O'Reilly: Theoretical Considerations in Cross-National Employment Research

O'Reilly, J. (1996) 'Theoretical Considerations in Cross- National Employment Research', Sociological Research Online, vol. 1, no. 1, <http://www.socresonline.org.uk/1/1/2.html>

Theoretical Considerations in Cross-National Employment Research

by Jacqueline O'Reilly
Senior Research Fellow, Labour Markets and Employment Research Group, Wissenschaftszentrum Berlin, Germany

Received: 7/2/96 Accepted: 25/3/96 Published: 29/3/96

Abstract

This article critically reviews a range of theoretical approaches to cross-national employment research in terms of universal, culturalist and intermediary perspectives. These approaches have difficulty accounting for change and the co- existence of similarity and diversity, as well as being 'gender blind'. Debates on the welfare state or women's employment have shown more interest in gender although this tends to become an optional variable in the cross-national comparison, or where there have been attempts to make it more central, the meaning of cross-national differences becomes blurred and confused. It is argued that an employment-systems approach, coupled with the gender order perspective, can provide a useful framework of analysis which enables us to identify how comparable pressures for change have generated specific interest coalitions; these coalitions resolve conflicts by agreeing on a particular gender compromise.

Keywords:

Convergence and Divergence; Cross-National Employment Research; Employment Systems; Gender; Gender Order; Patriarchy

Introduction

1.1: Cross-national research on industrial organization and labour markets over the past twenty five years has tended to take one of two approaches. Either researchers have tried to identify global, universal trends in industrial organization, or, they have given more emphasis to the differences that exist, and appear to persist, between societies at similar levels of industrial development. These apparently contradictory findings highlight the point made by Lane (1993: p. 275) that one of the shortcomings of much comparative research has been the problem of developing an 'appropriate comparative theory.' This makes it difficult to encompass 'cross-national differences and universal social trends' within a single framework. Sorge (1994) has argued for the development of a new 'dialectical' framework that can help synthesize these different approaches. Such an approach should be able to take account not only of the influences of institutional regulation, but of the attitudes and capacities of actors to bring about change. We can also distinguish cross-national studies in contemporary sociology on two further grounds. First, there are 'gender-blind' studies that concentrate on forms of economic production and industrial organization. And, second, there are studies, usually concerned with the welfare state or forms of women's paid labour market employment, which, to a greater and lesser extent, try to include a gender perspective. For the most part debates within these two fields have run in parallel, oblivious to the other, despite the fact that in terms of cross-national comparisons they are often concerned with similar problems related to structure and agency, convergence and divergence.
1.2: This article sets out to critically review these debates. It attempts to suggest ways of developing a comparative theoretical framework to address employment related issues that can retain a core conceptualisation of gender. This is likely to raise more issues than it can hope to resolve within the present remit. Nevertheless, given the growing importance of comparative research this article aims to act as a catalyst to provoke a more extensive debate on this theme. We start first by looking at the rationale and motivation to embark on comparative research in the first place.

Why Bother with Comparative Research?

2.1: There are a variety of reasons why researchers embark on comparative projects. These can include simple curiosity, or a sense of affinity with a particular foreign culture; concern for the competitive success, or failure, of their own country in comparison to others; or concerns about inequality and possible social policy solutions. Two major factors which have stimulated an interest in this area have come from 'managerial' or policy makers' concerns on the one hand, and theoretical interests on the other.
2.2: Managerial motives for conducting cross- national research often seek to identify 'best practice'. The recent fashion for Japanese working practices like Just-In-Time (JIT) and Total Quality Management (TQM) is an example of this. Subsequent attempts to adopt and adapt these practices in Western organizations, have met with varying degrees of success^[1]. In social policy, concerns to identify 'best practice' have also encouraged the use of cross-national comparisons. For example, there have been a number of studies examining the effects of welfare benefits or child care provision in Scandinavia, the US, the UK, France and other countries^[2].
2.3: From a theoretical perspective empirical cross-national research has highlighted weaknesses in the generalisations applied and exported to 'foreign' cultures. Warwick and Osherson (1973) argue that:

Relationships once assumed to be universal have been shattered on the proving ground of the non-western world. As a result there is now a more cautious and less grandiose attitude in theory construction, and a renewed quest for explanations that will stand the test of varying socio-cultural conditions. (1973: p. 6)
2.4: The understandings developed from empirical cross-national comparisons should be able to augment theory formulation. Nowak (1989) argues that an inductive and exploratory approach provided by comparative research can contribute to resolving some the current problems in social theory. One of the major values of such research is that it can challenge implicit assumptions that our own national system of organization is the best, or only, way to organize. We can also learn how the varied experience of industrialization has had long-term influences on current social arrangements. These differences can lead us to raise questions about the causes and effects of contemporary social structure and social action. This extends concern beyond the academic community, so that managerial and social science motives need not be exclusive.
2.5: Although both sets of motives can often inform each other, it is also important to recognise that the central focus of interest from each perspective varies. Managerial perspectives tend to seek normative and prescriptive solutions, whilst social science approaches are more interested in analytical methods and theoretical implications. However, each perspective can be mutually informative. Social science can inform managers and policy makers why there are no 'quick fix' solutions, whilst managerial and policy concerns can, and are, focusing research agendas on pertinent contemporary issues.

Background to the Debates

3.1: Comparative research was of interest to nineteenth and early twentieth century writers like Marx, Durkheim and Weber, who, according to Warwick and Osherson (1973: pp. 4-5), were influenced by classical evolutionist research. The concept of evolutionism when applied to social development suggested that societies pass through a similar series of universal and historical stages, as they become more 'civilised'. Despite coming from different political positions, these universalist theorists shared a similar set of basic underlying assumptions about the trajectory of human development.
3.2: However, the unilinear model of social evolution was challenged by anthropological research, such as that of Malinowski whose functional analysis of single societies suggested that these societies were unique coherent entities. The implications of these claims were that a society needed to be understood from a more holistic approach. Such an approach is opposed to reducing particular characteristics of a given society to the status of a few independent variables, and comparing them across societies. Instead greater emphasis is given to showing the relationship and development between different aspects of the same society.
3.3: These two basic approaches have continued to underpin contemporary disputes about universal and particular trends in social development. These conflicting traditions run deep and persist. Today debates in cross-national research are divided between those who focus on similarities and convergence, in contrast to those who emphasise differences and divergence. Those who stress universal trends often underplay cultural differences in their search for similar patterns across societies, whilst those who stress divergence tend to take a more holistic approach and give greater emphasis to the impact of culture.
3.4: The concept of culture as a significant explanatory variable is a key concern in cross-national comparative research. However, this idea has received quite diverse theoretical treatment. Hill (1973) points out that the problems in comparative research stem from:

...the current status of the comparativist's major independent variable: cultural or societal heterogeneity. Clearly, the variable is N-dimensional, and comparative sociologists have not as yet agreed on the size of N, let alone on the conceptual nature of the dimensions that define N-space. (Hill, 1973: p. 459)
3.5: Over twenty years later this problem still appears to be unresolved. One of the problems in trying to conceptualise, and operationalize culture for empirical research is, as Casassus- Montero (1989) points out: "Où faut-il chercher pour trouver l'explication des différences?" ('Where should we look to find the explanations for differences?'). Any analysis incorporating the impact of culture would need to include a comparison of the norms and values, as well as the mechanisms or institutions transmitting these values, for example the family, the state, the education and training system, trade unions or even religious organizations^[3]. The implications this has for comparative, empirical research are potentially overwhelming^[4].
3.6: Nevertheless, important contributions to the field of cross-national research have sought to grapple with these problems both at a theoretical and empirical level. The studies discussed in this article are categorised in terms of universal, cultural and intermediary perspectives; the final section examines studies with a stronger gender-orientated focus. In the light of this assessment this paper sets out to indicate potentially useful approaches for conducting cross-national employment research in the future, where gender is a core component of analysis.

Universal Theories of Convergence

4.1: Universal theories, although coming from different political perspectives, share a similar underlying theme: they assume a common dynamic. The main contribution of these differing schools of thought to comparative research has been to argue that there are shared, universally identifiable, pressures and trends working across all industrialized societies. Some of these early theories have been modified to accommodate empirical evidence that refuted the predicted universal pattern. Nevertheless, at the core of these theories is the assumption that generalisations can be made on the universal level, applicable to all countries. Here we will focus on Marxism and Marxist Feminism, Industrialism and Contingency theory.

