Institutional and labour relations regimes promoting decent working conditions for Local and Regional Government (LRG) Workers in Croatia, Germany, Greece, Spain, and Sweden
Abstract
This publication presents a comparative analysis of the Local and Regional Government (LRG) sector workforce in five European countries: Croatia, Germany, Greece, Spain, and Sweden. Despite variations in governance models and industrial relations, commonalities emerge, such as the LRG sector's significance in the national public sector, a predominant female workforce, and strong organization within social dialogue and collective bargaining systems. Governance structures influence LRG workforce size, with Croatia and Greece displaying highly centralized administrations, while Spain, Sweden, and Germany showcase stronger LRG-level administrations. Notably, LRG workers constitute a substantial portion of public sector employment across all five countries. The gender pay gap is lower in the public sector than the private sector, declining over time.
Diverging historical trends in LRG sector size are observed, with increases in Germany, Spain, and Sweden, while Greece experienced a decline linked to austerity measures. The study highlights variations in labour regimes. Training rights for LRG workers lack legal provisions in all countries except Spain, where it is included in collective bargaining. LRG workers benefit from a strong right to association, union representation, social dialogue traditions, and extensive collective bargaining coverage. Trade union presence is higher in the LRG sector compared to the private sector. Legal rights to strike exist for LRG workers in all countries except for German civil servants in the sector. While the ratification of the ILO Violence and Harassment Convention (No.190) is limited, all five countries have enacted national and EU legislation against workplace discrimination and harassment.
Executive Summary
The study provides a snapshot of the main features of the LRG sector workforce in five European countries: Croatia, Germany, Greece, Spain, and Sweden. The five countries have different models of governance, industrial relations, wage setting, collective bargaining, and collective interest representation. Whilst there are important differences, key similarities in the LRG sector in all five countries include the sector being an important part of the national public sector, employs predominantly women employees and is well organised in terms of the coverage in the social dialogue and collective bargaining systems.
In terms of the governance system, all five countries are the same in the sense of having three main levels of government: central, regional, and local. However, there are important differences between countries which are highly centralised with strong central government level (such as Croatia and Greece) and highly federalised states such as Germany and Spain where the regional government level plays a significant role. Sweden falls somewhat in between, with both strong national as well as local government levels. This shows a variety of state and LRG organisational models in the Europe region.
These governance differences translate in turn into different size of LRG workers in the five countries. The proportion of LRG workforce in the overall public sector employment ranges from 13 percent in Croatia, 16 percent in Greece to 78 percent in Spain and Sweden and 79 percent in Germany. This shows a large and highly centralized public administration in Croatia and Greece on one hand and strong LRG level administration in Spain, Sweden, and Germany. Still, in all five countries the LRG workers form an important part of the public sector. What is also common across the five countries is that most LRG sector workers are women. Consequently, the question of gender pay gap is important to consider. In all five countries, the gender pay gap is lower in the public sector compared to the private sector and declined over time.
On the other hand, countries differ in terms of the historical evolution of the size in the LRG sector. The numbers of LRG workers have increased in three of the five countries under study: +7 percent at the regional and +12 percent local level in Germany, +9 percent in Spain and +8 percent at regional level and +3.5 percent at local level in Sweden. Historical trend data for Croatia was not available, while LRG workers in Greece have decreased by around 20 per cent, mostly connected to the austerity measures related to Greece’s 2008-2009 debt crisis.
Most European countries have two main forms of labour regimes and employment in the LRG as a public sector: the civil servant regulated by laws relating to the civil service and the ordinary employee, under the employment contract law. The exception to this is Sweden, where the same employment rules are applied to public sector employees as those applied to the private sector and LRG workers have no special legal status.
The five countries are also similar in that none provide a legal right to training for LRG workers, and training and professional development topics are not typically included in the collective bargaining agreements (except for Spain). Training is provided typically by the individual LRG sector employers with LRG workers varying as to whether they are having a regular review of their training needs, training time being counted as working time and coverage of training expenses.
Across the five countries, the LRG workers enjoy a deeply entrenched right to association, union representation, strong traditions of social dialogue and high collective bargaining coverage. Trade union presence amongst the LRG workers is typically higher than for the private sector employees. Also, the right to strike for LRG workers is legally guaranteed in all five countries, except for civil servants in the LRG sector in Germany. Where data is available, the number of strikes in the public sector is lower than in the private sector.
Whilst the ratification of the Violence and Harassment Convention, 2019 (No.190) is not widespread amongst the five countries studied (only by Greece), all five countries have adopted national and EU legislation prohibiting discrimination and harassment at work.
Introduction
Countries have different layers of governance depending on the degree of political, fiscal, and administrative decentralisation. However, most countries have three layers of government – central, regional/state/provincial, and local/municipal. Collectively, the non-central layers of government are referred to as sub-national governments, local governments, or local and regional governments (LRGs). Organically, sub-national governments refer to any existing form of government below the national or central government. Various terms are used to refer to workers in sub-national governments such as council workers, municipal workers, local government, or sub-national workers. In this study, these terminologies are used interchangeably to refer to workers in local government.
The role of sub-national workers in the delivery of public services has become increasingly crucial, especially in the wake of climate change, global pandemics, and the need for sustainable development. These workers are at the frontline of public service delivery and the implementation of the Sustainable Development Goals (SDGs). However, the structure of sub-national workers and the depth of the services they provide differ substantially from one country to the next, depending on the level and form of decentralization. Usually, the depth of decentralised local government services in federalised countries is greater than in centralised countries. Additionally, the environment for good labour relations as well as social dialogue mechanisms tend to differ substantially depending on the existing constitutional frameworks and relevant labour regimes.
Decentralization is three-pronged: political, fiscal, and administrative. Political decentralization or devolution refers to the transfer of political authority to local governments, providing local communities with an opportunity to vote for their local representatives (IDEA 2015, 23), while fiscal decentralization involves the shifting of responsibility for revenues and expenditure to local governments and administrative units (USAID 2009, 13).
Administrative decentralization, on the other hand, is the transfer of administrative responsibilities for the planning and management of public functions from the central to sub-national governments and administrative units (USAID 2009, 14). Administrative decentralization also includes planning, monitoring and evaluation of service arrangements, along with human resource requirements and management systems such as recruitment, promotion, transfers, payment of salaries, and training. Decentralization has four mutually reinforcing characteristics – authority, autonomy, accountability, and capacity.
Table 1: Dimensions and characteristics of decentralization
|
Political |
Fiscal |
Administrative |
|
|
Authority |
Sub-national officials are authorised to govern through elections instead of via appointment by national government. |
Sub-national officials have the authority to levy taxes and take spending decisions. |
Sub-national officials have the authority to plan and manage the provision of an expanded range of services. |
|
Autonomy |
Sub-national officials gain autonomy from national governments because they hold distinct electoral mandates, and certain autonomies have been defined by law or institutionalized in long accepted practice. |
Sub-national officials can act autonomously (subject to national legislation and regulation) from national government to the degree that they can take decisions relating to revenues and expenditure. |
Sub-national officials are able to hire and fire sub-national government employees (subject to civil-service rules), giving officials some degree of autonomy from national government. |
|
Accountability |
Sub-national officials are accountable to local constituents via elections and civil-society forums. However, they remain accountable to national government through national legislation and standards. |
Sub-national officials are held accountable by sub-national voters and civil-society groups for the greater fiscal resources under their control. |
Sub-national officials hold sub-national bureaucrats accountable for the quality of service provision. |
|
Capacity |
Sub-national officials face electoral incentives to build sub-national governments’ capacity to provide valued services. |
Sub-national officials understand the likely economic consequences of tax and expenditure decisions. |
Sub-national officials are able to perform their assigned roles because they occupy top structures with adequate institutional capacity. |
Source: USAID, 2009.
Sectoral social dialogue at EU level
The European Sectoral Social Dialogue Committee for local and regional governments (SSDC LRG) was established in 2004 between EPSU and the Council of European Municipalities and Regions (CEMR). It was the only instance of sectoral social dialogue in the EU that dedicated special attention to the impact of the financial crisis of 2008. The agreed products of SSDC LRG (since 2008) are included in Table 2.
Table 2. Some agreed products of SSDC LRG, 2008-2015
|
2008 |
|
|
2009 |
|
|
2010 |
Joint statement to the European Council on the economic crisis |
|
2010 |
|
|
2011 |
The European Commission Guide on Socially Responsible Public Procurement (Joint statement) |
|
2011 |
Municipal and regional employers and trade unions deeply concerned about the effects of the crisis (Joint Statement) |
|
2012 |
Joint Social Partner Response to the European Commission’s Green Paper COM (2012) 7 final “Restructuring and anticipation of change: what lessons from recent experience?” |
|
2012 |
Joint Letter to MEP Tarabella on Review of Procurement Directives |
|
2012 |
Framework of Action for LRG |
|
2013 |
Necessity and nature of a new EU OSH policy framework (Joint Response) |
|
2013 |
Local and Regional Government: Supporting the European Framework of Action on Youth Employment |
|
2014 |
Joint Guidelines Migration and Strengthening Migration and Anti-Discrimination in Local Government |
|
2015 |
Joint statement in support of the Commission initiative to relaunch Social Dialogue |
|
2015 |
Joint seminar on digitalization of local government services as part of the joint project on “New forms of service delivery for municipalities, the contribution of social dialogue and good practice for well-being at work” |
|
2015 |
Joint statement on digitalisation |
Source: Bordogna 2018, p. 15.
Localizing SDGs for inclusive development
Local government, being the closest to the people, is central to achieving the agenda 2030. LRGs are inextricably embedded in the structure and formulation of the SDGs and their targets. The SDG bottom-up approach places LRGs at the centre of the agenda. From ending hunger and poverty in all its forms to protecting, restoring, and promoting the sustainable utilization of terrestrial ecosystems, LRGs remain key to the localization, adaptation, and implementation of the SDGs at the community level.
Development is ultimately local, and there cannot be inclusive and sustainable development without the full participation of LRGs, whether directly or indirectly. LRGs play a direct role in achieving the following SDGs:
-
SDG 3: Ensure healthy lives and promote well-being for all ages. In most countries, primary healthcare workers and health protection services have been decentralized to LRGs. This places LRGs at the centre of the implementation process of SDG 3, which seeks to, among others, strengthen the prevention and treatment of substance abuse, halve the number of global deaths and injuries from road traffic accidents, and end preventable deaths of new-borns and children below the age of 5.
