This chapter compares workplace equality legislation regarding marginalized groups, such as women, persons with disabilities, LGBTQ identity and racial/ethnic populations in Brazil, South Africa and the USA. It also contrasts these policies against each nation’s historical, social, political and legal contexts, and outlines future directions. These three countries share similar historical experiences in the positioning of power differentials between ruling classes, indigenous groups and those subjugated to legacies of inequality. In Brazil and the US the legacy of slavery endures, and in South Africa the vestiges of apartheid remains. All three countries still battle the influences of these measures on equity, diversity and inclusion of racial/ethnic and gender groups, and continue to struggle with the outcomes of everyday experiences of equality. Legislation aimed at anti-discrimination, promoting gender equality, disability and racial ethnic diversity varies between the countries, but is in existence. The concept of affirmative action is employed in each country in varying forms. Brazil imposes specific quotas for the employment of the disabled and women in certain areas. South Africa also has established quotas in the employment and training of designated groups – blacks, coloreds, Indians, women and the disabled – and in ownership, shareholding. Conversely, in the USA, affirmative action is used as a mechanism for achieving equality for racial/ethnic minorities, women and persons with disabilities, and quota systems are considered unconstitutional.
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Lize A.E. Booysen, Gwendolyn Combs and Waheeda Lillevik
Lourdes Susaeta, Paula Apascaritei, Esperanza Suárez Ruz, Isis Gutiérrez-Martínez, Sandra Idrovo Carlier and José Ramón Pin Arboledas
In this chapter, we analyze the relationship between the phenomenon of adultism, as one possible factor in youth discrimination, and its effect on youth unemployment. Our review is a cross-country comparative study of Mexico, Colombia and Spain. This chapter provides explanations and analyzes differences in youth unemployment in terms of educational attainment and experience, as well as country-level economic conditions. Firms and policy makers will face the challenge of optimally managing the diverse population predicted to be active in the labor market in future years and the related challenge of avoiding ageism in the workforce.
Isabel Metz, Eddy S. Ng, Nelarine Cornelius, Jenny M. Hoobler and Stella Nkomo
This chapter assesses the adoption and implementation of multiculturalism across Australia, Canada, the UK, the US and South Africa (the “Anglo bloc”), all of which receive a large number of immigrants. Australia and Canada espouse an official multiculturalism policy, and encourage their citizens and immigrants to adopt each other’s culture. The US does not have an official multiculturalism policy and follows an assimilation approach (“melting pot”) to immigration acculturation, but implements affirmative action to support racial minorities in education and employment. The UK and South Africa also do not have an official multiculturalism policy. They fall somewhere between Australia/Canada and the US on the immigrant acculturation continuum. The UK is heavily influenced by EU directives, and has strong anti-discrimination laws to compensate for a lack of multiculturalism policy. South Africa is a special case, where blacks are indigenous rather than immigrants. It has strong affirmative action policies, but they do not apply to those who attain citizenship after 1984. The emphasis is on the economic empowerment of previously disadvantaged groups. The chapter also updates the 2010 Multiculturalism Policy Index (MPI) with data from South Africa.
Terry A. Nelson, Kori Callison and Allison Freswick
The insufficient representation of women on boards continues to be a much-discussed topic globally. Many countries are taking note of this deficiency and are implementing laws and corporate governance to increase women’s presence on boards. Norway was the first country to champion this cause, and put legislation in place in 2003 to politically pressure companies to achieve 40 percent gender equality in boardrooms. Other countries have followed suit, utilizing an array of approaches to achieve diversity objectives. Research suggests that obtaining a critical mass of females (three or more) on corporate boards may have beneficial outcomes, such as encouraging strategy that focuses on organizational practices and policies. These policies may include human resource policies that support working women and mothers. We take a comparative look at whether a mandate of boardroom gender equality in five European countries (France, the Netherlands, Denmark, Belgium, and Italy) suggests a link between critical mass and decision-making as it relates to HRM policies. Although the potential of critical mass to help employees with work–life concerns seems promising, the possible limitations and ramifications of obtaining a critical mass of women are also discussed.