Marxism and Marxist Feminists

4.2: Marx's observations of the early stages of industrialization, in the last century, identified the varying patterns of state and capital consolidation in Britain, Germany and France^[5]. For example, while Britain retained parliamentary democracy, France and Germany had authoritarian or unstable liberal democratic governments. In Britain there were signs of a collective class consciousness developing amongst the proletariat, albeit through trade unions, whereas there was a lack or a fragmentation of class consciousness in France and Germany. In his later work Marx used these particular observations to develop a theory that could be applied to capitalist development in general, which he argued would become a universal phenomenon^[6]. Such a perspective is predicated on the argument that although ruling elites may respond to the universal contradictions and pressures of capitalism indifferently, essentially the structural demands of the capitalist mode of production to extract surplus value and generate profit will require them to be behave in similar ways. The inherent class struggle between the property owning class of capitalists to reduce the wage rates and skill levels of the propertyless proletariat would ultimately be resolved by communism^[7]. Although as the events leading up to 1989 have indicated, this promised more in theory than in practice for 'real-existing' communist states.
4.3: Revisions of Marxism try to take account of changes that Marx did not anticipate, as well as engaging with discussions on feminism. For the purposes of this article we are particularly interested in seeing how these debates have contributed a gender dimension to comparative research. Feminism has sought to challenge Marxism by arguing that exploitation occurs beyond the cash- nexus and outside the factory walls. Various attempts have been made to integrate an analysis of patriarchy in relation to the concept of class. Essentially Marxist Feminism has moved from the domestic labour debates, that attempted to conceptualize how domestic labour contributes to the production of surplus value, to accounting for inequalities generated by capitalism and patriarchy^[8]. One of the key issues in this latter debate is whether patriarchy is essential to capitalism, or whether it represents a separate system that is dependent on capitalism. The key concepts that account for social inequality are class and gender.
4.4: A major problem with the dual system approach, as Young (1981) points out, is where does one system end and the other begin, or should we analyse them as part of the one system? This raises questions as to whether or not patriarchy is essential to capitalism, and, secondly, why did earlier forms of patriarchy need to move to a capitalist system? A further problem arises, as Joseph (1981) points out, when this perspective is applied to the issue of inequality amongst non-white ethnic groups. Joseph's main concern is with ethnic diversity in the US, but this critique could also be applied to cross-national differences related to the varying importance and structure of the family in different societies, in particular when we consider the influence of colonialism and post-colonial migration for countries outside of Europe^[9].
4.5: One of the major critiques of Marxism, which can also apply to Marxist Feminism, is the over-emphasis on structural determinants. Lane (1989: pp. 26-7) argues that Marxist concerns with capitalism as an international system has led them to make 'grand sweep' generalizations. This has meant a relative neglect of 'meso-level peculiarities':

This methodological shortcoming of a narrowly Marxist analysis may be attributed to the fact that the actor and his/her perception and manipulation of organizational relations tends to disappear from sight. (Lane, 1989: p. 27)
4.6: Granovetter (1985) makes the case for a perspective that can take account of actors in relation to the institutions in which they operate:

Actors do not behave or decide as atoms outside a social context, nor do they adhere slavishly to a script written for them by the particular intersection of social categories that they happen to occupy. Their attempts at purposive action are instead embedded in concrete, on-going systems of social relations. (Granovetter, 1985: p. 487)
4.7: If we are to have a perspective on change we need to be able to locate how institutions, that forms the social system, shape the constraints and capacities of actors (Folbre, 1994).
4.8: Maurice et al. (1986: pp. 205-9) further criticise Marxist approaches for being 'reductionist'. Whilst developments in contemporary Marxist thought have allowed for a degree of autonomy amongst actors, ultimately productive relations are:

...determined by the forms of capital or its contradictions - that is in our view, by historical or national contingencies affecting the way the capitalist mode of production operates and reproduces itself. (Maurice et al., 1986: p. 208)
4.9: Instead, Maurice et al. argue that capital can be influenced by other social and historical factors, not determined by capitalism alone. These factors affect the forms capitalist production takes.
4.10: Nevertheless, some of the strengths to draw from a Marxist approach are the emphasis on the concept of conflicting interests. Societies and the social relations within them are dynamic. The most difficult question to answer is where does the dynamic for change come from? The comparative work of Sisson (1987), although not essentially Marxist, is a good example of how a perspective of historical conflicts and compromises between employers' associations and organized labour explain the varied traditions in industrial relations. The importance of acknowledging conflict and contradiction is also made by Sorge and Warner (1986) and Sorge (1994). Sorge argues for the development of a dialectical theory in the comparative study of employment relations and organizations.

The notion of dialectical theory used to raise the hair of so-called positivist scholars, who considered it a misguided endeavour to tolerate confusion and arbitrariness, things which were thought of as unscientific. ... By trying to do full justice to real-world events, dialectical theory therefore displays an inherent tension between the ambition to reduce contradictions and the recognition that this has clear limits. (Sorge, 1994: p. 3)
4.11: Thus whilst Marxist approaches have tended to focus on universal generalizations concerning the determinants of capitalist development, recognition of conflicting interests is a useful aspect to borrow from these theories.

Industrialism and Contingency Theory

5.1: Industrialism represents a more conservative perspective that seeks to identify universal trends in industrial organization, although it has less to say about gender. This approach argues that technological innovation and increasing wealth lead to the universal adoption of similar working practices. The level of technological sophistication was considered a determining factor shaping the characteristics of organizations. It was assumed that technological progress would occur along a single trajectory of development. We can see these assumptions in the early work of Haribson et al. (1955). In their study of the steel industry in the US and West Germany they identified several differences in the characteristics of the employees and in the organization of work. They argued that the use of similar technology would minimise these differences. This conclusion was popularized in the later work of Haribson in collaboration with Kerr et al. (1960).
5.2: Kerr (1983) states that one of the aims of this earlier collaborative work was to challenge the ideology that capitalist and communist societies were polar opposites. The theory of industrialism argues that there is an inherent logic to industrialism, regardless of the political context. 'Much of what happens to management and labour is the same regardless of auspices.' (Kerr, 1983: p. 18). Industrialism requires: a skilled and mobile workforce; large-scale production in large cities, together with political consensus for government intervention; a professional elite of managers; workforce participation in the benefits of industrialism and political acceptance of this system. This system is regulated by a web of rules (Kerr et al., 1960: pp. 33-46). The key assumption in this work is that as societies progress, the differences, rooted in traditional practices and relationships, would disappear. Productive technology acts as an intrinsic imperative forcing all societies in the direction of industrialism. We hear similar messages today in the debates on globalization.
5.3: Lane (1989: p. 22) argues that this perspective 'discounts the powerful impact of history.' Like Marxism, industrialism assumes societies will cross a historical 'threshold' before entering a new form of industrial order where consensus will reign. But, as we hear frequently in the 'post-perestrokia' period, attempts of former Eastern Bloc countries to cross this 'threshold' is constrained by the historical and political baggage of their former experiences and conflicts persist, albeit, in new forms.
5.4: Industrialism is largely a thesis that claims to identify grosso modo universal trends about modernization. However, when we come to look at an important aspect of modernization, i.e. women's integration into paid employment, we can identify notable differences, even within Europe. A number of studies have shown how some countries have sought to integrate women on a full- time permanent basis, whereas other countries have opted for a part-time work strategy, or alternatively maintaining low levels of female activity alongside an immigration policy to meet labour shortages. These studies clearly highlight that the pattern of modernization has different affects on the nature of women's economic dependence on men^[10]. But this significant aspect of modernization, which shapes the form of economic production and the social sphere of reproduction^[11], as well as rights to political citizenship, is completely ignored by the industrialism approach.
5.5: Contingency theory developed to counter some of the weaknesses of industrialism, although not its neglect of gender. However, it too is intellectually rooted in the same implicit assumption of the unilinearity of industrial development. Unlike industrialism, Contingency theory limits its scope to examining the differences in business structures, rather than in whole societies. This approach concentrates on the differences in organizational design and practices in relation to contingent factors like organizational size, the environment, or the type of technology used^[12]. The key argument is that under a given set of conditions, or contingencies, it was possible to identify optimal organizational behaviour and structural solutions because external contingencies were potentially malleable. The Aston School took the position that residual factors, not explained by these variables, could be accounted for in terms of culture. Culture was understood in terms of where a specific society was situated on a scale of being socially progressive. Culture was reduced to a single external variable, without being integrated into the analysis of other variables. Lane (1989: p. 24), although critical of this approach, argues that its success was largely due to the consistency of some results derived from standardized surveys in several countries. Contemporary developments in contingency theory, although less academic in style, can be seen in the populist work of Peters and Waterman (1982), and Peters (1992). They attempt to identify and prescribe recipes to achieve excellent companies. Unfortunately, some of the companies they awarded the laurels of excellence were seen floundering shortly after publication and public accolade. Despite much enthusiastic entreaty, American prescriptions may be inappropriate, both at home and abroad because they lack a deep rooted sociological understanding of the cultural context in which organizations work^[13].
5.6: Contingency theory has been criticized for being too formalistic, and it over emphasises the significance of organizational structures^[14]. Although contemporary versions advocate more flexibly structured organizations, they still do not avoid the essential problems with Contingency theory that is based on the premise that organizational success requires the optimal fit of an organization's structure to its environment. Tayeb (1988: pp. 22-4) argues that this perspective raises several problems. There are inconsistencies in empirical findings and methodological weaknesses; the theory also suffers from an inherent reductionism and 'theoretical ambiguity'. For example, how does one isolate the organizational characteristics and structures which account for success? Also, it is not clear that managers are always capable of consciously and strategically adapting the structure of their organization to achieve efficient and effective performance^[15]. This emphasis on formal structures neglects the influence of human action and informal relations (Sorge, 1994). What is of interest is not necessarily the formal structures in themselves, but rather the way they are understood and interpreted by the people who occupy these spaces in different countries (Lane, 1989: p. 25; Hofstede, 1980a). Through their behaviour and values these people embody cultural differences.
5.7: Contingency theorists see an approach from culture as complementary to their own in as far as they suggest that an explanation from culture might explain the varying magnitude of correlation coefficients i.e. of the mathematical value calculated for the relationship between a contingent factor and a structural property of an organization (Lane, 1989: p. 24). Intellectually this approach is rooted in the paradigm that assumes a unitary logic of action under a given set of circumstances. Contingencies in two or more organizations are examined and compared in isolation, without analyzing the relationship between other phenomena (Tayeb, 1988: p. 23). Cultural approaches make more effort to analyze the relationship between different phenomena in the same context, in an attempt to identify the affect of culture on organizations. The difference between these two approaches reflects the deep run divisions in social science discussed earlier, between universalists and cultural relativists.
5.8: Overall, the contribution of these universal theories of comparative employment research has been to argue that it is possible to identify universal pressures or imperatives. These encourage successful organizations or societies, under similar conditions, to adopt analogous practices. Despite the success of many of these theories, in practice they have been found inadequate. Even if organizations or societies experience comparable pressures it cannot be assumed that they will adopt identical strategies to deal with these because national institutions, coalitions of actors and values mediate the change process. In Marxism, and Industrialism the concept of culture tends to be relegated to the periphery because these grand theories want to be universally applicable. The motors of change are universal: class dynamics, technological imperatives, or markets. The issue of gender rarely gets mentioned despite the fact that modern societies are often marked by an increase in women's participation in the paid economy. Approaches that attempt to give greater weight to the role of culture have challenged these universal theories. We will now turn to review some of these theories and their contribution to comparative, cross-national research and the role for gender.

