The full-year-round Danish employee is guaranteed 3 weeks of annual vacation, but not necessarily in one consecutive stretch. The law provides that at least 12 days; i.e., 2 weeks of vacation must be given at one time, within the period from May 2 to September 30. The remaining 6 days, or 1 week, must also be given at one time, but may be in the other months of the year.*6

It is quite common for manufacturing plants and some other types of establishments in Denmark to shut down entirely for a few weeks during the May-September period, while all employees take their vacations simultaneously. The governmental authorities are empowered to require a firm which adopts this practice to follow a rotation schedule specified in advance for several years at a time—e.g., to shut down during the first 3 weeks of August one year, the last 3 weeks of July the next year, and so forth. Before prescribing such a rotation schedule for a firm, the authorities must consult with the Danish Employers' Federation, the Danish Federation of Trade Unions, and any other organizations with members affected by the scheduling. This central control over the timing of annual shutdowns not only may assure workers of a more satisfactorily balanced distribution of vacation periods over a number of years, but can also help to reduce peak periods of congestion at beaches and other vacation

areas.

4. Finland

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The Finnish vacation law, as extensively amended in 1960, is similar in important respects to the Danish law. Its coverage is broad, with few exclusions. The basic annual paid vacation, for full-year-round workers, is 3 weeks (18 days). The worker is entitled to 11⁄2 days' vacation for each month worked. However, once he has been in the continuous service of one employer for 10 years, the law requires that he receive 2 days' vacation credit per month-or 4 weeks (24 days) for a full year's service. Finnish law thus gives the long-service worker an increase in vacation time such as is usually provided by collective bargaining agreements in the United States.

Finland, unlike Denmark, does not completely adhere to a rule of pro rata entitlement to vacation in accordance with time worked. An employee receives no credit toward an annual vacation for any months in which he was not employed at least 16 days.48 The parttime worker and the worker who changes employers during the course of the year are protected, however. A part-time worker who normally is employed less than 16 days a month by one employer, but who works a total of 16 days or more for the employer during the year, must be paid-in lieu of an annual vacation-6 percent of his earnings for the year. Likewise, an employee who resigns or is discharged must be paid, upon termination of his employment, a sum equal to his accumulated vacation pay credit for the year-i.e., 11⁄2 days' pay for

There is some flexibility in the law's provision regarding vacation scheduling. Agricultural workers, for example, are guaranteed only 1 week of their 3 weeks' annual vacation during the warm months, MaySeptember. And, in any other industry of a seasonal nature or with special characteristics that make it difficult to concentrate vacations in the May-September period, the director of factory and labor inspection may grant an exemption from the usual scheduling requirements. He may do so, however, only after consultation with the trade unions and organizations of employers in the industry.

The main group explicitly excluded is merchant seamen, who are covered by a separate vacation law. The law counts toward these 16 days not only days actually at work, but other days such as national holidays and days on which the employee was temporarily absent on account of illness.

each month in which he had been employed 16 days or more, and 6 percent of his earnings for those months in which he had less than 16 days' employment.49

The Finnish law attempts to discourage anyone's working during his vacation. It authorizes the employer to deduct from vacation pay an amount equal to the earnings which he learns an employee is receiving from any work-including even self-employment during the time when he is supposed to be taking his annual vacation.

As in Denmark, the law in Finland prescribes May 2 through September 30 as the "holiday season." It calls, as a general rule, for the entire 3 weeks' vacation to be taken at one time during this season-but does allow exceptions."

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As is frequently the case in European labor legislation, the Finnish vacation law makes specific reference to collective bargaining as an alternative or supplement to rules imposed by legislation. It states that "Employers' and workers' organizations whose sphere of activity comprises the entire country shall be entitled to enter into a collective agreement stipulating that holiday remuneration *** shall be calculated in a manner other than that prescribed in this Act." This emphasis on employer associations and unions "whose sphere of activity comprises the entire country" reflects the much greater centralization of collective bargaining and reliance upon national industrywide negotiations in Finland, by comparison with the United States. 5. France

The basic French vacation law, as amended in 1956, provides a 3week (18 day) annual vacation. The worker accumulates vacation credit of 11⁄2 days per month worked. For very long-service workers, somewhat more liberal minimum periods of vacation are required by law. After 20 years of employment, the worker must receive 20 days of paid vacation annually; after 25 years 22 days; and after 30 years 24 days (i.e., 4 weeks).

