Description
Case Study on the Role of Regulatory and Temporal Context in the Construction of Diversity Discourses: UK, France and Germany, The "business case for diversity" stem from the progression of the models of diversity within the workplace since the 1960s. The original model for diversity was situated around affirmative action drawing strength from the law and a need to comply with equal opportunity employment objectives.
Case Study on the Role of Regulatory and Temporal Context in the Construction of Diversity Discourses: UK, France and Germany
Abstract
Despite growing interest in how the concept of diversity management is reinterpreted as it crosses national boundaries, there has been little study of this process in Europe. To bridge this knowledge gap, this article explores the construction of diversity discourses in the context of the UK, France and Germany. We use the discursive politics approach to investigate the ways in which the meaning of diversity is shrunk, bent and stretched. We demonstrate that the concept of diversity has no universal fixed meaning but is contextual, contested and temporal. Temporarily fixed definitions and frames of diversity are pathdependent and shaped by the regulatory context. Thus unique national histories and the context of regulation are key determinants of the ways in which the concept is redefined as it crosses national and regional borders.
Keywords
discrimination, discursive politics, diversity, diversity management, integracism, regulation, taboos
Corresponding author: Ahu Tatli, School of Business and Management, Queen Mary University of London, Mile End Road, London E1 4NS, UK. Email: [email protected]
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Introduction
Diversity management as a new paradigm to deal with the demographic diversity of employees has its roots in the North American context of the late 1980s. In this approach, diversity is framed as an attribute of individuals, moving the focus away from groupbased differences and resultant inter-group inequalities (Linnehan and Konrad, 1999). Institutional and legal rationales for responding to employee diversity have been replaced by a business-case rationale linked to positive performance and financial outcomes for organizations. This shift in the US context of employment relations is to some extent interpreted as a move to minimize the backlash among the majority white (or male) population against affirmative action policies (Kelly and Dobbin, 1998). In the ensuing decades, the concept of diversity management has entered the policy lexicon in other countries. The UK represents the earliest example outside the North American setting, with the publication of Managing the Mosaic (Kandola and Fullerton, 1994). The arrival of the concept in continental Europe has been comparably recent, only gaining a popular reception in the late 2000s. The international transfer among organizations and policymakers of an originally North American approach has stimulated academic research interest in how the concept is reshaped and reinterpreted (Klarsfeld, 2010; Syed and Özbilgin, 2010). Such research has demonstrated that the meanings and definitions attributed to diversity and its management vary considerably as they travel across place and time. Klarsfeld (2010) has shown that diversity management is interpreted across the spectrum of voluntarism and coercion. Variation is also present in terms of both the prevalence of the business-case rationale and the definition and dimensions of diversity that are captured in diversity management interventions. For example, in Scandinavia the interpretation and policy enactment of diversity management have been predominantly entangled with migration concerns and the integration of ethnic minorities into the labour force (Boxenbaum, 2006). As a result, arguments based on corporate social responsibility, rather than the business case, dominate the diversity debate (Kamp and Hagedorn-Rasmussen, 2004). Similarly, Klarsfeld (2009a) argues whereas diversity management was originally presented in the USA as an alternative to equal opportunities and affirmative action, when the concept arrived in France there was an accommodation of these two approaches. In Germany (and also in France), the concept of diversity management is not only applied to the employment sphere but involves broader issues of social integration, particularly concerning ethnicity and race. Despite the expanding stock of knowledge on how the concept of diversity management gains new meanings as it travels across national settings, cross-national comparisons of this concept in Europe remain rare. To bridge this knowledge gap, we explore the construction of the meaning of diversity in three countries, the UK, France and Germany. Such a cross-cultural comparative analysis is of particular relevance because of a common EU regulatory framework: diversity management as a discourse draws strength from, and is partly shaped by, EU legislation. For instance, such legislation has been instrumental in widening the definitions of diversity by introducing protection against discrimination on such grounds as gender, ethnicity, disability, sexual orientation, religion, belief and age. However, this legislation has been interpreted and implemented
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very differently across the member states, illustrating the complexity of the translation of legal and discursive notions of diversity across national boundaries. We use the 'discursive politics' approach developed by Lombardo et al. (2009, 2010) to investigate how the concept of diversity management travels across national borders. By discursive politics, Lombardo and colleagues (2009) refer to the contextual process of attributing meaning to concepts. Their analysis deals, in the main, with the meanings that gender equality has been assigned in different contexts, and shows how the concept is defined and redefined through a process of political contestation. This process involves four dynamics, which they term fixing, shrinking, stretching and bending. First of all, the meaning of a concept is always temporarily fixed, which is a necessary step to having a workable definition on which policies can be based. Temporarily fixed meanings are the outcomes of the other three processes: shrinking, stretching and bending. By shrinking, the scope of a concept is limited to a narrower set of meanings and policy goals than originally intended; conversely, stretching involves broadening a concept to include dimensions and meanings which were not originally signified. Bending a concept means redefining its meaning in order to match policy goals which differ from those that the concept was originally intended to address. In the process of travel, a concept can experience one or more of these transformations at the same time; they are not mutually exclusive. Shrinking, stretching and bending are processes of negotiation between multiple stakeholders who aim to advance their specific interpretations and agendas (Özbilgin and Tatli, 2011). In the case of diversity, stretching rather than shrinking or bending is often the source of positive change, as more progressive stakeholders negotiate to widen the coverage of a concept through stretching its meaning. Using this framework, we demonstrate the ways in which the meaning of diversity is fixed, shrunk, bent and stretched in our three countries. We illustrate how the concept of diversity is contextual, contested and temporal rather than having a universal fixed meaning. In other words, what diversity (and its management) means is only temporarily fixed through a political process of negotiation. These temporarily fixed definitions and frames of diversity are path-dependent and shaped by the regulatory context in each country. There also exist hegemonic frames of reference that set boundaries for imagining alternative meanings and definitions of a given concept. Such boundaries are products of a specific set of taboos, which are defined by Lombardo et al. (2010: 106) as an 'often tacit but shared and general inclination not to address or question an issue'. Biases and blind spots in defining certain concepts are not always the result of intentional choices by the policy actors, but may be outcomes of historically and contextually embedded presumptions. We suggest, therefore, that understanding the discursive politics of social regulation of diversity management requires simultaneous attention to what is present in the diversity debates (meanings and definitions), and what is absent (taboos and silences) (Bell et al., 2011). We thus pay particular attention to the taboo areas which create distinct blind spots in hegemonic frames of social regulation in each country. In undertaking a comparative and cross-cultural review of the diversity management debate, we adopt a contextual and relational standpoint. The review was conducted through a critical reading of the diversity literature in English, French and German.
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Secondary data from scholarly and practitioner sources, such as journal articles, research reports and books, national government and EU policy documents are included in our literature review for the years of 1990 to 2011. The year of 1990 is chosen as the starting point because diversity management as a scholarly concept and as a policy approach gained popularity from this date, particularly following the publication of the influential Hudson Institute report, Workforce 2000 (Johnston and Packer, 1987). Our aim is to uncover implicit assumptions and presupposed meanings attached to diversity in each national context. We do not employ techniques of systematic review or meta-analysis, but follow Mingers's recommendation (2000: 219) of adopting a healthy 'skepticism towards rhetoric, tradition, authority and objectivity' in the reviewed literature. We have drawn on electronic article retrieval systems as well as the libraries of four universities, using the search terms 'workforce diversity', 'diversity management' and 'managing diversity'. Acknowledging the importance of the larger context and relational and historical dynamics, our aim in reviewing the secondary sources is to illustrate how particular features of diversity evolved into their current form in each country. The discursive politics approach informs this article, not only conceptually but also methodologically, as it allows us to review the literature through critical lenses and to explore contextual and relational influences on the construction of diversity discourses. In other words, academic and documentary material are reviewed and analysed with a view to unpacking the processes of fixing, shrinking, stretching and bending, and to reveal the silences around the taboo areas. The following sections provide a cross-country analysis of the ways in which the concept of diversity management is redefined as it travels from North America.
