Ограниченные по сроку трудовые отношения у наемных работников старшего возраста

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Ограниченные по сроку трудовые отношения у наемных работников старшего возраста  


Введенное в Германии в рамках законов Hartz-Gesetz положение о том, что наемный работник с 52-летнего возраста может приниматься на работу на ограниченный срок без какого-либо обоснования, нарушает право Европейского союза.

 

Ограниченные по сроку трудовые отношения (befristetes Arbeitsverhältniss) довольно часто встречаются в различных отраслях народного хозяйства и областях трудовой деятельности наемных работников, для которых такие отношения имеют серьезные последствия. Прежде всего, затрудняется долгосрочное планирование жизни на основе финансовой стабильности. Наемный работник неуверенно чувствует себя на предприятии, он не заинтересован в результатах его хозяйственной деятельности и потому не всегда трудится в полную меру своих сил. Ведь чаще всего такие трудовые отношения возникают при временном найме работника взамен серьезно заболевшего или ушедшего в отпуск по уходу за родившимся ребенком постоянного сотрудника. Хотя в принципе могут быть и другие, существенно важные, причины, побудившие работодателя принять наемного работника на работу на ограниченный срок согласно Закону о неполной или временной трудовой занятости (Teilzeit- und Befristungsgesetz, TzBfG).

Согласно Закону TzBfG временный (или срочный, т.е. ограниченный по времени) трудовой договор может быть заключен на любой срок, но причина такого ограничения должна быть в принципе однозначно указана в тексте договора (§ 14 Abs.1 TzBfG). Однако при продолжительности срочного трудового договора в пределах двух лет указание предметной причины не обязательно  (§ 14 Abs. 2 TzBfG), причем в течение общего срока в два года первый срочный трудовой договор с наемным работником может затем трижды продлеваться. После этого работодатель должен решить, оставляет ли он работника у себя с бессрочным договором или расстается с ним. Т.е. четвертое продление договора законом не допускается, договор в таком случае считается бессрочным. Причем заключение срочного договора в принципе невозможно с работником, который когда-либо ранее работал на данного работодателя.

А вот наемного работника старше 52 лет  можно принимать на работу на ограниченный срок любой продолжительности без наличия на то предметной, объективной причины в пределах уже пяти лет, если прежде он, по крайней мере, в течение 4 месяцев был безработным, или получал пособие частично безработного (Transferkurzarbeitergeld) во время длительного простоя предприятия во избежании его увольнения и повышения шансов на рынке труда, или принимал участие в стимулируемых государством мероприятиях по обеспечению трудовой занятости (§ 14 Abs. 3 TzBfG). При этом его срочный трудовой договор может затем продлеваться неограниченное число раз на  любой период времени в течение 5 лет. После этого работодатель также должен решить, оставляет ли он работника у себя с бессрочным договором или расстается с ним. Ну, а потом. К сожалению, закон не дает на это четкого ответа. Следует понимать так, что, как и в случае работника моложе 52 лет, последующее  заключение срочного договора с тем же работодателем невозможно. Ведь это означало бы простое увеличение предельного пятилетнего срока. Но на практике нередко вновь и вновь такой договор на временную работу с тем же работодателем заключается.

Тому пример иск женщины в суд первой инстанции г.Кельна, с которой в течение 11 лет, в общей сложности 13 раз, один и тот же работодатель заключал срочные трудовые договора. В этом суде она предъявила свой последний трудовой договор, который без каких-либо обоснований был заключен с нею на неопределенный срок, т.к. уже просто не оставалось никакой объективной причины, оправдывающей ограничение срока договора. Во многих ее непосредственно следующих друг за другом срочных трудовых договорах со всей очевидностью больше не могли исходить из временной потребности в замещаемой рабочей силе. Дело в том, что данная сотрудница каждый раз принималась на работу для замещения очередной уходящей в отпуск по уходу за ребенком коллеги.

Федеральный суд по трудовым спорам Германии попросил в этой связи Европейскую судебную палату указать границы общеевропейского права в части ограниченных по сроку трудовых отношений. Хотя EuGH в этом актуальном случае не увидела факта принципиального злоупотребления, тем не менее, Федеральный суд Германии обязан, согласно решению EuGH, проверить точные обстоятельства этого случая, чтобы установить наличие объективного, предметного основания для заключения срочного трудового договора.