In fact, however, the 4-week vacation rather than the 3-week period legally required-is now the rule in France. The French labor movement in recent years has campaigned to have the vacation law amended so as to make 4 weeks the required minimum. Employers have resisted this legislative effort, but have apparently been less resistant to liberalizing vacations by negotiations with unions or unilaterally. A major breakthrough came at the end of 1962, when the Renault works-one of France's largest manufacturing operations-agreed to establish a 4-week vacation period, through collective bargaining. Other concerns followed, or were successfully pressured by unions, to follow, in the next few years. In August 1964, the National Council of French Employers recommended that the annual vacation be extended to 4 weeks through union-management negotiations. Thus it has recently been estimated that nearly 13 million French workers, 90 percent, have obtained the 4-week vacation through collective bargaining-and, in some cases, through brief strikes.

The annual month-long shutdown-particularly in manufacturing, but also in other industries-is a feature of the French economy which

Unless the worker had at least 16 days of employment before his discharge or resignation, the employer owes him no vacation pay.

50 Annual vacations, for example, may be scheduled outside the May-September months for workers in agriculture or other seasonal industries. And, "if it is necessary in order to prevent an interruption of the work or if the worker so consents," the annual vacation may be split into two or more periods, provided that at east 9 days (12 weeks) vacation are taken at one time;

also reflects the tendency to extend vacations beyond 3 weeks. It is common in France to close manufacturing plants and certain other establishments for the entire month of August, which allows all employees to take their vacations simultaneously.

The French worker's rate of pay while on vacation is just a little above his usual rate. The vacation law specifies that a full-yearround worker, taking a 3-week vacation, shall receive a sum equal to one-sixteenth of his total wages in the qualifying period, which is ordinarily the 12-month period ending on May 31. One-sixteenth of a year's wages provides compensation, for a 3-week vacation period, slightly in excess of the worker's regular earnings for 3 weeks of work. 6. Western Germany (Federal Republic of Germany)

In Western Germany, until a few years ago, legally required annual vacations were provided by statutes in the various Länder (provinces or subdivisions of the state) rather than by national legislation. These Länder statutes were replaced in January 1963 by a national law-the Federal Leave Act.

The scope of this vacation law is very comprehensive, covering "any wage or salary earner" in the Federal Republic. The required minimum annual paid vacation, for full-year-round workers, is set at 15 days (21⁄22 weeks). Upon the worker's reaching the age of 35, however, he becomes entitled to 18 days (3 weeks) of vacation.51

As is common in Europe, the German law prorates entitlement to vacation time on the basis of months of work. For each "full" month of employment, the worker acquires a credit for one-twelfth of the minimum annual vacation, or 14 days. If he resigns or is discharged from a job, he must be paid compensation for his accumulated vacation time credit.52

Although the German vacation law states that the annual vacation is to be taken in one continuous period, it waives this rule whenever "urgent operating requirements or personal considerations on the worker's part" necessitate the vacation being taken in two or more installments. The law also forbids a worker from engaging "in any gainful employment" during his annual vacation, but is silent on the subject of means of enforcing this prohibition.

The right of unions and employers to negotiate annual vacation plans is explicity recognized in the German law. The only qualification is that such collectively bargained plans must give the worker at least 15 days annual vacation and otherwise be no less advantageous to him than the conditions prescribed by the vacation law.

Collective bargaining has, indeed, helped to bring most German workers' vacations beyond the legal minimum. A study made by the West German labor federation (the DGB); and published in

The 15-day minimum, in fact, applies only to workers between the ages of 18 and 35. The worker under 18 is required to receive 24 days (4 weeks) of vacation. Western Germany, like other European nations bas special vacation legislation for young workers, based apparently on the assumption that the adolescent Joy or girl needs a longer annual holiday from work than the adult employee.

Special German legislation also allows 3 to 6 additional days of vacation annually to disabled workers and to those classified as 'victims of National Socialism"-i.e., the Hitler regime.

A prorata rule is not strictly followed, however. If a worker has been employed by a firm for at least 1year, and his employment terminates in the second half of the calendar year, he is entitled to compensation be his full 15-day annual vacation, even though he may have also had a vacation in the preceding calendar year. He qualifies for the full annual vacation-even if his employment should terminate on July 1 of that year.

A provision of the German law exempts the employer under some circumstances from his obligation to ompensate a departing worker for his accumulated vacation credit. The worker is entitled to no compensation if he is dismissed through his own fault for any reason justifying his dismissal without notice,' if he quits his job "prematurely without sufficient reason," and is thus "guilty of a serious breach of the yalty required of him under the employment relationship."

April 1965, reported that 70 percent of the manual workers surveyed and more than 40 percent of the white-collar workers were entitled to 21 days (32 weeks) of annual vacation; that 27 percent of the manual and 40 percent of the white-collar workers had 22 to 24 days vacation; and that 3 percent of the manual and 7 percent of the whitecollar workers had more than 24 days' vacation (4 weeks). As of May 1966, 7 million wage earners have secured 20 to 24 days of vacation annually through collective bargaining. A substantial gap has thus opened up between the vacation requirements laid down by law in Western Germany and the vacation practices generally prevailing. Recently, the DGB has been demanding even further liberalization of the vacation benefit. Its announced goal is a 5-week annual vacation for all workers 35 to 50 years old, and a 6-week vacation for those over 50.

