Abstract

Article 12 of the Law on the Administration of Free Trade-Industrial Zones delegates the regulation of employment in these zones to special regulations, while the 1994 Regulations on Employment, Insurance, and Social Security provide specific rules on employment contracts, termination, and dispute resolution. Supreme Administrative Court Unification Judgment No. 366 accepts recourse to general mandatory law where regional regulations are incomplete, ambiguous, or silent, while the judgment dated 20 November 2025 annulled parts of the protective provisions of the 1994 Regulations. The central issue is the effect of this distinction on termination of employment contracts by foreign employers and the distinction among three levels: mandatory Iranian law, non-binding international labor standards, and potentially binding obligations arising from home-country law or corporate structure. ILO Convention No. 158, which Iran has not ratified, is examined as a comparative benchmark concerning valid grounds for termination, the right to be heard, and access to an impartial body. The ILO MNE Declaration, UN Guiding Principles, and OECD Guidelines are analyzed as standards of corporate conduct and accountability. French and German laws and the EU directive on corporate sustainability due diligence are considered only where personal, substantive, and temporal conditions are met. Using a descriptive-analytical and comparative approach, the study examines the legal effects of termination, remedies, and the scope of a proposed institutional solution.