1. Name: CagiMerelitaID No.

: 2011001230
2. Table of Contents
Introduction ................................................................................................................1Key features
and processes of ER/IR system of the three countries .........................4
Structures and roles and relationship .........................................................................6
Role of Trade Unions in each country .......................................................................7
The role of the State in each country .........................................................................8
The role of Employers Association............................................................................9
Labour market philosophies .....................................................................................10
Labour legislations or Laws .....................................................................................11
Legal framework (collective or individual) .............................................................13
Recent Trends/ Changes ..........................................................................................14
Conclusion ...............................................................................................................15

3. Introduction Employment Relations can be defined as the study of the rules and rule making
processes that regulate the employment relations (Bray, Waring, & Cooper, 2009). It was further
noted by(Bray, Waring, & Cooper, 2009) that at the core of Employment relations, are different
views about the most effective way to manage the relationship between an organization and its
representatives, the managers, and employees and their representatives. This is evident,
as(Devereaux & Moore, 1995) defined employment relationship as the set of all relations and
supporting institutions between employees and employers (Flanagan et al., 1989). This is alls
ummed up by(Sagoa, 2013) who noted that; Industrial relations is a multidisciplinary field
thatstudies the employment relationship and it explores the relationship between employers
and employees, employers and trade unions, their relationship with the state and other
stakeholders, with industrial relations being increasingly called employment relations because of
the importance or significance of non- industrial or employment relationships. Historically, the
British system was heavily indebted in the Australian system. According to (Sagoa, 2013) , the
British system of employment was a collective bargaining one which was adversarial as
supposed to consensual by nature, with the system encompassed a well -developed trade union
movement which was primarily craft as opposed to industry based union. This system was
significant in terms of the development of other employment relations systems, such as
Australia. Since the 1960s, tradition voluntarism has been weakened by the increasing
 legislative intervention of the state, particularly since the election of the Conservative Party
in19701.It was further noted by (EIR Online, 2009) that; the system of industrial relations in the
United Kingdom (UK) is traditionally characterized by voluntary relations between the social
partners, with a minimal level of interference from the state. In the context of very early
industrialization and a liberal political culture in which the state seldom intervened in the affairs
of private actors,1Sagoa, I. (2013, January 4). Industrial or Employment Relations in the United
States; Industrial or Employment Relations in Great Britain. HRM 603: Comparative Studies in
Industrial or Employment Relations. Suva, Nasinu, Fiji: Fiji National University Nasinu Campus.
1CagiMerelita2011001230HRM 603Tri 1, 2013

4. trade unions gradually consolidated their membership and power base throughout the
19thcentury. Various legislative developments also allowed trade unions the right to organize
workers and engage in industrial action. The economic context throughout this time was also
favorable to the development of trade unionism. Owing to the pace of industrialization and the
existence of substantial colonial markets for UK industry, the 19th century and early
20thcentury were characterized by extensive economic growth. This economic climate
facilitated the development of a system in which some of the fruits of economic development
could be designated for collectively bargained wage increases. In terms of the role of the law,
collective bargaining was far more important than the influence of legal regulation. For
employers and trade unions, the role of statute law was to support and extend collective
bargaining rather than to comprehensively regulate the system. Notably, the law provided trade
unions with a series of immunities from UK common law. Historically, Australias employment
relations system can be traced back to the period of the Second World War when manpower
shortages and the demands of the war effort required the smooth assimilation of a large
number of women into the workforce, many in very non traditional roles (Cochrane, 1985)2.
Politically, the Australian system is heavily indebted to the British system. According to (Shelton,
1995), recent changes in the international economic standing of Australia have created an
economic crisis mentality, that is having a last impact on business and politics in this country,
as the government in the late 1980s, recognized the importance of human resource
management in its effort to restructure industry and promote a more productive business
environment. Economically,(Shelton, 1995) noted that, the international economy has changed
in recent times especially since the 1980s; the Australian governments have changed their
 strategies on how the domestic economy should respond to international developments.
Australian economic development has always been strongly affected by its place in the
international politicaleconomy.2Shelton, D. (1995). Human Resources in Australia. In L. F.
Moore, & J. P. Devereaux, Human Resource Management on the Pacific Rim: Institutions,
Practices, & Attitudes (pp. 31-35). New York: Walter de Gruyter. 2CagiMerelita2011001230HRM
603Tri 1, 2013

