The National Implementation of Employee Participation in the Administrative Board of the SE in the One-tier Model – A Legal Comparison on the Basis of Germany, Austria, Sweden, and France –

The adoption of the SE and the implementation of the employee participation in the member states took place against the background of their national tradition of employee participation. The statutory provisions for the SE thus take on specific characteristics that already applied to company co-determination in the public limited-liability company. Using the examples Germany, Austria, Sweden and France, the conflicts with the Council Regulation (EC) No 2157/2001 (SE-Regulation) and the Directive 2001/86 (SE-Directive) will be identified that arise under the continuation of specific national provisions and the implementation of the SE in the one-tier model.