“…In Italy, the Code for Public Contracts -the main regulatory framework for public procurement -establishes the inclusion of specific labour clauses requiring the successful tenderer to safeguard employment levels and to apply the most representative private national collective agreement (NCA) of reference in the sector. Similarly, in Denmark, in the application of the ILO-94 Convention, the labour clause included in the call for tenders requests subcontractors to rehire the personnel employed in the outsourced service and to adhere to wage levels and working conditions set in the most representative NCAs within the relevant sector (Refslund 2020(Refslund et al, 2020. Furthermore, trade unions have a strongly institutionalized role in the public sector, as evidenced by the consultation rights that they enjoy in the case of outsourcing involving personnel, the widespread presence of their elected representatives within workplaces, and their high organizational density, above the EU average -in 2016, respectively, around 50 per cent in Italy and 81.5 per cent in Denmark (OECD, 2021).…”