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This paper examines the role of different types of post-compulsory education in determining civic engagement (political interest and election participation) in England and Germany. The educational systems of England and Germany provide ideal comparators for investigating the social benefits of education, in particular those that accrue from vocational education. The paper uses two longitudinal panel surveys, the British Household Panel Survey and the German Socio-Economic Panel for empirical purposes. Contrary to our expectations, our findings revealed few differences between the two countries: the level of political interest is the same for youth who had a vocational degree as those without any further qualifications, in both England and Germany. Similarly, greater levels of interest in politics were observed in adulthood for youth who had achieved academic qualifications in both countries. Likewise voting behaviour in particular was associated with the achievement of academic qualifications in Germany and to some extent with the achievement of mixed vocational and academic qualifications in England. [ABSTRACT FROM AUTHOR]

Purpose — The paper aims to compare the office of directly elected mayor in England, Germany and the USA. Proposing and applying a conceptual model of government, governance and allegiance, it assesses the leadership role of the elected mayor in the three countries. Design/methodology/approach — Qualitative interviews were conducted with a sample of mayors in each country over a period of 11 years. These formed part of the authors' continuing research into local leadership and political management, which has also included interviews with ex-mayors, elected representatives and senior officials. Findings — The operation and success of the elected mayor in specific countries is influenced by formal variables (e.g. state constitutions, formal requirements) and informal relationships (e.g. with officials), represented in the distinction between structure and agency. The role of the individual mayor also varied in the light of local party affiliations. The paper considers the impact of these variables on the government, governance and allegiance functions of the elected mayor. Research limitations/implications — In providing an analytical framework and in the discussion of original research, a basis is provided for the further study of the office of elected mayor in different national contexts. This is likely to prove valuable as the future of sub-national government is subject to continuity scrutiny. Practical implications — The adoption and growth of the elected mayoral system may be considered as an example of lesson drawing. This has both positive and negative implications. Positively, much can be learned from comparative experience. Mayoral systems have resulted in quicker decision making. The mayor provides a very visible form of local leadership and accountability. However, dangers lie in the over-concentration of powers in the office of mayor and, in England especially, the failure of the mayoral system to enhance public engagement in local government. Originality/value — The discussion will be of value to practitioners, policy-makers and academic researchers who are concerned with the future of the elected local state and its office holders. [ABSTRACT FROM AUTHOR]

Purpose Higher education (HE) sectors form an important part of societies and their economy, on which the members of a society depend for their individual and collective future benefit. The purpose of this paper is to discuss the perceptions of accounting academics on the introduction of HE tuition fees in both England and Germany, and how this policy has affected the everyday life of academics and students alike in each country. The respective funding and reform approach sets the context of this study.Design/methodology/approach The study has adopted a qualitative methodology, analysing data collected through semi-structured interviews. Accounting academics discuss their perceptions of both policies in the respective context. Academics were focussed on as implementers of educational policies. Accounting academics were chosen due to their academic and professional background, changing academic position in the global market and their representative stance in the academic context. The data analysis took place through coding interview data.Findings While England’s fees have been increased several times over the past 15 years, few German federal states have introduced, and have already abolished the policy. Reasons as to why the outcomes are so radically different are discussed based on interviews with accounting academics, and the implications for future practice are that to be successful political support must be sustained regardless of the changing governments, and the HE sector itself must have strong champions supporting this policy. Furthermore, the effect of the respective tuition fee policy with regard to education is addressed, which suggests that English students have a broader education package expectation, while with regard to actual classroom education both German and English students have similar outlooks. A further issue is the different political and education contexts, the current state of affairs and the societal impact.Originality/value This study is one of the few to compare directly the differing tuition fee policies and the educational implications of these policies of Germany and England. These two cases are an illustration that Germany and England are at the opposite ends of the reform spectrum and that academics experience different expectations due to such different fee policies. [ABSTRACT FROM AUTHOR]

Purpose: The present paper is aimed to investigate the relationship between intangible assets, macroeconomic environment and market value of German, English and Portuguese public companies from 1999 to 2016. Although the IAS 38, assigns value to intangible assets, there is a gap between accounting and the market need. This gap is given by accounting conservatism in the accounting of intangible assets and by their difficult measurement. The verification of the impact of the intangibles on the company's market value is done through the methodology proposed by Gu and Lev (2011), using proxies such as CDS, Libor and Euribor and sensitivity tests. IDE is expected to reflect intangible capital and create shareholder value. This study seeks to interpret the contribution of intangibles and to forecast their impact on the market. Originality/value: The theme of evaluation of intangible assets has been approached in several ways. Its relevance lies in the need to establish methods for its measurement. Design/methodology/approach: The methodological approach is quantitative research with panel data using Stata-15. The database is the Capital IQ with public companies, listed in Germany, England, and Portugal from 1999 to 2016, with annual frequency. Findings: The results suggest that the comprehension value has a positive and significant relationship with the market value of the companies and that the intangible capital and the intangibles-driven-earnings are positively related to research and development expenses and general, administrative procedures. [ABSTRACT FROM AUTHOR]

