Case Studies on International Transfer of Policies And Practices

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Case Studies on International Transfer of Policies And Practices of Gender Equality In Employment to And Among Muslim Majority Countries:- Wire transfer or credit transfer is a method of electronic funds transfer from one person or institution (entity) to another. A wire transfer can be made from one bank account to another bank account or through a transfer of cash at a cash office, such as Western Union.

Case Studies On International Transfer Of Policies And Practices Of Gender Equality In Employment To And Among Muslim Majority Countries
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This article investigates the premise that it is possible to transpose organizational approaches to equal employment opportunity (EEO) from western countries to Muslim majority countries (MMCs). Drawing on policy interviews and documentary evidence from public sector organiza- tions and international development agencies engaged in the promotion of gender equality in Turkey and Pakistan, we question the effectiveness of diffusion of gender equality policies and practices to and among these two MMCs. Our investigation reveals the primacy of context over essence in developing effective ways to construct EEO policies and practices which can be adopted in MMCs. Keywords: gender equality, Islam, secularism, Pakistan, Turkey

G

ender equality is now a widely accepted goal in public administration (Connell,

2006). However, most studies on gender equality have been conducted in the USA and the UK and in other western contexts. There are relatively few studies conducted on the state of gender equality in the public sector in majority Muslim majority (MMCs). It is anticipated that because of significant religious, cultural and socioeconomic differences, issues of gender equality in employment in MMCs may be different from those in the west. Hayes and Vogel (1998) suggest that it is important to appreciate the extent to which religion and tradition are intertwined and permeate all levels of society in the countries of Asia and North Africa. Indeed, the compatibility of organizational values with wider societal values is essential to the long-term success of organizations (Harzing and Sorge, 2003; Hofstede, 1984; Schuler

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and Rogovsky, 1998). Organizational-societal cultural congruence is not only important to productivity and worker satisfaction (Newman and Nollen, 1996), but is also important in terms of perceived organizational legitimacy that affects the long-term survival of organizations (Giacobbe-Miller et al., 2003; Kostova and Zaheer, 1999). The current literature emphasizes the need for initiating organizational interventions aimed at educating and sensitizing employees and managers to utilize, understand, accept and value diversity (Soni, 2000). However, the phenomenon remains underexplored, with only a few cross-cultural studies on diversity management (Egan and Bendick, 2003; Özbilgin and Tatli, 2008; Wentling and Palma-Rivas, 2000) and almost none (for example, Tayeb, 1997) in the context of MMCs. This situation exposes international development agencies as well as multinational organizations to the challenge of transferring or developing policies and practices without first obtaining empirical evidence from MMCs. In this article we question the extent to which organizational experiences and practices of gender equality can travel from western countries to MMCs and whether such transfer is possible among MMCs. Drawing on institu- tional theory (DiMaggio and Powell, 1983; James and Wooten, 2006; Kostova and Roth, 2002; Oliver, 1991; Yang, 2005) and a relational framework for diversity management (Syed and Özbilgin, 2007, 2009), we present data from interviews with the key senior policymakers and documentary reviews in two MMCs, Turkey and Pakistan, and query the possibility of the migration of gender equality policies and practices to and between these two countries. Our investigation reveals the primacy of specific national contexts over religious essence in the construction of equal employment opportunities (EEO) in MMCs.

Institutional and relational perspectives
EEO have been defined as the government's attempt to ensure that all indi- viduals have an equal opportunity to be employed, regardless of character- istics such as race, colour, religion, sex or national origin (De Cieri and Kramar, 2003). The concept originated in the USA and other western coun- tries; however, its transferability to MMCs remains underexplored. We argue that the transposition of EEO practices to and across MMCs is a multi- faceted phenomenon characterized by a number of emergent considerations. While Islam presumably provides a transversal sense of cultural norm across MMCs, its practice and implications for gender equality are far from uniform in this geography (Ahmed, 1992). Hence, the efforts to transfer or implement effective EEO practices in MMCs require context-specific insights at multiple levels, including the contexts of the nation-state, its history and its approach to Islam, as well as the dominant regimes of orga- nization and gender equality.

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We utilize institutional theory and a relational perspective for managing diversity in this article to develop such context-specific insights. According to institutional theory, organizations are susceptible to various pressures, the presence of which encourages isomorphism in organizational practices and routines (DiMaggio and Powell, 1983). The theory holds that organizations that share the same environment will employ similar practices in response to institutional pressures driven by legitimacy motives. Given that many ele- ments of the institutional environment, such as laws and cultural traditions, are often specific to a nation (Rosenweig and Singh, 1991), organizational practices usually vary across countries. Therefore, we focus on two Muslim majority countries, Turkey and Pakistan, which have different institutional settings as well as some distinct similarities in their sociocultural environ- ment, not only because of their Muslim population but also because they are geographically neighbours (connected through Iran) and share significant cultural similarities. This article is also informed by Bourdieu's relational sociology, which treats social reality as layered across levels of agency and structure (Bourdieu, 1998). Drawing on Bourdieu, Syed and Özbilgin (2007, 2009) assert that the usual single-level conceptualizations of managing diversity at the organiza- tional policy level fail to capture the complex interplay of structural and agentic concerns of equality. Consequently, organizational processes, struc- tural conditions or individual choices, all of which collectively account for unrelenting power disparities within and outside the workplace, remain generally underexplored. Syed and Özbilgin's relational framework bridges the divide between macro-national, meso-organizational and micro- individual levels of analyses to arrive at a more comprehensive and realistic framing of diversity and equal opportunity. Applying institutional and relational theories to the case of EEO in MMCs, we highlight the unique sociocultural, historical, legal and insti- tutional complexity that organizations face in contexts outside the main- stream topography of gender equality discourses. The article considers the case of dissimilar, possibly con?icting institutional regimes of EEO that western donors and business organizations may face in MMCs (Westney, 1993). From a relational perspective, challenges faced by western organizations are likely to be found at many levels, ranging from historical and cultural differences to legal, organizational and individual concerns. Since it is vital for a foreign organization to achieve and maintain legitimacy, it will be forced to adopt local practices and become isomorphic with the local institutional context. At the same time it may be legally required to comply with the EEO regulations in the parent country. Herein lies the tension between a universalistic approach towards EEO, on the one hand, and local adaptation, on the other (Kostova and Roth, 2002; Rosenweig and Singh, 1991; Syed, 2008a, 2008b; Westney, 1993). We examine below the cases of Turkey and Pakistan to explore such

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tensions and to examine the possibility of transferring EEO practices to and between two MMCs.