Cultural Approaches

6.1: Approaches giving greater emphasis to the importance of culture have not, however, been able to agree on how the concept of culture should be integrated in their theoretical and empirical framework^[16]. Defining culture, as Hill (1973) points out, is a contentious issue. What is culture, and where do we begin to dissect it? Unless the concept is clearly specified, it can become a 'black box' into which all unexplained differences are allocated, willy nilly. Child and Tayeb (1982-3) argue that culture should be conceived as a substantively distinct field, separate from other social areas. Sorge (1982-3), on the other hand, proposes that culture mediates action at every level: the institutions of society are organized according to specific cultural values.
6.2: There is a considerable literature on organizational and national cultures that would be impossible to critically summarise in the context of this paper. Therefore, we will examine how key texts have used the concept of culture according to whether they belong to an ideational or institutional perspective; studies that cross these distinctions are also discussed as intermediary approaches.

The Ideational Approach

7.1: The ideational approach interprets culture as the practices and beliefs, or values of individuals within a given system. Hofstede's 'Culture's Consequences' (1980a) is one of the best known examples of this approach. Culture, for him, is about the 'collective mental programming' shared by a group, a tribe, a minority, or a nation. Aggregate individual personality traits in a particular country is equivalent to a national culture, or mind set (Hofstede, 1980b: p. 475). In his seminal work he attempted to operationalize his concept of culture in the context of a survey of employees from 54 different countries^[17]. Differences in attitudes to work were measured along four dimensions: power distance, uncertainty avoidance, individualism-collectivism and masculinity-femininity. The results of these surveys indicated that the United States, for example, had the highest individualist ranking, a relatively low power distance score, a higher acceptance of uncertainty, and a higher masculinity score. Countries like Singapore and Hong Kong had a high score on the power distance variable, compared to countries like Finland or Sweden where this was much lower. On the basis of these scores Hofstede attempts to link them to known research to argue that certain types of leadership or management practice will be accepted in some countries and not in others^[18].
7.2: However, some of the problems with Hofstede's work arise from his reduction of national cultures to aggregated personality traits based on four dimensions. For example, higher masculine traits are considered to exist if respondents agreed with a series of statements like 'Big and fast are beautiful' (Hofstede, 1980b: p. 480). It is over simplistic to reduce the cultural identity of a society to an aggregate standardised score based on individual responses. Also, within our own societies we know that conflicting identities exist between different sub-cultures and ethnic groups, which is not accounted for in Hofstede's schema. Further, Hofstede's approach allows little room for an analysis of historical change. He states that national cultures do not change very fast, if at all (Hofstede, 1980a). Finally, Hofstede's claims that these attitudes make certain forms of management style more acceptable are unsystematically drawn from other research rather than being obtained from his own findings.
7.3: One of the problems with an ideational approach is the overemphasis given to the attitudes and values of aggregate numbers of individuals. An ideational approach can only explain behaviour after the event. This approach takes little account of how values change over time. This is particularly problematic when studying countries in a process of transition, for example the former Eastern bloc or reunification in Germany. Values on their own are not enough to understand different working and organizational practices; values need to be rooted into the social and economic structure of a given society. An approach that gives more importance to the role of institutions is required (Berger and Luckmann, 1971: p. 72). Sorge and Warner (1986: p. 41) argue that institutions represent the 'typified and habitualized patterns of reciprocal social action'. They also argue that an institutional approach is more fruitful for cross-national comparisons because it captures the dialectic between universal economic rationales and the particularism of institutional constraints. In more recent work Sorge (1994) has argued that a combination of ideational and institutional approaches is required, in order to account for psychological as well as societal or institutional factors. But, before we assess this we will now turn to examine the contribution of institutional approaches to cross-national research.

Institutional Approaches

8.1: An institutionalist approach gives culture a more materialist underpinning: value differences are embedded in the social and economic institutions that support the continuation of traditional values and practices. For example, such an approach would argue that the economic success of West Germany is not attributable to individual West Germans having a strong 'work ethic', being 'disciplined' and hard working. In fact Germans work comparatively fewer hours than many other industrial countries^[19]. Instead, an institutional approach emphasizes the role of the comprehensive education and vocational training system which has created a highly skilled workforce; this has been complemented by a consultative industrial relations system, and long term financial support from banking institutions and the local state^[20]. In Japan comparable institutions like MITI, company unions, and consultative practices through quality circles have been seen as a key to Japanese success^[21]. Again the emphasis is on institutions that support industrial organization, rather than on the attributes of individuals.
8.2: The institutional approach is illustrated in the work of Maurice, Sellier and Silvestre (1986). They have argued that we cannot examine separate aspects of a given system without locating it in its specific societal context. They have argued that there is a strong relationship between organization of work at the micro level of the firm and national institutions at the macro level. Their work examines the relationship between the educational system, the structure of business, and the sphere of industrial relations. They argue that skill attainment, for example, is affected by the relationship between the educational system and the workplace hierarchy. Each dimension has a degree of autonomy but also forms part of an interdependent structure. They argue that:

...there are common features shared by firms in a particular country though they use different types of technology. ... the explanation of these similarities lies not in the effects of some sort of invisible hand or teleological principle but rather in the systematic structure of social factors influencing both the formation of the actors and the development of the industrial work system, factors that are at once the result of specific social relations and the cause of those relations.' (Maurice et al., 1986: pp. 78-9)
8.3: Commonality is attributed to belonging to a particular country, where social relations and the institutions that govern them have, historically, developed symbiotically. Social behaviour takes place within the context of particular institutions in a given society. The behaviour of social actors (groups or individuals) is influenced by these institutions, but it is also modified by the behaviour of these actors. Their approach is widely known as the 'societal effect'.
8.4: They found that German managers possessed a higher degree of technical skill, and were expected to perform a broader range of tasks compared to equivalent managers in France. French organizations also had more levels of management than German firms. They sought to explain these differences in relation to the structure of:

the educational and vocational training system
the nature of business organization and
the differences in the industrial relations structure.