-
SDG 4: Ensure inclusive and equitable quality education and promote lifelong learning opportunities for all. Early childhood educators (ECEs), pre-primary and primary-school teachers all fall within the ambit of LRGs. With adequate resources, local government’s capacity to deliver quality education to children in communities would help increase the number of youth and young adults with relevant skills, champion the elimination of gender disparities in education, ensure equal access for vulnerable groups, and provide adequate educational facilities that are child, disability, and gender-sensitive.
-
SDG 6: Ensure availability and sustainable management of water and sanitation for all. Sanitation workers are at the frontline of water and solid waste management systems. LRG-employed sanitation workers are critical to meeting the targets relating to the provision and adequate management of water supply and sanitation to communities and cities.
-
SDG 8: Promote sustained, inclusive, and sustainable economic growth, full and productive employment, and decent work for all. Inclusive development implies local communities’ participation in development, while simultaneously guaranteeing decent work for all. LRGs are better placed to localize “development-oriented policies that support productive activities, decent job creation, entrepreneurship, creativity and innovation, and encourage formalization and growth of micro-, small- and medium-sized enterprises including through access to financial services”.1
-
SDG 9: Build resilient infrastructure, promote inclusive and sustainable industrialization and foster innovation. LRGs build and maintain local infrastructure such as roads, office spaces etc. They are well positioned to conduct environmental assessments and make decisions on which type of industries to set up, taking into consideration both sustainability and environmental impact.
-
SDG 11: Make cities and human settlements inclusive, safe, resilient, and sustainable. LRGs operate in cities, towns, and communities and, therefore, are better placed, with support from central government, to advance this goal.
-
SDG 13: Take urgent action to combat climate change and its impact. LRGs are responsible for preserving and nurturing the environment through the maintenance of forests, and sensitizing communities against deforestation and prudent management of water resources.
-
SDG 14: Conserve and utilize oceans, seas, and marine resources responsibly to ensure sustainable development. LRGs have a key role to play in the prevention and elimination of marine pollution, especially from land-based sources such as plastics. Maintenance of the coastlines, beaches, and solid waste management fall within the LRGs’ mandate.
-
SDG 15: Protect, restore, and promote sustainable utilization of terrestrial ecosystems, manage forests sustainably, combat desertification, as well as halt and reverse land degradation and terminate the loss of biodiversity. Operating in communities, LRGs understand and appreciate the material conditions of local people who may be engaged in deforestation. They are better placed to lead sensitization programmes and design alternative sources of energy for local communities.
Model of analysis and methodology
This study seeks to reflect on the key issues affecting LRG workers in five European countries: Croatia, Germany, Greece, Spain, and Sweden which represent the different geographies, state organization models, and income levels. Although they are not representative of the whole of Europe, they are sufficient for a snapshot analysis of the situation obtaining in LRGs across Europe’s diverse degrees of decentralization.
The report is based primarily on desk research of available information, including European and national statistics, statistical banks, reports, studies, and publications. The information was obtained through a general search of key policy databases and general information holders at the national level (such as national statistical institutes). In addition, responses to the questionnaire issued to the affiliates of EPSU/PSI2 and Council of European Municipalities and Regions (CEMR)3 have been reflected in the report results.
The countries selected also represent a sample of the centralized industrial relations regimes, as defined by the European Commission in 2008 according to the manner the countries generally address them, as follows:
-
organised corporatism, with union density higher than employer density, but high collective bargaining coverage;
-
social partnership, with employer density higher than union density, but also high collective bargaining coverage;
-
state-centred, with high employer density, low union density, and high collective bargaining coverage.
Other two regimes are not studied here:
-
liberal, with low union and employer organization density and collective bargaining coverage; and
-
mixed, even lower than the liberal model on all three areas.
This study focusses on the three typologies with centralized collective bargaining: Sweden, an organised corporatism country; Germany, a social partnership country; and Greece, Croatia, and Spain, which are state-centred. Collective bargaining in Sweden and Germany is mainly at the sectoral level, while the OECD has characterised the principal level of bargaining in the remaining three countries as “variable/unstable” (Visser 2009, 49).
Table 3. Industrial relations regimes in countries under study
|
Regimes/ countries |
Union density |
Employer association density |
collective bargaining coverage |
|---|---|---|---|
|
Organised Corporatism |
|||
|
Sweden |
65.2 (2019) |
80-90 (2018) |
90.0 (2018) |
|
Social Partnership |
|||
|
Germany |
16.3 |
67.8 (2019) |
51.8 (2019) |
|
State-centred |
|||
|
Croatia |
20.8 (2018) |
56.3 (2014) |
46.7 (2017) |
|
Greece |
19.0 (2016) |
52.7 (2017) |
25.8 |
|
Spain |
12.4 |
77 |
80.1 |
Sources: ILOSTAT; OECD /AIAS ICTWSS database (Sept 2023)
The five countries selected also represent different forms of the decentralisation and organisation of the delivery of public services at the local and regional level. Indeed, the form and character of decentralization has implications on the working conditions of sub-national workers. According to the Decentralization Index – An interactive tool with a perspective on different dimensions of decentralisation (political, administrative and fiscal) across the 27 EU Member States, Germany and Latvia are the most politically decentralized countries at the local level in the EU region with Ireland being the least decentralised. Administratively, Denmark ranks first followed by Estonia and Poland while Ireland is the least administratively decentralized. In terms of fiscal decentralization, Denmark ranks first regarding the expenditure ratio (i.e., the relative share of overall sub-national expenditure compared to total government expenditure) followed by Spain, and Germany.
The Decentralization Index measures the degree of decentralization based on the three different dimensions of decentralization (political, fiscal, and administrative) by allocating a score of between 0 – 3 to each of the 27 EU member countries. A score of 3 implies the highest degree of decentralization while a score of 0 means the least degree of decentralization. On this basis, the five countries, which are a focus of this study score differently on the Decentralization Index as shown in the table below.
Table 4. Decentralization Index
|
Country |
Decentralization Score |
Overall Decentralization Score |
Decentration Index Rank out of EU27 |
||
|
Political |
Fiscal |
Administrative |
|||
|
Croatia |
1.5 |
2 |
1.2 |
1.6 |
16/27 |
|
Germany |
2.5 |
3 |
2 |
2.5 |
1/27 |
|
Greece |
1.8 |
0.3 |
1.6 |
1.3 |
22/27 |
|
Spain |
1.8 |
2.7 |
2.2 |
2.2 |
6/27 |
|
Sweden |
1.8 |
3 |
2.3 |
2.4 |
4/27 |
Source: European Committee of the Regions: Decentralization Index, accessed September 2022
Croatia
Croatia has three levels of governance - central level, regional level consisting of 21 regional government units - 20 counties (županija) and the City of Zagreb and local level that includes 428 municipalities (općine) and 128 towns/cities (gradovi). The constitutional basis for the establishment of Local and Regional Self-Government is enshrined in Part VI of the Constitution of Croatia.4
Governance system
Croatia has a highly centralized administration consisting of strong central government and LRGs that act as intermediary in organizing centrally led and financed health, education, and social welfare services (European Commission 2018a).
Figure 1. Croatia: government structure
The central state authorities are responsible for overall legislation and execution, the state budget and annual accounts, security and defence, adoption of decrees to implement laws, foreign and domestic policy, direction and control over the civil service operation, economic development, direction of the performance and development of public services.
Counties, in turn, are in charge of the following activities:
- education,
- medical care,
- town and urban planning,
- economic development,
- transit and traffic infrastructure,
- planning and development of the network of educational, medical, social and cultural institutions, and
- issuing building and location permits, other acts related to construction, and the implementation of physical planning documents within their physical area but outside large cities.
Municipalities perform tasks of local importance that directly address the citizens’ needs and are not assigned to state bodies, such as:
- organization of settlements and housing,
- town and urban planning,
- utility services,
- child-care,
- social welfare,
- primary health protection,
- education and primary-school education,
- culture, physical culture and sports,
- consumer protection,
- protection and improvement of natural environment,
- fire-protection and civil defence,
- traffic
Large cities have broader jurisdiction, which also includes the municipal economy, maintenance of public roads, issuing building and location permits, other acts related to construction, and the implementation of physical planning documents within their physical area.
LRG labour statistics
There are no complete statistics about LRG sector employment in Croatia. Estimates show that in 2015, there were 317,075 government employees in Croatia (about 18 per cent of the country’s workforce), out of which 87 per cent were central government employees, and the remaining 13 per cent (around 41,000) were employed in the LRGs, indicating a large and highly centralized public administration in Croatia (European Commission 2018a, 102-103). Between 2016 and 2018, the LRG sector employed some 36,000 employees, out of which 22,000 (60 per cent) were local government and around 14,000 (40 per cent) were employed in the regional government (Eurofound 2019).
Sectoral breakdown
Within the LRG sector, about half of employees work in local government administration, a third is employed in social work services, and the rest (20 per cent) are in the residential care services, libraries, archives, museums and cultural activities. At the regional level, less than a fifth of the public sector employees are in the regional government administration, and the remaining over 80 per cent are evenly widespread in residential care services, social work activities, and libraries, archives, museums and cultural activities.
Table 5. Croatia: Employment by sub-sector, 2018
|
Numbers of Employees in the entire LRG sector |
36 057 (Croatian Bureau of Statistics) |
|||
|
Numbers or estimates of the numbers of Local Administration Employees |
Administration of local governments |
Residential care activities under the responsibility of municipalities |
Social work activities under the responsibility of municipalities |
Libraries, archives, museums and cultural activities under the responsibility of municipalities |
|
22,308 |
9,765 |
3,654 |
7,015 |
1,874 |
|
Number or estimates of the numbers of regional administration Employees |
Administration of regional governments |
Residential care activities under the responsibility of regional administration* |
Social work activities under the responsibility of regional administration* |
Libraries, archives, museums and cultural activities under the responsibility of regional administration* |
|
14,521 (est.) |
2,521 |
4,000 (estimation) |
4,000 (estimation) |
4,000 (estimation) |
* These activities can be financed or governed by regional government / administration.
Source: Pavlovaite et al, 2022.