Transposition of EEO regimes to MMCs
With 1.3 billion people and a rich endowment of natural and cultural capital, MMCs are a significant part of the global economy (Hayes and Vogel, 1998). Muslims also constitute sizeable minorities across non-MMCs and regions. By 2015 Muslims will account for 30 per cent of the world's population (Quelch and Holt, 2004). This article is based on the premise that firms operating in MMCs may be subject to certain structural conditions, legal policies and organizational norms that are in?uenced by local traditions and perspectives on religion. Consequently, the crosscultural transposition of EEO practices to MMCs could be fraught with difficulties. Although the quest for similarities or differences in culture-specific beliefs and work-related attitudes has attracted ongoing interest for a considerable period (for example, Ghauri and Fang, 2001; Haire et al., 1966; Kerr et al., 1960), the convergence of cultural beliefs and work attitudes is far from universal (for example, Leung et al., 2005). In the absence of organizational studies embedded in local understanding, the most that one can realistically bring to a substantively new context is explicit theory and content that has been developed elsewhere (Peterson and Pike, 2002). This has been the case with attempts to transpose western conceptions of EEO to MMCs. Since the 1990s US-based multinational organizations have been endeav- oring to transfer the management of diversity programmes to their offshore operations, which perhaps re?ects their increasing relian ce on a globally diverse workforce (Wentling and Palma-Rivas, 2000). However, the frame- work seems to be predominantly based on their home-made model of diver- sity, which is amply re?ected in global mission and corporate values, global diversity teams, administrative structures, training programmes and affinity groups, particularly for women (Ferner et al., 2005; Nishii and Özbilgin, 2007; Özbilgin and Tatli, 2008). A non-local discourse on EEO faces the traditional challenge of being locally non-compatible (Jones et al., 2000; Syed, 2008a). Thus, the theoretical contribution of the present article lies in its examination of the cross-national transfer of gender equality regimes in and among MMCs. Not unlike most social science research, the main frames of reference for equal opportunity and diversity research have been developed in the west, particularly in the USA, and their transferability to contexts where the task and physical environments are significantly different remains in question (Thomas et al., 1994). Cross-national differences in institutional structures are known to result in management practices that vary from country to country (Gooderham et al., 1999, p. 508). Moreover, with a few exceptions

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(such as Ghorbani and Tung, 2007; Jain et al., 2003; Özbilgin, 2000; Syed, 2008a; Syed et al., 2005), international comparative studies of EEO are almost negligible within an Islamic context, held back by barriers such as the lack of contextual understanding and a general dearth of gender segre- gated data in MMCs. Our review suggests that, in the absence of robust empirical evidence from Muslim majority contexts, gender equality regimes and discourses which are created elsewhere will not fit well within MMCs. We investigate in our field study whether this assumption applies in the case of Pakistan and Turkey.

Transfer of EEO between Turkey and Pakistan
There are significant parallels between Turkey and Pakistan that make them wellsuited for the transfer of organizational policies and practices. Both countries are among the largest non-Arab MMCs in the world. In contrast to most of their Arab counterparts, their governments were founded as liberal parliamentary democracies in the aftermath of world wars in the last century; Turkey after the first and Pakistan after the second (Wolcott and Goodman, 2000, p. xi). Both countries have long imperial legacies, the Ottomans in Turkey and the Mughals in the subcontinent, and trace their evolution over the last millennium to Turkic people who migrated from Central Asia to Persia and set up empires that lasted for centuries (Faruqui, 2005). Both have predominantly Muslim population and are regional neighbours. Pakistan and Turkey, along with Iran and some central Asian states, are members of the Economic Cooperation Organization (ECO), a regional association for devel- opment. However, Turkey and Pakistan, with their respectively secular and Islamic state systems, also provide two divergent models of nation building in the Muslim world. Ever since Pakistan's independence in 1947 the idea of Turkey as a model state has been a subject of heated debate in Pakistani society. Muhammad Ali Jinnah, the founder of Pakistan, on more than one occasions expressed his penchant for the republican reforms in Turkey. Jinnah wanted to put in place reforms like those of Atatürk for Indian Muslims (Zakaria, 2001, pp. 60-1). However, doing so was a complex matter. Turkey is founded on six prin- ciples; republicanism, secularism, nationalism, populism, revolutionism and statism, which are commonly called Atatürk's principles. The principle of secularism makes Turkey as a model state contentious in today's Pakistan. Some argue that the idea of secularism is inconsistent with the foundations of Pakistan, which was created in the name of Islam (Ahmad, 2002). The idea that Islam and secularism are incompatible, however, has been widely stated and rarely contested across the Muslim world. Yet it is a fact that leaders in Pakistan on various occasions and to varying extents have identified Turkey as a useful model, a progressive MMC. For example, soon after assuming

