Verletzung des Wettbewerbsverbotes durch Arbeitnehmer?

Urteil des Bundesarbeitsgerichts vom 17.10.2012 –AZR 809/11-

Der Arbeitgeber kann vom Arbeitnehmer Schadensersatz verlangen, wenn dieser ein Wettbewerbsverbot gemäß § 61 Absatz 1 HGB (Handelsgesetzbuch) verletzt. Hat der Arbeitnehmer insofern Geschäfte auf eigene Rechnung gemacht, kann der Arbeitgeber auch die dadurch erlangte Vergütung herausverlangen.

Im vorliegenden Fall kündigte der Arbeitgeber (Kläger) zunächst das Arbeitsverhältnis mit dem Arbeitnehmer (Beklagter). Im darauffolgenden Kündigungsschutzprozess einigten sich die Parteien mittels Vergleich. Im Vergleich wurde vereinbart, dass der Arbeitnehmer bis zum Ende des Arbeitsverhältnisses freigestellt sei. Seine Vergütung würde ihm bis zum Ende der Kündigungsfrist gezahlt.

Noch in der Zeit der Freistellung begann der Beklagte ein Arbeitsverhältnis mit einem Wettbewerber des Klägers.

Der ehemalige Arbeitgeber (Kläger) war nun der Ansicht, der Beklagte habe durch Begründung des neuen Arbeitsverhältnisses gegen das Wettbewerbsverbot verstoßen. Er verlangte vom Beklagten Herausgabe der Vergütung des neuen Arbeitgebers. Hilfsweise verlangt er Anrechnung der beim neuen Arbeitgeber bezogenen Vergütung auf das von ihm geleistete Entgelt.

In allen drei Instanzen blieb die Klage erfolglos. Das Bundesarbeitsgericht begründet dies damit, dass der Beklagte nicht gemäß § 61 Absatz 1 HGB verpflichtet ist, ein Festgehalt, welches er vom Kläger erhalten hat, an diesen zurückzuzahlen. Grund hierfür sei, dass der Abschluss des neuen Arbeitsverhältnisses mit dem Wettbewerber kein „Geschäft“ im Sinne des § 61 Absatz 1 HGB ist.

Somit bezog der Beklagte als Arbeitnehmer rechtmäßig sowohl das Arbeitsentgeld des Klägers, als auch das des unmittelbaren Konkurrenten.

Vgl. dazu Urteil des Bundesarbeitsgericht:

Verletzung des Wettbewerbsrechts im Arbeitsrecht?

 

Anmerkung:

Sowohl als Arbeitnehmer, wie auch als Arbeitgeber, ist der Wechsel des Arbeitnehmers zu einem Wettbewerber ein juristisches Minenfeld. Dies wird durch die aktuelle Entscheidung deutlich. Neben der Frage, ob man sich als Arbeitnehmer schadensersatzpflichtig macht, wenn man zu einem Wettbewerber des alten Arbeitgebers wechselt, stellen sich naturgemäß eine Vielzahl weiterer Fragen:

Arbeitnehmer, die zu einem neuen Arbeitgeber wechseln, haben oftmals einen hohen Kenntnisstand, wie die unmittelbare Konkurrenz (alter Arbeitgeber) des neuen Arbeitgebers Prozesse gestaltet. Sie unterliegen jedoch in vielen Bereichen sowohl gesetzlich, wie auch einzelvertraglich vereinbart, einem Wettbewerbsverbot / einer Schweigepflicht gegenüber einem neuen Arbeitgeber. Die Grenzen hier auszuloten und sich die vorhandenen Kenntnisse im juristisch rechtmäßigen Umfang zunutze zu machen, ist ein Ziel der Zusammenarbeit zwischen Kanzlei Müller und OSICON, dem bekannten Unternehmen für Wettbewerbsanalyse.

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