(Sirkku Hellsten, Anne Maria Holli, Krassimira Das (BookFi)

Women’s Citizenship and
Political Rights
Edited by
Sirkku K. Hellsten, Anne Maria Holli and
Krassimira Daskalova
Women’s Citizenship and Political Rights
Women’s Rights in Europe Series
Series Editors: Christien L. van den Anker, Audrey Guichon, Sirkku K. Hellsten
and Heather Widdows
Titles include:
Sirkku K. Hellsten, Anne Maria Holli and Krassimira Daskalova (editors)

WOMEN’S CITIZENSHIP AND POLITICAL RIGHTS
Heather Widdows, Itziar Alkorta Idiakez and Aitziber Emaldi Cirión (editors)
WOMEN’S REPRODUCTIVE RIGHTS
Forthcoming titles:
Christien L. van den Anker and Jeroen Doomernik (editors)

TRAFFICKING AND WOMEN’S RIGHTS
Audrey Guichon, Christien L. van den Anker and Irina Novikova (editors)
WOMEN’S SOCIAL RIGHTS AND ENTITLEMENTS
Women’s Rights in Europe Series

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Women’s Citizenship and
Political Rights
Edited by
Sirkku K. Hellsten
Centre for Global Ethics,
University of Birmingham, UK
Anne Maria Holli

Department of Political Science,
University of Helsinki, Finland
and
Faculty of Philosophy and Social Sciences
Sofia University, Bulgaria
Contents
List of Tables vii
Foreword viii
Yakın Ertürk
Acknowledgements x
Notes on the Contributors xii
List of Abbreviations xv
Introduction 1
Sirkku K. Hellsten, Anne Maria Holli and Krassimira Daskalova
Part I Theoretical Feminist Perspectives 13

1. Dilemmas of Political Participation 15
Shirin M. Rai
2. European Citizenship: A Political Opportunity for Women? 37

Ute Gerhard
3. Can Feminism Survive Capitalism? Challenges Feminist

Discourses Face in Promoting Women’s Rights in
Post-Soviet Europe 53
Sirkku K. Hellsten
4. Citizenship, Civil Society and Gender Mainstreaming:

Complexities of Political Transformation in Central and
Eastern Europe 67
Barbara Einhorn
5. ‘Gender Equality’: On Travel Metaphors and Duties to Yield 86

Hege Skjeie
Part II Applying New Insights to Old Problems 105

6. Education and European Women’s Citizenship:
Images of Women in Bulgarian History Textbooks 107
v
vi Contents
7. Strong Together? A Comparative Study of the Impact of

the Women’s Movement on Policy-Making in Finland 127
Anne Maria Holli
8. Transnational and National Gender Equality Politics:
The European Union’s Impact on Domestic Violence
Debates in Britain and Finland 154
Johanna Kantola
9. Implementing Gender Equality: Gender Mainstreaming

or the Gap between Theory and Practice 179
Petra Meier
10. Good Governance and Good for Business Too?

Equality and Diversity in Britain 199
Judith Squires
Index 217
List of Tables
7.1 Typology for movement impact/state response 129

7.2 Typology for women’s policy agency activities 130
7.3 Country comparison by dual response/no
response impact across policy sectors 134
7.4 Summary of the results for Finland by date of
end of decision 140
7.5 Variables explaining the impact of the women’s
movement in Finland 142
8.1 Differences in refuge ideologies according to
Teuvo Peltoniemi 159
8.2 Proximity of domestic violence to which
women are victims (1) 169
8.3 Proximity of domestic violence to which
women are victims (2) 169
8.4 How widespread is domestic violence
against women? 170
vii
Foreword
This series is a timely initiative to counter the mounting opposition and

challenge to the progress made thus far in transforming mainstream
human rights discourse from a feminist perspective. Expansion of the
concept of human rights to address violations experienced by women
due specifically to their sex has considerably altered international and
domestic law and demystified the public/private distinction that justified
women’s subordination.
The Convention on the Elimination of All Forms of Discrimination
against Women, adopted in 1979 by the United Nations General Assembly,
was an important step in the recognition of the universality of human
rights, a view that became officially endorsed at the Vienna World
Conference on Human Rights in 1993. Also referred to as the International
Bill of Rights of Women, the Convention has been ratified by 180 member
states. Yet, after over quarter of a century since the adoption of the
Convention and the numerous human rights instruments that followed,
what remains universal is the gross violation of women’s rights worldwide.
Notwithstanding the notable progress achieved in the advancement
of women in the past decades, women in all parts of the world still face
obstacles in accessing rights, such as the rights to education, health, polit-
ical participation, property and to decide over matters related to their sexu-
ality, reproduction, marriage, divorce and child custody, among others.
Women’s bodies are the zones of wars and the sites of politics and policies
as revealed in the armed conflicts around the world, transgressions over
their reproductive and sexual rights, trafficking, dress codes as well as
immigration and refugee policies, etc. Even in countries where traditional
patriarchy is transformed, as in the European experience, gender-based
discrimination and violence against women continue to persist in modi-
fied, subtle and discrete forms.
In many of the countries in the European region, where human rights
standards and institutions are in place, women’s formal political partici-
pation is still extremely low, reproductive rights are an area of continu-
ous contestation and struggle, social entitlements are at risk and single
mothers and minority and immigrant women are at the greatest risk of
poverty. We need to learn more and understand how gender hierarchies
are reproduced under diverse conditions and in different places. The
books in this series promise to do that. They illustrate the need for
viii
Foreword ix
increased attention from researchers, NGOs and policy-makers through-

out Europe for these instances of violations of women’s rights.
This series comes at a time when the EU process of enlargement has
shown that respect for women’s rights within different regions in Europe
is diverse. It is fascinating to see that specific rights for women are pro-
tected better in some countries than others while it may also be the case
that in the same region other rights for women are less well observed. By
illustrating these trends and inconsistencies, this series allows for com-
parison across the region as well as for reflection on the policy gaps across
Europe.
The four books cover the areas of trafficking, political participation,
social entitlements and reproductive rights in detail, from a multidiscip-
linary perspective and with contributions from activists, professionals,
academics and policy-makers. State-of-the-art debates are reflected upon
and burning issues in women’s rights are brought together in one series
for the first time. The depth of the arguments, coverage of recent devel-
opments and clear focus on their implications for gender equality are
most commendable aspects of the series. The books push forward the
agenda for all of us and remind us that women’s rights are not protected
equally and intrinsically. In fact, the contributions confirm that we still
have a way to go to achieve women’s equality in contemporary Europe.
This unique and compelling collection is a must for everyone striving
for rights, equality and justice!
Yakın Ertürk
Human Rights Commission
Special Rapporteur on
Violence against Women, its
Causes and Consequences
Acknowledgements
This series is the result of the involvement of a large number of people

in the work of the Network for European Women’s Rights (NEWR). We
would like to thank them all for their input, although we cannot name
them all here.
We want to thank especially those who spent time and energy dis-
cussing the four themes of NEWR during a series of intensive and engaging
workshops across Europe and in the final conference in Birmingham.
We would also like to thank Professor Donna Dickenson for initiating
the project and leading it for two years, and Christien van den Anker for
taking over this leadership for the final year of the project, as well as all
the other project partners, Itziar Alkorta Idiakez, Francesca Bettio, Jeroen
Doomernik, Aitziber Emaldi Cirión, Maria Katsiyianni-Papakonstantinou,
Lukas H. Meyer and Irina Novikova, for their contributions.
We could not have done the project without the commitment and per-
sistence of Audrey Guichon and the consistent support of Jose Vicente.
We thank Rebecca Shah for taking over from Audrey in the final months
of the NEWR project and for her thorough editing work of all four
volumes in this series.
We thank the European Commission for funding the NEWR project
under its 5th Framework Programme.
We hope that this series of books will contribute positively to the debate
on women’s rights and to improving the lives of all women in Europe.
With regard to this book, Women’s Political Rights and Citizenship, we
would like to thank those activists and researchers from various parts of
Europe who participated in the workshops on this topic and shared their
thoughts about current problems, future challenges and suggestions for
remedies with us. Unfortunately, the participants are too numerous to
name but it is they who made this whole project possible. In particular
we are grateful to the many activists and NGO representatives who gave
up their valuable time to enlighten academics about the burning issues
in women’s political rights, political participation and citizenship across
Europe. These on-the-ground perspectives were invaluable in determining
the content and issues, which this book addresses.
We are also most grateful to the institutions that hosted these work-
shops, the University of Birmingham, the University of Helsinki and the
University of Sofia.
x
Acknowledgements xi
Last but not least, we want to thank Milja Saari for her work in getting
this book finished by helping us in checking references and bibliographies.
Sirkku K. Hellsten
Anne Maria Holli
Notes on the Contributors
Krassimira Daskalova teaches Modern European Cultural History at the

Faculty of Philosophy and Social Sciences, St Kliment Ohridski University
of Sofia, Bulgaria. Her research interests include the comparative history of
Balkan/East European women’s movements; women, gender and the East
European transition; the history of (women’s) authorship in modern
south-eastern Europe; the history of literacy and reading; the history of
women’s education; and the history of the East European intelligentsia in
the nineteenth and twentieth centuries; oral history. She is the author of
two books on Bulgarian cultural history and has edited and co-edited
several volumes; she has also published many articles and book chapters
on women’s/gender history and the history of the book and reading.
Barbara Einhorn is Reader in Gender Studies and Director of Graduate

Studies in the School of Social Sciences and Cultural Studies at the
University of Sussex. She is Associate Editor of the European Journal of
Women’s Studies and a member of the editorial board of the International
Feminist Journal of Politics. She has acted as gender consultant to The
United Nations women’s programme (UNIFEM), the International Labour
Organisation (ILO) and the World Bank. Her research interests include
citizenship, civil society and gender politics in the transformation process
in Central and Eastern Europe; identity, ‘home’ and belonging for (multiple)
migrants; and nation, gender and transformation. She is the author of
Citizenship in a Uniting Europe: Nation, Gender and Transformation, Palgrave,
forthcoming and Cinderella Goes to Market: Citizenship, Gender and Women’s
Movements in East Central Europe, Verso, 1993.
Ute Gerhard is Emeritus Professor of Sociology and Director of the

Cornelia Goethe Centre for Women’s and Gender Studies at the
University of Frankfurt/Main. She works in the fields of law, sociology
and history. Her research includes women’s rights, social policy in a
European comparison, the history of women, the women’s movement
and feminist theory. Among her recent publications are ‘Engendered
Citizenship: A Model for European Citizenship? Considerations against
the German Background’, in J. Andersen and B. Siim (eds) The Politics of
Inclusion and Empowerment. Gender, Class and Citizenship, Palgrave, 2004;
and Debating Women’s Equality. Toward a Feminist Theory of Law from a
European Perspective, Rutgers University Press, 2001.
xii
Notes on the Contributors xiii
Sirkku K. Hellsten is Reader in Development Ethics and the Director of

the Centre for the Study of Global Ethics, University of Birmingham. She
is the Coordinator for the political participation theme in the NEWR pro-
ject. Her main fields of interests are in political philosophy, with a focus on
social justice, and in applied ethics, with particular emphasis on develop-
ment ethics and bioethics. Dr Hellsten has undertaken numerous research
projects in these fields in Finland, the USA, New Zealand, Tanzania and in
the UK, and has published widely on related topics.
Anne Maria Holli is Researcher (Academy of Finland) at the Department

of Political Science, University of Helsinki. Her major areas of research are
in the fields of public equality policies, gender and politics. Her most
recent publications include Discourse and Politics for Gender Equality in Late
Twentieth-Century Finland, Helsinki University Press, 2003 and chapters
on Finland in the following RNGS books: A. Mazur (ed.) State Feminism,
Women’s Movements and Job Training: Making Democracies Work in the Global
Economy, Routledge, 2001; J. Outshoorn (ed.) The Politics of Prostitution.
Women’s Movements, Democratic States and the Globalisation of Sex Commerce,
Cambridge University Press, 2004; J. Lovenduski et al. (eds) Feminism and
Political Representation of Women in Europe and North America, Cambridge
University Press, 2005; and M. Haussman and B. Sauer (eds) Reconfigured
States and Opportunities: Comparative Women’s Movement Strategies since the
1990s, Rowman & Littlefield, 2005.
Johanna Kantola obtained her PhD from the University of Bristol, where
she is currently working as a post-doctoral researcher. She has published
articles on gender and the state in the International Feminist Journal of
Politics, European Journal of Women’s Studies and European Political Science
and has contributed chapters to various edited volumes. She is also affili-
ated to the Political Science Department at the University of Helsinki,
where she published a monograph, The Mute, the Deaf and the Lost: Gender
Equality at the University of Helsinki Political Science Department, University
of Helsinki Press, 2005. She is the co-editor of the Finnish Women’s Studies
Journal.
Petra Meier is research fellow at the Politics Department of the Vrije

Universiteit Brussel and the Radboud Universiteit Nijmegen. Her major
areas of research are feminist theories on representation, the conceptual-
isation of measures to promote social groups in decision-making and their
interaction with electoral systems, feminist approaches to public policies,
the political opportunity structures of the Belgian women’s movement
and state feminism. She edited Genre et science politique en Belgique et en
xiv Notes on the Contributors
Francophonie, with Bérengère Marques-Pereira, Academia-Bruylant, 2005;

and Vrouwen vertegenwoordigd, Wetstraat gekraakt? Representativiteit feminis-
tisch bekeken, with Karen Celis, VUBpress, 2004. She has published in Party
Politics, European Political Science, Acta Politica, Res Publica, Tijdschrift voor
Sociologie, Ethiek en Maatschappij and in edited volumes.
Shirin M. Rai is Professor of Politics and International Studies at the

University of Warwick. Her research interests are in the area of feminist
politics, democratisation, globalisation and development studies. She has
written extensively on issues of gender, governance and democratisation.
Author of several books, the most recent being Gender and the Political
Economy of Development, Polity Press, 2002. She has also co-edited Rethinking
Empowerment: Gender and Development in a Global/Local World, Routledge,
2002, and edited Mainstreaming Gender, Democratizing the State? published
for and on behalf of the United Nations by Manchester University Press,
2003, and the Special Issue of the International Feminist Journal of Politics
on Gender Governance and Globalization, 6(4) 2004.
Hege Skjeie is Associate Professor at the Department of Political Science,

University of Oslo. Her research interests include human rights, religion
and equality, equality policies, gender politics and party leadership. She
is currently involved in projects on Democracy, Religious Freedom and
the Human Rights of Women (2004–2008), Gender Equality, Cultural
Diversity: European Comparisons and Lessons (2005–2006), and Nordic
Gender Equality Discourses (2005–2006). Recent publications in English
include: ‘Equality Law and Religious Gender Discrimination: Norwegian
Examples’, in S. Cabbibio and K. Børresen (eds) The Impact of Cultural and
Religious Gender Models in the European Formation of Socio-Political Human
Rights (forthcoming 2005) and, with Anette Borchorst, ‘Changing
Patterns of Gender and Power in Society’, NIKK Magasin, 3 (2003).
Judith Squires is Professor of Political Theory at the University of Bristol.

She is currently working on the changing nature of equality discourses,
focusing on gender quotas, gender mainstreaming and diversity manage-
ment strategies. Her recent publications include: Ethnicity, Nationalism
and Minority Rights (co-editor with Tariq Modood and Steven May),
Cambridge University Press, 2004; Women in Parliament: A Comparative
Analysis, (co-authored with Mark Wickham-Jones), Equal Opportunities
Commission, 2001; and Gender in Political Theory, Polity Press, 1999.
List of Abbreviations
ACAS Advisory, Conciliation and Arbitration Service

ACE Accelerated Christian Learning
CEDAW Convention on the Elimination of all Forms of
Discrimination Against Women
CEHR Commission for Equality and Human Rights
CRE Commission for Racial Equality
CSGE Centre for the Study of Global Ethics
DFID UK Department for International Development
DRC Disability Rights Commission
DTI Department of Trade and Industry
EC European Community
ECJ European Court of Justice
EEC European Economic Community
EOC Equal Opportunities Commission
EPZ Export Processing Zone
EU European Union
EWL European Women’s Lobby
ICERD Convention on the Elimination of All Forms of
Racial Discrimination
IMF International Monetary Fund
JHP Southeast European Joint Project (an initiative of the Centre
for Democracy and Reconciliation in Southeastern Europe)
MEP Member of the European Parliament
MP Member of Parliament
NEWR Network of European Women’s Rights
NGO Non-Governmental Organisation
NYTKIS Coalition of Finnish Women’s Associations for Joint Action
PAET Policy Appraisal for Equal Treatment
RNGS Research Network on Gender, Politics and the State
SEWA Self-Employed Women’s Association
UK United Kingdom
UN United Nations
UNIFEM United Nations Development Fund for Women
WAVE Women Against Violence Europe
WEDO Women’s Environment and Development Organisation
WEU Women and Equality Unit
xv
xvi List of Abbreviations
WHO World Health Organisation

WID Women in Development
WIEGO Women in Informal Employment: Globalising and
Organising
WPA Women’s Policy Agency
WU Women’s Unit
Introduction
Sirkku K. Hellsten, Anne Maria Holli and Krassimira Daskalova
This book is part of a four-volume series based on the findings of a

three-year project, the Network for European Women’s Rights (NEWR),
funded by the European Commission 5th Framework. The objective of
NEWR was to study women’s rights in Europe across four sub-themes:
trafficking; reproductive rights; political participation; and social entitle-
ments. NEWR has set up a thematic network on the topic of women’s
rights as human rights by bringing together expertise and encouraging
dialogue across disciplines and among the countries of Eastern and
Western Europe. Launched in October 2002, it is a continuous source of
information and a platform capable of influencing the policy-making
process, especially in Europe. The project is led by the Centre for the
Study of Global Ethics (CSGE), University of Birmingham, together with
nine partners across Europe: the University of Siena, the University of
Amsterdam, the University of Bremen, the University of Deusto, the
University of the Basque Country, the University of Helsinki, the
University of Sofia, Panteion University and the University of Latvia.
This volume on Women’s Rights in Europe focuses on the NEWR
theme of political participation and citizenship. Its purpose is to dis-
seminate the NEWR findings and to convey a sense of the challenges
and opportunities for gender justice and active citizenship in integrating
Europe. It is based on the identification of the burning issues of women’s
political participation and citizenship that were raised during the project
networking and research. The issues were identified as:
1. Equality discourses and the importance of a normative debate.

2. Globalisation and state transformation.
3. Forces of resistance.
4. The impact of different waves of EU accession talks.
1
2 Sirkku K. Hellsten, Anne Maria Holli and Krassimira Daskalova
5. Accountability and implementation strategies.