The case of the UK: Diversity as multiculturalism and voluntarism
Since the 1990s, diversity management has become an increasingly popular approach to the multiple differences within the UK workforce. Historically, the UK has been a European leader in the regulation of diversity, with anti-discrimination legislation dating back to the 1967 Race Relations Act. Current equality legislation covers gender, race and ethnicity, age, disability, sexual orientation, gender reassignment, religion and belief. EU directives have contributed to the widening of UK equality legislation, by enforcing the relatively recent inclusion of age, sexual orientation and religion and belief in anti-discrimination law. In that sense, the EU as a transnational actor has facilitated the process of stretching the meaning of diversity. In the UK, equality laws had also supplemented by secondary legislation in the form of Public Sector Equality Duties addressing discrimination on the basis of gender, race and ethnicity and disability. Until recently, there were three equality bodies (The Commission for Racial Equality, Equal Opportunities Commission and Disability Rights Commission), with a research, advisory and enforcement role in their respective areas of equality legislation. In 2007, they were integrated into a single Equality and Human Rights Commission, responsible for overseeing the implementation of all strands of equality that are covered by law. In 2010, the Equality Act that distils the separate pieces of equality legislation into a single framework came into force.
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Progressive equality and diversity stakeholders, such as the trade unions, statutory equality bodies, social movement actors and minority advocacy groups have historically been instrumental in stretching the meaning of diversity in order to foster a comprehensive fairness agenda. Given the active presence of multiple stakeholders, public debate on diversity and equality in the UK is characterized by its dynamism (Özbilgin and Tatli, 2011). Since the 1980s there has been disillusionment with the unfulfilled promises of equal opportunities frameworks in delivering a progressive change towards more inclusive and egalitarian conditions in the labour market and organizations (Liff and Wajcman, 1996). Diversity management has entered the policy landscape against this backdrop, and the main frame of reference in fixing the meaning of diversity and its management has been the notion of multiculturalism and a pro-business approach. This dual commitment also underlined the regulation of diversity during the years of the 'New Labour' government (1997-2010), which was committed to promoting equality and inclusion but at the same time was wary of alienating business stakeholders (Healy et al., 2010). The adoption of the model of multiculturalism means that the meaning of diversity is progressively stretched to include multiple forms of group-based differences. The progressive nature of the social regulation of diversity in the country is best illustrated by the presence of a much stronger anti-discrimination policy on race and ethnicity compared to its continental European counterparts. Historically, the legacy of the slave trade and colonialism has had a decisive influence in shaping the frames of diversity and difference, not only through the resultant multicultural make-up of the UK population, but also by fuelling social movements, particularly in the second half of the 20th century (Oikelome, 2010). Although the history of the slavery, colonialism, and feminist and race equality movements are important in understanding the context of the regulation of diversity in the UK, the more recent case of Stephen Lawrence put the issue of race and ethnicity at the forefront of the diversity debate. Lawrence, a young British black man, was the victim of a racist murder in 1993. Following the persistent failure of the Metropolitan Police to bring his murderers to justice, the government established an independent inquiry under Sir William Macpherson; the resulting report, in 1999, concluded that the police force was 'institutionally racist' and recommended 70 separate reforms. This led to a set of government and trade union initiatives that gave public sector employers a number of duties to improve their ethnic, gender and disability equality provision. As a result, the meaning of diversity in the UK context is stretched to enable a proactive equalities agenda, in the public sector at least. However, recent declarations by prominent figures in the current Conservative-led coalition government suggest that the policy commitment to equality and diversity is now being sidelined. Conversely, the public and policy landscape in the UK is also traditionally shaped by a strong support for free market ideology, with resistance to state intervention. In terms of the adoption of the North American concept of diversity management, this has meant that the business-case arguments and the emphasis on voluntary action, particularly for the private sector, have predominated (Tatli, 2011). Kandola and Fullerton (1994: 7), who introduced the concept into the UK public and policy agenda, stated that diversity management is based on the premise that embracing the diversity within the workforce
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'will create a productive environment in which everyone feels valued, where their talents are being fully utilised and in which organizational goals are met'. Barmes and Ashtiany (2003), in their research into UK investment banks, found that business-case arguments for diversity were pushed forward at the expense of ethical concerns over exclusion and discrimination. The meaning of diversity management is bent and shrunk to a set of performance-driven business outcomes, whilst the social justice and moral dimensions of equality for, and inclusion of, diverse groups are marginalized. The dominant approach is supported in the hegemonic public discourse by the assumption that organizations will voluntarily take a proactive stance in promoting equality, diversity and inclusion because it makes business sense. Despite this temporal fixing of the meaning of diversity management, the research evidence demonstrates that the most important driver for diversity management policies in organizations continues to be legal compliance (Tatli et al., 2008). UK scholars have developed a powerful critique of the voluntaristic business-case rhetoric as a stratagem to divert attention from disadvantage rooted in group-based differences and hence to undermine the legal and moral underpinning of equality and justice, thus avoiding the burden of progressive, but costly, change programmes (Dickens, 1999; Noon, 2007). The traditional belief in ideologies of a free market and individualism generates a hegemonic frame for social regulation in the UK, through which the meaning of diversity is not only bent to fit particular policy concerns but is also shrunk in a way that enables the exclusion of taboo areas from surfacing in public debates. The key taboo areas in the field of diversity management are class differences and the use of strong coercive regulation for the effective enforcement of equality and diversity. In contrast to the celebration of a wide array of differences between the employees, social class as a topic of concern is omitted from diversity management debates. Additionally, although there is strong encouragement for public sector organizations to set equality and diversity targets and to monitor their implementation, the approach to private sector employers is far less prescriptive (Özbilgin and Tatli, 2011). The taboos are even more forceful in relation to enforcement mechanisms, such as positive discrimination or quotas to redress past inequalities (Noon, 2010).
The case of France: Diversity as assimilation of ethnic minorities
Klarsfeld and Bender (2009) suggest that diversity initiatives for employment in France are driven by increasing legal and international stakeholder pressures and by a growing awareness of the benefits of diversity. Managing diversity in French organizations is frequently associated with socially responsible actions (Chanlat, 2002). Diversity is currently understood and debated in political and organizational discourses in terms of gender and cultural differences. Bender (2004) highlights that French organizations are increasingly, if belatedly, conscious of the importance of managing gender diversity at work. Nevertheless, the meaning of diversity and its management remains very contentious, and indeed French law renders it illegal to distinguish people according to specific traits such as ethnicity (Al Ariss and Syed, 2011), since this is deemed inconsistent with the republican model which insists on the undifferentiated status of all citizens. For
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example, statistics are collected and analysed in terms of citizenship rather than ethnicity (HCI, 2007). Interestingly, most English-language scholarly work that tackles ethnicity in France argues that the republican model is in reality founded on particularities rather than universalism, for example in the use of implicit ethnic criteria in immigration policies that are supposedly ethnicity-neutral (Silverman, 2007). Nevertheless, French scholars have been resistant to any discussion of ethnic difference as a factor in national life (Peabody and Stovall, 2003). The topic of gender diversity seems to be better received in France, though its meaning is frequently bent in order to match policy goals. Gender diversity initiatives in France started with the loi Roudy of 1983, which adopted the principle of gender equality at work and encouraged organizations to promote positive measures. However, this initiative had a primarily voluntary character and exerted little impact within business circles (Bender, 2004). In 2001, the loi Génisson obliged organizations to publish a gender breakdown of working hours, recruitment and turnover, promotion, pay and training, and required issues of gender equality to be included in the annual collective bargaining agenda at company level. This new law was, in part, an illustration of the positive impact of EU gender mainstreaming (Cornet, 2002). Promotion of gender diversity at EU level had further practical implications in France. For instance, a law was adopted in 2011 obliging large companies to ensure at least 40 percent representation of women on their boards within six years, and there have been recent attempts to include such quotas in the Parliament; while in 2012 the new President François Hollande appointed equal numbers of women and men to his cabinet. These initiatives are an important break from France's traditional opposition to quotas. Aside from the inclusion of gender as a key parameter in defining diversity, a significant reconceptualization of the originally North American concept of diversity is how it is stretched around the treatment of cultural differences within the population and workforce. The term culture is rarely defined in the French literature in relation to diversity, and the meaning of cultural difference in the context of management and employment is generally left open-ended (Chanlat, 2002). Nevertheless, there are increasing calls in France to include intersectionality (the interlinkage between categories) in terms of gender, age, disability, sexual orientation (and 'ethnicity', although the term as such is not used) in order to eliminate inequalities (Cornet, 2010). For example, the Montaigne Institute is a think-tank that endorses affirmative action and supports the adoption of new regulations in the area of diversity (Klarsfeld, 2009b). Many other organizations, such as the Club du 21ème Siècle, which presses for equality for migrants and ethnic minorities, voice the issue of diversity in political, social, and corporate settings. Nevertheless, the processes of bending, shrinking and stretching the meaning of diversity are still based on a strong association between diversity, integration and immigration. The term 'integration', with a particular focus on immigrants, characterizes a contemporary bending of the discourses on the management of diversity (Al Ariss and Özbilgin, 2010). For many scholars, in contrast to the term 'assimilation', it does not require a break from the culture of the country of origin (Begag, 2003; Weil, 2004); but in France its meaning is commonly shrunk to assimilation. As Boubaker (2006) states, the riots in the French suburbs in 2005, coupled with the growth of ethnic minority enclaves, is strong proof that the French model of integration has failed.