This study aims to compare and contrast how specific information health technologies (IHTs) have been debated, how they have proliferated, and what they have enabled in Germany's and England's healthcare systems. For this a discourse analysis was undertaken that specifically focussed on future-scenarios articulated in policy documents and strategy papers released by relevant actors from both healthcare systems. The study reveals that the way IHTs have been debated and how they have proliferated depends on country-specific regulatory structures, their respective values, actors' and institutions' organized interests, and the status of health professionals. These conditions have enabled IHTs to promote a new and similar concept of patienthood in both countries, although they tend to affect practitioners' practices more dramatically in England. The conclusion is drawn that with the usage of IHTs, healthcare systems reproduced existing patterns of health provision while also enabling a sort of convergence. Future research should investigate whether the new concept of patienthood emerging in both welfare states actually suits patients' and professionals' needs and requirements. [ABSTRACT FROM AUTHOR]

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This study identifies three types of legitimation from the literature that can be applied within metropolitan governance in the contested sphere of spatial planning: input legitimation, throughput legitimation, and output legitimation. The reason for discussing different forms of legitimation within metropolitan governance is that, globally, only a relatively few metropolitan regions are governed directly through a single elected tier of government such as a regional council. Thus, governance mechanisms in most metropolitan regions involve some form of joint working or cross border governance initiatives that have to be legitimized in the absence of a single overarching elected council covering the whole metropolitan area. The main question discussed in this paper is, therefore, whether all three types of legitimation identified are utilized to legitimize governance mechanisms at the metropolitan scale with a specific focus—as a core part of metropolitan governance—on spatial planning processes and projects. In conceptual terms, our typology structures fuzzy lines of legitimation across the three (the "how", "who" and "what") suggested aspects of metropolitan governance in the literature. From this point, we draw on cross-case reviews of variables involved in the design, application, and outcome of input, throughput, and output legitimation in Germany and England, chosen because neither has a formal tier of metropolitan-wide government despite their differences in terms of their highly regionalised and highly centralised national government contexts respectively. This relational methodology helps us to learn about the contextual dynamics of how the three types of legitimation might reinforce one another in different international settings, leading to the overall conclusion that they will work best in combination, although output legitimation has a distinctive capacity to work in less formal settings. [ABSTRACT FROM AUTHOR]

When considering the manner of death, two categories can be distinguished, namely natural death and unnatural death. Though most physicians think that the distinction between the two is evident, this is not the case.When comparing the Netherlands, Belgium, England and Germany it is noticed that the terms natural and unnatural might be used in law but are not defined by law. In practice, the term unnatural death is used when there is an external cause of death, but even that turns out to not be sufficient in making an obvious difference between the two terms. Different countries may even label the same death differently. A, at times philosophical and semantic, discussion shows that when it comes to causes of death a very large grey area exists between natural and unnatural causes of death. The Netherlands, Belgium and Germany even have the possibility to label a death as natural (or unnatural) without actually knowing the cause of death.In conclusion, we recommend a new system in which the circumstances surrounding a death are properly investigated. This should lead to a report to an independent legal expert, who is able to decide if and what conclusion can be drawn, from a judicial and a public point of view, thereby, making the distinction and the use of the terms natural and unnatural/nonnatural obsolete. [ABSTRACT FROM AUTHOR]

Many contemporary analyses criticise metrics-based evaluation in the higher education context as a neoliberal technology, notwithstanding the different national contexts and organisational topographies in which metrics are used. This Anglo-German study offers a comparative exploration of the role of metrics in two contrasting cases: highly developed, state-driven sectoral use of metrics in England, and more dispersed, decentralised use of metrics in Germany, in the case of research particularly. This survey-based study examines academics' perceptions of fairness of accountability practices associated with metrics-based evaluations at the organisational level. Drawing on organisational justice theory, the analysis focuses on the extent that academic evaluations of fairness are underpinned by contextual evaluations linked to organisational practices or more abstract evaluations of these measures. In the English context, fairness evaluations were more related to organisational uses of metrics. In the German context, negative justice evaluations do not seem closely associated with organisational factors but relate to a cultural critique of metrics. The analysis demonstrates that academics may hold views on metrics which are contingent not only on their perceived accuracy as measures but also on their perceived efficacy as tools which support broader sectoral and organisational developments, such that metrics start to lead their own life in organisational contexts. The comparative dimension to the study suggests that in some cases, context-sensitive use of metrics can enable emancipation from informal power networks in academia. [ABSTRACT FROM AUTHOR]

