Comparative Employee Relations




A trade union is similar in character to a labor union. Generally, a trade union can be defined as an organization or grouping of persons who are closely associated due to their mode of employment or the nature of labor they provide to an economy. These organizations exist for both casual and formal employees, as well as the unemployed. Trade unions may be founded by individual workers, past workers or professionals in a certain field of work.

The major but not the only objective of trade unions is the improvement or maintenance of the working or employment conditions of workers.



Comparative Employee Relations

Trade unions have been evolving for the last 100 years. Many trade unions arose during the period of the rise of the industrial revolution in Western Europe.

During this period, much of Western Europe was revolutionizing from an agrarian mode of production to an industrial mode of production. The rise of trade unionism was because of the introduction of new work techniques as well as an increasing downward pressure the then existing structures of traditional wage

On top of this, the expanding industrial society was drawing more children, women, immigrants as well as rural workers in to the urban culture. This pool of semi skilled labor as well as unskilled labor started to organize themselves in small groups in order to articulate their plight collectively. This marked the onset of trade unionism.


The political dimensions or political orientations of trade unions have always been determined by the nature and type of political regimes existent in their economies all over the world. Due to this reason, many trade unions especially in former colonial states ended up forming themselves into political parties. In other democracies these trade unions concentrated only in their field of specialization and only rarely did they form themselves into political parties.

For the purposes of this paper, I will look at the political orientation of trade unions in one developed western country and one developing African country (Britain and Kenya).


Comparative Employee Relations

The rise of trade unionism in Britain could be best analyzed on a modernization theory perspective. On the other hand, in order to understand the rise of trade unionism in Kenya, which happens to be a former British colony can only be best understood from a dependency theory perspective.

Trade unions both in Britain and in Kenya have a long history of getting overly involved in political affairs. Surprisingly in both countries, there are instances where certain trade unions have turned into political parties and contested for national elections. Trade unions in Kenya have always had a political dimension ever since the struggle for independence from Britain began. Many trade unions were on the front line in advocating for the release of detained freedom fighters and ever since, they have always been very political.

Trade unions in both countries have been highly involved in political campaigns, especially for political parties that they consider to be of importance to them. The British labor union was one of the driving forces of bringing the labor party to power. Likewise, the Kenya federation of labor was supportive of bringing the current NARC regime in to power in Kenya. Additionally these trade unions have always been keen on criticizing bad legislation or poor government policies in all sectors of the economy.

In almost all countries of the world there is no country where trade unions have failed to conflict with the ruling regimes. This is in no exception to trade unions in Britain and Kenya. Kenya having been a former colony of Britain and given the fact that it is still a member of the commonwealth countries it shares a lot in common with not only Britain but with almost all of the commonwealth countries. On the field of trade unionism, the extent of political radicalism evident within the British trade unions is still rife and rampant within Kenyan trade unions as well.

Additionally trade unions in both Kenya and Britain have always been politically associated with the ruling elite, or a certain class of the bourgeoisie. This involvement between certain high-ranking politicians or leaders has always made trade unions to be highly political. This is


Comparative Employee Relations

because these trade unions are used as instruments for campaigns between the different politicians and or political parties.


Although many trade unions in Kenya are relatively young as compared to their British counterparts, they still do have the above similarities in their operations. However, there are some very significant differences between trade unions in the two countries. Some of these differences include the following.

Many trade unions in Britain were formed or are formed within a well laid down legal and administrative system and in addition to this they usually have a clear cut ideological perspective that is well known and articulated. On top of this, they usually have a guiding manifesto that steers the way for their operations. On the other hand, trade unions in Kenya usually do not have manifestos and even if they have, they are rarely followed. On top of this, these trade unions usually do not have an ideology to guide their operations. In addition, the legal framework is so complicated that the trade unions themselves are not fully aware of the powers they have under Kenyan law.

Secondly, there is the issue of financial security. Trade unions in Britain usually have enough funds to finance their operations, this makes it hard for the British government to threaten or to take action against them. This minimizes the chance that the government could lower their bargaining power, on the other side Kenyan trade unions have very weak financial bases, this makes it easy for the Kenyan government to ignore them and assume their role as irrelevant.


Comparative Employee Relations

This has made the trade union movement in Kenya very weak as compared to the British trade union movement.


Trade unionism is a very important aspect in the development of democracies. This is because trade unions are always at the forefront together with other interest groups to keep governments on their toes. Trade unions ensure that governments deliver what they claimed they would deliver once elected to power. Incase governments fail to deliver on their promises trade unions are usually there to demand the rights of the citizens.

This involvement in politics ensures that governments are always working maximally to deliver the greatest happiness to their people.

In instances where trade unions are unable to do their work efficiently and effectively due to government intimidation like is the case in Kenya then this is usually an indicator of some deficiencies in the democratic process within the said state or country.