5. (Shelton, 1995) further noted that the Australian economy during the nineteenth century, was
very open to international force, however, their economy remains highly dependent on its
mining and agriculture industries, despite these industries employing a mere 5% of the total
work force, and has generally experienced strong economic growth from the 1980s to 2007,
with the exception of a sharp downturn in 1990 91.When compared to the background of
Australia, United States of America, human resource management according to (Devereaux &
Moore, 1995), is at the turn of this century appears to be in a state of transition, whether
viewed by human resource specialists or industrial relations theorists. This is supported by
(Sagoa, 2013) , who noted that the persistence of economic pressure that first challenged
American industry in the 1970s continues to reshape US industrial relations, with an effort to
maintain their competitiveness, US firms have developed panoply of strategies ranging from
confrontation and labor control to collaboration and employee empowerment. Furthermore,
globalization of markets, rapid technological changes, shorter product life cycles and shifts in
consumer preferences have increased the pressures on USfirms. According to (Devereaux &
Moore, 1995), the modern employment relationship in the US began in the mid 1800s with
the advent of the mechanized factory, which required the availability of more unskilled and
skilled labor on a longer term, reliable basis (Chandler, 1962;Dobbin, 1992; Jacoby,
1985).(Schneider & Stepp, 2006)noted that employee involvement was first promoted in the
late1960s and 1970s as an antidote to growing disaffection with the industrial workplace.
Moreover, (Kaufman, 2006) added that, ..after the fields early ideas were adopted as public
policy and workers secured some protections at work through laws and unions-difficulties and
differences emerged. Therefore, this assignment will compare and contrasts the main features
of Employment/Industrial relations between Great Britain, US and Australia, with usage of
examples. 3CagiMerelita2011001230HRM 603Tri 1, 2013
6. 6. Key features and processes of ER/IR system of the three countries According to (Sagoa, 2013),
the key features of the system in Britain are; the influence of the Conservative Government
since 1970 on the pattern of employment relations in Britain, the effect which political climate
has on Trade union density, the decline in collective bargaining and the change in the level at
which the such bargaining is occurring, the extent to which Human Resource Management
policies are being pursued by British Management, the view of authors/scholars with regards to
the transformation of British employment relations and the influence of European Union and
the effect of change in government on the future direction of employment relations.
Furthermore, (Sagoa, 2013) noted that the key features in the United States Industrial Relations
systems. He noted that there is a three- tier structure of industrial relations in the United
States which are economy, sect oral, and company/establishment bargaining, and local unions
deal with the daily interaction with employers at the workplace. However, (Sagoa, 2013)
further noted that there has been a change in the shared ideology among the three players
(employers, trade union and government) since the 1980, with the employment having moved
from manufacturing jobs and other jobs that have traditionally been represented by unions to
more service and high technology jobs, and employers have learned that using positive human
resource management practices. Finally, in the past several the governments has increasing ly
provided for the protection of workers rights by passing a variety of legislative actions.
Moreover, the Australian key features of the system in Australia are, according to (Sagoa,
2013),the Australian employment relations have moved from centralized to decentralized
regulation of work, from awards and collectively negotiated agreements to individual contracts
of employment, from full-time, permanent and continuing jobs to contingent forms of work and
from a pluralist system of employment relations to a guitarist approach in which collective forms
of worker representation are diminished. Therefore, when comparing the key features of each
of the countries, the similar key features, are the significant legislative, structural changes, with
declines in union density and power, increase in non standard forms of employment.
However, Great Britain and United States both have a 4CagiMerelita2011001230HRM 603Tri 1,
2013

7. centralised system of industrial relations, whereas Australia, is trying to move away from
acentralised system to a decentralised system. According to (Sagoa, 2013), the voluntary system
characterized by the British industrial relations system for most of the 20th century, at its heart
 was a policy of relative legal abstention, with primacy to and support for regulation through
collective bargaining, as the regulation of employment relationship by means of collective
bargaining between employers and unions(including multi employer level) was far more
important than legal regulation through Acts of Parliament, where statutory law intervened, it
did so to support and extend the collective bargaining and to plug gaps, its coverage and
protection. However, the coverage of collective bargaining in Great Britain has shrunk, as union
membership and density, particularly in the private sector (Sagoa, 2013). This was further
supported by(EIR Online, 2009) who noted that, collective bargaining has become far more
decentralised since the 1970s and 1980s. But when compared to Australia, according
to(Shelton, 1995), The view of union movement is that Australian Workplace
Agreement(AWAs), are an attempt to undermine the collective bargaining power of trade
unions in the negotiation of pay and conditions of their members. Whereas, in the United
States, according to (Sagoa, 2013), collective bargaining effectively sets and regulates the broad,
middle tier of the wage distribution and employment conditions. Therefore, it can further be
said that collective bargaining is used by all the three countries as a means to settle disputes in
workplaces, and the outcome of the negotiations both are benefited by the employers and its
workers. 5CagiMerelita2011001230HRM 603Tri 1, 2013