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power in October 1999 Pakistan's President, General Pervez Musharraf expressed his desire to follow the Turkish model for his reforms in Pakistan (Cowasjee, 2002). This is in line with the friendly discourses that have ?our - ished between Turkey and Pakistan since Pakistan's attained independence. Nevertheless, gender equality in employment is an important, albeit uncharted, component of the Turkish model. Previous research has highlighted the deeply rooted disadvantage of women together with the need to formulate and implement gender equality policies at the national and institutional levels in the informal sector of economy in Pakistan (Baruah, 2004). Women in Pakistan generally remain subject to a broad range of restrictions imposed on them through the collu- sion of tribal customs, religious interpretations and an entrenched feudal system (Mumtaz and Shaheed, 1987, pp. 715). Women have been described as 'a picture of contrast' in terms of holding highly variable degrees of social and employment status. One frequently sees 'highly educated Pakistani women who are at a high level [of] professional life, contrasted to the millions of poor, illiterate women workers, who are exploited [and] earning low salaries' (Patel, 1991, p. 84). Pakistani society offers a polarized picture of gender equality. Compared with the extremely disadvantaged position of undereducated women from poor socioeconomic backgrounds, skilled women in the cities of Lahore, Karachi and Islamabad have better access to employment opportunities. Yet stereotypes based on gender are common- place. Pakistani public and private sectors rank EEO low on their list of priorities, the reason being that so far there has been no substantial model of EEO in Pakistani organizations (Naqvi, 2003, p. 35). In Turkey equality of opportunity is a constitutional right. Despite a rudimentary set of laws on equality and negligible numbers of court cases on gender equality, equal opportunities have long been part of the national employment discourse and an important part of the national project for development. Today, Pakistan's population stands at 162 million and Turkey has 69 million citizens. However, the Turkish economy is much larger. Turkey's GDP is about 46 per cent bigger than that of Pakistan (Pakistan is $US347.3 billion and Turkey is $US508.7 billion) (CIA, 2005a, 2005b). In terms of female participation in the formal labour force, 51.2 per cent women are economi- cally active in Turkey compared with only 36.7 per cent in Pakistan — a difference of more than 14 percentage points. The inequality becomes rather visible when examined in terms of female economic activity as the percentage of male economic activity; Turkey (63 per cent) is ahead of Pakistan (44 per cent) by about 19 percentage points (UNDP, 2005). It is not only in female economic activity which Pakistan appears to be lagging behind but also in other social dimensions such as female literacy rates. According to the UNDP's (2005) Human Development Report, the female literacy rate in Turkey is 81 per cent, compared with only 35 per cent in Pakistan. Consequently, Turkey is 42 points ahead of Pakistan in terms of

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human development and 37 points ahead in terms of gender development on a global scale (UNDP, 2005). Owing to its process of modernization and westernization, which have brought about wide-reaching social and cultural reforms since the early 1920s, the EEO practices in Turkey today are largely based on the European ideals of gender equality. With its current efforts to join the European Union (EU), Turkey is undergoing another significant phase of Europeanization through which it is aligning its legal and cultural frames to EEO to the European standards, which are popularly termed the Copenhagen criteria. This requires Turkey to transpose all current EU legislation on EEO to its national jurisprudence. However, a comprehensive study by Tan et al.,(2008) recently showed that the current government in Turkey is slow in enacting and promoting of many of the prescribed policies. Besides these legal reforms, Turkey also presents a polarized picture of gender equality for women across the educational spectrum: while under- educated and lowskilled women face severe forms of disadvantage in access- ing employment and in their conditions and terms of work, skilled women, particularly those with tertiary education, enjoy better standards of employ- ment than their European counterparts (Healy et al., 2005; Özbilgin and Woodward, 2003, 2004). Thus, while professional women in Turkey have achieved better gender representation than their counterparts in advanced economies, their less well-educated sisters are effectively barred from employment in many low skilled jobs. In his 1928 lectures on 'The Reconstruction of Religious Thought in Islam' Muhammad Iqbal compared the emerging gender reforms in Turkey with the plight of Muslim women in the Punjab, who suffered deep-rooted gender discrimination. Iqbal, who seems to be inspired by the ideas of the renowned Turkish intellectual Ziya Gökalp, described the Turkish experience as one based on 'intellectual freedom', moving 'from the ideal to the real' and 'neces- sitating fresh interpretations' of Islamic principles (Iqbal, 1962, p. 69). In view of the Turkish experience of social reforms, Iqbal suggested the need to move beyond the traditional standard works in Islam so that laws did not remain stationary while the people moved ahead. It may, however, be noted that one of the main factors behind the spectacular success of professional women in Turkey in achieving proportionate representation in occupation was the success of the Turkish state in inculcating secularism rather than reform of Islam in daily practice (Özbilgin, 2000). At first sight an examination of economic and social structures in Turkey and Pakistan presents the possibility that Pakistani organizations may draw on the Turkish model of EEO. However, this premise becomes doubtful when we examine gender equality regimes as re?ected in the EEO jurisprudence of Turkey and Pakistan in their respective historical contexts. Our discussion reveals that the structural similarity between the two countries is an impor- tant, albeit insufficient, prerequisite for the effective transfer of EEO practices.

