Punitive measures relating to the exercise of freedom of association will constitute a restriction and will have to be justified1: thus, for example, employers using financial incentives to induce employees to surrender important aspects of their trade union rights will violate the right to freedom of association2. However, Article 11 cannot be relied on to resist all forms of restriction on cooperation, such as EU rules in respect of anti-competitive agreements3. When considering sanctions for association membership the European Court of Human Rights often examines the issues under Article 10 (freedom of expression)4 and deals with the complaint under
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