Workers in Europe and Africa are fighting back against Twitter layoffs, with one senior exec successfully reclaiming her job

In Ireland, global vice president for public policy Sinéad McSweeney on Friday won a High Court injunction suspending her dismissal, and on Wednesday Twitter told the court it had restored her to her position. That may be taken as a positive sign by ex–Twitter staff fighting back elsewhere. In Germany, half a dozen of them have teamed up with a major trade union to get better terms from the company. And in Ghana, laid-off employees in Twitter’s only African office have formally protested to the government that the firm was trying to “silence and intimidate” them into accepting worse terms than they are due.

On Oct. 28, when Musk completed his acquisition of Twitter, the company had about 7,500 employees; it is not clear how many worked outside the U.S., though it was a small fraction of the total. Over the next couple of weeks, Musk laid off about half of the staff worldwide. More left voluntarily, and by the time Musk demanded on Nov. 17 that remaining staff agree to work very long hours at high intensity, only an estimated 2,900 were still around. Hundreds reportedly left following that demand, and the last reported total of remaining employees was 2,300.

But many Twitter employees abroad have job protections that Americans lack. Countries in the European Union have relatively strong employment laws that place big requirements on companies that are conducting mass layoffs. Such companies need to give substantial notice of the dismissals, which have to be justified; they are also supposed to consult with workers about limiting the impact. Laid-off workers outside the U.S. are objecting that Twitter, in essence, ignored those legally required steps.

Twitter, which has laid off most if not all of its communications department, did not respond to a request for comment.

“Tom”—he’d prefer to use an alias at this time—was a senior software engineer in Twitter’s German operations. When Musk made his layoff announcement on Nov. 4, those in the U.S. were immediately impacted, but Tom says he and his colleagues were only told that “our role might potentially be impacted”—a discrepancy Tom attributed to the fact that “in Germany you can’t just lay off people by just writing an email.”

Tom says the lack of clear information for German workers led him to believe the company may not have yet decided what to do with them. But then came the chaos.

‘Not pressing a button’ isn’t the same as resigning

Tom’s termination letter arrived on Nov. 16. The letter put him on “garden leave”—meaning he is still technically employed but not expected or allowed to work—until the dismissal takes effect at the end of the year. However, the letter gave no reason for his redundancy. “You can’t really do that in Germany,” Tom said in an interview. “There are specific rules you need to follow, and it’s currently unclear if Twitter did do all of that.” That same day, Musk emailed an ultimatum to remaining staffers around the world, saying they had to either commit—by clicking a link in the email—to being “extremely hard-core,” or to leave the company. “In Germany, not pressing a button doesn’t mean you accept voluntary resignation,” Tom said.

That same argument is what won McSweeney—a seasoned lawyer—her temporary injunction in Ireland. She told the court that Twitter had stopped treating her like an employee after she declined to respond to the “generic and vague” email, but that didn’t mean she had resigned. According to reports Wednesday, Twitter has now told the court it will restore McSweeney’s access to the company’s IT systems and Dublin premises.

Around 140 of Twitter’s 500 Irish employees were made redundant in the cuts, Enterprise Minister Leo Varadkar said on Nov. 18 after “at long last” receiving Twitter’s formal notification of the cuts—notification that was supposed to arrive well ahead of the terminations, to allow for a 30-day consultation process.

“It remains to be seen if they’ve broken Irish labor law. It depends on how they proceed,” said Owen Reidy, secretary-general of the ICTU labor union, which is not involved in any action against Twitter.

In Spain, Twitter laid off 26 employees through an emailed notice on Nov. 6, again flouting a national requirement for prior notice and justification, as well as negotiations. “All companies must comply with labor rights, whatever power they have,” Labor Minister Yolanda Díaz tweeted the day after the layoffs. “Twitter will not be an exception,” she said, adding that her department was “acting in the case.”

On paper, Musk was required to argue why he needed to lay off half the staff—including, if it was for economic reasons, that Twitter had suffered “persistent decrease in its level of income.” And at least in theory, if the government can prove the layoffs broke Spanish law, Musk would be obligated to offer staff their jobs back. “The null dismissal implies the reinstatement of the workers as if their dismissal had not taken place, and the payment of all processing wages,” labor lawyer Teresa Ezquerra told the newspaper El Confidencial last week.