: Their work is important in linking the micro, firm level and macro, national institutional levels of industrial organization within a society.
8.5: Although Maurice et al. offer a fresh perspective for conducting comparative research, they have been criticized for the functionalist nature of their explanations, although they would deny this (1982: p. 374). Rose (1985) has argued that their approach allows only a limited role for individual action; it also fails to incorporate an analysis of change. Lane (1989: p. 36) questions the nature of causality in the systems they outline: does the syndrome they set out determine the organization of work, or is it a case of 'mutual adaptation' between business organizations and other institutions in society? Maurice et al. argue that by putting the education system at the centre of their analysis they can focus on the relations between skill attainment and the organization of workplace hierarchy. However, the gendered construction of skill is ignored in their work^[22]. In seeking to bring down the bastions of Marxist laws of economics, and the work on convergence and technological determinism, they admit that they have given greater weight to the differences they found, which is inherent in their methodological perspective (Maurice et al., 1982: p. 263).
8.6: A more recent institutional approach has been developed by Whitley (1992a; 1992b) who advocates a Business Systems perspective. This analysis includes the nature of the firm, the way the market is organized, and the authoritative coordination and control systems. He argues that these characteristics are shaped by background social institutions, i.e. kinship trust, loyalty and authority relations, as well as by proximate social institutions including business relations with the state, financial system, education and training system, unions, and other professional organizations. Whitley uses this approach to account for the differences in firm organization in Asia and Europe.
8.7: However, one of the problems with Whitley's approach is that whilst it draws attention to the way institutions are shaped, and how this is linked to the historical development of the society under observation, his analysis leaves little room for change. This is because of his emphasis on the historical legacy of institutions and social relations. We can clearly see the institutions of a particular society, but we have little sense of the people occupying these. The weight of history also makes it difficult to identify the nature of conflict between major social actors, thus generating a rather static model of industrial organization.
8.8: Overall, the strength of institutional approaches to comparative research has been to give a distinct material basis to the nature of cross-national differences in work organization. These studies have attempted to give more weight to the values and attitudes of actors within an institutional setting; albeit with scant regard for gender or recognition of heterogeneity within nation state societies^[23].

Intermediary Approaches

9.1: Intermediary approaches that cross the boundaries of the ideational and institutional schools can be seen in particular in the work of Dore (1973) and Gallie (1978). Dore in 'British Factory, Japanese Factory' (1973) compares organizational practices and the values of employees at English Electric in the UK and Hitachi in Japan. Dore opposes the argument that Japanese distinctiveness was a product of industrial 'backwardness' (1973: p. 375). Instead, he argues that the Japanese system developed from:

the creation of new institutions to suit their cultural disposition;
the selective adoption of foreign models; and
an unconscious evolution and continuity of existing pre- industrial institutions (Dore, 1973: p. 376).

: However, what is more significant to Dore is not the existence of 'institutional inertia', but rather why certain choices were consciously made by Japanese industrialists that, accumulatively, have created the Japanese system (1973: p. 401). Dore argues that the disposition to make certain kinds of choices were influenced by the 'modified Confucian world-view' that assumed original virtue rather than original sin (1973: p. 401). This predisposed Japanese industrialists to see benevolence as efficient. The ideological context made them more willing to make certain choices rather than others. Second, it shaped their objectives; for example, leadership in Japan required a moral force as well as a purely material one. And third, ideology affected different objectives: the ideological emphasis on honour and respect led them to give greater weight to these factors than was the case for industrialists in other countries.
9.2: Essentially Dore's argument for the difference between British and Japanese firms was based on the impact of i) Confucian ideology and ii) the late development of Japanese industrialization. The choices made by early British industrialists in the mid-nineteenth century were very different to those posed to Japanese industrialists in the early half of the twentieth century. Late development meant that late comers benefit, not only from advances in technology, but also from 'social technology', for example, education, personnel management techniques and 'ideologies' of increased democratisation. Dore argues that egalitarian democratic ideologies that developed in advanced industrialized societies, 'can have independent life and force of their own when diffused to societies just beginning industrialization.' (Dore, 1973: p. 12). He argues that the need to handle complex technology and organizations, and the need to meet demands for status equality do not create imperatives requiring identical institutional solutions. Instead, he argues, diversity will persist. This is because of

the varied pre-industrial history;
the diversity of other imperatives like war and revolution, the ideology of the elite group, the role of state intervention, as well as the social and racial composition of the country; and
the experience of industrialization (Dore, 1973: p. 419).

: These factors account for the persistence of differences between Japanese and British firms. Although Dore emphasizes the influence of Confucian ideology on management decision making, he also gives equal weight to how history has shaped the parameters of these decisions. Unlike Hofstede he assesses the significance of values and attitudes from a historical and case-study approach. This has the advantage of linking attitudes to the historical evolution of social institutions. Dore, like Gallie (1978), criticizes the simplistic determinism of arguments based on technological imperatives and universal patterns of development.
9.3: Gallie (1978) is interested in examining contingency theory and Marxist arguments on the deterministic affect of technology on

the social integration of workers in the capitalist enterprise,
on the structure of managerial power, and
on the nature of trade unionism (1978: p. 36).

: In his study of oil refineries in Britain and France he asks whether the use of advanced technology leads to the integration or alienation of workers. Gallie argues that a comparative approach to these questions can allow him to include 'the influences of societal differences in culture and social structure.' (1978: p. 37). He is interested not only in identifying the similarities and differences in the structure of work organization in each country, but also in how the attitudes and aspirations of workers in these plants compare. In this way his work straddles the ideational and institutional approaches found in cross-national employment research.
9.4: In terms of social integration Gallie found that French workers were more discontent with their wages and the salary structure than the British workforce. The conflict that arose over 'manning' levels created greater friction in the French plant than in the British one. Although there were disputes over work organization in Britain, Gallie argues that the relationships between the British management and workers was more 'co-operative' than in France. The French workforce perceived their relationship with management as being more 'exploitative'. The British workers were more content with the system of negotiating with managers, while French workers felt consultations were superficial, symbolising their exclusion from participation in decision making within the firm. By drawing on large scale survey research Gallie seeks to generalize these findings to the national level (1978: pp. 146-8). French workers were not only more discontent with existing power structures but they also had much higher aspirations of what they wanted to achieve in terms of control of the enterprise. Gallie argues that:

Although market economies involve similar objective conflicts of interest between employers and employed, these contradictions appear to have different implications for the workers' perception of the firm in different societies. ... The effects of institutional structure are not, then, mechanical, but are conditional upon certain cultural contexts. (1978: p. 206)
9.5: Gallie attempts to identify the variables that shape workers' aspirations and experiences within given institutional structures. He argues that where the 'value of equality has more salience', but where participation is blocked, this creates greater tension between management and workers: 'it is the interaction of cultural values and institutional structures that is crucial' (1978: p. 210).
9.6: In his explanations for these differences he focuses on the structure of managerial power and the nature of trade unionism in each country. French management was more paternalistic, compared to the 'semi- constitutional' strategy of British management. French managers were more active in reminding the work force of their discretionary powers whereas British managers played down their potential powers. In France the legitimacy of managerial authority was low. French management retained a tighter degree of control than British managers. The organization of the unions in each country differed significantly. This affected the way union demands were formulated, and the role they saw for themselves in the firm and society in general. In France, union membership was comparatively low and fragmented. The French unions were highly politicized, so that their demands were linked to a broader long term strategy to bring about societal change and mobilize the workforce to this goal. In Britain union density was much higher. This gave them a greater potential to coerce management. Gallie argues that they had a more representative role: the unions negotiated on a narrower range of issues that emerged from shop floor grievances. Further, Gallie argues that there was little evidence that union structures, both within the plants and at the national level, would converge; instead he argues that their distinctiveness would persist.
9.7: In conclusion he argues that technology per se has negligible influence on the integration of workers in a capitalist enterprise. He argues that social interaction at the work place is determined by the patterns of culture and social structure within a given society (1978: pp. 295, 318). These include managerial ideology, the structure of power in social institutions, and the 'ideology and mode of action of the trade union movement'. Gallie draws on comparative empirical evidence to counter the universalist thesis of technological determinism in workplace organization. His approach clearly seeks to show the relationship between societal structures and institutions and the attitudes of the people who populate these spaces in relation to their working environment. In a later book he attempts to identify the historical factors that have shaped these institutions in each society (Gallie, 1983).
9.8: Cross-national studies which take more account of variation in work organization have given differing weight to the role of individual and social values as well as institutional effects. In many ways this attempts to overcome the overtly structuralist perspective of universal approaches. However, we have seen that a purely ideational approach fails to fully recognize social heterogeneity within a single society. It tends towards a post-hoc account for national differences without accounting for how these differences came about. An institutional approach, on the other hand, is more successful at identifying the material and historical basis for particular societal characteristics. Nevertheless, the tendency to emphasize historical origins can create a rather static conception of social arrangements, with little account given to the role of actors in shaping and interpreting these. The intermediate approaches are more successful in this respect. They manage to identify both the historical constraints and perceptions of contemporary actors in their accounts for societal differences. They also recognise how conflict and change emerge through changing alliances of elites and organized labour. Even so, any consideration of gender is sadly lacking.