Labour regimes
There are two main forms of labour regimes and employment in the public sector: the civil servant and the employee. Civil servants employed by the central state (within the ‘state administration system’) at the central level and LRGs are regulated separately from employees and other workers in all parts of public administration who are employed based on labour contracts regulated by the Labour Act of 2014. Civil servants perform administrative and professional tasks within the field of activity of their relevant bodies, whereas employees perform supporting and auxiliary tasks. The Act on Civil Servants and Employees in Local and Regional Self-government regulates the rights, duties and responsibilities, as well as other matters relevant for the work of civil servants and employees in local government units’ administrative bodies.
Most state-employed workers in the administration are civil servants. The largest share of civil servants is in the state (central and LRG) administration – 93 per cent of all employed. In the LRG, their share is 88 per cent, and in centrally financed public services it is 86 per cent. The civil servants’ rights established in the Civil service legislation include the right to salary, the right to training, the right to equal treatment in service, political rights, and the right to be protected in the event of whistleblowing, among others (European Commission 2018a).
Pay structures
The Government Decree of 2001 (with multiple later amendments) establishes the coefficients that determine civil servants’ remuneration, complemented by other factors.
High-ranking senior civil servants are paid less than their counterparts in the private sector, while the salaries in the lower echelons of public administration are higher than the lowest salaries in the private sector (European Commission 2018a). Average wages in the public sector in Croatia declined between 2008 and 2016. In 2020, the government increased the wages for all civil and public servants by 6.12 per cent (in three increments of 2 per cent).
Figure 2. Croatia: gross wages, public administration and defence; compulsory social security (2012 - 2022, EUR)
Source: ILOSTAT
In 2021, men working in the public sector earned eight per cent more than women on average (Salary Explorer 2021). However, overall, in the public sector the gender pay gap was lower than in the private sector and decreased slightly in the last years.
Figure 3. Croatia: gender pay gap (per cent), 2016-2019
Source: Eurostat
Training
In Croatia, civil service training is seen as closely linked to the objectives and processes of public administration reforms. These links are explicitly recognised, making civil servants’ participation in training activities and programmes both a right and an obligation (OECD 2008). Article 54 of the Labour Act obliges the employer provide “schooling, education, vocational as well as professional training for the worker.” In-service training for civil servants is partially centralised. In 2004, the Civil Servants’ Training Centre was established as the main training institution responsible for promoting and implementing civil service reforms. Training programmes and curricula for civil servants are derived from training needs assessments. More than ten state bodies continue to organise in-service training in their respective fields (tax administration, diplomacy, etc.) (European Commission 2018a).
Trade union rights and working conditions
There are no collective agreements covering the whole of local and regional administration. Out of all workers in the LRG sector, half are covered by multi-employer and single employer collective bargaining. Collective agreements are bargained and signed separately at the regional and local levels, and they cover around 70 per cent of the workers in the LRG administration, public order and safety, 20 per cent of the workers in the fire service, and 10 per cent of the social workers under LRG, residential workers, and library, archives and museum and cultural activities employees under LRG (Eurofound 2019). There is significant heterogeneity in the extent and patterns of collective bargaining in LRG units. There are LRG units in which rights of all employees, including in enterprises they own, are regulated by regular collective bargaining agreements. There are also LRG units in which collective agreements were concluded only for a segment of employees. This situation results in lack of coordination of employees' rights in different units of local government.
The Trade Union of State and Local Civil Servants and Employees of Croatia (SDLSN) is the only trade union that represents all types of public service workers. SDLSN - the strongest trade union in the sector and member of PSI, EPSU, ITUC and ETUC - is involved in multi-employer and collective bargaining in the sector and is consulted by the government on working conditions or employment related issues in the sector (Eurofound 2019). In some cities or regions there are some smaller and less influential TUs, which are not representative for the collective bargaining. Public sector trade unions have been successful in challenging outsourcing reforms, such as a reform intended to outsource about 26,500 jobs from public administration to the private sector in 2014 (European Commission 2018a).
The other three local government associations promoting and serving the interests of sub-national governments include the Association of Municipalities which cover 283 associated municipalities out of 428; Association of Towns, with 121 out of 128 towns; and the Croatian County Association with 20 counties and the City of Zagreb as members. The three associations are all members of CEMR.
The right to strike is constitutionally guaranteed with some restrictions that apply to the armed forces, the police, the civil service and public services (where some LRG workers are working, such as in the municipal police for example) (EPSU and ETUI 2020a).5 Such workers even when on strike must continue to work to guarantee minimum services in their area of responsibility.6 According to the Labour Act, only trade unions have the right to call and undertake a strike.7
There is a significant body of European countries that are implementing national legislation on the prohibition of discrimination and harassment at work.8 However, Croatia has not ratified ILO Convention on the Elimination of Violence and Harassment in the World of Work, 2019 (No. 190).
Germany
Governance system
Germany is a federal state, consisting of three levels of government – national federal government, 16 states (Länder) and 11,054 municipalities. The Basic Law (the Constitution) defines the federal and state governments' legislative responsibilities as exclusive federal powers (Articles 71 and 73), competing powers (Articles 72, 74), shared powers (Article 72), and exclusive state /region powers (Article 70). The regions have exclusive powers in the police (excluding federal police), most of education, the press, freedom of assembly, public housing, prisons, and media affairs. Municipalities are the lowest level of administration in Germany. There are several types of municipalities in Germany, with different levels of autonomy.
Figure 4. Germany: the government structure
Services provided by municipalities
The federal government can exercise authority only in the areas specified in the Basic Law. The exclusive legislative jurisdiction of the federal government includes defence, foreign affairs, immigration, citizenship, communications and currency standards
The federal and state governments share concurrent powers in several areas including but not limited to business law, civil law, welfare, taxation, consumer protection, public holidays and public health. German states organize registry offices, food inspection, civil registration, and statistical work.
The lowest level of official territorial division are the five main different types of municipalities. The municipalities have “mandatory tasks that are prescribed by federal or state laws . . . . These include passport and civil registration services, the provision of schools and roads, urban land-use planning, street cleaning and wastewater management. . . . In addition, there are voluntary municipal tasks such as culture, sports facilities and local development cooperation.” (Engagement Global 2023)
Other municipal tasks include road construction, transport, maintenance of schools and kindergartens, public safety (fire protection service, labour inspectorate, building inspectorate), social assistance (social welfare, old people‘s homes, homeless shelters), education and culture (adult education centres, libraries, theatres, orchestras, museums), utilities (water, electricity, gas), housing construction, urban planning, economic development, health and youth welfare, waste disposal, sewerage, green spaces, recreation, cemeteries, hospitals, playgrounds, and sports facilities.
LRG labour statistics
Currently, more than six million public sector employees work in the country, where most or 41 per cent are at the regional governments, 38 per cent in the municipal governments and 12 per cent in the federal government. The number of employees has increased at all government levels over the last five years, with the highest increase observed at the municipal level (+12 per cent).
Table 6. Germany: Evolution of public employment by government level
|
2015 |
2016 |
2017 |
2018 |
2019 |
2020 |
Change 2015-2020 |
|
|
Federal |
690,890 |
692,840 |
702,745 |
716,405 |
734,050 |
755,070 |
9% |
|
Regional |
2,501,095 |
2,527,215 |
2,556,870 |
2,602,305 |
2,650,600 |
2,684,645 |
7% |
|
Municipal |
2,218,510 |
2,257,845 |
2,317,270 |
2,362,785 |
2,416,970 |
2,478,450 |
12% |
|
Social insurance |
407,845 |
410,355 |
411,880 |
413,885 |
414,425 |
419,180 |
3% |
|
Total |
5,818,340 |
5,888,260 |
5,988,765 |
6,095,375 |
6,216,040 |
6,337,345 |
9% |
Source: Federal Statistics Office
Over half of the employees in the public sector are women. The share of female employment is particularly high at the municipal and regional level, in contrast with less than a third of female employees at the federal level.
Table 7. Germany: Female employment, 2020
|
Women |
Total |
Per cent of women |
|
|
Federal |
215,365 |
755,070 |
29% |
|
Regional |
1,543,915 |
2,684,645 |
58% |
|
Municipal |
1,471,100 |
2,478,450 |
59% |
|
Social insurance |
292,520 |
419,180 |
70% |
|
Total |
3,522,895 |
6,337,345 |
56% |
Source: Federal Statistics Office
There is a high incidence of part-time employment at the municipal and regional level, where more than a third of employees are working part-time.
Table 8. Germany: Part-time employment, 2020
|
Part-time |
Total |
Per cent of Part-time |
|
|
Federal |
88, 415 |
755 070 |
12% |
|
Regional |
875, 740 |
2, 684, 645 |
33% |
|
Municipal |
933, 535 |
2, 478, 450 |
38% |
|
Social insurance |
154, 690 |
419, 180 |
37% |
|
Total |
2, 052, 385 |
6, 337, 345 |
32% |
Source: Federal Statistics Office
Sectoral breakdown
Employees at the regional and local levels show different patterns of concentration in particular sub-sectors, reflecting the different levels of competence. At the regional level, more than half of employees work in the education sector, and a third in general services. In contrast at the local level, the employment is more evenly widespread between general services, social security, and health sub-sectors.
Table 9. Germany: Employment by sub-sector, 2020
|
Sector |
Total |
% |
Federal |
% |
Regional |
% |
Municipal |
% |
|
General services |
1,695,410 |
27% |
417,515 |
55% |
776,085 |
29% |
501,810 |
20% |
|
Education, Science, Research, Cultural Affairs |
1,753,980 |
28% |
18,285 |
2% |
1,519,990 |
57% |
213,575 |
9% |
|
"Social security, family and youth, Labour market policy' |
935,500 |
15% |
9,095 |
1% |
49,130 |
1.8% |
498,920 |
20% |
|
Health, environment, sport and recreation |
688,760 |
11% |
12,715 |
2% |
86,870 |
3.2% |
556,290 |
22% |
|
Housing, urban development, regional planning and community services |
276,870 |
4% |
20 |
0% |
25,455 |
0.9% |
251,280 |
10% |
|
Food, agriculture and forestry |
45,865 |
0.71% |
1 725 |
0.2% |
36 260 |
1.4% |
7 875 |
0.3% |
|
Energy and water management, trade, services |
535,070 |
8% |
136,430 |
18% |
82,200 |
3.1% |
310,850 |
13% |
|
Transport and Communications |
388,085 |
6% |
151,990 |
20% |
103, 355 |
4% |
132, 735 |
5% |
|
Finance |
17,805 |
0.3% |
7,295 |
1% |
5,295 |
0.2% |
5,110 |
0.2% |
|
Total |
6,337,345 |
100% |
755,070 |
100% |
2,684,645 |
100% |
2,478,450 |
100% |
Source: Federal Statistics Office
Labour regimes
There are two main forms of labour regimes and employment in the public sector: the civil servant and the employee, under the employment contract law. The majority of workers are non-civil servant employees (65 per cent), however this differs by government level. At the regional level, more than half of workers are civil servants, whereas at the local level the proportion of civil servants is the lowest at 12 per cent. Typically, the civil servants enjoy a high level of job security, guaranteed pension payment, and additional benefits such as family allowances. Civil servants are not allowed to take industrial action. Employees are employed under the existing employment contract law and covered by the collective bargaining outcomes.
