Between headquarters and the works council
An international group runs on standards. One performance framework, one pay structure, one HRIS, one code of conduct, one way to handle underperformance. That is what makes a group manageable from Boston, London or Singapore. The German subsidiary inherits all of it, and then meets a legal system in which a works council (Betriebsrat) has to agree to the performance framework's monitoring elements, the HRIS's data fields and the working-time rules embedded in the shift plan, under Section 87 of the Works Constitution Act (BetrVG). A policy that headquarters considers rolled out is, in Germany, often a draft.
The same applies to separations. A group that handles underperformance with a 30-day improvement plan and an exit meets German dismissal protection under the Protection Against Dismissal Act (KSchG), which applies from ten employees onwards and makes a termination for performance reasons a documented, multi-step process with the works council heard first. Country managers who learn this from an employment lawyer after the fact tend to lose both the case and the trust of headquarters.
The HR lead in a subsidiary therefore does two jobs. Upwards: explain, in English, what German law requires and what a realistic timeline looks like, before the group plans around a date that cannot hold. Downwards: run HR in German with the works council and the employees, adapting group standards so that they achieve the same intent within the law. Language is the smaller part of that translation. Substance is the larger one.
Typical HR triggers in international subsidiaries
Three situations in which, in my experience, a country manager or regional HR director calls:
A global rollout has stalled in Germany
The new HRIS or performance system is live in nine countries. In Germany the works council has not agreed, headquarters is asking why, and the local HR lead has just resigned.
A group decision meets German law
Headcount reduction, site consolidation, a change in bonus rules. The group has a date. German procedure has its own. Someone has to reconcile them before the announcement.
The German entity has outgrown its setup
Fifty people, then 120, a payroll provider and a shared HR contact in Amsterdam. The entity now needs its own HR structure, built to group standards and German law at the same time.
Which role fits a German subsidiary
When the local HR lead is missing, the fit is Interim HR Manager: full ownership of German HR, full-time, three to eighteen months, reporting to the country manager and to group HR, running the works council relationship and the local team. That is the shape of most of my subsidiary engagements.
When the subsidiary has an HR team but the country manager needs a senior counterpart for headquarters, for the works council and for difficult decisions, HR Business Partner fits, full-time or on fixed days. And when the trigger is an acquisition, two HR organisations that now have to become one, the format is the scoped project Post-Merger Integration.
A case from a past role
At a global consumer goods group, the corporate performance and talent framework had been designed at headquarters and did not yet exist as a working process in the German business unit I supported as HR Business Partner in a permanent role. Rolling it out unchanged would have produced a form nobody used. Instead, I built it with the local line managers so that it achieved the group's intent, comparable performance data and a talent pipeline, in a form that managers applied and employees understood. Headquarters got its framework, the unit got a process it actually ran. The write-up, anonymised, is under Building Talent Management Processes That Line Managers Actually Use.
The growth side is documented too: building HR structures in new markets for an international company while it scaled, under Scaling a Region from 70 to 115 Employees.
How an engagement runs
30 minutes, directly with me, in English or German. You describe the entity, the group's expectations and what is stuck. Within one working day I say whether and from when I can help.
Group policies versus local practice, works council agreements, pending cases, contracts, payroll provider scope. Meeting the works council and the country manager. First briefing to headquarters on what German law requires.
Group standards adapted and agreed with the works council, local HR processes built or repaired, decisions executed on a German timeline that headquarters has signed off. Weekly one-page report, in English.
Documented processes in both languages, agreements filed, open items with status, and if wanted the permanent HR lead recruited and onboarded.
Questions from country managers and group HR
Do you report to headquarters in English?
Yes. Most of my international teams and all headquarters communication in past roles ran in English, including Roles in corporate groups, mid-sized companies and scale-ups. The operational HR work with the works council and employees runs in German. I do both, and I translate between them, in language and in substance.
What do you do when a global policy conflicts with German law?
I say so early, in writing, with the specific rule that applies. Then I propose the version of the policy that achieves the group's intent within German law. Headquarters usually wants the outcome, not the wording, and a works council will accept a policy that was adapted with them rather than imposed on them.
Our headquarters does not understand why the works council has to agree to a new HR system.
That is the most common conversation in this kind of engagement. Under Section 87 of the Works Constitution Act (BetrVG), technical systems that can monitor performance or behaviour are subject to co-determination, which covers most HRIS, time-recording and AI tools. I explain that to headquarters once, properly, and then build the timeline around it.
Can you also handle a headcount reduction ordered by the group?
Yes, as a scoped project. A restructuring in Germany follows fixed steps with the works council, and the timeline is set by the procedure, not by the group's quarter. I have carried that out in a reorganisation across nine countries, delivered in three months at a software company.
The German entity has no HR at all, only a payroll provider. Where do you start?
By taking stock of what exists: contracts, the payroll provider's scope, works council status, pending cases. Then the minimum HR structure a German entity needs, built to fit the group's standards where they fit and adapted where they do not.
How fast can you start?
Usually within two weeks of being engaged. If a group decision is the trigger, I say on the call what a realistic German timeline looks like, so headquarters hears it before it is a surprise.