Lize A.E. Booysen and Heather Wishik
This chapter compares lesbian, gay, bisexual, transgender and queer (LGBTQ) rights, politics and workplace inclusion in South Africa (SA) and the USA. We explore the histories, backgrounds and legal landscapes of LGBTQ rights, and highlight relevant trends and current issues pertaining to LGBTQ issues in the two countries. We utilize Reynaud’s theory of social regulation (1979) to analyze social regulation involved in LGBTQ equal opportunities and inclusion, in historical, current coalitions and political debates in the two countries. We conclude that SA has a higher level of national control regulation than the USA, with more laws of national scope in place creating a broad pattern of progressive legislation towards LGBTQ equality. Regarding the autonomous societal rules activated spontaneously by actors, we conclude that the USA has taken the lead over SA in the relatively widespread acceptance of LGBTQ people in American society and in broad voluntary employer action. We found there is no straight line of progress in advancing LGBTQ rights, in either the USA or SA. We recommend that SA should build stronger cooperative ties beyond Africa to increase gay and lesbian social acceptance and to prevent anti-gay and lesbian violence. In the USA more formal regulation at the federal level is needed, where federal law addresses full LGBTQ rights and where federal court decisions affirm rights to constitutional equal protection in all arenas of life.
Sabine Bacouël-Jentjens and Liza Castro Christiansen
Adopting a two-level framework of diversity management analysis, we show how the concept of diversity management and its corresponding policies and practices differ in diverse country-specific environments, namely Denmark and France. We refer in this exploratory study in a Danish and a French company to two interrelated levels: macro-social and meso-organizational. By examining the field of diversity management as a multilayered phenomenon, we offer empirical insights into how distinct diversity discourses can develop in different national settings, and in which ways macro-level discourses may influence meso-level perceptions of diversity and practices of diversity management. We show that diversity discourses from the macro level help explain whether companies adopt a rights-based approach of equal opportunities to diversity management aimed at reducing discrimination and group-based disadvantages or a mainstream approach with emphasis on the “business case,” focusing on performance-related outcomes of diversity.
Alain Klarsfeld, Eddy S. Ng, Lize A.E. Booysen, Liza Castro Christiansen and Bård Kuvaas
Tarani Merriweather Woodson and Ariane Ollier-Malaterre
The US and France share common democratic values and ideals for diversity, yet differ greatly in the ways in which they frame diversity, which makes for an interesting comparison to outline the interactions between the framing of diversity at the country level, the operational paradigms to manage diversity, and intersectionality research. Our objectives are to enrich intersectionality research by calling attention to its embeddedness within specific historical, legal, and political contexts, and to foster a critical examination of diversity management paradigms in both countries. As intersectionality research is still very much embedded in the American context, it is important to first examine its origins and then explore how it can be applied to the French context. Thus while the US has come to acknowledge the reality of intersectionality with regard to race and gender, France is still grappling with the notions of race and ethnicity, let alone their application to an accepted gender dichotomy. Although the context and policies differ, the practice of exclusion based on ethnicity and gender is still sustained in both countries. By applying intersectionality to a comparative study between nations, we are not assuming one context or approach as more advanced than the other; rather, we highlight the need for exchange among the different approaches. We hope that situating diversity management paradigms and intersectionality research in their national contexts can bring forth a fresh perspective on how to address and research diversity in both countries.
Katherine Ravenswood, Stéphane Le Queux, Erica French, Glenda Strachan and John Burgess
This chapter examines the approaches to diversity management in the South Pacific, specifically New Zealand, Australia and two French Pacific Territories – Polynesia and New Caledonia. The focus of the analysis is on gender and racial equality. The chapter will examine the legislative requirements promoting diversity and equality; organizational programs to promote diversity and equality; and the equity and diversity challenges confronting each of the countries/territories. In terms of equity and diversity there are three common features across the region. All have indigenous populations with unique cultures and histories that have in general been marginalized in terms of access to jobs and wealth. All have a colonial legacy as European settlement was imposed across the region in the 18th and 19th centuries and, to different degrees, indigenous communities and lifestyles have been irrevocably altered. Finally, immigration from Europe, and more recently from Asia, has been an ongoing feature of the region. Diversity management and equal employment opportunities (EEO) issues are important across the region with major inequalities by gender, race, age and ethnicity in terms of employment access and labour market outcomes.