Most IEL readers will be well aware of the huge divide between US labour law and UK/European employment law; the former being based on an “economic” model where a business owner’s rights to hire and fire at will around levels of productivity trump individual workers’ rights; whereas, conversely, the latter is founded on “social” principles, prioritising individuals’ rights to safety and dignity at work, including rights to a higher level of job security and to be paid fairly for their work.
Not so united: the trapdoors between English and Scottish law
05/09/2022
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