Newsletter Employment Law IV/2016

 

IV /2016

As the year 2016 draws to a close we would like to inform you about a number of decisions and legislative amendments that are of employment law relevance. The increase in the statutory minimum wage as of 1 January 2017 and the reform of the Temporary Employment Act which has also now been passed by the Bundesrat and will enter into force on 1 April 2017 will have noticeable effects upon business practice. Whether there will be any legislative activities at all during the election year 2017 remains to be seen. In all events, the employment courts will be contributing with new decisions towards the constant development of employment law in Germany. For example, in its most recent decision dated 13 December 2016 the BAG affirmed a codetermination right of the works council pursuant to Sec. 87 Subsec. 1 No. 6 German Shop Constitution Act [Betriebsverfassungsgesetz, BetrVG] in cases where the employer has set up a public commenting function on its Facebook page via which users can comment on employees’ conduct. In view of its significance, we will be discussing the BAG’s decision in detail once the reasons for the decision have been published.

 

1. Current case law

1.1 No obligation to attend a personnel talk whilst incapacitated from work
1.2 The (to all intents and purposes - familiar) problem of the one-week deadline of Sec. 102 Subsec. 1 BetrVG
1.3  A regulation in the collective bargaining agreement limiting the term of employment contracts to up to five years without an objective reason is valid
1.4 Direct insurance and pension fund – choice of insurance-oriented solution upon premature departure from the company
1.5 Caution: EUR 40 lump-sum damages for wage payments
1.6 Uniform assessment of the need to participate in a works council training event
1.7 Compensation of tax damages on grounds of a severance payment disbursed before it was due?

2. Legal developments

2.1 Entry into force of the amended German Workplace Ordinance
2.2 Increase of the statutory minimum wage as per 1 January 2017 to EUR 8.84
2.3 Act on temporary employment enters into force on 1 April 2017
2.4 Employment law aspects of the Corporate Social Responsibility–Directive

 

1. Current case law

 

1.1 No obligation to attend a personnel talk whilst incapacitated from work

In its decision dated 2 November 2016 (docket No. 10 AZR 596/15), as yet only available as a press release, the Federal Employment Court [Bundesarbeitsgericht, BAG] stipulated further regulations to be observed by employers in the handling of employees incapacitated from work due to illness.

The employee in question had been incapacitated from work due to illness from the end of November 2013 to mid February 2014. The employer had invited the employee to a personnel talk at the company on 6 January 2014 to clarify further employment possibilities. The employee refused to attend, making reference to his incapacity to work. A further invitation by the employer to a personnel talk to be held on 11 February 2014 was also not accepted by the employee and he also refused to provide proof of the particular reasons for his refusal, which had now been demanded by the employer. The employer subsequently cautioned the employee.

The employee’s legal action to have the caution removed from his personnel file was successful in all three instances. The BAG established that the employee was under no work obligations or related ancillary obligations during his incapacity to work. He therefore did not have to appear at the company. However, the employer is not fundamentally denied the right to contact the employee to a reasonable degree during the latter’s incapacity to work in order to discuss questions concerning his further employment after the end of the period of incapacity to work, presuming the employer’s legitimate interest herein can be established. An obligation to appear at the company, however, only exists if this is unavoidable for operational reasons and if the employee’s health fundamentally permits his attendance.

It comes as no surprise that the BAG sets very narrow parameters for an employee’s obligation to appear at the company for a personnel talk whilst incapacitated from work, which will only rarely be fulfilled in practice. All the more positive is the BAG’s remark that the employer definitely is entitled to already discuss with the employee whilst he is still incapacitated from work due to illness the possibilities his further employment in the period thereafter. Particularly in cases of lengthier periods of illness, a legitimate interest can be affirmed in the light of the employer’s personnel planning needs. In case of periods of incapacity to work of over six weeks per year, this interest also arises from the employer’s obligation to conduct a company integration management programme [Betriebliches Eingliederungsmanagement, BEM] (Sec. 84 Subsec. 2 German Social Code Book IX, [Sozialgesetzbuch IX, SGB IX]), which also can (and must) be initiated during the incapacity to work. It goes without saying that a sensitive handling of the matter always helps in such cases.

