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I don’t get it why the US company layoff culture is so different from what I’m familiar with, the European one. What are they afraid of that people need to be l
by rollulus 3y ago
I don’t get it why the US company layoff culture is so different from what I’m familiar with, the European one. What are they afraid of that people need to be locked out? That one brings a gun to work? Here you get laid off, get a notice, are expected to continue working for a while (but depending on your work ethic you’ll take it easy), consume your remaining PTO, complain to your coworkers about what happened during a farewell dinner. So much more humane.
- mrweasel 3y agoHonestly given Oktas recent security problems I don't blame them from be very pro-active in deactivating accounts, but the ways it's handled though is just inhumane. At least have the balls to call people, give them instructions and let them know that their account is being disabled during the call. For companies like Okta, and a few other high security positions, it's not uncommon for companies in Europe to simply pay people do to nothing for their remaining time.
- sushibowl 3y agoI think the answer is pretty simply due to the difference in laws. In the US no notice is legally required. As you noted, employees that already know their employment is shortly coming to an end generally don't perform to the same level. Therefore it is in the company's interest to give no advance notice whatsoever until employment is officially, actually terminated. In every European country, there's a legal requirement to give notice. And therefore there is an incentive for the company to maintain amicable relations during the notice period to try and prevent trouble.
- gabrielgio 3y ago> In the US no notice is legally required. Required or allowed? So in the US you can't give notice?
- dspillett 3y agoI think you've read that wrong. It is probably better phrased as “In the US, notice is not legally required”.
- ricardobeat 3y agoIf you’re asking about resigning as an employee, it seems to work the same way: legally speaking, you could just stop showing up from one day to the next. I imagine most of the time people will have the courtesy of giving 1-2 weeks notice if possible.
- wccrawford 3y agoIt's not just courtesy. For many local companies, the business owners will know each other and will let other business owners know if someone quits without notice, and so it's harder to get hired after that if you don't give notice. That said, sometimes the company will decide that they'd rather you just go, and they'll tell you not to bother giving notice and you can leave immediately. Someone in another comment said that was because of bad blood, but it's also because of risk and it's unlikely that a person will be very productive during a short notice period. When there's a tricky hand-off, though, the company might ask for and incentivize a longer notice period, too... So nothing's written in stone.
- thunfischtoast 3y agoWhat bugs me: in most companies, especially ones where people do mostly knowledge-based work like Authy does, almost everyone has some kind of unique information on them. No matter how good your project management and code base, most people carry some kind of valueable knowledge in their head that only becomes apparant as soon as they are not there anymore: something like how to log into certain systems, backup schedules, currently pressing issues etc etc. In my opinion the most important thing that needs to be done during offboarding is transfering as much of this hidden knowledge as possible into the company. How do they proceed operating after kicking people out without prior notice? Do those projects just get stomped and started over with new people?
- soco 3y agoWell, yes, but actually no: you can easily give notice then lock them out, you just have to pay them over the entire notice period as the law says. It's not commonly done but in special cases of really bad blood, it will. The law is there to protect the employee income, not to force the employer to give them work.
- lopis 3y agoThis has been my experience in most cases. When an employee is terminated, they are sent home and paid the rest of their time, to avoid risk of vengeful acts or whatever.
- matsemann 3y agoNot only do you have to give notice, but here in Norway you also have to include employee reps and follow a strict process. Part of that process is to define criteria for how to determine who should stay or go. Then after notifying the employees about the ongoing reduction, each employee should have the opportunity to discuss with their superiors how they fit the criteria or if there are other roles in the company they could fill. And then at a set time the actual layoffs will be announced. So it's virtually unheard of to show up, hear about layoffs, and not have a job the next day. Unless it's a situation where the whole company is going bankrupt or so.
- raverbashing 3y agoThe notice period is mostly monetary. 30 days notice means you should pay for that time, but having the person actually work is optional (if you're being terminated)
- Scarblac 3y ago> Therefore it is in the company's interest to give no advance notice whatsoever until employment is officially, actually terminated. That doesn't follow at all. The notice period exists so you can transfer your knowledge and projects to colleagues who will take over your work. If the notice period is in the company interest when people leave on their own, it's also in the company's interest when they have to leave?
