Social progress protocol
The European Trade Union Confederation has proposed a "Protocol on the relation between economic freedoms and fundamental social rights in the light of social progress" in 2008 as a response to the court cases in the Viking case 11 December 2007, the Vaxholm case 18 December 2008 and the Rüffert case 3 April 2008.
These verdicts from the European Court of Justice allowed, "Dumping" of salaries.