So far, laid-off workers in Spain have not taken their case to court, or contacted labor unions to help negotiate on their behalf. “Those who have been fired will take the compensation, and that’s it,” Diego Gallart, a spokesman for the UGT union told the Spanish version of HuffPost on Monday. And for 26 employees who remain, the situation remains deeply uncertain. “We have been in a surreal limbo for almost a month,” one of them, unnamed, told the HuffPost. “Until Musk, a lawyer, or someone sends me a fax or an official communication that I am fired, I am not moving from here.”

In Germany, Tom and a handful of his colleagues enlisted the Verdi union to their cause. He says that move, plus raising a stink in the local media, prompted Twitter to belatedly make a severance offer. Although Musk has repeatedly claimed over the past few weeks that laid-off workers were getting three months’ severance pay, those outside the U.S. have had to fight for theirs. (Many in the U.S. have also experienced delays in receiving severance, though Twitter has blamed that on a class-action lawsuit that has been launched against the company in California.)

However, even with a severance offer—of less than three months, though Tom wouldn’t specify the offer while negotiations are ongoing—in hand, the going was not smooth. Earlier in the month, Twitter emailed Tom’s personal account to ask for information, and when he responded his emails initially bounced, because the company had failed to white-list his address. When he later asked Twitter for a contact point so his lawyer could discuss the wording of the severance terms, Tom says Twitter could only offer “the same email address that didn’t work last week.”

‘Insulted’ in Ghana

Similar experiences were described by Twitter employees outside Europe, who also found Musk to be flouting local labor regulations.

On Nov. 1, Twitter finally opened its first office in Africa, in Accra, the capital of the West African nation of Ghana. Three days later, on Nov. 4, the entire Ghana staff—roughly 20 people—received generic layoff notices that were not addressed to individual people, telling them that owing to a company “restructuring” their last day of work would be Dec. 4. Until then, the employees would be put “on garden leave.” Again, the employees were given a Twitter email address if they wanted to raise concerns, but emails to that address bounced back.

There was initially no mention of that elusive three months’ severance pay, which those abroad were apparently due. That’s what truly irked the African staff, according to a lawyer now involved in the case.

“They were insulted,” says Carla Olympio, an attorney in Accra representing about 10 laid-off Twitter staff in trying to negotiate with the company. “It raised the question: What accounts for the difference?” she says.

After the BBC and CNN reported on Musk’s Ghana layoffs, Twitter sent a second letter to laid-off staff on Nov. 8, offering to negotiate severance pay. Olympio says the offer was far less than the three-month severance offer that Musk had said Twitter would pay to all people the company laid off, though she also declined to say how much the offer was. She says the impact was especially severe for those staff who had been recruited from other parts of Africa, and who had relocated their families to Accra and placed their children in local schools. “There has been no discussion of repatriation,” she says.

On Nov. 17, Olympio filed a petition on behalf of the staff with the Ghanaian government’s chief labor officer, claiming that the company had violated Ghana’s laws, which require advance notice of layoffs and a negotiated severance package. “It is our contention that this is a clear display of bad faith by the current management of Twitter Inc.,” says the petition, which was shared with Fortune, and which compares their treatment with European workers. “The treatment of African employees is in stark contrast to other jurisdictions,” the petition says. “In the U.K., for example, which has similar redundancy laws to Ghana’s, Twitter employees were given some days to select representatives to negotiate a redundancy package on their behalf.”

In comparison, the staff said, Twitter “seeks to silence and intimidate former employees into accepting any terms unilaterally thrown at them.”

Olympio says she believes that Twitter not offering the African staff the same layoff terms as elsewhere was either a conscious decision, or perhaps simply a rash move that they did not believe would have any legal consequences. “I would say it was either deliberate, or it was reckless,” Olympio says. “You have a subsidiary incorporated in the country. Why would you not know what the laws in the country are?”