Meta, Snap, and Twitter Cuts in Europe Vs US
- Big Tech layoffs at Meta, Twitter, Amazon and Snap have laid off thousands of workers globally.
- European workers can negotiate softer landings thanks to better labor protections, experts say.
- That can mean better severance, more notice of cuts, and contesting dismissals.
The layoffs feel never-ending.
Meta this week announced a further 10,000 job cuts, after axing 11,000 roles in November, Insider’s Kali Hays and Grace Kay report.
More than 200,000 roles are estimated to have been cut at tech companies since the beginning of 2022, per layoffs tracker Layoffs.fyi.
Rising interest rates and a tougher economy mean job losses have ticked up over the past year, but it’s Twitter owner Elon Musk who has supercharged their speed and brutality with his slash-and-burn cuts in November.
As Big Tech cuts extend beyond the US, some overseas employees are finding they can fight back thanks to better employment protections.
Sinead McSweeney, a VP at Twitter’s Ireland office, successfully applied for an injunction in November when staffers in the office were laid off, stopping her imminent dismissal.
While Twitter had sent around an email requiring employees to either accept ‘hardcore’ terms of employment or resign, McSweeney contested her dismissal on the grounds that she was not treated as an employee due to the mass email.
A month after her initial dismissal, she won an injunction from the High Court which restored her employment at Twitter, Fortune reported, the only employee thought to have achieved this. Insider has contacted McSweeney for an update.
Twitter’s American employees have also filed lawsuits against the company’s layoffs and severance policies, but to Insider’s knowledge, these have not necessarily staved off cuts.
Until recently, tech employees haven’t had to think too seriously about mass layoffs. For the most part, these firms were desperate to hire talent and stop them from going to the competition and bolstered their pay packages accordingly.
But the scale of cuts has highlighted one perk of being in Europe, where the pay is conventionally less.
The law offers “far more protection against dismissal than in America,” according to Dr. Christopher Jordan, partner at law firm CMS.
—Charmi Trevadia (@charmitrevadia) November 18, 2022
European Big Tech employees have better labor protections
“There are regulations in Europe that apply to collective situations, based on European law: the so-called Mass Dismissal Directive,” said Dr. Jordan.
Companies in Europe, for the most part, have to let employees know in advance that they’re planning to cut staff — meaning shock layoffs where workers are suddenly locked out of laptops are much less likely.
Collective consultation in Europe and the UK means that employees at firms with over 100 redundancies have to be notified at least 45 days in advance. Employers also have to meet with union representatives to talk through ways in which layoffs can be minimized.
This makes quick dismissals “much more complex and expensive” in comparison to the US.
European laws differ from country to country and depend “on the size of the company and the number of redundancies proposed,” Freshfields partner David Mendel said. But, he added: “The obligation to inform and consult with employees or employee representatives is stronger in Europe than the US.”
Here’s how some of those geographical differences are playing out:
Twitter, under Elon Musk, has opted for rapid-fire layoffs over the past few months. However, these have been married by lawsuits in the US and Europe and public spats. Musk initially promised three months of severance pay for US employees who were laid off. But in January, Twitter employees were reported to have been paid just one month’s severance, according to CNN.
The Worker Adjustment and Retraining Notification Act (or WARN) requires US companies to give a 60-day notice period before dismissing an employee, which pushed Twitter to hold onto a portion of its workforce that it had initially laid off. But the WARN act does not guarantee a minimum base pay, said Freshfields’ Mendel.
Twitter employees in other European hubs such as Germany, Spain, Ireland, and the UK are also pushing back, with the help of the countries’ labor laws and unions.
When Twitter’s Spanish office dismissed 26 employees via a general email notice, Spain’s Labor Minister Yolanda Diaz said that her department was working to ensure that Twitter was complying with labor regulations.
In Germany, employers have to make a severance offer that is attractive enough for the employee to accept it, according to Dr. Jordan.
“In some countries in Europe, such as Germany, the following applies: if there is no justification or a court does not recognize this justification, the termination is invalid and the employment relationship continues,” Dr. Jordan told Insider.
Twitter employees in Germany have also worked with the Verdi union to push Twitter into making a better severance offer, Fortune reported.
“Where employees in Europe are unionized — and social plans have been negotiated with trade unions — the severance packages can be significantly higher than these levels,” Mendel told Insider.
Twitter did not reply to Insider’s request for comment.
Facebook’s parent company Meta announced it would lay off 11,000 staffers in December, and opted for generous goodbye packages with a base offering of 16 weeks’ severance pay. At the time, CEO Mark Zuckerberg agreed to continue health insurance for employees’ families for six months. “We’ll provide three months of career support with an external vendor, including early access to unpublished job leads,” Zuckerberg said in a memo to employees.
The memo detailed the company’s severance procedure in the US and added that support would be broadly similar outside of the US per local employment laws, where it said it was complying with labor laws on a country-to-country basis.
In Dublin, Ireland, 350 staffers were let go; per the bloc’s collective consultation requirement, Meta said that the timeline for layoffs would be defined by Irish Government regulation, according to Impakter.
According to balance sheets obtained by reporter Myles Udland, Meta spent $975 million on severance and personnel packages, which tallies at around $88,000 per employee.
Meta did not give Insider any further details beyond the memo shared. On Tuesday, the firm announced a further 10,000 cuts.
When Snapchat’s parent company Snap laid off 20% of its employees, Paris-based social location app Zenly — which it had acquired in 2017 — was shut down.
But French labor laws are stricter than California’s. In contrast to US-based Snap employees, who said they were immediately locked out of company work platforms, the French Labor Authority required Snap to help Zenly employees plan their next steps in gaining employment, per The Pragmatic Engineer.
This included measures such as training budgets, relocation packages, financial support for job interviews both in France and abroad, company creation funding, and support with outplacement companies, the outlet added.
“The law in France is very tough about laying off teams — it will last at least a few months,” a Zenly employee told Insider when news of the shutdown first broke. Zenly’s wind-down lasted at least five months, with the app disappearing from app stores in February.
Despite the added protections during the wind-down period, Insider’s employee source said Zenly staffers were told that they could not vest their stock options.
Snap did not reply to Insider’s request for comment.