Janet Saura: Mastering Global Labor Relations Strategies for Multinational Companies.
Multinational companies face unique challenges in managing labor relations across various jurisdictions, balancing local laws with global standards. Janet Saura, a recognized expert in labor and employment law, shares key strategies for navigating these complexities, offering practical insights on maintaining compliance, mitigating risks, and fostering positive employee relations worldwide.
What are key challenges multinational companies face when managing labor relations across multiple jurisdictions?
Global labor relations leaders face numerous challenges: differing economic conditions, balancing global standards with local adaptations, and addressing various cultural norms. Leaders must bridge these differences while maintaining consistency in corporate values and ensuring compliance with local laws, many of which may clash with home-country practices.
A good example of the compliance challenges facing multinational companies is a Fortune 500 manufacturer that faced significant issues when rolling out a global performance management system across 23 countries. The system, managed from the U.S., included peer feedback and performance ratings impacting compensation. While effective in North America and parts of Asia, it exposed legal vulnerabilities in the EU, particularly in Germany, where the company failed to involve works councils and overlooked General Data Protection Regulation (GDPR) compliance. The result: an injunction, legal fees, a six-month delay in compensation reviews, costly system modifications, and adverse media coverage, leading to EU-wide compliance audits.
How can international firms navigate the complexities of aligning local labor laws with their global HR compliance strategies?
I recommend these essential steps:
- Jurisdiction-Specific Legal Reviews: Conduct a legal review for each jurisdiction before implementing global HR systems and map HR processes against local legal requirements.
- Regional HR Adaptability: Never assume that successful HR practices in one region are legally viable elsewhere. Leverage a diverse network of global labor relations professionals as a resource.
- Works Council Consultations: Integrate works council consultations into project timelines for U.S.-led initiatives. Coordinate with Public Relations, Labor Relations, and Legal to ensure that workforce decisions and technology expansions align with consultation requirements.
- Early Involvement of Local Teams: Engage local HR and legal teams early in system design changes to pre-emptively address jurisdiction-specific compliance needs.
- Data Privacy Compliance: Consider cross-border data privacy implications from the outset to avoid costly mistakes.
What are best practices for elevating legal outcomes in global employee relations while ensuring consistency across different countries?
The key is having tools and processes in place to track and share important information across the employee relations team globally. In particular, I recommend the following best practices:
- Establish a process infrastructure akin to a legal case management system to objectively track minor events and data patterns that help identify and address issues early while anticipating future trends.
- Provide real-time analytics for trend identification; have a searchable database of anonymized events and an early warning system alerting for potential issues.
- Closely monitor global legislative and regulatory developments to understand emerging issues.
- Perform regular compliance audits and continuous refinement of response protocols based on new patterns and outcomes to reinforce the framework's effectiveness and adaptability.
- Foster a global knowledge-sharing culture through an internal platform, open discussions, and monthly roundtable sessions featuring internal and external thought leaders.
- Implement an integrated approach that combines robust governance frameworks, proactive risk management, repeatable processes, and agile response capabilities to ensure uniformity across operations.
- Develop individual and collective employee voice mechanisms to fully understand and respond to employee sentiment and ensure employee’s feel seen and heard.
Can you discuss how differences in union regulations around the world impact a company’s labor relations strategy?
Labor strategy in multinational companies is shaped by corporate culture, local regulations, and employee expectations. However, the strategy must be flexible to account for differing union regulations around the world.
The differences in regulations can be substantial. For example, EU countries with established works councils may require consultation and/or co-determination and structured engagement with employee representatives and trade unions. Asian markets vary widely: Japan features enterprise unions and “lifetime employment” by culture. China’s labor relations are controlled by the All-China Federation of Trade Unions. Companies in Africa often contend with multiple unions per workplace and government intervention, while Mexico’s recent labor reforms have empowered independent unions and enhanced collective bargaining rights.
Establishing clear global principles while allowing for tailored local approaches ensures that policies align with diverse regulatory landscapes. Effective frameworks should include:
- Detailed protocols for union engagement across jurisdictions;
- Robust compliance monitoring systems to pre-empt legal risks;
- Flexibility to accommodate various negotiation models and respond swiftly to labor actions within legal boundaries;
- Cross-border strategies to unify efforts and maintain stability; and
- Reputational risk management to safeguard the company’s image in multiple markets.
Together, these measures foster resilient and compliant labor relations strategies on a global scale.
What are common compliance pitfalls that multinational companies encounter when expanding into new international markets?
Common pitfalls include failure to comply with labor law regulations and employment contracts, mishandling of employee data, ignoring cultural differences, and misclassifying independent or platform workers as employees.
It is essential to have a labor relations expert at the table to provide guidance in advance of market entry. Without proper due diligence, a company may fail to comply with country-specific regulations regarding employment contracts, notice periods, and termination procedures.
