Job retention programmes have been used in many jurisdictions to preserve jobs in enterprises experiencing a temporary reduction in business activity.34 Examples of these programmes include short- term work programmes that directly subsidise hours not worked35 and wage subsidy programmes that subsidise hours worked or top up the earnings of workers on reduced hours.36 34 A crucial aspect of all job retention schemes is that employees keep their contracts with the employer even if their work is suspended. 35 For example, the German Kurzarbeit or the French Activité partielle. 36 For example, the Dutch Emergency Bridging Measure (Noodmatregel Overbrugging Werkgelegenheid, or “NOW”) or the Job Keeper Payment in Australia ...