Kathrin Vossen

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1.2 Inadmissibility of evidence in case of a use of detective services in breach of data protection provisions

The Regional Employment Court [Landesarbeitsgericht, LAG] of Baden-Württemberg recently had to decide whether detective services that had been ordered by an employer on grounds of a suspected concrete breach of contract by the employee were justifiable via Sec. 32 German Data Protection Act [Bundesdatenschutzgesetz, BDSG] (LAG Baden-Württemberg dated 20 July 2016, docket No. 4 Sa 61/15).

The claimant had been employed at the defendant since 1978. He had been incapacitated from work due to illness several times during the year 2014 and had been constantly off sick since 20 January 2015. He was suspected of having worked for a competitor during this time and of having merely feigned his incapacity to work. To clarify the matter further the defendant hired a detective who, in June 2015 in particular, approached the competitor as a customer, found the claimant – who was incapacitated from work due to illness at the defendant – conducting assembly work there and was given a tour of the “family-run business” by him. The defendant subsequently declared the extraordinary termination of the claimant’s employment relationship, alternatively the ordinary termination, on suspicion of anti-competitive activities for a competitor and of feigning incapacity to work, and demanded from the claimant the reimbursement of his continued salary payment during illness, compensation of the detective’s fees as well as information on the competitive activities.

The LAG granted the unfair dismissal action and rejected the defendant’s claims to payment and information. Although anti-competitive activities for competitors and the feigning of incapacity to work are fundamentally suited to justify an extraordinary termination, a strong suspicion to this effect could not be established by the LAG. In particular, on grounds of a suspected breach of Sec. 32 BDSG, the detective’s findings were not admissible in the proceedings. The detective’s work in June 2015 had not been suited to disclose a criminal offence perpetrated within the employment relationship because the claimant no longer received the continued payment of his salary at this time and, consequently, could not have committed any fraud (Sec. 263 German Criminal Code, Strafgesetzbuch, StGB]) to the detriment of the defendant. Fraud to the detriment of the health insurance company through his receipt of sick pay also did not constitute a criminal offence “within the employment relationship” pursuant to Sec. 32 Subsec. 1 sentence 2 BDSG. Anti-competitive activities for a competitor were also generally not classed as a criminal offence. Moreover, on grounds of the clear wording of Sec. 32 Subsec. 1 sentence 2 BDSG, the justification of the collection of data by using a detective in case of an otherwise severe breach of a contractual obligation which is not a criminal offence, did not come into question. Other circumstances beyond the detective’s observations were also not suited to support a strong suspicion. The mere sighting of the claimant’s vehicle on the company premises of the competitor during periods of his incapacity to work did not allow one to conclude in all probability that he had rendered employment services or feigned his incapacity to work. It also did not suffice that the competitive enterprise had touted the claimant’s skills in its advertising vis-à-vis third parties.

This decision impressively shows how a strict interpretation of individual statutory norms and in particular of the requirements which must be fulfilled to meet the justification criteria of the BDSG can lead to such dissatisfactory results. The LAG’s appraisal of the legal situation in this connection is by no means compulsory, for according to what is certainly widespread and correct opinion, Sec. 32 Subsec. 1 sentence 1 BDSG also comes into effect in cases of a breach of duty within an employment relationship, which could have justified the detective’s assignment in the present case. The LAG had rejected this because it supposedly only covers those measures which are not aimed at disclosing concrete suspects. We therefore eagerly await the BAG’s decision in the appeal on points of law expressly admitted by the LAG (docket No. 2 AZR 597/16). 

Kathrin Vossen

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1.3 A regulation in the collective bargaining agreement limiting the term of employment contracts to up to five years without an objective reason is valid

In its judgement dated 26 October 2016 (docket No.: 7 AZR 140/15) the BAG affirmed the validity of a collectively bargained regulation which permits the limitation of the term of an employment contract to an overall period of five years without an objective reason and with the possibility of extending the contract five times.

The claimant was employed at the defendant as a commercial employee from 15 January 2012 until 31 March 2014 on the basis of a fixed-term employment contract which had been extended once. Pursuant to an applicable collective agreement, the limitation of the term of the employment contract without an objective reason to a period of up to five years was permissible. Up until this overall term, the contract could also be extended for a maximum of five times. The claimant deemed the collective stipulation invalid and contested the limitation of the term of his employment contract on this basis.