Table 10. Germany: Employees by employment status, 2020
|
Total public |
Federal |
Regional |
Local |
|
|
Civil servant |
35% |
37% |
53% |
12% |
|
Armed Forces |
- |
34% |
- |
- |
|
Employee |
65% |
29% |
47% |
88% |
|
Total |
100% |
100% |
100% |
100% |
Source: Federal Statistics Office
The federal, regional, and municipal workers are not evenly distributed across Germany. Almost a third of workers work in three states of Nordrhein-Westfalen, Bayern and Baden-Württemberg – a consistent pattern at the regional and local as well as federal levels.
Table 11. Germany: Employees by place of work, at the level of Länder, 2020
|
Place of work |
Total |
Federal |
Regional |
Municipal |
|
Nordrhein-Westfalen |
1,003,880 |
92,910 |
473,870 |
360,410 |
|
Bayern |
808,535 |
70,940 |
372,020 |
312,400 |
|
Baden-Württemberg |
656,315 |
34,990 |
325,480 |
253,610 |
|
Niedersachsen |
471,185 |
64,300 |
223,865 |
151,015 |
|
Hessen |
357,855 |
35,995 |
176,820 |
122,170 |
|
Berlin |
288,825 |
46,540 |
210,575 |
|
|
Rheinland-Pfalz |
251,830 |
33,250 |
117,900 |
84,535 |
|
Sachsen |
231,145 |
13,840 |
120,030 |
79,410 |
|
Schleswig-Holstein |
170,890 |
28,700 |
78,185 |
53,330 |
|
Brandenburg |
140,060 |
17,840 |
59,955 |
51,785 |
|
Hamburg |
129,950 |
13,115 |
100,645 |
|
|
Sachsen-Anhalt |
126,025 |
9,410 |
60,760 |
46,410 |
|
Thüringen |
119,640 |
9,535 |
62,020 |
37,815 |
|
Mecklenburg-Vorpommern |
97,445 |
17,425 |
45,040 |
26,575 |
|
Saarland |
57,260 |
4,445 |
30,465 |
17,300 |
|
Bremen |
43,740 |
3,345 |
35,580 |
40 |
|
Abroad |
13,435 |
13,340 |
95 |
Source: Federal Statistics Office
Pay structures
Remuneration in the LRG sector is defined by the level and grade occupied by workers in the administrative career grade, which can be complemented by other factors such as the length of service and family status. There are wage differences in the monthly wage earned between the civil servants (over 4,000 EUR per month) and employees in the public sector (around EUR 3,300). Overall, in the public sector civil servants earned nearly 900 EUR more per month compared to ordinary employees. The difference was smaller at the federal level and increased to over 1,000 EUR at the local level. For comparison, an average monthly gross wage in the private sector in 2020 was estimated to be around EUR 3,000 thus lower than in the public sector.9
Figure 5. Germany: Gross monthly wage, 2020, EUR
Source: Federal Statistics Office
The gender pay gap decreased from nine per cent in 2014 to 5.9 per cent in 2022 in the public sector, which was significantly smaller than in the private sector where it stood at 17.7 per cent (Eurostat).
Training
There is no legal right to training in the public sector (including LRG) legislation or collective agreements (nor for the private sector). Training is provided at the discretion of the individual public sector employers with employees having a right to a regular review of their training needs. Training time is counted as working time and training expenses are covered by employers. The Collective Bargaining Agreement for the public sector (TVöD) acknowledges the importance of continuous and lifelong learning as being in the best interest of employers and employee. Training services are provided by a range of training providers at the regional and local level. The public sector is one of the most active sectors in providing further training to its employees. In 2018, the proportion of public sector entities providing training was 85 per cent, compared to the average of all organisations (public and private) 54 per cent (Bundesrepublik Deutschland und des Bundesministeriums für Bildung und Forschung 2020).
Trade union rights and working conditions
In the public sector, freedom of association and the plurality of trade unions are recognised and deeply entrenched. Trade unions are permitted to organise workers as well as civil servants in the public sector but may not represent civil servants in the collective bargaining structures. The wages of the latter are unilaterally set by the public employer after consultation of the trade unions.
Collective bargaining takes place separately at the regional and local levels and its outcomes together cover more than 80 per cent of local and regional employees (Eurofound 2020). At the local level, the single existing collective bargaining agreement is called Tarifvertrag öffentlicher Dienst (TVöd), negotiated typically for the duration of three years.10 It covers more than 90 per cent of all workers employed with the municipal employers; the TVöd is taken as a reference by publicly owned companies. On the trade union side, the United Services Union (Ver.di) and the Civil Servants Union and Wage Union (dbb) participate in negotiations on behalf of local government workers. The Gewerkstatt Erziehung und Wissenschaft (GEW), Industriegewerkstatt Bau, Agrar Umwelt (IG BAU) and Gewerkstatt der Polizei (GdP) are also part to the signed collective agreements signed on behalf of the workers while the employer is represented by Verband Kommunaler Arbeitgeber (VKA).
At the regional level, the single existing agreement is called Tarifvertrag der Laender (TV-L), negotiated typically for the duration of three years. It covers the workers employed by the governments of the 15 (out of 16) Laender which signed the agreement and is taken as a reference by publicly owned companies. The state of Hesse did not sign the agreement, negotiating its own separate agreement. On the trade union side, the Ver.di, GEW, GdP, IG BAU and dbb represent the workers in negotiations while the employers are represented by the Tarifgemeinschaft deutscher Länder (TdL). In 2001, Ver.di claimed to have 3.85 million members and represented 85 per cent of LRG employees. (Waltheri 2001)
The industrial relations actors have stayed unchanged over the past decade. In collective bargaining, the municipalities and district authorities are represented by the federal employer association VKA whereas 15 out of 16 federal states cooperate in the wage commission of the Laender, the TdL. The remaining state, Hesse, settles a collective agreement by its own.
On the worker side, ver.di – the strongest trade union in the sector and a PSI and EPSU member - takes the lead in negotiating with VKA and TdL. Another three subsector-related DGB-affiliates are also involved, these are the police union GdP, the union for education GEW, and the construction, forestry, and environment workers union IGBAU. The second main actor aside of ver.di is dbb, a CESI member, which in collective bargaining represents two sector-related affiliates (i.e. KOMBA and the German police union DPG). A small affiliate of the Christian Trade Union Federation CGB, the GÖD, also operates in the sector and settles some agreements in eastern Germany. Thus, ver.di takes the lead in negotiating with VKA and is delegated to negotiate by GEW, IG BAU and GdP; the latter involve in negotiating with the Laender. At both levels, ver.di cooperates with dbb. GÖD is a competing union which reached some agreements in eastern Germany.
The right to strike is constitutionally recognized for employees. Civil servants amongst the LRG workers are not allowed to take industrial action (EPSU and ETUI 2020b). The ban is justified by the reference to one of the traditional principles underlying the professional civil service in Germany. Moreover, as the right to strike is confined to issues that can be settled by collective agreement, public servants are consequently excluded from that right because the terms and conditions of their employment are established by legislation. LRG workers with the status of employees have unlimited right to strike.
In the last few years, the number of striking workers and the strike days has consistently been lower in the public sector than in the private sector. For example, only 30 per cent of workers in the public sector went on strike in 2020 relative to private sector workers.
Between 2015 and 2020, the number of public sector workers on strike had consistently been less than that of workers on strike in the private sector which reflects in the low number of days lost due to the strike (strike days).
Table 12. Germany: Number of workers striking and strike days, 2015-2020: Public administration, defence and compulsory social security vs. other sectors
|
Year |
Number of workers striking |
Strike days |
||
|
Public Administration |
Others |
Public Administration |
Others |
|
|
2015 |
39,881 |
189,723 |
292,121 |
800,000 |
|
2016 |
15,003 |
200,264 |
21,236 |
188,199 |
|
2017 |
2,608 |
58,631 |
3,018 |
125,979 |
|
2018 |
34,083 |
648,010 |
37,379 |
533,429 |
|
2019 |
3,919 |
84,274 |
4,824 |
157,045 |
|
2020 |
32,535 |
107,111 |
34,040 |
161,380 |
Source: Federal Employment Agency
Table 13. Germany: Number of strikes, 2022: Public administration, defence and compulsory social security vs. other sectors
|
|
Number of strikes |
Number of workers |
Strike days |
|
Public Administration |
332 |
31,100 |
34,052 |
|
Others |
1,200 |
253,800 |
232,642 |
Note: Breakdown for regional and municipal workers not available
Source: ILOSTAT
Germany has not ratified the Violence and harassment Convention, 2019 (No. 190) but has adopted legislation that prohibits discrimination and harassment at work.
Greece
Governance system
In Greece the levels of governance consist of the central/state government that includes a central and a decentralised level (7 decentralised branches of the central government, called ‘decentralised administrations’), and local self-government, consisting of 13 regions and 325 municipalities. Municipalities are divided into local communities (with less than 2,000 population) and municipal communities (with population over 2,000). The municipalities and regions constitute the first and second level of local self-government, which cooperate with each other (European Committee of the Regions n.d). The Greek public administration is highly centralized (EU 2018).
Figure 6. Greece: the government structure
Note: In some policy areas, the competences of the different levels of government overlap.
Sources: European Union, 2018; CCRE – CEMR, 2016
Services provided by Subnational governments
Most competences remain largely in the hands of the central government. There are also competences in different policy areas that are shared between the central and local government.