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Method
To understand the complexity of the context and content of gender equality policies in Turkey and Pakistan, the article draws on a case study of Turkey and Pakistan. The primary data include policy interviews and documentary reviews in a selection of public sector and non-government organizations (NGOs) in each country. The organizations were selected on the following criteria: (a) an explicit commitment to promote gender equality in employ- ment; (b) a track record of gender equality-related activities and (c) consid- erable in?uence in policy-making and implementation in the country. In the first stage we analysed formal policies, mission statements, action plans and other documents on women's participation in employment. In the second stage, ten in-depth interviews (one in each organization) were conducted with high-level policymakers and senior executives in each participating organization. The case studies set out the scope and limits of transfer of policies and practices of gender equality to and among MMCs. The interview schedule consisted of 36 semi-structured questions that explored the possibility of transposing gender equality regimes to and among MMCs, the nature of the national legal framework of gender equality as viewed by the participants, organizational approaches and policies to promote gender equality in employment, the role of the local culture and religious traditions, and also examined their personal experiences of and opinions on women's participation in the labour force. The interviews allowed the participants a degree of freedom based on their personal perspectives or experiences of gender equality or lack thereof in the workplace, to determine the issues they would like to discuss within a broad framework of gender equality and women's participation in the formal employment sector. The interviews were undertaken in the Turkish language in Turkey and in English in Pakistan. For the Turkish interviews, the issue of linguistic equivalence was resolved by translating related English terms and questions into Turkish, and then back-translating them into English. Validity requires that the questions in one language be translated into another language in such a way as to retain their meanings. Since systematic inferences were necessary in this case (different languages), a non-literal translation was deemed appropriate to achieve validity (Iyengar, 1976). The translation was finally verified by a bilingual academic at a university in the UK. The interviews were tape-recorded and transcribed verbatim in both countries. The Turkish transcripts were translated into English so that all co-authors could develop an understanding of the emergent themes in both countries. The participants were drawn from the public sector (three from Turkey and three from Pakistan) as well as from the international NGO sector engaged in an advisory role to the respective governments (two from Turkey and two from Pakistan), with the recognition that public sector organizations and international development agencies play varied roles in both countries in

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the implementation of gender equality policies. The interviews were analysed and the relevant policy documents in each organization were subjected to detailed scrutiny. The analyses of the organizational policies as well as the interview data were in?uenced b y a critical realist approach (see Layder, 1993), which helped to focus on participants' perceptions and experiences of the gender equality regimes and their interrelation with the wider structural context. We had two axial codes: (a) the transfer of gender equality regimes toMMCs and (b) the transfer of these regimes among them. We designed the survey and analysed our interview and documentary data around these two codes; however, other codes were developed inductively based on the primary data. We used the relational method (see Özbilgin, 2005) not only in organizing our themes but also as a way to analyse the data and explore interconnectedness across multiple levels (macro, meso and micro) of gender equality in the accounts of our informants. Even though the small sample size is recognized as a major limitation, considering that the interviews were conducted with high-level policymakers (opinion leaders), access to whom is rather privileged in both countries, and that we collated substantial docu- mentary evidence, the study is expected to advance our understanding of EEO in MMCs.

Findings: Pakistan
The Pakistani sample included three government organizations and two international development agencies operating in Pakistan. This selection was made in view of the fact that international agencies and development funds play a significant role in gender equality policies and practices in Pakistan.

Transposition of western gender equality regimes to Pakistan
The results of our interviews with the policymakers and documentary analyses reveal that the gender equality debate in Pakistan is strongly in?uenced by international agencies as well as agreements of trade, labour and social regu- lations, including the Committee on the Elimination of Discrimination against Women (CEDAW). One respondent explained the in?uence of international agencies and conventions on gender equality activities in Pakistan thus: Pakistan has been a signatory of different conventions like CEDAW. This involves taking responsibility for empowering women and in economic activities and also mainstreaming gender equality in all walks of life. In 2000 the Government of Pakistan conducted a study with the help of Asian Development Bank. They found that the inclusion of women in public activity is a development activity. Previously, if the government wanted to do something for women they would establish a technical centre for them

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to teach cutting, sewing and so on. Or they would set up a dispensary specifically for women to educate them. (Government official) The emphasis on gender empowerment is visible in official policies and mission statements of various projects undertaken by international agencies. It is also clear that they relate the agenda of gender equality to the overall project of democracy in Pakistani society: In order to address the gender disparities in Pakistan, the gender pro gramme will focus on the economic, social and political Empowerment of women.... The empowerment of a woman is a twofold process. Firstly, the process of increasing awareness of her potential, capacities and rights, which includes an understanding of her own social conditioning. Secondly, working towards an environment of democratic principles which will allow her to participate actively and equitably in all spheres of life. (NGO policy document) In order to account for the significant role of international agencies one of our informants explained that the indigenous feminist movement is very weak in Pakistan and that gender equality discourses are imported through these international agencies. However, the three respondents from Pakistan note that the transposition of western discourses does not often lead to workable policies, practices or strategies in Pakistan. One of the reasons for this is the unique nature of the gender relations that are at work in Pakistan.

Possibility of transposition of gender equality among MMCs
It is apparent in our respondents' accounts that, despite an extensive range of projects on gender equality in Pakistan, the impact of these projects remains marginal as there are countervailing forces in play. The incumbent government, in line with the NGOs, is attempting to improve the current status of women in employment. In contrast, there is a strong legacy of protectionism, that is, laws that seek to protect women against unsuitable work, and traditionalism, that is, traditions that uphold paternalist and patriarchal interpretations of religion to keep women within the four walls of the home and under the veil. This interplay of progressive and traditional forces fosters a unique regime of gender equality in Pakistan that requires an understanding of sensitivities of culture and history, as well as the requirements of a better future. The Government of Pakistan declares it is actively involved in projects to improve women's empowerment, including their employment in organiza- tions. There are gender quotas in all types of government employment and career development centres have been established in different provinces. However, there is little monitoring of female employment in the private corporate sector. The main barrier to implementing this policy in a country like Pakistan is the attitude of the people, especially the men. Pakistan is a