As in the previous instances, his complaint was also unsuccessful before the BAG. The BAG justified its decision - which is as yet only available as a press release – by stating that the envisaged possibility of limiting the contractual term was covered by the collective bargaining parties’ regulatory power arising from Sec. 14 Subsec. 2 sentence 3 German Part-Time and Fixed-Term Employment Act [Teilzeit- und Befristigungsgesetz, TzBfG]. Although this regulatory power of the collective bargaining parties is not without boundaries for reasons of Constitutional and Union law, the structuring framework of the collective bargaining parties arising from Sec. 14 Subsec. 2 sentence 3 TzBfG does permit provisions through which the values stated in Sec. 14 Subsec. 2 sentence 1 TzBfG for the maximum period of a limited-term employment contract without an objective reason and for the number of possible contract extensions would be exceeded no more than thrice.


With thrice the legally permissible framework, the BAG states for the first time a maximum threshold for collectively bargained fixed-terms and therewith creates legal clarity, albeit to the detriment of collective bargaining autonomy. If an employment relationship is not governed by a collective agreement, then the statutory provision of Sec. 14 Subsec. 2 TzBfG still applies, pursuant to which the limitation of the term of an employment contract to a fixed calendar date without the existence of an objective reason for a period of up to two years and with a possibility of its extension for a maximum of three times is permissible.

Jamilia Becker

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1.4 Direct insurance and pension fund – choice of insurance-oriented solution upon premature departure from the company

If an employee leaves the employment relationship with a vested pension right before the event triggering the pension, then his subsequent pension claim corresponds to that part of the overall pension achievable by him until the event triggering the pension which has been earned by him by the date of his departure from the company. The employer also has to fulfil this part claim if the pension is provided via an external pension provider such as a provident fund.

However, there is one peculiarity in case of the modes of pension provision via direct insurances and pension funds: here, by choosing the so-called insurance-oriented solution, the employer is able to limit the employee’s claim to the insurance benefit to be paid pursuant to the insurance contract concluded with the pension provider. Because the amount of the insurance benefit falls short of a pro rata expectancy in the event of an employee’s premature departure from the company, employers usually make use of the insurance-oriented solution.

The choice of the insurance-oriented solution is subject to certain conditions, however. In particular, the employer must make a corresponding demand and must notify the employee and the insurance provider of such demand within three months of the employee’s departure from the company. To date, the established practice has been to already exercise the demand through the inclusion of a corresponding clause in the pension promise.

The BAG has now put a stop to this practice (judgement dated 19 May 2016, docket No. 3 AZR 794/14). In the underlying case, the applicability of the insurance-oriented solution was stipulated in a pension shop agreement for the event of an employee leaving the company with vested pension rights. This provision was deemed inadequate by the BAG. Although the demand for the insurance-oriented solution can already be declared prior to the end of the employment relationship, a material and temporal connection with a concretely imminent termination of the employment relationship was necessary at the time of the receipt of the declaration. The employer’s demand serves to procure legal certainty for the employee specifically in the concrete situation of his departure from the company.

 

Employers will have to adapt accordingly and, if necessary, may have to repeat a prematurely declared demand within the prescribed periods; existing processes with external service providers will have to be examined to ensure that the notification and its content are in line with the case law.


Alexander Heider

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1.5 Caution: EUR 40 lump-sum damages for wage payments

According to two recent decisions of the LAG Cologne dated 22 November 2016 (docket No. 12 Sa 524/16) as well as the LAG Baden-Württemberg dated 13 October 2016 (docket No. 3 Sa 34/16), in the event of a or incomplete payment (of a wage), employers also face lump-sum damages in the amount of EUR 40 pursuant to the new Sec. 288 Subsec. 5 BGB.


Although the legal norm of Sec. 288 Subsec. 5 BGB was already inserted into the BGB with effect as per 29 July 2014 in order to combat payment defaults in the course of trade, on grounds of a transitional provision until 30 June 2016 only employees whose employment relationship were established after 28 July 2014 could demand the lump-sum default payment (Art. 229 Sec. 34 sentence 1 Introductory Act to the German Civil Code [Einführungsgesetz zum Bürgerlichen Gesetzbuch, EGBGB]). The two-year transitional period has since expired, which means that since 1 July 2016 all employees can demand the lump-sum damages.

