69) For detailed discussion see AIER Report, pp xiii-xiv, 25-60, 77-112; I gratefully acknowledge the work of the Report's co-authors, especially Peter Gahan, in identifying these categorisations for the three overseas models.
71) Although increasingly, company-level 'opt-outs' from sectoral agreements have become features of these systems: see AIER Report, pp 49-50; A fair go at work, p 55; and, for example, Michael Whittall, 'Modell Deutschland under Pressure: The Growing Tensions between Works Councils and Trade Unions' (2005) 26 Economic and Industrial Democracy 569.
74) See AIER Report, pp xvi-xvii, 61,63-64, and Appendix 2.