Германский закон о трудовых договорах на работу в режиме неполного рабочего дня или недели, а также на ограниченный срок, который подвергся изменению в рамках реформы Hartz-I-Reform в декабре 2002 года, очевидно имел благие намерения. Дело в том, что он снизил возможные ограничения для заключения временных трудовых договоров с 58 до 52 лет. Конкретно это означает, что каждому, кто старше 52 лет, в любое время может быть предложен трудовой договор, конечно, на ограниченный срок, и без какого-либо обоснования. 

Целью этого законоположения по замыслу федерального правительства было облегчить трудоустройство наемных работников старшего возраста на германском рынке труда. В то время правительство находило нарушение пропорциональности в возрастной статистике безработных. Но вот 54-летний безработный из Мюнхена подал в суд первой инстанции жалобу. Адвокатская контора предложила ему временный трудовой договор на работу сроком на 8 месяцев без указания объективной, предметной причины, т.е. так, как это допускает действующий закон. Согласно же Европейскому праву это является недопустимой дискриминацией – с этим аргументом истец обратился в компетентный суд Мюнхена, который направил далее запрос в Европейскую судебную палату (EuGH) в Люксембурге. И та приняла решение в пользу соответствующего наемного работника старшего возраста. Ведь цель - оказывать содействие вовлечению в профессиональную трудовую деятельность наемных работников старших возрастов – несправедливо нарушается в национальном трудовом праве, поскорльку оно допускает неограниченную возможность заключения временных трудовых договоров со всеми наемными работниками, которые достигли 52-летнего возраста.

Т.к., далее аргументировали в своем решении судьи из Люксембурга, запрет дискриминации по возрасту, как и по признаку пола или вероисповедания, является основополагающим принципом общеевропейского права. Хотя, конечно, государства-члены ЕС могут предписывать для различных групп наемных работников на рынке труда неравные законоположения, если при этом преследуются определенные правовые цели, особенно в области трудовой занятости.  Но, и это является решающим правовым обстоятельством, средства достижения этих целей должны быть соразмерны и востребованы. Или, как разъяснила представитель Европейской комиссии Катарина фон Шнурбайн (Katharina von Schnurbein), по поводу заключения EuGH: «Это не является критикой цели сохранить наемных работников старших возрастов на рынке труда с помощью ограниченных по сроку трудовых договоров, а, напротив, речь идет о средстве достижения этой цели».

Однако Европейская судебная палата имеет обоснованное сомнение в том, что закон Германии в таком виде является неправомерным. Ведь этот закон означает, что всем безразлично наемным работникам, достигшим 52-летнего возраста, вне зависимости от того, являются ли они в данный момент безработными и сколько времени они находятся в таком состоянии, могут быть предложены только срочные трудовые договора. А это представляет для этой группы наемных работников серьезную опасность того, что уже до окончания ими трудовой жизни для них исключены постоянные трудовые отношения. Такая ситуация несправедлива и незаконна, решила EuGH.  А, значит, существущий в Германии закон должен быть изменен так, чтобы в нем учитывалось, к примеру, влияние прошлого периода безработного состояния принимаемого на работу наемного работника. Действующий сегодня в Германии закон, по мнению EuGH, недопутимым образом подвергает дискриминации наемных работников старшего возраста. 

Европейская судебная палата (Europäischer Gerichtshof, EuGH) в своем решении Az: C-586/10 потребовала от государств-членов ЕС воспрепятствовать с помощью четких и ясных законоположений последовательному злоупотреблению на предприятиях срочными трудовыми договорами. Важно, каждый раз, указывать конкретную причину, которая оправдывает продление таких договоров, - подчеркивает в своем решении EuGH. Такой объективной причиной в свете общеевропейского права могла бы быть временная потребность в замещаемой рабочей силе, как это предусматривается в германском праве.

Толстоног Веньямин

Источник: www.tagesschau.de


Datum: 01.05.2012
Hinzugefügt: ava  oxana.sher
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