CASE Network Studies and Analyses 472 - Employee financial participation in businesses: Is it worth discussing?

Materials published here have a working paper character. They can be subject to further
publication. The views and opinions expressed here reflect the author(s) point of view and are
not necessarily shared by CASE Network.
Keywords: Financial participation, industrial democracy, employee saving plans, profit
sharing, employee share ownership, employee share ownership plans, legal
regulations, incentives, European countries, USA
JEL Codes: A13, D02, G32, J54,M52, P12
© CASE – Center for Social and Economic Research, Warsaw, 2014
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CASE Network Studies & Analyses No. 472 –Employee financial participation in business
Contents
Contents ....................................................................................................................... 1
Abstract ........................................................................................................................ 3
1. Introduction .............................................................................................................. 4
2. Financial participation vs. workers’ participation in management ..................... 5
2.1 Non-financial participation .................................................................................... 6
2.2 Financial participation ........................................................................................... 8
2.3 Types of financial participation ............................................................................ 10
2.4 Employee Profit-sharing ....................................................................................... 11
2.5 Employee Share Ownership ................................................................................. 11
3. Financial participation: Experiences and achievements ..................................... 13
3.1 A little history ......................................................................................................... 13
3.2 The development of financial participation after World War II .......................... 15
3.3 Examples of national solutions ............................................................................ 15
3.4 The scale and impact of financial participation in the United States
and Europe .................................................................................................................... 22
4. Activities of the European Community to foster employee financial
participation................................................................................................................. 25
4.1 EU initiatives in the 1990s and at the turn of the century ................................. 25
4.2 Proposals for long-term measures in the European Union .............................. 27
5. Questions for future research, in particular in Poland ........................................ 28
6. Conclusion................................................................................................................ 30
Bibliography ................................................................................................................. 22

Barbara Błaszczyk is a Professor of Economics and a member of the Scientific Board
of the Institute of Economy of the Polish Academy of Sciences (PAN), for whom she has
worked in different positions since 1982. She is a co-founder of CASE - Center for Social
and Economic Research in Warsaw (1991), a think tank devoted to the support
of the transition process. President of the CASE Foundation in 1991 – 2004, since 2006
Deputy Chairwoman of the Council of the Foundation. In 2004 – 2012 she worked as professor
at the Nowy Sącz School of Business - National Louis University (WSBNLU). She graduated
from the University of Warsaw in 1970 (MA in Economics). In 1975 she received her PhD
at the Institute of Organization and Management of the Polish Academy of Sciences
(PAN). She was qualified as an assistant professor in 1989 by the Department of Sociology
and Economy of the University of Lodz. In 1996 she received an academic title
of Professor of Economics. Between 1989-1996 she was an advisor to the Polish government
and to the Polish Parliament. Between 1991-1996 she was the deputy Chairwoman
of the Council of Ownership Changes at the Prime Minister’s Office. She has participated
in and co-ordinated numerous domestic and international research projects, including
comparative studies on privatization and restructuring processes of the enterprises
in Central and Eastern European Countries. Her main fields of research interest
are privatization, corporate governance, deregulation of the state sector, and generally
systemic changes in countries in transition and in the past, as well as the employee share
ownership and industrial democracy. Her additional field of interest during the last few
years has been the process of enlargement of the European Union and the economic
and social reforms in the countries of EU, especially the implementation of the Lisbon Strategy
in old and new accession countries. She is an author, co-author and editor of approximately
150 publications.

Abstract
This paper is an overview of the achievements in the area of employee financial
participation (EFP) during the last fifty years. It addresses the question of the extent
to which EFP is relevant in today’s world. EFP is distinguished from participation in management
(industrial democracy), and the various types of EFP are discussed. The major arguments
for EFP are presented and discussed critically. The evolution of major forms of EFP, the scale
of their operation in several advanced economies, and the legal and tax incentives for EFP
are described. The efforts of European Union bodies to popularise this idea
in all member countries are illustrated. Showing that EFP has become a broadly recognised
principle of modern management in thousands of enterprises, we consider opportunities
for disseminating these solutions on a wider scale, in particular in Poland.
Finally, a number of directions for further research on financial participation are considered.

1. Introduction1
During the systemic transformation of the Polish economy in the late 980s
and early 990s, a keen interest arose in various forms of participation of employees in the profits
and ownership of the enterprises employing them. (For convenience we can refer
to these various forms of participation as employee ownership.) This was linked to ongoing
discussions about how to privatize the country’s state-owned companies on a large scale.
The author of this paper took part in these discussions, trying to popularize employee share
ownership, which was well-known in Western countries. In our view then, this kind
of institution could be used to build a new business model for certain groups
of enterprises created as a result of privatization . At that time, however, neither the Polish
intellectual elite nor the working class was prepared for, or understood, the long-term
advantagesof the forms of employee ownership implemented in some companies in the most
developed Western countries. Even in these countries, however, these forms were not very
common at that time. They were mainly perceived as marginal and, thus, were not taken
into account as an option to be widely disseminated in the market economy (as opposed
to the fairly widespread and partly mandatory use of employee participation
in the management of companies in Europe). Nevertheless, the idea
of employee financial participation (including profit sharing
and employee shareholding), which since then has gone through various ups
and downs, has survived and evolved into new forms, gaining ever wider acceptance
and a firm legal grounding in some of the Western European countries and the United States.
An international and European institutionalized movement has also been established to promote
these solutions .
In view of events in recent years that have revived certain doubts about the basic
principles and durability of the traditional forms of capitalism, we again notice a growing
interest in employee financial participation, including widespread employee ownership.
We observe its growing popularity in Europe and a strong commitment
The author would like to thank U. żrzelońska, P. Kozarzewski, K. Madej, L. Pietrewicz,, R. Woodward
and A. Zabkowicz for valuable inputs, comments and discussion of the first version of this paper and
for editorial help. The author presented the idea of employee share ownership as one of the possible
options for privatization in Poland (Błaszczyk, 1993).
The author presented the idea of employee share ownership as one of the possible options
for privatization in Poland (Błaszczyk, 1993).
It is, however, important to note that beginning in 956 Poland had seen a current of thought
supporting the participation of employee councils in the management of state-owned enterprises.
In 98 , this idea began to be implemented in Poland, and gained force in 989, when the collapse
of the communist system made the councils in the enterprises genuinely autonomous.
In Europe, the European Federation of Employee Share Ownership (with headquarters in Brussels)
and in the USA, the National Center for Employee Ownership, located in Oakland, California.

of the źuropean Commission (źC) to popularize it. Much empirical material has been
gathered, new instruments have been designed, and their implementation
is being advocated by the most important bodies within the EU. This article is intended, first,
to remind us about the relevant legacies of the past and, second, to present new concepts
of financial participation, examining the opportunities for their implementation and the conditions
necessary for this to be successful, and providing a critical evaluation of their relevance
in Poland and elsewhere.
The first part of this article starts by making a clear distinction between employee
financial participation and employee participation in management (non-financial
participation). After presenting the theoretical justification for financial participation, addressing
its main values and objectives, it outlines the classical concepts and types of employee financial
participation, The second part of the paper briefly reports on the evolution of the most important
forms of financial participation, such as the American and English Employee Stock
Ownership Programs (źSOPs), żerman Kapitalbeteiligung or Żrench participation, and includes
a brief discussion of the legal and financial instruments in the business environment fostering
their implementation. This part also includes an outline of the extent to which these solutions
are being used in the most advanced countries and a short summary of conclusions drawn
from the latter’s experiences. The third part of this report discusses the efforts to disseminate
financial participation, supported by the EU and presented in subsequent reports
on the subject prepared for the European Parliament, the EC and its bodies. The final part
discusses the potential relevance of these solutions for the emerging new economic order.
It also considers opportunities for disseminating these solutions on a wider scale, in particular
in Poland. In the conclusion, a number of new questions for further research
on financial participation are considered.
2. Financial participation vs. workers’ participation
in management
Financial participation5 is the participation of employees in the profits and / or assets
of the company. It refers to financial benefits, property and rights resulting from this fact.
By contrast, workers’ participation in management (non-financial participation)6 means
employee representation in business management (on various levels) and refers
to employees as social partners. Both forms of employee participation
have very different ideological roots and different practical justifications,
which does not prevent them from sometimes occurring simultaneously in one company.
5
5 German term: “materielle Beteiligung der Arbeitnehmer”.
6 żerman term: “Mitbestimmung” (źnglish: “codetermination”).