Heritage conservation and adaptive reuses of textile mills are not only tasks for planners, architects, and conservationists in practice, but are also framed by policies, inspired by initiatives, and promoted by real estate companies. Forty years of experience in Northwest England, and practices in the Rhine region of Germany provide reflections on good practice in heritage conservation and adaptive reuse. The article considers case studies of smaller cities and towns neighbouring these two industrial regions. Our main findings are: first, best practice criteria for heritage conservation of textile mills differ slightly between England and Germany. The discussion in England pays more attention to long-term use and effective management, and we also recognise the influence of powerful stakeholders with economic interests. Second, heritage conservation and adaptive reuse of textile mills is an important task for regional mills, smaller textile towns and within areas of deprivation. Furthermore, such areas provide examples of good practice. Third, a 'one size fits all' approach is not appropriate: instead, such projects require a variety of motivations, stakeholders, and concepts. Most important is the key role of heritage conservation in awareness-building, research, listing of heritage, and consultancy in the planning and construction processes. [ABSTRACT FROM AUTHOR]

This article examines COVID-19 and residential care for older people during the first wave of the pandemic in 2020, comparing a range of countries – Denmark, England, Germany, Italy and Spain – to identify the policy approaches taken to the virus in care homes and set these in institutional and policy context. Pandemic policies towards care homes are compared in terms of lockdown, testing and the supply of personal protective equipment. The comparative analysis shows a clear cross-national clustering: Denmark and Germany group together by virtue of the proactive approach adopted, whereas England, Italy and Spain had major weaknesses resulting in delayed and generally inadequate responses. The article goes on to show that these outcomes and country clustering are embedded in particular long-term care (LTC) policy systems. The factors that we highlight as especially important in differentiating the countries are the resourcing of the sector, the regulation of LTC and care homes, and the degree of vertical (and to a lesser extent horizontal) coordination in the sector and between it and the health sector. [ABSTRACT FROM AUTHOR]

Trilingual families need language support if they wish to maintain three languages. Most studies on trilingualism have paid little attention to the influence of grandparents as an affective factor. The aim of this paper is to shed light on the impact of the extended family, particularly grandparents, on trilingual families' language maintenance. The content of this study has been informed by an analysis of 70 interviews of trilingual families with children residing in England and Germany. Grounded Theory (GT) was used for the data analysis. It was found that most parents whose native language (NL) repertoire included the community language (CL) ‘dropped’ at least one of their home languages (HLs). This was partly related to the grandparents, who often lived in the same community. They tended to speak the highly regarded CL with their young grandchildren, rather than a minority language. In contrast, parents who did not speak the CL natively often used their HLs with their children in order to provide a means of communication between the children and their grandparents. Usually, they resided in a different country and did not speak the language of the community where their grandchildren lived. [ABSTRACT FROM AUTHOR]

Over the last decade, the introduction of professional standards and competences in initial teacher education for secondary teachers in England, France and Germany has provided the cornerstone of education reform in all three countries. The precise number and specific content of a measurable set of skills for teachers have offered challenges for policy makers, teacher educators, student teachers and teachers alike. The concept of standardised teacher education feeds into the idea that there is some convergence towards a uniform teacher ideal. However, an examination of the skills required of teachers in each of the three countries in this study reveals distinct education systems where path divergence is more evident. [ABSTRACT FROM PUBLISHER]

Purpose: We compare pre- and post-operative health-related quality of life (HRQoL) and length of stay after total hip replacement (THR) in matched German and English patient cohorts to test for differences in admission thresholds, clinical effectiveness and resource utilisation between the healthcare systems. Methods: German data ( n = 271) were collected in a large orthopaedic hospital in Munich, Germany; English data ( n = 26,254) were collected as part of the national patient-reported outcome measures programme. HRQoL was measured using the EuroQoL-5D instrument. Propensity score matching was used to construct two patient cohorts that are comparable in terms of preoperative patient characteristics. Results: Before matching, patients in England showed lower preoperative EQ-5D scores (0.35 vs 0.52, p < 0.001) and experienced a larger improvement in HRQoL (0.43 vs 0.33, p < 0.001) than German patients. Patients in the German cohort were more likely to report no or only moderate problems with mobility and pain preoperatively than their English counterparts. After matching, improvements in HRQoL were comparable (0.32 vs 0.33, p = 0.638); post-operative scores were slightly higher in the German cohort (0.82 vs 0.85, p = 0.585). Length of stay was substantially lower in England than in Germany (4.5 vs 9.0 days, p < 0.001). Conclusions: Our results highlight differences in preoperative health status between countries, which may arise due to different admission thresholds and access to surgery. In terms of quality of life, THR surgery is equally effective in both countries when performed on similar patients, but hospital stay is shorter in England. [ABSTRACT FROM AUTHOR]