For example, France, Italy, and Germany generally mandate that certain key aspects of employment contracts, particularly fixed term or probationary periods, be in writing. In Germany, labor unions and works councils play a major role in workplace decisions, especially concerning performance management, layoffs or restructuring. In October 2024, the UK’s labor government shared an Employee Rights Bill package that will have significant impacts to employers. For example, unfair dismissal protections will apply from day one of employment, subject to a statutory probationary period. This will require a significant change on how employers handle short-tenured employees and document the reasons for termination. Included in the changes, trade unions will have easier access to employees and to call for industrial action. Most of the UK provisions will take effect in 2026, giving time for companies to plan for compliance.
The EU is increasingly scrutinizing gig workers and contractors. For example, under new labor regulations like Spain’s "Rider Law," which establishes a presumption of employment for workers on digital delivery platforms, classifying them as employees rather than independent contractors, which entitles them to benefits like social security, health insurance and potential backpay claims. Employers must review the Rider Law and similar legislation to avoid misclassification claims and related tax liability.
Under the GDPR, companies must obtain consent from employees to process personal data and ensure proper data storage, processing, and transfer.
What emerging trends in labor and employment law should global HR teams be aware of to stay ahead of regulatory changes and maintain compliance?
I think the key trends for global HR teams are:
- The growing use of AI in recruitment, performance monitoring, and workplace decision-making has attracted significant regulatory scrutiny, with a focus on fairness, anti-discrimination, and data privacy. Compliance teams must stay informed about legislative developments such as the EU AI Act, which sets transparency and risk management standards, and the U.S. Algorithmic Accountability Act, aimed at preventing algorithmic biases.
- Regulations concerning human rights in supply chains are intensifying, creating reporting obligations and potential causes of action for failure to adequately disclose risks. Laws like Germany’s Supply Chain Due Diligence Act and the UK Modern Slavery Act mandate that companies ensure ethical labor practices not only within their own operations but throughout their supply chains.
- The classification and rights of gig and platform workers are changing fast. Legislation such as California’s AB 5 and the EU’s proposed platform work directive seek to clarify whether gig workers should be classified as independent contractors or employees, directly impacting their access to benefits, social protections, and collective bargaining rights.
- In the United States, Cabinet member selections by the President-elect suggest immigration enforcement will be a top priority in 2025. US employers should take action now to ensure compliance with immigration regulations, and that they are prepared by worksite enforcement activity and prepared to respond to government investigations or employee complaints regarding foreign workers. Conduct an internal I-9 audit, establish protocols for meeting with government officials, review how the company conducts labor markets tests when sponsoring foreign workers for permanent residence.
- While pay transparency laws may appear routine, labor relations and HR executives in the EU must understand the new requirements of the EU Pay Transparency Directive and take steps for compliance by June of 2026. The Directive will require major changes in how companies structure, communicate, and report on pay. Employers with 250+ employees also need to be mindful of changes to UK employment laws, which will require annual action plans to address gender pay disparities.
- An increased emphasis on employee mental health is transforming workplace requirements. The EU has broadened workplace health and safety rules to encompass mental health, pushing employers to develop programs that address psychological safety. Australia requires companies to prioritize mental well-being, reflecting the global trend toward more comprehensive health and safety obligations.
Executive Bio - Janet Saura, Legal and HR Executive
Janet is a globally recognized leader in employment and labor law, known for driving high-performance teams across Legal, Human Resources, and Compliance functions in the U.S. and abroad. She formerly led Amazon’s Employee and Labor Relations team. As Amazon's first Vice President of Employee and Labor Relations, she spearheaded the company’s approach to employee relations in North America, while also building constructive partnerships with global trade unions in Europe and abroad, fostering a thriving work environment and improving employee relations decisions based on data and analytics.
Janet strategically transformed Amazon’s Employee and Labor Relations function with a multi-disciplinary approach, incorporating experts from various fields to deliver innovative, customer-centric solutions for 1.4 million employees and third-party contractors across Operations, Corporate and Consumer functions. Her focus on mission-driven talent development, proactive risk management, and early identification of challenges helped mitigate negative impacts on business performance, reputation, and employee satisfaction,
In her previous roles as Deputy General Counsel at Lowe's, Janet led Employment, Labor, Risk Management, and Compliance, where she created a profit center within the Legal Department and developed programs that minimized employment disputes and general liability lawsuits. Janet has also served as Vice President of Employment and Labor at Office Depot, and in senior legal roles at Republic Industries and Kmart, where she played a key role in labor relations and corporate restructuring.
Janet holds a Juris Doctor from the University of Detroit Law School, where she was Editor-in-Chief of the Michigan Business Law Journal. An accomplished speaker, she regularly presents on employment law, risk management, and emerging liability theories, and is committed to mentoring minority HR and legal professionals. She has served on the boards of Masters, the Bechler Museum of Art and the Morikami Museum, and is an active member of World 50.