International comparison of health and safety responsibilities of company directors.

Title	International comparison of health and safety responsibilities of company directors.
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Author	Bergman, D., Davis, C. and Rigby, B. Centre for Corporate Accountability for HSE.
Series Code	RR
Series Number	535
Publisher	HSE BOOKS
Date of Publication	2007
Length	130 pages
Stock Code	RR535
Notes	research report 535. (RR535) (RR 535) WEB VERSION ONLY
Abstract	This report looks at whether the law in nine different countries imposes health and safety duties upon boardroom directors (and other senior managers), and if so, what these duties comprise and whether they assist in the prosecution of directors. The main finding is that seven out of nine countries contain safety legislation that imposes positive safety obligations upon either directors or senior managers of companies. These are: Germany, France, Italy, Sweden, Japan, Canada (four out of fourteen jurisdictions) and Australia (two out of nine jurisdictions). There is in addition another category of jurisdictions which, whilst not imposing explicit positive duties upon directors, do impose significant responsibilities through the creation of offences that are targeted at directors. This category includes four Australian states. There are also, however, jurisdictions which either impose minimal or no duties upon directors. Two countries – USA and Holland – do not impose any obligations. This report and the work it describes were funded by the Health and Safety Executive (HSE). Its contents, including any opinions and/or conclusions expressed, are those of the authors alone and do not necessarily reflect HSE policy.
Keywords	Research; Directors; International Law