노동조합 전임자의 임금제도 비교연구: 독일, 영국, 미국 및 일본의 Time-off(근로시간면제)제도를 중심으로

The study examined the overseas cases on full-time union officer and wage payment and compared the systems with full-time union officer system and wage payment in Germany, UK, Japan and USA. Regarding the collective bargaining, the value and attitude of labor-management autonomy should de facto be applied to the practices with minimizing the involvement of the government. It is widely known that the UK and USA has a history of voluntarism with regard to the collective regulation of employment. This places the emphasis on trade unions and employers to agree relevant procedures and practices independent of regulation from the State. Most of the German industrial relationship is determined by the dynamics among works councils, trade unions, and employers. In Japan, there have been attempts by the government to abolish this practice through amendments to the labor union law after the war, this system still continues today together with and due to the labor union form based on each business. The wage payment to full-time union officer and implementation of the Time-Off system is an issue that the management and the labor have to solve gradually.