- sumuyuda 3y agoThe notice period also exists so you can find a new job and aren’t immediately out on the street like in the US. It is both in the interest of the company and employee, as neither can terminate the contract immediately.
- sokoloff 3y agoThe big difference between those two cases is when it's the company's decision, they have plenty of opportunity to plan for the transition and may frequently conclude that they've done enough for the transition before the conversation with the employee.
- mytailorisrich 3y agoThis is not the "European culture", which I am not sure exists as one on this issue. I have seen many times people be quickly "locked out" when being laid off. A term for this in the UK is "garden leave" because you're still paid but you're told not to work or come to the office anymore. As the case may be this makes sense in order to avoid any issues (from bad blood in the office to actively malicious actions) and, realistically someone being laid off is not exactly going to do their best work, anyway... Edit: Personally I think a quick cut is better as it avoids having to continue going to the office when you know it's pretty much pointless and it allows to focus on your next step. The thing is that it brings home the fact that this was all a business arrangement despite all the emotional attachment we may develop over time.
- Keirmot 3y agoGarden leave also happens in Portugal, but only when the relation between employer and employee deteriorated to the point of no return. As an example in the same company I had a co-worker layed off with 3 months notice, while in the previous year a different person in the same team was called to HR during the day, and let go - we all found out he was fired on the next daily stand up.
- mytailorisrich 3y agoWell, if you're fired it's either that your performance was inadequate or that you did something serious enough. In the latter case, in general there is no notice period and in the former, well obviously they don't want you around anymore...
- mytailorisrich 3y agoFor those who might not know: To be fired is not the same thing as being laid off. To be fired meand being at fault, hence my previous comment.
- DrBazza 3y agoI've seen the 'bad blood' issue happen at a place I formerly worked at, that I refer to as 'MegaBank' (which isn't short of the truth). One was developer that seemingly left on good terms, but sneakily deleted a load of prod data as he was 'clearing down his inbox', and another that smashed up an office. Which was why, after the latter, the 'reduction in force' meetings were conducted on a separate floor with security guards.
- tgv 3y agoI had that experience with a US mother company of a European subsidiary (of a subsidiary). CEO swings by, as he does once per year, and fires the whole dev team, including the local branch manager, because they'll take over in the US (they couldn't, and then bought a competitor instead; the original product is still running, 15 years later), and we were told to leave the building. I had a program building something for an unusual client project, but I had to close the laptop, and that was €60k down the drain, probably more if the project had been successful. Since then, I've avoid companies with US ties.
- sksksk 3y agoWhat country was this? If it was a European subsidiary, then would you have not have been subject to the employment protection of the country's laws?
- throwaway11073 3y agoSure - in most EU countries, especially to the east, they get some additional money (usually 1-6 months of wages + unused vacation days). That's about it. I don't know why people think it's not possible to fire people in the EU, but it is and it's a normal thing. It just costs some money.
- rjzzleep 3y agoIt is possible, but if someone does whatthe parent described like that in Europe, you get more than that and you could walk out of there with your laptop and nobody would be able to stop you, and if they did, you'd probably get more than 6 months of wages. There is a process to firing. EVEN in the US there is a process of firing. The big lie is that most people are fed, is that in "right to work" states you have no legal recourse. You do, but not if you take the severance and sign your leave papers, because you panic right away. Something I didn't know either in the US. The most important rule my (senior) friend once told me is to document everything, especially when your bosses make you do something that you feel uncomfortable with. Print emails if you have to and put them in a folder that you might never have to open if you're lucky.