Gender Relations in Comparative Perspective

10.1: Comparative research which has taken more interest in exploring the nature of gender relations in different countries has largely been conducted, usually by female researchers, around issues related to women's employment or studies concerned with the welfare state and the family^[24]. The various conceptual frameworks generated by these studies raise similar issues, to those discussed earlier, concerning divergent and convergent patterns of development. It will be argued here that a particularly useful theoretical approach has been developed by Connell (1987) and empirically applied and adapted by other researchers. These studies can, potentially, allow us to incorporate an analysis of gender that includes the role of actors within the institutions of the state, the sphere of economic production and social reproduction. Such an approach can identify common developments across societies, but at the same time retains a holistic analysis that sees how these global trends are implemented within nation state societies. In this section we will first examine studies related to the welfare state, women and employment before moving on to the gender order approach of Connell.

Gender and the Welfare State

10.2: The work of Esping-Anderson (1990) and his critics have generated considerable debate about cross-national classifications of welfare states and their effects. His typology of liberal, conservative, social-democratic, and subsequently rudimentary welfare states was based on the concept of 'de-commodification'.

De-commodification occurs when a service is rendered as a matter of right, and when a person can maintain a livelihood without reliance on the market. (Esping-Anderson, 1990: pp. 21-2)
10.3: This means the extent to which the state intervenes in the class system to reduce individual's dependence created by the system of wage labour. He argues that these 'unique configurations' refute both Marxist and Modernization theses on convergence. They also have a differential effect on the position of women in the labour market, and will in the future potentially create 'new axes of social conflict.'^[25]
10.4: His approach has been criticized by Lewis (1992) for being gender blind, in ignoring the importance of unpaid domestic labour, and for focusing purely on the cash-nexus. He also ignores how women's dependence on men can be transferred to dependence on the state. Duncan argues that:

[The] theoretical core is firmly rooted in capital-labour divisions in a capitalist system, based around the relationship of (male, standard) workers to markets as modified by the welfare state. (1995: p. 267)
10.5: Despite revisions to Esping-Anderson's original model, by other writers, a conceptualization of gender, which means more than talking about women, remains an optional add-on extra. Further, the categorizations have been criticized for becoming purely descriptive and the model is less able 'to deal with variations in gender inequality than might at first appear.' (Duncan, 1995)^[26]
10.6: Alternative categorizations have been advocated by Lewis (1992; 1993) who distinguishes between strong, moderate and weak breadwinner states. The extent to which these categorizations provide a theoretically informed account and explanation for why variously modified forms of breadwinner states exist has been questioned by Duncan (1995: p. 268). He argues that 'Gender inequality is more than just simply the result of state policies towards women in families and paid work.' Nevertheless, these debates highlight the differential effects of state welfare policies and variations in women's access to the labour market. They are important in showing how the supply of labour, in particular women's labour, is structured by these policies; an aspect which has often been neglected by studies which have concentrated solely on the economic sphere of production.

Women and Employment

11.1: There is an enormous literature on women's employment which has been applied to comparative research. This ranges from concepts of patriarchy to debates in Human Capital and segmented labour market theory. Depending on the perspective adopted, cross-national differences have been explained in one of three ways: in terms of patriarchal structures, or, alternatively the characteristics and preferences of female labour supply, or the incentives and disincentives created by a nationally specific employment system. Each of these will be discussed in turn.
11.2: An approach emphasizing patriarchal systems of employment can be seen in the work of Walby who has sought to developed her earlier conception of patriarchy and apply it to comparative research (1990; 1994). She advocates the conceptualization of patriarchy in terms of six structures: paid work, the household, the state, male violence, sexuality, and culture. She argues that in the last century there has been a move from private to public forms of patriarchy, at least in the UK. In comparative research she further tries to differentiate between the degree and form of public or private patriarchy that can be observed in each of these six structures.
11.3: One of the advantages, and in some ways disadvantages, of Walby's approach is that she sets out to address the issue of comparative research with a preconceived theoretical concept about gender inequality, largely developed from earlier studies in the UK. However, what initially appears to be a set of sleek conceptual categories quickly falls into confusion when she attempts to apply it to comparative research issues and cross-national data (Walby, 1994). What we find, like the air we breathe, is that patriarchy is all around us - to a greater or lesser degree, in a stronger or weaker form. Her approach could benefit from the use of a dialectical method of analysis as advocated by Sorge (1994). Empirical indicators that could be used to measure these concepts only highlight that they are open to a plethora of contradictory interpretations once we try to examine these across countries; part-time work is a particularly good case in point (Walby, 1994: pp. 1346-7).
11.4: The reason Walby's approach generates more confusion than clarity is, first, because the aspects she calls structures are not really structures at all: paid employment, the household and the state are sites of action which take different structural forms over time and space; moreover, male violence and sexuality are processes that occur at these particular sites. A further problem is that the relationship between these 'structures' is not systematically specified: sometimes they coincide with each other, to a greater or lesser extent, and sometimes they are not relevant at all, but we have no consistent explanation for why this variation occurs, other than that they are a product of patriarchal relations. Finally, culture becomes little more than an add-on extra because the relationship between culture and other institutions, values and practices is not fully and systematically specified. This conceptualization when applied to cross-national research suffers from many of the same problems that were observed in critiques of contingency theory.
11.5: Second, it is claimed that these 'structures' are held together by the concepts of public and private patriarchy. However, it is not clear if the public-private dimension represents polar opposites or a continuum. If they are polar opposites then we are faced with the problem of deciding where the public ends and where the private starts^[27]. If it is a continuum model we are then left asking what is the nature of the categories between the two poles. A further problem with her approach is a neglect of individuals and institutions. She argues that patriarchy refers:

...to a system of social relations rather than individuals, since it is presumed that it is at the level of a social system that gender relations may be explained, not that of individual men, nor that of discrete social institutions. (1986: p. 51)
11.6: This systemic approach ignores individuals. Both men and women on a daily basis interact and create around them the very institutions that shape the particular system that Walby is interested in studying (Granovetter, 1985). Duncan (1995) points out that her approach underestimates women's capacity to act. Although in later work she argues that women's political activity is essential, there is little systematic analysis of women's behaviour and attitudes that does not include strikes or open political action. Finally, an underlying assumption of this approach is based on a universal perspective of development, as discussed in earlier comparative studies in this article.
11.7: From a contrasting perspective neo- classical economists in the form of Human Capital theory have also sought to provide a universal model to account for differences in women's labour market participation and the domestic division of labour. Unlike the patriarchal emphasis on structures they give greater importance to individual supply side decisions. They argue that when women receive lower rates of pay compared to men, and where women are less likely to have equivalent investments in human capital (understood in terms of qualifications, training and continuous patterns of labour market participation) then they are more likely than men to take greater responsibility for unpaid domestic labour. This theory has been well criticized both in terms of its overemphasis on a model of 'rational economic man' as well as its claims that such a division of labour is 'efficient'^[28].
11.8: Hakim (1991), also emphasizing supply side factors, has claimed that differences in female work patterns can be explained in terms of an individual's commitment to work.

The degree and pattern of job segregation in any country are historically determined, but the persistence of job segregation from now on should be regarded as a reflection of women's own preferences and choices. (Hakim, 1991: pp. 114-5)(author's italics)^[29]
11.9: She suggests differentiating between women with a full-time career orientation and those who prefer a homemaker role. She argues that up until now social scientists have tended to treat women as 'grateful slaves' subject to structural constraints, whereas she says that they should be seen as 'self- made women', in the sense that they choose freely between the career or homemaker track. For her, part-time work can be seen as 'a proxy indicator to differentiate the two groups' (Hakim, 1991: p. 114).
11.10: In fact, the issue of part-time work particularly highlights how this form of employment means different things in a given employment system^[30]. Rubery and Fagan (1995: p. 226) have criticized the supply orientated approach of Hakim. They argue that the effects of the societal employment system provide a better explanation for the cross-national differences in women's take up of part-time work and in forms of occupational segregation. They advocate a more holistic approach when analysing employment systems. Such an analysis would need to include the impact of: industrial organization, labour market conditions, consumption patterns, social attitudes, training systems and career paths, working-time arrangements and systems of pay determination. Rubery has argued that applying a societal perspective to women's employment:

means that we need to understand the way in which the system of industrial, labour market and family organization interrelate and the role of the society's political and social values in maintaining these relationships before we could expect to make sense of the differences between countries in the position of women. (1988: p. 253)
11.11: Rubery (1993) has forcefully argued how the characteristics of a national production regime are influenced by the form and structure of the sphere of social reproduction^[31]. It is this broader definition of an employment system which can provide a particularly useful bridge with the studies discussed in the earlier parts of this article, but one which maintains a consistent focus on the significance of gender in employment relations in their broadest sense. In the final section we will now look at the theoretical perspective provided by the gender order approach which complements that of the employment systems perspective discussed here.