6. Alliances with other equal opportunity, so-called vulnerable groups.
7. The impact of changes in the representation of women on the polit-
ical/policy agenda.
8. The generation gap in the feminist movement in the 1990s.
9. Access to resources; economic and power structures.
The chapters that follow deal with and bring together these issues, dis-
cussing them from both theoretical and empirical points of view.
The theme of this book, women’s political participation and citizen-
ship in Europe, is extremely broad and multi-layered, particularly in a
time of political and economic transition in Eastern Europe and the
related expansion of the European Union (EU). Before we can evaluate
which strategies work best in promoting women’s equal political partici-
pation and full citizenship we need to analyse the concepts of citizen-
ship, political participation, feminist discourses and gender equality.
Thus, discussion of women’s political participation and citizenship calls
for both theoretical and empirical political analysis of concepts such as
equality, gender, citizenship, democracy, discrimination, feminism and
many others, as well as of political and social institutions and attempts
to reform them. Understanding the current status of women’s political
participation and citizenship in Europe also requires that we pay atten-
tion to the role and position of the multiplicity of actors relevant to the
field, such as supranational and governmental bodies, political parties,
non-governmental organisations, civil society and other formal organ-
isations, such as administration, education and women’s movements, as
well as informal networks.
The enlargement of the EU has allowed activists and academics to con-
front some of the ‘false rhetoric’ of gender equality that prevailed under
socialist regimes, to compare women’s position under different political
and economic orders, and to reconsider the burning issues related to
attempts to achieve gender equality across Europe. The comparative stud-
ies and increasing collaboration between the formerly socialist Eastern
and Central European countries and Western Europe has created the
opportunity to bring into discussion and under new evaluation various
national gender equality machineries, on the one hand; and on the other,
it has brought the disparities in gender policies back onto the agenda of
political debates in various parts of Europe as well as within the political
organs of the EU.
Strategies for improving women’s position are various and differ
between European countries. Gender mainstreaming is a central pillar of
Introduction 3
European policies on gender equality; quotas are the subject of highly

contested debates, often linked to their misuse throughout history; and
the recourse to adopting positive action measures is not provided for –
let alone in use – in many countries across Europe. The variety of means
available for achieving gender-equal political participation reflects how
far we are from full equality between women and men in politics.
Part I of this volume focuses on the theoretical framework related to
political participation and women’s rights as human rights. Feminist
theorists have argued for the gendered nature of citizenship. This is also
the standpoint supported by Shirin M. Rai in Chapter 1, ‘Dilemmas of
Political Participation’. Rai shows that feminist theorising on citizenship
has been looking for ways to overcome the shortcomings of the concept
by reconceptualising citizenship from a more encompassing perspec-
tive, developing ideas on how to include gender in democratic theoris-
ing or how to develop new theories of democracy with a feminist face.
In order to find a solution more comprehensive understandings of citi-
zenship are required, notably social citizenship and ideas of deliberative
democracy. Rai notes that European politics is increasingly reflective of
the dilemmas and challenges of the politics of citizenship. On the one
hand, there are ongoing debates about the relationship between the
nation-state (the traditional site conferring citizenship) and the regional
and supranational institutions of the EU. There are concerns about iden-
tities and accountabilities, borders and regulations. On the other hand,
there is an acknowledgement of the expanded sense of Europe and
expanded citizenship thereafter, and how this links to the wider world.
Rai discusses how participation has been a language of both inclusion
and exclusion; of a vibrant civil society as well as a dysfunctional pol-
itics. She reflects on the complexity of the issues of citizenship and polit-
ical participation, particularly with regard to the differences among
women, engagements with institutions of power and the experience of
participation they have. Her conclusion is that political participation is
an important measure of the confidence that women have in the devel-
opment of states and polities, but it is not quantifiable without taking
into account the changing context of our global society.
In Chapter 2 Ute Gerhard expands the theme of citizenship by study-
ing ‘European Citizenship: A Political Opportunity for Women?’ She
presents historical models of citizenship across Europe and shows how
the inclusion and exclusion introduced by Rai have actually worked in
European political history. Gerhard notes that the forces of ‘globalisa-
tion’ in their various forms (e.g. immigration, trafficking in women,
transnational corporations, neoliberal reconfiguration of welfare states)
not only challenge the boundaries between the national and the trans-
national, the local and the global, the economy and politics, but also
point in a variety of ways to theoretical and practical problems, gen-
dered and ethnicised injustice among them, embedded in our under-
standings and practical application of ‘citizenship’ as a right and an
enabling precondition for participation. Gerhard focuses on Europe as a
community of law with respect to women’s gains and losses, and dis-
cusses whether European citizenship might be an option for women.
Here the question is whether and how far the Draft Treaty establishing a
Constitution for Europe reconsiders women’s rights. This aspect will be
of interest in order to discuss the European integration process as a polit-
ical opportunity for the empowerment of women.
The idea of European citizenship has developed together with the for-
mation and enlargement of the EU, but has remained a top-down concept
with which individuals have not established spontaneous connections.
From a gender perspective, the building of the EU has also contributed to
a certain extent to gender equality, and even if some critiques suggest that
progress in that field is exclusively enjoyed by working women, today
European citizenship has extended beyond its previous limitation to the
economic sphere. This extension allows for women’s multiple constitutive
identities and divergences to be expressed, while contributing to the cre-
ation of a certain European sphere made of a ‘multiple, layered system of
rights, obligations and loyalties’.1 However, European citizenship cannot
be prejudicial to the level of social protection of a given country since it
will remain a national prerogative.
In Chapter 3, ‘Can Feminism Survive Capitalism? Challenges Feminist
Discourses Face in Promoting Women’s Rights in post-Soviet Europe’
Sirkku K. Hellsten discusses the problem of achieving solidarity between
European women, by focusing on the paradoxes that feminist discourses
face in relation to the promotion of women’s rights in today’s Europe. She
notes that the various feminist approaches in Eastern as well as Western
Europe are embedded in their particular historical and socioeconomic
frameworks and sometimes appear incompatible and unable to work
together in current European political and economic practice. Particularly
in transitional societies, this makes the situation for women’s rights advo-
cacy confusing, to say the least. Post-socialist feminism faces a dilemma
whether to continue to believe in the values of socialist solidarity, whether
to grapple with individualist liberal values from within the liberal feminist
framework (and by engaging in related NGO projects), or whether to be
post-Soviet, post-socialist and postmodern altogether by declaring all ‘the
great stories dead’ and turning to more anarchistic feminist approaches.
Introduction 5
Hellsten argues that the various Western formulations of feminism, for

their part, need to be clear in their normative agenda and avoid turning
into a flagship for liberal democracy, which acts as a Trojan horse to
smuggle in individualist and capitalist values to replace the remnants of
egalitarian ideologies, which – after all – originally provided the most
powerful ideological critique of capitalist injustice and its negative impact
on women’s rights. Her main claim is that women’s rights advocates need
to redirect their focus on the wider structural issues, such as the future
directions of liberal democracy and its economic policies. While it might
be essential to teach women across Europe how to survive capitalism, it is
at least as important to unite – rather than assimilate – women’s move-
ments in the region, and the world as a whole, in order to have more
influence on local and global economic policies and move in a direction
in which equality and social justice, rather than gender issues alone, are
the common goals of all the parties of interest: men and women across
Europe.
In Chapter 4 Barbara Einhorn expands on the theme of ‘Citizenship,
Civil Society and Gender Mainstreaming: Complexities of Political
Transformation in Central and Eastern Europe’. She focuses on three cru-
cial issues impacting on women’s political participation in the region, fif-
teen years since the end of the Cold War: 1) the multiple levels of social,
economic and political transformation constituting both the context and
opportunity structures of political change; 2) contestations about the
analysis of the situation, particularly the relevance of Western feminist
theories; and 3) debates about the most appropriate strategies for achiev-
ing gender-equitable political participation. Einhorn shows that while
involvement in civil society and NGOs has long been women’s most
common platform for political engagement and change, it is problem-
atised in post-Soviet Europe. In the former socialist countries, women’s
NGOs flourished after the fall of communism and throughout the 1990s.
In the Balkans, although perceived as non-feminist, women’s organisa-
tions provided the most efficient space for women’s empowerment. Yet
the process that fostered the creation of all these women’s organisations
was not without problems. Women’s NGOs and grass-roots activist
groups now tend to fill the vacuum created where the state has with-
drawn from public service provision. This has created a ‘trap’ for women,
which at least in part derives from the idealisation of civil society, which
followed the fall of state socialism. Civil society was seen as the epitome
of democratic space, which had been lacking earlier, by both dissident
activists and (primarily male) theorists within the region, and by Western
analysts and international donor agencies.
Both Einhorn and Hellsten point out that limited funds mean that
women’s NGOs are rarely able to initiate large-scale projects, but instead
concentrate on voluntary work or social services through a framework of
programmes initiated by Western donors, who also bring in liberal ide-
ology which tends to undermine and diminish the local feminist dis-
courses and set aside local attempts to use the socialist and communist
concept of equality to promote social justice that treats women as equal
to men. Financial investments by international donors have contributed
as much to the mushrooming of women’s organisations as to their shift
in mandates or downright dissolution: for example, international aid
has facilitated the involvement of many women in the ‘reconstruction’
effort, especially in post-conflict zones. There is an ‘NGO-isation’ of
feminism or, in other words, the ‘co-option of the feminist agenda by
the interests of the state’.2 Women’s NGOs, however, tend to be unstable
and often permeable entities facing many difficulties in financing and
organisation. They have difficulties in maintaining their identity and
keeping their profile, while trying to adjust to donors’ expectations. The
sustainability of women’s NGOs is at considerable risk in many post-
Soviet societies and many of them dissolve after the completion of a par-
ticular project and after exhausting the funds available to them. Thus,
women’s organisations in these countries today are often subjected to
constraints that threaten their very nature and existence. Paradoxically
at the same time ‘NGO-isation’ is taking space and women’s labour and
time away from more traditionally ‘political’ efforts, e.g. participation
in parties or directly feminist organisations. This is a burning issue in
the former socialist countries (where women’s political representation
declined after the transition) as well as in many Western countries in the
context of welfare state reconfiguration and downsizing (such as in
the Nordic countries). The basic question is: are women ‘cheated’ into
participating as grass-roots service-providers, without a say in the
formulation of public policies and the larger issues of the society they
live in?
In Chapter 5 Hege Skjeie explores the complexities and debates
surrounding the discourses on gender equality. Her chapter, ‘“Gender
Equality”: On Travel Metaphors and Duties to Yield’, reveals that even
in those European countries, and particularly in Scandinavia, in which
equality is considered to be at a high level, there is a persistent pattern
of patriarchy which continuously demands gender equality to yield in
the face of other societal values, and lately also of other human rights
and equity issues, such as issues relating to religious or cultural rights.
Skjeie also points out that, particularly in the Nordic countries (Finland,
Introduction 7
Sweden, Norway, Iceland and Denmark), there has been a tendency to

be over-optimistic about ‘being almost there’ when it comes to gender
equality when in reality all these countries still have a long way to go to
achieve gender-neutral social justice. She identifies the ‘travel metaphor
of equality’. This refers to the state of affairs in the Nordic countries
where women’s organisations, and society at large, admit that while some
problems might remain, they certainly are well on their way to gender
justice. Consequently, since these countries can see that the goal is in
sight, they feel there is no need to take more radical action. Instead, femi-
nists in the region can compare their achievements among each other
(‘Who is the closest to the goal?’) – and against those countries that still
have a longer way to go (particularly the newly independent, transi-
tional post-Soviet countries). Skjeie points out that it is often overlooked
that, despite optimistic enthusiasm, the goal of gender equality in fact
appears to recede in the process of trying to reach it, and that women’s
rights, to an increasing degree, are now made to yield in favour of other
human rights issues related to religious freedom, cultural integrity or
ethnic identity.
In contrast to the theoretical focus adopted in Part I, Part II presents
empirical research concerned with more concrete problems and barriers
to women’s political participation and full citizenship and strategies
to improve them. The problems appear in many guises, ranging from
outdated and patriarchal attitudes apparent at individual, institutional
and cultural levels to the existence of exclusive political structures (for
example, in electoral systems, political recruitment, the organisation of
political and administrative institutions and political processes) and
ideologies that do not fully accommodate women as participants or gen-
der as a legitimate concern in policy-making. Challenging these barriers
to women’s citizenship has been a central strategy for feminist activism
and scholarship since the rise of second-wave feminism in the 1960s,
and even before.
However, the reforms achieved by women’s efforts are also bound to
be compromised by a major historical challenge to their permanent
character; namely, that political institutions and contexts are in a con-
stant state of flux as a result of other demands and external pressures,
too. In these processes, women’s achievements may be lost, if not by
intention, then by neglecting to pay attention to their preservation. In
a way, the challenge of politics lies in its contingent nature; that institu-
tions and political contexts do not stay fixed but are re-created continu-
ously. This demands careful analysis by all of us to be aware of what the
changes imply for women’s citizenship. This is especially true today, as
the transition of Central and Eastern Europe to post-communism, the

enlargement of the EU, neoliberal economics and the shifts between the
role of the nation-state and supranational decision-making constitute a
series of forces of change, unprecedented in peacetime Europe.
The following empirical chapters address precisely these issues, between
the constants of women’s political exclusion and devaluation and the
forces of change pulling in different directions, in today’s Europe. For
example, the dynamic of the EU accession process has been referred to as
a potential catalyst for efforts towards greater gender equality. While it is
agreed that women have been particularly affected by the transition to a
market economy (some women more so than others), it is also true that
the transition has had an effect on equality legislation. During the NEWR
workshops some argued that ‘the closer a country is to accession, the
greater the level of gender equality’. Others contested that the element of
proximity to accession is a sufficient criterion, but admitted that the
accession process nevertheless creates pressures and conditions that con-
tribute to improving gender equality. It can be said to be positive only in
so far as it brings gender equality issues onto the domestic political
agenda. However, especially in the Nordic countries where gender equal-
ity has traditionally been considered to be already well achieved, some
scholars observe that the combined impacts of ‘Europeanisation’ seem
multifaceted and contradictory from the viewpoint of increasing women’s
rights.
In Chapter 6, ‘Education and European Women’s Citizenship: Images
of Women in Bulgarian History Textbooks’, Krassimira Daskalova dis-
cusses the role of education and cultural values for women’s political
participation and citizenship. Daskalova suggests a feminist (resisting)
reading of the (sexist) (mis)representations of women in Bulgarian his-
tory textbooks published during the period of transition after 1989. Her
text is one more example that the so-called ‘turning points’ of history
do not transform the lives of women and men in the same way. The
representation of women and their experiences are still largely missing
from the new national history canon, demonstrating the sexist biases
of the new educational politics parading as civic and liberal. In tune with
the ideas developed by many feminist theoreticians who have shown that
the concepts of nation-state, citizenship and liberalism are not gender-
neutral, Daskalova argues that the official discourse developed in school
textbooks after 1989 can be seen as a hidden programme for civic edu-
cation; that what is at stake now is the formation of the civic identity of
future generations of European citizens; that if we want contemporary
education to build a tolerant, multicultural and pluralistic European
Introduction 9
civil society in the future, women should enter The His(s)tory. As

Daskalova insists, one of the strategies for implementing gender justice
and equal citizenship entails a cultural change from social models where
women are defined as ‘minors’, or mainly in relation to their reproduct-
ive capacities, to models in which they are defined as persons, individuals
and citizens, entitled to take part equally in public institutions of every
contemporary European society.
In Chapter 7, ‘Strong Together? A Comparative Study of the Impact of
the Women’s Movement on Policy-Making in Finland’, Anne Maria
Holli explores the question of women’s substantive representation. Holli
examines when and how various women’s constituencies succeed in
inserting their concerns in public policies. Drawing on the results of a
large, international, comparative project, Holli addresses some of the
perennial issues concerning women’s participation and representation
by illustrating that women’s inclusion does indeed matter. Including
women’s movements in the policy-making process tends to produce
more satisfactory policy outcomes from the women’s point of view. The
openness of the policy sub-system, the presence of left-wing power,
some characteristics of women’s movements (inclusion of women’s
movements that are close to the Left, the cohesiveness of movements
and the high priority of the issue at stake) as well as the backing of a
state women’s policy agency are shown to play a crucial role in deter-
mining women’s policy success. However, as Holli argues, these factors
may combine in different ways in different countries to produce similar
outcomes. Focusing on Finland, she illustrates this in practice by pin-
pointing the movement strategies and institutional mechanisms which
have contributed to Finnish women’s relatively high policy success in
that specific national context. The analysis also highlights the problems
that Finnish-type ‘party feminism’ faces between party and gender con-
cerns, providing food for thought on the possibilities and pitfalls of
politicising gender in precisely those legislative and party contexts that
are supposed to provide the solutions for problems concerning women’s
participation and citizenship.
In Chapter 8, ‘Transnational and National Gender Equality Politics:
The European Union’s Impact on Domestic Violence Debates in Britain
and Finland’, which focuses on domestic violence policy, Johanna
Kantola investigates one of the most salient topics in a context of an
enlarging Europe, namely the impact of supranational EU discourses on
domestic discourse and policies, and vice versa. Kantola shows that the
EU plays an important role in negotiating new conceptions of gender
equality, and thus forms a potential arena of reforms in the realisation
of European women’s rights and full citizenship. In the field of domes-

tic violence, as Kantola’s analysis illustrates, the EU has provided mem-
ber states with new actors, discourses, institutions and policies. Its
impact has been notable especially in Finland, where domestic violence
policy had traditionally been weak. While it is often assumed that it is
the developing countries that benefit from the international influence
in terms of advancing gender equality, Kantola clearly illustrates that
the EU and transnational discourses can also benefit countries which are
internationally thought of as pioneers in gender equality. However, the
other side of the picture that Kantola paints points to the continuing
power of national discourses. The EU member states also learn from one
another and for their part influence the EU to produce new conceptions
of gender equality and initiatives to advance women’s status.
In Chapter 9, ‘Implementing Gender Equality: Gender Mainstreaming
or the Gap between Theory and Practice’, Petra Meier takes up the ‘latest’
answer to gender equality problems by the EU, that is, gender main-
streaming, and explores its problematic and weak implementation in
practice. She focuses on the potential of gender mainstreaming to achieve
gender equality taking the political and institutional setting of the public
policy into account. She analyses the definition of gender mainstreaming
and shows that whether it can be evaluated to be a success or a failure
often depends on the definition adopted. The concept of gender main-
streaming promises a lot and raises high expectations, but it is also a very
demanding task and thus depends on the goals set whether it is a benefi-
cial strategy for improving women’s rights. Contrasting the prerequisites
for gender mainstreaming with what are considered to be sufficient con-
ditions for an effective implementation of public policies more generally,
Meier shows not only that gender mainstreaming shares the typical exter-
nal constraints affecting the implementation of public policies, but also
that it faces particular internal restrictions. Furthermore, contrasting an
ideal condition of gender equality with everyday practices of policy-
making shows that the different problems related to the implementation
of gender mainstreaming reinforce each other. To be able to mainstream
gender in public policies better, Meier argues, we need to be aware of
which problems relate to the implementation of gender mainstreaming
specifically and how to deal with them.
In the concluding chapter, ‘Good Governance and Good for Business
Too? Equality and Diversity in Britain’, Judith Squires brings together
the various themes discussed in the earlier chapters in her study of the
pursuit of gender equality in Britain. She claims that the struggle for
gender equality was previously framed by arguments for social justice
Introduction 11
and inclusive citizenship with limited focus on the labour markets, but
is now increasingly addressed as part of a wider ‘equality and diversity’
strategy, framed by arguments for economic productivity and applied
widely to all aspects of social, economic and political citizenship.
Squires suggests, via an exploration of both gender mainstreaming and
diversity management in Britain and the EU, that whilst both main-
streaming and diversity have theoretical appeal to radical political
democrats and theorists, they are conceived, defended and imple-
mented in ways that aim to appeal to business sector interests. Although
quite different in their derivation, both the diversity and mainstreaming
discourses share certain features. Both are increasingly framed by con-
siderations of good governance and economic competitiveness such
that they marginalise social justice issues and egalitarian citizenship.
When we reflect on all the topics discussed in this book Squires’ con-
clusion appears to summarise well the state of today’s gender equality
and the emphasis related to the concern for women’s rights in the inte-
grating Europe. It clearly appears that amongst the complexity of all the
developments, two key features emerge: the pursuit of equality is bound
up with modernisation and the practices of a new form of governance;
and the conceptual framing of equality is shifting from a concern with
egalitarian citizenship to one of economic productivity. Returning to
Skjeie’s rhetoric: we still have a long way to go and need to plan for the
many steps that must be taken to build a united Europe that is striving
for true social justice.
Notes
1. U. Gerhard, ‘Gendered Citizenship: a Model for European Citizenship’. Paper

presented at the Sofia workshop for NEWR, March 2004, p. 11.
2. B. Einhorn, ‘Political Participation: Some Key Issues in the Context of Political
Transformation in Central and Eastern Europe’. Paper presented in Birmingham
for the launch workshop of NEWR, January 2003, p. 6.
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Part I
Theoretical Feminist Perspectives
1
Dilemmas of Political Participation
Shirin M. Rai
Introduction
In an ‘era of globalisation’ political participation and citizenship are

issues that need to be discussed within a wider global context that
reaches beyond the borders of Europe. European politics is increasingly
reflective of the dilemmas and challenges of the politics of citizenship.
On the one hand, there are ongoing debates about the relationship
between the nation-state (the traditional site securing citizenship) and
the regional institutions of the European Union (EU). There are concerns
about identities and accountabilities, borders and regulations. On the
other, there is an acknowledgement of the expanded sense of ‘Europe’,
and expanded citizenship therefore, and its links to the wider world. Due
to the changing structures of international relations, new laws and pol-
icies on immigration (on national and regional levels, that is, the EU,
African Union and any other regional arrangements), and new forms of
multilateral co-operation (such as international civil society networking
within and without Europe), political participation cannot be under-
stood without taking into consideration that wider context.
Theoretically, political participation has a long genealogy. Like most
concepts that we use today, this is an unfolding concept. From the direct
participation of the Greek city-states to the Schumpeterian model of par-
ticipation in elections, the concept has been central to our conversations
about democracy. There are several ‘myths’ about participation that we
can examine: Participation is good in itself – it creates the stake people have
in society; it legitimises decisions that are taken in the name of people in
society; it allows individuals to relate to each other as participants in a
common cause; it educates us in a civic culture which is crucial for the
stability of the polity. Participatory politics allows for claims to be made
15
16 Shirin M. Rai
against the state – freedom of speech, movement, association, what we

