There are a lot of similarities between US and UK employment law. But while the guiding principles which are followed may be the same or at least very similar, there are significant differences in terms of the actual laws which are applied. These differences can create particular challenges for companies that have employees in both countries, especially where termination issues are concerned.
Some of the differences this webinar will discuss include whether and when an employment agreement is needed and/or desirable; whether and when cause to terminate is needed; whether and when notice to terminate is required; and the nature and existence of protected groups in the two jurisdictions. And that’s not all. Other key topics featured will include:
- The legal status of bullying in the US v the UK;
- Differences in the litigation systems and how these differences inform business decisions;
- How to obtain an enforceable release in UK v US;
- Non-competes and other forms of business protection.
This program will be an engaging dialogue between two lawyers who became friends exploring what we have in common and where we differ in terms of our employment laws on opposite sides of the pond.
Jonathan A. Segal
Jonathan A. Segal is a partner at Duane Morris LLP in the employment, labor, benefits and immigration practice group. He is also the managing principal of the Duane Morris Institute.His practice focuses on preventive counseling, training, and a host of other issues.
Segal has served intermittently as a consultant to the Federal Judicial Center in Washington, D.C., providing training on employment issues to federal judges around the country. In this capacity, he has been a featured speaker at conferences for Chief United States District Judges.
He also has provided training on harassment on behalf of the EEOC as well as providing training on diversity to members of the United States intelligence agencies. Segal is also frequently a featured speaker at national, state and local human resource, business and legal conferences.
Jon Heuvel is a partner in the London office of Penningtons Manches LLP, a top 100 UK law firm headquartered in London, England. He specializes in all aspects of employment law including complex employment tribunal and High Court proceedings for employers and employees across a range of industries and sectors, with a particular focus on hotels and restaurants, regulatory bodies, educational establishments, recruitment and temporary workers.
In addition to his domestic practice, Mr. Heuvel also specializes in the international aspects of employment, from advising start-ups in the UK to dealing with cross-border issues for multinational clients. Jon is Global Chair of the Employment Practice Group for Multilaw, and is the general editor (and co-author) of the Multilaw publication How To Hire and Fire: A Global Guide which is currently in its fifth edition (2015).
Mr. Heuvel is a regular author and speaker on a range of employment issues and has appeared on TV and national radio as an expert commentator.