In the weeks since George Floyd died under the knee of a Minnesota police officer, the United States has been rocked by major civil unrest as people protest against police brutality. Fingers were quickly pointed at the US police unions as a major impediment to necessary reforms.

According to New Zealand Police Association president Chris Cahill, an important role of a police union is to make sure the views and experiences of frontline officers are heard in public debate on law and order issues. The union argues for police to have the right equipment and the right training to be able to keep themselves and the public safe.

However, he says it’s not the union’s job to automatically argue against any criticism of police. “We’re open to listening to criticism. It’s important that police do that. New Zealand police have a good relationship with their communities because we do listen.

“That’s what’s annoyed police here about the criticism from Black Lives Matter. They are totally ignoring the relationships that police have in their communities. There are some wonderful partnerships going on.”

Another important role of a good police union is to cooperate with police accountability processes, while still ensuring that any officer under investigation gets proper legal representation and is afforded the same due process as any other New Zealander, he says.

It’s also to bargain for good wages and conditions for police. This is not only good for members, but has a wider more altruistic benefit, Chris says.

Research shows that in countries where police are unionised there is less police corruption. That’s because police with good pay and a pension are less likely to try to supplement their income by nefarious means.

So how do police unions in New Zealand and the US differ?

The first difference is that the police service in New Zealand is, by comparison, very small and unified. In this country there are 10,000 police officers (alongside nearly 4000 Police employees), all working in one police department, under one commissioner. There is one police union, negotiating one national employment contract.

One police college trains all officers to the same standards, and one Independent Police Conduct Authority works to uphold the public’s trust in police.

This makes the police service here “very nimble” in its ability to change, reform and adapt, says Police Association senior legal officer Liz Gooch.

By contrast, the US police system is very large and fragmented, and operates in a different political, legal and social environment. Take the New York City Police Department, the largest municipal police service in the US – the entire New Zealand police force would make up just a third of NYC’s finest. And the NYPD alone is served by five different unions, for each officer rank.

Altogether, the US has about 800,000 police officers, serving in about 18,000 police departments, including municipal services, county sheriff departments or campus police services. The unions are numerous, with no one overall national body.

Compared with other occupations, US police are highly unionised (75-80 per cent of the workforce), which makes them a powerful lobbying force, particularly in a political system where police chiefs, district attorneys and public prosecutors are elected positions.

Some police unions are known to actively lobby against candidates for law enforcement positions, and for city councils and in state legislatures, that want police reforms, including tougher accountability processes, and to donate their money and voice to police sympathisers.

Over the years, police unions have negotiated contracts with city authorities that have become increasingly lax in their accountability provisions. Not only is this because of the political pressure the unions can exert, but also because, in contract negotiations, many cash-strapped city councils have offered police unions easier disciplinary terms in lieu of pay rises they can’t afford.

Robert Olson, chief inspector of the Garda Síochána Inspectorate in Ireland and former chief of police in Minneapolis, told a Reuters investigation into police contracts in 2017: “During recessions [the city] would give the union management rights in lieu of money. And when that happens, that’s when trouble starts.

“We’re not talking about just one union contract. We’re talking about incremental changes in contracts over years and cumulatively, suddenly, there’s all of these hoops, which makes it far more difficult for chiefs to sustain discipline,” he said.

The same Reuters report found that in Chicago, in 2016, of 1000 civilian complaints sent to Internal Affairs, only one resulted in disciplinary action.

Police unions are entitled to ensure their officers are afforded due process, but critics say the balance has tipped too far in their favour in the US.

Many police contracts now stipulate that information about an officer’s disciplinary breaches – such as demotions, suspensions and disciplinary transfers – can be wiped from their record in as little as three years, and in some contracts as little as six months.

Some clauses allow disciplined officers to forfeit vacation time or sick leave instead of serving suspensions.

The doctrine of “qualified immunity” protects police from civil lawsuits arising from misconduct on the job. And access to arbitration can often lead to officers being reinstated after being suspended or fired.

Activists for reform say such protections give police a feeling of invulnerability – that they can get away with using excessive force, particularly in Black communities.

At federal, state and local authority level, police reform is now high on politicians’ agenda, with many calls for “defunding” of police services. This most often means restructuring of police operations to include more community policing, and removal of some funding to be used by social agencies in poor communities.

Under intense pressure from the national protests sparked by George Floyd’s death, police unions are conceding that reform is necessary. Three of California’s largest police unions took out full-page ads in newspapers in June, pushing for national police reform.

They recommended creation of a national database of former police officers who had been fired for gross misconduct to keep other agencies from hiring them.

The unions also called for a national standard on use of force that “emphasises reverence for life, de-escalation, a duty to intercede, proportional responses to dangerous incidents and strong accountability”.

Paul Kelly, president of the San Jose Police Officers Association, said union leaders were sensitive to criticism that the announcement was a face-saving tactic. “We don’t want to be the roadblock in change,” he said. “The days of unions trying to block reform and new policy are gone. We can’t continue to say the stats don’t show a problem... That rhetoric has to stop.

“We still believe in the thin blue line, but who we want on that line with us is our community,” he said. “That is who we serve.”

Chris Cahill says New Zealand police should feel fortunate they live and work in the social and political conditions in this country rather than the US.

He says it’s hard to generalise about the quality of US policing, particularly in terms of charges of racism. “What I would say is that it’s clear there are significant barriers between some communities and police.”

He says American police union colleagues are feeling “pretty bruised” by the intense criticism they are facing. He does not believe the debate about police conduct there is “even-handed”, in that it fails to acknowledge the dangers that US police face at work every day in a highly armed society.

However, he is convinced that US police unions fully understand that they can’t ignore it when large parts of society are advocating for change, and that it’s better for them to be “inside the tent” when those changes are being debated so the change works for both society and police.

On the “defunding” issue, he says there is no harm in US authorities casting an eye over how money is spent to address crime, violence and drug addiction. But social problems take generations to change, “and in the meantime you need someone to keep order”.

Liz Gooch says the systems governing police accountability are a lot clearer and more transparent in New Zealand than the US, with less risk of corruption. The separation of powers – between the legislature, the executive and judiciary – means decisions on prosecution of police officers are not influenced by politicians.

It’s easy to judge US police “from a little, safe country”, she says, but “every police officer should be able to go home alive at the end of their shift. We forget how highly armed the US population is”.