would consider human rights today could be said to have evolved in
response to the needs of participatory politics. Participation took the
form of military service in the defence of the state, from which flowed
the rights of citizenship. From Jean-Jacques Rousseau to Karl Marx, there
is a strain of thought that focuses on participation as a marker of a good
and unalienated society, where citizens have control over not only their
representatives, but also the political agendas set by the state and its insti-
tutions. On the other hand, there is also the myth that participation is
destabilising – from Socrates to Samuel Huntington participation has been
regarded as problematic. It brings into public discourse voices that are
unfit to be heard – racism, sexism and ethnic cleansing have all been
articulated in the public sphere and legitimised through the language of
participation and of fundamental rights of speech, movement and asso-
ciation; it allows the loudest voices to be heard – the rule of the mob
instead of Reason; is a luxury for the privileged – the costs of participa-
tion are met by those who cannot afford to participate; levels of parti-
cipation can prove destabilising in the absence of strong controlling
mechanisms of state power; participation is therefore problematic and
threatening and needs to be framed within representative institutions
where the voice of Reason might be better heard. Participation thus has
been a language of both inclusion and exclusion; of a vibrant civil soci-
ety as well as a dysfunctional politics.
Feminist theorising participation: movements, citizenship

and democratisation
Feminist theorising has largely supported the importance of the partici-

patory politics and practice at different levels – grass-roots as well as
global. It is through their participation in these movements that women
and women’s groups have been able to stake a claim to citizenship and
equal representation in political life and institutions. The points of depart-
ure for women participating in various movements have been different,
as have been the political contexts – colonialism, military dictatorships,
authoritarian regimes, religious states (Jayawardena, 1989; Bystydzienski
and Sekhon, 1999). These contexts have influenced the forms this par-
ticipation has taken – women’s participation in the suffragette move-
ments in England and the United States, peaceful mass participation
as part of mainstream, organised political action such as the Indian
national movement, negotiations with religious authorities over a long
period of time such as in the Islamic Republic of Iran, struggles for
Dilemmas of Political Participation 17
human rights in Chile, Guatemala and other states, where violence as a

means of social control was paramount, or participation in armed strug-
gles at different levels such as those in China, Algeria and South Africa
(Rai, 2000). The constituencies of women that participated, as well those
who did not or were unable to, are important indicators of the politics
of these movements as well as their long-term impact. While reflecting
on the exclusionary practices of states and organisations, feminists have
also examined how participation in political movements is not uninflu-
enced by the cleavages of class, caste, religion and ethnicity – the differ-
ences among women as well as between women and men are important
in shaping the future agendas for struggle.
Women’s political participation in these oppositional movements has
highlighted one of the most important anomalies for democratic prac-
tice – the distinction made between the public and the private spheres.
Women have, even as part of mainstream political movements, been
characterised in terms of motherhood – they have been spoken of as the
reproducers of nations and ethnicities, as bearers of cultural norms as
makers of traditions, of embodying the past and future of nations.
Women’s groups have been in the forefront of challenging the separ-
ation between the public and the private. For example, in the democra-
tisation movements against the military dictatorship, we saw Chilean
women call for democracy in the home as well as in politics. However,
these struggles have not always been successful. Women’s participation
has often legitimised movements without necessarily resulting in women’s
political visibility much less representative parity for them. Agenda-
setting for political movements has reflected this dichotomous thinking.
Together with other feminists I have argued that political priorities have
often been fashioned to accommodate the dominant power relations,
and to postpone the struggles against these (Stacey, 1983; Helie-Lucas,
1991; Rai, 1996, 2002).
Feminist arguments against a distinction between the public and the
private spheres have been long and well made (Pateman, 1989). While
radical feminists have seen the obliteration of this distinction as neces-
sary to democracy that is inclusive of gender-based difference, others
have seen such a bridging of the public and private as transitory – a phase
that would allow the entry of women into the public arena as independ-
ent actors (Phillips, 1995, 1999). Feminists have also pointed to the
diversity of women’s histories and the experiences of ‘the public’ on
account of class, race, disability and sexuality to argue for the essentially
contingent and contested nature of the debate on the distinction between
the public and the private spheres (Lister, 1997: 122–5). Some feminist
18 Shirin M. Rai
scholars have argued that while democratising the private domain is cru-
cial for women’s participation in the public, it ought not to be confused
with issues of civic participation and rights (Dietz, 1992; Mouffe, 1992).
Young, for example, has stressed the importance of maintaining the sep-
aration between the two spheres. She suggests that the private sphere
should be thought of as ‘that aspect of his or her life and activity that any
person has the right to exclude from others. The private in this sense is
not what public institutions exclude,’ she argues, ‘but what the individ-
ual chooses to withdraw from public view’ (Young, 1990: 119–20). Lister,
quite rightly, points out the problems with this articulation of the public–
private divide: ‘it does leave open the question as to which individuals
have the power to make their choices stick’ (1997, p. 121). Like the
others cited above, I would question particular constructions of the dis-
tinctions between the public and private spheres. I would also emphasise,
however, the need for a simultaneous, but parallel, democratisation of
both the public and the private spheres. Here I would insist with Dietz on
keeping the two domains separate. It is important, I would argue, to mark
a conscious transition that women must make to politicise the issues that
affect them within the private sphere. Rather than focusing on the issue
of exclusion from the private sphere, I would emphasise the terms of
inclusion into the public sphere. I would suggest that it is only through
making the private public that we can move forward on this issue. While
not entirely answering the question of agency raised by Lister, such an
understanding of the bringing together of the public and the private
would do so in part through the social mobilisation of women (and men)
on particular issues in the public sphere. As Kandiyoti (1991) has pointed
out, such negotiations might involve bargains with patriarchy. These
would necessarily involve, as Molyneux (1998) has discussed, making
analytical distinctions between strategic and practical interests. However,
I would argue, both these processes could contribute, in different ways in
different contexts, to making women’s ‘private’ experiences and struggles
political.
Within the feminist movements the claim to participation has gone
hand in hand with claims to citizenship. The concept of citizenship itself
has evoked vigorous debates over meanings as well as the materiality of
participative politics. In the 1980s we saw citizenship linked to the
embodied participation of a stakeholder, which generated a deeply exclu-
sionary discourse, in the words of Bina Agarwal (1997), of membership as
opposed to one of usufruct rights. On a more positive note, debates about
civil society embraced citizenship rights and led to a revisiting of the
Marshallian analysis of the concept in its three forms: individual rights,
political rights and socioeconomic rights. The latter further led to the
examination of entitlements to citizenship in the context of economic
retrenchment. Globalisation debates have led scholars to consider the
local as well as global implications of citizenship in the context of elite
embeddedness (Kothari, 1995). Feminist scholars have been engaged in
all these debates. Some are worried about the impact of macroeconomic
neoliberal policies on the erosion of citizenship rights, while others are
hopeful of new terrains of social participation in the context of expan-
sion of politics under globalisation.
Constitutional change and debates on citizenships are perhaps one
area where the activism of the women’s movements at both the global
and national levels, international pressure through the various United
Nations (UN) conferences, and the establishment of national machiner-
ies for women have been able to open up new territory for gender equal-
ity. Legal and constitutional reforms promoted in many countries have
resonated with the theoretical and strategic debates on women’s inter-
ests and with the feminist scholarship in the area of citizenship. It is in
the operationalising of particular citizenships that we can view the con-
texts within which new claims to citizenship rights might be made and
others extended. The struggles over what it means to be a citizen, the
terms on which citizenship can be crafted, the need to acknowledge dif-
ferences among populations and also an insistence on equal citizenship
rights, as well as the reopening of settled arrangements in the context of
economic and social changes in the polity, all form part of this unfold-
ing process. Feminist scholars have written extensively on citizenship,
arguing that it is an important as well as a contested concept (Lister,
1997: 3). It has been argued that:
modern citizenship is inserted into a social field … [where] freedom,

autonomy and the right to be different … are pitched against the regu-
lating forces of modernity and the state, and subverted by discourses
of ‘culture and tradition’ – of nationalism, religiosity and the family.
(Werbner and Yuval-Davis, 1999: 1)
Citizenship is thus embedded in the dominant social relations in particu-

lar contexts, while at the same time appearing as a universal discourse of
rights. Feminist scholars have felt this ambiguity acutely and pointed
out the term has as often been used in struggles to secure greater stand-
ing within the national political arena as it has ‘often simultaneously
functioned to justify the exclusion of other members of the national
community’ (Narayan, 1997: 49). Citizenship can be exclusionary in
20 Shirin M. Rai
two ways: first, by denying national citizenship to individuals it can

be used to reject the ‘human’ claims of those who are thus denied; and
second, by individualising citizenship it limits the political space to
acknowledge collective rights to citizenship, and therefore an historic-
ally embedded understanding of citizenship (Kymlicka, 1995).
Citizenship has also been important to the discussions on gender and
democratisation. Perhaps here more than anywhere else, we are conscious
of the changed international political climate. We also become aware of
the political context of the old and new democracies, and of transitional
or fragile democracies within which women have to negotiate their citi-
zenships. In transitional societies the terms of women’s inclusion in pol-
itical life have been important (Blacklock and MacDonald, 2000; Zulu,
2000). However, these debates on citizenship are taking different forms,
depending on the nature of transitions. So in South Africa, given the his-
tory of systematic exclusion of black people from the polity, the focus of
political debate has been on constitutional provisions for an engendered
citizenship. In Guatemala and Mexico, the experience of military dicta-
torships has seen the women’s movements shifting the debate from a
citizenship-based to a human rights-based discourse. This shift is visible
in other states, where liberalisation is creating tensions around the envir-
onment, or displacement of peoples, or of conditions of employment. In
countries where the transition has included a dismantling of economic
state structures such as in the Eastern European countries and in Russia,
citizenship debates have necessarily had to take on board the new eco-
nomic realities (Jereska, 1998; Einhorn, 2000). The question of entitle-
ments to citizenship has then become important.
What this very rapid trawl through the participation theory and prac-
tice shows is that political participation has a chequered history, which
is reflected in the dominant social relations through the regimes of inclu-
sion and exclusion and is shaped by the struggles to alter these regimes. It
is interesting to note that political participation is no longer being juxta-
posed to representative politics. In the colonised world, this suspicion of
state institutions has not been so much in evidence. The fight for national
recognition was one in which in most countries women and men partici-
pated together. The forms that this participation took were deeply gen-
dered, but the promise of a postcolonial equality of citizenship held this
alliance together regardless. However, the terms of this participation per-
meated processes of state formation and the levels of women’s presence in
state institutions remained low. In western polities, the engagement of
feminists with the state was more problematic. While the liberal feminists
engaged the state on policy reform, radical and socialist feminists saw the
state as part of the problem of patriarchal oppression of women rather

than as a solution. Overall, we had to wait until the 1980s, when chan-
ging economic and political conditions led to a serious engagement of
women’s groups with state institutions in both the North and the South.
During the 1980s, with the expansion of NGO networks and their inclu-
sion, in a consultative capacity, in institutions of governance, new
avenues of engagement with the state and international bodies were
opened up. The fall of the Soviet Union also translated into a third ‘wave
of democratisation’, which during the 1990s came to include governance
institutions in consolidated democracies and international bodies such as
the UN in the context of pressures of globalisation. This allowed the gap
between institutions and movements to narrow. The focus shifted to par-
ticipation in and dialogue with institutions. As a result, strategies for
increased levels of representation of women in public institutions have
been explored – quotas for women, parity representation, new equal oppor-
tunity legislation in employment and provision of appropriate social
infrastructure for women to be able to participate in political life.
We can review the engagement of women’s groups with the state in
three different fields. The first is that of participation in political institu-
tions. They have insisted on the importance of representation of women
in these institutions from different standpoints – that women do politics
differently/better, or that it is just that historically excluded groups be
allowed a say in the ‘governing’ that affects their lives. Strategising for
this, feminists have argued for quotas for women in political institutions
in order to make women more visible and audible in political processes.
They have also engaged with political institutions by participating in
bureaucracies, policy-making bodies and representative organisations
under the broad principles of gender mainstreaming (McBride, Stetson
and Mazur, 1995; Miller and Razavi, 1998; Rai, 2003). The second arena,
which links the state debate with that on democratisation, is that of
women organising in the informal and formal sectors and spaces of
politics – women’s movements, human rights groups, functional lobby-
ing groups such as the Self-employed Women’s Association (SEWA) and
Women in Informal Employment: Globalizing and Organizing (WIEGO).
These groups have lobbied governance institutions at all levels from the
outside. The focus has been both the protection of their members as well
as lobbying for shifts in state policy. Women’s movements have been
grappling with the issue of the changing role of the state. As the sites of
production and reproduction shift within states, as new regimes of pro-
duction make for different forms of work – part-time, flexible, concen-
trated in export processing zones, migratory – women are having to
22 Shirin M. Rai
organise differently. While the state continues to be a central focus of

women’s mobilisation on various issues, supra-territorial strategies are
increasingly employed in order to counter the state, to delegitimise its
position or to mobilise global discursive regimes in their interests. So,
women’s groups have participated in ethical trading initiatives (Hale,
2004), as well as challenged the erosion of welfare provision and pressed
for gender-sensitising economic policies at the global as well as the local
level (O’Brien et al., 2000). The third area of feminist intervention is that
of developing political and epistemic networks that feed into policy insti-
tutions as well as debates. Feminist scholarship in the fields of econom-
ics as well as development studies has unpacked key economic concepts,
particularly the crucial concept of work: What constitutes work? How is
it reflected in economic documents that form the basis of policy-making?
And how, alternatively, might work be assessed, analysed and reflected
in public debates? (Rubery, 1988; Bakker, 1994; Bakker and Gill, 2003).
Gender budget groups in many countries have done useful work in dis-
covering the male bias in economic accounting for the work of women
and the impact of this on economic policy-making and its impact on the
lives of both men and women (Elson, 2004). These groups have engaged
in discussions with Treasury departments with intellectual expertise and
political commitment to attempt to make transparent the contribution
of women to the economy.
If the state is a participant in the reconstitution of its own relations
with the global political economy, then it continues to be a focus for the
struggles against this changing relation, whether it is from (dis-)organised
labour in the urban or the rural context, or from other social movements
(Rai, 2002). The nation-state as the focus of developmental struggles
allows historical knowledge of traditions, cultures and political contexts
to be mobilised with greater facility than the amorphous ‘international
economic institutions’ peopled by shadowy figures not visible to the
local oppositional struggles. Thus, state accountability and the space for
political participation for both men and women form an important part
of the understanding of governance for many women’s groups at both
the national and the global levels (Tambiah, 2002). Around these strug-
gles new markers of inclusion and exclusion have developed, but these
are increasingly being viewed in the context of globalisation.
Globalisation and the terms of political participation
Feminists have and are engaging and extending the debates on global-
isation from different perspectives (Sen and Grown, 1985; Mies and
Shiva, 1993; Chang and Ling, 2000; Rai, 2002; Peterson, 2003). Faced
with new challenges, feminists have also sought to examine and the-
orise how globalisation is changing political activism at grassroots level
as well as at the level of global institutions (Basu, 1995; Cockburn, 1998;
Stienstra, 2000; Waylen and Rai, 2004). While some feminist scholars
have focused on communicative expansion that has been brought about
by globalisation (Eisenstein, 1998), others have been concerned about
global economic regimes. In particular global production and structural
adjustment policies that are affecting women’s lives directly and indir-
ectly, reshaping gender relations within the home and in the workplace
(Afshar and Dennis, 1991; Elson, 1995, 2004; Jackson and Pearson,
1998; Beneria, 1999; Runyan, 1999) have been the focus of attention, as
have been issues of security and insecurity, and of well-being (Elson,
1995). In terms of political activism, feminist scholars have built on and
stretched further the ideas of ‘borders’ and a ‘borderless world’ through
studies of women’s migration (Pellerin, 1998; Kofman, 2000; Staudt,
2004), world communities such as those based on religion (Moghissi,
1999; Karam, 2000), and by examining the growing density of women’s
networking through informal and formal organisational structures
(Stienstra, 2000; Liebowitz, 2002). One of the key contemporary polit-
ical debates regarding globalisation is the perceived shift from (state)
government to (global) governance.
What does the shift from government to governance signify, and what
have been the ramifications of this shift for political participation? Are the
terms of political participation shifting in the light of the changing rela-
tions between state and supra-state institutions? How can we participate
in supra-territorial institutions when national institutions have proved
to be so unnameable to politically marginal groups? Have technological
advances that have ‘networked’ us globally opened up new avenues of
participation, or are these reinforcing the economic and political gap
between the rich and the poor? Can the rise of religious fundamentalism
be seen as a particular form of political participation in response to an
experience of fragmentation that accompanies globalisation?
The rise of global institutions led to a liberal institutionalist analysis of
the consequences of global governance for democratisation. On the one
hand, the various interventions focus on the need for conceptualising
alternatives to state institutions of government in the context of the
global political economy. On the other, the literature focuses on address-
ing the democratic deficit of the global institutions themselves. How
can these institutions be made more accountable in a context where
they seem to be usurping the power of the state (Woods, 2002)? The
24 Shirin M. Rai
effectiveness of global institutions, especially the UN system and the

Bretton Woods institutions, are evaluated and found wanting, leading
to prescriptions of reform. New governance institutions are recom-
mended to regulate actors and issues emerging as key in a globalised
world, such as mechanisms of consultation, surveillance and co-ordination
of macroeconomic policies, an ‘international financial architecture’
stabilised through global institutions, and the regulation of capital
(transnational corporations) and labour (migration) (Nayyar and Court,
2002: vii–xi). A juxtaposition of this liberal institutionalist agenda
for global governance and of the social democratic framework might
allow us to develop some key themes of democratic governance, such as
the link between political democracy and social justice, the relation
between representative and participatory politics and the importance of
global democratic space for mobilisation in challenging the hegemony
of neoliberalism. Such a juxtaposition would also allow us to explore
the concerns of feminist scholarship – about democratising the private
as well as public spheres, the unbundling of citizenship in the context
of neoliberal policy agendas and the struggles to defend the welfare
state provisions and the mainstreaming of gender perspectives in policy-
making – which are sidelined in the liberal institutionalist framework.
Feminist studies of transitional and democratising states emphasise
these points. While some of the studies have focused on the impact of
liberalising economies and the marketisation of the state on women’s
lives (Einhorn, 2000) others have considered how women can engage
the state in a globalising context where the state is coming under mul-
tiple pressures and is repositioning itself in different ways in different
contexts ( Jaquette and Wolchik, 1998; Blacklock and Macdonald, 2000;
Eschle, 2000; Rai, 2000, 2002).
Feminist engagements with global governance have built on the
insights derived from the debates on the market and the state, as well as
on processes of democratisation (Rai, 2004). Meyer and Prugl (1999) have
defined three different feminist approaches to global governance. First,
gender in global governance is seen as ‘involving institutional structures
in which women have found or carved out niches for themselves and
their interests as women’ and therefore ‘introduce into global governance
women-centred ways of framing issues …’ (1999: 4–5; Stienstra, 2000;
Liebowitz, 2002). Gender mainstreaming processes have seen feminist
bureaucrats and gender policy advocates make homes in state and global
governance structures (Miller and Razavi, 1998; Sawer, 2003; Staudt, 2003).
The outcomes of these engagements from within have varied greatly
depending on the level of bureaucratic hierarchy at which feminists are
able to operate, the political culture of the site of governance, the dom-
inant framework of analyses used by organisations to fashion policy, the
resources that gender work has been able to attract – both financial and
political capital – as well as the support that feminists within organisa-
tions have been able to depend upon from social movements engaged in
advancing women’s strategic interests. Second, gender in global govern-
ance is approached through critical politics ‘exploring the purposive,
goal-oriented … social-movement strategies to influence the United
Nations’ and Bretton Woods institutions (Meyer and Prugl, 1999: 5; also
see O’Brien et al., 2000). UN conferences have been catalysts for women’s
organisations to mobilise in the interests of their constituents, as well as
to develop conceptual tools to engage critically with the discourses of
growth-led development emanating from Bretton Woods institutions.
NGOs have mounted campaigns, such as Women’s Eyes on the Bank
and the ‘Women Take on the World Trade Organisation’ campaign by
Women’s Environment and Development Organisation (WEDO). In the
context of the regional free trade agreements, such as the North American
Free Trade Agreement, ‘Transnational NGO activism can actually be seen
as contributing to or expanding the resources an national political move-
ment has at its disposal’ (Liebowitz, 2002: 175), thus linking the various
levels of organisations and sites of resistance. Feminist and women’s
groups have engaged with institutions at all these levels through conven-
tional and virtual forms of political engagement and developed insights
from these engagements (Eisenstein, 1998; also Youngs, 2001). Finally,
feminists have approached gender politics in the context of global govern-
ance as ‘contestations of rules and discursive practices in different issue
areas’ (Meyer and Prugl, 1999: 5). They have done so not only by focusing
on the consequences of the dominant global neoliberal economic policy
frameworks espoused by the Bretton Woods institutions, but also by the
constitutive gendered nature of the concepts used to formulate these
policies (Bakker, 1994; Elson, 1995; Rai, 2003). Some have argued, for
instance, that the intensification of globalisation through the extension
of marketised economies and state institutions has been accompanied by
changes in the governance of production and social reproduction. This is
resulting in the transformation of ‘gender orders and regimes associated
with intensified globalization’ and the institutionalisation of these trans-
formations in gendered governance frameworks (Young, 2003: 109).
Though women’s groups are engaging with institutions of power, this
is not an uncontested strategy; many women’s NGOs find such engage-
ments too problematic and politically flawed. Despite sceptical voices,
globalisation of participation through social movements is regarded by
26 Shirin M. Rai
many as the dynamic, creative response to the forces of economic con-