The Gender Order

12.1: The gender order approach to comparative research integrates both a core recognition of gender relations in different social spheres and can be used to address the importance of varying cultural and cross-national dimensions. In this section we will concentrate on the work of Connell and the empirical application and adaptation of his ideas^[32].
12.2: Connell (1987) in his book 'Gender and Power' attempts to develop a framework which avoids structural categoricalism found in early accounts of gender relations, where 'all women' are swept into a distinct category from 'all men'. His perspective attempts to develop a dynamic approach to understanding gender relations both across societies and over time. He seeks to show how actors are both affected by the structural relations in which they live, whilst at the same time they have a capacity in which to shape and change these relations.
12.3: He argues that normative gender relations are produced through the inter-relationship of the 'gender order' and different 'gender regimes'. By 'gender order' Connell refers to the way power relations, and the definitions of femininity and masculinity, have been historically developed in society in general. The concept of a gender order refers to the relationship between:

the division of labour,
power expressed in the context of authority associated with masculinity, and
cathexis, which refers to emotionally charged, sexual relations.

: Each of these constituent structures can have independent effects and may even conflict with each other. However, they provide a form of unity in which gender relations are realized. By 'gender regimes' he refers to the way these power relations and identities are shaped in specific institutions for example through forms of state regulation, through workplace practices, as well as within the family and on the street, i.e. through peer group encounters. These concepts attempt to account for the relationship in the sphere of state social policy and labour demands, as well as in the emotional relationships experienced by individuals. By pointing out that there is not necessarily a functionalist fit between these spheres, he can identify the arena through which change comes about. It can also allow us to compare the gender order in different societies.
12.4: An empirical cross-national application of these ideas can be seen in the work of Lane (1993) who compares gender regimes at the state level for Britain, Germany and France, and she argues that:

...a focus on the construction of gender categories at the highest level (i.e. the state) often yields fruitful insights about cross-national variation, particularly if it is combined with an historically informed study of political actors and institutions. Such an approach thus links an institutionalist perspective, emphasizing national diversity, with a universalist focus on a division of labour in which masculinity is associated with power. (Lane, 1993: p. 276)
12.5: Further applications and adaptations of his work have been conducted by Pfau-Effinger (1993; 1994) for Finland and West Germany^[33], by O'Reilly (1994) for Britain and France, by O'Reilly (1995) for East and West Germany^[34], by Daune-Richard (1995) for France, Sweden and the UK and by Einhorn (1993) for the former communist bloc. Other empirical historical work which can be used to support the framework outlined by Connell can be found in the comparison of industrialization and women's employment in Britain and France by Tilly and Scott (1987). What these studies clearly show is that the process of industrialization and the integration and regulation of women's entry into the economy of paid work took different paths. These early arrangements have had a long-term influence on the contemporary position of women in these societies in relation to the availability of full and part-time employment, the basis of entitlement to social welfare and childcare provision. The arrangements which have specified gender relations in these societies could be seen as a form of 'gender compromise' in the sense that they have regulated coalitions of interests supporting, or opposing, a more equal treatment of men and women in society at particular historical periods. This argument is supported by the work of Jenson (1991) comparing Sweden and France, according to Daune-Richard who says:

...it was the strong commitment of women to political life (parties and trade unions) that enabled the Swedish women to widen the scope of thinking on equality to women on the one hand and to the private world of the family on the other (Jenson 1991); this is the reason for the equal entitlement of both sexes to parental leave, and for the development of task sharing within the family and of child care facilities. Jenson (1991) sees in this a difference from France where, in the absence of any real link between the feminist movement and political power (and even the trade unions), demand for equality between the sexes have remained confined to the world of production, where labour legislation has traditionally been relatively neutral and little influenced by the great political debates. (1995: p. 60)
12.6: Women's interests have been mobilized and expressed in the public arena through various channels. For example, Norway is the only country where women have their own party. In Britain the extent of radicalism found in the first wave of feminism amongst the suffragettes was exceptional, compared to the rest of European and North America. In continental Europe women's demands have tended to be funnelled, and peripheralized, through radical parties demands for the universal 'Rights of Man'. The type of gender compromises arrived at can be related to the nature of coalitions built between male and female interest groups. Folbre argues that:

Rather than thinking in terms of a transition from the 'traditional' to the 'modern', or some evolution of distinct modes of production, such as capitalism and patriarchy, we need to focus on the ways in which structures of constraint stabilize and destabilize each other. ... we need to ask how given groups interact in processes of political change and economic growth. Sets of assets, rules, norms, and preferences that enforce membership in given groups define the context for both market exchange and state planning. They set the stage for contest among competing distributional coalitions. (1994: p. 81)
12.7: It is the nature of these coalitions which distribute resources allowing for a greater or lesser degree of equality between men and women that shape the characteristics of the gender compromise. The interesting question for the future, after the extinguished heat of the second wave of feminism, is what shape and impact these new coalitions will have.

Conclusions

13.1: This article has sought to critically outline a range of theoretical approaches to cross-national employment research. We have seen how universal and culturalist studies vary significantly in their treatment of differences and similarities between contemporary societies. Universalists tend to ignore the concept of culture, or at best acknowledge it as a marginal phenomenon or additional variable. Culturalists, on the other hand, have sought to integrate the concept of culture into their analysis at a socio-economic and institutional level as well as at the psychological level of the individual. The emphasis on similarities between countries tends to lead to a universalist approach, whilst the emphasis on difference is often supported by a more culturalist perspective. However, as we have seen from this review, whilst each perspective can shed light on a particular feature of economic organization, they also have their shortcomings, both in terms of accounting for change and the co-existence of similarity and diversity. Furthermore, these approaches, for the most part, are blind to the affects and effects of gender on industrial organization and employment practices.
13.2: Cross-national studies which have given more weight to gender concerns have tended to be concentrated in debates on the welfare state or patterns of women's employment. One of the problems with many of these studies has been that either gender becomes an optional variable in the cross- national comparison, or where there have been attempts to make it more central, the meaning of cross-national differences becomes blurred and confused. What is clearly required is an approach which shows how gender relations shape observable differences in national regimes of economic production and social reproduction and how these vary between countries. It has been argued here that the employment systems approach coupled with the gender order perspective can provide a useful framework of analysis. This enables us to identify how comparable pressures for change have generated specific interest coalitions; these coalitions resolve conflicts by agreeing on a particular gender compromise.

Notes

¹ See Ouchi, 1981; Oliver and Wilkinson, 1988; Garrahan and Stewart, 1992; Pollert, 1991.

² See Moss, 1990; Barrere- Maurisson et al., 1989; Schmid et al., 1992; Reissert, 1993; Bradshaw et al., 1993; Dex et al., 1993.

³ Dore, 1973; Gallie, 1978; 1983; Maurice et al., 1982; Whitley, 1992a; 1992b; Musesduttir, 1995.

⁴ Grimshaw, 1973: p. 9; Tayeb, 1988: pp. 42-3.

⁵ Marx and Engles (1977).

⁶ Marx (1988: pp. 15-16).

Eine Nation soll und kann von der andern lernen. Auch wenn eine Gesellschaft dem Naturegesetz ihrer Bewegung auf die Spur gekommen ist - und es ist der letzte Endzweck dieses Werks, das ökonomische Bewegungsgesetz der modernen Gesellschaft zu enthüllen -, kann sie naturgemäße Entwicklungsphasen weder überspringen noch wegdekretieren. Aber sie kann die Geburtswehen abkuerzen und mildern.
A nation should and can learn from others. Furthermore, when a society identifies the natural laws of its development - and the ultimate goal of this work is to reveal the economic laws that govern the motion of modern society -, it can neither skip over nor outlaw the objective stages of development. But it can shorten and ameliorate the birth pains.' (author's translation)

⁷ Marx, K and Engles, F. (1977)

⁸ See Walby (1986) and Sargent (1981) for a good summary of these debates; Hartmann (1981); Folbre (1994).

⁹ See Folbre (1994) for a comparison of Northern Europe, the US, Latin American and the Caribbean.

¹⁰ Pfau-Effinger (1993); Tilly and Scott (1987); Einhorn (1993).

¹¹ In fact one important trend as societies have become increasingly more wealthy, as measured in GNP, is for there to be a decline in the birth rate (Folbre, 1994).

¹² See Lawrence and Lorsch (1967); Woodward (1965; 1970); Hickson et al. (1979).

¹³ Even Peters recognises this (1992: p. 756). He acknowledges the resistance to his ideas from middle managers in the US who would loose their jobs, as well as those working in government organizations.

¹⁴Tayeb, 1988; Lane, 1989.

¹⁵ See O'Reilly, 1994, chapter 2 for a more detailed discussion about debates on managerial strategy.

¹⁶ See Lammers and Hickson, 1979; Maurice et al., 1982; 1992; Maurice, 1989; 1990; d'Iribarne, 1991.