Comparative Employee Relations





Comparative Employee Relations

Industrial relations concern itself with the relationship that exists in any economy between workers or organized groups of workers and the management. The workers are mostly represented by trade unions.

Governments or states have always been involved in industrial relations for a long time now. The reasons for their involvements always differ from state to state. Even within the same state the role and extent of government, involvement in the industrial relations will always depend on the regime in power. In addition to this, the ideological dimension of the regime always influences its involvement in industrial relations.

Command economies like North Korea and Cuba have extensive government control not only in industrial relations but also generally in all occupations. On the other hand, liberal democrats have always allowed a system of laissez faire to supersede and they only involve themselves in industrial relations mostly in the field of formulation and implementation of government policies.

The extent and the nature of this involvement will always depend on the state itself as well as the ideological background of the ruling party.

In this analysis, I will look at the role of the state in two industrial states (Britain and France). In analyzing this relationship, we shall assume that the main reason for the two states involvement in industrial relations is purely for regulation purposes. Thus, we shall use the Regulationist approach in order to analyze the role of state institutions in the industrial relations.

Both France and Britain are industrial powers. Since the 1980s, thaw role of the state in industrial relations has always had some similarities as well as some disparities. Britain under Thatcherism and France under Gaullism had their strengths and weaknesses when it came to the role of state intervention in the systems of industrial relations and regulation.


Comparative Employee Relations

Government involvement in the industrial processes usually conceals some form of class power. Thus, the only influencing factor that enables the state to maintain this form of control is usually an invisible yet present form of balance of class power within the economy as well as an existing agreement between the economic interests of employers, workers and the state.

Scholars have argued that states intervene or involve themselves in the restructuring of the industrial relations because they have their own. Some of these reasons may be political, social, economic or even strategic in a security-wise manner.

Both the governments of Britain and France have been involved in the processes of industrial relations especially when the nature of the competition in a particular industry is deemed to be unfair or discriminatory e.g. in the case of Tesco and Carrefour in the case of Britain and France respectively. In addition, the two states have always been involved in settling industrial disputes either directly through workers unions or indirectly through tribunals. In addition, they have always been monitoring the sensitivity of demand to economic conditions.

By monitoring this sensitivity, they have always been able to implement the necessary micro and macro economic policies through either the fiscal policies or the monetary and foreign exchange policies in order to ensure that there is maximum productivity within their industrial sectors.

The industrial relations systems of the two countries are relatively similar since both states are capitalistic in nature. These industrial relations represent a collective system of regulatory mechanisms that have widely been used in settling industrial disputes and problems like strikes, high inflation, high unemployment as well as ever-recurring political crisis.


Comparative Employee Relations

Due to the fact that states can and do, exercise the monopoly of power states thus have the necessary capabilities and capacities to influence policies that will ultimately be accepted by the industrial organizations.


Despite these similarities in the role of the state in industrial relations, there are still some remarkable differences between the state roles in those same relations between the two states. These differences were not only structural but they were also because of the legacies of specific industrial relations that the two economies adopted from their past. These legacies compounded by internal structural difficulties and lack of certain institutional capacity building resulted in certain rigidities of dealing with the industrial relations in the two states.

In the British case, the rigidities were highly associated with the deep trade union resources and capacities that have been widely spread within the British economy as well as the system of decentralization in the collective bargaining in the work place.

The labor government elected in 1997 did not change the industrial relations that were existent during the Thatcherism years since 1979.


Comparative Employee Relations

On the side of France, the rigidities especially during the ford years were more associated with the role of the state mostly on the issue of its excessive regulation of the labor market.

The other difference between the British and the French roles in industrial relations is more political than social. The two countries pursue different ideologies and this resulted in immense structural differences between the two states.


For the past decade, the industrial relations in both Britain and France have been improving. The role of the state in industrial relations and reforms has been on the decrease. This trend has helped to bring some sense of security and facilitation not only some sense of security and facilitation not only in the industrial relations sector but also the respective economies, as well as the promotion of international trade and commerce.

Britain and France are two of the biggest and most powerful countries within the European Union. This means that issues of involvement in the industrial sector is closely monitored since the effects of their actions will not only be felt within their economies only but also within the wider European Union as well as their major trading partners as well.


Comparative Employee Relations


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François Crouzet. 1995. Management and Business in Britain and France: The Age of the

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Hoffmann, J. Waddington, J. Kahmann, M. 2005. A Comparison of the Trade Union Merger Process in Britain and Germany: Joining Forces?. London: Rout ledge

Ian Clark.2000. Governance, the State, Regulation and Industrial Relations. London: Rout ledge


Comparative Employee Relations

Robert Salais.1998.Governance, Industry and Labor Markets in Britain and France: The

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