"In most countries of Western Europe it makes little sense to speak of non-union employee representation, as this is understood in the Anglo-American world, for the principle of collective representation independent of the employer is strongly institutionalised. In this article we examine experience in two countries. In Germany, works councils with a wide repertoire of rights typically work in close partnership with trade unions. The system has experienced strains in recent years, and a growing proportion of mainly smaller workplaces are covered neither by councils nor by collective agreements; but there is virtually no evidence of alternative 'voice' mechanisms, and systems of direct participation are normally introduced by negotiation with councils. In France, works committees have fewer powers, and a divided trade union movement has been less successful than its German counterpart in 'embedding' the legally mandated institutions, at least in the private sector. Despite some common trends in both countries, national distinctiveness remains very apparent. There is growing scope for managerial strategic choice, but this is still institutionally bounded. Much more generally, countries displaying characteristics of a 'European social model' can be expected to sustain a close articulation between union and 'non-union' channels of representation."

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