¹⁷ Hofstede tried to hold constant the influence of corporate culture by taking respondents from the same multinational, later identified as IBM.

¹⁸ For example, a more authoritarian style of management (i.e. reflected by a high power distance score) is more common in countries like Singapore or even France, but it would be less acceptable in Scandinavian countries.

¹⁹ Sorge, 1994; Financial Times, 10/5/94.

²⁰Steedman & Hawkins, 1993; Lane, 1989, chapter 3; Sisson, 1987; Zysman, 1983; Cox, 1986; Quack et al., 1995; Vitols, 1995.

²¹Whitehill, 1991.

²² See Maurani & Nicole, 1989; Walby, 1989; Cockburn, 1981, as examples of research which show how skill recognition and the use of technology has been gendered in organizations.

²³ See Duncan (1995) for a discussion of the importance of regional differences.

²⁴ Where men's employment is the focus of study, gender is not seen to be relevant, although a notable exception to this is the excellent work of Cockburn (1983).

²⁵ For example he argues that as a result of pressures for wage moderation in Sweden 'one might easily imagine a war between (largely) male workers in the private sector and (largely) female workers in the welfare state'(p. 227). For Germany he envisages conflicts between insiders (job-holders) and outsiders (the jobless and inactive), and in the US 'class differences will crystallize more sharply within the various minority groups. As some women become yuppies and some Blacks become bourgeois, the women and Blacks left behind will experience much more keenly the phenomenon of relative deprivation' (pp. 228-9).

²⁶ The reader is referred to Duncan (1995) where these debates and critiques have been well summarized.

²⁷ The case of single parents on income support in the UK is a particularly good example of the problems such categorization creates. The state directly intervenes in the private sphere, through the Child Support Agency, to take resources from men (the fathers), directly out of their wages, and redistribute these to women (the mothers of their children), with the aim of moving these women off the publicly funded income support system. Although Walby claims that in the last century the UK has moved from a system of private to public patriarchy, this case suggests that the British state is trying to reverse this trend. It also illustrates that the distinction between the public and the private is empirically less easy to sustain.

²⁸ See Folbre (1994), Rubery et al. (1996) and Humphries and Rubery (1995) for more detailed critiques of this approach.

²⁹ To suggest that from 1991 onwards women have suddenly being able to exercise more choice than the past hundred years seems a little fallacious.

³⁰ Buchtemann and Quack, 1990; Daune-Richard, 1995; O'Reilly, 1995; Fagan et al., 1995; O'Reilly and Fagan, forthcoming.

³¹ See also Humphries and Rubery (1984) on the relative autonomy of the social reproduction.

³² Duncan (1995: pp. 270-1) has shown that similar debates have been developing in Scandinavia, but unfortunately much of this work remains in Swedish.

³³ Pfau-Effinger prefers to refer to these differences in terms of a gender contract and gender arrangements.

³⁴ In this work I have suggested that such a framework could be called a gendered societal approach.

References

BARRERE-MAURISSON, M.-A., DAUNE-RICHARD, A.-M. et LETABLIER, M.-T. (1989),'Le Travail �� temps partiel plus d��velopp�� au Royaume-Uni qu'en France', Economique et Statistique, no. 220, avril, Paris.

BERGER, P. and LUCKMANN, T. (1971), The Social Construction of Reality. Harmondsworth: Penguin.

BRADSHAW, J., DITCH, J., HOLMES, H. and WHITEFORD, P. (1993) Support for Children: A comparison of arrangements in fifteen countries, Department of Social Security, Research Report no. 21, London: HMSO.

BUCHTEMANN, C. and QUACK, S. (1990) 'How precarious is non-standard employment?', Cambridge Journal of Economics, vol. 14, pp.315-29.

CASASSUS- MONTERO, C. (1989), 'Les diffèrentes approches dans les comparaisons internationales du travail industriel' in Sociologie du Travail, no. 2-89.

COCKBURN, C. (1981), 'The Material of Male Power' Feminist Review, no.9, October.

COCKBURN, C. (1983) Brothers. London: Pluto Press.

CONNELL, R. W. (1987) Gender and Power. Oxford: Polity.

COX, A. (editor) (1986) State, Finance and Industry: A Comparative Analysis of Post-War Trends in Six Advanced Industrial Economies New York: St. Martin's Press.

DAUNE-RICHARD, A-M. (1995) 'Women's Employment and Different Societal Effects in France, Sweden, and the UK', International Journal of Sociology, vol. 25, no. 2, pp. 39-65.

DEX, S., WALTERS, P. and ALDEN, D. M., (1993) French and British Mothers at Work. Basingstoke: Macmillan.

DORE, R. (1973) British Factory - Japanese Factory. The Origins of National Diversity in Industrial Relations. London: Allen and Unwin.

DUNCAN, S. (1995) 'Theorizing European Gender Systems', Journal of European Social Policy, vol. 5, no. 4, pp. 263-84.

EINHORN, B. (1993) Cinderella goes to Market: Citizenship, Gender and Women's Movements in East and Central Europe. London: Verso.

ESPING-ANDERSON, G. (1990) The Three Worlds of Welfare Capitalism. London: Polity Press.

FAGAN, C., PLANTAGNA, J. and RUBERY, J. (1995) 'Does Part-time Work Promote Sex Equality? A Comparative Analysis of the Netherlands and the UK', WZB discussion paper FS I 95-203.

FOLBRE, N. (1994) Who pays for the kids?. London: Routledge.

GALLIE, D. (1978) In Search of the New Working Class: Automation and social integration within the capitalist enterprise. Cambridge: Cambridge University Press.

GALLIE, D. (1983) Social Inequality and Class Radicalism in France and Britain. Cambridge: Cambridge University Press.

GARRAHAN, P. and STEWART, P. (1992) The Nissan Enigma: Flexibility at Work in a Local Economy. London: Mansell.

GRANOVETTER, M. (1985) 'Economic Action and Social Structure: The problem of Embeddeness', The American Journal of Sociology, vol. 91, no. 3, pp. 481-510.

GRIMSHAW, A. (1973), 'Comparative Sociology: In What Ways Different from Other Sociologies?' in M. Armer, and A. Grimshaw (editors) Comparative Social Research. New York: John Wiley.

HAKIM, C. (1991) 'Grateful slaves and self-made women: fact and fantasy in women's work orientations', European Sociological Review, vol. 7, no. 2, pp. 101-21.

HARIBSON, F.H., KOCHLING, E., CASSELL, F.H. and RUEBMANN, H.C. (1955), 'Steel Management in Two Continents', Management Science, vol.2, pp. 31-9.

HARTMANN, H. (1981) The unhappy marriage of Marxism and Feminism: Towards a more progressive union in L. Sargent (editor) Women and Revolution: A discussion of the unhappy marriage of Marxism and Feminism: A debate on Class and Patriarchy. London: Pluto Press.

HICKSON, D.J., McMILLAN, C.J., AZUMI, K. and HORVATH, D. (1979) 'Grounds for Comparative Organization Theory: Quicksands or Hard Core?' in C.J. Lammers and D.J. Hickson (editors) Organizations Alike and Unlike. London: Routledge and Kegan Paul.

HILL, R. (1973), 'In Retrospect: A brief analysis of the confessions of comparativists' in M. Armer, and A. Grimshaw, (editors) Comparative Social Research. New York: John Wiley.

HOFSTEDE, G. (1980a) Culture's Consequences. International Differences in Work-Related Values. London: Sage.

HOFSTEDE, G. (1980b), 'Motivation, Leadership and Organization: Do American Theories Apply Abroad?', D.S. Pugh, (editor) Organization Theory, 3rd Edition, 1990. Harmondsworth: Penguin Business.

HUMPHRIES, J. and RUBERY, J. (1984) 'The reconstitution of the supply side of the labour market: the relative autonomy of social reproduction', Cambridge Journal of Economics, vol. 8, no. 4, pp. 331- 46.

HUMPHRIES, J. and RUBERY, J. (editors) (1995) The Economics of Equal Opportunities. Manchester: Equal Opportunities Commission.

d'IRIBARNE, P. (1991), 'Culture et effet sociètal', Revue FranHaise de Sociologie, vol.32, pp.599-614.

JENSON, J. (1991) 'Making Claims: Social Policy and Gender Relations in Post-war Sweden and France', Annual Meeting of the Canadian Sociology and Anthropology Association, Mimeo, cited in Daune-Richard (1995: p. 29).

JOSEPH, G. (1981) The incompatible menage à trois: Marxism, Feminism and Racism in L. Sargent, (editor) Women and Revolution: A discussion of the unhappy marriage of Marxism and Feminism: A debate on Class and Patriarchy. London: Pluto Press.

KERR, C. (1983) The Future of Industrial Societies: Convergence or Continuing Diversity?. Cambridge, Mass: Harvard University Press.

