If you are enjoying annual leave right now, spare a thought for your colleagues across the pond.

The U.S. is one of the few countries in the world where employees have no right to statutory holiday pay – vacation time is strictly a matter for discussion and contract negotiation between employer and employee.

Different leave allowances for different employees

Paid holidays can be a thorny issue when companies operate in multiple countries, where typically leave allowances will be different in each country – meaning US employees could expect substantially less holiday than their UK based counterparts.

For example, at Google, one of the more generous U.S. employers, U.S. employees tell Glassdoor they can start off with three weeks of paid time off and can work their way up to five weeks if they stay with the company for five years.  UK-based employees would have to automatically receive at least the statutory minimum of 28 days in their first year, although reportedly the company exceeds this and offers UK employees 25 days plus bank holidays.

UK Bank Holidays – and a caution for employers

Often UK employees get confused about bank holidays – legally, there is no entitlement to be paid for bank holidays, which means that the ’28 days’ is often 20 days annual leave plus 8 public holidays in practice.

A common, but mentionable issue for UK employers is holiday wording on your contracts of employment, which many employers have not kept up to date.  If employers have worded contracts to say that employees are entitled to “statutory entitlement plus bank holidays”, this no longer denotes 20 days’ leave plus eight bank holidays. Following the increase in statutory minimum leave from four to 5.6 weeks in 2009, this wording grants 28 days’ holiday with eight bank holidays on top. Check your employment contracts to make sure they reflect your current bank holiday policy.

Some employees believe that they are entitled to premiums for working bank holidays, Christmas Day or New Year’s Eve.  Actually, while employers will often pay a premium, there is no legal requirement for them to do so!

How can employers manage different leave allowances?

Sometimes called the ‘staff holiday go-to man’ Adrian Lewis is Director of absence management software company Activ Absence, whose software manages staff holiday for customers across the globe.

Adrian explains:

“These days, businesses usually have more than one location, but often need to have data on staff sickness and holiday across the business, even when staff work remotely, in multiple locations, or even multiple countries.

“One customer alone has a presence in 140 countries – which means that our software needs to manage multiple leave allowances (which can vary by individual contract as well as by country) and multiple public holidays.  Thankfully, our software is geared up to do that – it’s pretty rewarding that an M.D. can login from anywhere in the world with an internet connection, and measure the impact of both sickness absence and annual leave across the business at the touch of a button.”

38 days – will everyone be heading to Austria or Malta?

With 38 days paid annual leave, are Austria and Malta the world’s best nations for statutory paid staff holiday?  We asked Adrian for his expertise.

Adrian says:

“Surprisingly, no!  That honour goes to Kuwait, where employees receive 30 days paid holiday, plus a further 13 paid public holidays, giving staff a whopping 43 days off – and if an employee has not yet taken Haj (pilgrimage to Mecca), they are entitled to an additional 21 days paid leave after two years continuous service to do so.  Again our system can manage this.

“Cambodia comes a close second.  Employees are entitled to 27 paid public holidays, as well as 15 normal days.  In all these cases, this is the statutory minimum – some employers will exceed this!”

Should UK employers increase their leave provisions?

Although we do very well compared to our U.S. colleagues, one can’t help but notice the UK is far nearer the bottom than the top of the European league table for staff holiday.  Should UK employers be striving to improve the standard staff holiday offering in order to compete for top talent, especially post-Brexit?

Adrian says it’s not that simple.

“Accessing annual leave is as important as the amount of days available.  Employees get unhappy and frustrated if they want time off and can’t get a quick answer, because the data is stuck somewhere on a spreadsheet or form, and often by the time someone has come back confirming they can book the time off, that ‘sweet deal’ at the travel agents has gone already and they know their partner will be annoyed as well.  

“We’ve focused on making decisions easy, by storing data centrally.  When an employee requests time off through Activ Absence, (which they can do anywhere, anytime) managers are sent information alongside the leave request, so they can say yes or no with a simple click.”

“Of course, the amount of days is still important, but being demonstrably fair, and dealing with leave queries expeditiously is vital in maintaining good employee relations.  In our experience, employers who manage their annual leave better have happier employees, no matter what the actual leave allowance is.”