Most IEL readers will be well aware of the huge divide between US labour law and UK/European employment law; the former being based on an “economic” model where a business owner’s rights to hire and fire at will around levels of productivity trump individual workers’ rights; whereas, conversely, the latter is founded on “social” principles, prioritising individuals’ rights to safety and dignity at work, including rights to a higher level of job security and to be paid fairly for their work.
Not so united: the trapdoors between English and Scottish law
Main image
![Welcome to Scotland](https://cdn.internationalemploymentlawyer.com/public/styles/5_4/public/2022-09/Welcome%20to%20Scotland.jpg?itok=AF8Tll9R)
iStock.com/milesgilmour
Get Access
Continue reading International Employment Lawyer
Already have access? Login now
Need access? Find out how to enjoy unlimited access