Article 102 of the Greek Constitution establishes the foundations for the provision of subnational government services: “The range and categories of local affairs, as well as their allocation to each level, shall be specified by law. Law may assign to local government agencies the exercise of competences constituting mission of the State.”
Decentralised state administrations supervise regional and municipal authorities, assess the legality of administrative acts of municipal authorities, manage state assets etc. There are several areas of concurrent powers between regions and municipalities, and others are exclusive to each.
Regions are responsible for regional development planning, “green development”; agriculture, livestock, fishery; natural resources, and energy-industry (water management, mineral wealth, energy, industry and manufacturing); employment, trade and tourism; transports and communications; works, spatial planning, and environment; health; education, culture, and sports; and civil protection, and logistics.
Municipalities are responsible for building permits and urban planning applications; issuing of professional licences; rural development, agriculture, livestock and fisheries; transport infrastructure; healthcare; education; environment; quality of life and proper functioning of cities and settlements; employment; social protection and solidarity; education, culture and sports; and civil protection. However, insular municipalities exercise additional powers in the following areas: agriculture; natural resources, energy and industry; employment, trade and tourism; transports and communications; and works, urban and spatial planning and environment. (Council of Europe 2012)
The economic adjustment programme for Greece called for merging municipalities, prefectures and regions with the aim of reducing operating costs and “establish local government units sizeable enough to marshal resources and skills useful for the absorption of EU funding.” (European Commission 2011) As a result, 325 municipalities were created from 1034 previously existing ones (Sotiropoulos 2018), part of around 4,500 local government entities that were closed or merged. (European Commission 2011) However, a recent study “[u]sing data for the 2005-2018 period, [found] very weak evidence of the reform on current costs, while the amalgamation of municipalities is associated with a significant decrease in per capita investment of around 31 Percent. This effect is robust, persistent, and associated with a substantial decline in GDP per capita of about 5% after the amalgamation took place.” (Benos et al. 2023)
LRG labour statistics
In 2022, there were 371,800 public administration employees in Greece. Public administration employment in Greece shrank by 18.2 per cent between its pre-crisis level of 382,000 in the first quarter of 2008 and its zenith in 2019 (Table 16). This trend is connected to the austerity measures related to Greece’s 2008-2009 economic crisis, which led to layoffs and 50 per cent reduction in government subsidies to the local administration (Pavlovaite et al, 2019).
Figure 7. Greece: Evolution of employment in public administration and defence; compulsory social security (thousands), share of total employment
Sources: ILOSTAT
Sectoral breakdown
The share of the central government in the public sector employment was 84 per cent, and that of the local and regional government – 15 per cent and one per cent, respectively.11 Between 2015 and 2017, the number of employees at the local government/municipal level reduced from 82,769 to 74,134, the majority of whom - around 66,000 (89 per cent) – were employed in the local administration. An even higher decrease took place at the regional level between 2012 and 2015 when the number of regional administration employees was reduced by more than half from 14,943 in 2012 to 6,803 in 2015 (Table 14). Apart from the overall number of employees, it was not possible to find disaggregated data at regional or municipal level by, for example, department.
Table 14. Greece: number of employees in the local and regional administration (LRG), 2012 - 2017
|
Year |
Total number of Local administration employees |
Administration of local |
Municipal administration: Residential care activities |
Municipal administration: Social work activities |
Municipal administration: Libraries, archives, museums and cultural activities |
Total number of regional administration employees |
|
2012 |
- |
65,919 |
672 |
7,066 |
477 |
14,943 |
|
2015 |
82,769 |
- |
- |
- |
- |
6,803 |
|
2017 |
74,134 |
- |
- |
- |
- |
- |
NOTE: ELSTAT no longer publishes two-digit economic activity data. Also, it was not possible to find the gender-disaggregated data for local and regional government employees.
Sources: European Union, 2018; Hellenic Statistical Authority (ELSTAT), 2017; European Council, 2012.
Labour regimes
There are two broad categories of employees of the central and local government: civil servants and public employees with a labour contract. The latter may have a contract for an indefinite time period or a fixed-term contract while civil servants are appointed with tenure and their employment relation with the state is regulated by the Civil Service Code (included in Laws 3528/2007, 3584/2007 and 4057/2012). However, court decisions have equated the status of civil servants with that of employees with indefinite period contracts. Public employees under fixed-term or project-based contracts, regulated by Labour Law, do not enjoy tenure of employment (European Commission 2018b). Subnational workers are represented by the ADEDY union, which represented 73.33 per cent of them in 2001 (Waltheri 2001).
Pay structures
Between 1997 and 2009, there were pay increases to bring the civil service in line with the private sector, with a new pay method based on a series of 36 salary scales according to each job category. Each scale is broken down into 18 levels, each one with a base salary. Employees salary is raised by one level automatically every two years. Local government contractual employees’ salaries are set by collective agreements concluded between trade unions, the Ministry of the Interior, and the Ministry for Finance. In local governments, remuneration is the same as for State civil servants (Eurostat 2015b). Remuneration in the public sector is generally defined by two factors: a) three components (basic salary, seniority and post allowance), established by law, which often changes depending on the condition of the state’s finances; and b) variations in the remuneration by ministry and state agency. The basic salary depends on educational level; the seniority allowance is added to the basic salary every three years; and a post allowance is provided to civil servants in managerial positions. There are no performance-related bonuses (European Commisssion 2018b).
Between 2009 and 2013 the average income of civil servants fell by eight per cent, while that of employees in public corporations (albeit starting from a comparatively much higher level) fell by 25 per cent. In comparison, salaries in the non-banking private sector fell by 19 per cent for the same period (European Commisssion 2018b).
Some categories of civil servants earn more than other public sector employees (European Commisssion 2018b). In 2021, on average, the public sector employees in Greece earned six per cent more than their private sector counterparts, with average salary in the public sector being EUR 2,520 compared to EUR 2,370 in the private sector (Salary Explorer 2021). Data specifically relating to the wages of local/regional government workers are not available, but the trend for the overall public sector wages also applies at local government level.
From 2010 to 2018, the gender pay gap in the public sector declined by 53 per cent compared to one per cent decline in the private and remained smaller than that in the private sector (Table 18).
Table 15. Greece: Gender pay gap in unadjusted form by type of ownership of the economic activity
|
2010 |
2014 |
2018 |
Difference, (2010-2018) |
% Change (2010 – 2018) |
|
|
Public sector |
16.4% |
13.0% |
7.7% |
8.7% |
-53% |
|
Private sector |
17.3% |
16.4% |
17.2% |
0.1% |
-1% |
Source: Eurostat, “Gender pay gap in unadjusted form by type of ownership of the economic activity”.
Training
In 1994, a High Council for the Selection of Personnel was established by Law No.2190/1994 and is responsible for the selection and training of civil servants (including local and regional government workers). It is an independent authority overseeing the selection process, ensuring merit, impartiality, and transparency. In 1983, the National Centre for Public Administration and Local Government was founded with the aim of training civil servants. High level civil service officials have been trained in the National School for Public Administration before entering the public service. The Institute for In-Service Training is an additional unit of the Centre, providing continuous professional training (Hellenic Republic 2022). The Ministry of Administrative Reconstruction is responsible for standardising recruitment and skills profiles, overseeing the initial and in-service training of civil servants in the National Centre of Public Administration and monitoring the conduct of competitions for entry-level civil servants ((European Commisssion 2018b).
Trade union rights and working conditions
There are two major trade union confederations in Greece – ADEDY (Supreme Administration of Greek Civil Servants Trade Unions), covering the central, local, and regional government employees – a member of PSI and EPSU, and GSEE, which organises private sector employees and employees in firms and sectors under public control. Below this level is a hierarchy of union structures - primary level unions (at the base) and second level organisations (industry or occupational federations, or regional organisations, known as labour centres). ADEDY is a third-level organization with primary-level trade-unions of civil servants forming secondary-level federations which are members of ADEDY, among them is the municipal workers’ POE-OTA trade union federation (ETUI 2016a).
General collective agreements which regulate the overall terms and conditions of employment of employees covered by Law No. 2738/1999 are drawn up following negotiations between these employees' most representative third-level trade union organisation (i.e. confederation) and the central government. For negotiations on issues concerning first- and second-level local authority employees, representatives of the Central Union of Municipalities and Communes of Greece (KEDE, a member of CEMR) or the Union of Prefectural Governments of Greece (ENAE) respectively are also present at the negotiations (Pavlovaite et al 2019).
The Civil Servants’ Code regulates the status of public employees except some cases, which require special conditions or are subject to constant changes. In addition to civil servants and contractual staff, temporary staff are hired for three to eight months in order to cover temporary staffing requirements. Public employees have almost the same rights and obligations as civil servants, with differences related to their assessment, promotion, health and social security system and pension schemes. Temporary contractual staff do not enjoy the same rights, but some benefits are the same, such as maternity leave (Eurostat 2015b). The Civil Service Code defines the rights and obligations of civil servants and contract employees with indefinite period contracts, including workers at the local and regional government level. Individual rights include the right to privacy, the protection against dismissals, the right to participate in political activities, the freedom of association, the right to belong to a political party, and the right to strike (European Commission 2018b). The right to strike is guaranteed by Article 23 of the Constitution. Only trade unions may call strikes (ETUI 2017).
As regards civil servants, a strike may be called only by the second level and third-level trade union organisations after a decision of the general assembly, or by primary trade union organisations of broader geographic regions or national coverage. Strikes are prohibited for members of the judiciary and persons serving in the security corps, including military personnel and civil servants of the armed forces and the Hellenic Coast Guard (EPSU and ETUI 2019a). There are no official statistics for strikes in Greece. According to the GSEE Institute of Employment, between May 2010 and the end of 2015, the GSEE organized 28 general strikes (20 lasting 24 hours and 4 lasting 48 hours) (ETUI 2017).
The new Greek employment Law No. 4808/2021, domesticates the Violence and Harassment Convention, 2019 (No. 190), which, along Italy makes Greece a forerunner amongst the EU. Under this law, employers are obliged to take measures to prevent discrimination and harassment at work and to receive, investigate and manage all complaints related to violence and harassment at the workplace confidentially, without any tolerance for violence, and in a way that respects human dignity.12
Spain
Governance system
Spain has three levels of government - central, regional (comprised of 17 autonomous communities and the autonomous cities of Ceuta and Melilla) and local, (consisting of 50 provinces and 8, 131 municipalities). The Constitution sets out the division of powers, where exclusive, legislative, and basic competences are attributed to the State while the Autonomous Communities assume competences that are not attributed to the State and defined in their Statutes of Autonomy. The provinces exist mainly for coordinating purposes (see Figure 8).