A controversial issue to date has been whether the provision also applies to employment law. Pursuant to the Act, namely, the lump sum has to be credited against the damages insofar as such damages constitute the costs of the legal action. In contrast to civil law, however, in employment law no claim exists to reimbursement of extra-judicial costs of legal actions in the first instance. For this reason, some are of the opinion that, lacking a claim to the reimbursement of the extra-judicial costs of a legal action, the EUR 40 lump sum also lapses.

This opinion has now been expressly rejected by the LAG Cologne (as already previously by the LAG Baden-Württemberg), which established that no exception exists for the field of employment law. The EUR 40 lump sum damages represent an extension of the statutory regulation on default interest, which must also be paid in case of claims to employment remuneration. In addition, the purpose of the statutory revision – to increase the pressure upon the debtor to effect payments punctually and completely – also supports its applicability to the benefit of employees who receive their wage unpunctually or incompletely.

Employers should therefore pay greater attention than they have in the past to the punctual payment of remuneration. In particular, any agreement possibly reached with the employee in advance on the exclusion of this claim will be invalid pursuant to Sec. 288 Subsec. 6 sentence 2 BGB. Because of the fundamental importance of this legal issue, however, the LAG Cologne has admitted the appeal on points of law to the BAG, which means that it remains to be seen whether and what stand the BAG will take on this issue.

Isabel Hexel

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1.6 Uniform assessment of the need to participate in a works council training event

If a training event cannot be booked in modules, but only in its entirety, then the necessity of such a training event within the meaning of Sec. 37 Subsec. 2, 6 sentence 1 BetrVG can only be assessed uniformly. In this case, the necessity is essentially determined on the basis of whether the topics that are required for activities of the works council take up more than 50% of the training time (BAG dated 28 September 2016, docket No. 7 AZR 699/14).

The claimant – the chairman of the works council – works at the defendant and is a member of the integration team established at the business in his capacity as a representative of the works council. According to a shop agreement existing at the defendant’s business, the integration team is to be involved in the execution of the company integration management programme. In November 2012 the works council ruled, against the defendant’s will, to register the claimant for the seminar “Professional Company Integration Management”. The seminar comprised a total of four modules and a closing event. On the registration form it was only possible to book the entire seminar. The claimant attended the first two modules of the training course, each of which lasted three days. The defendant subsequently cut the claimant’s pay for these days. The claimant opposed this action.


Upon the defendant’s appeal on points of law, the BAG repealed the appeal judgment and referred the case back to the LAG, stating that a claim of the claimant pursuant to Sec. 611 BGB in conjunction with Sec. 37 Subsec. 2, 6 BetrVG only came into consideration if his attendance of the training session had been “necessary”. The necessity of the training had to be assessed uniformly if the training could only be booked uniformly as a whole, for the works council could also only decide uniformly on whether or not to attend the training. The training session was only “necessary” if the topics required for the activities on the works council took up more than 50% of the training time. Hence, the LAG now has to check whether the individual modules could have been book individually, respectively whether the necessary topics took up more than 50% of the training time.


The employment court’s examination of the works council’s decision on the “necessity” – whereby it is a known fact that the works council has a margin of judgement - fundamentally uniformly extends to the overall training event unless the modules can be booked individually. The necessity threshold of “more than 50%” is surprisingly low in consideration of the fact that, in the worst case scenario, the employer still has to pay the costs for the unnecessary 49%.

 

Nils-Frederik Wiehmann

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1.7 Compensation of tax damages on grounds of a severance payment disbursed before it was due?

In its decision dated 23 June 2016 (docket No.: 8 AZR 757/14), the BAG had to decide on an interesting problem in connection with the winding-up of an employment relationship.


Within the scope of an unfair dismissal action, the parties had concluded a settlement on 19 April 2011, pursuant to which the employment relationship would end upon the expiry of 31 December 2011. The claimant was entitled to prematurely end the employment relationship in capitalisation of the remuneration becoming available. In addition, the court settlement regulated that the severance payment was to be disbursed “with the regular salary round of the calendar month following the month in which the employment relationship ended”. The claimant did not exercise his right to a premature release, with the result that the employment relationship ended on 31 December 2011. Contrary to the regulation in the settlement, the defendant did not await the salary round in January 2012 before disbursing the severance pay and paying the remuneration for the month of December 2011, but already transferred them on 30 December 2011. The claimant deemed this a breach of the employer’s duties under the settlement and demanded compensation of the tax damage, for if the severance payment had been effected in the year 2012 the tax burden would have been less.


