National industrial relations influences on European Works Councils: the case of UK- and US-based companies

The view that the role of European Works Councils (EWCs) is shaped predominantly by national industrial relations traditions in the company’s country of origin derives largely from the experience of EWCs in companies based in continental Europe. This article argues that a more differentiated approach to the influence of national industrial relations factors on EWCs needs to be developed to take account of the circumstances of companies headquartered in the UK and the US, whose national industrial relations arrangements do not provide a strong institutional model for the EWC, and, in the case of US-based companies, where headquarters management has little or no direct involvement in the EWC. Findings from comparative case studies of EWCs in eight UKand US-based multinationals suggest that their character is shaped by the interplay between ‘country of origin’ factors, ‘country of location’ factors and company-specific considerations.