This paper aims to provide comparative analysis on Indonesian regulation on employee participation in contrast with Germany’s regulation on co-determination. This paper used normative method with a combination of statute approach and comparative approach. The implementation of labor union and employee stock participation under Indonesian law to guarantee employee participation in the decision making of companies is still ineffective. The concept of direct employee participation under German law should be seen as a feasible means to guarantee employee participation, thus improve Indonesia’s corporate governance. This concept can be implemented in Indonesia through two ways: the amendment of the Company Law or another implementing regulations that provides a more specific guidance to complement the Company Law.
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