As in the previous instances, the claimant was also unsuccessful before the BAG. The BAG pointed out that, pursuant to Sec. 271 Subsec. 2 BGB, if no performance period has been stipulated, it can be assumed that the creditor is unable to demand performance before this date whereas the debtor most certainly can render performance beforehand. Since the settlement did not contain any provision to the effect that the severance amount could not be disbursed before January 2012, the employer had been entitled to already disburse the amount prior to the period stipulated in the settlement. This actually constituted an agreement on the maturity of the severance payment, reached merely for purposes of determining the time as of which the employer would fall into arrears with the payment.

Even though the claimant’s legal action was unsuccessful, this case nevertheless illustrates the problems which can still arise after the conclusion of a court settlement during the winding-up of the employment relationship. Especially in cases of considerable severance payments, the tax damage can be a sensitive issue in such scenarios. Here, the BAG stated that, during the conclusion of the settlement, the claimant had not expressed any particular interest in a disbursement after 1 January 2012. For this reason the possibility cannot be ruled out that such a case will be appraised differently by jurisprudence if the claimant points during the proceedings out his interest in avoiding possible tax damages. Nevertheless, it is the duty of the employee to make such an interest clear and, for example, through a clear definition of the performance period, to ensure – i.e. in the present case, that the severance would be settled and disbursed in January 2012, and not before or after this date.

 

Dr. Alexander Willemsen

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2. Legal developments

 

2.1 Entry into force of the amended German Workplace Ordinance

On 3 December 2016 the revised German Workplace Ordinance [Arbeitsstättenverordnung, ArbStättV] entered into force. The aim of the amendment is to improve the safety and protection of the health of employees when establishing and operating places of work. It simultaneously aims to make it easier for employers to implement the requirements laid down in the ArbStättV.
  
May we highlight the following points of the revised Ordinance in particular:

  • A controversial issue to date has been the extent to which the requirements of the ArbStättV also apply to workplaces in the home within the scope of a teleworking job. The Ordinance now contains special requirements concerning teleworking jobs. The term “teleworking job” is defined in Sec. 2 Subsec. 7 ArbStättV. It encompasses permanently installed computer workstations within the private sphere of the employed person, but not forms of mobile work such as occasional work on a laptop during leisure time or work that is not tied to a specific place (e.g. on the train).
  • The instruction of employees on industrial safety matters has now been conclusively regulated in Sec. 6 ArbStättV. The requirements as to the content of such instruction have been set down in greater detail. These now have to encompass, in particular, first aid measures as well as fire protection measures, including the use of escape routes and emergency exits.
  • Sec. 3 ArbStättV makes it clear that, within the scope of the assessment of work conditions pursuant to Sec. 5 German Industrial Safety Act [Arbeitsschutzgesetz, ArbSchG], the definition of health encompasses both physical and mental health, and that both elements must be taken into consideration in the risk assessment. To be included, for example, are stress and detrimental effects to employees caused by disturbing sounds or noise, unsuitable lighting or ergonomic deficiencies at the workplace.
  • A new inclusion is the provision that only rooms which receive, to the extent possible, sufficient natural light and that have an outside view may be used as work rooms (Number 3.4 Appendix to the ArbStättV). This requirement also exists in a milder form for break rooms and duty rooms, as well for canteens. Exceptions are envisaged inter alia for rooms in which operational, production-related or structural reasons oppose these requirements, as well as for rooms generally not visited by employees for a lengthier period or in which they only have to stay for a short period (in particular archives, storage rooms, machine rooms and adjoining rooms, tea kitchens). Rooms built prior to 3 December 2016 are excluded from the requirements as long as they are not substantially expanded or converted.
  • The Computer Workstation Ordinance [Bildschirmarbeitsverordnung, BildscharbV] has been cancelled and integrated into the ArbStättV. Its content can now be found in Number 6 of the Appendix to the ArbStättV.
  • The procedure regulated in the Industrial Safety Ordinance on Artificial Optical Radiation [Arbeitsschutzverordnung zu künstlicher optischer Strahlung, OStrV] on the verification of the expertise of laser protection officers has been concretised.

