ABSTRACT
The European approach to disability has generally been based on compulsory employment quota systems, e.g. France, Germany and Spain, and extensive state intervention in contrast to the US model of civil rights and strong anti-discrimination measures (Goss et al., 2000). The US model is based on the premise that discrimination owes more to society’s attitude and structural barriers than personal limitations caused by impairment or disability. The Rehabilitation Act 1973 provides for affirmative action, which could include the achievement of preferential quotas, while the Americans with Disabilities Act 1992 recognizes disabled people as a group whose relative lack of power has prevented them from achieving fair or equal treatment in the face of societal prejudice. Case study 4.6 illustrates some early court decisions on disability and acquired immune deficiency syndrome (AIDS), which
Italy has a stronger legal framework supporting women, but job opportunities are limited and favourable maternity rights appear to be damaging women’s employment prospects. Women returners are considered out of touch, and they are offered chambermaids’ jobs. Family-friendly policies are unknown, even to large hotel groups. The pay gap is smaller because all sectors are regulated by legally binding collective agreements. Some employers pay above the minimum in cash to avoid higher tax and social insurance costs.
