IJTTHL1/2025

modification to the governance of multinational groups should be linked to the protection of the rights of all workers, rather than to any actions arising from dramatic events harming life and health. Although the risk of being belied remains (see Moreau 2017, 792 et seq.), any capillary exercise of actions before the European courts by workers from States providing lower protection of pay and employment conditions is not very likely, which would lay the foundations for rebalancing remuneration and vocational opportunities. Despite being an additional reputational threat, the legislation on the parent company’s control underestimates the organizational and financial difficulties generated by moving jurisdiction from the States where activities are performed to those where the central corporate structures are based. Expenses seem disproportional to opportunities for the usual disputes, as the financial amounts in question can hardly be consistent with court actions heard thousands of miles away from the places where the related misconducts were perpetrated. Irrespective of reference being made to the parent company’s obligation of diligent control and consistent direction, it is of little consequence to emphasize the binding nature of the indications given by the International Labour Organization or by the sources of international law based on conventions, if their poor effectiveness remains unprejudiced (see Sobczak 2012, 139 et seq.). Albeit wishing to be operating globally, trade unions seem unable to go to court in continents other than the ones where they have their continuing operations, with costs and difficulties that are disproportional to many court action goals. Court actions may trigger realistic changes only if they are capillary. II. THE FRENCH AND GERMAN LEGISLATION The French and German regulatory model aims at centralizing competent jurisdiction in the two Countries for any disputes involving multinational groups whose parent companies are based in the Countries, imposing an obligation of diligent control on the conducts of all those engaged in production, which is decentralized globally. Had the reform in those two legal systems been more drastic, the attempts would have had no more room, as European Countries do not have the political strength and the institutional belief to venture on paths that are utterly disliked by large corporations. Conversely, the improvement in workers’ occupational conditions and the recognition of higher effectiveness to the criteria coming from international law go along with progressive attraction 72

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