 

Alexander Heider

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2.2 Increase of the statutory minimum wage as per 1 January 2017 to EUR 8.84

The statutory minimum wage will increase as per 1 January 2017 from presently EUR 8.50 to EUR 8.84 gross per hour. This was adopted by the Federal Cabinet on 26 October 2016 within the scope of its approval of the Ordinance Amending the Minimum Wage [Mindestlohnanpassungsverordnung, MiLoV].

The task of the Minimum Wage Commission is to examine the effects of the minimum wage. According to its current report, however, no clear effects of the minimum wage on work costs, productivity, and unit wage costs can be determined. It decides on the adjustment of the amount of the minimum wage every two years, hence for next time in the year 2018 on an adjustment as per 1 January 2019.

For a German overview of the minimum wages in all branches published on the federal government’s homepage (status: October 2016) please click here.

Isabel Hexel

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2.3 Act on temporary employment enters into force on 1 April 2017

After three years of debates in and outside of parliament, the Bundesrat now also formally approved on 25 November 2016 the revision of temporary employment and contracts for work. The Act will enter into force on 1 April 2017. We have reported on this on many occasions. An overview of the most important revisions can be found here.

Isabel Hexel/Jörn Kuhn

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2.4 Employment law aspects of the Corporate Social Responsibility–Directive

On 21 September 2016 the Federal Government published a governmental draft of a CSR-Directive-Implementing Act to Implement Council Directive 2014/95/EU [CSR-Richtlinie-Umsetzungsgesetz zur Umsetzung der Richtlinie 2014/95/EU] (so-called CSR-Directive on the Disclosure of Non-Financial and Diversity Information). Through this, the reporting on specific sustainability topics for a defined target group has been regulated for the first time in Germany. The legislative procedure will be finalised over the next few days, as it was a compulsory requirement that the Directive be harmonised into German law by 6 December 2016. The reporting period begins as of 1 January 2017.


Corporate social responsibility exceeds the compliance requirements, as it does not demand the observance of statutory provisions but that enterprises act in a responsible manner. Of relevance from the employment law perspective is, above all, that the content of the non-financial declaration also extends to employee matters. The provision of Sec. 289c Subsec. 2 HGB-E stipulates in this connection:

 

“(2) The non-financial declaration also covers at least the following aspects:

 

    1. […]

2. Employee matters, whereby the information can cover, for example, the measures which are taken to ensure gender equality, the work conditions, the implementation of the fundamental Conventions of the International Labour Organisation, the observance of the rights of employees to be informed and consulted, the social dialogue, the observance of the rights of the unions, the protection of health or industrial safety.”

 

Furthermore, in Sec. 289c Subsec. 3 HGB-E the Act demands that additional information referring to the aforementioned matters can become necessary. For example, the “concepts”, the “due diligence processes” as well as the “results of the concept” of the company will also have to be presented as additional information. The concepts to be established for the employee matters can cover a multitude of criteria that are subject to a codetermination obligation or at least a cooperation obligation. It therefore must be conceded that the works council can assert rights in the establishment and development of the concept.

Even though the target group addressed by the Act only covers certain enterprises, we must bear in mind that they will ensure that CRS requirements are observed and, accordingly, that a distinctly larger number of enterprises will ultimately be indirectly affected by the new regulations.

 

Jörn Kuhn

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Dr. Gilbert Wurth

Partner

Telephone: +49 221 2091 351 / 381
Telefax: +49 221 2091 333

gilbert.wurth@oppenhoff.eu

Kathrin Vossen

Partner

Telephone: +49 221 2091 351
Telefax: +49 221 2091 333

kathrin.vossen@oppenhoff.eu

Jörn Kuhn

Partner

Telephone: +49 69 707968 140
Telefax: +49 69 707968 111

joern.kuhn@oppenhoff.eu

Isabel Hexel

Partner

Telephone: +49 221 2091 348
Telefax: +49 221 2091 333

isabel.hexel@oppenhoff.eu

Southeast Asia

Recent matters we advised on include:

Arbitration proceedings between a Belgian and a Singaporean company concerning the delivery of parts for a big industrial complex to be erected in China.

Dr. Alexander Willemsen

Partner

Telephone: +49 221 2091 551
Telefax: +49 221 2091 333

alexander.willemsen@oppenhoff.eu

Jamilia Becker

Associate

Telephone: +49 221 2091 346
Telefax: +49 221 2091 333

jamilia.becker@oppenhoff.eu