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patriarchal society and also it follows mainly patriarchal interpretations of the religion. Furthermore, there is no EEO Commission in Pakistan to tackle cases of gender discrimination. The only cases that occur are dealt with are in the labour courts, which are characterized by corruption and a slow-moving bureaucracy (Javed, 2005). Despite the apparent in?uence of international agencies, the policymakers (and perhaps the people in general) do not look to the western model of EEO as a workable model for gender equality in Pakistan. The tendency is to develop indigenous models that are sensitive to specific cultural and religious requirements. The commonplace conventional or conservative interpretation of Islam renders women subordinate to men. Such views have visible negative impli- cations for women's employment in formal organizations. There is very low awareness of gender rights and gender discrimination among women and men. Awareness of gender, self and gender differentiation is also low. Gender stereotyping in jobs is commonplace. It seems that laws alone are not enough to improve gender equality in employment. A number of NGOs in Pakistan are working, along with government agencies, to promote women's rights. Female modesty and inhibition is com- monplace. A female employee will rarely accept that she has been subject to sexual harassment or any other abuse. Our informants suggest that institu- tional reforms and training are possible solutions. Pakistan is an agricultural society; however, women's roles in informal sector remain undervalued. Furthermore, even those women who, for reasons of personal fulfilment or for economic reasons, are employed in formal organizations are expected to fulfil their caring roles in the family in addition to their professional duties. Husbands or other family members are less prepared to contribute in domestic caring roles (Naqvi and Shahnaz, 2002; Sathar and Kazi, 1990). Furthermore, Pakistan itself is a diverse society comprising diverse reli- gions, sects, tribes, languages and ethnicities. All these values, along with urban and rural divisions, have implications for the understanding and prac- tices of gender equality in Pakistan. For example, one of our informants suggested the following Pashto language quote: 'A woman is safe either in the home or in the grave'. This quote, it was suggested, informs the psyche of the general public in rural segments of Pakistani society, particularly in Pashto-speaking areas. Urban women are more aware of their rights and they are more active economically. They are better educated. Accordingly, there is extensive diversity of female experience across the rural-urban divide. One of our respondents explains: We are an agricultural country but there is no concept of female farmers in our country. There is no landholding for women in Pakistan. Women's labour in the informal sector is not recognized. (NGO official)

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Some labour laws are protective and discriminatory; for example one regu- lation prohibits women's employment near rotating machinery wheels. One of our respondents explains the cultural norm that legitimizes the protective legislation in Pakistan: The model adopted in the west to put women in all sort of jobs without any discrimination or considering their basic nature is not very good. In Pakistan, we realize that women should not be forced to such jobs where it's not safe for themselves and their family life. (Government official) While there are general legal provisions for gender equality however, there is little awareness of these laws, their implications or their practical use for women at work. Therefore, the laws are not supported at the level of imple- mentation. In particular, the Islamization of the law during General Zia's administration in Pakistan (1979-1988) was described as 'very injurious to women's rights because of its genderdiscriminatory nature' (NGO official). Secularism is usually considered a bad word in Pakistan; it deemed to be opposite or harmful to religion. Local culture and the local interpretation of Islam are deeply intertwined, resulting in strict customs such as Purdah (the veil) and gender segregation. One respondent explains how secularism is interpreted in Pakistan and how this in?uences gender relations: Secularism for me is a plurality of belief. In Pakistan they [secularists] are considered to be non-religious. I think religious people in Pakistan have deliberately done this. It has been done politically. The word they use in Urdu for secularism is la deeniat, that is, 'no religion'. Secularism is a concept which is above religion but it is not detached from religion. It's not the case that if I am a member of secular state then I have no religion. (NGO official) This unique set of conditions, cultural and structural arrangements in gender equality and discrimination make it difficult to transpose gender equality regimes even from within one MMC to another. One of our respondents explains why: We have our unique countries [in the MMCs]. Some countries have very rigid policies for female employment; for example, Arab countries like Saudi Arabia. Then there are other countries where they have high number of women in employment but their model is in between the west and their own culture. In Pakistan we have a diverse society. Different cultures and different people live here. It is becoming enlightened. It is getting there. So our model is unique as well. We have a mix of religious values, tribal values and so on. We have to accommodate all the areas. We have to take care of all the aspects by developing a working model. For example, recently in Pakistan women have started taking up non-traditional fields of work. For example, they are coming into the armed forces as commissioned officers.

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So the things are changing. The society is changing, we are changing our mind-set. Our women are taking the tactics of getting employment very seriously. Our employers are also interested in it. So we are getting there but it will take some time. (Government official) What is really interesting in understanding the case of Pakistan is that there is a desire to develop a workable and actionable model that suits the specific requirements of the Pakistani context. The respondents generally concur that developing such a model requires ingenious efforts using indigenous insights.

Findings: the case of Turkey
Our field study in Turkey draws on three interviews with high-level policy- makers in five organizations. The organizations included three government agencies and two NGOs. We have chosen these organizations for our study as they represent the key players of gender equality in the country.

Transposition of western gender equality regimes to Turkey
The results of our interviews with the policymakers and our documentary analyses reveal that the gender equality debate in Turkey is strongly in?u - enced by international trade and labour agreements and social regulation, including the EU accession process and CEDAW. The in?uence of interna - tional agencies on gender equality activities is also apparent. The NGO official in our study explained that international agencies play a significant role in the development of the 'social/joint inclusion memorandum' of the government, which is a requirement of the EU candidacy process for Turkey. Besides the impact of international agencies on gender equality and discrimination outcomes in Turkey, our research found that there are active processes of information exchange, negotiation and contestation among representatives of government (for example, the Turkish Republic Prime Ministry and the General Directorate on the Status of Women — GDSW) employers and NGOs. Therefore, international pressures has brought renewed enthusiasm into the discussion of issues that are pertinent for gender equality at work in Turkey. Although the international transfer of gender equality policies, particularly in the case of CEDAW and EU accession, received a warm welcome in Turkey, such transposition also bring about the question of whether the changes are making an impact on the ground or whether they remain limited to policy changes with little practical impact on women and men's lives at work. Our NGO informant criticized the current government for shying away from producing meaningful policies for gender equality:

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The main problem in Turkey is that women's employment is not consid- ered to be an issue that falls under the theme of the national employment policy. The current situation [with women's employment in Turkey] has been defined; however, there is no plan of action in place to address the problems of women's employment. Our main aim is to ensure that women's employment is taken seriously and considered as a part of the macro-political plans in Turkey. (NGO official) Once policies are developed they must be furthered with action plans that will require budgets and schedules which do not currently exist. She explains having projects using funds from international institutions such as the UNDP, the UN or the World Bank cannot be considered 'policies'. Our informant then went on to explain what was sorely lacking in the Turkish context: The government does not have a serious national policy that seeks to improve and support women's paid employment in Turkey. Projects and campaigns are not national policy. This issue [women's employment] is mentioned under national development plans. However, the government does not subscribe to an action plan, offer a budget, allocate human resources, commit to a time frame or a set of targets.... There is a need for certain temporary and special preventive measures such as positive dis- crimination in order to combat gender inequalities before equal opportunities measures could be successfully introduced. (NGO official)

Possibility of transposing gender equality among MMCs
Like Pakistan, there is an extensive range of national projects on gender equality in Turkey. The impact of these projects remains marginal as there are countervailing forces at play. Unlike Pakistan, however, the current govern- ment is not attempting to improve the current status of women in employ- ment. The incumbent government has been criticized for bringing in protectionist legislation and removing the right to gender equality in the drafts of the new Constitution in Turkey. These changes mean that there is now a strong sense of legal protectionism in Turkey, as it remains unlawful to employ women in jobs which are deemed unsuitable for them: Primarily, jobs are for men and during all periods of crises women are the first group to be made redundant. Even if the business owners set up their businesses mainly for profit, many still believe in gender inequality.... Redundancy based on performance appraisal is rather uncommon in Turkey. Recruitment on merit is also uncommon. The situation that I describe re?ects the secondary social status that women are afforded in Turkey ... in the public domain. (NGO official) Despite its different starting point, Turkish politics is now also characterized by traditionalism, which upholds paternalist and patriarchal interpretations

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of religion in a way similar to contemporary politics in Pakistan. This shift is viewed as a severe blow to women's rights in the workplace in Turkey. One of our informants explains how this is re?ected as a con?ict between the policy and practice of gender equality: In our employment law there is a requirement of equality. However, this does not include the stage of recruitment. There are many recruitment practices that exclude women altogether. (NGO official) Nevertheless, NGOs and private companies from all sides of the political spectrum contribute to the gender equality debate in Turkey. The interplay of progressive and traditional forces fosters a unique regime of gender equality in Turkey. However, the dynamics of this regime has very little in common with the regime in Pakistan. The GDSW is a high-powered government agency in Turkey responsible for monitoring gender equality. However, its impact does not go beyond monitoring and implementing a number of awareness-raising projects. Although the laws suggest that equality of opportunity exists, there are no established mechanisms for monitoring and penalizing discriminatory prac- tices. The directorate adopts an approach that emphasizes providing examples of positive practices of gender equality to main institutional actors (that is, NGOs, government departments and the private sector). The GDSW's work is underpinned by a belief that improving gender equality in education will lead to equal opportunities at the workplace: Education is very important in improving employment of women. This is also suggested by employment statistics. As women's education level increases, so do their chances of being employed. In education Turkey aims to have 100 per cent schooling by the year 2010. There are many projects under this umbrella. (Government official) The commitment to gender equality, at least in principle, is visible in official policies. For example: The aims ... include increasing the education level of Turkish women, increasing women's participation in economic life in the agricultural, industrial and service sectors; and improving women's status by giving them equal and merited places in social, economic, cultural and political fields. (Government agency policy document) However, in practice, a sea change is taking place in public opinion in Turkey. A conservative interpretation of Islam is becoming commonplace in daily life as well as in politics. The outcome of these changes and challenges to the principles of secularism in Turkey is likely to call for the redefinition of gender relations at work and in the domestic sphere. Similar to Pakistan today, Turks also expect changes that may bring about stricter norms on female modesty and inhibition (BBC, 2008).

16

GENDER, WORK & ORGANIZATION

Turkey is a fast industrializing society. Similar to Pakistan, the significant contribution of women to the informal economy is often ignored in Turkey. Current patterns of employment suggest that women are withdrawing from the formal work sector. Although the family roles of women along with their work in formal employment are important, husbands or other family members seem to be less prepared to contribute to domestic caring roles in rural and less-well educated segments of Turkish society. Our respondents highlight this as an important cultural reason for the apparent decline in women's economic activity in Turkey. While there are equality laws in Turkey there is rudimentary awareness of such laws and their implications for women at work. Therefore, the laws are not supported at the level of implementation. Furthermore, some labour laws are protective and are tacitly discriminatory. One of our respondents explains this situation in Turkey: Women are perceived (even by themselves) to have rights to participate in work and social life only after they deliver on their domestic responsibili- ties (their predetermined priority). This is a cultural assumption and it is reinforced by formal statements and practices. This is most clearly re?ected in the design and implementation of some laws. For example, if there are 150 women in a workplace, a kindergarten must be opened. Therefore, taking care of children is considered a women's responsibility. The message is embedded in this law. (NGO official) Another respondent explains that although private sector firms often do not have explicit gender equality policies there is a general feeling of support for women's employment in the private sector. However, our respondent notes that gendered stereotypes on work and domestic work present barriers for the employment of women: Because of their perceived social roles, women are the ones who ask for permission on the first school days to take their children to school, or maternity and breast-feeding leave are evaluated as interruptions on women's managerial ambitions. (NGO official) Unlike Pakistan, secularism is not a contested term in Turkey. It is one of the founding principles of Turkey. Therefore, it is constitutionally uncontestable. However, the emergence of political parties inspired by Islam and their current control over political power in government has brought about a political contestation of secularism in the country. The situation is very dif- ferent to Pakistan, for which Islam is a founding principle. These unique set of conditions, cultural and structural arrangements in gender equality and discrimination make it difficult also for the transposition of gender equality regimes the two MMCs of Turkey and Pakistan. In the case of Pakistan, there is a desire to develop workable and actionable models which requires ingenious effort using indigenous insights. However, in