vergence. And yet, can we see this global politics as co-optive of increas-
ing populations forced to interact with the dominant discourses of
reasonableness – capitalist growth and the predominant logic of mar-
kets, liberal democracy and individual human rights? Is the language of
participation becoming a discourse of justification of the dominant
social order? Fundamentally, participation in what? How do we translate
into practical politics the feminist slogan ‘Think globally, act locally’?
I discuss some of these issues in the next section.
Political participation: a new stabilising ethic?
According to Clark (2002) the following reasons contributed to the NGO

engagements with the Bank and international financial institutions more
generally: the debate was brought within target institutions, such as the
G7, regional bodies such as the European Commission, national parlia-
ments; creeping conservatism of the North including the perceived failure
of aid and loan regimes; building on some victories for other battles –
success in one area led to greater confidence of successful advocacy and
campaigns in another; comparative perspectives of Southern partners
made Northern economic actors appear more reasonable; the debt crisis
made economic justice an important issue to mobilise on. Therefore,
as Miller and Razavi point out, ‘ “disengagement” – proposed by some
feminists – is untenable as long as multilateral development institutions
continue to exercise influence over the development policy process’ (1998:
139). The output of the political participation of women’s groups at dif-
ferent levels and in different forums has been measured by whether or
not gender has been mainstreamed in policy and institutional structures.
Mainstreaming gender in economic policy-making became one import-
ant element of social movement politics.
Mainstreaming has been defined as:
a strategy for making women’s as well as men’s concerns and experi-

ences an integral dimension in the design, implementation, moni-
toring and evaluation of policies and programmes in all political,
economic and societal spheres so that women and men benefit equally
and inequality is not perpetuated.
(ECOSOC, cited in Staudt, 2003)
Assessing mainstreaming of gender agendas, Jahan has pointed out that

the need is not simply for organisational change, but for a transformatory
approach which would lead to a fundamental change in the mainstream

itself (Jahan, 1995). If we are to assess the engagement of women’s NGOs
with the World Bank, for example, we need to ascertain the range and
limits of possibilities that the NGOs have been able to explore and influ-
ence. What we find is that despite several gender-sensitive initiatives, the
Bank’s fundamental approach to economic growth and its endorsement
of the neoliberal market-based economic framework has not shifted.
The instrumentalist argument continues to pervade its policy-making –
women’s education and health in particular are linked to the pro-
grammes on population control, for example. In a comparative study of
six World Bank poverty assessments in four countries – Ghana, Zambia,
Tanzania and Uganda – for example, Whitehead and Lockwood found
that ‘[t]here is tendency to locate WID [Women in Development]/gender
concerns in the soft areas – such as human resources – in an organization
giving strong analytical and policy priority to economics’ (1999: 528). As
a result of treating gender as discrete, and as a cultural issue related to
women’s ‘social status’ in some cases and as ‘gender division of labour’ in
others, there appears to be a somewhat ‘accidental’ diversity in the way
in which these assessments address the issue of the gendered nature of
poverty (ibid.: 528–30).
I have argued elsewhere (Rai, 2002) that the NGOs and women’s
movements working with institutions of power at any level are con-
strained by the dominant paradigms of power. Most of the initiatives
taken by these institutions under pressure from women’s groups are
‘integrating’ rather than ‘agenda-setting’ (Jahan, 1995). The limitations
of ‘cultural’ and ‘socio-economic’ structures that embed the local polit-
ical institutions are significant constraints upon women activists. These
constraints not only impose limits to change, but also raise the issue of
co-option of women’s groups into the hierarchies of power and influence.
Second, in each case the issue of differences among women is crucial.
The differences that have emerged among women have been many –
between NGOs of the North and those of the South, between activists
and femocrats, between those who decide to engage with multilateral
and state institutions and those who do not, between those who are
funded by multilateral agencies and those less well funded or not
funded at all. These divisions are also about who gets heard and who
doesn’t, and therefore about the implicated nature of engagement
which normalises critiques through mainstreaming them. Third, and
linked to this, there has been a recognition that the terms of women’s
engagements with multilateral bodies or state institutions do not gener-
ally favour women. The shifts in the paradigms within which various
28 Shirin M. Rai
institutions of power function are minimal. Multilateral institutions as

well as states show a minimal shift in their approach to economics and
policy-making (DFID, 2005), the national machineries of various coun-
tries are embedded in and constrained by the political economy of their
contexts (Rai, 2003; DAW, 2004), and at the local level, state institutions
work with women’s groups within very narrow boundaries, reluctant
to challenge the dominant social mores. Fourth, there are disagreements
about the costs attached to the engagement of women’s movements
with institutions of power – and that these are differentially borne by
women in the North and South, and by women of different socio-
economic strata. While a strategy of disengagement with multilateral
and national institutions of power might be untenable, it is important
to have cognisance of the costs of such engagements in terms of the
fragmentation of women’s movements, fracturing of dialogue between
different NGOs, and groups within countries, and also between North
and South. These costs are not inconsiderable and are unevenly dis-
tributed. For women in socially vulnerable positions due to either their
class, religious, ethnic or caste position the cost can be personally very
high. Finally, there is also the question of the legitimacy not only of the
state or multilateral institutions but also of women’s NGOs speaking
for women at international and national forums. Who can speak of
the pain and confusion of activists who, on the ground, feel betrayed by
the system that they thought was going to be their ally for change? The
argument is thus not about whether to participate in and engage with
institutions of power or not. The argument needs to be how far the
process of participation and engagement is necessarily part of the out-
comes. In short, it is about taking politics seriously in order to challenge
the dominant paradigms but with cognisance of structural power, which
can be a powerful obstacle to attaining gender justice. If feminist engage-
ments with global governance institutions do not take into account the
disciplinary power of the dominant social relations within which these
institutions are embedded, these engagements could succumb to the
danger of supporting ‘systems that create themselves’ (Riles, 2002: 173).
In this sense, how do we measure effectiveness of engagement and par-
ticipation at the state and the global levels?
Indicators of participatory effectiveness
Participation has always been difficult to measure. Is political participa-

tion effective when we focus on the outcomes achieved through it, or
is it the processes of participation that are empowering themselves
whatever the outcome? As far as outcomes are concerned, one easy way
to measure the effectiveness of political participation is assessing how
that translates into women’s participation in representative bodies. If
the number of women in parliaments and governance bodies continues
to be minimal or to climb up very slowly, then we can assume that
despite the rhetorical space occupied by feminists, the evidence points
to the continued exclusion of women in society. From that perspective,
we see that globally mainstreaming strategies and the political pressure
brought about by women’s groups and movements have begun to
address some issues of under-representation. Quota legislation in differ-
ent parts of the world, for example, are increasing women’s member-
ships of legislatures and resulting in women becoming involved in the
government as well as in the governance institutions at the global level
(DAW, 2000; Dahlerup, 2005). There is some evidence from comparative
feminist research that women representatives do attempt to address
women’s basic needs, are approached by women’s groups to address
their problems and even some evidence that, on the whole, women rep-
resentatives are less corrupt and therefore bring to local governance
some degree of credibility in the eyes of the people (Rai et al., 2005).
A second would be an examination of the role of social movements as
political participation: Have social movements been able to shift macro-
economic policy (outcome) which, for instance, might adversely affect
the environment? Or have the movements been able to mobilise general
interest in sustainability (process) and engender increased awareness of
global environment that might sustain participatory politics of a differ-
ent kind – recycling, organic consumption, fair trade initiatives, etc.? Are
these the markers of a new citizenship? The engagement of women’s
NGOs and activists with the World Bank raises some difficult questions
for women’s NGOs. Lobbying the World Bank means dealing with econ-
omists who are not necessarily convinced of the agendas of the women’s
NGOs and speak a language that is inaccessible to activist women, and
therefore means making time for and expending energy on learning this
language. Time and energy are at a premium for most women activists.
The process of ‘consultation’ with Bank (or other major economic insti-
tutions) representatives is not without its power imbalances, and can
therefore be alienating (Cohen, 2000). The gathering of information
required to challenge the economic indicators that the Bank officials
bring to bear on these discussions also requires resources and training
that many Third World NGOs cannot provide. However, as Chiriboga
(2002) has pointed out, the tendency of many southern NGOs to look to
the World Bank to provide funding runs the risk of creating a clientelistic
30 Shirin M. Rai
relationship, where funding possibility are achieved in return for

favourable comments and risk losing international and Northern allies.
The differential resourcing of NGOs and questions of access thus become
important issues of difference among the NGOs:
the evolution of the campaign [Women’s Eyes on the Bank] to date is

illustrative of the power differences between women’s movements
North and South, of the importance of geographical location, and also
of delays in the spread of communication technologies to margin-
alised social movements.
(O’Brien et al., 2000: 65)
Also, the costs of engaging with multilateral organisations – especially

those associated with the enforcing of structural adjustment policies –
are differentially felt by women’s NGOs. Women in the South are often
faced with abuse for engaging with ‘foreign’ organisations. There are
also questions of accountability of the NGOs that make links with multi-
lateral organisations and those that do not (see Rai, 2002). Attempts
to leapfrog the nation-state by approaching multilateral organisations
can also result in the undermining of democratic politics or struggles
towards a democratic politics on the ground. None the less the increased
levels of NGO activity, especially the forum of UN organised conferences
on women, has led multilateral institutions to address the question of
gender equity, and has prompted many nation-states to do the same.
A third measure would focus on the processes of participation and not
just the outcomes. This would allow us to examine issues of sustainabil-
ity of political participation in institutions as well as the levels of vul-
nerability attached to such participation. The debate on deliberative
democracy could be one useful framework within which to address
some of these issues. Contemporary deliberative democracy framework
involves three elements: process, outcome and context. Feminists have
argued for a similar process/outcome-based politics when they have
spoken of ‘rooting and shifting’ or ‘transversal politics’, of situated
deliberation leading to democratic outcomes as particularly suited to the
way women do (or are predisposed to do) politics (see Yuval-Davis, 1997;
Cockburn, 1998). Deliberative theorists have defined deliberative democ-
racy in the following way. As a process it includes: collective decision-
making with the participation of all those who will be affected by the
decision or their representatives; decision-making by means of argu-
ments offered by and to participants who are committed to the values
of ‘rationality and impartiality’ such that they are able to argue in terms
of public rather than simply particular interests; conversing such that

individuals speak and listen sequentially before making collective deci-
sions, and from the perspective of participants, ensuring that some
interests are not privileged above others, and no individual or group can
dictate outcome of actions of others which means that outcomes are not
known before the deliberations are conducted and completed (Knight
and Johnson, 1997: 279–319; Elster, 1998). On this view, political equal-
ity becomes a central theme in the deliberative democratic argument.
The deliberative democracy argument does focus on outcomes as well
as processes, but these are different outcomes: the educative power of the
process of deliberation; the community-generating power of the process
of public deliberation; the fairness of the procedure in such a model; the
epistemic or knowledge-building outcome of deliberation and the ‘con-
gruence of the ideal of politics articulated by deliberative democracy with
“who we are” ’ (Cooke, 2002: 53–87). Deliberative theorists point out that
as outcome the concept includes the following presumptions: deliber-
ations lead to change of preference resulting from communication; it
leads to better decisions; it legitimises decisions, which improve the
chances of these being carried out; it lessens the impact of bounded
rationality – situated positions become open to scrutiny and possible
shifts; it improves the qualities of the participants – speaking, listening
and deliberating; and it may constrain misrepresentation and irrational-
ity, in language if not in decisions – the ‘civilising force of hypocrisy’ – as
a ‘second-best’ argument. Decisions and the quality of decisions are thus
both part of the deliberative equation. Finally, as context, the deliberative
setting promotes rationality and impartiality, and considers the question,
who deliberates? It is here that arguments of justice are juxtaposed with
those of general interests or the common good (Cohen, 2000). As is clear
from the above discussion, the emphasis of deliberative democracy theor-
ists has been on political equality. Knight and Johnson acknowledge that
‘a commitment to political equality involves potential trade-offs with
other societal goals’ and concede that ‘some redistribution of power and
relevant material resources as well as an acceptance of inequalities in the
treatment of citizens by the state’ will have to be deemed acceptable
(Knight and Johnson, 1997: 310). How does deliberation fare under such
conditions of relative or absolute inequality?
For women in public political institutions as they currently function
this approach to equality poses multiple problems. First, there are prob-
lems of identity – whom do they represent? Their constituents are obvi-
ously both men and women, but do they also take upon themselves (or
not) the added burden of ‘representing the interests of women’? Are they,
32 Shirin M. Rai
therefore, feminists, ‘womanists’? Second, how do they reconcile their

membership of a political party with, if not membership then sympathy
with women’s movements? Without such sympathy would they be any
different from men in political institutions? Is the question of the pres-
ence of women a sufficient question? Third, how are the differences of
socio-economic positions reflected in the work of women representa-
tives? Is it important that the women representatives are from particular
class/caste groups? To paraphrase Anne Phillips, ‘which (in)equalities
matter’? (1999). Finally, how does the general social position of women
in society affect their participation in the political process? Is the delibera-
tive process, rather than being more open to the participation of women
in politics, more inhibiting for women as they seek their voice? Would a
more secretive process of voting be better suited to their participation?
These questions are relevant for us as we balance an increased engage-
ment of women with governance structures on the one hand, and an
expanded sense of political participation through international women’s
movements and NGOs on the other. In this essay I have tried to ques-
tion the assumption that political participation is empowering per se for
women. I have reflected upon the complexity that a) differences among
women, b) engagements with institutions of power and c) the experi-
ence of participation bring to the discussion on political participation.
Political participation is, upon my reading, an important measure of the
confidence that women share in the development of states and polities.
It is however by no means measurable without taking into account the
changing context of our global society.
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2
European Citizenship: A Political
Opportunity for Women?
Ute Gerhard
Looking at the European integration process from a gender perspective,

two questions arise: What does Europe mean for women? And, what can
women expect from the European unification process? In other words,
what opportunities does the European Union offer women to influence
its policies and to participate in its bodies? Those who get involved in
this topic will be surprised by how much European reality already is
established – beyond the Euro and unnoticed in everyday life. This is
especially true for Europe as a legal community. Therefore, experts are
already talking about an ‘integration through law’ and an ‘integration
through citizenship practice’ (Wiener, 1999).
This chapter focuses on both of these aspects and starts with a short
introduction to the terminology of citizenship, particularly with respect to
its meaning in different political and historical contexts. Against the back-
ground of the diversity and particularism of European legal history the cur-
rent debates are both fascinating and demanding. Perhaps we might learn
from this history how to deal with these differences. I then give a short his-
torical insight into the gender of citizenship rights – the women’s case. I
focus on Europe as a community of law with respect to women’s gains and
losses, in order, finally, to discuss the question of whether European citi-
zenship might be an option for women. Here the question is whether and
how far the Draft Treaty establishing a Constitution for Europe considers
women’s rights. This aspect informs any discussion of the European inte-
gration process as a political opportunity for the empowerment of women.
The meaning of citizenship: terminology
Citizenship denotes a particular relationship between the individual and

the state. But the term has and has had different meanings in various
37
38 Ute Gerhard
historical periods and languages. The varied vocabulary shows that, at

present, it is not possible to define citizenship as a universal and abstract
category. Instead, in the broad theoretical discourse on citizenship we
have learned to distinguish not only meanings but also different dimen-
sions of citizenship:
Whereas in Anglo-American history the term citizenship implies both
status with participatory rights and membership in the sense of belong-
ing, in the Central European tradition we can discern a difference between
the legal status of an inhabitant/denizen of a community, city or state in the
simple sense of being situated or ‘belonging to’ (Staatsangehöriger), and
inhabitants/citizens, who are recognised as full members of a city or state
and participate in its authority or sovereignty (Staatsbürger). Only the lat-
ter would be a citizen in political terminology, as defined by Immanuel
Kant, whose legal theory influenced political theory for more than a
century: ‘Only the one who is entitled to vote and to take part in legisla-
tion is called a citizen (citoyen, i.e. citizen of the state, not only of the city/
bourgeois)’ (Kant, 1996: 458). In the same paragraph we find the often cited
statement concerning women: ‘Among those who have difficulties being
active citizens are, besides journeymen, servants, minors, all females,
everybody … who is compelled to earn his/her living at the disposal of
others’ (ibid.). The distinction between the Stadtbürger (inhabitant of a city
or bourgeois) and Staatsbürger (citoyen) governed European jurisprudence
throughout the nineteenth century. It distinguished between the citizen/
bourgeois as a private individual, entitled to civil (that is, private) rights
on the one hand, and the ‘citoyen’ entitled to political rights to take part
in government and sovereignty on the other. This distinction also mir-
rored the separation of the public and private spheres as well as the
systematic differentiation between public and private legal rights.
Another distinction is made between citizenship-as-legal-status, in
the sense of full membership in a particular political community, and
citizenship-as-desirable-activity with a greater emphasis on responsibilities
and virtues (Kymlicka and Norman, 1994: 353). This is also the distinc-
tion between citizenship as rights, with individual entitlements and
autonomy of the subject as core element of the liberal tradition on the
one hand, and attachment to a particular community with certain obli-
gations on the other: the communitarian approach. Others underscore
citizenship as a political obligation and discern three components as
offering distinct models of the citizen, namely citizenship as rights,
belonging and participation, identified as characteristics of the liberal, the
communitarian and the civic republican model. The latter is marked not
only by the capacity and right to participate as full and equal members
European Citizenship: A Political Opportunity for Women? 39
within the economy and polity, but also by obligations linked to taxation,
military conscription and the duty and ability to perform paid work and
to contribute to national social insurance schemes (Bellamy, 2004: 7).
Beside the fact that these ideal types never occur in reality in a pure form,
it is apparent that all these conceptions are modelled on predominantly
male criteria. Given the sexual division of labour, the ideal citizen of clas-
sical republicanism belonged to an exclusive minority largely freed from
the necessity of labour and unencumbered by demands of everyday life
(see Lister, 1997: 32). Correspondingly, the freedom to earn one’s own liv-
ing, not ‘at the disposal of others’ (Kant’s definition) or to own and
acquire property, the liberal approach, throughout the nineteenth century
until the middle of the twentieth, was granted to male legal subjects or
heads of household only, whereas women’s work inside the home, car-
ing for others – hidden, but indispensable for the common good and
welfare – did not count, or did not entitle women to act as citizens.
In her critical synthesis of the different approaches, Ruth Lister offers an
illuminating ‘reconstruction’ of citizenship from a feminist perspective:
Citizenship is thereby understood as both a status, carrying a set of

