Analytical note on comparative legislation in the field of countering bullying and mobbing
Published on 13 March 2023, 15:17Abstract. A comparative analysis and generalization of the legislation of foreign countries on combating bullying and mobbing was carried out in the following areas:
- the model of legal regulation of bullying and mobbing;
- types of legal liability and sanctions (measures of influence) applied for acts related to bullying and mobbing;
- measures to prevent, respond to and counteract bullying and mobbing.
Legislation of the USA, Canada, France, Germany, Sweden, Norway, Poland, Estonia, Great Britain, the Netherlands, and Spain was analyzed. It was established that the model of legal regulation of bullying and mobbing provides for the determination of preventive and sanctioning provisions in legislation for actions related to persecution the victims in legal relations in the fields of education and labor. It was noted that there are no unified approaches to the definition of the terms "bullying" and "mobbing" in the legislation of foreign states, and legal liability for such actions, as a rule, is disciplinary, material, civil and criminal.
Key words: bullying, mobbing, persecution, victim, offender.
02/2023