6
2.1 Non-financial participation
The rights of employees to take part in the decision-making process (sometimes referred
to as co-management) are derived solely from a labor-based legitimization;
that is, they result from employees’ share in work, not in property . Ideologically, these rights
are derived from the non-financial needs of the workers, such as their need for involvement
and self-realization, as well as to a broadly understood need for work “empowerment”.
But advocates of these arrangements make other arguments on the basis of economic
efficiency as well: employees engaged in issues concerning the enterprise will be able
to find new motivations to improve work efficiency and innovation, making it possible
for their full potential to be used for the benefit of the company. By enhancing the position
of employees in the company’s management system, the participation schemes may
also significantly improve the material well-being of personnel. In most countries
of continental Europe, non-financial participation is regulated by law (at least since the 980s)
and operates in the majority of large companies8. Institutions supporting
non-financial participation have been created at different levels of business
management and have taken different forms in different countries (including,
in particular, direct and indirect, or “representative”, participation). The most common
and most popular form of indirect participation involves employee councils,
which are usually elected at the department level throughout the entire company.
Their primary role is to serve as information and consultation bodies and, in some areas,
to enable participation in the decision-making process. In some countries, where trade unions
are not able to operate at the shopfloor level, employee councils can take their place,
and in others, these two representative institutions co-exist within the company9.
Another important form of indirect participation is co-management at the level of entire
company, which involves the participation of employees’ representatives
in the supervisory boards of public limited companies. Since 00 , in addition
to national legislation regulating this type of co-management, European companies
are subject to an amended EU-Joint Stock Company Statute, which includes the participation
of employees’ representatives in the governing bodies of such companies 0.
In its most extreme form the labor-based argumentation was encompassed in the concept
of the classic self-governing enterprise (owned collectively by the employees). The analysis
of this form can be found in Blaszczyk ( 990).
8 Details can be found in Blaszczyk (1988) and more up-to-date information can be found in Lowitzsch
( 0 ).
9 This does not change the fact that in some countries trade unions were vehicles for the introduction
of non-financial participation. A detailed description of employee councils’ rights in Western European
countries can be found in Blaszczyk ( 988, pp. 0 - ).
0 This affects multinational corporations operating in several EU countries.

It seems that, in Europe, this type of non-financial participation at the enterprise level
has already reached its maximum possibilities. The most far-reaching forms have not always
proven to be the most beneficial for the business or for the employees themselves.
For example, the supervisory council “parity co-management” set out in the 95 Act
(the so-called “Montanmitbestimmung” Act), which was compulsory for enterprises
employing more than 1,000 workers in the coal and steel industry in the Żederal Republic
of żermany (ŻRż), led to a mass exodus of businesses wanting to avoid this law.
These businesses used various strategies, such as redeployment of production, division
of the companies into smaller units and / or dismissal of employees . Similarly, the less radical
Co-management Act of 9 6, mandatory in all German joint stock companies
employing more than ,000 people, led to a similar business
“escape strategy”, which began during the negotiations regarding
the legislation in the first half of the 9 0s and took on such forms as changing
the legal form of companies, reducing the number of employees, changing the companies’
by-laws to reduce supervisory council authority, forming internal committees
and advisory teams to the supervisory board composed solely of shareholder
representatives, etc.). According to some critics of the most far-reaching forms
of employee participation in management, these were merely healthy attempts
to escape from wrong-headed requirements that would have limited their ability
to make rational management decisions. Analyses of the German economy
of the late 980s have shown that companies with far-reaching
employee rights to co-manage at the supervisory board level avoided risky
decisions and developed strategies focused mainly on maintaining existing jobs
and not attempting deep restructuring (Benelli 1983, ŻitzRoy & Kraft, 1987).
Having said this, the author of this paper does not intend to question the legitimate
arguments for employee representation at different levels of management or to deny the benefits
of the different forms of workplace democracy, in particular those ensuring better
communication in the workplace. However, some forms of employee representation
at the highest levels of management have become highly politicized over time
and, in most cases, have served the interests of trade unions’ leaders and majority
shareholders, rather than benefitting the entire company. However, assessing different forms
This refers to an equal number of employee representatives and shareholder representatives
in the Supervisory Council, and the human resources director selected by the employees (Blaszczyk,
988, pp. 8 -8 ).
There were 00 large companies employing one million people subject to this law
when it was approved in 95 . In 980 the group consisted of only 5 companies employing half
a million people.
Under the terms of this act, the shareholders’ representation on the Supervisory Board
has the majority thanks to the additional voice of the Board’s chairman (representing
the shareholders).

of employee participation in management is not the aim of this study, so we will not continue
this discussion further.
It should be noted that, in addition to the legally required forms of participation
in management, many companies (especially smaller ones) voluntarily offer additional forms
of non-financial participation as a result of the particular needs of the companies.
This type of participation often arises in connection with the introduction of financial
participation and the need to attract employees and involve
them in the process. An interesting, though less popularized, form of non-financial
participation is the so-called direct workplace participation, which consists
in creating autonomous working groups, quality circles and other similar institutions
that enable employees to manifest their initiative and creativity in shaping both the work
environment and work process. This form was introduced particularly in the Scandinavian
countries (Rudolf 1982), but despite promising results, did not spread on a wider, more
general scale in Europe. It seems that this type of non-financial participation
deserves special attention in the current situation, taking into account both the needs
of today’s businesses (the ability to introduce rapid changes and innovations),
as well as the characteristics of the work environment (the increasing level of education
and growing aspirations).
8
2.2 Financial participation
Moving on to the main topic of this paper, employee financial participation in companies,
one first needs to stress that this term covers a very wide spectrum of solutions ranging
from participation in profits, through individual shares in equity and employee stock options,
to employee ownership systems like ESOPs, specially designed to serve this purpose,
which combine employees’ participation in the profits and capital of the companies .
Financial participation is thus an umbrella term referring to various forms of supplementing
employees’ fixed remuneration with a variable component of earnings, the value of which depends
on the profit or loss of the company. However, the term should only be used to describe
solutions used regularly and universally and covering the majority of employees of a given
company 5 . One of the main features of financial participation is that it is introduced voluntarily,
on the initiative of the entrepreneurs. However, legal and tax incentives play an important role
as well.
Financial participation creates additional economic and legal bonds between the company
The term employee financial participation concerns individual property rights, hence it does not cover
the legal form of cooperative which assumes collective ownership of an economic entity.
5 This far-reaching interpretation stems from the 00 EC report.

and its employees. All financial participation schemes are based on a similar idea: to make
the employees co-beneficiaries of the company or, in the most far-reaching systems,
co-owners. The justifications for these ideas include ethical, psychological, economic,
and systemic motivations. At the forefront are the demands for greater fairness
in the compensation of workers, who are not treated merely as a cost but also as the most
creative factor of production. In this context, we are reminded of the demand for workers’
empowerment in the discussion of non-financial participation, though in this case,
its implementation would have to be based on a solid financial foundation: the participation
of employees in profit-sharing and ownership, as well as in the resulting rights.
One of the most frequently cited economic reasons to implement financial participation
is the aim to improve individual and collective motivation at work. By introducing additional
benefits linked with the company’s performance, it is expected that employees will show
greater interest in the quality of their work, greater ability to work in teams, and greater
identification with their own company. Employees receive various benefits, including
an increase in revenues and, above all, solid insurance for the future, consisting of support
for old age and accidental events, security for the future needs of their families,
as well as support in the event of employment loss.
However, for the entrepreneur, the important justification lies in the ability to enhance
the flexibility of remuneration in response to market conditions and the company’s profit
and loss. For smaller companies implementing employee equity-sharing, it is also
important for the improvement of their capital structure (increase in shareholders’ equity)
and for the ability to resolve succession issues when the owner retires. In the case
of large companies, the key arguments supporting the existence of financial participation
are the improvement of internal communication, the greater achievement of social goals,
and the implementation of a more effective HR policy (żuski and Schneider, 1986, p. 28).
For all types of companies it is argued that financial participation is positively linked
with sustainable employment and the tendency to promote the development of employees’
human capital.
On the macroeconomic scale, social and economic benefits linked with financial participation
should result in a more equitable distribution of wealth (without expropriation or redistribution)
and consequent changes in social stratification and attitudes (this is most aptly described
by the slogan “people’s capitalism” which was popular in the 950s- 960s). This argument
again becomes valid in the present context, due to the rapidly increasing socio-economic
stratification of modern societies and concentration of wealth and property in the hands
9

