Author Box
Articles Categories
All Categories
Articles Resources

US Vs UK Employment Law: What's the Difference?

February 23, 2012 | Comments: 0 | Views: 385

The old saying goes that the United Kingdom and the United States are just "two countries separated by a common language." But it's more than the use of the letter "u" in labo(u)r that distinguishes these two nations.

Similar to the rest of the European Union, U.K. employment law is designed to protect employees, and is very different than those that exist in the U.S. When first considering international expansion to the U.K., here are some of the employment differences that businesses need to keep in mind:

"At-will" validity. Similar to most countries outside the U.S., at-will employment does not exist in the U.K. The employee-employer relationship is governed by employment law and some of these provisions are reflected in detailed employment contracts; your standard, U.S.-based offer letter will not satisfy the requirements here. Furthermore, terminations in the U.K. must be justifiable and follow certain statutory rules, included a required period of notice. Failure to adhere to the due-process requirements may result in unfair dismissal or discrimination claims by the employee. Non-compete agreements. While non-competition agreements are sometimes included as part of U.K. employment contracts, post-termination restrictions may be unenforceable depending on a number of factors, including the circumstances around the termination of the employment relationship. Again, U.K. employment law skews in favor of employees; courts tend to take a particularly hard look at these types of clauses to see if they are truly justified and ensure that they do not cause hardship to former employees. Background checks regulations. Even though both the U.S. and U.K. are working towards enhancing data privacy for citizens, the countries differ in how pre-employment screenings are managed. The U.S. allows most employers to conduct background checks without many hurdles (some types do require consent); the U.K. allows these checks, but they are only allowed when relevant to the job to be performed. Additionally, in the U.K., data collection providers must meet certain minimum requirements and be registered with the government before being permitted to conduct checks. Different right-to-work requirements. In the U.S., proving the legal right to work in country is often the responsibility of the employee. Companies can be fined for right-to-work issues, but the price tag is minimal when compared to the penalties for such violations in the U.K. As a result, evidence of right to work is part of the employment onboarding process in the U.K., putting the burden on the employer to physically evidence and retain appropriate records of an employee's eligibility to work in the U.K.

Melissa is content manager and international expansion specialist at High Street Partners, the leader in international business services. With innovative, technology-enabled business solutions, HSP simplifies the management and control of international operations.

Read more at: Or follow HSP on Twitter:

Source: EzineArticles
Was this Helpful ?

Rate this Article

Article Tags:

Employment Law


Employment Differences


International Human Resources


United Kindgom Hiring

In India, employment opportunities are set to grow by a good margin in the coming year, a phase which was started in the turn of the second decade of the 21st century. organisation, candidates with

By: Sarkariexam l Business > Careers Employment l April 01, 2013 lViews: 11708

Sometimes it is amazing to see that certain jobs can precipitate huge turnouts in the recruitment drives. It is as if thousands of people were waiting for the vacancy advertisements and the moment

By: Sarkariexam l Business > Careers Employment l December 30, 2012 lViews: 690

In recent times, jobs in healthcare segments have grown tremendously. It is anticipated that this growth curve will continue for the times to come. Various factors are responsible for this

By: Sarkariexam l Business > Career Advice l December 27, 2012 lViews: 446

Are you in a dilemma whether to choose web based CRM or not? If yes, don’t worry. You aren’t the sole person having this doubt.There are numerous firms trying to make out whether investing in a

By: Reneta Vasileva l Business > Customer Service l December 23, 2012 lViews: 409

If you think about it you will realize the fact that each business has its own set of risks that are involved in it.The trade secrets that you have and the information related to the business is what

By: brumbrum1 l Business > Risk Management l December 23, 2012 lViews: 263

As the time is changing, concierge management services are now growing despite the slowing economies of the world. The main reason of it is the need that is highly specific to the people who like to

By: willsmith10 l Business > Management l December 23, 2012 lViews: 333

People resort to self employment opportunities because of economic hardships. If you have just decided to work as a self-employed individual, then you can start looking at prospects that can offer

By: Tim Baberel Business > International Businessl July 10, 2012 lViews: 211

Given that homes and offices worldwide use furniture, it is easy to understand why the furniture business is a huge industry that generates tens of millions of pounds each year and is a truly global

By: Catherine Gliddonl Business > International Businessl July 10, 2012 lViews: 258

When a company evolves, expands and goes public, it is important to start considering international relations. Trading internationally can be hugely beneficial for both parties if your cards are

By: Tomas Donovanl Business > International Businessl July 08, 2012 lViews: 278

In preparing for your very first company trip to China, many Westerners feel that they are adequately equipped to do business as soon as the plane touches the ground. Usually, they have Cliff Notes

By: Tomas Donovanl Business > International Businessl July 08, 2012 lViews: 193

There is a common saying that communication is over 85% nonverbal. We have seen countless examples in movies, television and other popular media where we make fun and laugh at situational comedies

By: Tomas Donovanl Business > International Businessl July 06, 2012 lViews: 240

90% of the packages which are imported or exported from countries go through without any issue. However for the 10% that don't manage this, it's good to know why your package might have been stopped

By: Andrew Mollisonl Business > International Businessl July 06, 2012 lViews: 255