Figure 8. Spain: the government structure
Sources: European Committee of the Regions; European Commission, 2018c
The central government has constitutionally guaranteed basic and legislative competences in different areas, such as exclusive powers in international relations, defence, administration of justice, commercial, criminal, civil and labour legislation, customs, general finances ad state debt, public health, etc.
Autonomous communities have almost exclusive power to manage their own finances, education, health, social services, agriculture, industry, and trade, although the central government has the power to issue basic legislation in these areas. Depending on their Statutes, autonomous communities may have additional powers, such as regional security forces, co-official language, etc.
Provinces are generally responsible for securing coordination and provision of municipal services. Municipalities, in turn, provide local public services (the type of which depends on the municipality size), such as public road maintenance, drinking water supply systems, waste collection and treatment, civil protection, etc.
LRG labour statistics
Between 2009 and 2019, public sector employment as a share of total employment slightly increased from around 2.8 million to just above 3 million employees, or around 15.6 per cent of all employees in Spain (Table 15). The OECD reports that “In 2021, public employment in Spain represented 16.6% of total employment,” for an annual average growth rate of 2.8 per cent (OECD 2023). The regional government share was 58 per cent, compared to around 20 per cent for the central and local government each, indicating high decentralisation from central to regional and local government (EC 2018).
Figure 9. Spain: Growth in employment (thousands of employees)
Sources: Author’s calculations based on data from Eurostat, “Employment and activity by sex and age – annual data” and OECD 2021a.
Sectoral breakdown
In 2019, 43 per cent (1,313,600) of the public sector employees were employees in the local and regional administration, most of which (79 per cent) were in the regional administration. Two-thirds of the regional and three-quarters of the local administration employees were employed in the administration of their respective level of government (Pavlovaite et al, 2022). There was no data on female employment at the local and regional levels of government.
Table 16. Spain: number of employees in the local and regional administration (LRG), 2019
|
Total number of regional administration employees |
Administration of regional |
Regional administration: Residential care activities |
Regional administration: social work activities |
Regional administration: libraries, archives, museums and cultural activities |
|
1,037,000 |
680,000 |
202,000 |
136,000 |
19,000 |
|
Total number of Local administration employees |
Administration of local |
Municipal administration: Residential care activities |
Municipal administration: Social work activities |
Municipal administration: Libraries, archives, museums and cultural activities |
|
276,600 |
203,900 |
37,800 |
25,500 |
9,400 |
Source: Pavlovaite et al, 2022
Labour regimes
There are two main forms of labour regimes and employment in the public sector: the civil servant and the employee with a labour contract. Civil Servants are appointed for life and their employment relation is regulated by Administrative Law. Civil servants may hold most positions in the public sector, as the posts related to the safeguarding of public powers and the State general interest are reserved to civil servants. There is no probation period for newly employed civil servants. The employees under contract are regulated by the Employment Law; they do not enjoy tenure and are recruited only for certain positions. In 2016, civil servants represented a majority of employees in the State (81.6 per cent) and regional (64.8 per cent) administration, while in the local administration they were around 38 per cent (EC 2018).
The Civil Service Basic Statute defines a Code of Conduct and ethical principles as well as rights and obligations accrued to public service workers. Rights include the right to privacy, immobility, administrative career and pay, right to association, and the right to strike, amongst others. Non-civil service employees are subject to an employment contract and are regulated by the Labour Law (Workers’ and Collective Agreements Statute). The Spanish Federation of Municipalities and Provinces represent employers, while Subnational workers are represented by the public service branches of the General Worker Union, the Worker Commissions and the Basque Workers Solidarity, which together represented 72.53 per cent of them in 2001 (Waltheri 2001). At present, there are hundreds of municipal and provincial (called autonomous) collective agreements (Eurostat 2015c).13 There were 78 collective agreements in the provincial and local administrations that had financial impacts in 2022, covering 21,302 workers.14 The Workers’ Commission reports that these agreements recorded the smallest salary increases among all economic sectors in 2021, but the greatest relative increases in 2022. (CCOO 2023, p. 16). A recent effort by the Spanish government to increase their autonomy over the centralized collective agreements was not approved by the parliament.
Most vacancies are filled through competition among the successful candidates. A large proportion of successful candidates are first admitted into a specific training school (e.g. tax inspectors, civil administrators or diplomats). The training may last up to 10 months, and it is more customary at the central than at the LRG levels of government. There is no clear competency framework or performance/competency appraisal that determines the individual training track for each civil servant. Public employees are entitled to training after receiving the permission of the head of the unit (Eurostat 2015c).
Pay structures
Remuneration of the civil servants consists of five components: the basic salary (depends on the educational level); a seniority allowance (paid every three years); rank allowance (based on the personal grade of the civil servant); post allowance (depends on the features of the job); and performance-based bonuses. Basic salary, seniority and rank allowance are established in the Annual Budgetary Law, while post allowance and bonuses are determined by each ministry in negotiations with the Ministry of Finance and Public Administration. The higher the hierarchical level, the less relevance is assigned to the three basic components (basic salary, seniority, and rank), and more to complementary rewards that are not used for working out the pension scheme (EC 2018).
In 2021, on average public sector employees in Spain earned 5 per cent more than their private sector counterparts (2,780 EUR versus 2,660 EUR) across all sectors (Salary Explorer 2024). From 2011 to 2019, the gender pay gap in the public sector decreased from 13 per cent to around 10 per cent and remained smaller than that in the private sector, where a decrease was observed as well - from 21.4 per cent in 2011 to 16.2 per cent in 2019 (Table 21).
Figure 10. Spain: gender pay gap (2013 - 2022)
|
Change 2013-2022, p.p. |
Change 2013-2022, % |
|
|
Public |
-5.4 |
-40% |
|
Private |
-8.3 |
-39% |
Source: Eurostat, earn_gr_gpgr2
Training
In Spain, the development of training policies is in principle assigned to the government bodies in charge of public service and personnel policies. In addition to legal provisions, there are negotiated collective agreements regulating the details of in-service training for public servants. The in-service training of public employees is mostly governed by collective agreements (OECD 1997). The National Institute of Public Administration (INAP) is responsible for training and improvement of the Civil Service, as well as recruitment into the Civil Service; training and professional improvement of public employees; research and publishing; promoting innovation within the public administration, among others. INAP is an autonomous body within the national government of Spain, attached to the Department of Territorial Policy and Civil Service.
Trade union rights and working conditions
The main trade union organizations representing public employees at a state level are: The Trade Union Confederation of Workers’ Commissions (CCOO), the General Workers’ Union (UGT) (both members of PSI and EPSU) and the Confederation of Independent Trade Unions and Trade Union Confederation of Civil Servants (CSIF) (Eurostat 2015c).
By law, unions must be consulted regarding working conditions, the employment framework, the code of conduct, as well as the right to strike and the establishment of minimum services in the event of a strike. The conditions of employment of the civil servants and labour staff (base salary and the employment framework), including the LRG workers, are negotiated between the Ministry of Finance and Public Administration and the public sector trade unions (EC 2018).
The right to strike is a fundamental right under the Spanish Constitution. Strikes affecting an entire sector may be called by trade unions (ETUI 2016b). In 2006, a new Civil Service Statute was agreed between the Ministry of Public Administration and the trade unions FSP (State Federation of Public Services) and FSAP (Trade Union Federation of the Public Administration). This Statute introduced a unified approach to employment conditions in the public sector, such as career paths, code of conduct and collective bargaining. The Statute recognises the right to strike as a full right, but demands that essential community services are maintained, without specifying them.
Civil servants are entitled to strike and union membership except for the armed forces, civil guard and judges, magistrates, and prosecutors, (although professional associations are allowed) and the National Security Forces and Corps (Eurostat 2015c).
Article 37 of the Constitution establishes the right to collective labour bargaining between worker and employer representatives and guarantees the “binding force of the [collective] agreements”.
Spain has ratified 121 of the 178 ILO Technical Conventions including the Labour Relations (Public Service) Convention, 1978 (No. 151); all eight fundamental Conventions; and all four Governance Conventions but is yet to ratify 22 of the up-to-date Conventions and Protocols including the Violence and Harassment Convention, 2019 (No. 190). However, there is a significant body of European legislation on the prohibition of discrimination and harassment at work.15
Sweden
Governance system
Sweden has three levels of governance: central, regional (formerly counties), and municipal. The Constitution recognises local self-government in certain areas and delegate certain responsibilities.16 There is no hierarchy between the two levels of self-government. Each level has different areas of responsibilities. There are 290 municipalities (kommuner) and 21 regions. The regions are a result of the transformation of counties into regions which began in the late 1990s until late 2010s.
The establishment of the local government system is enshrined in Chapter 14 of the Instrument of Government. Beside the Constitution, the Municipal Act of 2017 defines the regions and municipalities as well as their forms of activity. Regions and municipalities are responsible for regional/local matters of public interest. Regions and municipalities do not hold legislative powers. However, they do have executive powers in taxation and administration at their respective levels.17 Taxes are levied as a per centage of the inhabitants’ income (with municipalities and regions deciding on their own tax rates).
Swedish municipalities and regions are responsible for providing a significant proportion of all public services. In a European comparative context, Sweden has a strong local administration with a weaker regional level. Many of the competences are joint responsibilities between local and regional level or shared responsibilities among local administrations. Municipalities are responsible for local transport; Social welfare; education; environmental protection; refuse and waste management, and water and sewage and housing, among others. Regions are responsible for hospitals, energy, Industrial and commercial services and tourism, among others. Additionally, some public services are provided by other devolved state authorities with regional organisation (police, National Employment Authority and more), managed by the county administrative boards. The division of tasks between central government and local and regional authorities has changed over the years, with activities mostly being transferred from central government to regional or municipal bodies.
Figure 11. Sweden: The government structure
Source: Paul T., Levin, 2019
LRG labour statistics
About 1.6 million public sector employees work in Sweden, representing about 30 per cent of all employees (Statistics Sweden 2020). Sweden’s local government (municipal and county councils) account for a large share of the public sector employment. For example, 55 per cent of the total public sector employment is at the municipal level and an additional 6 per cent work in municipality owned enterprises or organisations and a further 17 per cent public sector workers at regional level (Statistics Sweden). The remaining share of public service workers are employed in national government or state-owned enterprises or organisations.