of a few over the past few decades 6. Employee financial participation, if introduced
on a large scale, could somewhat mitigate these changes. Another important goal of financial
participation is to increase society’s capacity to save and invest, as well as to promote
knowledge of the market economy and the acceptance of its rules. The introduction
of the most far-reaching form of financial participation, employee share ownership, extends
an awareness of responsibility for the issues of business efficiency, investment, capital
market rules, etc., to large numbers of people who had formerly been excluded from this. Finally,
in many countries, financial participation is meant to strengthen directly the pension system
by allowing employees to accumulate large savings on their supplementary pension
accounts.
0
2.3 Types of financial participation
Due to differences in the manner and degree to which employees are linked with the finances
of their companies, we can distinguish three basic forms of financial participation (Błaszczyk,
99 , page ):
. Employee sharing in company surplus, calculated in various ways (e.g., based on profit,
income, etc.), also called „pure” profit-sharing ;
. Employee share ownership (e.g. stock, shares, equity 8); and
3. Mixed systems (including both profit- and equity-sharing).
In the „pure” profit sharing systems, an additional source of employee income,
supplementary to their contractual remuneration, is established, albeit without the employee
empowerment implicit in share ownership. However, if employees are given the right to re-invest
this income in the company, profit-sharing systems gain a new role as the basis for financing equity.
More and more often, company profit shares are becoming the initial phase
of the establishment of employee share ownership, and sometimes the two systems
(profit- and equity-sharing) go on to function simultaneously (in the mixed form).
However, because of their different economic implications, we need to describe each form
separately.
6 For example, according to research conducted in Germany in 99 , the one million wealthiest
households owned more wealth than the 25 million poorest households put together (Lowitzsch, 2011,
p. 9). The situation is more extreme in the United States, where, according to the latest ( 00 )
data on the distribution of net wealth, the richest % of Americans owned .8% of the country’s total
wealth, the richest 0% held .5% of total wealth, and the poorest 50% owned only .5% of the country’s
total wealth. There are similar disparities with respect to income. According to the author of an article
published in the Business Insider in November 0 , there has never been such wealth and income
inequality in the United States since the onset of the żreat Depression in 1928 (Lubin, 2011).
German term: “Erfolgsbeteiligung”.
8 żerman term: “Arbeitnehmer-Kapitalbeteiligung”.

2.4 Employee Profit-sharing
The most traditional form of profit-sharing, also referred to as cash-based profit-sharing,
is a direct bonus payment based on the share of profits allotted to the employee. This does
not include a personal bonus 9 based on measures of individual performance, but rather
bonuses paid under a collective, pre-determined profit-sharing program, linked with the overall
profit of the company.
Under deferred profit-sharing, the allocated profit share is held for a given period of time
either in a special individual savings account or reinvested in the company. In deferred
profit-sharing systems, the premium may also be awarded in the form of company shares,
which are also retained for a fixed period and may only be sold by the employee
after this period.
2.5 Employee Share Ownership
Employee share ownership is a qualitatively different form of employee financial
participation, since employees become co-owners and investors in the company
by acquiring shares. This means that, through their financial contribution, employees
purchase shares and hold the legal right to a given part of the company’s assets
and to the profits generated by these assets. The employee becomes the owner
of the share (including the real appreciation in its value, or capital gain) and, depending on the type
of participation, he or she has a right to take part in business decisions, bearing the risks
and sharing in the benefits associated with the company’s performance. Thus, in such
a system, employees receive dividends on profits based on the amount of their investment,
in addition to their salaries. Here we propose a broad definition of employee share ownership,
including any form of employee investment in the company aimed at bringing profit. Some
of these forms (e.g. loans) are not strictly considered equity-sharing; however, since they fulfill
a similar economic function, they will also be the subject of our analysis.
Employee share ownership exists either in the form of direct employee shareholding,
i.e. individual acquisition of shares in joint stock companies and other types of individual
equity-sharing (in other types of companies), or in indirect forms 0 included in special
shareholder plans. In addition to individual acquisition of shares, direct employee ownership
9 Individual bonuses (gain-sharing) create a flexible part of income, dependent on performance
and supplementary to the fixed salary. Performance is measured in various ways and depends
on the employee’s position and his/her level of responsibility. Bonus systems include piece rates
and bonuses based on productivity or cost-cutting..
0 In this case, shares are at first owned by the institutions representing employees and are later
transferred to individual employee accounts after a grace period (most often when the credits used
for their acquisition are repaid from the company’s profit).

includes the rights of employees to acquire future shares (share options). Either company
or employee funds can be used to purchase employee shares. Employees may also purchase
company bonds or lend their money to the company in a different way.
As mentioned above, in addition to individual equity-sharing, there exist collective
employee ownership programs, referred to as Employee Stock (or Share) Ownership Plans
(ESOPs). These plans are equipped with specialized institutions (most often trusts) that act
as intermediaries between the company and its employees in matters related
to the creation and management of capital held on behalf of the employees. Whereas individual
employee equity-sharing is popular mainly in continental Europe, ESOPs are much more common
in Anglo-Saxon countries.
There are several different ways in which employees obtain their shares in enterprises:
in some systems, employees bear the acquisition costs at least partially, and in others,
the acquisition of shares or stocks is fully covered by the employing company, through
a bank loan or a combination of financing mechanisms, often supported by the state . Shares
are most commonly distributed through equity or share savings plans , which allocate shares
to employees on an individual or collective basis at the issue price, with a discount or deferred
payment option .
Granting employees stock options or the rights to acquire shares at a later date,
but at a price fixed in advance, is yet another form of employee ownership. The advantage
of this form is that employees are given the opportunity to profit on the difference between
the purchase and selling price of shares if the price increases. However, this type of benefit
is not universally recognized as a type of financial participation per se because, at the moment
of sale, employees most often keep the profit but do not become co-owners of the enterprise
shares for a longer period of time. Similarly, the previously mentioned employee bonds
and loans to companies cannot be regarded as classic employee equity-sharing,
as they increase the company’s debt rather than build its capital. However, taking
into account their long-term nature and the right of employees to the interest
on the borrowed capital or to dividends in the case of bonds, they can be seen as similar
in character to equity-sharing. Moreover, such instruments enable the company to obtain funds
for a lower price than on the market.
The previously mentioned forms of collective employee ownership (ESOPs)
are characterized by a different way of acquiring shares. ESOPs are based on special financial
In the form of tax relief, reduced or cancelled social contributions, or various kinds of subsidies.
In share savings plans employers regularly bring input in cash or shares.
The payment can be deferred and paid in installments, often with an employer’s subsidy or a bonus.