Both Rational Action Theory (RAT) and Bourdieu’s habitus theory are employed to explain educational decision-making. RAT assumes that decision-making involves cost-benefit analysis, while habitus theory sees educational pathways as shaped by dispositions reflecting familial class of origin. These theories are often seen as conflicting, but we argue that they can fruitfully be used together.Proponents of these theories often employ different methods. RAT advocates usually employ survey data, while those favouring habitus theory often use case studies. If cost-benefit reasoning does partly explain educational decision-making, then we should expect to find evidence of it at the micro-level. Drawing on interviews conducted in Germany and England, we show that young people do indeed talk about their educational choices in ways which fit RAT accounts. Their class-based habitus often, however, provides upper and lower boundaries for their aspirations, thus conditioning the nature of the cost-benefit analysis entering into decision-making. [ABSTRACT FROM AUTHOR]

Education policy has undergone transformation in many countries over the last decade. In this article, we focus on the effects of the most significant international initiative in secondary education, which is the Organisation for Economic Co-operation and Development's (OECD) Programme for International Student Assessment (PISA). We analyse two countries that provide variation regarding the degree of change in their respective education policy-making due to this study; while Germany substantially reformed its education system in reaction to its mediocre PISA results, almost no change has been observed in England. As we show, alterations and shifts in ideas of education policy best account for such a change. [ABSTRACT FROM PUBLISHER]

The German and Swiss economies value skilled work highly and initial vocational education and training (IVET) has been the predominant traditional pathway into such work. However, concerns about a more ‘knowledge-based society’ and the ‘academic shift in the labour market’ are starting to undermine the status associated with those who complete IVET pathways and these former trainees also face competition from graduates from the relatively new Bachelor programmes in Switzerland and Germany. An international project investigated whether these developments pose a threat to developed IVET systems and whether companies are changing their recruitment strategies and how they rate the status of IVET. The findings from Germany and Switzerland were compared with the situation in England, the home of two-phase HE structures along with a very different tradition of vocational training. The findings from individual case studies in England, Germany and Switzerland are presented here, with the focus on the expectations of companies towards applicants with experience of IVET or Bachelor’s degrees. [ABSTRACT FROM AUTHOR]

This study examined attitudes on the ethics of bribe taking in four European countries -- France, Great Britain, Italy and Germany. Nineteen demographic variables (gender, age, marital status, etc.) were also examined, and most mean scores were found to be significantly different. Although most people thought taking a bribe was unethical, there was some divergence of opinion. [ABSTRACT FROM AUTHOR]

Within the context of globalisation, this article problematises some of the literature on teachers’ professional identities in which a convergence and homogenisation of the profession is implied. It achieves this by focusing on the early experiences of 32 newly qualified teachers in Norway, Germany, and England. The article explores conceptions of identity, deployed for this research, relating these to high- and low-trust forms of trust and accountability in teaching. Aspects of similarity and difference between the three education systems are then used to focus on generic as well as culturally specific issues raised by some of the interview extracts. [ABSTRACT FROM AUTHOR]

The three examples considered - England, France and Prussia - are all very important instances of capitalist agrarian transformation. They illustrate, moreover, strikingly different paths of agrarian transition. These are termed, respectively, landlord-mediated capitalism from below, capitalism delayed, and capitalism from above, and an explanation is offered of how these different outcomes came to pass and of why there was such a marked divergence in the nature of agrarian transition. It is argued that the character of the landlord class and of class struggle have determined both the timing of each transition and the nature of the transition. Both the quality of the landlord class and the manner and outcome of the class struggle have sometimes delayed, perhaps for prolonged periods, and sometimes hastened transition; and have had profound implications for the nature and quality of the transformation and how reactionary or progressive it has been. In this the state has always played a prominent part. It is further argued that differentiation of the peasantry is central to transformation: it is not an outcome but a determining variable, a causa causans rather than a causa causata. Differentiation of the peasantry feeds into and interacts with the landlord class and class struggle, these three being critical to the eventual outcome. The distinctly varying trajectories in the three crucial instances are explained in these terms. [ABSTRACT FROM AUTHOR]

A survey of social work academics' education profiles in Denmark, England and Germany is discussed. Material was collected in 2004, mainly from schools' Internet websites. Findings were classified by highest achieved level of qualification, using British terminology: ‘diploma’, ‘degree’ and ‘doctoral’. Findings are discussed with reference to the status of social work knowledge and social work education. This discussion is framed by drawing on the model of the teacher-researcher developed by Wilhelm von Humboldt (1767–1835). The German sample showed the highest proportions of social work academics with doctoral qualifications, with the lowest levels being found in the Danish sample and the English sample being situated in-between. [ABSTRACT FROM AUTHOR]