Considering the wide spectrum of meanings of the expression 'worker participation', the article focuses on the differences between some of the most significant experiences of employee involvement, starting with the 'benchmark model', the German co-determination system. The analysis of the German system, its origins, characteristics and rationale, leads on to a critical evaluation of the progressive movements from this 'strong' and mandatory form of worker participation: from the 'weak(er)' and negotiable European model to the simultaneous use of managerial and financial participation in a recent Italian Act, up to employee participation in the firm's profits (and risks), associated with a loss of rights, in the recent 'shares for rights' scheme in the UK.A comparative overview of these schemes weads to a final reflection on the difference between 'uses' and 'misuses' of worker participation, based on the ideals underlying the various forms of employee involvement.
International Journal of Comparative Labour Law and Industrial Relations