engineering, whereby the institutional intermediary between employees and the company
(usually a trust) purchases the shares (usually using a bank loan) and allocates them to individual
employee accounts for deferred use. The bank loan can be repaid either from the company’s
profit or from dividends on employees’ shares, but rarely by the employees themselves .
Broad privatization in the UK and other Western źuropean countries in the 1970s-1980s
provided an excellent opportunity for the introduction of employee financial participation
on a wider scale. Massive privatization of state-owned companies in the former źastern Bloc
began a bit later, in the 990s and early 000s. Both waves of privatization led to significant
changes in the structure of ownership, in part including the “top-down” creation of specific
forms of employee ownership, which often turned out to be less stable 5 than the financial
participation schemes steadily developed from the bottom up over many years.
It should also be noted that, in practice, employee ownership of a company’s shares
or bonds does not guarantee influence on business decisions. Most often, employees
are represented at shareholder assemblies by proxy, and if they participate in person,
their proportion among shareholders is too small to constitute the deciding vote. Some
forms of employee ownership are deliberately designed so as not to give workers the full
voting rights of their shares (for example, by giving them non-voting shares). However,
the problem of linking employee ownership to the appropriate form of non-financial participation
is another topic, which we must omit here.
3. Financial participation: Experiences and achievements
3.1 A little history
The tradition of employee financial participation dates back to the early nineteenth
century, when the first attempts were made to create systems enabling employees to receive
regular shares in profit. In the middle of the nineteenth century, profit-sharing schemes were
already successfully implemented in companies across Great Britain and Germany. One
of the best-known cases was the system of financial participation in profits introduced
in 1847 by the żerman economist J.H. von Thünen in his own estate of Tellow in Mecklenburg
(Thünen, 850). Interestingly, the capitalized profit shares in this system were assigned
to the creation of future employee retirement security. This system lasted until the owner’s
The description and classification of various institutional solutions fostering equity-sharing,
both individual and through ESOPs, can be found in Blaszczyk ( 99 , p. 5-5 ).
5 Comparative studies, conducted at the end of the 990s in several Central and Eastern European
countries, showed that post-privatization changes in the ownership structure of enterprises privatized
with a predetermined allocation of shares are usually quick and in many cases lead to the concentration
of capital in the hands of a few shareholders (Blaszczyk et al. [eds.], 00 ).

death and the estate’s subsequent sale at the end of the nineteenth century. Attempts
to implement financial participation also have a long history in France, where at the end
of the nineteenth century it was attempted to pass a law imposing employee financial
participation in company profits. Emploee participation systems were developed
in a systematic way from the bottom up in European countries, in Great Britain
and in the United States until the Great Depression in the early 9 0s,
when they collapsed along with the economy 6. The renewed development of financial
participation began after World War II.
Another early example of overall financial participation (both in company profit and equity)
was the pioneering system of “workers’ enfranchisement” established in Poland in 9 6
and developed on a wider scale in the 1920s by engineer Marian WieleĪyński
in his mining enterprise żazolina (WieleĪyński 1985). Initially, shareholder status was offered
to a selected group of the most trusted employees, and then (after 9 ), it was made
gradually accessible to all permanent employees of the company. According to the by-laws
of 9 , permanent employees were entitled to an annual bonus equal to their monthly
salary, dividends on stocks and a large severance payment based on the duration
of employment. They were, however, obliged to invest one month’s salary per year
into the company’s shares. Employees demonstrated their engagement in the company’s
fate several times. First, they supported the reinvestment of a large
surplus instead of demanding a pay raise. Later, they successfully
replaced the owner who, when arrested by the Ukrainian occupation authorities,
was absent for more than a year. They proved their commitment again in 9 , when they
refused to take part in the general strike organized by the trade unions of the entire region.
The decision was justified by the fact that the salaries and social benefits of Gazolina’s
employees were much higher than those demanded by unionists from other factories.
Finally, another positive example of the employee ownership system was the employees’
refusal to sell their shares despite the proposed 5-fold gain relative to the nominal price,
which was offered by a foreign company that wanted to buy Gazolina out in 9 9. The company
was developing and flourishing until the outbreak of World War II. Despite these impressive results,
the system was not adopted in other Polish companies in the interwar period (WieleĪyński
985, pp. 5- ) .
6 It was estimated that in Great Britain in 9 9, over a quarter of a million employees participated in
such systems (Estrin et al. 98 ).
According to L. WieleĪyński, Poland’s President Ignacy Mościcki and źconomy Minister
źugeniusz Kwiatkowski were considering introducing a similar system in “Wspólnota Interesów”, a large
nationalized coal conglomerate in the Silesian region, in the late 9 0s. The idea was dropped,
probably due to the very poor industrial relations in this company, characterized by great mutual hostility
between workers and managerial staff (WieleĪyński 1985, p. 177-188).

5
3.2 The development of financial participation after World War II
The evolution of financial participation can be divided into two periods. The first period
lasted from the end of the war until more or less the end of the 980s, when systems
were developing separately in various European countries and the United States. The second
period (from the early 990s onwards) is increasingly characterized by a supranational approach
to financial participation, in particular with the development of the EU and its institutions.
Furthermore, European countries have attempted to use American solutions,
and vice versa. Recently, the źuropean Commission and the źuropean Parliament
have undertaken initiatives to promote financial participation and to find common institutional
solutions, so as to implement them on a broader scale.
3.3 Examples of national solutions
Financial participation systems implemented in European countries after the war differ
significantly. They depend, on the one hand, on the political situation and position
of particular governments and, on the other hand, on the attitudes of trade unions and employers.
The earliest attempts at creating a legal framework for financial participation,
as well as the greatest efforts to implement these laws, were observed in France, Great Britain,
Belgium and Germany. Different approaches were used in each of these countries
in their repeated attempts to ensure financial participation of employees in their companies.
At the same time, intensive activities were undertaken in the United States, leading
to the creation of other institutional forms of financial participation, which will be described
below.
France
In France 8, which is one of the few countries where financial participation is required
by law, efforts were first concentrated on programs enabling employees to share in profits
and to participate in corporate savings plans. In 959, under President de Gaulle,
the government passed a decree obliging all enterprises to introduce so-called
participatory systems giving employees the right to a share of the company’s profits. The decree
was then reviewed in 1962 and 1967. Initially, these were cash payments out of profits. Later,
deferred payments were added 9, which were made into special participatory funds,
where they had to be held for three years in exchange for tax benefits. The form
8 Historical information concerning France is taken from Blaszczyk ( 99 ), and newer data are taken
from Lowitzsch, Hashi, Woodward (2009) and Lowitzsch (2011).
9 Since 96 , deferred payments out of profits have been obligatory in all companies employing
more than 00 people and, since 986, in all those employing more than 50 people.

of profit distribution is usually determined by collective agreements. Since 96 ,
increasingly broad employee savings plans, implemented voluntarily by entrepreneurs, have
been introduced in addition to the required profit-sharing. Participation in these plans is voluntary
for employees and most often requires a financial contribution from both parties.
These savings funds are later used to purchase company stocks or shares in external investment
funds. In the first case, employee share ownership is created and can be further enhanced
by the right of employee savings funds to acquire company stocks while enlarging its capital,
if employees hold less than % of shares in the company’s capital stock. In the 980s these legal
solutions were supplemented and expanded. Furthermore, financial participation was placed
high on the political agenda with the passage of a law requiring financial participation programs
to be part of negotiations between employers and trade unions. In the 990s additional tax
benefits were extended to employees exercising the right to purchase options, provided
that they did not sell them within a given period. In 00 , two new types of savings plans
were introduced: one designed for employees of small businesses, and the other for pension
purposes. Today, as a result of the implementation of these laws, France has a rich
and multi-faceted system of employee financial participation.
6
Belgium
In Belgium 0, various proposals to create mandatory or voluntary forms of profit-sharing
were hindered by both the uncompromising attitude of trade unions and the reluctance
of the majority of political parties. As a result, it was not possible to implement
any incentives for financial participation until the early 980s, when efforts were undertaken
to introduce financial participation in a different way, i.e. by creating financial facilitation projects
for employee shareholders, which were gradually transformed into laws. Subsequent
bills, passed in 98 , 98 , 986 and 98 , introduced an incentive system to encourage
employees to purchase shares in their own companies, whereby a specified amount set asi-de
for the purchase of shares would be tax exempt, if these shares were frozen for five years.
This facilitation concerned the purchase of newly issued shares by all employees in joint stock
companies, limited liability companies, and foreign companies and their subsidiaries subject
to taxation within the country. The supplementary act of 990 stipulated that shares issued
to employees alone could not exceed 0% of the company’s capital stock. A law
was also passed in 98 to regulate employee rights to purchase stock options
and associated privileges. These rights apply to all employees of the types of companies listed
above. The law also specifies a maximum amount for which an employee may purchase options
and stipulates that the options must be frozen for at least two years and that the capital
0 Historical information concerning Belgium is taken from Blaszczyk ( 99 ), and newer data are taken
from Lowitzsch, Hashi, Woodward (2009) and Lowitzsch (2011).
In the beginning, the sum amounted to 0,000 Belgian francs but was later lowered to 0,000.
This was 500,000 Belgian francs or 5% of the employee’s income from the previous year.