17

Turkey the main emphasis is placed on mechanisms to improve equality of opportunity by improving women's human capital. Therefore, the main field for gender equality is considered to be education rather than employment. Our informant explained that this was an important yet insufficient condition for gender equality at work and that more work needed to be done at the level of the government: Although education is important, it does not guarantee ultimate employment. Indeed, the proportion of undereducated men is much higher than proportion of undereducated women in employment.... In order to ensure equality of opportunity by gender, government could form a permanent parliamentary commission for gender equality. With such a commission, all laws could be filtered through a gender perspective before they are enacted. (NGO official)

Discussion and conclusions
We have argued in this article that Turkey and Pakistan provide ideal examples through which we can question the premise that EEO across MMCs warrants a unique set of comparators. However, our case studies in the two countries suggest that the similarities between Turkey and Pakistan should not be overstated as differences in the discourse and enactment of gender equality in these countries are quite noticeable. The differences are interesting as they show that gender relations are both outcomes and catalysts of their divergent macro-economic and social agendas. Table 1 summarizes our discussions on the contexts and implementation of EEO in the two countries. Our comparative study has demonstrated that the current gender equality practices in both countries stem from institutional and relational contexts. The organizational regimes and practices of gender equality (or lack thereof) seem to be deeply ingrained in, and re?ect widespread understanding of social reality [and are] enforced by public opinion, by the views of important constitu- ents, by knowledge legitimated through the educational system, by social prestige, by the laws. (Meyer and Rowan, 1977, p. 343) As gender discriminatory practices appear to be institutionalized at multiple levels, they become viewed in the respective society as normal and are adopted by organizations for reasons of legitimacy and not necessarily for efficiency (Zucker, 1987). The study also informs us about the transferability of the western model of EEO to MMCs and also the transferability of gender equality practices across MMCs. It suggests that both pathways to EEO, that is, the transfer from the west or across MMCs are fraught with difficulties. Our case studies in Turkey and Pakistan alert us against superimposing a model of gender equality that

Table 1: Gender equality in employment in Turkey and Pakistan
Pakistan Poor female participation in economic activity, gendered impact of growth in formal sector including industry and services, very low female literacy rate, lack of skill and vocational training

Dimension

Turkey

Major national issues

Decreasing female economic activity, gendered impact of migration and recession, challenges to secularism.

Common issues

Increased legal support for gender equality, rudimentary level of legislation, slow pace of change, continued female disadvantage in organizations, international labour and human rights instruments as a key driver The Constitution: Gender equality within the Constitution (Articles 25 and 27), special measures for women's participation (Article 34) Labour law Special protective measures in The Mines Act 1923 and The Factories Act 1934, such as unsuitable hours, Maternity benefit laws (The West Pakistan Maternity Benefit Rules 1961), social security laws (The Provincial Social Security Ordinance 1965) that provide for maternity benefits to mothers for a maximum of 12 weeks International ILO instruments ratified, Conventions no. 100, 111, 159, CEDAW ratified in 1996 The Ministry of Women Development est. 1979 under the auspices of Article 99 of the Constitution of Pakistan 1973 to promote gender equality at federal level, women development departments established at the local government level Non-discrimination is assumed, gender-role stereotyping is common, anti-discrimination action is voluntary without penalty for non-compliance National Plan of Action in pursuance of the objectives of the Beijing Conference 1995, international agreements and laws, National Policy for Development and Empowerment of Women, Gender Reform Action Plan

18 GENDER, WORK & ORGANIZATION

Legal framework

The Constitution: Gender equality within the Constitution Labour law Article 26 on equal pay, Article 70 on maternity leave, Article 50 on inappropriate work, Article 68 and 69 on sectors and conditions inappropriate for women, protective legislation in Article 50 International CEDAW ratified in 1986

National machinery for gender equality

Turkish Republic Prime Ministry General Directorate on the Status Of Women est. 1990

Organizational policy approach

Non-discrimination is assumed, anti-discrimination action is voluntary without penalty for non-compliance, there is precedence of test cases on constitutional rights of equality

Drivers for change

European Union, national modernization project, international agreements and laws, ideology driven approach

Note: CEDAW, Committee on the Elimination of Discrimination against Women.