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In France, not only has the meaning of cultural diversity shrunk to a limited understanding of ethnic diversity framed around the assimilationary notion of integration, but it is also bent to address a specific set of policy issues around immigration. Weber (2007) explains that a focus on immigration is a key means for governments to gain votes. The first restrictions on the entry of immigrant labour were imposed in 1974; the implicit argument was that there was a need to integrate existing immigrants before accepting more. The code civil provides that a person cannot be naturalized unless they can prove assimilation to French society; hence the burden of proof and responsibility for successful 'integration' falls mainly on the immigrant, rather than the state (Lang and Bras, 2006; Weber, 2007), introducing additional barriers for minority ethnic individuals in French organizations (Ramboarison-Lalao et al., 2012). The hegemonic framing of the meaning of cultural diversity around assimilationary references to the integration of immigrants owes its legitimacy partly to the social regulation of the notion of citizenship. French republican values of freedom, equality and brotherhood are intended to transcend all other identities, setting the boundaries for the meaning of diversity and determining what can and cannot be discussed. The French Constitution in theory guarantees the equality of all citizens before the law, without distinction of gender and ethnicity; but such an approach overlooks existing fault lines involving ethnic origin and is thus counterproductive for promoting equality and diversity, because discussions of discrimination on the grounds of ethnicity are marginalized. Yet, disparities clearly exist between the native French citizens and the ethnic minorities in terms of job opportunities and political representation (Cediye and Foroni, 2007; Senik and Verdier, 2008). The taboos in fixing the meaning of diversity in France also have their roots in the history of the country. As Osler and Starkey (2005) explain, by taking a 'neutral' position towards minorities the state has failed to address unfair treatment and discrimination on the basis of ethnic origin. The taboo areas are also a reflection of the dominant patterns of political and social power: historically, policies have been made and implemented by politicians from the ethnic majority, who share the same elite educational background (Bach and Rocca, 2000). Instead of adopting a collective approach to compensate for discrimination against minorities, the state pursues the integration of minorities into a homogeneous republican model (Koff, 2009; Koopmans, 2010). As a result, an assimilationist integration approach shapes the meaning and interpretation of diversity and its management.
The case of Germany: Diversity as 'integracism'
Diversity management emerged as a topic of debate, both among management and in scholarly circles, in the late 1990s. The concept entered the research and management rhetoric as a human resource management notion (Vedder, 2006), with no base in human rights or anti-discrimination arguments. Interestingly, whilst the meaning of diversity management is shrunk as an HRM notion, it is at the same time stretched to include gender issues, which represent the dominant dimension in the framing of diversity management in Germany (Koall and Bruchhagen, 2002). Researchers who were originally engaged with women's studies now conduct the majority of diversity management
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research. When these scholars moved across to diversity research, the agenda of female emancipation was retained as the central foci of their work; while race-related issues, which were not traditionally considered, have been excluded. Thomas (1995) argues that in the USA, diversity management might provide an optimal way to include ethnic minority groups. In Germany, on the other hand, its meaning is shrunk to exclude problems of discrimination based on ethnicity (Köppel et al., 2007). However, more recently the government changed its discourse and started to promote diversity management as a tool for the better integration of ethnic minority workers. Consequently, terms such as 'valuing diversity' and diversity management have increasingly appeared in the debate (Böhmer, 2007), as the government attempts to bend the meaning of diversity management towards integration and immigration policies. However, governmental interventions predominantly concentrate on changing the discourse and by doing so fail to target the structural barriers. As a result, organizations still do not view managing ethnic diversity as important (Köppel et al., 2007). There is a general resistance to tackling race-related issues in Germany, as the heated political debates concerning the implementation of the two EU Equality Directives of 2000 clearly illustrate. Both directives are based upon Article 13 of the Amsterdam Treaty, providing the EU with a legal basis for action to combat discrimination on the grounds of racial or ethnic origin, religion or belief, disability, age or sexual orientation. Although trade unions and NGOs hoped that the EU legislation would contribute to the development of an anti-discrimination approach in Germany, their expectations were not met. Employers' associations and churches were particularly opposed to the new protections, and discussion of the implementation of the EU race directive lasted for nearly six years. This resistance delayed implementation by means of the Allgemeines Gleichbehandlungsgesetz (general equal treatment law) until the 2006 (Vassilopoulou and Merx, 2007). One reason for this resistance is that the process of fixing the meanings of diversity is trapped in history, the Nazi past and the more recent experience of economic immigration. Tajfel and Turner (1986) argue that individuals tend to externalize group-based guilt feelings because they may threaten their group identity and their self-image that is derived from group membership. Germany's Nazi past and the associated collective national guilt establish a hegemonic frame of reference in generating temporarily fixed meanings of diversity. National guilt, related to the crimes of the Holocaust, has deeply affected the collective memory; processing this guilt was at the heart of post-war democratization (Habermas, 1988) and plays a key role in many facets of contemporary German social and political life (Safran, 2000). This goes beyond the externalization of feelings of guilt, in a way that creates a silence around everything that could be a reminder of these negative feelings. Such is the case with current issues of race discrimination, externalized and silenced through efforts to transcend the collective guilt. As a result, race-related issues remain ignored and unchallenged. In effect, the meaning of diversity is fixed in such a way that race-related issues are excluded from the diversity management agenda and debate. Notions such as racism or race discrimination construct the key areas of taboos in the processes through which the meaning of diversity is bent, stretched, shrunk and consequently temporarily fixed (Van Dyk, 1995). One example is the absence of race-related issues in the diversity
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management approaches of German organizations, which in turn serves as a mechanism to exclude racial and ethnic differences from the frames of diversity. Köppel et al. (2007) found that the management of ethnic diversity in Germany lags behind in an international comparison; more than half of German companies do not view the management of ethnic diversity as pertinent. The treatment of minorities of Turkish ethnic origin, who are seen as the most problematic minority group in Germany, illustrates the contextual nature of the ways in which the meaning of ethnic and cultural diversity is bent in line with the hegemonic frames of reference. Contrary to the original North American framing of difference along the contours of including, embracing and valuing diverse backgrounds, Turkish minority individuals are portrayed through negative arguments. For instance, failure to employ workers of Turkish ethnicity is defended by arguments that this group is deficient across various job criteria, particularly regarding their alleged lack of proficiency in the German language. These negative representations of ethnic minorities support ethnocentric views and stereotypes, which are used to legitimize and normalize discrimination towards ethnic minorities in the German workplace. There is a shared belief that the policy on ethnic minorities needs to focus on 'helping' them to develop skills, rather than on tackling discrimination and including ethnic minorities in diversity policies in positive terms. Another reference point is the notion of integration. The concept of diversity is shrunk, bent and stretched to fit the policies and debates around immigration and integration. Post-war Germany has received a high number of economic immigrants, and has the third largest number of immigrants in the world (IOM, 2010). Despite this, for a long time Germany had difficulties in accepting its status as a country of immigration. This resistance was reflected in government policies, which aimed at excluding immigrants from the labour market when times were economically hard and regarded them as 'guest workers' (Gastarbeiter). According to the Chancellor, Angela Merkel, multiculturalism has 'absolutely failed' (Der Spiegel, 19 October 2010). This assessment is surprising since the government has never pursued a national agenda for multiculturalism: the aim has always been to assimilate ethnic minorities into the dominant culture (Esser, 2006). Alarmingly, a study in 2010 revealed a rise in decidedly anti-democratic and racist attitudes among native-born citizens: more than 30 percent of respondents believed that foreigners overran the country, and that when jobs are scarce foreigners should be sent back to their own countries (Decker et al., 2010). The notion of integration is the most dominant concept in the management of ethnic diversity in Germany. The socio-political context in the country generates a specific interpretation of integration with implicitly racist assumptions, which we term integracism. This racially biased and ethnocentric notion of integration frames the meanings of managing ethnic diversity in Germany. Integration polices and measures are deployed to 'aid the better integration' of ethnic minorities, who are widely seen as deficient and difficult to integrate, rather than adopting diversity management measures to foster equality, fairness and inclusion at work. In that frame, ethnic diversity is depicted as a source of potential problems (Berlin-Institut, 2009). Contrary to the North American approach to diversity management, which is based on the premise of valuing and utilizing difference, the German version of integration sets out to assimilate ethnic minorities into the dominant white organizational culture. Diversity
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management in Germany does not cater for such central aspects as race equality and antidiscrimination. Such issues are largely silenced in the political and public debate. Consequently, the current framing of ethnic diversity in employment, through a racially biased and ethnocentric notion of integration, undermines the need to manage ethnicdiversity in organizations.
