place where the work is to be or has been performed

law of the place where the work is carried out

In the absence of a choice of law, a consumer contract is governed by the law of the country of the consumer's habitual residence, and an employment contract is governed by the law of the place in which the employee habitually carries out his work in performance of the contract or in the absence of such a place, the law of the place in which he was engaged.

For a service contract, for example, an ACAN outlines for suppliers the nature of the work to be completed, a proposed supplier and rationale for proceeding, the kind of knowledge and experience considered essential, the time frame involved and the estimated value of the contract.

In order to facilitate any adjustment of a protection measure, the certificate should indicate whether the address specified in the protection measure constitutes the place of residence, the place of work or a place that the protected person visits on a regular basis.

Consequently, in the case where the employee carries out hisactivities in more than one Contracting State, the Convention must be construed as guaranteeing the applicability of the first criterion referring to the law of the State in which the employee, in the performance of the contract, performs the greater part of his obligations towards his employer and thus to the law of the place in which or from which the employee actually carries out his working activities and, in the absence of such a centre of activities, to the law of the place where the employee carries out the greater part of his activities.