rights including social and reproductive rights, and a practice, involv-
ing political participation broadly defined so as to include the kind of
informal politics in which women are more likely to engage. The rela-
tionship between the two elements is a dynamic one which is fired by
the notion of human agency.
(Lister, 1997: 196)
The modern conception of citizenship emerged with the social and polit-
ical transformations of the American and French revolutions together
with the Industrial Revolution. The freeing of individuals from subjec-
tion, from subjecthood to feudal authorities, to an emancipated subject
of civil society was, according to different historical contexts, a complex
process that had taken place through the rule of law, particularly the free-
dom of contract and the guarantee of property rights. It was tightly con-
nected to the emergence and development of the nation-state, which
means it is and was exclusive with regard to a culturally and legally con-
structed nationality; it was always tied to a particular territory and
authority. Therefore, the question is: how can a European citizenship be
envisaged that transcends national boundaries? European citizenship has
been at issue ever since the Maastricht Treaty of 1992 used the legal term
citizen of the Union and stated that a ‘citizen of the Union is, anyone who
is a citizen of any of the member states’ (Art. 8). Although the Amsterdam
40 Ute Gerhard
Treaty of 1997 later specified that ‘Citizenship of the Union shall com-
plement and not replace national citizenship’ (Art. 17), the nature of
European citizenship remains contested, especially in the face of inter-
national migration and increasing numbers of refugees and asylum-seekers.
Before going into this, I want briefly to discuss the gendered aspects, bar-
riers to and steps of women’s citizenship in an historical perspective.
Gendered citizenship: an historical approach
The systematic exclusion of women from the public sphere and their
inclusion in the private sphere was neither coincidental nor merely a
remnant or leftover from the past, but constitutive of the way civil soci-
ety functioned. The public/private division as a main structure of a liberal
civil society maintained inequality for women in and because of the fam-
ily as an inherent contradiction. Beside ‘private’ law (otherwise known as
civil law) exclusion from citizenship was organised by a broad range of
political measures that formed part of public law. Corresponding to the
double foundation of civil society and its hidden base, the family, reasons
given for women’s subordination derived from the subordination of
women, legitimised by private law, especially by family law, on the one
hand, and on the other, the exclusion from citizenship organised by a
broad range of political measures which were part of public law.1
Refusing to grant women citizenship status, and thus denying them all
public and political rights, was, from a legal perspective, closely tied to the
‘special role’ women played in the family, according to civil society the-
orists. ‘Women are the representatives of love, just as men are representa-
tives of law in a general sense’ (Conversations-Lexikon, 1817–1819, 2: 789).
This condensed gender assignment hit the nail precisely on the head with
respect to civil society.
Carol Pateman has elaborated the systematic meaning and relevance
of the marital contract in political philosophy, regulated by a particular
contract, the ‘sexual contract’ (Pateman, 1988; 1989). Although I do not
agree with all her conclusions, because she posits a ‘sexually differenti-
ated citizenship’, it is still worthwhile re-reading the core reflections of
civil society’s key thinkers to understand what love has to do with limi-
tations on women’s rights (see also Gerhard, 1978; 2001: 22ff., 154).
Whereas classical natural law scholars were able to leave matrimonial
law to custom, the pressure for legitimacy grew towards the end of the
eighteenth century. This becomes apparent following the reflections of
Johann Gottlieb Fichte’s Grundlage des Naturrechts nach Prinzipien der
Wissenschaftslehre, written in 1796. Fichte is mentioned here because his
‘Deductions from Natural Law’ are paradigmatic of the liberal way of legit-
imising the gendered order of civil society. Moreover, his argumentation
had – like Jean-Jacques Rousseau’s philosophy of gender (Rousseau, 1911
[first published 1762]) – a lasting impact on continental legal theory and
the practice of family law. Fichte justified the ‘subjection’ of woman and
the husband’s ‘right of compulsion over her’ according to Rousseau’s gen-
der model (Fichte, 1970: 441). Regarding the civil and legal status of
women he concluded: ‘since only a self-determined, free subject can real-
ize the concept of right, that is, can restrict its freedom through the possi-
bility of another’s freedom’ (ibid.: 76–8), ‘[woman’s] continuous necessary
wish … to be so subjected’ excludes her from all individual rights. ‘Her
husband is, therefore, the administrator of all her rights in consequence of
her own necessary will’ (ibid.: 441).
The legal framework anchoring this gender-based inequality was the
marriage contract, which in a liberal society was more contradictory than
ever. For this point on marriage was conceptualised not only as a con-
tract, which ideally demanded the ‘free will’ of the woman, but also as a
natural and moral institution, which meant it existed irrespective of the
will of the partners and could not be dissolved. Significant, though, was
the new, modern motivation for marriage. Bartering and economic calcu-
lation were replaced by love, perceived as mutual yet unequal. However,
Fichte’s acknowledgement of this thoroughly ‘modern’ emotion by no
means signified greater self-esteem, self-realisation and emancipation for
women. Rather, it implied consent to subservience and subordination to
the will of the man. This was very different from the gender philosophy
of early Romanticism, which developed at the same time. For writers like
Friedrich Schlegel and Friedrich Schleiermacher, the experience of love,
both sensual and intellectual, created the prerequisite for woman to
escape social convention and follow her destiny as a human being
(Nowak, 1986: 284).
Both Rousseau and Fichte derived the bourgeois-patriarchal argument
for the legitimacy of female subordination from a typology of the sexual
act. In Rousseau’s pedagogical novel Emile (Rousseau, 1911) we read in
chapter 5 under the heading ‘Sophy, or Woman’:
In the union of the sexes each alike contributes to the common end,
but in different ways. From this diversity springs the first difference
which may be observed between man and woman in their moral rela-
tions. The man should be strong and active; the woman should be
weak and passive; the one must have both the power and the will;
it is enough that the other should offer little resistance. When this
42 Ute Gerhard
principle is admitted, it follows that woman is specially made for

man’s delight.
(ibid.: 322)
Interestingly enough, this connection between a specific sexual behav-

iour, described as ‘natural’, and the social order governing men and
women – and thus the connection between love and state theory – was
going to play a central role in political theory. Although such polarising
characterisations – male/female, active/passive – represent a near-unbroken
pattern of thought in western philosophy, it was new to take the gender
roles thus defined to such extremes, assigning women to the sphere of love
and morality, as opposed to law. Fichte and Rousseau have since been criti-
cised and analysed thoroughly from a feminist perspective.
The exclusion of women from citizenship was not only organised by
family and marriage law as the hidden base of civil society, regulated by
a particular contract, the ‘sexual contract’ (Pateman, 1988 and 1989;
Gerhard, 1990/2001, 22ff., 154). An explicit barrier to women’s political
participation in the public was a broad range of political measurements
which were part of public law. It is noteworthy that the story of women’s
exclusion from participation in power and sovereignty refers not only to
their long-term exclusion from the franchise, but also to implicit and
explicit limitations and gender-related discriminations which have
accompanied the history of women’s movements for 200 years and pro-
voked mobilisation and numerous initiatives and policies. For instance,
through various bans on the formation of political associations by
women or their simple participation in assemblies dealing with political
issues (see e.g. the association laws in Germany, Austria, Hungary and
Italy after the failed Revolution of 1848) women were explicitly excluded
from participating in the public sphere and from political representation.
These barriers were all the more grave as bourgeois society drew its demo-
cratic legitimacy from this new ‘type of social organisation’, from associ-
ations and voluntary organisations of civil society (see Nipperdey, 1972;
Dann, 1976).
It is therefore remarkable how bluntly lawyers and political theorists
continued to justify this exclusion even at the end of the nineteenth
century. This was not only about the preservation of the gender-related
division of labour and sex roles, or simply about the consistently
emphasised protection of the family, but also about the idea that ‘the
written law, as well as customs have always been against the admission
of women to political power and still are’ (Ostrogorskij, 1897: 40; see
also Gerhard, 1997: 526). In a comparative study of the role of women
in public law at the end of the nineteenth century titled History and
Legislation in Civilized Nations, awarded a prize by the Parisian Faculty of
Law, Ostrogorskij legitimises these traditional/patriarchal opinions by
giving an informative survey of legal dogma and leading opinion, court
cases and controversies across the ‘civilised world’ as influenced by the
women’s movement and its activities. The author did not limit himself
to legal postulates, but referred to common sense as expressed in innu-
merable essays, tracts and, not least, in encyclopaedias of the era. He
found the same arguments everywhere: even if the term ‘woman citizen’
or ‘citoyenne’ was often used, for Ostrogorskij the concept offered noth-
ing whatsoever on women’s participation in politics. Even the most
advanced liberals who defended ‘recognition of women as citizens’ and
urged elimination of tutelage found it unthinkable that women be
granted the right to vote, their continued exclusion was seen as ‘the sin-
gle limitation derived from the customary position of women in the
family or from her subordination under the man’s decision-making
power: Whoever is entitled to decide to go to war, he must be in a pos-
ition to fight’ (Welcker, 1847, 5: 668–70). The traditional argument that
women cannot bear arms appeared to present an insuperable obstacle
whereas, in reality, the social contract and representation of the people’s
will had long replaced military prowess, let alone the authorisation to
duel as a precondition for voting rights.
The concept of ‘citizenship’ as agency, however, allows us to reconsider
the different spheres where participation and cooperation occur within
civic society. Women – not least because they had no other choice – used
less formal relationships, means of social service and their involvement
in social reform for civil rights activism and thus transcended the narrow
limits of the private sphere to enter public life. Their ‘practical social
work itself actually provided a back-door through which women slipped
into public life’ (Klein, 1971: 17).
By overcoming obstacles, women’s movements in different nations
and phases have frequently demonstrated their acumen in political
action by means of various arguments, strategies and social practices.
Initially, and for the most part, they made claims for the equality of all
humans, yet also emphasised differences – the different way of living
and different experiences of women. Women’s rights activists at the turn
of the twentieth century, for example, legitimised their programme
as ‘organised motherhood’, which ‘sends women not only to day care
centres, kindergartens and schools but also to parliaments’ (Zahn-Harnack,
1928: 77; cf. also Sarvasy, 1994: 306f.). This was a strong point in the
face of patriarchal means of domination all over the world. At other
44 Ute Gerhard
times criticism was based on the inadequacies of policies that lacked

solidarity and consideration of care for others, which is why feminists
even today argue for a re-conceptualised notion of ‘democracy as prac-
tice of care’ (Tronto, 2000: 25f.). Thus the eventual success story of these
movements in the twentieth century must be seen as a very dynamic
and open-ended process, which permanently extended and changed the
space of the political sphere. The aim of the claim for self-determination
and political participation does not and did not ever mean becoming
similar to men or ‘the same as men’; rather it meant making freedom a
possibility for different human beings and making relevant experiences
that had been uttered as experiences of injustice. Meanwhile it is
emphasised again and again that the theoretical as well as the practical
process of ‘re-gendering citizenship’ is all about the transcendence of
false dichotomies: ‘beyond equality versus difference’ and ‘beyond an
ethic of justice versus an ethic of care’ (Lister 1997: 91f.).
Women’s rights within the legal framework of the

European Union
The European Community (the European Union (EU) since 1992) has,
since its foundation nearly 50 years ago, evolved into a community of
law that is guaranteed by various institutions. Even though its codes of
law are very complex and frequently not very transparent, they increas-
ingly determine the everyday life of all EU citizens. Experts even agree in
the assertion that the European Community has been a particularly
active contributor to legal advances made to improve the situation of
women in Europe (an exception can be found in the Scandinavian coun-
tries) (Meehan, 1993; Hoskyns, 1996; Hubert, 2001: 145). The history of
European gender-related policies begins with Art. 119 of the founding
Treaty of the European Economic Community (EEC) of 1957, which
explicitly inscribed the principle of ‘equal pay for equal work’. But in the
next twenty years the regulation was rarely observed. Article 119
prompted public attention only when Belgium female workers in the
Herstal equal pay strike of 1966 referred to it to add force to their
demands for better wages, and two years later when the Belgian stew-
ardess Gabrielle Defrenne sued the airline SABENA for equal treatment
(Hörburger, 1991; Hoskyns, 1996: 40f.). In particular, the judgment of
the European Court of Justice (ECJ) in the second Defrenne case in 1976
had a far-reaching impact, since the Court ruled that Art. 119 is directly
applicable in each member state and that non-application is a violation
of community law (ECJ Case 43/75 Defrenne II, 8 April 1975), thus
enabling every man and woman to refer to this Community law in the
courts of their own country. At that time, in which the second wave of
feminism, together with the first World Conference on Women 1975 in
Mexico, was changing awareness of sex discrimination and when the
first ‘enlargement’, with three new member states (UK, Ireland and
Denmark) was taking place in 1973, women’s and gender issues were
pushed onto the political agenda. At the same time, the groundwork was
laid to carry on gender-related policies on a European level.
In 1976 the Directive on the ‘application of the principle of equal pay
for men and women’ came into force, which, among other things, defined
that this principle should apply not only to equal work but also to work of
equal value (EEC, 1975).
During the 1970s and 1980s the European Commission took a num-
ber of initiatives to advance the equal treatment of men and women at
work, which led to the introduction of further Directives, for example
the Directive regarding ‘access to employment, vocational training and
promotion, and working conditions’ (EEC, 1976) or the Directives on
the equal treatment in statutory or occupational social security systems
(EEC, 1979; 1986a; 1986b). For the first time, these Directives contained
an explicit interdiction of indirect discrimination, while the ECJ pro-
ceeded to a wider interpretation of Art. 119 and punished indirect dis-
crimination in these cases as well. In these and other cases the ECJ
played a crucial role in enforcing the Directives on the equal treatment
of men and women. On the one hand, the ECJ has increasingly guaran-
teed the right to take action in the courts and established far-reaching
standards for the interpretation and application of the principle of equal
treatment. On the other, it has the task of exerting control jointly with
the European Commission: other than recommendations, Directives
have a binding character and have to be incorporated into domestic law
within a certain period of time. In the past, again and again, the
Commission has had to take action or at least had to threaten such a
step because member states have missed deadlines for adjusting domes-
tic law or because they have implemented insufficient legislation.
In spite of this success story feminist criticism refers consistently to
the fact that all achievements remain focused on paid work and thus
follow the logic of the common market. As far as the reconciliation of
family and professional life is concerned, progress is much slower.
Caring needs and responsibilities still seem to be private issues and are
ignored as ‘non-market appendage[s] of a labour-market participant’
(Lewis and Ostner, 1994: 178). Meanwhile, the Directives on ‘the pro-
tection of pregnant workers and workers who have recently given birth
46 Ute Gerhard
or are breastfeeding’ (EEC, 1992), on parental leave (EC, 1996) and part-
time employment (EC, 1998) establish a minimum legal standard. Still,
these Directives address the working population only, and thus also
focus on paid work, which characterises the social policies of the EU and
has prevented a more comprehensive consideration of care work.
The Amsterdam Treaty of 2 October 1997 (which replaced the
Maastricht Treaty, 1992) has meanwhile created a new legal base for
European gender equality policies. The Treaty confirms the principle of
equal pay and treatment at work (Arts. 137 and 141) and explicitly allows
for ‘measures providing for specific advantages’ (that is, affirmative
action) in order to support the ‘under-represented sex’ (Art. 141, Par. 4).
Article 2, in combination with Art. 3 (2), moreover, provides that promot-
ing gender equality is the binding task of all activities of the Community,
and thus introduces the concept of gender mainstreaming to the EC
Treaty. At the same time, the European employment strategy, launched at
the Luxembourg summit in 1997 and laid down in annual employment
guidelines, country-specific recommendations and national action plans,
sets up the strengthening of equal opportunities as one of its four pillars,
alongside the objectives of raising employability, adaptability and entre-
preneurship. Thus the Amsterdam Treaty enlarged the European mandate
on gender equality in a crucial manner, especially since it sought to guar-
antee the promotion of gender equality under Art. 2 of the Treaty in com-
bination with Art. 3 (2) ‘in all activities referred to in this article [these are
21 activities ranging from a common trade policy to environment, educa-
tion, health protection or technical development, agriculture, transport or
development policies]’ (Hubert, 2001: 157). However, the effect of these
new provisions on gender equality remains open-ended, since the Draft
Treaty for a European Constitution, drawn up by a European Convention
under the presidency of Valéry Giscard d’Estaing and presented to the
European Council during the meeting at Thessaloniki in June 2003, is still
contested and has yet to be ratified by all 25 member states.
European citizenship – The Draft European

Constitution as a trial run
The Draft European Constitution defines EU citizenship in the same way

as the Treaty of Amsterdam and the draft therefore confirms the word-
ing and its contents: ‘Every national [sic] of a Member State shall be a citi-
zen of the Union.’ Listed are the rights to move and reside freely within
the territory of the member states, the right to vote and stand as a can-
didate in elections to the European Parliament, diplomatic as well as
consular protection and a right to petition the European Parliament

(Art. I-8). But what does this mean for the implementation of citizenship
rights in a much broader sense? As mentioned, EU citizenship does
not replace national citizenship; explicitly it ‘shall be additional [to it]’.
Therefore, Union citizenship does not entail citizenship in a European state
in the sense of a people or sovereign, for to date the EU Constitution does
not rely on the will of the people nor is the representation of citizens in
the European bodies democratically resolved. The Draft tries to improve
the democratic deficits, but the citizenship issue touches on fundamental
questions concerning the institutional character of the European Union.
So far, the Union is neither a state nor an ensemble of contract partners; it
is a trans- or post-national body in its own right. Commentators therefore
use the concept of post-national citizenship based on justice (Habermas,
1998), and on the Union as ‘a space for freedom, security and the rule of
law’ (see Amsterdam Treaty, Art. 2 as well as the draft for a European con-
stitution), rather than on nationality or statehood (Bellamy, 2004: 2).
Some believe these circumstances open up new possibilities for extending
citizenship to new groups of people and spheres of social and political life
beyond the state in ways that will lead to a fairer world (Soysal, 1994). The
Charter of Fundamental Rights of the European Union, which was agreed
by the European Council in December 2000 and proclaimed as a first step
towards a European Constitution (it is now included into the constitu-
tional draft as Part II), places the EU’s citizenship provisions within the
broader European context that promises to guarantee human rights as a
basic individual right.
Political scientists analysing the dynamics of European integration dis-
cover alongside a new community of law (‘integration through law’) a par-
allel process of integration by means of formal and informal practices of
civic rights (integration through citizenship practice) (Wiener, 1999: 272).
Part of this citizenship practice is the so-called acquis communautaire, a
technical term that is also used in the text of the treaties. It signifies the
active property of rules, but also court decisions, agreements and all forms
of collaboration, which can be formal as well as informal ways of doing
things, forming opinions and enacting practices. Emphasis is put espe-
cially on informal practices and discourses of civil rights, on social
movements, particularly the women’s movement as well as NGOs and
transnational policy networks as key features of civil society. Others men-
tion the European Women’s Lobby and woman activists in official bodies,
e.g. the Women’s Rights Committee of the European Parliament or the
network on Women in Decision-Making, for it became apparent that the
‘democratic deficit’ of the EU was and is first of all a gender issue. ‘For both
48 Ute Gerhard
political and socioeconomic reasons, gender equality is linked to the

future of the European Union’ (Hubert, 2001: 156).
There is, therefore, no cause to idealise the situation. Also when we look
at the representation of women in European institutions and decision-
making positions, the gender disparity flies in the face of any equality
rhetoric and gender mainstreaming policy. Although the proportion of
elected women in the European Parliament is even higher than in most
member states, except in the Scandinavian countries (2004: 30.3 per cent),
women’s participation in committees, positions of power and decisive
bodies is less (chair persons in political groups: 20 per cent in 2004,
http://www.womenlobby.org/parl6th.htm). Again, the composition of
the Convention, which has drawn up the draft European Constitution,
proves that a critical mass is necessary to represent and defend the inter-
ests of an under-represented group, especially when gender issues are on
the agenda. The Convention was a gentlemen’s club: only 17 out of a total
of 107 members were women. The gender gap, to many observers, is one
reason why the Draft Constitution in various respects offers less than the
Amsterdam Treaty or remains vague and insufficient concerning women’s
issues (Mateo, 2004).
Single provisions in the Draft confirm the terms of the Amsterdam
Treaty, for example Art. 141, the former famous Art. 119, now reads:
‘Equality between men and women must be ensured in all areas, including
employment, work and pay’ (Art. II-23). However, active promotion of
women is formulated in negative terms only, as an exceptional possibility,
not as an inducement. Instead ‘positive measures’ should be prescribed in
order to achieve substantive gender equality. Moreover, it is remarkable
that in Art. I-2, sub-titled ‘Union’s values’, ‘equality’ is listed among other
values, e.g. ‘dignity, liberty, the rule of law’, but not explicitly as ‘equality
of men and women’. Gender equality, however, is mentioned in Art. I-3,
sub-titled ‘Union’s objectives’, but here again equality is reduced to for-
mulations of social exclusion and discrimination. This, once more, is a
negative defence, not a demand for positive action and promotion. To
hint at another critical point: in Art. II-52 under the heading ‘General pro-
visions governing interpretation and application’, there is a typical gate-
way for traditional and systematic exclusion of women’s needs and
interests. Following the wording that all fundamental rights ‘shall be
interpreted in harmony with … traditions … common to Member States’,
gender experts can imagine the consequences. The contradiction between
the emancipation of women and adherence to traditional values has
always been the main obstacle blocking the implementation of women’s
rights. Finally, what is essential but nevertheless totally absent in this
promising Draft are all those important concerns that the new feminist
movement put on the political agenda as inalienable women’s rights,
which are recognised and confirmed by UN Conventions and in the inter-
national as well as European human rights discourse: women’s repro-
ductive rights and freedom and protection against violence. Feminist
initiatives and civil rights activists were not listened to, nor did they
receive answers to their questions in the public debate about the constitu-
tional treaty. One critique was that the constitutional project ‘promotes
the right of marriages and the right to found a family, but is silent on all
forms of violence committed against women. At the same time, it doesn’t
mention anything about the right to contraception, abortion or divorce’
(see http://www.penelopes.org).
At present, since the process of ratifying the Draft Constitution was
halted by the ‘No’ vote in the French and Dutch referendums and the
British postponement not only are detailed questions concerning
women’s rights still open, but the European integration process as a whole
is in crisis. To assess this development is a political question. There might
be different political traditions and experiences with constitutional agree-
ments in Europe. In any event, from a gender perspective, any agreement
and confirmation of individual rights instead of customs and traditional
gender practices offer opportunities for women. Therefore, the question of
whether this European integration process to date has ‘failed women’
(Klausen and Maier, 2001) in my opinion has to be denied. With regard to
the integration already achieved through law and citizenship practice,
women in Europe have more to win than to lose. Therefore, a new and
broader debate about a European constitution has to be taken as an oppor-
tunity for intervening on multiple levels of European civil society and the
political public. The EU as a democratic project remains a trial run for
activities of civil society and also as a political empowerment structure for
women. In Europe, the women’s movements bring in political and his-
toric experiences, which are essential for building European citizenship
rights. They have introduced new standards of justice to the European
agenda. There is no doubt that new forms of intervention and new forms
of coalition-building are necessary, which transcend national limits and
practice active citizenship.
Note
1. The distinction between private and public law – not familiar to common
law – stems from Roman law and governs continental jurisprudence. Private
law refers to relations between individuals with which the state is not directly
50 Ute Gerhard
concerned. Its central plank, freedom of contract, rests on the supposition

that both/all partners are free and equal to make the agreement, whereas pub-
lic law regulates relationships between authorities, the government or officials
and a subject in a hierarchical relationship. The private law doctrine of free-
dom of contract, however, was contradictory and contested not only with
regard to employment relationships, but particular in family law where the
husband in all civil rights legislation until well into twentieth century was
considered to be the master and head of the household (see e.g. Steinmetz
2000 for elaboration).
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3
Can Feminism Survive Capitalism?
Challenges Feminist Discourses
Face in Promoting Women’s Rights
in Post-Soviet Europe
Sirkku K. Hellsten
Introduction
This chapter examines the role of feminism and women’s rights move-
ments in today’s Europe. It pays particular attention to the role of Western
feminist discourse in relation to the women’s movements and women’s
rights protection in Eastern and Central Europe. The purpose is to set
women’s rights advocacy in relation to the further integration of Europe,
and the issues of social justice related to the expansion of the European
Union (EU). The chapter takes a critical look at the fragmented stage of
European feminist discourse per se by discussing feminist influence and
women’s role in the practical and ideological unification and reconstruc-
tion of post-Soviet Europe. This theoretical analysis is reflected against the
practical promotion of women’s participation through civil society
activism and formal political positions. The main research question asked
is whether theoretical feminist discourses and practical, political women’s
rights promotion can go hand in hand in contemporary Europe in prac-
tice and help women in post-Soviet Eastern and Central Europe gain a
stronger voice in national and trans-European integration policies.
Background
During the last decades there has been active dialogue between the
global North and South on women’s rights as well as on particular
approaches to feminism and their normative political and social agenda.
Non-Western, postcolonial third world feminism as well as the feminist
53
54 Sirkku K. Hellsten
discourse of women of colour within the United States have criticised