Conclusions
This article has filled a gap in the literature by providing a cross-cultural comparison of the reinterpretation of diversity management in three different national settings. This is achieved by examining the historically and contextually embedded processes of the construction of the meaning of diversity management in the UK, France and Germany. Table 1 summarizes our findings. While the main emphasis in defining diversity management in the UK has been on voluntarism and multiculturalism, in France the traditional discourses of equality has been used to pursue an agenda of assimilation and integration. Different historical legacies and meanings afforded to equality and diversity mean that organizations have in the main regulated diversity in order to encourage sameness rather than to celebrate difference among their workers. In Germany, diversity management is advocated as a voluntary strategy, which is almost explicitly liberated from the notion of ethnicity, allowing other forms of difference to be accommodated in workplaces. What appears at first sight to be common across Britain, France and Germany is the very national nature of the interpretation of diversity, despite the uniting character of the supranational regulation emanating from the EU. This dependence on the national context serves to accentuate the blind spots in these three countries, which we identify as the ineffectual nature of business-case based voluntarism and the omission of social class inequality in the case of the UK; an emphasis on sameness and assimilation that renders difference a threat in workplaces in France; and partial consideration of diversity at the expense of its ethnic dimensions in Germany. Furthermore, there is a recent political and public consensus in Germany that not only multiculturalism, but also the integration of ethnic minorities, has failed. And like Merkel, the former French President Nicolas Sarkozy rejected multiculturalism as a failure (Le Monde, 25 February 2011), while British Prime Minister David Cameron denounced 'state multiculturalism' (The Guardian, 5 February 2011). Extreme right-wing electoral success across Europe may be partly responsible for the growing lack of commitment to promoting equality and diversity in all three countries. Recent developments suggest that diversity management is likely to be shrunk to integration and assimilation, with a focus on putting the burden solely on individuals from minority ethnic groups to seek conformity to a monolithic conception of national identity, the existence of which is highly debatable. Social regulation in the UK, France and Germany has so far followed a path-dependent trajectory in which the meaning of diversity management has been bent, stretched, shrunk and fixed in order to fit with the national traditions and requirements of social and economic activity. However, this nationally focused understanding of context has been limiting in many ways, as it is imbued with silences, taboos and omissions. In order for social regulation to be effective, there is a need for social policy to transcend rather than
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Table 1. The construction of the meaning of diversity management in the UK, France and Germany Temporarily fixed meaning of diversity management UK Fixed as a policy approach to address the multicultural society. Bent away from a morally driven equal opportunities agenda towards a pro-business one. Stretched to include multiple forms of difference. Shrunk to instrumental logic and bottom-line concerns Fixed around values of liberty, equality and fraternity. Bent to the values of French Republicanism. Shrunk to issues of assimilation of ethnic minorities. Stretched to include issues related to culture and gender. Fixed around an assimilative notion of integration. Bent to address immigration concerns. Shrunk to gender equality and integration of immigrant/ethnic minorities. Stretched to respond to business needs. Frame of reference Multiculturalism and voluntarism based on the business case Taboos Social class inequality. Positive discrimination and quotas
France
Secularism, equality and integration
Discrimination based on race/ethnicity and religion
Germany
Gender equality and the business case
Racism and discrimination based on race/ethnicity
simply to adopt national context as its key consideration. Despite earlier warnings that diversity management may be resisted in its journey to other national contexts, we demonstrate that the resistance took a subtle form of liberal subversion, when diversity management entered the lexicon of British, French and German social regulation, where its meaning is localized. Diversity management has therefore not fully replaced other social regulation concepts, such as equal opportunities, multiculturalism, integration and assimilation, but neither is it fully rejected as a new approach. Instead, diversity management both contaminates and is contaminated by the local vernacular of managing differences in social and employment settings. This article has explored the social regulation of diversity management, drawing on an extensive review of key literatures. However, our findings could be extended to frame a comparative empirical study in the future. Such field research into the mechanisms of fixing, bending, stretching and shrinking of the notion of diversity management may collect data in the form of policy documents and statistical evidence, and use a variety of methods, such as interviews, surveys, observation and ethnography. In this article, we offer a bird's-eye view of the temporarily fixed social regulation and dominant frames of diversity management by exploring the processes of bending, stretching
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and shrinking of the meanings conferred on diversity and its management. However, these processes through which diversity management is defined are also processes of struggle for legitimacy, power and domination between various interest groups. We have explored the role of multiple stakeholders in negotiating the meaning of diversity, but only in a limited way, as our main focus has been to understand the general and hegemonic trends of the regulation of diversity management cross-nationally. Nevertheless, trade unions, statutory equality bodies, social movement actors and minority advocacy groups in the UK were instrumental in stretching the meaning of diversity in order to foster a comprehensive fairness agenda. Similarly, in France, progressive institutions such as the Montaigne Institute played a key role in stretching the meanings of diversity to more inclusive intersectional issues. Future research may examine in-depth the role and influence of, and the conflicts of interest between, different institutional actors in relation to the processes that shape the fixed meanings of diversity management. It would be interesting to investigate further the unspoken motives and stakes of institutional actors in attempting to define and frame diversity management in particular ways. There is clearly more research needed in order to break through the wall of silence around the taboo areas. Further research could focus on the strategies, experiences and agency of the groups that are sidelined, made invisible and disadvantaged because of the blind spots in the hegemonic frames. Moreover, equalityand diversity research needs to overcome its own taboos by examining the intended and unintended opportunity structures generated through particular ways of fixing, bending, stretching and shrinking the notion of managing diversity. Our analysis has relevance for diversity policy and practice. A key implication is that direct transposition of diversity management ideas is not feasible, as would be the case with direct transposition of diversity management policies. Drawing on our conclusions, we argue that social policy should capture the local meanings and path dependencies concerning the concept of diversity with a view to transcend them. For instance, the management of diversity in France and Germany requires the reframing of ethnic minorities' contribution to the labour market in positive and supportive ways. This article has shown how the traditional approach of not fully accepting and valuing ethnic minority workers in these two countries has been counterproductive. Institutional support is increasingly needed in a context where immigrants are expected to fill job vacancies in developed countries. On the other hand, omission of social class-based disadvantage is a significant barrier in promoting justice and inclusion in UK organizations. Concrete steps in regulating diversity management through the formulation and implementation of strong antidiscrimination legislation and diversity codes of practices that address marginalization of all disadvantaged groups are essential to promote diversity and equality in organizations and the labour market. There is a particular necessity to extend equality and diversity regulation to the currently overlooked ethnic and racial minorities in the case of France and Germany, and to address social class inequality in the UK. Finally, as we have demonstrated, with examples, frames of diversity management are historically embedded. However, times do change with changes in the political and hegemonic order. Therefore, social regulation and policy efforts on diversity management should capture dynamism and change in this field.
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This research received no specific grant from any funding agency in the public, commercial or not-for-profit sectors.
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Author biographies Ahu Tatli is a senior lecturer in the School of Business and Management at Queen Mary University of London. JoanaVassilopoulou researches and lectures at Brunel Business School, Brunel University, London. Akram Al Ariss is a professor at the Toulouse Business School, Université de Toulouse. Mustafa Özbilgin is Professor of Organizational Behaviour at Brunel Business School, Brunel University, London and the co-chair of Management et Diversité, Université Paris-Dauphine, France.
doc_293530929.docx
Case Study on the Role of Regulatory and Temporal Context in the Construction of Diversity Discourses: UK, France and Germany, The "business case for diversity" stem from the progression of the models of diversity within the workplace since the 1960s. The original model for diversity was situated around affirmative action drawing strength from the law and a need to comply with equal opportunity employment objectives.