gain derived from the difference between the purchase price and selling price is not taxable.
In 999, the revised law on options determined that no social contributions should be paid
on the employee capital gains on stock sales. These regulations have made financial
participation very attractive for both employers and employees in Belgium, where the high
tax progression and relatively high social security payments can be avoided by paying
out a part of employee income in the form of options. For the same reason, these solutions
have met with opposition from trade unions, which have demanded higher primary wages
and the protection of high social security contributions instead of participation. At the end
of the 980s, many Belgian enterprises introduced voluntary employee profit-sharing
programs in the form of share certificates. The 00 act on employee ownership
and profit-sharing schemes brought all existing tax advantages related to financial
participation programs under a single regulatory umbrella and introduced common systemic
rules, including requirements of universal participation of all employees in such schemes,
approval of schemes by an employee representative, and the right of employees owning
shares to vote. At the same time, it also introduced limits for financial participation
programs in companies and allowed institutions for collective management of employee shares
to be established. An important element of the act is the introduction of the foundations
for establishing savings funds based on deferred employee profit-sharing in small
companies. Despite considerable political difficulties in Belgium, a multifaceted employee financial
participation system, with extensive possibilities in practice, has thus been established.
Germany
In the post-war period West Germany began the first activities aimed at fostering
employee financial participation from a different angle, i.e. by supporting savings and efforts
to reduce financial inequalities among citizens and by rebuilding the middle class. Laws
introduced since 96 aimed to support these attempts by creating financial incentives
for systematic saving in various forms, including the acquisition of shares in companies
and incentives for employers to partially finance these acquisitions 5. As part of the national policy
to create wealth, a new term was coined, namely “wealth-increasing expenditures” 6,
which refers to regular payments by the employer (excluding payroll) for the benefit
of employee savings, subject to an additional state premium. The upper limit of annual savings
and the premium amount were determined by the state , whereas specific amounts
The yearly expenditures on financial participation programs cannot exceed 0% of annual
remuneration and 0% of the company’s profit before tax.
Most of the data concerning żermany are taken from Blaszczyk (1992), which also contains detailed
information on regulations implemented in Germany, together with their financial engineering.
5 Vermögensbildungsgesetze”.
6 “Vermögenswirksame Leistungen”.
Initially the limit was 312 DM per year, which was raised to 936 DM at the end of the 1980s.

were negotiated by the employer and employee representatives in collective
or workplace agreements. Initially, public benefits referred equally to all forms of long-term
savings (e.g. construction, housing or insurance savings, or savings on the purchase of shares
or bonds). After 98 , clear legal priority was given to savings in the form of capital aimed
at creating wealth in the hands of employees, either in their own company or with institutional
investors. The Participation Act of 986 8 differentiated the premiums that could be obtained
from different types of savings, in favor of equity-sharing 9. It also greatly expanded the range
of possible forms of employee equity-sharing schemes that could benefit from these premiums,
to include stocks, bonds, shares in limited liability companies, as well as other less-known
forms of investment in one’s own business and beyond 0. These benefits were conditional
upon meeting some formal requirements and providing employees with the freedom to choose
the form and location of their investment. In order to receive an untaxed savings premium
from the state, the savings had to be frozen for a period of six years; however, the company’s
subsidy to the employee is subject to taxation and social security payments. Additional
incentives to invest in equity-sharing were introduced with changes in fiscal law, whereby
the capital gain resulting from the difference between the market price of shares and the price
at which they were issued to employees was exempted from income tax (and from social security
payments). As a result of these long-standing forms of support for employee savings
and investments, stemming partially from employers, partially from the state and only in small
part from the employees themselves, such employee capital savings programs exist in most
German businesses. The most widespread form of employee participation is profit sharing
via profit-sharing systems created by combining savings plans with employee shareholding
promotion measures.
8
Great Britain
In the UK , legislation supporting employee ownership in companies was initiated in the 9 8
Finance Act and then expanded in 98 and 988 by the Income and Corporation Taxes Act
and the 989 amendment to the Finance Act. Originally, the facilities only included tax relief
for employees participating in “approved all-employee profit-sharing schemes”, recognized
by the Inland Revenue, which meant that the employees received grants consisting
8 “Vermögensbeteiligungsgesetz”.
9 Savings in the form of capital shares (and housing construction savings) were given a % premium,
while other forms of savings received a 6% premium.
0 Such as employee loans to their company, attestations and usage rights, shares in silent
partnerships, cooperative shares, as well as fund shares , share certificates and foreign securities
accepted in the ŻRż.
However, only up to the amount of 500 DM per year.
Most of the data used in this section are taken from Blaszczyk (1992), and newer data are taken
from Lowitzsch (2011).

of company shares, with a fixed upper limit , free of charge or at preferential prices.
These shares could be sold after two years; however, only after a five-year period could
the granted amount be exempted from income tax. The tax on capital income was maintained
regardless of the length of the grace period. In subsequent years, other facilities for employee
stock options were introduced, related to regular savings plans (“savings-related share
option schemes”). These facilities covered employees who declared having saved a certain
amount of money (up to 50 pounds) every month for a period of -5 years. By the end
of this period, the total amount saved could be spent on acquiring shares at a price
that was 0% lower than the issue price (at the beginning of the savings period).
By establishing the institution of a “qualifying employee share ownership trust” (ESOT)
and introducing special exemptions from corporate income taxes on the amounts invested
by companies into these trusts, the act of 989 significantly expanded the opportunities
for investing within the framework of employee share ownership. The ESOTs can use
the money received from the company to purchase its shares, repay loans with the interest
received, pay dividends and shares to shareholders, as well as cover other expenses.
To obtain a corporate tax exemption, the company is required to fulfill a number
of conditions, such as extending the benefits to all employees and disbursing the money
received by the trusts from the company in a timely manner. The employees have similar tax
advantages and withdrawal periods, as in the case of profit sharing and saving schemes
described above. The legislation of 989 was designed to facilitate the establishment
of employee equity-sharing schemes and to increase their popularity among all companies,
not just those listed on the stock exchange. ESOTs can be set up in smaller companies,
which do not issue stock, in which case they serve as an internal market for the company’s
shares. Additionally, the ESOT can invest outside the company as a collective fund.
Legislation on employee share ownership was last revised in 2000 in the framework
of the Share Incentive Plan (SIP). The SIP confirmed and extended the tax advantages
for both employees and employers on savings intended for share purchases.
Up to a specified amount, the money set aside for share purchases is deducted from taxable
income. Furthermore, employers may transfer their shares to employees free of charge;
the latter can then sell their shares after five years without being subject to income tax or social
security contributions . Due to the significant administrative burden on businesses in carrying
Initially the limit was 0% of annual employee income or 5,000 pounds per year, which was raised
9
to 6,000 pounds in 989.
Four categories of employee shares were distinguished in the SIP framework: “free shares”,
i.e. stocks obtained for free from the employer, with a maximum value of ,000 pounds per year;
“partnership shares”, i.e. stocks that employees can purchase from non-taxable remuneration,
with a value of up to ,500 pounds per year or 0% of the annual income; “matching shares”,
i.e. double stocks that employers can add to every “partnership share” they purchase; and “dividend shares”,
i.e. dividends obtained from the other three types of stocks, which can be reinvested
into these stocks for up to ,500 pounds per year. All of these stock types may be sold immediately,