Western feminism for its cultural hegemony. The main focus of critique
has been the abstract liberal illusion of a ‘global sisterhood’ that can be
enhanced by the traditionally Western universalistic thinking which
focuses on procedural justice and individual rights. The third world and
non-Western feminist discourses have pointed out that the Western ten-
dency to focus on universal moral principles and the methodology of just-
ice tends to erase important differences in power and access to resources
not only between men and women, but among women themselves com-
ing from distinct races, ethnicities, nationalities and historical settings.
Thus, within contemporary feminist argumentation we can detect an
internal fragmentation between individualist and communitarian trad-
itions. Particularly women from non-Western, or in general from origin-
ally more collectivist, cultures are left to defend their traditions against
liberal feminists who base their battle for women’s right on the individu-
alist approach. At the same time, however, they want to try to improve
women’s position within their own traditions. The third world feminist
discourse has critically challenged the idea that there is any intrinsic soli-
darity of ‘universal sisterhood’. Instead, women can be just as discrimin-
ating, demeaning and biased when it comes to granting full equality to
women in other cultures, different traditional value systems and differ-
ent ways of thinking about the place of women in social context and in
relation to set gender roles (see, for example, Mohanty, Russo and Torres,
1991; Narayan, 1997; Bulbeck, 1998; Narayan and Harding, 2000).
This debate between Northern and Southern feminists has brought out
discussion on identity, difference, race, social status, power relations and
various colonial histories to ‘world feminism’ as well as to world politics. It
has also influenced many global development policies and projects, par-
ticularly in the developing world. It has also helped the Western feminist
discourse to reorient itself to recognise difference and marginalisation, not
merely between sexes, but within the gender discourse and in action aimed
at realising social and gender justice in a global context. It has also led to
further empowerment of women in the South within their distinct cultural
contexts and to understanding the value of local knowledge. Nevertheless,
until very recently this debate on difference and power, internal to the femi-
nist framework, has focused on the issues of race, ethnicity and traditional
culture as the basis of differences between women, rather than on the rela-
tionship between women’s rights and transitional political culture.
Thus, despite the rapid changes in social, political and cultural order in
post-communist Eastern and Central Europe until recently, there has been
very limited discussion on the relation between earlier socialist feminism,
Can Feminism Survive Capitalism? 55
post-communist feminism, Western liberal feminism and post-feminist

attitudes. Besides the theoretical debates on the role and structure of femi-
nist discourse, feminist voices of the Eastern European women’s rights
movements may listen less attentively to the Western feminists when the
local reconstruction and transition policies in Eastern and Central Europe
are decided, and vice versa. This appears particularly to be the case when
Western feminists account for the violations of the post-Soviet women’s
rights and advocate programmes that they see are needed in women’s
rights promotion, while feminist movements in post-Soviet countries are
trying to cope with the new socioeconomic development and women’s
place in it. In a sense the post-communist feminists are set between a rock
and a hard place: their views tend to be debated by both – the Western
liberal feminists as well as the post-Soviet liberal market economics.
The Network of European Women’s Rights (NEWR) project has shown
that across Europe there are fractions in feminist reasoning, which dis-
allow a cohesive promotion of women’s rights across the politically and
economically integrating Europe. These fractions also prevent a deeper
common understanding of democratic values and shared demands for
local, regional and international commitment to the realisation of these
values. Thus, in order to take women’s rights seriously, there is a need to
overcome the internal fractions of the feminist movement in Europe and
to bring the views on the best ways of promoting women’s rights closer
together. Women’s rights can be advocated only when we use women’s
ideological, ethnic, cultural and historical differences as strengths – rather
than as dividing features – in focusing on the wider issues of social and
economic justice.
Cinderella goes to the market, but does she know what to

buy and for what price …?
The uneasy relationship between Western and Eastern European feminist

discourses starts with the universalising nature of Western feminism,
which disregards the local contexts, generalises and scandalises informa-
tion. Feminist theorists in Eastern and Central Europe note that much of
the empirical work published in the West about the situation of women in
the former Eastern Bloc has predominantly focused on the extremely dele-
terious effects of post-communist reforms on women. It has discussed
some of the worst-case scenarios, focused on the most difficult situations
and relied on statistics that can be used to make hasty generalisations
about Eastern European women as a homogeneous group of victims of
socialist politics and post-socialist transition (Phehar, 2004: 145–52).
Women are presented as the losers in the recent transformations in post-

communist societies: they are shown to lose out socially and econom-
ically; not only are the failing economies cutting those social entitlements
that women had during the communist era, but also the underlying cul-
tural values and traditions that further enforce women’s suppression are
now emerging in many newly independent or transitional countries.
Western liberal feminists tend to point out that Eastern European transi-
tions have brought in ‘male democracies’. With the collapse of the state
socialism of the Soviet era, the position of women has deteriorated and
Eastern and Central European democracies are suffering the ‘resurgence of
patriarchal discourses’, which include both capitalist exploitation of
women and women’s suppression by ethnic nationalism and religious
conservatism (Einhorn, 1993; Platek 2004: 5–25; Rueschmayer, 1994: 226;
Moghadan, 1995: 348).
When set in the global context, Western liberal feminists appear to
have created yet another category of the ‘victimised’ and ‘helpless’
women living in suppressive social, economic and political conditions
that they cannot change. Much in the same way that women in the
South were at one time categorised as passive victims of the forces of cul-
ture, economy and politics, women in post-Soviet societies are now seen
as victims of the economic and social forces they can neither control nor
fully understand. This view of liberal feminism hastily generalises
women’s experiences, and ignores their role in different national and
political histories. It is also based on biased knowledge, which in the
Foucauldian sense categorises its objects according to Western norms,
values and standards. Thus, knowledge on women in formerly socialist
states always remains knowledge about the ‘Other’. This ‘Other’ is ‘the
object of knowledge’ which is different from the subjects of knowledge
that is ‘us’, the Western women/women in the West, who see themselves
as the objective observers and thus, tend to think they ‘know better’
(Ghodsee, 2004; Phehar, 2004: 145–6).1
Feminists in various Eastern and Central European countries point out
that it is also often ignored that the downfall of the communist system
in the late 1980s did not bring merely negative effects to women’s
rights, as the Western studies might have led us too easily to believe.
There are now also more opportunities for women in the former Eastern
Bloc to establish new groups and to mobilise others with similar policy
preferences in order to create pressures on the new political establish-
ments and take action on gender issues. In addition, post-Soviet women’s
rights advocates point out that the role of women’s movements during
the socialist era and after it should not be dismissed. In fact, today we
can witness a prolonged period of development of women’s and feminist

movements in the countries of the former Eastern Bloc. This era is marked
by the fundamental transformation of those very societies during the
socialist era when women participated in the class struggle and promotion
of social equality. Thus, socialism as a political system was not hostile to
women, but included gender equality in its ideal. Eva Fodor, for instance,
argues that the state socialist emancipation project was indeed successful
because it enabled more women to participate in various forms of
workplace authority than its capitalist-corporatist, apparently democratic
counterpart did and that women in socialist countries actually had a bet-
ter chance of career advancement than women in many more conserva-
tive capitalist countries. She points out in her comparative study on
women’s rights in Hungary and Austria that women in Austria could get
ahead only if they assimilated the male-biased norms of the ‘ideal worker’
by eschewing reproductive responsibilities, while in Hungary the work-
place and the promotion ladder were somewhat reconceived to enable
(if in a segregated manner) the presence of women, not as ‘imperfect men’
but also as wives and mothers (Fodor, 2004). In other words, feminism
was part of socialism in its equality discourse, unlike in capitalist societies
in which feminism had to find its way to the prevalent socioeconomic
system, which was, by its very nature, hostile to women. After the fall of
socialism, feminism has re-emerged in various forms across transitional
Europe and influenced women’s attitudes and promoted rights in all for-
merly socialist societies, but now in a more distinct form, looking for its
place in new socio-economic situation (Ostrowaska, 2004; Rymanenko,
2004; Susnik, 2004).
(Re)-emerging capitalism and gender equality
Despite the post-Soviet feminist critique of paternalism that is in-built

in liberal feminism, women’s rights activists in the post-Soviet Europe
admit that in many cases after the fall of socialist system women have
actually lost both their social entitlements and their political power.
Social entitlements are seen as relics of the former socialist egalitarian-
ism. Women’s role in politics, on the other hand, is weakening with the
fact that without these entitlements many women are forced to return
to take care of the home and family. When social security is withdrawn,
women’s responsibilities in the private sphere take over their participa-
tion in the public sphere. Simultaneously the tightening economy had
led quickly to vast unemployment. More women than men are now
unemployed, and fewer women get a good education. As a result there
are fewer women in high political or private sector positions, while more
women are reported as victims of domestic violence, trafficking, forced
prostitution, etc. (see for instance Micu, 2004: 163).
Finally, women’s rights advocates in the post-Soviet Europe have
admitted that not all generalisations made by Western liberal feminist
are hasty or prejudiced. It is possible to show that most, if not all, post-
Soviet societies have gone through similar (though not the same) experi-
ences during the transitional era. All former socialist countries have
suffered economic shocks that have reduced their capacity to collect rev-
enue, and thus challenged the basis on which state support rests. All the
new states have experienced some change regarding public enterprises
and welfare systems and employment levels that went with them. All
have also experienced political change with access to democratic ideas
which, on the one hand, grant greater freedom to organise, but, on the
other hand, have led to a resurgence of the earlier suppressed national,
cultural and religious identities and traditions, which may contribute to
women’s weakening position.
Thus, while the impact of all the transformations has been different
across the regions and thus the very term Eastern and/or Central European
women cannot cover the experiences and situations of women in various
countries, it might still be useful to try to draw some conclusions about
women’s relations to the state and to families in the new Eastern European
regimes in order to help women in the region share and compare experi-
ences during and after the socialist system (Phehar, 2004: 146–50; Wallach
Scott and Keates, 2004: 179).
In this context we face the paradoxical relationship between the uni-
versalistic agenda of Western feminism and the particularistic concerns
of local promotion of women’s rights. On the one hand, most of the cur-
rent movements are open to Western experiences, but at the same time
they search for their own conceptual prospects and development of
authentic practices. Some post-socialist feminists note that the ‘term’
feminism has become a ‘dirty word’ in the post-Soviet context. People
tend to equate it with radicalism rather than with democracy; it brings
conflict rather than social harmony. Feminism is also often seen as for-
eign propaganda rather than the improvement of local gender equality
and women’s political participation. Feminist ideologies are detested
by women outside academic and activists circles, and widely rejected by
common people who are just trying to get by and find their identity in
the midst of the turbulent transition (Micu, 2004). Neither men nor
women in transitional countries want ‘feminism’ as a new form of polit-
ical radicalism. They do not welcome the ‘feminism’ of the West, but see
it as yet another foreign ideological doctrine; nor do they encourage

‘indigenous feminism’. What people need are resources that help them
to organise their lives and to work together for common goals. What
women need are opportunities for equal participation and influence. All
in all, what everybody wants is a working democracy that delivers its
promises of equal participation.
Feminism, civil society and the politics of non-governmental

organisations in transitional societies
Democracy, however, has not fulfilled its promise in post-socialist prac-

tice. Thus, foreign assistance and intervention are needed in order to
build proper political and economic institutions and efficient infrastruc-
ture. Various governmental and non-governmental donor organisations
are engaged in helping the political and economic reconstruction of
post-Soviet Europe. When it comes to gender equality it is often Western
feminists and their non-governmental organisations (NGOs) that have
been employed by the multilateral and bilateral aid communities to help
women in former socialist countries survive the process of economic and
political transformation.
In many cases the Western feminist movements and their local coun-
terparts have adopted liberal ideologies in order to get the necessary
funds to improve women’s lives and to widen women’s participation.
This often results in the hope that the further integration of Europe can
provide even more protection for women’s rights in post-Soviet, transi-
tional societies. Particularly the EU accession states (new members as
well as those still in line for membership) have high expectations of
improving women’s formal rights with membership in the EU. These
positive expectations are often enforced by Western European feminists,
who sometimes present themselves – as well as Europe as a whole – as
the forerunner of women’s rights. While they may criticise the emerging
international, neoliberal economic policies for their traditionally patri-
archal nature, their own activities are highly dependent on these very
neoliberal policies. Ironically, then, both feminist and capitalist agendas
often go hand in hand with the Western aid and funding for local and
international NGOs, which, for their part, are harnessing local women
to build democracy with capitalism and a market economy in the name
of women’s rights promotion. (Ghodsee, 2004; Discussion in the NEWR
Workshop on Women’s Political Participation in Sofia, March 2004).
The problems are evident: first, feminism in/from the West appears to
be returning to its roots as ‘bourgeois’ liberal feminism, which tied the
feminist agenda to the wider value framework of the Western liberal

democracy and market economy. This connection, for its part, tends to
ignore the complex historical legacies and class struggles of socialist femi-
nism and does not necessary fit the cultural, historical and other local
aspects of post-Soviet societies. It then easily ignores the class struggles of
socialist feminism and focuses only on the problem of patriarchy as the
evil force in capitalism (Ghodsee, 2004). Consequently, when class strug-
gle is set aside and patriarchy is left to take the blame for the drastic reduc-
tion in living standards for women in post-communist societies alone,
attention is easily distracted from the wider structural adjustment policies
of the World Bank and the stabilisation programmes of the International
Monetary Fund (IMF), which are primarily responsible for the removal of
the safety nets that once supported women in both the former socialist
countries and the European welfare states and social democracies. The fact
that the support for women’s programmes and women’s NGOs in post-
Soviet Europe within transitional economies are themselves based on
international neoliberal goals works on two levels. On the one hand, the
private sector and civil society are taking over the earlier responsibilities
of the state and public sector such as childcare, education and care of the
elderly. On the other, it may simultaneously weaken grass-roots opposition
to these same neoliberal policies and to the dismantling of social welfare
by placing the blame for the drastic reduction in living standards for
women on the shoulders of patriarchy only. This also creates fractions in
the united front of men and women in fighting the root causes of poverty
and injustice.
NGO activity, then, is Janus-faced: while women’s increased political
participation is ‘the pronounced goal’, many NGOs are quite evidently a
part of an ‘anti-politics’ machine. They tend to create immediate tech-
nical fixes to various social problems and not to focus on the wider struc-
tural conditions in society that create those problems in the first place.
They emphasise women’s problems and isolate women’s struggles from
general social inequality. While funded by international aid agencies or
bilateral programmes NGOs are encouraged to be politically neutral and
to concentrate on issues that are independent of politics. Many women’s
NGOs tend to emphasise individual projects which address specific goals,
narrowly defined by the project sponsors, and avoid tackling larger
issues of economic injustice and inequality in society (Ghodsee, 2004).
Simultaneously, they may divert well-educated middle-class women away
from participating in formal political decision-making by providing rela-
tively secure personal income as well as guaranteed funding for concrete
smaller-scale projects, the immediate results of which are evident, even
though the long-term social impact might turn out to be less productive
for the promotion of women’s rights because the various self-help and
community programmes release the state from the responsibility of taking
care of basic social services. Involvement in civil society and NGOs has
long been women’s most common platform for political engagement and
change. In former socialist countries, women’s NGOs flourished after the
fall of communism and throughout the 1990s. In the Balkans, although
perceived as non-feminist, women’s organisations provided the most effi-
cient space for women’s empowerment (Blagojevic, 2003). Yet the process
that fostered the creation of all these women’s organisations did not take
place without problems. At the launch workshop of NEWR Barbara
Einhorn referred to her theory of the ‘civil society “gap” and indeed
“trap”’ (Einhorn, 2003). Einhorn argues that the civil society ‘trap’ relates
to the way women’s NGOs and grass-roots activist groups are filling
the vacuum that is created when the state withdraws from public service
provision.
Financial investments from international donors have contributed as
much to the mushrooming of women’s organisations as to their shift in
mandate or dissolution; while in post-communist and post-conflict coun-
tries, international aid has facilitated the involvement of many women in
the ‘reconstruction’ effort. Having to adapt to the resources available
meant that a considerable number of NGOs, as was the case in Latvia for
example, have shifted women’s activism and efforts from (or back to)
political groups to service providers. In Slovenia, only a few organisations
today focus on political change by paying attention to problems of the
new, market-based economic system and women’s status in it. In Hungary
only a few women’s organisations focus on women’s political participa-
tion despite the fact that there is a great need to have more women in
formal decision-making organs in order to influence the reconstruction of
the economic and political machinery in the newly structured European
context. Similarly, in Bulgaria women’s organisations tend to concentrate
on the charity sector and to be weaker in the political sector (Filipova and
Daskalova, 2003). One can recognise the phenomenon of the ‘NGO-
isation’ of feminism or, in other words, the ‘co-option of the feminist
agenda by the interests of the state’ (Einhorn, 2003). All in all, due to the
limited direct funds, the sustainability of women’s NGOs in post-Soviet
Europe is at considerable risk, with many of them disappearing after the
completion of a particular project.
Consequently, while foreign aid through women’s civil society organ-
isations might increase women’s grass-root participation, they simultan-
eously tend to keep women away from national and international
politics. Instead, they let capitalism remain the masculine and patri-
archal practice it was before women had any direct influence in politics
and in markets. All in all, while various critical feminist discourses in
Eastern and Central Europe are welcoming democratic ideals and
change, they rightly see the need to challenge the Western tendency to
universalise a set of capitalist values in one comprehensive package of
liberalism.
Therefore, there is a need to clarify the current relation between social-
ist feminism, post-socialist feminism and liberal feminism. Normatively,
socialist and Marxists feminisms advocated more comprehensive
changes in societal and economic power structures, but have lost their
plausibility with the fall of the socialist political and economic system in
practice. As elsewhere in a global economy, liberal policies are now
offered as the only feasible option for post-Soviet societies. The liberal
form of social Darwinism that has crept into politico-economic dis-
courses by trying to prove that only the strongest will survive, has also
taken over feminist discourse in Europe by setting different variations of
feminism to compete rather than complement each other. Within the
feminist discourse in Europe only the best one in practice will survive by
working closely together (and in harmony) with the global neoliberal
economics within the liberal ideological framework. The irony is, of
course, that in most cases the neoliberal market policies that have been
responsible for the very decline in general living standards both in tran-
sitional societies as well as in the Western European welfare states are
now actually giving Western feminist their mandates to help Eastern
European women (as well as women in the South) in the first place.
Conclusion
The paradox of feminism in contemporary Europe is that the various

