In some EU countries employee involvement in management’s decision-making processes is exclusively based on legislation (for example in Germany), in others exclusively on collective agreements (for example in Scandinavia), and again in others on a mixture of both (for example in Belgium). The subject matters for employee involvement are as different as the degree of participation, ranging from mere information-sharing to co-determination.

Although South African labour legislation provides for statutory, institutionalised employee participation, it is a concept virtually unknown in South Africa. A number of voluntary (‘non-statutory’) employee participation systems are however in place (tailored by the stakeholders themselves in accordance with their own needs) and these have generally been found to be functional and highly satisfactory. They also tend to vary significantly in scope and extent of involvement.