- glitchalumni 3y agoNot sure which part of Europe you are referencing, but from the layoffs I've seen and heard of (DACH) the procedure was always to lock the person out immediately after the layoff call/meeting. If that's good or bad is rather subjective, personally I would rather walk out the door right after. One might have enough time to send their farewells, but that's about it - you are still getting payed until the end of the notice period of course. (let's not talk about severance packages, they are either non existent or a joke - you often also have to sign an NDA prohibiting you to talk about the package and the layoff in general). So basically companies pull the same questionable stuff in Europe as well, it's far from the fairytale you sometimes read about. (there are always exceptions ofc)
- wouldbecouldbe 3y agoNot sure, I haven't seen mass layoffs, but individual ones. Normally it's a contract ending not being renewed, or the trial period, often the employee is then still active for 1-3 months; till the contract ends. It's rare it's immediate and if it is there needs be an agreed fee for termination.
- rad_gruchalski 3y ago> you often also have to sign an NDA you don't have to, that they arm wrest you, sure, but you don't have to do anything
- deleted 3y ago[deleted]
- glitchalumni 3y agoSure, you can always say no to a couple of grand. (referring to voluntary severance packages, not whatever the legal construct of your country guarantees - which btw is a laughable amount most of the time)
- e12e 3y agoAt least in Norway the guiding principle in law is that the employee can and must work out the grace period, and locking an employee out is illegal. It's possible to mutually agree to exceptions or be granted an exception - but the latter is rare.
- the_mitsuhiko 3y ago> I don’t get it why the US company layoff culture is so different from what I’m familiar with, the European one. Personal bias? Layoffs/Firing etc. in Austria in IT look very much the same. You're locked out, your devices are taken, you are escorted out of the office. That has nothing to do with being afraid, it's just a clear cut process. Why make it ambiguous?
- Draiken 3y agoI agree it's a process (not very clear everywhere though), but the reasoning is 100% being afraid of what the employees can do. If the company could keep reliably profiting off of the employee during its notice period, why wouldn't they? It's all about mitigating the risk. Personally when I left, I've always spent weeks finishing off what I was doing, adding/updating documentation and generally passing on any knowledge that could potentially leave with me. They allow that because they're not afraid I'm gonna delete their source code, since I'm choosing to leave. If the company didn't see risk after layoffs, that's how they would react. And let's be real here: this is mostly a threat when layoffs are not justified. So to keep it simple and streamline the process, they treat every layoff the same.
- rglullis 3y agoAmericans don't understand/trust/respect institutions. Because they don't trust institutions, if someone that is working for a company and does something bad, or is shown to be corrupt, it will affect the public perception of the company, not of the individual. Also, because Americans don't trust institutions, a lot of the internal processes and cultural values are upheld by the individuals, and how strongly this is done depends on the individual's power and ability to influence. This applies to all levels of the organization. This allows for the organization as a whole to be more dynamic and effective, but the downside is that this works only when the individuals have a vested interest in the organization. When there is a layoff, or even when a simple individual is fired, this mutual alignment is removed and all bets are off. Except for fear of legal retaliation, the individual is no longer bound to the organization. This can lead to things like: - Executives preempting the communication of their firing and using it to swing internal opinion, or even taking key team members away with them, like Sam Altman vs OpenAI. - Employees with access to (supposedly) restricted areas copying sensitive information: E.g, sales reps getting data from all their clients to contact them and move them along. - Plain old espionage / sabotage. Don't forget, if a company is laying people off it means they are not doing well, and if they are not doing well means they certainly want to keep as much of what is "really happening" to themselves. Fired employees can use their internal communications to gather evidence from their boss wrongdoings, find internal memos and share with journalists willing to get a scoop, etc.
- cmbothwell 3y agoThis is a very incisive and insightful take and really distills some large cultural differences between Americans and Europeans down to its essence. Can I ask if you are American or European? How did you come about this insight?
- rglullis 3y agoBorn and raised in South America. Lived in the US for ~5 years (2008-2013). Living in Germany since 2013. :)
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- dkobia 3y agoThis is a typical approach for SaaS companies - especially ones that house sensitive data like Okta/Auth0. A CISO’s nightmare is someone who’s been laid off, disgruntled and still has access to the network.