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is inconsistent with local institutional and contextual considerations, not taking into account the structural conditions, organizational processes and individual choices within each respective country. Thus, context seems to have primacy over essence in the construction of EEO in MMCs. In this sense, the findings of this study are not much different from the contentions of Creed et al. (2002), who are concerned with the conditions and practices that support social movements (gender equality in employment, in our case). Creed et al. found that the frames from the political realm are in some ways adopted wholesale and in some ways translated and manipulated by agents pursuing change in local workplace settings. However, it must not be construed from this that the project of gender equality in employment confronts an impasse in these and other MMCs. Our case studies attest to a desire to change in both countries. This desire and the change itself seem to emanate from multiple sources, both indigenous and foreign, political and socioeconomic. For example, in both countries there is a realization that an increase in women's participation in employment is crucial for national or social progress. The in?uence of international actors such as donor agencies, trading partners, international bodies and western govern- ments is quite visible in both countries. However, the study suggests that the EEO project in both countries must be built in a gradual manner through progressive change. It suggests that such change should come through local adaptation instead of by superimposing foreign principles and policies. The study also alerts us to the issue of political will and the durability of gender equality initiatives in both countries. For example, one of our partici- pants in Turkey highlighted the governmental tendency to treat the EU projects as governmental policies. The participant noted that foreign-driven projects cannot be termed as policies because they lack specific targets and timelines. In contrast, governmental policies are expected to have some dura- bility and are usually expected to pursue objectives of an ongoing indigenous importance. One outcome of a foreign agenda is there is no governmental emphasis on monitoring and measuring the progress of gender equality in Turkey. The situation in Pakistan is not very different. Here international donors usually pressurize the government to comply with instruments such as CEDAW. Financial aid is usually tied to such compliance (for example, the Gender Equality Project in Pakistan, which is linked to and supported by the Department for International Development [Waterhouse and Neville, 2005]). Naturally, the government's interest in it is unlikely to survive beyond the life of the international financial assistance. What is lacking is a genuine commitment and political will towards developing and implementing gender equality policies. Consequently, what is witnessed in both countries is the fragmented nature of legal policies and organizational actions towards women's employment, with little consideration of such factors as cultural transformation, and little attention to the rural and urban differences, literacy rates and skill levels of women.

20

GENDER, WORK & ORGANIZATION

At a more philosophical level, comparisons between Turkey and Pakistan suggest that employment practices are gendered in different ways across national borders, refuting the essentialist and deterministic arguments about gender, work and cross-national transfer of good practice. Commonalties between Pakistan and Turkey in terms of female disadvantage are striking. Yet there are significant differences between the two in terms of their dis- courses of gender equality and the macronational and cultural approaches towards women's status and roles in society. This finding is consistent with the suggestion of Tienari et al. (2005) that more gender research is needed on the local and national in relation to the global in the contemporary world of organization and management. Table 2 summarizes some key recommenda- tions and implications of this study as a possible way forward for EEO in the two countries. Our study suggests that policymakers in both countries must attend to evaluating the efficacy of gender equality regime in their respective countries. Although the rhetoric of formal policies and verbal commitments is abun- dant, what is lacking is an assessment of the state of gender equality in employment, such as women's participation in formal organizations and decision-making positions. While most participants in our study reproduced the commonly known discourses on gender there was little tangible evidence, such as in statistics on the historical pattern of gender discrimination in employment or any other evidence, of the real progress made by various legal or organizational initiatives. Therefore, we recommend that adequate mecha- nisms may be developed to assess the impact of gender equality programmes. For example, surveys of legal awareness, the participation rates of women in employment and management jobs and the efficacy of various legal or orga- nizational policies could be conducted. One way forward is to engage with stakeholders, particularly women's rights organizations and individual women, to obtain their insights in developing a context-specific approach to gender equality in employment. On an institutional level, attention should also be paid to enforcement, penalties and sanctions for non-compliance. The implication for multinational organizations is that while international NGOs as well as multinational businesses may be subject to legal regimes in the parent country they must attempt to understand and negotiate their approaches towards gender equality with the relevant institutions in the host country (for example, partner organizations and regulatory bodies). Such negotiations may also be communicated to regulatory bodies in the parent country (for example, the EEO Commission or the foreign trade office) so as to ensure their participation, gain their insights and develop their under- standing of these issues. The study also confirms the fact that MMCs are not homogenous in their approach towards gender equality. Thus, instead of pursuing a blanket strat- egy towards EEO in MMCs, international organizations must consider the complete range of institutional and relational forces in each country, taking

21

Table 2: Recommendations and implications for future policy and practice
Cross-national comparison Recommendations Structural changes supporting the implementation of CEDAW (in both countries), broadening the scope of GDSW (in Turkey) and the Women's Ministry (in Pakistan). Modification in legislative structure (sharia laws) causing female disadvantage in Pakistan. Introduction of laws on gender equality at work in both countries. Introduction of public and private sector partnerships to tackle discrimination. Regular monitoring of the state of gender equality in employment, such as women's participation in formal organizations and in decision-making positions. Development of adequate mechanisms to assess the impact of gender equality programmes, e.g., surveys to assess the extent of legal awareness, participation rates of women in employment and management jobs and the efficacy of various legal or organizational policies. Furthermore, attention may also be paid to enforcement and sanctions for non-compliance. Gender equality practices in both countries stem from the institutional and relational arrangements. Context seems to have primacy over the essence of gender differences or similarity in construction of EEO in MMCs. Transposition of EEO practices to and among MMCs is at best a problematic idea. Efforts to transpose EEO from one cultural context to another are laden with difficulties of adaptation. Nevertheless, cross-cultural learning continues to promise a rich source of inspiration for social change. There is a need to develop a context-specific approach to EEO in each society. A discourse of EEO borrowed from English language sources may not be relevant to local sociocultural realities in the countries with a predominantly Muslim population. Gender cultures and structures are constructed through social and economic experiences, therefore EEO can be achieved by using a combination of diverse strategies, e.g., awareness-raising, political campaigning, policy and law making, public and private sector partnership, monitoring, and penalties for non-compliance as well as the development of sophisticated voluntary measures.

Implications

Note: CEDAW, Committee on the Elimination of Discrimination against Women EEO, Equal employment opportunities, GDSW, the General Directorate on the Status of Women; MMCs, Muslim majority countries.

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GENDER, WORK & ORGANIZATION

into account its specific structural, organizational and individual traits. Fur- thermore, training of employees and managers on equality and diversity should help the trainees contextualize EEO practices. Therefore, such training must either be situated in the host country or supported by local insights and indigenous resources.

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