out such a plan, the law allows for the plan’s administration to be outsourced to third parties,
which is often done in practice. Thus, the UK offers many financial advantages to employees
and companies introducing financial participation schemes. The process, however,
is controlled by detailed regulations and scrutinized by the tax office 5.
0
United States
In the United States modern forms of support for employee participation were preceded
by a long-term state policy aimed at supporting equity-savings among employees
and at encouraging employers to allocate their funds for this purpose. In the mid- to late
9 0s, high economic prosperity was accompanied by rigorous control of wages and high tax
progression. This prompted several companies to develop plans for employee profit-sharing,
under which the transfer of income to employees was exempt from income tax, if the shares
were frozen for a ten-year period. Most of the plans introduced at that time were designed
as supplementary pension funds for employees and included either employee profit-sharing
systems within the company or systems whereby the shares were transferred to pension
funds outside the company. In the following years, despite the abolition of wage controls,
profit-sharing plans developed rapidly and their number doubled every five years.
In the 9 0s state policy priorities changed, and the state began to give more and more support
to employee share ownership in companies. The initiator of the original institutional solutions
for American employee ownership was Louis O. Kelso, a lawyer, economist and visionary,
who in 956 organized the first buyout of a company by its employees under
an employee stock ownership plan. Kelso actively promoted this type of ownership 6
until his death in 99 .
In 9 the Congress passed the first law in support of employee ownership plans
called ESOPs (“Employee Stock Ownership Plans”). The ESOP is an institutional solution
in which case they are subject to regular taxation and social security payments. If the stocks are kept
in the system for -5 years, they are subject to lower tax and social payment rates, and if they are kept
for over 5 years, the employee is exempt from paying taxes and social contributions. If the employee
leaves the company before the grace period, s/he pays lower taxes and social contributions or,
if justified, is completely exempt from them.
5 According to a high-ranking official of the Ministry of Żinance, state budget costs related to tax re-liefs
for employee financial participation were estimated at approximately 00 million pounds per year
in 989. In his opinion, these expenditures are justified if they serve the interests of the employees;
however, they should not be abused by employers trying to lower the wage costs (Blaszczyk, 99 ,
pp. 6 -6 ).
6 Among Kelso’s numerous publications, two deserve special mention: The Capitalist Manifesto (1958)
and Democracy and źconomic Power: źxtending the źSOP Revolution Through Binary źconomics
( 986).
źmployee Retirement Security Act (źrisa). Its author, Russell Long, was a Democratic senator
from Louisiana, although źSOPs were also supported by Republicans, including three Republican
presidents.

that allows for collective acquisition of shares/stocks by employees in the companies employing
them, on credit, which is later repaid from the profits of the enterprise. The employees become
full-fledged owners of their individual shares after the loan is repaid by the trust managing
the ESOP. However, they cannot freely dispose of their shares until they either retire
or leave the company. In the following fifteen years, the Congress passed 5 more acts favoring
the źSOP concept, the most important of which was the Tax Reform Act of 1983
enacted under President Reagan. This act provided tax relief to all parties interested
in setting up and running ESOPs, under the condition that the plans did not lead to discrimination
and were available to all employees. Under these provisions, the taxable income
of the company was decreased both by the company’s contribution to the ESOP on behalf
of its employees (up to 5% of the wage bill per year) and by contributions used to repay
bank loans used for purchasing employees shares, including interest. ESOPs were exempt
from income tax, bank income on the loans to ESOPs were subject to a 50% tax relief,
and the owners of the companies who gave shares to ESOPs were exempt from capital
gain tax, conditional upon the reinvestment of these assets in other stocks. The employees
were obliged to pay income tax only after the withdrawal of their shares from the ESOP trust,
usually when they retired 8. In such favorable conditions, the employees could become owners
without incurring any costs on their part. Hence, a proliferation of ESOPs began.
All these facilities were subject to numerous restrictions aimed to prevent fraud, which in turn
has led to considerable complexity of fiscal regulation and a high degree of administrative
control. These factors in turn mean that helping to set up an ESOP has become a profitable
business for several thousand legal and consulting firms. It has also had a negative impact
on the federal budget. Due to the reliefs and tax exemptions discussed above, lost revenues
to the budget between 9 and 98 were estimated at US$ billion 9 to 9.9 billion50. Despite
this fact, the idea of the ESOP as an institution promoting employee financial participation
assisted by loans turned out to be very interesting and has survived not only in the United
States but has also been adopted in many countries around the world. In the United States,
the ESOP as an institution has remained almost unaltered, though amendments
to and interpretations of the law have become too numerous. An important feature
of the ESOP is its universality, i.e. the possibility for it to be set up in almost any type
of business, regardless of legal form and size. This has enabled ESOPs to be set up in even
the smallest family-owned companies. So far, Europe has not introduced such a flexible legal
form of financial participation.
As popular as establishing ESOPs in United Sates was in the late 9 0s and 980s,
in the 990s a wide dissemination of employee stock option plans began. While ESOPs
8 The financial architecture of ESOPs is shown in a more detailed way in Blaszczyk ( 99 )
9 According to data of the ESOP Association.
50 According to Estrin et al. ( 98 )

were created mostly in smaller and unlisted companies, the stock option purchase plans could
be introduced in large companies. In 000 it was estimated that the number of stock option
owners equaled or exceeded the number of ESOP members5 . The scale of particular types
of financial participation in the United States will be discussed further below.
3.4 The scale and impact of financial participation in the United States
and Europe
At the beginning of 0 in the United States, according to the US National Center
of Employee Ownership (NCEO), there were about ,000 ESOP-type plans, covering more
than 0 million employees. About 0 million people were participating in stock option plans.
In addition, approximately 5 million employees participated in older types of savings plans,
investing mainly in company shares. Furthermore, more than million employees
had bought shares under a share purchase plan. Eliminating double counting,
it is estimated that about 8 million people participated in one of the employee share ownership
plans. At the end of 0 0 it was estimated that approximately . % of all private sector
employees had shares or stock options in their companies and about 8. %
had stock options. In all limited liability and joint stock companies as much as 6%
of employees had stock options. It is estimated that the capital included in employee
ownership now constitutes about 8% of the total capital of all commercial companies.
While ESOPs are present in most of the companies not listed on the stock exchange,
only % of public companies have ESOPs.The forms dominating in public companies
include stock option purchase plans and other ownership savings plans. It is estimated
that each employee of a company that has an ESOP receives an annual average
revenue equivalent to US$ , and has an account worth an average of US$55,8 6.
At the end of 009, ESOP capital resources were estimated at approximately US$869
billion. It is hard to assess such data for other types of employee ownership and profit sharing
plans, as the reporting obligations are much less strict than in the case of ESOPs. Although
companies that are majority-owned by employees are rare in the United States, large
and well-known global companies are among them5 . It is also worth noting that more than half
of Fortune magazine’s “ 00 Best Companies to Work for in America” has an ESOP or another
employee share ownership plan (National Center for Employee Ownership, 0 ).
In źurope, in the 15 old źU Member States, 17% of private sector employees work
5 According to Joseph Blasi from the National Center of Employee Ownership, in 000 in the Uni-ted
States there were approximately 8.5 million ESOP members in approximately ,000 companies
and -9 million share option owners in several thousand companies (Blasi et al. 000, p. V).
5 These include the sales network Publix, which employs 5,000 people, the construction company
McCarty, the companies Nypro and Lifetouch (employing 18,000 each) or W.L. żore and Associates
(with 8,000 employees).