- kypro 3y agoThis does seem to be a lot more common in the US, I actually had this happen to me while working for a US company and the author's experience was very relatable – I was immediately locked out of my accounts and couldn't even say goodbye to the people I had been working with for the last several years (I was working remotely at the time). But I've seen it in the UK too... Specifically one corporate I worked for sent a mass email to everyone on a Thursday afternoon saying something along the lines of "please ensure you're in the office tomorrow morning". Then on the Friday morning people were called into a room one by one, told they had been made redundant and were immediately escorted off site by security. This was just a fairly regular retail business too. Nothing that you would think required such an extreme approach. I suppose I understand it in some ways though... If you've just told someone you've lost your job you're probably not going to be very motivated to continue to work. And suppose there is some risk people might try to disrupt business activities in protest... I think it probably is better to give employees their redundancy pay and let them move on rather than waste their time for several weeks. That said, I'm not sure why the security escort was needed in this case. The layoffs came from McKinsey's infinite wisdom though, so it wouldn't surprise me if the security escort was their recommendation to reduce risk.
- Someone 3y agoA reason I’ve heard for not keeping those laid off around is that you want those who stay to look to the future, not to what was, and that’s what those who got fired will do, because they don’t have a future at the company.
- _cenw 3y agoI had a job I referred my spouse to. The team she was in had some reservations, but nothing that couldn't be addressed, essentially a bit of temperament by culture shock young talented engineers tend to have on their first or second job. But the HR person assigned took the entire next year off, so she did not get any feedback except from her boss, who said everything was fine. Another feedback round got delayed for the next 3 months because someone on the team was sick, and eventually her delayed "team feedback round" appointment changed to one with HR, in which they fired her "just in case it was still a problem". That was the only time I've seen someone completely locked out - in Germany. She couldn't even complete the normal offboarding, because her building access was revoked, and the company didn't have an alternative process, so I had to bring it in, where people would agree with me that it was a process failure, and that they were very sorry, but not sorry enough to tell it to my spouse's face. That work relationship didn't last long after.
- pcl 3y agoI find the "lock out and leave immediately" thing to be pretty weird, and perhaps US-specific. But! The Nordic approach is also bizarre! The norm is that employees keep working for 3 months after giving notice. There are, of course, plenty of exceptions. The "normal exception" is that if someone quits and the business thinks they are going to go to a competitor, they'll leave the premises within a few days, but continue as a paid employee for the remainder of the time -- known as "garden leave." In either case, though, the employee doesn't start working at their new job for three months!! In my experience, it's super-stifling, especially for startups, since three months is an eternity for a new company. Of course, in the tech industry, nobody really does all that much work for at least the trailing two months, since who's going to get assigned to a new project just before they leave? I guess this is perhaps sorta how things play out in areas of the US that allow noncompetes to be enforced, too.
- mickeythug 3y agoIn some parts of Europe, it is very common to do “mutual termination”, since you cannot easily fire someone just on a whim. If you use the “redundancy” excuse, companies are usually prohibited from hiring again on the same position for 6 months. If you want to fire someone and not face this, there’s a very detailed process of what you have to do, before you can justify termination (documented first warning to the employee, steps they need to take to improve, second warning, proof that they didn’t so what was asked of them, etc). Virtually no one goes through this, and they opt for mutual termination, and generally a person can negotiate a severance package for their signature (I have seen examples of people negotiating almost a year’s salary as severance), and they are out immediately. But this is also a scare tactic and people get caught by surprise and sign anything, sometimes without any severance. During this past year, as mass layoffs were happening in waves, people got more informed about this and were smarter in negotiating their exits.
- iamacyborg 3y ago> What are they afraid of that people need to be locked out? That one brings a gun to work? So I'm a Brit who briefly worked over in Alabama for a few months and yes, that was a genuine concern with some of the folks that were let go by the company. It was well known that quite a few staff members had firearms in their vehicles.
