionists. It is taken to task for not making enough room to unions, because participation in management is based upon direct votes from the staff rather than from rank and file. They also consider that this form of participation is naturally discouraging union members who wee a means for the employers to get the unions to accept responsibilities in spheres where decisions based on restrained deals slop out from them. It is said that where the union is weak, it is enough for the economic situation to become tight to see decisive influence pass out of their hands to the employers'.
Moreover, it is clear that French unions with their acquired power do not reject a certain participation in decision making. For instance, in the nationalized firms, to oppose the State prerogatives, unions try to strenghten their role in them. CGT particularly does not give up searching in those fields to a form of representation in which it would succeed in reaching the majority with the help of consumers's representatives. CFDT is far more unwilling; it rather aims at decentralizing the use of control-power, in other words, self-management. FO, closer to the American concept of collective bargaining, give s preeminence to the latter and dismisses the participation in management to workers.
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