Case Study on the Role of Regulatory and Temporal Context in the Construction of Diversity Discourses: UK, France and Germany
Abstract
Despite growing interest in how the concept of diversity management is reinterpreted as it crosses national boundaries, there has been little study of this process in Europe. To bridge this knowledge gap, this article explores the construction of diversity discourses in the context of the UK, France and Germany. We use the discursive politics approach to investigate the ways in which the meaning of diversity is shrunk, bent and stretched. We demonstrate that the concept of diversity has no universal fixed meaning but is contextual, contested and temporal. Temporarily fixed definitions and frames of diversity are pathdependent and shaped by the regulatory context. Thus unique national histories and the context of regulation are key determinants of the ways in which the concept is redefined as it crosses national and regional borders.
Keywords
discrimination, discursive politics, diversity, diversity management, integracism, regulation, taboos
Corresponding author: Ahu Tatli, School of Business and Management, Queen Mary University of London, Mile End Road, London E1 4NS, UK. Email: [email protected]
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Introduction
Diversity management as a new paradigm to deal with the demographic diversity of employees has its roots in the North American context of the late 1980s. In this approach, diversity is framed as an attribute of individuals, moving the focus away from groupbased differences and resultant inter-group inequalities (Linnehan and Konrad, 1999). Institutional and legal rationales for responding to employee diversity have been replaced by a business-case rationale linked to positive performance and financial outcomes for organizations. This shift in the US context of employment relations is to some extent interpreted as a move to minimize the backlash among the majority white (or male) population against affirmative action policies (Kelly and Dobbin, 1998). In the ensuing decades, the concept of diversity management has entered the policy lexicon in other countries. The UK represents the earliest example outside the North American setting, with the publication of Managing the Mosaic (Kandola and Fullerton, 1994). The arrival of the concept in continental Europe has been comparably recent, only gaining a popular reception in the late 2000s. The international transfer among organizations and policymakers of an originally North American approach has stimulated academic research interest in how the concept is reshaped and reinterpreted (Klarsfeld, 2010; Syed and Özbilgin, 2010). Such research has demonstrated that the meanings and definitions attributed to diversity and its management vary considerably as they travel across place and time. Klarsfeld (2010) has shown that diversity management is interpreted across the spectrum of voluntarism and coercion. Variation is also present in terms of both the prevalence of the business-case rationale and the definition and dimensions of diversity that are captured in diversity management interventions. For example, in Scandinavia the interpretation and policy enactment of diversity management have been predominantly entangled with migration concerns and the integration of ethnic minorities into the labour force (Boxenbaum, 2006). As a result, arguments based on corporate social responsibility, rather than the business case, dominate the diversity debate (Kamp and Hagedorn-Rasmussen, 2004). Similarly, Klarsfeld (2009a) argues whereas diversity management was originally presented in the USA as an alternative to equal opportunities and affirmative action, when the concept arrived in France there was an accommodation of these two approaches. In Germany (and also in France), the concept of diversity management is not only applied to the employment sphere but involves broader issues of social integration, particularly concerning ethnicity and race. Despite the expanding stock of knowledge on how the concept of diversity management gains new meanings as it travels across national settings, cross-national comparisons of this concept in Europe remain rare. To bridge this knowledge gap, we explore the construction of the meaning of diversity in three countries, the UK, France and Germany. Such a cross-cultural comparative analysis is of particular relevance because of a common EU regulatory framework: diversity management as a discourse draws strength from, and is partly shaped by, EU legislation. For instance, such legislation has been instrumental in widening the definitions of diversity by introducing protection against discrimination on such grounds as gender, ethnicity, disability, sexual orientation, religion, belief and age. However, this legislation has been interpreted and implemented
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very differently across the member states, illustrating the complexity of the translation of legal and discursive notions of diversity across national boundaries. We use the 'discursive politics' approach developed by Lombardo et al. (2009, 2010) to investigate how the concept of diversity management travels across national borders. By discursive politics, Lombardo and colleagues (2009) refer to the contextual process of attributing meaning to concepts. Their analysis deals, in the main, with the meanings that gender equality has been assigned in different contexts, and shows how the concept is defined and redefined through a process of political contestation. This process involves four dynamics, which they term fixing, shrinking, stretching and bending. First of all, the meaning of a concept is always temporarily fixed, which is a necessary step to having a workable definition on which policies can be based. Temporarily fixed meanings are the outcomes of the other three processes: shrinking, stretching and bending. By shrinking, the scope of a concept is limited to a narrower set of meanings and policy goals than originally intended; conversely, stretching involves broadening a concept to include dimensions and meanings which were not originally signified. Bending a concept means redefining its meaning in order to match policy goals which differ from those that the concept was originally intended to address. In the process of travel, a concept can experience one or more of these transformations at the same time; they are not mutually exclusive. Shrinking, stretching and bending are processes of negotiation between multiple stakeholders who aim to advance their specific interpretations and agendas (Özbilgin and Tatli, 2011). In the case of diversity, stretching rather than shrinking or bending is often the source of positive change, as more progressive stakeholders negotiate to widen the coverage of a concept through stretching its meaning. Using this framework, we demonstrate the ways in which the meaning of diversity is fixed, shrunk, bent and stretched in our three countries. We illustrate how the concept of diversity is contextual, contested and temporal rather than having a universal fixed meaning. In other words, what diversity (and its management) means is only temporarily fixed through a political process of negotiation. These temporarily fixed definitions and frames of diversity are path-dependent and shaped by the regulatory context in each country. There also exist hegemonic frames of reference that set boundaries for imagining alternative meanings and definitions of a given concept. Such boundaries are products of a specific set of taboos, which are defined by Lombardo et al. (2010: 106) as an 'often tacit but shared and general inclination not to address or question an issue'. Biases and blind spots in defining certain concepts are not always the result of intentional choices by the policy actors, but may be outcomes of historically and contextually embedded presumptions. We suggest, therefore, that understanding the discursive politics of social regulation of diversity management requires simultaneous attention to what is present in the diversity debates (meanings and definitions), and what is absent (taboos and silences) (Bell et al., 2011). We thus pay particular attention to the taboo areas which create distinct blind spots in hegemonic frames of social regulation in each country. In undertaking a comparative and cross-cultural review of the diversity management debate, we adopt a contextual and relational standpoint. The review was conducted through a critical reading of the diversity literature in English, French and German.
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Secondary data from scholarly and practitioner sources, such as journal articles, research reports and books, national government and EU policy documents are included in our literature review for the years of 1990 to 2011. The year of 1990 is chosen as the starting point because diversity management as a scholarly concept and as a policy approach gained popularity from this date, particularly following the publication of the influential Hudson Institute report, Workforce 2000 (Johnston and Packer, 1987). Our aim is to uncover implicit assumptions and presupposed meanings attached to diversity in each national context. We do not employ techniques of systematic review or meta-analysis, but follow Mingers's recommendation (2000: 219) of adopting a healthy 'skepticism towards rhetoric, tradition, authority and objectivity' in the reviewed literature. We have drawn on electronic article retrieval systems as well as the libraries of four universities, using the search terms 'workforce diversity', 'diversity management' and 'managing diversity'. Acknowledging the importance of the larger context and relational and historical dynamics, our aim in reviewing the secondary sources is to illustrate how particular features of diversity evolved into their current form in each country. The discursive politics approach informs this article, not only conceptually but also methodologically, as it allows us to review the literature through critical lenses and to explore contextual and relational influences on the construction of diversity discourses. In other words, academic and documentary material are reviewed and analysed with a view to unpacking the processes of fixing, shrinking, stretching and bending, and to reveal the silences around the taboo areas. The following sections provide a cross-country analysis of the ways in which the concept of diversity management is redefined as it travels from North America.