8. Structures and roles and relationship The structure of employment has changed radically in
recent years (Sagoa, 2013). This statement is true as over the years, the countries, Australia,
Great Britain and United States developed economically, with the increase in supply and
demand for labor. According to (Sagoa, 2013)Australias structure of employment changed
radically, that is, there is a decline in full time permanent employment, with the expansion of
various forms of non standard employment(such as casual work, temporary jobs, outsourcing
and use of agencies and other labor market intermediaries). (Moriguchi, 2000)noted that, in the
U.S. employment system, explicit and elaborate employment contracts in large manufacturing
firms were reinforced by the well-developed legal enforcement mechanism provided by the
state; at the same time, as more firms in the economy relied on explicit contracts, the states
return from providing a legal system to enforce such contracts became higher.(Huebsch,
2013)added that in the United States of America; the history of the labor-management
relationship started in the mid-1860s with the Industrial Revolution. Mass migration of workers
from rural to urban areas led to a surplus of labor, and tough competition between factories. In
 general, few laws existed to protect workers, and employers focused on cutting costs rather
than the care of their personnel. Companies often fired workers for taking part in union
activities. The first national union, the Knights of Labor, dominated labor-management relations
by organizing political actions and conducting arbitration with companies on behalf of workers.
6CagiMerelita2011001230HRM 603Tri 1, 2013

9. Role of Trade Unions in each country The role of trade unions has changed significantly over the
past thirty years (Wright, 2011).Trade unions have a number of functions, some of which have
been more prominent than other sat different periods in history, but, over the course of time
trade unions have developed five principal functions (Ewing, 2004). (Ewing, 2004)further noted
that the five developed principal functions are a service function; a representation function; a
regulatory function; a government function; and a public administration function. According to
(Wiki Answers, 2013), there are nine main functions of a trade union which are; collective
bargaining with the management to settle terms and conditions of employment, advise the
management on personnel policies and practices, taking up the individual and collective
grievances of the workers with the management, work for achieving better say of workers in the
management of affairs of the enterprise which influence the lives of the workers directly,
organising demonstrations, strikes, etc, to press demands of workers, education of workers and
their children, welfare and recreational activities of their members, representing of workers in
various national and international forums, and securing legislative protection for workers from
the government. The main service a union provides for its members is negotiation and
representation. According to (Margetts, 1998), most collective bargaining takes place quietly
and agreements are quickly reached by the union and the employer. The establishment of
conciliation and arbitration systems encouraged the rapid growth of Australian unions and, to a
lesser extent, employer association(Sagoa, 2013). According to (Shelton, 1995), in Australia,
unions may acquire the status of a legal entity (known as collective bargaining) over wages,
working hours and other terms and conditions of employment. In Great Britain, it has been
noted by (EIROnline, 2009),trade unions in different companies and sectors often share
information with one another 7CagiMerelita2011001230HRM 603Tri 1, 2013
10. 10. The role of the State in each country According to (Devereaux & Moore, 1995), the role of
the state has become more important than the labour may having to lose power to
management. Overall, the role of the state is to establish laws such as Safety regulations and to
 also provide financial aid to businesses, that contribute to the economy of a country, in order to
keep the economy afloat(Rollinson, n.d.).Until the 1950s there was probably no other
industrialised country in the world where the State was less interventionist in terms of its
employment relations laws than Britain (Rollinson, n.d.).However, the pace of State intervention
has accelerated significantly since the end of the Second World War, first during the 1960s and
1970s and then again in the 1980s; further interventions by the State during the new millennium
have altered the employment relations landscape in Britain even more(Rollinson, n.d.). As a
result, it is now probably fair to say that individual employment laws, rather than voluntary
collective bargaining agreements, regulate working conditions in Britain (Ewing, 2003), which
has had a huge impact on the behaviour of managers, trade unions and employees(Rollinson,
n.d.).Overall, it can be summarised as, according to (Sagoa, 2013), the key roles of the state in
theindustrial relations or employment relations context are; provision of institutional framework
where the general aim of the state is to provide for the bilateral relationship between the
worker/trade unions and employers/their representatives, provision for collective bargaining
where the state provides the general alternative mechanism for settling general terms
employment by non-political means, limiting or avoiding industrial conflicts where in all
developed nations, the state tries to avoid or limit collective industrial conflicts, and
interpretation of conflict of right and interest where clear distinction is and collective conflict of
interest which are solved peacefully between the parties. 8CagiMerelita2011001230HRM 603Tri
1, 2013

