Codetermination rights may differ in at least four ways: the scope of who is covered, the method of worker representation, the kind of board level representation, and the level of power given to worker representatives.

# 1. The scope of who is covered Usually determined by a range of thresholds based on the number of employees in a firm # 2. The method of worker representation Germany and France have works councils with clearly defined legal rights, and codetermination is a de facto extension of unions. In Sweden the codetermination law is a framework that regulates negotiations between employers and a union movement that is powerful enough to enforce these rights by itself. # 3. The kind of board level representation Germany has “parity codetermination” with a much higher proportion of worker representatives on a supervisory board that is not responsible for the day-to-day management of the company. Sweden has a smaller number of worker representatives on a board structure more similar to the United States. France has an even smaller number of representatives on a board structure chosen by each company. # 4. The level of power given to worker representatives This can vary across countries and times. In France, rights have been rolled back: *Where once companies were required by law to prove that mass layoffs were economically necessary, they now merely have to consult the works council on a “social plan” to cushion the impact for those being laid off before they initiate firings.*

theoretical