Employment in the public sector increased at all government levels in the 2015-2019 period but decreased in 2020. The accumulated growth in employment was slightly higher in the public sector than in the public sector (+6.5% vs. 3.5%). Compared to the public sector average, employment increased more in the Swedish regions (+8%) and less at municipality level.
Figure 12. Sweden: Private and public employment by government level
|
% Growth (2005-2020) |
|
|
Public |
6.5% |
|
Private |
3.5% |
|
Regional |
8.0% |
|
Municipal |
3.6% |
Source: ekonomifakta, “Privat och offentlig sysselsättning”, accessed August 2022; SALAR, Antal sysselsatta under perioden 1981-2020 (Excel) and Antal anställningar under perioden 1990-2020 (Excel).
Over 70 per cent of employees in the public sector are women. The share of female employment is particularly high at the municipal and county level averaging 77 per cent and 78 per cent respectively, and relatively lower in the national public administration (53 per cent).
Table 17. Sweden: Female employment, 2019 (in thousands)
|
Level of Government |
Women |
Total |
% of women |
|
National public administration |
135.1 |
256.7 |
53 |
|
County council |
213.8 |
273.6 |
78 |
|
Municipality |
692.4 |
902.2 |
77 |
|
Other public organisation and institutions |
114.8 |
190.7 |
60 |
|
Total |
1,156.1 |
1,623.2 |
71 |
Source: Statistics Sweden, ”Arbetsmarknad”, accessed August 2022.
Looking at the share of employees working part-time (especially at municipality level), a clear majority of employees at both regional and municipality levels work full time. There are more workers on part-time at municipal level (25%) than at regional level (9%) resulting in an overall average of 21 per cent.
Table 18. Sweden: Part-time employment, 2020
|
Level of Government |
Part-time |
Paid by hour |
Total employees |
% of part-time |
|
Federal |
NA |
NA |
NA |
NA |
|
Regional |
28,398 |
25,438 |
304,575 |
9% (with an additional 8% paid by the hour) |
|
Municipal |
213,816 |
131,228 |
844,516 |
25% (additional 16% paid by the hour) |
|
Total |
242,214 |
156,666 |
1,149,091 |
21% (with an additional 14% paid by the hour) |
Source: SALAR, , Tabeller Regionanställd personal 2020 and Tabeller Kommunal personal 2020
Sectoral breakdown
Employees at the regional and local levels show different patterns of concentration in particular sub-sectors, reflecting the different levels of competence. Employment is concentrated in school and pre-school related employment (38 per cent), followed by health and care functions other than hospitals (20%) and social services, care, and integration (14 per cent).
Swedish regions are responsible for tasks that are common to large geographical areas, including health care, culture, public transport and strengthening the regions' growth and development. More than six in ten of employees work in healthcare. And additional 19 per cent work in administrative functions.
Table 19. Sweden: Employment by sub-sector, 2020
|
Sub-sector |
Regional |
% |
Municipal |
% |
|
Administration |
53,361 |
19 |
101,814 |
13 |
|
Healthcare |
173,022 |
62 |
- |
|
|
Health and social care |
- |
153,862 |
20 |
|
|
Dental care work |
13,150 |
5 |
- |
|
|
Rehabilitation and prevention |
14,234 |
5 |
7,452 |
1 |
|
Curative and social |
5,333 |
2 |
||
|
social services, care and integration |
- |
109,588 |
14 |
|
|
School and pre-school |
2,549 |
1 |
29,0271 |
38 |
|
Culture, tourism and outdoor life |
668 |
0.2 |
21656 |
3 |
|
Technical |
16,048 |
6 |
82,970 |
11 |
Source: SALAR, , Tabeller Regionanställd personal 2020 and Tabeller Kommunal personal 2020
Note: – means services are not provided at this level.
The national, regional, and municipal workers are not evenly distributed across Sweden. Nearly half of all workers (48 per cent) are concentrated in three of the 20 regions, the regions of Stockholm, Västra Götaland and Skåne. These three regions also contain the highest numbers of regional, local, and national employees, although more pronounced for employees working at state level (with 55 per cent of state level employees working in the three regions).
Table 20. Sweden: Employees by place of work, 2019
|
Place of work |
Total |
National incl. Decentra-lised bodies |
Regional |
Municipal |
Natio-nal (%) |
Regio-nal (%) |
Munici-pal (%) |
|
|
Stockholms län |
292,816 |
129,766 |
32,168 |
130,882 |
29 |
12 |
15 |
|
|
Västra Götalands län |
280,674 |
63,686 |
52,209 |
164,779 |
14 |
19 |
18 |
|
|
Skåne län |
207,182 |
52,975 |
36,728 |
117,479 |
12 |
13 |
13 |
|
|
Östergötlands län |
76,455 |
20,931 |
14,590 |
40,934 |
5 |
5 |
5 |
|
|
Uppsala län |
68,634 |
24,650 |
13,283 |
30,701 |
6 |
5 |
3 |
|
|
Jönköpings län |
61,819 |
11,780 |
11,400 |
38,639 |
3 |
4 |
4 |
|
|
Västerbottens län |
58,518 |
15,399 |
11,131 |
31,988 |
3 |
4 |
4 |
|
|
Örebro län |
55,144 |
12,554 |
11,276 |
31,314 |
3 |
4 |
3 |
|
|
Dalarnas län |
50,560 |
9,847 |
9,649 |
31,064 |
2 |
4 |
3 |
|
|
Värmlands län |
49,751 |
10,628 |
8,898 |
30,225 |
2 |
3 |
3 |
|
|
Hallands län |
49,454 |
10,394 |
8,738 |
30,322 |
2 |
3 |
3 |
|
|
Norrbottens län |
48,689 |
13,634 |
7,597 |
27,458 |
3 |
3 |
3 |
|
|
Gävleborgs län |
47,766 |
10,287 |
8,098 |
29,381 |
2 |
3 |
3 |
|
|
Södermanlands län |
45,847 |
8,685 |
8,570 |
28,592 |
2 |
3 |
3 |
|
|
Västernorrlands län |
45,369 |
11,393 |
7,304 |
26,672 |
3 |
3 |
3 |
|
|
Kalmar län |
42,772 |
8,395 |
7,877 |
26,500 |
2 |
3 |
3 |
|
|
Västmanlands län |
39,705 |
7,999 |
7,599 |
24,107 |
2 |
3 |
3 |
|
|
Kronobergs län |
34,453 |
6,767 |
6,673 |
21,013 |
2 |
2 |
2 |
|
|
Blekinge län |
30,230 |
7,905 |
5,525 |
16,800 |
2 |
2 |
2 |
|
|
Jämtlands län |
26,082 |
6,031 |
4,315 |
15,736 |
1 |
2 |
2 |
|
|
Gotlands län |
11,245 |
3,650 |
1 |
7,594 |
1 |
0 |
1 |
|
|
Total |
1,623,165 |
447,356 |
273,629 |
902,180 |
100 |
100 |
100 |
Source: Statistics Sweden, “Antal förvärvsarbetande (dagbefolkning) efter sektor och kommun”, 2019.
Labour regimes
Generally, the same employment rules are applied to public sector employees as those applied to the private sector. State employees are employed under some special conditions, but there is no formal legal status. The Civil Service Act and the Public Employment Act of 1994 stipulates the basic regulations for public employees (rights and obligations of public employees) and sets out the disciplinary measures respectively (Eurostat 2017).
Swedish laws do not regulate many areas of public employment, except for public employee responsibilities. Like other sectors of the labour market, Swedish public employment conditions are based on sectoral agreements which replace the provisions of the law (where applicable). This method for legislation is called “semi-dispositivity” in the Swedish terminology and means that deviations from the law can only be made through national level collective agreements. Wages and the procedures for wage-setting are strong exceptions from this, these matters are solely regulated through collective and/or individual agreements.
All of Sweden's municipalities and regions are members of the Swedish Association of Local Authorities and Regions (SALAR). Workers are represented by the unions Vision, Vårdförbundet (Association of health professionals), union of professionals (SSR) and the Union for Service and Communications Employees (SEKO), which together represented 74 per cent of subnational government workers in 2001 (Waltheri 2001).
Pay structures
The key level for collective bargaining in Sweden is the sectoral level. There is one set of agreements for the regional and municipal sector and another set of agreements for the sector of central government administration.
In the public sector, collective agreements cover almost all wage earners, white and blue-collar workers alike. They cover all public employers and the Swedish Association of Local Authorities and Regions (SALAR, a member of CEMR) represents all municipalities and regions.18 More than 80 per cent of public sector employees are organised. Collective agreements, however, also cover those not unionised.
Salaries in Sweden are generally negotiated individually upon recruitment. Collective agreements in some cases regulate lowest/starting wage levels, which provide a basis for the individual negotiations. Of the approximately 680 collective agreements on wages in Sweden, fewer than 250 have specified levels for the lowest wages. These include, however, key sectors of employees working at regional or municipal level (including workers in pre-schooling and the care sector).19
Average public sector gross monthly salaries were SEK 36,600 in 2022. There are wage differences, with salaries at regional and national level being, on average, significantly higher than at municipality level: central government wages are 20 per cent higher or SEK7,900 monthly which is equivalent to EUR€707. Average public sector salaries compare globally to average private sector salaries (-6%), and the gap is comparatively larger between private sector white-collar workers and regional and central government workers (-13.4 and 13.0 per cent respectively). The gender pay gap of nine per cent in 2020 in the public sector was identical to that of the private sector, but there are marked differences between the employees in the sectors. Across public and private sectors, the gender pay gap is the smallest at municipality level (-1.5 per cent) and the highest among regional employees (-17.3 per cent). At central government level the pay gap it stood at 4.9 per cent in 2022. The gender pay gap has decreased across the public sector in the last five years, from 12 per cent to 8.2 per cent. The decrease is most marked among regional employees (from 22.3 per cent to 17.3 per cent) (See table 20).
