They will of course be different sources as they are both sovereign states
I sort of understand French employment law but do not understand French employment practice never having worked there.
You really ought to get a local employment law specialist or go to tone of the big UK solicitors who either have overseas offices or specialists sitting in London..
I liken it to teaching an employee French and then expecting to understand the culture let alone the working culture.

Catherine
Both of these countries have legal systems derived from the principles of the Napoleonic legal code; where procedure and specific wording of law drives the system. Consequently the very British notion of adhering voluntarily to codes of good practice and judging a case on its specific merits, behaving reasonably, and precedent are not at the heart of the legal systems. In both these countries specific binding sectorial collective agreements also play a large part in the legal landscape.
In Belgium disputes relating to employment contracts can only be referred to arbitration after they have arisen (Article 1676, §5, Judicial Code (JC) with Article 13 of the Belgian Employment Contracts Law of 3 July 1978) - arbitration then takes place vie a formal arbitration tribunal with contradictory evidence being exposed in a formal manner.
In France an employment tribunal (prud'hommes) claim can only proceed once a pre-hearing and an attempt at conciliation hasoccured before a judge.
If you want an introduction to employment law as applied in these countries a good approach would be to attend a training course run by companies like Eversheds. In the event of problems or doubt ALWAYS use a local legal firm, since the cost of getting it wrong can be very high.
If you have a payroll operator in these countries, then maybe they can offer you a legal overview (many of them are equipped to do this)

Hi Catherine,

For an English summary of employment law, you could try iclg.com/.../employment-and-labour-laws-and-regulations to give you some background information. Mercer and ECA International also have reports on employment conditions available to buy - but, as Peter mentioned, it's a good idea to get legal advice. If your company already has an agreement with an international legal company, it would be worth checking if they can give you a summary for your two locations - some legal firms will include delivering a number of education sessions as part of their agreement.

In reply to Julia:

thank you all fro your comments - all very helpful. Julia - fantastic link - thank you!