for an employer offering some form of employee shareholding, and if we broaden our view
to include various forms of profit-sharing, then 6% have the opportunity to participate
financially in the companies where they are employed” (Lowitzsch et al. 2009). Taking
a closer look at the data (Lowitsch 2011), we see that in all of these countries
there is a fairly high percentage of companies practicing various forms of financial participation
(from several to several dozen percent in different categories), but the percentage of employees
who actually benefit from these programs is much lower (a few percent, typically less
than 0). For example, in Belgium, % of companies employing more than 00 people offer
shareholding plans, but only . % of the potential beneficiaries use these opportunities.
There is a similar situation in France, where the respective percentages are % and 5. %.
This means that the potential scope of financial participation is much greater than its use
in practice. However, when analyzing the data, one must take into account the fact
that they are based on estimates, as the summarizing reports use a variety of sources,
with varying methods and research tools that are difficult to compare5 . Moreover,
the kinds of financial participation practiced in Europe differ significantly across countries
and are sometimes so particular that they cannot be easily compared. These peculiarities stem
from the different ways financial participation evolved in those countries, as well as different
legal systems. Thus, in some countries the dominant forms are various kinds of profit-sharing
(for example, in France in 00 , deferred profit-sharing affected as much as 5 %
of employees, or 6.3 million people, and in Sweden, the Netherlands, Luxembourg
and Finland, 5%, .8%, .5% and % of employees, respectively, were affected
by profit-sharing), whereas there is a more even balance between profit-sharing
and shareholding in Germany (with % of employees participating
in profit-sharing, and – as of 006 – shareholding plans in practice in more
than 3,000 companies employing 2.3 million people) and the UK (where, in 2006,
for example, shareholder-approved plans associated with participation in profits and stock
options were present in 5,000 companies and included approximately one million people,
and other savings plans were present in more than ,000 companies covering .6 million
workers) (Lowitzsch 2011, pp. 28-31).
In most of the countries we notice a similar pattern, in that – as in the United States – stock
option purchase plans are most prevalent in the largest companies, which are often listed
on the stock exchange. When examining the percentage of beneficiaries
of these programs in large companies, one sees that stock option purchase programs are present
in as much as 8 % of listed companies in Finland, 80% in the Netherlands, more than two
thirds in Germany, approximately 50% in France, one third in Denmark, about 5%
5 Outstanding research in this field is conducted by The European Foundation for the Improvement
of Living and Working Conditions, whose reports and studies are conducted for the źC (źuropean
Foundation 00 ). Another important source is the Cranet Survey, concerning European companies
employing more than 200 people (Lowitzsch 2011)

in Luxembourg, and 40% of companies employng more than 50 people in Belgium.
Sweden is the only country where share option schemes are non-existent. In the UK
it is difficult to specify the number of beneficiaries of stock options, as in many companies
these programs are combined with other employee share ownership schemes, as discussed
earlier. In most of the countries where there are employee ownership schemes, the latter
have either an individual (employee share ownership) or (temporarily) collective
character (ESOPs), though in Finland the dominant form is the collective employee fund,
which was also in force in Sweden until 1991 (Lowitzsch 2011).
According to reports prepared by the European Federation of Employee Share
Ownership (EFES 0 0), employee share ownership developed strongly in the first decade
of the 000s. While in 00 , 0% of large European companies offered employee share
ownership plans, these plans were present in as many as 8 % of such companies
by the end of 2010. Moreover, newer plans have included all employees, and not just
selected groups as was the case earlier. The question how often employees actually exercise
such rights to financial participation in their companies, however, remains open.
There is a fairly widespread view that the implementation of financial participation
in źurope in its various forms is most advanced in Żrance and the UK. These two countries
have the most experience and longest tradition in implementing legal solutions (over 50 years
in Żrance and more than 30 in the UK). Within the źU-15 the lowest achievements
are in the Southern European countries, i.e. Italy, Spain and Portugal. The reasons
for this differentiation are not fully clarified and need to be studied. In conclusion, despite
the inability to determine the exact number of people benefiting from various forms of financial
participation in the 15 old źU Member States, it must be said that employee financial
participation has already been introduced on a large scale, and it is likely that the benefits
of these programs affect millions, or even tens of millions, of people in Europe. Existing
legislation, which in many countries strongly supports the development of financial
participation, provides an additional opportunity for its further significant development.
In the New Member States, financial participation is much less widespread
and far from achieving its maximum potential. Although in most of these countries
employees benefitted from acquiring stocks and shares at preferential prices duringthe
privatization of their companies in the early transition period, there were neither incentives
to keep these shares nor the will on the part of employees themselves to do so. It seems
that this willingness is linked to a certain standard of living on the one hand, and the level
of economic education of rank and file employees, and awareness of managers
(in particular their expertise in the field of business culture and modern management methods)
on the other.

4. Activities of the European Community to foster employee
financial participation
5
4.1 EU initiatives in the 1990s and at the turn of the century
At the European level, the debate on employee financial participation began in the early
1990s. The first report of the źuropean Commission, entitled PźPPźR I (full name: Promotion
of employee participation in profits and enterprise results), was written in 99 . On the basis
of this report, in 99 the Council of the European Union issued a recommendation concerning
the promotion of employee participation and the European Parliament adopted a resolution
on the same subject.
Within these recommendations, the European Council formulated the basic principles
that must be met so that employee participation programs obtain EU support.
These rules remain in force today, in the more precise formulation contained in the Commission
Communication of 00 (European Commission 00 ); hence, we quote the complete version
below:
. Employee financial participation must be voluntary (for both employers
and employees).
. Participation programs are a supplement to the existing remuneration system
and not a substitute.
. Programs must not discriminate; the benefits of financial participation must
be extended to all employees.
. Programs must be understandable and transparent.
5. Rules of financial participation in companies should be based on a clear, predefined
formula.
6. Firms are obliged to provide information and training to employees on the model
introduced and participation details.
. Unreasonable risk for employees in the programs implemented must be avoided,
and if it exists, objective information and warnings must be given to employees.
8. Participation programs must take into account the employees’ right to mobility between
enterprises and countries.
Subsequent PźPPźR reports, which were designed to diagnose progress in the field
of financial participation in źurope, were written successively in 1997 (PźPPźR II), 2006
(PźPPźR III) and 2009 (PźPPźR IV) and referred only to the forms of participation that met

the requirements specified above and, consequently, obtained EU support5 .
The last report (PźPPźR IV, 2009) gave a complete picture of financial participation
in all źU Member States and candidate countries and not only described various
participation programs and their popularity in individual countries but also presented the government
policies and the attitudes of social partners. It also discussed the obstacles
for implementation of the programs and legal, fiscal and other incentives for their
application. Hence, a large amount of information on financial participation in individual
countries and legal solutions fostering their implementation is available. Nevertheless, a single
common legal framework for the EU still has not been created. This is justified by the fact that
the EU has no decisive competences on internal regulations concerning enterprises or tax
and fiscal systems within Member States. So far, the źU could only advise on good practices
and provide recommendations on the mutual recognition of their rights in other countries.
Since 0 0, the EU has made efforts to support employee financial participation
and, after an in-depth discussion, the European Socio-Economic Committee adopted
an opinion on the matter on October 0 0. “The aim [of the opinion] is to encourage
Europe to draw up a framework concept which promotes Europe’s economic and social
cohesion by facilitating the application of EFP at various levels” (European Committee
for 0 0). In the opinion, the Committee first recalls the basic principles of financial
participation (listed above) and then lists various social and economic benefits resulting
from the introduction of participation programs (for workers, for businesses and for entire
communities). The document lists concrete examples of practical solutions for employee
participation in the profits and assets of companies, and, finally, calls for joint efforts
to disseminate these solutions. In the part devoted to benefits for businesses, it is stated
that special attention should be paid to the positive impact of financial participation
on corporate governance in the company.
The Committee also proposes to develop a transnational “Building Block Approach”,
which would include all forms of financial participation practiced, so that individual
countries can choose the combinations of modules that are most suitable for their needs55.
Within this approach, the Committee differentiates between three basic forms of financial
participation: profit-sharing, individual share ownership, and the ESOP model. The Committee
recommends a combination of profit-sharing and idividual share ownership
and, in the case of SMźs, the źSOP model.
5 Hence, stock option programs for management alone, share ownership available for selected
employees, and irregular profit-sharing or individual merit-based bonuses are not included.
55 The “Building Block Approach” has been described in Lowitzsch (2011).
6

