Introduction

If you’re managing employees in both Greece and the United States, you’re likely already aware that the two countries approach employment very differently. For global businesses, understanding these contrasts isn’t just about compliance - it’s about creating a people strategy that works across cultures and legal systems. As companies expand or hire internationally, misinterpreting local labour laws can lead to serious risks, from fines to reputational damage.

The key is not to assume what works in one region will automatically translate to another. Labour law is always local. Here’s a practical guide to navigating the critical differences between Greece and the US - and how to protect your people and your business across borders.

Quick Tips

• In Greece, employment is highly regulated and pro-employee - always get local legal review.

• US 'at-will' employment does not exist in Greece - terminations must be justified and documented.

• Overtime rules, minimum wages, and collective bargaining are more robust in Greece.

• US benefits are often discretionary - in Greece, many are mandated by law.

• Local holidays, severance, and working time rules differ widely - don’t copy and paste contracts.

Employment Models: Structure and Termination

The US is known for its 'at-will' employment model - meaning an employer can terminate an employee at any time for any legal reason, and vice versa. This model offers flexibility but also introduces risk when not managed well, especially around protected classes or retaliation claims.

In contrast, Greece offers strong worker protections under its Civil Code and Labour Law. Termination without cause is not a concept recognised under Greek law. Employers must provide written notice, follow procedural steps, and pay statutory severance depending on the length of service. Failing to comply can lead to reinstatement orders and financial penalties.

One client I supported was downsizing in both the US and Greece. While the US process involved internal documentation and 30-day notice, the Greek reduction required union consultation, detailed economic justification, and Ministry of Labour filings. The difference in complexity was stark - but manageable with the right local advice.

Working Time, Pay, and Leave

Greek law regulates working hours tightly - the standard is 40 hours per week, with strict rules on overtime. Employees are entitled to at least 20 working days of paid annual leave (more with seniority), and public holidays are protected. Any work on these days must be compensated with additional pay or rest.

The US has no federally mandated paid leave or public holiday entitlements. Employers typically set their own policies. While this allows flexibility, it also creates inconsistencies and confusion for global teams. According to the OECD, Greece offers some of the highest statutory annual leave in Europe, while the US remains the only OECD country without a national paid holiday law.

For HR leaders, this means your benefits strategy needs to reflect each local context. A one-size-fits-all holiday policy won’t work and may cause resentment or non-compliance.

Unions, Benefits, and Employee Rights

Collective bargaining plays a significant role in Greek employment law. Many sectors operate under national or industry-level agreements that determine minimum pay, benefits, and conditions. Even non-union employers may be bound by these terms.

In the US, union presence is less widespread, and terms are typically set at company level. Benefits such as healthcare, pensions, and parental leave are often employer-provided rather than government-mandated. This creates both freedom and risk.

One US-headquartered client assumed their global benefits plan would cover Greek employees equally. But Greek law requires specific maternity benefits, employer contributions to social security, and rules on medical exams and occupational safety. We helped them redesign their policies to align with Greek obligations - without losing the flexibility of their global offer.

A Real Example: Preventing Missteps Through Local Insight

Recently, a client with operations in Athens and New York asked for a single global employee handbook. Rather than pushing back, we worked through a core vs local model: values, ethics, and behaviours formed the core, while employment terms were customised by country.

We partnered with legal counsel in Greece to align their contracts with collective agreements and clarify probation periods, hours, and benefits. In the US, we revised language around termination, arbitration, and at-will disclaimers. The result was consistency in tone and purpose - and legal clarity in each region.

Final Thoughts

When managing international teams, compliance isn’t just a box to tick - it’s a foundation for trust and operational integrity. Greece and the US offer a perfect case study in how different employment can be across borders.

Smart companies don’t just react when things go wrong. They build scalable frameworks, engage with local expertise, and see compliance as a strategic advantage.

What’s next for your global people strategy?

Book a free compliance check-in or HR audit with ThinkGlobal HR. We can help you navigate labour law across jurisdictions, ensure your contracts are watertight, and build an HR model that’s ready for global growth.