- ryandrake 3y agoWhen I lived in Florida, we had a guy who, upon learning he was fired, loudly threatened to come back to the office with one of his AK-47s and mow everyone down. He shouted this across to everyone in the single-floor open office as he was being physically removed from the building. And we knew he had multiple guns because we did a few company outings at a shooting range. You better believe he was locked out as soon as he could be removed from the building, and we had armed security there for some time after his termination.
- sokoloff 3y agoAt my second job, the company terminated an employee for poor performance and intended to let them stay on a short term to wrap things up and then start their severance. The first evening (or maybe the first Friday evening), that dev stayed late in the office and deleted the source trees from as many machines as he could get access to (this was 1996, so most machines didn't have logins) and wiped the hard drive on the revision control server. That experience (and the amount of loss and wasted time in reconstructing as best we could) heavily colored my view of the risk-reward ratio of letting terminated employees have continued access to premises and systems. If I have any doubts about the future behavior of someone who just received very shocking, disorienting, and angering news, it is my job to protect the company and other employees much more than it is to allow the terminated employee continued access.
- supriyo-biswas 3y agoAlso see the case of Shannon You[1] where the person in question leaked the trade secrets for BPA-free liner production used in soft drink cans for being fired. [1] https://www.justice.gov/usao-edtn/pr/phd-chemist-sentenced-168-months-conspiracy-steal-traded-secrets-economic-espionage https://www.justice.gov/usao-edtn/pr/phd-chemist-sentenced-1...
- anonexpat 3y agoYou’s case was deliberate corporate espionage, not a disgruntled former employee.
- madsbuch 3y agoGiven that this is the US, he was probably sued and is still in prison. Also, this is an insanely childish way to act – again to the original commenter. It it seems like there is a difference in US an EU culture here.
- dylan604 3y ago> Given that this is the US, he was probably sued and is still in prison. Like most things in life, it depends. You'd have to get a prosecutor to agree to accepting the case to bring charges against the individual. They'd have to decide if there was enough evidence, they'd have to decide if they thought they could convince a judge/jury, then they'd have to decide if it was even worth their time. In 1996, that might have been a more difficult thing to do than today. > Also, this is an insanely childish way to act Yeah? And? So? Are you attempting to say that no non-American has ever acted irrationally or childish? I have a few history books that would disagree
- Foobar8568 3y agoI have seen a company firing one of their developer who went to Europe on a 2weeks business trip to assist a NGO to implement their tool. One day, said developer couldn't access their emails and was wondering why. At the end, it was the NGO/client who let the dev informed.
- mgaunard 3y agoIn Europe, for some jobs, you'll be granted garden leave, i.e. you can stay home during your notice and still be paid. It's essentially a mechanism where they avoid having someone with a negative mentality that's not going to work hard anyway around the office.
- ollysb 3y agoGardening leave is usually for positions where the employee holds competitive information on active deals etc. During the gardening leave they're under NDA which allows for their competitive information to go stale before starting at a new company.
- mgaunard 3y agoNon-disclosure, non-compete and notice are different things that you're mixing together. Notice is compulsory -- you simply cannot let go of the employee immediately and must continue paying them for 3 months (or up to 4 months in some countries where every calendar month started is due). Non-compete is opt-in by the employer, and allows them to prevent you from working for a competitor (for up to one year I believe). In exchange the employer must still pay your previous salary (some employers will ask employees without compensation, but that's not legally enforceable). Non-disclosure means that you're not able to disclose company and trade secrets, similarly to an NDA. It is a standard term in most employment contracts and usually applies for one year, regardless of the non-compete being enforced or not. It is fairly common to send people for garden leave during their notice, but actually extending it further by enforcing the non-compete is a costly thing and will only be done for strategic employees.