11. 11. The role of Employers Association(Sagoa, 2013)noted that for the role of employers
association are to provide advice, support and training to members on industrial relations, and a
wide range of employment or work related matters.An employers association could also be
described as (EIROnline, 2009) noted, as a counter part to a trade union in that it organises
employers and represents them in collective bargaining, offers them specialist advice and
services and represents them before certain bodies such as the Employment Appeals Tribunal of
the Labour Court. For Australia, most employers Association were vocally supportive of Work
Choices legislation, with some bodies even funding pro- Work media advertisement (Sagoa,
2013). Whereas in Great Britain, the role of the employers association according to (EIROnline,
2009), is for the purposes of negotiation with trade unions or to provide affiliated employers
with industrial relations advice and assistance. Therefore, overall, the employers association
 roles in each country are slightly similar, as they negotiate industry wide, multi-employer
collective agreements with trade unions (EIROnline,2009). 9CagiMerelita2011001230HRM
603Tri 1, 2013

12. 12. Labour market philosophies According to (Bray, Waring, & Cooper, 2009); the public policy
relevance of employment relations in Australia is long running and unidentifiable the
controversy over the introduction and operation of the 2005 Work Choices legislation is only the
most recent example of employment relation contributing a defining issue on which
governments and oppositions differ and on which governments rise and fall. Unemployment
rate are one of the factors that contribute to the rise and fall of the government. According to
(Fontes & Fedec, 2013),unemployment Rate in the United States decreased to 7.60percent in
March of 2013 from 7.70 percent in February of 2013 as reported by the Bureau ofLabor
Statistics. Historically, from 1948 until 2013, the United States Unemployment Rate averaged
5.81 Percent reaching an all-time high of 10.80 Percent in November of 1982 and a record low of
2.50 Percent in May of 1953. In the United States, the unemployment rate measures the
number of people actively looking for a job as a percentage of the labour force. When compared
to United States, Australia had the unemployment rate which remainedun changed at 5.4
percent and had been on the upward trend since reaching 4.9 percent in June of2012 (Fontes &
Fedec, 2013), whereas as also added by (Fontes & Fedec, 2013), Great Britain had the
unemployment rate that is at 7.8 percent up from a year low of 7.7 percent. Therefore, Great
Britain and United states had approximately the same percent of 7.7 percent unemployment
rate. America had the polarization of the business community and organized labour over the
basic provisions of American labour law has accompanied and contributed to the decline in
trade union membership. 10CagiMerelita2011001230HRM 603Tri 1, 2013

13. 13. Labour legislations or Laws Studying notes written by (Sagoa, 2013), it is evident that in the
country Australia has a federation where it is a system of government with a central federal
government and six regional governments, where the role of the state is to only making laws in
relation to industrial relations. However, in 2005, the Howard Liberal government, according to
(Sagoa, 2013), amendments made to the Work Relations Act 1996 were to remove the state
control of industrial relations .According to (Sagoa, 2013), a period of Conservative Government
from the year1979 to 1997under Mrs. Thatcher and then Mr. Major saw a radical break with
 voluntarist tradition of Britishindustrial relations, but the post 1997 Labour government had
taken a different approach to that of its predecessors regarding the role of legislation in
regulating employment relations. However, the voluntary system characterized by British
industrial relations for most of the 20th century, where at the heart of the policy of relative legal
abstention was the regulation through collective bargaining. Furthermore, in the post 1997
legislative agenda, according to (Sagoa, 2013), the National Minimum Wages (NMW) was
introduced in April 1999 and legislation which regulates work time and leave from 1998 with,
legislation on Trade Union recognition procedure being effective from the year 2000.According
to (WikiAnswers, 2013), United States labor law is the body of law that mediates the rights and
duties of workers, employers and labor unions in the United States of America. Federal laws,
such as the Fair Labor Standards Act, the National Labor Relations Act and the Occupational
Safety and Health Act set the standards that govern workers rights to organize in the private
sector, and override most state and local laws. Usually more limited rights for employees of the
federal government, but not state or local governments, where workers derive their rights from
state law(WikiAnswers, 2013).The pattern is even more mixed in the area of wages and working
conditions. Federal law establishes minimum wages and overtime rights for most workers in the
private and public sectors; state and local laws may provide more expansive rights. Similarly,
federal law provides minimum workplace safety standards, but allows the states to take over
those responsibilities and to provide more stringent standards. 11CagiMerelita2011001230HRM
603Tri 1, 2013