The case of the UK: Diversity as multiculturalism and voluntarism
Since the 1990s, diversity management has become an increasingly popular approach to the multiple differences within the UK workforce. Historically, the UK has been a European leader in the regulation of diversity, with anti-discrimination legislation dating back to the 1967 Race Relations Act. Current equality legislation covers gender, race and ethnicity, age, disability, sexual orientation, gender reassignment, religion and belief. EU directives have contributed to the widening of UK equality legislation, by enforcing the relatively recent inclusion of age, sexual orientation and religion and belief in anti-discrimination law. In that sense, the EU as a transnational actor has facilitated the process of stretching the meaning of diversity. In the UK, equality laws had also supplemented by secondary legislation in the form of Public Sector Equality Duties addressing discrimination on the basis of gender, race and ethnicity and disability. Until recently, there were three equality bodies (The Commission for Racial Equality, Equal Opportunities Commission and Disability Rights Commission), with a research, advisory and enforcement role in their respective areas of equality legislation. In 2007, they were integrated into a single Equality and Human Rights Commission, responsible for overseeing the implementation of all strands of equality that are covered by law. In 2010, the Equality Act that distils the separate pieces of equality legislation into a single framework came into force.
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Progressive equality and diversity stakeholders, such as the trade unions, statutory equality bodies, social movement actors and minority advocacy groups have historically been instrumental in stretching the meaning of diversity in order to foster a comprehensive fairness agenda. Given the active presence of multiple stakeholders, public debate on diversity and equality in the UK is characterized by its dynamism (Özbilgin and Tatli, 2011). Since the 1980s there has been disillusionment with the unfulfilled promises of equal opportunities frameworks in delivering a progressive change towards more inclusive and egalitarian conditions in the labour market and organizations (Liff and Wajcman, 1996). Diversity management has entered the policy landscape against this backdrop, and the main frame of reference in fixing the meaning of diversity and its management has been the notion of multiculturalism and a pro-business approach. This dual commitment also underlined the regulation of diversity during the years of the 'New Labour' government (1997-2010), which was committed to promoting equality and inclusion but at the same time was wary of alienating business stakeholders (Healy et al., 2010). The adoption of the model of multiculturalism means that the meaning of diversity is progressively stretched to include multiple forms of group-based differences. The progressive nature of the social regulation of diversity in the country is best illustrated by the presence of a much stronger anti-discrimination policy on race and ethnicity compared to its continental European counterparts. Historically, the legacy of the slave trade and colonialism has had a decisive influence in shaping the frames of diversity and difference, not only through the resultant multicultural make-up of the UK population, but also by fuelling social movements, particularly in the second half of the 20th century (Oikelome, 2010). Although the history of the slavery, colonialism, and feminist and race equality movements are important in understanding the context of the regulation of diversity in the UK, the more recent case of Stephen Lawrence put the issue of race and ethnicity at the forefront of the diversity debate. Lawrence, a young British black man, was the victim of a racist murder in 1993. Following the persistent failure of the Metropolitan Police to bring his murderers to justice, the government established an independent inquiry under Sir William Macpherson; the resulting report, in 1999, concluded that the police force was 'institutionally racist' and recommended 70 separate reforms. This led to a set of government and trade union initiatives that gave public sector employers a number of duties to improve their ethnic, gender and disability equality provision. As a result, the meaning of diversity in the UK context is stretched to enable a proactive equalities agenda, in the public sector at least. However, recent declarations by prominent figures in the current Conservative-led coalition government suggest that the policy commitment to equality and diversity is now being sidelined. Conversely, the public and policy landscape in the UK is also traditionally shaped by a strong support for free market ideology, with resistance to state intervention. In terms of the adoption of the North American concept of diversity management, this has meant that the business-case arguments and the emphasis on voluntary action, particularly for the private sector, have predominated (Tatli, 2011). Kandola and Fullerton (1994: 7), who introduced the concept into the UK public and policy agenda, stated that diversity management is based on the premise that embracing the diversity within the workforce
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'will create a productive environment in which everyone feels valued, where their talents are being fully utilised and in which organizational goals are met'. Barmes and Ashtiany (2003), in their research into UK investment banks, found that business-case arguments for diversity were pushed forward at the expense of ethical concerns over exclusion and discrimination. The meaning of diversity management is bent and shrunk to a set of performance-driven business outcomes, whilst the social justice and moral dimensions of equality for, and inclusion of, diverse groups are marginalized. The dominant approach is supported in the hegemonic public discourse by the assumption that organizations will voluntarily take a proactive stance in promoting equality, diversity and inclusion because it makes business sense. Despite this temporal fixing of the meaning of diversity management, the research evidence demonstrates that the most important driver for diversity management policies in organizations continues to be legal compliance (Tatli et al., 2008). UK scholars have developed a powerful critique of the voluntaristic business-case rhetoric as a stratagem to divert attention from disadvantage rooted in group-based differences and hence to undermine the legal and moral underpinning of equality and justice, thus avoiding the burden of progressive, but costly, change programmes (Dickens, 1999; Noon, 2007). The traditional belief in ideologies of a free market and individualism generates a hegemonic frame for social regulation in the UK, through which the meaning of diversity is not only bent to fit particular policy concerns but is also shrunk in a way that enables the exclusion of taboo areas from surfacing in public debates. The key taboo areas in the field of diversity management are class differences and the use of strong coercive regulation for the effective enforcement of equality and diversity. In contrast to the celebration of a wide array of differences between the employees, social class as a topic of concern is omitted from diversity management debates. Additionally, although there is strong encouragement for public sector organizations to set equality and diversity targets and to monitor their implementation, the approach to private sector employers is far less prescriptive (Özbilgin and Tatli, 2011). The taboos are even more forceful in relation to enforcement mechanisms, such as positive discrimination or quotas to redress past inequalities (Noon, 2010).
The case of France: Diversity as assimilation of ethnic minorities
Klarsfeld and Bender (2009) suggest that diversity initiatives for employment in France are driven by increasing legal and international stakeholder pressures and by a growing awareness of the benefits of diversity. Managing diversity in French organizations is frequently associated with socially responsible actions (Chanlat, 2002). Diversity is currently understood and debated in political and organizational discourses in terms of gender and cultural differences. Bender (2004) highlights that French organizations are increasingly, if belatedly, conscious of the importance of managing gender diversity at work. Nevertheless, the meaning of diversity and its management remains very contentious, and indeed French law renders it illegal to distinguish people according to specific traits such as ethnicity (Al Ariss and Syed, 2011), since this is deemed inconsistent with the republican model which insists on the undifferentiated status of all citizens. For
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example, statistics are collected and analysed in terms of citizenship rather than ethnicity (HCI, 2007). Interestingly, most English-language scholarly work that tackles ethnicity in France argues that the republican model is in reality founded on particularities rather than universalism, for example in the use of implicit ethnic criteria in immigration policies that are supposedly ethnicity-neutral (Silverman, 2007). Nevertheless, French scholars have been resistant to any discussion of ethnic difference as a factor in national life (Peabody and Stovall, 2003). The topic of gender diversity seems to be better received in France, though its meaning is frequently bent in order to match policy goals. Gender diversity initiatives in France started with the loi Roudy of 1983, which adopted the principle of gender equality at work and encouraged organizations to promote positive measures. However, this initiative had a primarily voluntary character and exerted little impact within business circles (Bender, 2004). In 2001, the loi Génisson obliged organizations to publish a gender breakdown of working hours, recruitment and turnover, promotion, pay and training, and required issues of gender equality to be included in the annual collective bargaining agenda at company level. This new law was, in part, an illustration of the positive impact of EU gender mainstreaming (Cornet, 2002). Promotion of gender diversity at EU level had further practical implications in France. For instance, a law was adopted in 2011 obliging large companies to ensure at least 40 percent representation of women on their boards within six years, and there have been recent attempts to include such quotas in the Parliament; while in 2012 the new President François Hollande appointed equal numbers of women and men to his cabinet. These initiatives are an important break from France's traditional opposition to quotas. Aside from the inclusion of gender as a key parameter in defining diversity, a significant reconceptualization of the originally North American concept of diversity is how it is stretched around the treatment of cultural differences within the population and workforce. The term culture is rarely defined in the French literature in relation to diversity, and the meaning of cultural difference in the context of management and employment is generally left open-ended (Chanlat, 2002). Nevertheless, there are increasing calls in France to include intersectionality (the interlinkage between categories) in terms of gender, age, disability, sexual orientation (and 'ethnicity', although the term as such is not used) in order to eliminate inequalities (Cornet, 2010). For example, the Montaigne Institute is a think-tank that endorses affirmative action and supports the adoption of new regulations in the area of diversity (Klarsfeld, 2009b). Many other organizations, such as the Club du 21ème Siècle, which presses for equality for migrants and ethnic minorities, voice the issue of diversity in political, social, and corporate settings. Nevertheless, the processes of bending, shrinking and stretching the meaning of diversity are still based on a strong association between diversity, integration and immigration. The term 'integration', with a particular focus on immigrants, characterizes a contemporary bending of the discourses on the management of diversity (Al Ariss and Özbilgin, 2010). For many scholars, in contrast to the term 'assimilation', it does not require a break from the culture of the country of origin (Begag, 2003; Weil, 2004); but in France its meaning is commonly shrunk to assimilation. As Boubaker (2006) states, the riots in the French suburbs in 2005, coupled with the growth of ethnic minority enclaves, is strong proof that the French model of integration has failed.