- brk 3y ago>I don’t get it why the US company layoff culture is so different from what I’m familiar with, the European one. Not trying to single you out, but these kinds of comments always baffle me. Around the world, we have different religions, cultures, languages, customs, currencies, holidays, skin colors, legal structures, etc. And then someone is confused why people on the other side of the world don't do things the same way. For me, as a product of all of the things above in the US, if a company tells me they no longer need my services, then I am not going to keep working for a while. That doesn't mean I am going to be spiteful, but just that I acknowledge their decision, and so I will move on to something else. To me, continuing to work alongside (former-ish) teammates in a dead man walking situation seems strange, but I can see why it might work in Europe.
- artyom 3y agoBecause losing your job is really a bummer everywhere, but in Europe you've got a lot of things covered by the welfare state (how well, it's a different discussion), so it's less stressful, which reduces the probability of people being really pissed. In the US, you're probably out of healthcare in the blink of an eye, may have no severance, no coverage, no unemployment benefits, and in some cases it'd mean deportation. So yeah, two different worlds.
- rescbr 3y ago> and in some cases it'd mean deportation. I completely understand the shittiness of this issue and I'm not from a developed country, but I mean, this is the reality of a temporary work visa, no? I might be more pessimist/realist, but until I receive a permanent residency visa, I'd treat everything as temporary, ready to move back in a couple days notice.
- cptskippy 3y agoIn the US there's an H-1B Visa program that allows skilled workers to come over as a path to citizenship. However the program is fraught with all manner of requirements like company sponsorship. Changing jobs under the H-1B program results in your journey to citizenship being reset, and current bureaucracy and politics have resulted in that journey taking upwards of a decade or more. As a result of policy, H-1B workers will take substandard pay, abuse, and burdens to maintain a job with a company willing to sponsor them until they can get their Green Card. This creates a from of indentured servitude. The knock on affect is that it lowers wages for everyone because there's a vast pool of skilled workers willing to accept lower pay from a company willing to maintain sponsorship of them for 10+ years. Imagine on year 9 you get laid off, now your indentured servitude got extended another 10 years if you can find a new sponsor.
- estebank 3y agoIn (some?) other countries work visas are not tied to employer but rather job category, and the length of time waiting for permanent residency is usually 2 years. In the US an H1B can be transferred once you reach the portability threshold if you can find another employer, and depending on the country of origin you can be waiting for permanent residency (green card, not citizenship) for 2 decades. An L1B is tied to an employer and you're effectively illegally in the country as soon as you're laid off. In practice the government gracefully gives you a week to completely uproot your life and get the hell out. I was lucky, I went from arriving in the country to receiving citizenship in ~10 years, but the 4 years trying to get permanent residency were the most stressful of my life, and being spared by layoffs did little to help. Even being privileged knowing you can go elsewhere, and fully open eyed about the situation, it still sucks.
- andrewaylett 3y agoThe UK has rules about such things. If your job is at risk of redundancy, there are formal processes to follow. If enough jobs are at risk of redundancy, there's a whole consultation process that needs to happen before people are actually "made redundant". People are expected to work while that takes place. Money can smooth things over, though. The process is expensive, and has to be done properly, or the company can offer "voluntary redundancy" where they pay you to go away quietly. That happened to me. I don't know whether I was locked out or not, because I didn't try to log in again.
- tw04 3y agoWho would want that? The US style is the best of both worlds IMO. By cutting you off immediately the company protects itself from rogue employees who may try to harm the company while their access is still enabled. For the employee, being cut off means you don't actually have to do anymore work for a company that's letting you go. You're either getting severance or you aren't, and I'd much rather collect severance while not having to work. In the instance that they're letting you go without severance: yes that's horrible they just pulled the rug. But usually that's a result of poor performance and you probably should've seen it coming. And frankly that's also why we have unemployment.
- Repulsion9513 3y agoIt's definitely a thing in the UK as well, at the very least. https://en.wikipedia.org/wiki/Garden_leave https://en.wikipedia.org/wiki/Garden_leave
- deleted 3y ago[deleted]
- paulddraper 3y ago> So much more humane. I'd 100% rather get 3 weeks severance than get paid to a couple more months (or whatever). --- Also, the whole "security escorting you out" schtick...I'm certain that happens, but I've never seen it personally.