14. 14. Finally, both federal and state laws protect workers from employment discrimination. In
most areas these two bodies of law overlap; as an example, federal law permits states to enact
their own statutes barring discrimination on the basis of race, gender, religion, national origin
and age, so long as the state law does not provide less protections than federal law would.
Federal law, on the other hand, preempts most state statutes that would bar employers from
discriminating against employees to prevent them from obtaining pensions or other benefits or
retaliating against them for asserting those rights(WikiAnswers, 2013).
12CagiMerelita2011001230HRM 603Tri 1, 2013
15. 15. Legal framework (collective or individual)For Great Britain, since the employment tribunal
was set up in the year 1964, individual statutory employment rights were enforceable via
Employment Tribunal, however, there is no provision for class action against one employer
(Sagoa, 2013). However, since 1979, there has been no thorough exploration of how
employment disputes might be best dealt with, but the system favors individuals to enforce
their rights where focus is advocated less on providing individual redress for breaches of rights,
more about providing the kind of workplace where breaches is less likely to occur(Sagoa,
2013).However, Australia had changes that were introduced in 1993 by the Keating Labor
government in the form of the Industrial Relations Reform Act 1993, allowed federal non-union
collective agreements to be certified for the first time with incorporated a limited right to
protected industrial action during a designated bargaining period(Sagoa, 2013).America has a
collective framework of industrial relations(EIROnline, 2009), where the federal and state laws
provide legislations to govern labor relations (WikiAnswers, 2013).
13CagiMerelita2011001230HRM 603Tri 1, 2013

16. 16. Recent Trends/ Changes The most critical changes revolve around the role of the
government actions in the workplace (Devereaux & Moore, 1995). For the country United States
some major changes faced is, according to (Devereaux & Moore, 1995), managers revolve
around the characteristics of workers, with more women joining the workforce, as well as
minorities, causing adjustments in the traditional expectations. In addition, (Devereaux &
Moore, 1995), further noted that due to the demographic changes in the profile of workers is
the lack of workers with requisite skills and productivity, compared to workers in industrialized
countries. Moreover, in United States the role of the government was to establish rules for an
orderly process in which workers would duly: elect individuals to represent them in a collective
negotiation with employers, over wages, hours, and working conditions, finally, the extensive
degree of experimentation with employee participation, work organization, and human
resource practices in both union and non union setting has further tested traditional patterns,
but these conflicts and experiments have occurred primarily in the private sector, with
government sitting on the sidelines as a seemingly uninterested observer (Sagoa, 2013).
However, according to (Sagoa, 2013), during Clintonsadministration, the labour market and
workplace policies were put back on the national agenda For the Australian employment
relations system, (Sagoa, 2013) noted that some changes are; previously the regulation of work
 and employment are that a long tradition of centralized regulation of wages and conditions
through awards and agreements in the Australia Industrial Relations Commission, at both the
industry and national level. However, over the past decades, the reduction in the scope of the
Commissions jurisdiction to conciliate and arbitrate award matters with encouragement of
individualized agreements between workers and employers at the enterprise level. Added to
this changes is that, previously, predominantly permanent, full-time forms of employment with
hours regulated by awards and collective agreements, however, over the past decades, almost
half of the workforce now employed in jobs which are casual, part-time and/or fixed contract.
When compared to Australia and United States, for Great Britain, (Sagoa, 2013), highlighted that
some of its changes are, the retreat from collective bargaining, voice, high involvement of
Human Resource Management (HRM), contingent pay, upheaval in the public sector and legal
regulation. 14CagiMerelita2011001230HRM 603Tri 1, 2013

17. 17. Conclusion The purpose of this assignment was to explore the origins of the distinctive
employment systems that emerged in the U.S. Australia and Great Britain, and to develop a
theory which provides consistent explanation for the institutional developments for both
countries since the beginning of this century. The main findings and interpretations provided by
the comparative historical analysis can be summarized as follows. At the beginning of the
twentieth century, in spite of the underlying differences between the three countries cultural
traditions, political regimes, and the stages of industrialization, employment relations in large
American, Australian and Great Britain manufacturing firms were similar in the following
aspects. Employment contracts were simple, short-term, and individualized, and employment
at-will was a prevailing principle in both societies. There were highly competitive labor markets
in which wages were determined by general skills and experience. Production workers, skilled or
unskilled, frequently moved among factories seeking higher wages and better working
conditions, implicit, long-term employment contracts and company-wide unions under a new
legal framework, with some important modifications. In particular, blue-collar workers achieved
a higher economic and social status within firms during the process of democratization (Wright,
2011). 15CagiMerelita2011001230HRM 603Tri 1, 2013

18. 18. References

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