The prohibition of forced labour and the right to freely chosen work: a comparison of Denmark, the Netherlands and the UK
The prohibition of forced labour and the right to freely chosen work: a comparison of Denmark, the Netherlands and the UK
This chapter uses the six legal safeguards, identified in chapter 4, that concretise the proportionality test under the prohibition of forced labour and the right to freely chosen work to evaluate the national social assistance legislation in Denmark, the Netherlands and the UK. The analysis shows that none of the national legislation complies with all six safeguards. The Dutch legislation stands out for its lack of legal regulation with respect to the duty to participate in work programmes. In addition, a comparison between the Danish and the British WTW law shows that, while the Danish legal provisions aim at a collaboration between the recipient of social assistance benefits and the authorities, the British provisions reflect the aim of the national authorities to control the recipient.
Keywords: Comparative social assistance, Welfare-to-Work, Prohibition of forced labour, Right to freely chosen work, Duty to work
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