7. Great Britain

In contrast to each of the countries discussed so far, Great Britain has no general national vacation law. For many British industries, however, "wages councils" have been established by law, and these councils are empowered to set minimum levels of wages and certain fringe benefits that are binding upon all employers. Each wages council is composed of representatives of employers and of workers in the industry--although almost all the industries with such councils are only weakly unionized-and the council's decisions and orders are, to a large degree, reached through a process of bargaining between the two groups of its members. The Wages Council Act authorizes. each council to establish a vacation benefit for its industry, and the current practice of the councils is to require 2 weeks of annual paid vacation. Council orders generally stipulate that the vacation must be given during the months of April through September. They also usually protect the worker changing jobs by requiring that, upon resignation or discharge, he be paid for the time he has accrued toward his vacation for the year.

Though required by no law, annual vacations are also the rule in British industries and trades for which no wages council has been established. The large majority of union members are under collectively bargained vacation plans. So far, however, the British labor movement has been less interested than the American in winning progressively lengthened vacation periods. The usual vacation negotiated in unionized British industries is only 2 weeks, and no major drive has been launched to raise the general level up to the Continental European standard of 3 weeks or more.

Collective-bargaining agreements in Britain normally stipulate the period of the year when vacations are to be taken. They also usually give the worker who was not employed continuously throughout the year either a shorter period of annual vacation, or the full period but at a rate of pay less than his regular rate. Many of the agreements are multiemployer, or industrywide. Some major agreements-particularly those in the building industry-establish a vacation fund into which employers make weekly payments in accordance with the size of their payrolls, and from which the workers are paid when they go on vacation.

8. Ireland (Eire)

The general Irish law governing public holidays and annual vacations was updated in 1961. It covers the large majority of workers

in the private sector of the economy, with the major exception of such groups as agricultural workers (to whom a special law applies) and merchant seamen.

The minimal annual vacation required by the Irish law is 2 weeks. In contrast to the prevailing practice in the other countries surveyed, a worker does not need to be employed throughout the year to qualify for the full vacation. If he works 1,600 hours during the yearwhich is the equivalent of forty 5-day weeks, or about thirty-six 5%-day weeks-he is entitled to 2 weeks of paid vacation.

The Irish rule for prorating vacation credit to a worker who resigns or is discharged during a year also is based upon number of hours worked. Upon termination of his employment, the worker must be paid one-sixth of his usual weekly earnings for each month during the current year in which he was employed at least 135 hours. Thus an employee, for example, who had worked 6 such months would receive 1 week's vacation pay upon leaving his job.

A worker is forbidden by the Irish law to take any paid employment during the time of his annual vacation. Violation of this prohibition is even made a criminal offense, for which the Minister of Industry and Commerce may initiate a prosecution. The employer must give the full 2 weeks of annual vacation in one consecutive period, but exceptions are allowed in certain cases.

Full-year-round servants are also guaranteed 2 weeks of annual paid vacation under specific provisions of the Irish law. While on vacation, a domestic servant who normally lives in his employer's house and receives board and room, must be paid not only his regular cash wages but also a specified extra sum to help defray his living costs while away from his residence.

9. Italy

The Italian Constitution provides that all workers are entitled to receive a paid annual vacation. Commonly, the vacation terms for each industry are developed through collective bargaining or discussions between employer and worker representatives.

A fairly typical example of the Italian vacation benefit structure is provided by the metal trades industry. As of 1964, blue-collar workers in this industry were entitled to a 12-day (2 weeks) annual vacation after 1 year of service with an employer. After 5 years' service, the annual vacation rose to 14 days, and after 20 years' servive, to 18 days (3 weeks). However, foremen and certain other workers with special responsibilities were entitled to 15 days' annual vacation after 1 year, 20 days after 3 years, 25 days after 11 years, and 29 days (approximately 5 weeks) after 19 years. For salaried workers in the Italian metal trades industry, vacation terms were more favorable than for foremen, as well as for blue-collar workers generally. Salaried workers received 15 days' annual vacation after 1 year, 20 days after 2 years, 25 days after 10 years, and 30 days (5 weeks) after 18 years.

As shown by this example, Italy has adhered much more than other countries surveyed to the principle of a graduated vacation plan, in which the worker's annual vacation becomes longer as the length of his period of continuous service with one employer grows. Thus, Italy is exceptional among European countries, in that an Italian worker does usually suffer some real or potential loss of vacation benefits when he changes from one employer to another. Italy is also