The provisions found unconstitutional were those that the court ruled here that the « First Amendment to the Constitution prohibits the levying of an investment tax [by workers] who do not want to join or support the union. » In doing so, the Court also concluded a very strong contrast with Abood. While Abood focused on public employees, the facts of this case are personal assistants who respond to private clients and not to the government. As a result, personal assistants « do not enjoy most of the rights and benefits that civil servants have granted and are not compensated by the State for claims resulting from acts committed in the course of their employment ». The question arises as to which organisations can genuinely represent workers. Some national laws provide for elected « workers` councils » or employment councils different from trade unions. The German system of works councils places workers` representatives on the works councils of the largest companies and on the daily board of directors of the coal, steel and steel industries. While these works councils exchange information and organise consultations, they do not conduct collective bargaining. In the Philippines, since 1994, the Government has encouraged the dissemination of employment councils in order to overcome the serious conflict that has marked labour-management relations over the past decade (International Labour Organization, 1998). In Central America and other regions, many factories have associations of « solidarity » workers and managers, created as « mutuals » with a financial contribution from the employer, to lend housing, education and other uses and to promote « unity and cooperation » between workers and employers (International Labour Organization, 1994). In the United States, the National Labor Relations Act of 1935 made it illegal for any employer to deny union rights to a worker. The issue of the union organization of government employees in a public sector union was much more controversial until the 1950s. In 1962, President John F.
Kennedy passed an executive order granting federal employees the right to unionize. However, the Court found that the legislation did not minimally affect Charter rights and that the government had not provided any evidence to support the conclusion that the infringement was minimal. Instead, the government had merely asserted that the legislation infringed at least the rights.