KERR, C., DUNLOP, J. T., HARBISON, F. H. and MYERS, C. A. (1960) Industrialism and Industrial Man: The Problems of Labor and Management in Economic Growth. London: Heinemann.

LAMMERS, C.J. and HICKSON, D.J. (editors) Organizations Alike and Unlike. London: Routledge and Kegan Paul.

LANE, C. (1989), Management and Labour in Europe: The Industrial Enterprise in Germany, Britain and France. Hants: Edward Elgar Publishing.

LANE, C. (1993) 'Gender and the Labour market in Europe: Britain, Germany and France compared' The Sociological Review, vol. 41 no. 2, pp. 274-301.

LAWRENCE, P. R. and LORSCH, J. W. (1967) Organization and Environment. Cambridge, Mass: Harvard University Press.

LEWIS, J. (1992) 'Gender and the development of welfare regimes', Journal of European Social Policy, vol. 2, no. 3, pp. 159-73.

LEWIS, J. (1993) Women and Social Policies in Europe. Hants: Edward Elgar.

MARX, K. & ENGLES, F. (1977) Ausgewählte Schriften Band I. Berlin: Dietz Verlag.

MARX, K and ENGLES, F. (1977) [1872] Manifest der Kommunistischen Partei in Ausgewählte Schriften I. Berlin: Dietz Verlag.

MARX, K. (1988) [1867] Das Kapital: Kritik der politischen Ökonomie - Erster Band. Berlin: Dietz Verlag.

MAURANI, M. and NICOLE, C. (1989) Au labeur des dames: Mètiers masculins, emplois féminins. Paris: Syros Alternatives.

MAURICE, M. (1989) 'Méthode comparative et analyse sociétale: Les implications théoriques des comparisons internationales', Sociologie du Travail, no.2.

MAURICE, M. (1990) 'Convergence and/or Societal effect for the Europe of the future?' Paper presented at the Work, Employment and European Society Conference, Newton Park, Bath, 6-8th September.

MAURICE, M., SELLIER, F. and SILVESTRE, J.-J. (1982), Politique d'éducation et organization industrielle en France et en Allemagne. Paris: Presses Universitaires de France. Translated in (1986), as The Social Foundations of Industrial power: A Comparison of France and Germany. Massachusetts: MIT Press.

MAURICE, M., SELLIER, F. and SILVESTRE, J.-J. (1992), 'Analyse societal et cultures nationales: Réponse à Philippe d'Iribarne', Revue Française de Sociologie, vol. 33, pp. 75-86.

MUSESDUTTIR, L. (1995) 'The state and the egalitarian, ecclesiastical and liberal regimes of gender relations', British Journal of Sociology, December.

MOSS, P.(1990) Childcare in the European Community 1985-1990, Commission of the European Communities 'Women of Europe Supplements No.31, Brussels, August.

NOWAK, S. (1989), 'Comparative Studies and Social Theory' in Kohn, L.M. (editor) Cross-National Research in Sociology. London: Sage.

O'REILLY, J. (1994) Banking on Flexibility: A Comparison of Flexible Employment in the Retail Banking Sector in Britain and France. Avebury:Aldershot.

O'REILLY, J. (1995) 'Le travail à temps partiel en Allemagne de l'Est et en Allemagne de l'Ouest: Vers un 'modèle sociétal sexué' Cahiers des MAGE (Marché du Travail et Genre), vol. 1 no. 2, pp. 77-88.

O'REILLY, J and FAGAN, C. (forthcoming) (editors) Part-time Paradoxes: From marginalisation to social integration - part-time work in Europe, North America and the Pacific Rim. London:Routledge.

OLIVER, N. and WILKINSON, B. (1988) The Japanisation of British Industry. Oxford: Basil Blackwell.

OUCHI, W. (1981) Theory Z: How American Business Can Meet the Japanese Challenge. Reading, Mass: Addison-Wesley.

PETERS, T. (1992) Liberation Management. California: KNOPF.

PETERS, T. and WATERMAN, R.H. (1982) In search of excellence: Lessons from America's Best- Run Companies. New York: Harper Row.

PFAU- EFFINGER, B. (1993)'Modernization, culture and part-time work', Work, Employment and Society, vol. 7, no. 3, pp. 383-410

PFAU-EFFINGER, B. (1994) 'The gender contract and part-time paid work by women - Finland and Germany compared', Environment and Planning A, vol. 26, pp. 1355-1376.

POLLERT, A. (editor)(1991) Farewell to Flexibility?. Oxford: Blackwells.

QUACK, S., O'REILLY, J. and HILDEBRANDT, S. (1995) 'Structuring change: training and recruitment in retail banking in Germany, Britain and France', The International Journal of Human Resource Managment, vol. 6, no. 4, pp. 759-794.

REISSERT, B. (1993), 'National Unemployment-Support Schemes in the EC', Employment Observatory inforMISEP, no.43, Autumn, pp. 19-27.

RUBERY, J. (editor) (1988) Women and Recession: a comparative perspective. London: Routledge and Kegan Paul.

RUBERY, J. (1993) 'The UK Production Regime in Comparative Perspective', Paper presented to the International Conference on Production Regimes in an Integrating Europe, WZB, Berlin, July.

RUBERY, J. and FAGAN, C. (1995) 'Gender Segregation in Societal Context', Work, Employment and Society, vol. 9, no. 2, pp. 213-40.

RUBERY, J., MAIER, F. and FAGAN, C. (1996) 'Occupational Segregation, Discrimination and Equal Opportunity' in G. Schmid, J. O'Reilly, and K. Schoman (editors) The International Handbook of Labour Market Policy and Evaluation. Hants: Edward Elgar.

SARGENT, L. (1981) (editor) Women and Revolution: A discussion of the unhappy marriage of Marxism and Feminism: A debate on Class and Patriarchy. London: Pluto Press.

SCHMID, G., REISSERT, B. and BRUCHE, G. (1992) Unemployment Insurance and Active Labor Market Policy: An International Comparison of Financing Systems. Detriot: Wayne State University Press.

SISSON, K. (1987) The Management of Collective Bargaining: An International Comparison. Oxford: Basil Blackwell.

SORGE, A. (1982-3), 'Cultured Organization', International Studies in Management and Organization, vol. 12, pp.106-38.

SORGE, A. (1994) 'Actors, systems, societal effects and culture: Conceptualising variations in cross-national personnel and organizations', paper presented to the EMOT Group 1 workshop, Humbolt University, Berlin 22nd-24th March.

SORGE, A. and WARNER, M. (1986) Comparative Factory Organization: An Anglo-German Comparison of Manufacturing, Management and Manpower. Aldershot: Gower.

STEEDMAN, H. and HAWKINS, J. (1993) Mathematics in Vocational Youth Training for the Building Trades in Britain and Germany, NIESR mimeo.

TAYEB, M. (1988) Organizations and National Culture: A Comparative Analysis. London: Sage.

TILLY, L. and SCOTT, J. (1987) Les Femmes, le Travail et la Famille. Marseilles, Editions Rivages.

VITOLS, S. (1995) 'Financial Systems and Industrial Policy in Germany and Great Britain: The Limits of Convergence', WZB discussion paper FS I 95-311.

WALBY, S. (1986) Patriarchy at Work. Minneapolis: University of Minnesota Press.

WALBY, S. (1989) 'Flexibility and the changing sexual division of labour' in S. Wood, (editor) The Transformation of Work?. London: Unwin Hyman.

WALBY, S. (1990) Theorising Patriarchy. Oxford: Basil Blackwell.

WALBY, S. (1994) 'Methodological and theoretical issues in the comparative analysis of gender relations in Western Europe', Environment and Planning A, vol 26., pp.1339-1354.

WARWICK, D.P. and OSHERSON, S. (editors) (1973), Comparative Research Methods. Englewood Cliffs N.J.: Prentice Hall.

WHITEHILL, A.M. (1991) Japanese Management: Tradition and Transition, London: Routledge.

WHITLEY, R. (1992a) Business Systems in East Asia: Firms, Markets and Societies. London: Sage.

WHITLEY, R.(editor) (1992b) European Business Systems: Firms and Markets in their National Contexts. London: Sage.

WOODWARD, J. (1965) Industrial Organization: Theory and Practice. Oxford: OUP.

WOODWARD, J. (1970) Industrial Organization: Behaviour and Control. Oxford: OUP.

YOUNG, I. (1981) Beyond the Unhappy Marriage: A Critique of the Dual System Theory in L. Sargent (editor) Women and Revolution: A discussion of the unhappy marriage of Marxism and Feminism: A debate on Class and Patriarchy. London: Pluto Press.

ZYSMAN, J. (1983) Governments, Markets and Growth: Financial Systems and the Politics of Industrial Change. Oxford: Martin Robertson.