to labor laws favoring the employee, Brazil has also seen a significant increase in unionized workers in the past several years. The number of unionized workers stood at 18.35% in 2005, up from 16.73% in 2001.94 Labor is also guaranteed the right to strike in the constitution, and labor agreements either can be in writing "or maybe implied from the relationship between an individual and the company."" Labor laws in Brazil also require any disputes between manage-ment and workers "to be settled in labor tribunals rather than in the companies involved, so 1;ttle space is left for direct negotiations between employers and employees."96