Union power around the world

The UK may have been the birthplace of the trade union movement, but that doesn’t mean other countries have followed in its footsteps in terms of legislative power and national attitude

There are major differences in union power in different parts of the world, says UNI Global’s Christina Colclough, differences that are “defined partly by culture, partly by historical tradition and partly by law”.

“In the US for example you can’t just join a union for ideological reasons, you can only join if your workplace has collective agreement... Then you have the Nordic model where about 80% of employees are members and unions and employers have great autonomy in defining labour market roles,” she says.

Colclough cites academic Tony Huzzard’s definition of union and employer relationships as either “boxing or dancing”: “In the Nordics, Germany and Holland it’s dancing – ‘we agree to disagree, but we’ll dance and find a solution that suits us both’. In other places, like Latin America, there are awful cases where unionists are killed.”

Differences in approach can be traced back to the post-war era, says University of Glasgow’s Melanie Simms. “In advanced capitalist countries like North America, the EU, Australia… much of the reason why the union movement looks as it does goes back to the social compromises made about the balance of power between workers and capital in the aftermath of the war,” she says. “Where we had the process of industrialisation and the urbanisation of the population there’s been a greater impetus to regulate and organise work.”

Where worker voice is encouraged, there’s much stronger union membership levels and power, adds Simms: “If you look at countries like Sweden, what they’ve done is be able to collectively negotiate the way new forms of work are introduced. Then America is the furthest down the road of decollectivising the labour market – it’s almost entirely about labour law and their legal system is not particularly supportive of worker rights.”

Meanwhile, unions in the UK and Australia are very similar to each other in terms of “their approach to the workforce and interaction with leaders”, says Jamie Getgood, director of Getgood Consulting and former HR director of General Motors Holden.

“I’ve probably seen more difference in the influence of unions in Asian countries, possibly because of their socio-economic conditions... These unions had a stronger influence to the point where industrial action was a lot heavier and they would be a lot more aggressive in how they would approach leaders.”

By contrast, under French law unions represent employees whether they are union members or not, meaning low membership doesn’t translate into low power, explains Wright: “France has amazing bargaining. 90% of the workforce are covered by a collective bargaining agreement, but only about 9% of employees are members. Unions are seen as necessities to running the country.”

This piece appeared in the September print issue. Subscribe today to have all our latest articles delivered right to your desk

Further reading

A new dawn for trade unions?

What do good HR-union relations look like?

D&I and HR at trade unions