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In France, not only has the meaning of cultural diversity shrunk to a limited understanding of ethnic diversity framed around the assimilationary notion of integration, but it is also bent to address a specific set of policy issues around immigration. Weber (2007) explains that a focus on immigration is a key means for governments to gain votes. The first restrictions on the entry of immigrant labour were imposed in 1974; the implicit argument was that there was a need to integrate existing immigrants before accepting more. The code civil provides that a person cannot be naturalized unless they can prove assimilation to French society; hence the burden of proof and responsibility for successful 'integration' falls mainly on the immigrant, rather than the state (Lang and Bras, 2006; Weber, 2007), introducing additional barriers for minority ethnic individuals in French organizations (Ramboarison-Lalao et al., 2012). The hegemonic framing of the meaning of cultural diversity around assimilationary references to the integration of immigrants owes its legitimacy partly to the social regulation of the notion of citizenship. French republican values of freedom, equality and brotherhood are intended to transcend all other identities, setting the boundaries for the meaning of diversity and determining what can and cannot be discussed. The French Constitution in theory guarantees the equality of all citizens before the law, without distinction of gender and ethnicity; but such an approach overlooks existing fault lines involving ethnic origin and is thus counterproductive for promoting equality and diversity, because discussions of discrimination on the grounds of ethnicity are marginalized. Yet, disparities clearly exist between the native French citizens and the ethnic minorities in terms of job opportunities and political representation (Cediye and Foroni, 2007; Senik and Verdier, 2008). The taboos in fixing the meaning of diversity in France also have their roots in the history of the country. As Osler and Starkey (2005) explain, by taking a 'neutral' position towards minorities the state has failed to address unfair treatment and discrimination on the basis of ethnic origin. The taboo areas are also a reflection of the dominant patterns of political and social power: historically, policies have been made and implemented by politicians from the ethnic majority, who share the same elite educational background (Bach and Rocca, 2000). Instead of adopting a collective approach to compensate for discrimination against minorities, the state pursues the integration of minorities into a homogeneous republican model (Koff, 2009; Koopmans, 2010). As a result, an assimilationist integration approach shapes the meaning and interpretation of diversity and its management.
The case of Germany: Diversity as 'integracism'
Diversity management emerged as a topic of debate, both among management and in scholarly circles, in the late 1990s. The concept entered the research and management rhetoric as a human resource management notion (Vedder, 2006), with no base in human rights or anti-discrimination arguments. Interestingly, whilst the meaning of diversity management is shrunk as an HRM notion, it is at the same time stretched to include gender issues, which represent the dominant dimension in the framing of diversity management in Germany (Koall and Bruchhagen, 2002). Researchers who were originally engaged with women's studies now conduct the majority of diversity management
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research. When these scholars moved across to diversity research, the agenda of female emancipation was retained as the central foci of their work; while race-related issues, which were not traditionally considered, have been excluded. Thomas (1995) argues that in the USA, diversity management might provide an optimal way to include ethnic minority groups. In Germany, on the other hand, its meaning is shrunk to exclude problems of discrimination based on ethnicity (Köppel et al., 2007). However, more recently the government changed its discourse and started to promote diversity management as a tool for the better integration of ethnic minority workers. Consequently, terms such as 'valuing diversity' and diversity management have increasingly appeared in the debate (Böhmer, 2007), as the government attempts to bend the meaning of diversity management towards integration and immigration policies. However, governmental interventions predominantly concentrate on changing the discourse and by doing so fail to target the structural barriers. As a result, organizations still do not view managing ethnic diversity as important (Köppel et al., 2007). There is a general resistance to tackling race-related issues in Germany, as the heated political debates concerning the implementation of the two EU Equality Directives of 2000 clearly illustrate. Both directives are based upon Article 13 of the Amsterdam Treaty, providing the EU with a legal basis for action to combat discrimination on the grounds of racial or ethnic origin, religion or belief, disability, age or sexual orientation. Although trade unions and NGOs hoped that the EU legislation would contribute to the development of an anti-discrimination approach in Germany, their expectations were not met. Employers' associations and churches were particularly opposed to the new protections, and discussion of the implementation of the EU race directive lasted for nearly six years. This resistance delayed implementation by means of the Allgemeines Gleichbehandlungsgesetz (general equal treatment law) until the 2006 (Vassilopoulou and Merx, 2007). One reason for this resistance is that the process of fixing the meanings of diversity is trapped in history, the Nazi past and the more recent experience of economic immigration. Tajfel and Turner (1986) argue that individuals tend to externalize group-based guilt feelings because they may threaten their group identity and their self-image that is derived from group membership. Germany's Nazi past and the associated collective national guilt establish a hegemonic frame of reference in generating temporarily fixed meanings of diversity. National guilt, related to the crimes of the Holocaust, has deeply affected the collective memory; processing this guilt was at the heart of post-war democratization (Habermas, 1988) and plays a key role in many facets of contemporary German social and political life (Safran, 2000). This goes beyond the externalization of feelings of guilt, in a way that creates a silence around everything that could be a reminder of these negative feelings. Such is the case with current issues of race discrimination, externalized and silenced through efforts to transcend the collective guilt. As a result, race-related issues remain ignored and unchallenged. In effect, the meaning of diversity is fixed in such a way that race-related issues are excluded from the diversity management agenda and debate. Notions such as racism or race discrimination construct the key areas of taboos in the processes through which the meaning of diversity is bent, stretched, shrunk and consequently temporarily fixed (Van Dyk, 1995). One example is the absence of race-related issues in the diversity
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management approaches of German organizations, which in turn serves as a mechanism to exclude racial and ethnic differences from the frames of diversity. Köppel et al. (2007) found that the management of ethnic diversity in Germany lags behind in an international comparison; more than half of German companies do not view the management of ethnic diversity as pertinent. The treatment of minorities of Turkish ethnic origin, who are seen as the most problematic minority group in Germany, illustrates the contextual nature of the ways in which the meaning of ethnic and cultural diversity is bent in line with the hegemonic frames of reference. Contrary to the original North American framing of difference along the contours of including, embracing and valuing diverse backgrounds, Turkish minority individuals are portrayed through negative arguments. For instance, failure to employ workers of Turkish ethnicity is defended by arguments that this group is deficient across various job criteria, particularly regarding their alleged lack of proficiency in the German language. These negative representations of ethnic minorities support ethnocentric views and stereotypes, which are used to legitimize and normalize discrimination towards ethnic minorities in the German workplace. There is a shared belief that the policy on ethnic minorities needs to focus on 'helping' them to develop skills, rather than on tackling discrimination and including ethnic minorities in diversity policies in positive terms. Another reference point is the notion of integration. The concept of diversity is shrunk, bent and stretched to fit the policies and debates around immigration and integration. Post-war Germany has received a high number of economic immigrants, and has the third largest number of immigrants in the world (IOM, 2010). Despite this, for a long time Germany had difficulties in accepting its status as a country of immigration. This resistance was reflected in government policies, which aimed at excluding immigrants from the labour market when times were economically hard and regarded them as 'guest workers' (Gastarbeiter). According to the Chancellor, Angela Merkel, multiculturalism has 'absolutely failed' (Der Spiegel, 19 October 2010). This assessment is surprising since the government has never pursued a national agenda for multiculturalism: the aim has always been to assimilate ethnic minorities into the dominant culture (Esser, 2006). Alarmingly, a study in 2010 revealed a rise in decidedly anti-democratic and racist attitudes among native-born citizens: more than 30 percent of respondents believed that foreigners overran the country, and that when jobs are scarce foreigners should be sent back to their own countries (Decker et al., 2010). The notion of integration is the most dominant concept in the management of ethnic diversity in Germany. The socio-political context in the country generates a specific interpretation of integration with implicitly racist assumptions, which we term integracism. This racially biased and ethnocentric notion of integration frames the meanings of managing ethnic diversity in Germany. Integration polices and measures are deployed to 'aid the better integration' of ethnic minorities, who are widely seen as deficient and difficult to integrate, rather than adopting diversity management measures to foster equality, fairness and inclusion at work. In that frame, ethnic diversity is depicted as a source of potential problems (Berlin-Institut, 2009). Contrary to the North American approach to diversity management, which is based on the premise of valuing and utilizing difference, the German version of integration sets out to assimilate ethnic minorities into the dominant white organizational culture. Diversity
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management in Germany does not cater for such central aspects as race equality and antidiscrimination. Such issues are largely silenced in the political and public debate. Consequently, the current framing of ethnic diversity in employment, through a racially biased and ethnocentric notion of integration, undermines the need to manage ethnicdiversity in organizations.
