Table 4.
Follow-up of sick-listed employees, support and dismissal in the Nordic countries (Sweden, Denmark, Finland, Norway and Iceland) and in Germany, the Netherlands, Belgium and the UK.
| Denmark | Finland | Germany | Norway | Sweden | The Netherlands | Iceland | Belgium | The UK | |
|---|---|---|---|---|---|---|---|---|---|
| Dismissal of sick-listed possible? | Yes, but depends on the type of contract | Yes, but not only because of illness | Yes, but the employer must be certain that the employee will not get well | No | Yes, if the employer has done all they can to facilitate return to work (RTW) | No | Yes | No, it is prohibited to terminate the contract because of sickness a | Yes, if the employee cannot do his/her job and no reasonable adjustments can be made, it may be fair for the employer to dismiss the employee, even if disabled |
| Sanctions in the system? | Yes, the employer can send a warning to employees with extended sick-leave, and this can lead to dismissal | Yes, sick-pay can stop if the employee does not deliver the 90-day evaluation by the occupational health services (OHS), made in collaboration with the employee and employer | Yes, the employer can send a warning to employees with extended sick-leave, and this can lead to dismissal b | Yes, the employer can dispute the sick-leave | Yes, if the RTW plan is poor and not followed up, the caseworker can report the employer to the labour authorities | Yes, if the employer and employee do not comply with carrying out an evaluation (after 52 weeks and 2 years), they can be fined* | Yes, the employee can be dismissed | Yes, there are sanctions (suspension of salary) if the employee does not provide a medical certificate | Yes, the employee can be dismissed |
| Who assists the employer if the sick-leave is prolonged? | The job centre in the municipality | OHS and occupational rehabilitation actors | OHS and prevention companies | The local Labour and Welfare Office and the OHS or work centre | If the employee does not fulfil his/her responsibility, he/she can turn to the trade union. There is an opportunity to engage the Swedish Work Environment Authority if the problem is considered to be a structural one | Occupational physicians, whose main task is to translate the medical diagnosis into work ability. Only work ability information can be communicated with the employer to safeguard privacy | The employer can buy services from the private sector | Controlling doctors who can be sent by the employers to check the status of the sickness of employees at any moment | Different advice services are available to employers for consultation |
| What competence do these actors have? | Labour market competence, social work and occupational health | The OHS has occupational health competence, but occupational rehabilitation actors have varying competences | Various | Social security, labour market and health if OHS are available | Various | Translate the medical diagnosis into work ability | Not relevant | Medical doctors | Various |
| Does the system differentiate between work-related and non-work-related sickness absence? | No, no differentiation between ‘social risk’ and ‘occupational risk’. Occupational accidents are compensated from separate insurance | ||||||||
a: Dismissal of an employee with a permanent medical health condition will only be allowed if the occupational doctor confirms that the employee will never be able to perform any job within the company.
b: The employer has to go through a statutory process to determine the incapacity for work.