What is different about how references work between Germany and UK/Ireland? My ex-manager doesn't want to give me a reference and I don't understand

Question

I live in Ireland and until recently worked as a technical lead for a multinational software company.

Then recently the company began a voluntary redundancy program which I applied for and was accepted.

For the last year in the company I was managed remotely by a manager in Germany for HR aspects and a local program/project manager for day to day delivery work.

I asked my manager in Germany is it possible for him to be one of my references for my future job applications. He replied that because references are so completely different between UK&I and Germany, he's not sure if it is a good idea, and also because in the 12 months we worked together he didn't really get to know me well enough to provide a good reference.

Although he was the manager I reported to, he suggested I should ask the other manager I worked more directly with on a day to day basis for a reference instead.

I am asking the other manager anyway but my challenge is, I think I may need 2 references.

I am not aware of any issues there might be with my work, I feel I have worked extremely hard and that my manager is aware of this.

So I can't help feeling a little let down by his declining my request. He is managing what I think is an awful lot of people, something like 35+ direct reports across 4 countries, so maybe it is a challenge to get to know that many people well in a year.

What I would like to know is:

Firstly, what is different about how references work between Germany and UK&Ireland? I am not clear what he means?

Secondly, at this point, is there anything else I could say now that might change his mind?

Any other suggestions about how to proceed? The only other option I can think of is to make the references request to my previous "HR" manager as well, but I don't want to bypass any other steps I could take with this manager.

Answer 1

I obviously cannot know if this is really the full explanation but references really are quite different in Germany so that your manager might not even quite understand what you are expecting of him.

To give you an idea, in Germany, it's customary when leaving a job to receive a “certificate” (Zeugnis) detailing your duties and performance over the whole duration of your employment at that company. It uses a coded language so that something like zu unserer vollen Zufriedenheit (“to our complete satisfaction”) in the summary is actually pretty bad. A good certificate would say stets zu unserer vollsten Zufriedenheit (“constantly to our completest satisfaction”; “vollsten” sounds just as odd as “completest”). It gets worse: for example a word like “empathy” (“Einfühlungsvermögen”) is generally taken as implying sexual harassment or inappropriate behaviour toward female colleagues.

Employees are entitled to a reference certificate and it must be broadly positive. There have been numerous court cases about this (one of them made the news in Germany this week). People really go to court over the little nuances I described above (in the last case, the court confirmed that employees are entitled to zu unserer vollen Zufriedenheit but the onus is on them to prove they deserve more, whereas employers must have specific serious grievances to write anything more critical).

Traditionally, you would send all your certificates (along with your transcripts all the way back to secondary school) with each and every application, even before the first interview or phone screen (although more and more companies now accept or even invite what's called a “short application”, i.e. what you would think of as a regular job application).

In a multinational company, I would expect some people to be aware of the differences but even in relatively young and dynamic companies in the IT industry, I have met recruiting managers who were genuinely surprised that people from other countries could not produce such certificates or would invite them to contact someone else as a reference.

So it seems possible to me that your manager thought you expected him to write such a certificate and that he is unsure about how to express the right nuances in English or concerned about getting himself in hot waters if you were not happy about the result. Or maybe he does know how it works in Ireland and the UK but he is uncomfortable at the idea of being contacted by someone else as it is simply not done in Germany.

Answer 2

It seems your manager does not want to provide a reference, and has given a good reason -

because in the 12 months we worked together he didn't really get to know me well enough to provide a good reference

It sounds like the manager believes there really is some big difference between how references work in these countries - if there is a difference, I don't know what it is.

Edit - it turns out there is a big difference, which has alot to do with the manager's refusal - for more detail please see the accepted answer. The rest of this answer focuses on references as they are used in the UK, US and other countries rather than the German Zeugniss certificate, which is dealt with by @Relaxed in their answer.

It looks like you won't get a reference out of this manager, and even if you could twist his arm into giving you one, he has already said he doesn't think he can provide a good reference, so do you really want it?

In general it's a good idea to ask for references from people that you have worked with enough that they have some idea of your abilities and character, and think well enough of you to give a good reference - this manager feels he is not that person, and he may well be right even if you disagree.

My advice is to definitely ask your other manager, and anyone else you can who you think will have something good to say about you. You can't force him to give a reference and it would be unethical to list him as one regardless - you just need to work with what you have.

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EDIT after re-reading the question:

asking other managers would not be 'bypassing' in this situation, as normally there wouldn't be any expectation about a chain of command when asking for references - ask whoever you think will be a good reference. If he's refused to give one, he won't feel put-out if you ask someone else.

Answer 3

You seem to be interpreting this as a huge slight and you may be over-thinking things. It might simply be that he doesn't really feel he knows you well enough to write a useful reference, just as he says.

I can see why this is inconvenient but in the absence of any evidence that something else is afoot I think the best thing to do is to respect his decision and get a reference from someone who knows you better.

Who knows, you might end up with a better reference from doing that, too. It certainly seems counter-productive to try and insist on a reference from someone who doesn't seem to want to provide one, regardless of their reasons for that.