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the UK and their approach towards collective bargaining is strictly negative.

In Germany on the other hand, has a highly regulated industrial relations system which, in theory at least, provides considerable constraints on the employee relations practices of MNEs. As a result McDonald had to thing the statutory bindings and regulations constraints regarding approaches to collective bargaining.

Codetermination and collective bargaining rights
The McDonald's in case of both Germany and UK has considered these rights as a different approach. German workers enjoy a dual system of representation, collective bargaining rights and co-determination rights through the institution of the works council and the supervisory board. Together with codetermination and collective bargaining rights, these legally enforceable and constituted rights appear to provide German employees with significant power resources compared to UK employees.

So McDonald's must have considered the issues of the both rights of the employees before establishing their bargaining approach.

Size of Franchise:
The McDonald's corporation established itself in the UK in 1974, in Germany in 1971. The corporation currently has well over 800 stores in Germany amongst approximately 65% outlets are franchisee where in there are a similar number of stores in the UK with some 20% franchisee with approximately 45,000 employees in each country.

In this case being a fast-food market leader in both countries McDonald's have considered the size of franchise. The franchise aspect influence collective bargaining issues through local entity and regulations involvement. So size of franchise is also a factor that may have been considered.

Unioin Membership:
McDonald also may have considered Union membership. German unions are arguably better organized and have retained a position of relative strength compared to those in the UK. Union membership at McDonald's in Germany and in the German fast-food industry is very small at around 5 per cent. However, these low percentages are still higher than the percentage of union membership at McDonald's and the fast-food industry in the UK.

So this issue is an important consideration in establishing Macdonald's collective bargaining approach.

The increasingly anti-union climate:
The increasingly anti-union climate in the 80s and early 90s has encouraged Macdonald's in the UK to withhold or withdraw union recognition, and discouraged employees from joining unions and posed difficulties for recruitment. In Germany, union membership remains at around 5 per cent at McDonald's. The findings suggest that it is only where a works council has been established where still there is better union practice than the UK.

So this consideration may have been involved in planning McDonald's approach towards collective bargaining.

Characteristics of Workforce and Nature of the industry:
McDonald's have considered both the factors in case of both countries to design its approach towards collective bargaining.

Redundancy and employee apathy:
Redundancy and employee apathy amongst part-time, temporary, foreign or young workers undoubtedly play an important role in the low or non-existent levels of union membership. So this factor may have been considered in both UK and Germany.