Recent recommendations of the źuropean Socio-źconomic Committee steer towards
combining various forms of financial participations in such a way as to make employee
shares funded by profit-sharing. In its opinion, the Committee indicates that in some large
European companies there already exist models of employee ownership
where purchasing shares through trusts is financed by a profit share paid in addition to wages.
Usually, for this purpose, a separate intermediary entity56 is created, which, acting as a trust,
manages the shareholding of the employee. The governance of this entity should be a direct
expression of the will of all employee shareholders, with no influence from management,
in a democratic way. The Committee lists examples of such companies and describes
the stated goals of their financial participation schemes. These include: AUCHAN (France),
HOMAż Aż (żermany), Pfalz Żlugzeugwerke PŻW Aerospace Aż (żermany),
Voestalpine AG (Austria), Oktogonen Foundation (Sweden), Herend-ESOP (Hugary),
Tullis Russell źSOP (United Kingdom), the źircom źSOP and AerLingus-źSOP (Ireland).
In three of these cases, the declared purpose of introducing financial participation
was “enhancing the loyalty and motivation of employees”, in three others “privatization
and strategic shareholding” and in others “financing of the company’s growth”,
“business succession” or “spin-off”.
4.2 Proposals for long-term measures in the European Union
Today, the European Socio-Economic Committee proposes to develop the “Building Block
Approach” and its gradual implementation in the Member States, as well as coordination,
streamlining and mutual recognition of the principles of financial participation for companies
operating across borders. For the future, however, the Committee sees the need for closer
cooperation, for instance in relation to the increasing mobility of employees and enterprises
between Member States, which does not go in hand with the limited mobility of participatory
solutions.
While tax incentives, according to the Committee, are not a must for financial
participation, they have been shown to provide positive and important leverage for its wider
implementation. However, in the opinion of the Committee, since the EU lacks competence
over taxation issues, there is a need to develop “a facultative, simple, uniform incentive model,
with the same tax arrangements and incentives throughout the EU, [which] could
considerably boost the number of cases where there is a willingness to introduce EFP.”
(European Socio-Economic Committee 0 0) It also proposes to take deferred taxation
as the lowest common denominator for the development of the proposed model.
Before the European model is established, the Committee calls for mutual recognition
56 In continental Europe it is a limited company, foundation or association, and in Anglo-American coun-tries
it is usually a trust.

of individual Member States’ schemes for businesses operating across borders.
As Europe unites, the differences in employees’ rights to financial
participation in their companies become particularly visible and can have
an adverse effect on both labor mobility and enterprise competitiveness.
Therefore, an important argument can be made in favor of the attempt to give equal rights
in this regard to all employees within the European Union.
8
5. Questions for future research, in particular in Poland
For the past 0 years, employee financial participation, i.e. profit-sharing and employee share
ownership, has proved effective in the leading European economies and the United States.
This paper clearly shows that financial participation cannot be treated as a socio-economic
experiment in today’s economy. It is rather a widely-acclaimed operating principle
in thousands of companies that have recognized it as a good practice and included it in the modern
management of business and human capital.
In Poland, we also need to realize this and start giving financial participation
the attention it deserves. However, while bearing in mind the important human aspect
of financial participation, many questions need to be answered regarding the economic
dimension of this issue. For example, what could be expected as a result of the implementation
of participation on a broad scale in our companies? What might be its impact
on productivity? How might it change the behavior of companies, and under what conditions
would it support their development? How could the interests of employers and employees
be taken into consideration without harming the efficiency of management?
In what institutional framework could financial participation generally be beneficial
for raising the competitiveness of companies? What might be its impact on corporate
governance?
The influence of financial participation on companies’ performance has been the subject
of studies too numerous to discuss at length in this article. Generally, it can be stated
that participation has a positive influence on the survival of a company in a difficult situation
and on maintaining employment. Judging by the recent American experience, companies
with financial participation have adapted better to harsh crisis conditions and provided more
protection for disappearing jobs than other companies (National Center 0 ). A more
controversial issue is the advantage of such companies in the area of raising labor
productivity and other economic outputs, because the impact of participation on efficiency seems
to be less direct and depends on many additional factors. At this point, we can say
that not only are these benefits different across countries but also across different

types of financial participation. Therefore, we plan for the next stage of our work to investigate
this issue and to deliver a study devoted to the economic results of different forms
of financial participation, based on a review of research conducted in Europe and America.
Another question concerns the main purposes for introducing financial participation
in our country and whose interests should be addressed by doing this. We think that these
interests may exist among employees, managers, employers, individual consumers, pensioners
and the whole society. As we suggested earlier, maintaining jobs and ensuring fair incomes
can be seen as one of the purposes of financial participation, and this lies in the interest
of employees. Enhanced loyalty and work motivation, better work quality and more flexible pay
lie in the interest of managers and owners of companies. More and richer sources of funds
for the time after retirement are in the interest of each working person. Finally, higher savings
would benefit the whole society in a country with a very low savings rate. A deeper and more
precise investigation of the nature of these interests is in our future plans, too.
Another important question is how to deal with the fear of risk among working people.
Our observation from the privatization process is that employees are willing to invest in their
companies, but they are strongly determined to avoid any kind of risk. All forms of employee
share ownership (including stock options) bear some kind of risk. Without this, there is no true
co-ownership. But if the employees don’t accept risk at all, we have to avoid or to limit this kind
of financial participation schemes and limit ourselves only to profit sharing schemes.
Taking in consideration the particular model of privatization in our country that included
in many cases employee buy- outs, we could try to find out in our future research,
what is the today’s heritage from this privatization model – taking into account
the remaining scope of employee ownership and the attitudes of working people to it.
This could partially explain the status of and potential for financial participation
in Polish companies. The question is whether employee ownership and broader: financial
participation is considered by the people as a temporary form or rather as a stable feature
of a modern company.
Another question to answer is whether financial participation is consistent with the evolution
of the modern business and contemporary forms of work. Taking into consideration
the high work force mobility and the various forms of flexible work that are needed in today’s
economy, we have to ask how these can coexist with financial participation that favors stability
of employees in their company.
A final important question for us is to find the sources of differences between countries
that have led to differences in the scale and scope of financial participation. One can
9

assume that differences in organizational culture and the historical legacies of individual
countries have played an important role. In particular, the historical character of industrial
relations could play a role: where cooperation has been given priority over conflict, financial
participation could play an important role. In places dominated by class conflict,
this, or any other kind of participation, is not likely to find fertile ground. But these factors
only partially explain the high or low achievements of each country in this area. These questions
need to be investigated further.
0
6. Conclusion
There are many important arguments in favor of employee financial participation.
The benefits for employees are obvious in schemes that follow the rules described
above. Taking the broader socio-economic context into consideration, we can see other crucial
arguments. One of them is the recognition of employees as the most important factor
influencing a company’s success and, as a result, aiming to better meet their financial
and spiritual needs. An employee who is co-owner of the company has a higher self-esteem
and a different, better attitude towards the problems of his/her company. This is especially
essential during the current technological revolution, when employees are much better
educated and the existence of the company often depends on their attitudes
and innovativeness. Thus, from the point of view of an employer, the successful
implementation of a financial participation scheme seems to be a “win-win” situation for both
sides: the employee and the company.
Another important argument is that modern profit- and asset-sharing schemes raise
the savings rate, with the savings accumulated over the years providing employees
with higher pensions. The argument that profit- and asset-sharing schemes contribute to reducing
income and wealth disparities in society also seems to be very relevant today and worth further
investigation.
All the arguments given above are also valid in Poland, so it seems reasonable
to undertake efforts to learn about various forms of financial participation and to consider
their implementation. Their success, however, depends on several factors.
The first is availability of the necessary legal and technical solutions. Research on that topic
is already in progress5 , and even if Polish law lacks such solutions, it would not be too difficult
to adopt legal models developed in other EU countries and the United States.
5 Żor example research conducted by the Allerhand Institute in Krakow (Allerhand Institute, 2011).

The second and most important factor is the will of the shareholders, management elites
and the working people, who have to decide whether they want such solutions in their
companies. This question cannot be answered easily, as the answer is related not only
to the interests of these groups, but also to deeply-rooted values that might not favor financial
participation. Equally important is the attitude of trade unions towards financial participation,
which seems, to date, to be neutral. What we need is to clarify these attitudes with the help
of research, education and promotion in a broad, open discussion.
The third factor is the political will to address this problem. So far, there is no such clear
intention in Poland. However, this could change under the pressure of interested social
groups.
To conclude, we need to learn from the most advanced countries and companies
how to make financial participation work for the mutual benefit of enterprises, employees
and society as a whole.

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