feminist discourses in Eastern as well as in Western Europe are embedded
in their particular historical, socioeconomic frameworks and sometimes
appear incompatible to work together in current European political and
economic practice. Particularly in transitional societies, this makes the
situation for women’s rights advocacy confusing, to say the least. Post-
socialist feminism faces a dilemma whether still to believe in the values
of socialist solidarity, whether to tackle individualist liberal values from
within the liberal feminist framework (and by engaging in related NGO
projects), or whether to be post-Soviet, post-socialist and postmodern
altogether by declaring all ‘the great stories dead’ and turning to a more
anarchistic approach.
Western feminism, for its part, needs to be clear with its normative
agenda and avoid turning into a flagship for liberal democracy, which
provides a Trojan horse to smuggle in individualist and capitalist values
to replace the last remains of egalitarian ideologies, which – after all –
originally provided the most powerful ideological critique of capitalist
injustice and its negative impact on women’s rights.
Women’s movements across Europe need to unite in the global strug-
gle against poverty, inequality and injustice. This can be done only by
preventing liberal democracies from giving full ‘political’ authority to the
invisible hand of capitalist markets. More attention should have been
paid to the shrinking responsibilities of states in the care of children and
the elderly, equal access to education, health care, and equal opportun-
ities to employment and political participation. Without serious attempts
to integrate the different feminist discourses under the same normative
and practical agenda there can be no united front in the promotion of
women’s rights across integrating Europe. Instead, liberal feminism
remains a foreign import, while socialist and Marxist feminism is losing
its credibility and voice within the currently dominant neoliberal ideolo-
gies. This is despite the fact that feminist theorists and women’s rights
activists in Eastern and Central Europe have repeatedly noted that social-
ist egalitarianism provided women with much better social and eco-
nomic protection than the so-called individual rights of new economy
and liberal politics have succeeded in doing in the long run. If we take
seriously the experiences that women had in pre-transitional time from
socialist and communist heritage, we could find new ways to shape the
social policies across Europe in the future.
Thus, the final suggestion of this chapter is that women’s rights advo-
cates refocus on the wider structural issues such as the future directions
of liberal democracy and its economic policies. While it might be essen-
tial to teach women how to survive capitalism, it is at least as important
to unite – rather than assimilate – women’s movements across Europe,
and the world as a whole, in order to have more influence in the local
and global economic policies and move towards a direction in which
equality and social justice, rather than gender issues alone, are the com-
mon goals.
Notes
1. Naturally there are divisions and different trends of feminist thought within
Western women’s rights promotion (such as liberal feminism, radical femi-
nism, Marxist feminism, postmodern feminism, etc.), which disagree with and
challenge each other. Thus, no Western ‘liberal sisterhood’ is established at a

theoretical level, but nevertheless ‘the attitudes’ of Western feminists tend to
maintain their superiority in women’s rights advocacy. See Skjeie in this vol-
ume for a discussion of the idea that many Western societies are ‘almost there’
in relation to gender equality, and have set all the right methods in place, and
how this tends to undermine many other feminist approaches born in differ-
ent social, cultural and economic contexts and ignore how equality has had
‘the yielding duty’ also within the Western framework of liberal democracy
working within the competitive, capitalist environment.
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4
Citizenship, Civil Society
and Gender Mainstreaming:
Complexities of Political
Transformation in Central
and Eastern Europe
Barbara Einhorn
Introduction
The mission of building gender-inclusive democracies is far from

being fulfilled. … We must ensure that women’s voices are a vital part
of global politics. Simply put, if women are excluded from democracy,
democracy fails.
(Posadskaya-Vanderbeck, 2002: 7)
This chapter is concerned with the opportunities for and constraints on

the achievement of gender equitable political participation in Central
and Eastern Europe.1 I propose to focus on three areas, all of which illus-
trate the complexity of the issues at stake, the varying pace and scope of
change, and some of the factors influencing these changes. The three
areas for discussion are:
• the context of social, economic and political transformation across

the region of former state socialist regimes in Central and Eastern
Europe;
• contestations about the most pertinent analytical framework for
theorising the current situation;
• debates concerning the optimal strategies for the achievement of
gender equitable outcomes.
67
68 Barbara Einhorn
Clearly, the transformation process which the countries of Central and

Eastern Europe have been undergoing for the past fifteen or sixteen years
has been enormous. Far from representing, as much of the literature would
have us believe, a straightforward ‘transition’2 from one known economic
and political system cast as both hegemonic and homogeneous (commun-
ism or state socialism, coded negatively and hence rejected) to another
known system (capitalism and democracy, coded unquestioningly as a
homogeneous and positive good), this process has been extremely com-
plex, with outcomes on several fronts still unclear, especially in terms of
the costs and benefits of change. For most of these countries, the transform-
ation has involved several processes going on simultaneously: the transi-
tion from a centrally planned ‘command’ to a market economy with the
prioritised modality of privatisation; the transformation of a state socialist
to a liberal democratic political system; an enormous restructuring process
which included the shift from an industrial to a post-industrial economy;
and a move away from public social support and state welfare provision as
a result of the IMF-imposed neoliberal market model.3
Several of these processes mark the policy outcome, namely the polit-
ical abandonment of the socialist rhetoric of egalitarianism and social just-
ice in favour of the liberal discourse of individual liberty and (economic)
opportunity. The discourse of transformation has highlighted gains in
civil and political rights, while the process itself has been, in material
terms, almost entirely focused on economic restructuring: marketisa-
tion, interpreted as privatisation. Thus, as I shall argue in this chapter,
European Union (EU) accession, while embodying hopes in relation to
EU commitment to gender equality through gender mainstreaming, is
in practice a process of economic alignment and integration. In this
process, concerns not only for gender equality but also for citizenship
and social justice are marginalised.
Many of these processes have also been occurring in Western Europe,
both over the same period and earlier (in the UK since the beginning of the
Thatcher government in 1979), signalling the end of the post-Second
World War welfare state and its assumptions about citizenship being based
on social as well as economic and political rights. Nancy Fraser argues that
today, ‘the Keynesian–Westphalian frame is losing its aura of self-evidence’
(Fraser, 2005: 2). For her, this loss of self-evidence denotes the demise of
Western European social democratic welfare states as a result of neoliberal
policies, and simultaneous challenges to the nation-state as the unques-
tioned address for citizenship claims, as a result of supranational institu-
tions of governance such as the EU and the United Nations (UN), but also,
more powerfully still, of the growing impact of economic globalisation.
Citizenship, Civil Society and Gender Mainstreaming 69
The fundamental nature of the transformation in Central and Eastern

Europe has resulted in profound social as well as economic and political
dislocations. The relative retreat of the state from welfare provision
within the externally imposed neoliberal paradigm has exacerbated the
impact of economic restructuring (Steinhilber, 2002). Some of the nega-
tive effects have been huge increases in poverty and a widening income
gap (Daskalova, 2000: 339). Some authors would claim that one of the
most definitive effects has been the re-emergence of class as a social deter-
minant in the region (Gapova, 2002; Regulska, 2002). Economic losses are
presented as more than matched by new opportunities, in terms of both
entrepreneurship and the freedom (not always matched by the capability)
to organise politically. Yet in several countries the increased space for indi-
viduation and the establishment of differentiated identities has encour-
aged discrimination, marginalisation and – in extreme cases – conflict
based on ethnic or religious ‘otherness’.
The most significant factor of the transformation process from the per-
spective of a commitment to social justice is its intrinsically gendered
nature (Gal and Kligman, 2000a, 2000b; True, 2003b). Women have lost
economic rights and social entitlements that were theirs in the past, and
their newly won political rights seem up to now to remain largely paper
rights. Not only is the gap between rich and poor widening; so too is the
gender gap, across a wide spectrum: within the economy, in the polity, in
media representations, in nationalist and religious discourses, in terms of
reproductive and social rights, but also in terms of increases in the femi-
nisation of poverty (Daskalova, 2000: 342), in ‘trafficking’ (True, 2003b:
94–8)4 and in domestic violence. The political, economic and social
aspects of the transformation process were accompanied by a reconfig-
uration of gender dynamics. Indeed, understandings of what constituted
‘masculinity’ and ‘femininity’ shifted in a way that structured as well as
reflected the transformation process (Duhacek, 1998).
The context
The transformation process in Central and Eastern Europe and the for-
mer Soviet Union, in all its complexity and multi-layeredness, is occur-
ring within the framework of two further supra-regional transformation
processes, both of them exerting a direct impact on the shape and direc-
tion of change within the region. The first of these is globalisation, a
process setting East European workers and industries into the formerly
unknown global market. The impact on heavily feminised industries in
the region such as textiles has been immediate, with the loss of heavily
70 Barbara Einhorn
subsidised trade with the Soviet Union and competition with even
cheaper female workers in East and Southeast Asia. The second, currently
most significant, process is that of EU enlargement. Like the fall of the
Berlin Wall and the end of the Cold War that that has come to signify,
what is little recognised is that the process of EU enlargement and
European economic integration has implications for both sides of the
process, implying change in the West as well as in the East. Many of the
problematic issues in terms of women’s rights and gender equality that I
shall discuss in this chapter are of course issues that remain thorny and
to varying degrees also largely unresolved in pre-2004 EU member states.
The first round of enlargement, implemented in March 2004, inte-
grated the Czech Republic, Estonia, Hungary, Latvia, Lithuania, Poland,
Slovakia and Slovenia, but, due to a European Commission decision in
October 2002, not Bulgaria and Romania as originally planned. There
is currently, therefore, a very real danger that this process will create
second- and third-class European citizenship for those countries left out
in the cold, reinforcing already widening gaps between the ‘in’ group of
countries in Central Europe and the Baltic states, and the countries of
Eastern and South-eastern Europe (with the exception of Slovenia), not
to mention Belarus, Russia, Ukraine and Central Asia.
A second danger is that the EU’s exclusive focus on the economic sphere
will simply elide many of the most crucial problems of political participa-
tion and social entitlements faced by women in the region. In a confer-
ence paper, speaking on behalf of the KARAT Coalition of women’s NGOs
from the region, Regina Barendt stated: ‘If state intervention remains
limited to the labour market, as was the case under socialism, the most
immediate impact is to intensify the exploitation of women on the one
hand, and fail to alter the traditional gendered division of labour on the
other. We in the region have known this for 25 years, but it is only now
slowly gaining recognition in the EU’ (Barendt, 2002). The dangers for
gender equality inherent in the way that in the EU ‘from the beginning
the social has been subsumed within the economic and only given a sep-
arate focus when this appeared functional or necessary to economic inte-
gration’ has been identified earlier by Catherine Hoskyns (Hoskyns, 1996:
207), but not necessarily adequately addressed within EU policy.
Joanna Regulska maintained in 2002 that ‘the increasing privileging of
economic over social and political ties has further threatened CEE coun-
tries’ hopes for joining the EU as equal partners’. She found that the evi-
dence of negotiations around accession ‘reinforces the impression that
there is a lack of EU commitment to carry gender discourse as a part of
accession negotiations’. Furthermore, while the Polish government had
felt obliged, admittedly only in May 2001, to introduce ‘required legisla-

tion regarding equal pay and equal treatment of men and women’, this
was confined to measures in the sphere of the labour market, and ‘purely
instrumental’ (Regulska, 2002). Jacqui True documents the Czech ‘gov-
ernment’s failure to properly implement’ the equal opportunities legisla-
tion it introduced as an amendment to the Labour Law in 1999 for the
purposes of harmonisation with EU requirements (True, 2003b: 98–100).
On this evidence, it would seem that neither national governments in
the region nor the EU itself perceived gender as a key barometer of eligi-
bility readiness for accession.
The EU policy of gender mainstreaming – even in existing EU countries –
hides a lack of conceptual clarity in terms of meaning, intentionality and
purpose: is the goal, for example, equal treatment, equality of opportunity
or equality of outcomes? Does it necessitate equal opportunity legislation
or anti-discrimination legislation? Is there a problem in the fact that gen-
der mainstreaming is a top-down strategy? Might a crucial political edge
in terms of feminist goals of social transformation be lost through this
strategy? ‘Gender mainstreaming should not replace politics’ (Verloo,
2002). Nor should it be used to mask issues of women’s rights, or withdraw
funding from, or replace, measures of positive discrimination for women.
In practice, gender mainstreaming strategies, especially within the EU
context, are often formulated in terms of economic efficiency, hence they
are effective strategies for integrating women into the labour market,
rather than within a framework of political transformation towards the
goal of gender equitable societies.
Added to the lack of conceptual clarity is the fact that ‘almost all acces-
sion countries have commissions or departments on equal opportunities,
but, with very few exceptions, they hardly understand the concept, not
to mention the initiative they may take or the competence they have to
carry out activities in this respect’ (IHF, 2000: 17). In Poland, the Equal
Opportunities Officer appointed in November 2001 did not have an
automatic right to attend cabinet meetings, nor to insist that her recom-
mendations are translated into legislation or government policy. Initial
attempts by the Parliamentary Women’s Lobby to introduce a draft Equal
Opportunities Bill into the Polish Sejm, for example, met with laughter
and ridicule. As of 2002, the only country to have an ombudsperson deal-
ing with gender issues was Lithuania, which in June 2002 introduced
amendments to its 1998 Equal Opportunities legislation allowing resort
to ‘positive discrimination’ in order to ensure women’s rights (NWP/OSI,
2002: 14). There is a need, recognised in some existing EU member states,
for example Germany, for state institutions to institute a dual strategy,
72 Barbara Einhorn
combining gender mainstreaming policies with positive measures to

enhance gender equality.
Even where the formal mechanisms and legislation are in place, there
are questions about the level of implementation. As in Western Europe,
many of the countries in the region lack sufficient numbers of women
in positions of power in legislatures and in trade unions who are com-
mitted to gender equality and might ensure that the legislation, once
passed, becomes a reality. Again the Polish case is illustrative, suggesting
that compliance or non-compliance with the gender norms of EU legis-
lation was unlikely to impede, or delay, accession for those countries that
joined in 2004 (Steinhilber, 2002).
Moreover, there is a danger that EU enlargement might result in an
equalisation downwards, whereby women in Central and Eastern Europe
are forced to accept lower levels of female political participation, labour
force participation, childcare provision, pay equity or reproductive rights
than they were accustomed to. This was evident in some aspects of the
German unification process.
Analytical frameworks in question
I have argued above that an often overlooked outcome of the end of the
Cold War and, more recently, of the EU enlargement process too, is that
these processes involve change on both sides. The only aspect of this
which the British media – and politicians – manipulate is the fear of vast
hordes of East Europeans ‘taking our jobs’ or ‘sponging off the state’ in
Britain. Evidence that the health system would collapse without immi-
grants, that farms and factories would have to close without the seasonal
and short-term workers from Eastern Europe, is harder to get across.
Similarly, the fact that most Polish people who come to Britain for work
have no intention of settling here, thus paying into the UK social secur-
ity system without ever staying long enough to benefit from it, is seem-
ingly too complex a reality to be reflected in media portrayals or political
and populist discourse. What is important is to recognise that there is
mutual benefit to be gained from the movement of people resulting from
EU enlargement.
The mutual changes and two-way benefits of EU enlargement have
repercussions for both issues to be discussed in this section. Both issues
concern contestations around the appropriate analytical framework for
dealing with the impact of political transformation in Central and
Eastern Europe. The first question is whether the relevant frame for
rights claims in the era of EU enlargement (and the wider context of
globalisation) is the nation-state or supra-national institutions such as

the EU. The second is whether feminist theory, especially that perceived
as an import in Eastern Europe, has anything pertinent to offer in under-
standing the gendered ramifications of the transformation process itself.
The jury is still out on whether the nation-state has been superseded by
regional or international institutions in terms of its ability to confer citi-
zenship rights or implement human rights. Nancy Fraser argues that in
the post-social democratic era ‘it is no longer axiomatic that the modern
territorial state is the appropriate unit for thinking about issues of justice,
nor that the citizens of such states are the pertinent subjects’ (Fraser,
2005: 3). A special issue of the International Feminist Journal of Politics in
2004 is devoted to exploring issues of gender and governance in the era
of globalisation (Waylen and Rai, 2004). In it, Shirin Rai argues persua-
sively that ‘comparative feminist scholarship provides key insights into
the constitutive, gendered nature of the state in the global political
economy and thus challenges the “declining state” thesis’. She documents
the ‘decisive shift’ in the 1990s ‘from scepticism and caution towards
the state to an engagement with and embrace of state institutions’ on the
part of feminists. Of particular relevance to this volume is the centrality
of feminist efforts to change state policy, in part through arguing for
quotas for women in political institutions, as well as their engagement
with the policies of gender mainstreaming (Rai, 2004: 584, 586).
With reference to Eastern Europe, Joanna Regulska (2002: 11–12)
observes that ‘neither the official “sameness” imposed by the communist
political culture nor the “difference” engendered by differing degrees of
democratisation liberates women as fully participating political actors’.
She therefore poses the question: ‘Will the fact that women have not
found significant opportunities in formal, domestic political structures
make them more likely to search for alternative ways to act politically
beyond the nation-state?’ The successful international lobbying activities
of KARAT, a coalition of NGOs in Eastern Europe, might suggest an affirma-
tive response. Yet I am not entirely convinced that transnational institu-
tions are well enough established to supplant the nation-state’s role as
addressee for citizenship claims, at least not yet.
Whilst it is true that the existence of the European Court of Human
Rights has enabled some individuals within the EU to take their own gov-
ernments to court, this surely represents the exception. It also exempli-
fies the way that human rights discourse – and indeed liberal democratic
discourse – focuses on the individual, rather than on social groups,
whereas gender equality – despite multiple differences between women –
implies the need to overcome structural disadvantage, not mere individual
74 Barbara Einhorn
difficulty. Most women in Western Europe, whether they are exercised

about the continuing gender pay gap, the glass ceiling, occupational seg-
regation in all its forms, parental leave, domestic violence, lesbian rights,
the rights of migrant women or female asylum seekers, possess neither
the social nor the financial capital to access such supranational institu-
tions. For the majority, then, the nation-state remains the only address to
which they have access and are in a position to address their claims for
citizenship rights, social entitlements and greater social justice.
On the question of whether Western feminist theory has anything
positive to offer in the analysis of the transformation process, it has first
been necessary to acknowledge that women in Western Europe have
much to learn from the experiences of women in Central and Eastern
Europe, in other words our exchanges of ideas need to be genuinely two-
way processes. The very fact of diametrically different past experiences of
citizenship and political participation offers potential for throwing new
light on old issues in analysing gender injustices. Where gains in women’s
economic and political rights in Western Europe were hard won through
struggle against a liberal democratic state which proclaimed individual
freedoms, women in Central and Eastern Europe experienced a concep-
tion of ‘equality’ handed down from above by a paternalistic state, but
within a context in which everyone lacked individual rights and there
were no political and public spaces in which civil society associations
could function.
In neither case has gender-equitable citizenship status or even equal
political participation been achieved. There is therefore a great need for
the establishment – and/or expansion – of networks across the still exist-
ing ‘wall in our heads’, as Bärbel Bohley, a leading member of the oppos-
ition movement in pre-1989 East Germany, called it after the fall of the
Berlin Wall. A precondition for the kind of sharing that empowers both
sides is both the capacity and the willingness for mutual listening and
learning. One inspiring example within the region of such networking
and a ‘transversal politics’ in which women show willingness to listen,
learn, and work together while respecting their different locations and
not trying to erase their differences, was the cross-ethnic project coord-
inated by Cynthia Cockburn in Bosnia-Herzegovina (Cockburn, 2000;
Cockburn et al., 2001).5
Since the transformation process began, feminists in Central and Eastern
Europe have been at pains to stress differences, not only between coun-
tries within the region, but also in relation to what were perceived as
hegemonic Western feminist theories or colonising Western feminists.6
As Susan Bassnett noted early in the transformation process, ‘the general
assumption even among feminists seemed to follow lines ominously close

to those of the colonial discoverer’ (Bassnett, 1992: 12).7 Dasa Duhacek
ponders the difficulty of definition in constructing a theory relevant to the
needs of women in the region. ‘How do we speak of feminism which is
other than Western feminism, if not as a feminism which is the other to it,
which would presuppose Western feminism as the parameter?’ (Duhacek,
1998: 129).
Dasa Duhacek is one of several analysts who explain hostility to
Western feminism as the result of the different significance attached to
the private sphere and hence to the public/private divide in the region
(Duhacek, 1998; Einhorn, 1993; Gapova, 2001). Commentators from the
region see this as the main explanatory factor in East European women’s
resistance to Western feminism, which they interpret as women striving
for autonomy against men as opposed to the solidarity within the family
whilst it was a ‘rump’ civil society space and hence a kind of substitute
public sphere and site of resistance during the state socialist period
(Drakulic, 1992; Duhacek, 1998; Havelkova, 1993: 69; 2000; Jalusic, 2002;
Zhurzhenko, 2001a).
Despite these differences, several scholars from the region are now
modifying their stance, partly as a result of engagement – at international
conferences and in cross-regional European networks – in the difficult
but creative process of East–West feminist dialogue. Hana Havelkova
writes: ‘I believe that East European women tend to over-emphasise the
differences between Western theories and post-Communist realities …
attempting to protect their own authentic experiences against the invad-
ing feminist theory’ (Havelkova, 2000: 120). Judit Acsady (1999: 407)
analyses the media’s role in creating hostility to feminism as ‘Western
ideology’ that is ‘alien to Hungarian tradition’. Denise Roman speaks of
the ‘fallacious’ rejection of Western feminism by East European femi-
nists. Her view is that Third Wave difference-based feminisms hold con-
siderable potential for Central and Eastern Europe:
The very Western definition of gender as ‘socially’, ‘historically’, and

thus locally and contextually constructed (Scott, 1986), is indeed useful
as an analytical-theoretical tool for surveying gender relations anywhere
and anytime, … – even if the dynamic of patriarchy or women’s politics
[in any one country, at a particular moment in history] is revealed to be
specifically different, thus claiming particular normative propositions.
Roman views concepts such as Mouffe’s ‘coalition politics’ or Yuval-Davis’s