Conclusions
This article has filled a gap in the literature by providing a cross-cultural comparison of the reinterpretation of diversity management in three different national settings. This is achieved by examining the historically and contextually embedded processes of the construction of the meaning of diversity management in the UK, France and Germany. Table 1 summarizes our findings. While the main emphasis in defining diversity management in the UK has been on voluntarism and multiculturalism, in France the traditional discourses of equality has been used to pursue an agenda of assimilation and integration. Different historical legacies and meanings afforded to equality and diversity mean that organizations have in the main regulated diversity in order to encourage sameness rather than to celebrate difference among their workers. In Germany, diversity management is advocated as a voluntary strategy, which is almost explicitly liberated from the notion of ethnicity, allowing other forms of difference to be accommodated in workplaces. What appears at first sight to be common across Britain, France and Germany is the very national nature of the interpretation of diversity, despite the uniting character of the supranational regulation emanating from the EU. This dependence on the national context serves to accentuate the blind spots in these three countries, which we identify as the ineffectual nature of business-case based voluntarism and the omission of social class inequality in the case of the UK; an emphasis on sameness and assimilation that renders difference a threat in workplaces in France; and partial consideration of diversity at the expense of its ethnic dimensions in Germany. Furthermore, there is a recent political and public consensus in Germany that not only multiculturalism, but also the integration of ethnic minorities, has failed. And like Merkel, the former French President Nicolas Sarkozy rejected multiculturalism as a failure (Le Monde, 25 February 2011), while British Prime Minister David Cameron denounced 'state multiculturalism' (The Guardian, 5 February 2011). Extreme right-wing electoral success across Europe may be partly responsible for the growing lack of commitment to promoting equality and diversity in all three countries. Recent developments suggest that diversity management is likely to be shrunk to integration and assimilation, with a focus on putting the burden solely on individuals from minority ethnic groups to seek conformity to a monolithic conception of national identity, the existence of which is highly debatable. Social regulation in the UK, France and Germany has so far followed a path-dependent trajectory in which the meaning of diversity management has been bent, stretched, shrunk and fixed in order to fit with the national traditions and requirements of social and economic activity. However, this nationally focused understanding of context has been limiting in many ways, as it is imbued with silences, taboos and omissions. In order for social regulation to be effective, there is a need for social policy to transcend rather than
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Table 1. The construction of the meaning of diversity management in the UK, France and Germany Temporarily fixed meaning of diversity management UK Fixed as a policy approach to address the multicultural society. Bent away from a morally driven equal opportunities agenda towards a pro-business one. Stretched to include multiple forms of difference. Shrunk to instrumental logic and bottom-line concerns Fixed around values of liberty, equality and fraternity. Bent to the values of French Republicanism. Shrunk to issues of assimilation of ethnic minorities. Stretched to include issues related to culture and gender. Fixed around an assimilative notion of integration. Bent to address immigration concerns. Shrunk to gender equality and integration of immigrant/ethnic minorities. Stretched to respond to business needs. Frame of reference Multiculturalism and voluntarism based on the business case Taboos Social class inequality. Positive discrimination and quotas
France
Secularism, equality and integration
Discrimination based on race/ethnicity and religion
Germany
Gender equality and the business case
Racism and discrimination based on race/ethnicity
simply to adopt national context as its key consideration. Despite earlier warnings that diversity management may be resisted in its journey to other national contexts, we demonstrate that the resistance took a subtle form of liberal subversion, when diversity management entered the lexicon of British, French and German social regulation, where its meaning is localized. Diversity management has therefore not fully replaced other social regulation concepts, such as equal opportunities, multiculturalism, integration and assimilation, but neither is it fully rejected as a new approach. Instead, diversity management both contaminates and is contaminated by the local vernacular of managing differences in social and employment settings. This article has explored the social regulation of diversity management, drawing on an extensive review of key literatures. However, our findings could be extended to frame a comparative empirical study in the future. Such field research into the mechanisms of fixing, bending, stretching and shrinking of the notion of diversity management may collect data in the form of policy documents and statistical evidence, and use a variety of methods, such as interviews, surveys, observation and ethnography. In this article, we offer a bird's-eye view of the temporarily fixed social regulation and dominant frames of diversity management by exploring the processes of bending, stretching
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and shrinking of the meanings conferred on diversity and its management. However, these processes through which diversity management is defined are also processes of struggle for legitimacy, power and domination between various interest groups. We have explored the role of multiple stakeholders in negotiating the meaning of diversity, but only in a limited way, as our main focus has been to understand the general and hegemonic trends of the regulation of diversity management cross-nationally. Nevertheless, trade unions, statutory equality bodies, social movement actors and minority advocacy groups in the UK were instrumental in stretching the meaning of diversity in order to foster a comprehensive fairness agenda. Similarly, in France, progressive institutions such as the Montaigne Institute played a key role in stretching the meanings of diversity to more inclusive intersectional issues. Future research may examine in-depth the role and influence of, and the conflicts of interest between, different institutional actors in relation to the processes that shape the fixed meanings of diversity management. It would be interesting to investigate further the unspoken motives and stakes of institutional actors in attempting to define and frame diversity management in particular ways. There is clearly more research needed in order to break through the wall of silence around the taboo areas. Further research could focus on the strategies, experiences and agency of the groups that are sidelined, made invisible and disadvantaged because of the blind spots in the hegemonic frames. Moreover, equalityand diversity research needs to overcome its own taboos by examining the intended and unintended opportunity structures generated through particular ways of fixing, bending, stretching and shrinking the notion of managing diversity. Our analysis has relevance for diversity policy and practice. A key implication is that direct transposition of diversity management ideas is not feasible, as would be the case with direct transposition of diversity management policies. Drawing on our conclusions, we argue that social policy should capture the local meanings and path dependencies concerning the concept of diversity with a view to transcend them. For instance, the management of diversity in France and Germany requires the reframing of ethnic minorities' contribution to the labour market in positive and supportive ways. This article has shown how the traditional approach of not fully accepting and valuing ethnic minority workers in these two countries has been counterproductive. Institutional support is increasingly needed in a context where immigrants are expected to fill job vacancies in developed countries. On the other hand, omission of social class-based disadvantage is a significant barrier in promoting justice and inclusion in UK organizations. Concrete steps in regulating diversity management through the formulation and implementation of strong antidiscrimination legislation and diversity codes of practices that address marginalization of all disadvantaged groups are essential to promote diversity and equality in organizations and the labour market. There is a particular necessity to extend equality and diversity regulation to the currently overlooked ethnic and racial minorities in the case of France and Germany, and to address social class inequality in the UK. Finally, as we have demonstrated, with examples, frames of diversity management are historically embedded. However, times do change with changes in the political and hegemonic order. Therefore, social regulation and policy efforts on diversity management should capture dynamism and change in this field.
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This research received no specific grant from any funding agency in the public, commercial or not-for-profit sectors.
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Author biographies Ahu Tatli is a senior lecturer in the School of Business and Management at Queen Mary University of London. JoanaVassilopoulou researches and lectures at Brunel Business School, Brunel University, London. Akram Al Ariss is a professor at the Toulouse Business School, Université de Toulouse. Mustafa Özbilgin is Professor of Organizational Behaviour at Brunel Business School, Brunel University, London and the co-chair of Management et Diversité, Université Paris-Dauphine, France.
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