İşyerinin (veya İşletmenin) Devri ve İşçilerin Korunmasına İlişkin Karşılaştırmalı Bir İnceleme

There are various regulations on the protection of employee (worker) in situation transfer workplace or business Turkish legislation. First, Article 202 Code Obligations (TCO) dated 2011, provides this issue general. Furthermore Articles 428 and 429 regulate conveyance employment contracts. 6 Employment Act (EA) 2003, which partly fully, is based European Union (EU) Directive no. 2001/23/EC relating to safeguarding employees’ rights transfers undertakings, businesses parts undertakings (also named as Acquired Rights Directive). Finally, 178 Commercial (TCC) 2011 regulates relationships case organizational changes companies such merger, division conversion (restructure companies). Among these three Acts, provisions compliance with each other. On other hand, English law, status employees laid down revised Transfer Undertakings- Protection (TUPE) Regulations 2006. TUPE also EU 2001/23/EC. similarities between legislations concerning employees. These differences examined article. Consequently, some arguments proposed.