This article is an extract from The Employment Law Review, Edition 13. Click here for the full guide
I Introduction
Religion plays a critical role in the lives of individuals throughout the world. It influences the workplace, and employees are directly affected by the ways in which employers protect employees' religious beliefs. In an era when transnational corporations are key actors in the global economy, there is a heightened need for businesses to understand different national approaches to accommodating religion in the workplace. This chapter compares how the United States, France, Germany, Turkey, Saudi Arabia and India each manage religious discrimination in the workplace. In light of the legal debate surrounding the donning of headscarves in the workplace, discussion is included on the relationship between headscarf bans and religious discrimination in the workplace in each of these nations.
II United States
i Backdrop
The United States has long recognised the importance of freedom of religion. Early US history demonstrates that many of the original settlers were fleeing religious persecution and sought to challenge the degree to which religion should be integrated into politics. Thus, the US Constitution was written in the context of a deeply pluralist society. The notions of freedom of religion and separation of church and state developed early on and were enshrined in the First Amendment to the US Constitution.
The doctrine of religious accommodation in the...
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