Table 21. Sweden: Gross monthly wage 2022 (SEK) by gender, and pay gaps 2015/2022
|
Employment |
Total |
Women |
Men |
Difference Women/Men 2022 (%) |
Difference Women/Men 2015 (%) |
|
Municipal |
33,700 |
33,600 |
34,100 |
-1.5 |
-4.5 |
|
Regional |
41,300 |
39,500 |
47,700 |
-17.3 |
-22.3 |
|
Central government |
41,500 |
40,500 |
42,600 |
-4.9 |
-7.4 |
|
Average public sector |
36,600 |
35,700 |
38,900 |
-8.2 |
-11.9 |
|
Manual workers, private sector |
30,800 |
28,600 |
32,000 |
-10.6 |
-10.5 |
|
Non-manual workers, private sector |
47,700 |
43,300 |
51,200 |
-15.4 |
-18.4 |
|
Average private sector |
39,000 |
36,600 |
40,500 |
-9.6 |
-12.0 |
|
Total average |
38,300 |
36,200 |
40,200 |
-10.0 |
-12.3 |
Source: Statistics Sweden, ”Average monthly salary by sector 1992–2020”
Training
There is no legal right to training in the public sector or for LRG workers. The collective agreement between Kommunal and SALAR does not include training and professional development provisions. In terms of OSH-related training, the Swedish Work Environment Act, 2014 states that employers must ensure that employees receive the necessary training that promote a good and safe work environment such that no one becomes sick or hurts themselves because of their work.
In 2020, a draft legislation for a joint education within the state administration was published, covering basic education and continuing education for employees in the state administration (Regeringen, 2020). A separate proposal to amend the Swedish labour law has provisions which grant employees the right to take study leave, with a grant corresponding to 80 per cent of their salary (Lindholm, 2021). Additionally, some collective agreements include a right to training leave. In practice, Swedish employee’s participation rate in job-related non-formal education and training 20 across public and private sector is high, and largely above the European average (German Economic institute 2018).
Trade union rights and working conditions
In the public sector, the freedom of association and the plurality of trade unions are recognised and deeply entrenched. The Swedish labour market is mainly regulated through collective agreements without interference from the government.
Reflecting the centralised approach to collective bargaining, the Swedish Agency for Government Employers (SAGE) represents central government while all regional and local governments are represented by the Swedish Association of Local Authorities and Regions (SALAR). Two additional employer organisations represent state-owned companies and municipal companies while workers are represented by the following trade unions which organise and lead different professional groups in the negotiations: the Union for Professionals ASSR; the Swedish Association of Physiotherapists; Vision; the Swedish Teachers’ Union; the Swedish Association of Graduate Engineers; the Swedish Municipal Workers’ Union; the Swedish Association of Occupational Therapists; the Swedish Association of Health Professionals; the Confederation of Executives and Managerial Staff; the Swedish Medical Association; and the Swedish Firefighters Association. The largest of these organisations working regionally or locally is the Swedish Municipal Workers’ Union Kommunal, which has about 280,000 members and is a member of PSI and EPSU.
The central collective agreement between the Swedish Municipal Workers’ Union (Kommunal), and the Swedish Association of Local Authorities and Regions (SALAR) includes regulations about a large variety of working conditions. The collective agreement is revised by the parties every negotiation period. Kommunal and SALAR have signed the latest collective agreement which covers:
-
Contract of employment and working time
-
Termination, notice and terms
-
Working time and working time management
-
Wages, compensation for unsocial working hours and over time etc.
-
Compensation during sickness and parental leave
-
Leave due to personal circumstances
-
Vacation
-
Insurances and pensions
Public employees are regular employees and are therefore regulated by the general rules on strike and collective action (EPSU and ETUI 2019b). Section 14 of Chapter 2 of the Instrument of Government of 2015 guarantees the right to strike and to undertake collective action on the labour market, unless otherwise provided by law or collective agreement. Employees who are bound by a collective agreement may not strike during the agreement period.
The Public Employment Act contains provisions that limit and restrict the exercise of the right to strike in the public sector. These limitations relate notably to strikes of workers in the exercise of official power or which is unavoidably necessary in order to ensure the exercise of official power (Section 23); the obligation for the parties to enter into negotiations in the event of a strike (Section 27) and the award of damages (Sections 28 to 29).
The incidence of strikes in Sweden is low,21 compared to other Nordic countries. There have been no public sector strikes in the last five years, and the LRG workers have not participated in a strike since 2003, while mediators have solved institutional advance notifications. These are issued in advance of the announced intention to strike. 22
Sweden has not ratified the Violence and Harassment Convention, 2019 (No. 190) although preparatory work is underway;23 however, there is a significant body of national legislation that prohibits discrimination and harassment at work.24
Comparative summary
In this study, we have seen how distinct the working conditions of LRG employees are from those in the countries and even in the broader public service. This requires a different approach from the more common cross-national comparative studies, because “given that each sector is characterised by specific product and labour markets, resulting in different workforces, different work practices and different economic contexts.” (Bechter et al. 2012: 184). As the Director of the ILO Sectoral Policies Department stated in 2010, “While social dialogue at the national level (both sectoral or multi-sectoral) have recognized attributes, at the same time, [. . .] there are local level issues related to labour which vary according to the municipality, and are difficult to capture at the national level.” (Tinoco 2010). The conditions of work are different in each country’s LRGs, but the differences with other groups of workers is also noteworthy. As a result, working conditions and status of civil servants and public employees in LRGs do not follow national patterns but a sectoral pattern, resulting in common dynamics within LRGs workers among countries studied.
This echoes the findings from the theoretical work on the sectoral regimes of industrial relations (Bechter et al. 2012) which pointed out the existence of sectoral regimes of industrial relations complementing and even replacing national regimes. This is especially relevant in relation to the labour conditions and statuses of civil servants and public employees in LRGs. Such common trends with LRGs workers among countries studied included principally the existence of two main labour law regimes for the civil servants and ordinary employees in the LRG sector and a high coverage of collective bargaining agreements for LRGs workers and employers.
Governance systems
The governance systems of the five countries are a spectrum ranging from the highly centralised countries with a strong central government (such as Croatia and Greece) to the highly federalised states such as Germany and Spain where the regional government level plays a significant role. Sweden falls somewhat in between, with shared policy responsibilities for the national and local governments.
LRG labour statistics
Differences in employment figures for LRG workers exist in the five countries. The proportion of LRG workforce in the overall public sector employment ranges from 13 per cent in Croatia, 16 per cent in Greece, 78 per cent in Spain and Sweden, and 79 per cent in Germany. Broadly speaking, the number of LRG workers has been increasing in recent years– with a notable exception of Greece, mostly connected to the austerity measures related to Greece’s 2008-2009 debt crisis and subsequent international rescue packages. In other countries, a similar trend in employment growth was observed: For example, a +7 per cent employment growth at the regional and +12 per cent at the local level in Germany.
Gender breakdown
In most countries, the majority of LRG sector workers are women, up to 70 per cent in Sweden. The gender pay gap in the public sector stood at seven per cent in Greece and Germany, eight per cent in Croatia and 10 per cent in Spain. In Sweden, across public and private sectors, the gender pay gap was smallest at the municipality level (2 per cent, where most LRG workforce is concentrated) and the highest among regional employees (18 per cent). In all five countries, the gender pay gap is lower in the public sector compared to the private sector. Furthermore, a decrease in the gender pay gap in the public sector is observed in all five countries (as well as a decline in the private sector).
Labour codes
In most of the countries studied, there are two main forms of labour regimes and employment in the LRG sector: the civil servant regulated by laws relating to the civil service and the ordinary employee, under the employment contract law.25 The proportion of civil servants in the overall LRG sector workforce varies: 88 per cent in Croatia (both local and regional levels combined), 12 per cent at local level and 53 per cent at regional in Germany, 38 per cent at local level and 65 per cent at regional in Spain. The exception to this is Sweden, where the same employment rules are applied to public sector employees as those applied to the private sector. In Sweden, state and hence LRG employees are treated with special conditions, but there is no formal legal status.
Right to training and professional development
None of the five countries recognize a legal right to training for LRG workers, and training and professional development topics are not typically included in the collective bargaining agreements (with the exception of Spain). Typically, training is provided by the individual LRG sector employers with LRG workers varying as to whether they are having a regular review of their training needs, training time being counted as working time and coverage of training expenses. In some countries, part of the training for LRG workers is centrally organised.
Trade union rights and working conditions
In the LRG (as for the whole public sector) sector, freedom of association and trade union pluralism are recognised and deeply entrenched in all five countries. Trade unions are typically permitted to organise both workers and civil servants in the LRG sector, and trade union presence amongst the LRG workers is typically higher than for the private sector employees (in the countries examined where data was available).
The organisation of collective bargaining differs in the LRG sector between the countries. In Croatia and Germany, collective agreements are bargained and signed separately at the regional and local levels. This is different in Sweden where there is one set of agreements for the regional and municipal sector (i.e. the employer organisation SALAR makes a recommendation for the local and regional governments to sign the agreement, who then all sign the collective agreements individually) and another set of agreements for the sector of central government administration. The collective bargaining coverage is generally high. In Croatia, out of all workers in the LRG sector, half are covered by collective bargaining (both multi-employer and single employer bargaining). In Germany, collective bargaining outcomes together cover more than 80 per cent of local and regional employees. Similarly, a high proportion is reported in Sweden, where the collective agreements also apply to employees who are not unionised.
The right to strike for LRG workers is legally guaranteed in the countries, except for civil servants in the LRG sector in Germany. In Spain, whilst LRG workers can strike, the delivery of essential services must be guaranteed. Where data is available, the number of strikes in the public sector is lower compared to the private sector. In Sweden, there have been no strikes in the LRG sector since 2003, with the industrial conflicts resolved by mediators.
Of the five countries studied, only Greece has ratified ILO Convention No. 190 (alongside Italy, which makes it two EU Member States with ratification). This is to be seen in the context of the proposal for an EU Council decision authorizing all EU Member States to ratify the ILO Convention 190.26 In this light, it appears that Germany and Croatia have taken steps to start the ratification.27 Furthermore, all five countries have adopted further national legislation prohibiting discrimination and harassment at work.
Possible directions for future research include examining the trends of LRG employment in other European countries, as well as broadening the scope to examine the aspects of occupational health and safety, digitalization, teleworking and the right to disconnect and responses to green transitions affecting the LRG sector. Also, the aspects relating to promoting gender equality and continuing to ensure a high collective bargaining coverage are worthy to investigate, also in view of pressures on the public budget resources framework.
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