‘transversal politics’ as offering analytical and potentially normative
76 Barbara Einhorn
frameworks for the development of a ‘democratic, gendered future’ (Roman,

2001: 61, 62, 64).
Strategies for gender equality
Regardless of their adherence to particular versions of feminist theory,

feminists in both East and West, North and South debate the optimal
strategies for the achievement of more gender equitable participation.
There is even debate about whether increased female political participa-
tion is indeed a sufficient, or even a necessary condition for that end.
Two particular strategies that are currently on the international agenda
but whose merits are contested, are: gender mainstreaming as a policy
designed to achieve gender equality, and quotas as a means to increase
the level of women’s political participation. One could argue that these
strategies are symptomatic of the old debates concerning the merits of
top-down versus bottom-up approaches.8 Since the Fourth UN World
Conference on Women in Beijing in 1995, international agencies and
supranational bodies such as the EU have favoured top-down gender
mainstreaming strategies. In many regions of the world, and also in the
context of EU enlargement, this strategy is hampered by the lack of
women at leadership level, and the fact that women’s rights or gender
equality as goals are, with few exceptions, not included on political
party platforms. During the run-up to EU accession, the Polish Centre
for Women’s Rights reported as late as 2000 that
Poland has done nothing to adjust its legislation to EU standards in

the field of equal status of women and men and that issue is probably
the last item on the government priorities list.
(Women’s Rights Centre, 2000: 14; cited in Regulska, 2002)
Suspicion of top-down statist approaches that was prevalent in the early

years of transformation has persisted in some countries and goes some
way to explaining the enhanced status of NGO activity in the region as
opposed to mainstream political involvement. This suspicion was a per-
fectly understandable reaction to the experience of an all-powerful and
invasive state during the socialist period (Szalai et al., 1990). Nor is anti-
statism peculiar to East European feminisms (Mansbridge, 2003). When
Western or Southern feminists ponder whether or not to ‘give up on the
state’ they are (with the exception perhaps of Latin American countries
re-establishing democratic institutions after the end of military dictator-
ships) not speaking from a position of similar experiences of the state.
The resistance to state-led solutions has – until recently – expressed itself,

among other ways, in rejection of the use of quotas as a political strategy.
Quotas seem to many feminists from the region to smack of the undemo-
cratic manipulation of the political process by the previous regimes
through the installation of puppet ‘representatives’ in parliaments, whose
job it was merely to rubber-stamp decisions taken elsewhere, i.e. in the
Central Committees and Politburos of the ruling Communist Parties (with
women notably absent from those higher echelons of political power).
However, the experience of drastically falling levels of female political
representation in early democratic elections in several countries in the
region eventually led to shifts in this attitude.9 Women activists in
Georgia, Latvia and Poland, for example, now advocate the adoption of
quotas for women as the necessary short-term strategy for achieving some
level of critical mass of women, and thus as a mechanism for the achieve-
ment of gender equality, in parliaments and legislatures. In Poland, strong
lobbying by the Parliamentary Women’s Lobby and the adoption by three
political parties of a 30 per cent quota rule led to an increased percentage
share, rising from 13 per cent in 1997 to 20 per cent in 2001 in the Sejm
(Lower House) and from 12 per cent to 23 per cent in the same period in
the Senate (Upper House) (Fuszara, 2000; Spurek, 2002).
Another reason for not abandoning the national state, which is
particularly pertinent in the case of Central and Eastern Europe, is the
loss of social entitlements which followed the transformation process
(Daskalova, 2000: 346–7). During a 1995 political debate in Hungary, the
proposal to dismantle remaining social welfare entitlements was justified
by arguments that ‘social expenditures had to be brought down to secure
a “healthy” economy, while welfare universalism had to be abolished to
ensure economic “growth”’ (Haney, 2002: 186). Women’s relative loss of
access to the labour market has been well documented (Einhorn, 1993,
1997; Lokar, 2000). So also have the issues of discriminatory hiring prac-
tices and sexual harassment that have followed (Daskalova, 2000: 340,
342; Einhorn, 1997; Lokar, 2000; NWP/OSI, 2002). I have long argued that
the neoliberal market paradigm empowers the male economic actor as
the citizen with the capacity to exchange contracts in the marketplace.
Without social entitlements, for example, to adequate and affordable
childcare, and in a context where women are still seen as primarily
responsible for looking after children, they do not have an equal capacity
to access the public spheres of either the market or the polity. This situ-
ation is exacerbated by the nationalist and religious discourses paramount
in several countries of the region which allot women sole responsibility
for the private sphere and enjoin them to produce babies for the nation
78 Barbara Einhorn
(Slapsak, 1997; Gapova, 1998; Daskalova, 2000: 350; Zhurzhenko, 2001b).

Such discourses insidiously support the economy’s need to shed labour
and provide a rationalisation for the closure of childcare facilities.
In this context, it is necessary to rethink the optimal modality for the
achievement of gender equitable outcomes, particularly in relation to the
question of women’s full participation in determining policies and prac-
tices that affect their lives, exerting influence as active political subjects.
I have expounded elsewhere (Einhorn, 1995; 2000a) a theory of social
entitlements rather than one of individual rights as best enabling the
necessary conceptual and practical linkages between state, market and
household. It is necessary to reiterate here that the state, historically the
locus of welfare and social provision, and the actor with regulatory power
over working conditions, has a crucial role to play in enabling women to
develop the capacity to access both market and polity on an equal basis
with men. Obviously, the nation-state’s power to enforce decent working
conditions is waning in the face of powerful transnational corporations.
In future, therefore, there will be a need to develop transnational regula-
tory bodies for the protection of citizens’ and workers’ rights. However,
for the short to medium term, in the absence of easily recognisable or
accessible bodies of this kind, political participation at the nation-state
level will remain important. The extent to which the regulatory role in
relation to issues of social justice and gender equality hitherto played by
the nation-state is increasingly taken on by supranational legislative and
enforcement bodies such as the European Parliament or the European
Court of Justice, is a development to be watched.
Finally, I want to return to the issue of the level at which women’s
political participation can be most effective. The transformation process
has seen a veritable explosion of ‘civil society’ activity in Central and
Eastern Europe, at the same time as the role of civil society associations
and NGOs is the focus of funding and policy-making by international
donor agencies and governments alike. Political theory has long estab-
lished that women – and not only those adopting the anti-state stance
particular to this region in the post-communist period – find grass-roots
and local, single-issue as opposed to universalist and mainstream polit-
ical party involvement, to be more in tune with and compatible with
their commitments and lifestyle. An enormous number of NGOs has
emerged in the region, many of them initiated and managed by women.
However, in the particular context of a rigidly applied neoliberal market
model and the loss of social provision this entails, such political involve-
ment takes on particular meanings and is accompanied by particular
risks.
Specifically, there is a danger of what I have called elsewhere the

civil society ‘trap’ (Einhorn, 2000a; Einhorn and Sever, 2004). This is
where women’s NGOs in effect provide some of the welfare functions
abandoned by the state. KARAT, an advocacy coalition of women’s
NGOs in the region formed following the 1995 Beijing UN conference,
states that women are active in NGOs on an equal footing with men,
and that NGOs have been successful in influencing government policy
in several countries. However, they also document the lack of capacity-
building and expertise, the dependence on foreign donors and the dis-
tortions this can produce in NGO priorities and activities (Barendt,
2002; KARAT, 2002). KARAT speaks of the necessity of professionalisa-
tion of NGO advocacy work; Sabine Lang argues in contrast that the
‘NGOization of feminism’ dilutes its political and dynamic impact
(Lang, 1997).
My theory of a civil society ‘trap’ relates to the ways in which it is
women’s unpaid labour – often of women made redundant who have
difficulty finding re-employment – that provides social supports such as
childcare or care of the elderly. This labour remains invisible, simultan-
eously depended upon yet unrecognised by state agencies. Women’s
NGOs and grass-roots activist groups are filling the vacuum where
the state has withdrawn from public service provision. This seems to
me a ‘trap’ which derives at least in part from the idealisation of civil
society that followed the collapse of state socialism. Civil society was
seen as the epitome of the democratic space that had been lacking
earlier, both by dissident activists and (primarily male) theorists within
the region, and by Western analysts and international donor agencies.
There are debates around the conceptualisation of civil society and its
relationship to autonomous women’s or feminist movements. In the
context of the transformation process in Central and Eastern Europe,
Ferenc Misslevitz, a Hungarian academic and former dissident activist,
once commented: ‘We dreamed of civil society. What we got were
NGOs.’
Compounding the civil society ‘trap’ is what I call the civil society ‘gap’.
This relates to the lack of channels of communication between NGOs and
social movements on the one hand, and political power structures and
state agencies on the other. How does civil society activism by women
translate into gender-sensitive policy-making? KARAT identifies two prob-
lems in the region which precisely exemplify this ‘gap’:
Despite the fact that a process of opening the state authorities to

the public has started, NGOs are kept outside mainstream policy
80 Barbara Einhorn
formation. … The main obstacle is the unresponsiveness and unwill-

ingness of the administration to engage in a dialogue with civil society
or even with other departments and governmental institutions.
(KARAT, 2002)
Thus there are risks in focusing on bottom-up strategies, or grassroots

activism, to the exclusion of involvement in conventional party politics
and the policies of gender mainstreaming.
In conclusion, I would argue – as did Catherine Hoskyns in relation to
the EU – that there is a need for both top-down gender mainstreaming
policies and for grass-roots campaigning pressure on the part of strong
women’s and feminist movements (Hoskyns, 1996). Jacqui True and
Michael Mintrom validate the key role of social movements and particu-
larly the transnational feminist movement in ‘the diffusion of gender-
mainstreaming mechanisms’ (True and Mintrom, 2001: 27). In her later
study of the efficacy and transformative potential of gender mainstream-
ing as a strategy, True concludes that ‘gender mainstreaming is an open-
ended and potentially transforming project that depends on what
feminist scholars, activists and policy-makers collectively make of it’
(True, 2003a: 368). Without support from mainstream politicians and the
institution of properly supported mechanisms for their implementation,
gender mainstreaming policies cannot succeed. On the other side of the
balance sheet, only pressure from below can ensure that issues of gender
equity are kept on the agenda of national, supranational and inter-
national institutions, and that gender-sensitive policies are not merely
written into legislation, but are also given weight in terms of the human
and financial resources necessary for their implementation. Only then
can policies such as gender mainstreaming or quotas or other mechanisms
designed to achieve greater gender equity make a real difference, not only
women’s lives, but to the life and health of the whole of societies, nation-
ally and internationally.
Notes
1. It goes without saying that the transformation process has differed in pace,
scope and nature within individual countries in the regions. Beyond individ-
ual country differences, the trends evident over the past 15 years vary within
the region. Thus there are both notable inter-country differences and con-
trasting directions of development between the sub-regions of East Central
Europe, Eastern and South-Eastern Europe and Central Asia. The process of EU
enlargement is contributing to widening the gaps between these regions in
terms of political participation, as this chapter will discuss.
2. On the debate about the use of the term ‘transformation’ as a more accurate
term than the more commonly used ‘transition’, see Einhorn (2000b); Einhorn
and Sever (2005); Gal and Kligman (2000a: 11–12).
3. In terms of their impact on the transformation process in this region, I would
characterise as premature claims that ‘the neoliberal Washington consensus
has given way to a “post-Washington consensus” aimed at integrating social
and economic dimensions of development … and challenging the old state
versus market dichotomy’ (Bergeron, 2003: 397; see also Monbiot, 2003).
Rather, I find Jane Jaquette’s view (in the same journal special issue on gender
and democratisation) apt in relation to this region, namely that the increasing
level of women’s political participation in many countries in the world
‘has not altered the neoliberal consensus that is harmful to their interests’
( Jaquette, 2003: 331).
4. See O’Connell Davidson (2006) for the contested and problematic nature of
the term ‘trafficking’.
5. In this path-breaking work, Cockburn applied and developed the concept of
‘transversal politics’ elaborated by Yuval-Davis (1997).
6. Of course, this emphasis on ‘difference’ in feminist theory is not exclusive to
Eastern Europe, since it is also reflected, as Tat’jana Zhurzhenko notes, in the
shift within Western feminism from a ‘feminism of equality’ to a ‘feminism of
difference’ (Zhurzhenko 2001b: 519). On difference feminism in international
social movements, see Mansbridge (2003).
7. ‘If we look at women in Eastern Europe now, it seems to me that we would be
better helped if we were to seek ways of exchanging ideas and experiences
rather than to assume that we … have all to offer and nothing to learn’
(Bassnett 1992: 12–13).
8. Some might argue that both of these strategies are top-down mechanisms;
however, it could be argued that the introduction of quotas is something
women’s movements in many countries have fought to have introduced. The
argument is that whilst numerically more women politicians does not guar-
antee the introduction of gender-sensitive legislation or the implementation
of gender equitable policies, nevertheless, achieving a ‘critical mass’ of women
is a pre-condition for this to occur, since marginalised ‘token’ women have no
possibility of altering the prevailing gendered hierarchies of power.
9. Women’s political representation fell drastically in the first democratic elec-
tions from an average 33 per cent to levels of 10 per cent and below. Even
more alarmingly (given the token nature of representation during the state
socialist period), the level fell further in several countries in subsequent demo-
cratic elections. Thus in Albania, for example, women held 36 per cent of par-
liamentary seats prior to 1989. Their share fell to 20 per cent in 1991, but
much more drastically, to 7 per cent in the 1997 elections. There appears to be
an East–East divide opening up, with Central European countries showing
improvements in levels of female political participation in subsequent elec-
tions, while Eastern and South-Eastern Europe and the Central Asian republics
levels continue to fall. However, in several countries where there has been
improvement, it is only slight. In Ukraine, women held 4.2 per cent of parlia-
mentary seats in 1994, and 5.6 per cent in 1998. In Hungary, the level rose
from 7 per cent in 1990 to 8.5 per cent in 1998 (NWP/OSI, 2002: 11; UNICEF,
1999; in several cases, what has happened is that the East European level has
fallen to one comparable with Western European countries).
82 Barbara Einhorn
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5
‘Gender Equality’: On Travel
Metaphors and Duties to Yield
Hege Skjeie
Introduction
Securing gender equality is an ongoing democratic challenge. The ‘culture

of equals’ is intrinsic to democracy, as Anne Phillips (2004) has written:
democracy involves an assertion about the fundamental equality of all
human beings and an expectation that this will be reflected in public pol-
icies and law. Principles of gender equality are written into international
covenants, national constitutions, laws and bureaucratic guidelines. But
how gender equality actually translates into law and public policies is
highly controversial politics. Gender equality is conceived of in various
ways. But all kinds of gender equality politics contain battles over rights,
recognition, participation and distribution.
This chapter discusses gender policies in the Nordic countries, and par-
ticularly in Norway, in light of what I call the ‘travel metaphor’, which is
embedded in the gender equality discourse. This is the cherished image
of the ‘road towards’ gender equality, the view of automatic, gradual equal-
isation between genders vis-à-vis power and influence. As a way of hand-
ling persistent inequality, political leaders often frame ‘gender equality’
as a kind of nationally encapsulated, common journey. In the official
gender equality policies that I have analysed, equality rights are mainly
treated as consensual, free of controversy and achievable over time. The
travel metaphor portrays ‘gender equality’ as a linear process of evolve-
ment where we all, together, continuously take new steps towards the
goal. This goal might still be ‘far ahead’, but nevertheless it is securely
within our reach; we just have to travel for as long as it takes and far
enough.
A brief example illustrates the case. When the Norwegian representa-
tive for gender equality policies recently met the UN women’s committee
86
‘Gender Equality’: On Travel Metaphors and Duties to Yield 87
in New York, her main message was that although all gender equality
goals had ‘not yet’ been obtained, ‘considerable achievements’ had been
made. In official gender equality rhetoric, we regularly find references to
areas of society which might have ‘a long way to go’. In others, ‘consid-
erable steps have been taken’. Some ‘setbacks’ might occur, some parts of
society are ‘lagging behind’, while others are ‘almost there’.
There is an implicit ‘be patient’ clause to official gender equality rhet-
oric which makes abundant use of the road/travel/journey. It implies that
everybody involved is really working hard and truly doing their best to
achieve the common goal. This patience clause makes it tempting to ask
when, exactly, will ‘we’ finally arrive ‘there’ in the gender equal society
where justice reigns uninterrupted? Are we ‘there’ when all imaginable
equal rights are secured? When all gender structured violence is left
behind? When all public budgets are gender equalised? When all organ-
isations are gender mainstreamed? When all ‘reconciliation problems’
of paid work and unpaid care are finally solved? When all the world’s
religious leaders have left all their gender hierarchies behind? Is there,
actually, an end-station to democracy that reaches the set ideals?
I wish to contrast the linear optimism of the travel metaphor of gender
equality with what I (consequently) call gender equality’s ‘duty to yield’.
This expression signifies all the situations where a general commitment
to gender equality is combined with political willingness to grant com-
peting principles or different sets of values precedence in actual conflict
situations. Gender equality policies are shaped within complex systems
of political negotiations and compromises. In political practice, gender
equality often has to give way to other important values. A classic example
is the yielding duty of gender equality when confronted with the prin-
ciple of freedom of religious beliefs. The right to religious freedom is a cor-
nerstone of human rights thinking. In liberal state-religion orders, this
right remarkably often translates into a claim for due respect for religious
doctrines and customs, and consequent group claims for rule-based non-
interference from the state – so-called exemption rights. The gender hier-
archies imposed by many religious doctrines and practices are often in
direct conflict with women’s rights to equality. When religious groups are
granted formal exemption from laws against gender discrimination, a
duty for gender equality to yield is imposed. Yielding duties pose actual
barriers to the recognition of gender equality rights. In this sense, there is
no travelling going on.
Closely connected to the image of the journey towards gender equality
is one particular argument about why gender equality is so important to
‘achieve’. This argument addresses the usefulness of gender equality – the
88 Hege Skjeie
many ways that women will enrich the public sphere (and men the
corresponding private sphere), when gender equality is finally here.
Consider, for instance, the European Commission’s 2005 gender equality
report. The introduction is securely set within the travel metaphor of
equality: the report ‘shows advances, but inequality remains’. Then fol-
lows a standard utility argument for gender equality, which with notable
lack of delicacy, is stated as follows: ‘Increased integration of women into
the work force will release the productive potential of the EU [European
Union] and increase social cohesion, in line with the Lisbon strategy’
(European Commission website, 2005).
In my view this is a prime example of degrading pragmatism in official
equality talk. The Commission seems to have forgotten that there are
democratic obligations which are different from productivity concerns.
Democracy cannot be subsumed under productivity. What if increased
integration of women into the workforce did not increase social cohesion
in the EU? Should gender equality principles be abolished?
This chapter contrasts the image of the gender equality ‘journey’ with
actual duties to yield, as such duties can be observed in Norwegian gen-
der equality law. In my view, yielding duties deserve at least as much
attention as ‘the steps taken’ at any time. Three examples of yielding
duties are given particular attention in this chapter. First, I discuss the
limited scope of regulations to secure equal pay for work of equal value.
Second, I address the general exemption from anti-discrimination legis-
lation which is granted to religious communities. And third, I discuss
the incorporation of CEDAW (Convention on the Elimination of All
forms of Discrimination Against Women) in Norwegian law, which has
been carried out in such a manner so as to give CEDAW less binding
force than other human rights conventions. I shall set my discussion
within a framework that is based on a policy analysis study conducted
by Mari Teigen and myself. This analysis was a part of a large-scale gov-
ernment initiated research programme on ‘Power and Democracy’ in
Norway over the period 1998–2003 (Skjeie and Teigen, 2003).1
The travel metaphor
The rhetoric of linear gradualism, or incrementalism, has been identified

as a dominant gender equality discourse in each and every Nordic coun-
try (see Freidenvall, Dahlerup and Skjeie, forthcoming). While I do not
think that gradualist conceptions of equality journeys are in any way
exclusive to this territorial unit, there is a particular legacy of feminist
writings on Nordic political cultures that might be partly ‘responsible’ for
this discursive frame. The influential work on Scandinavian welfare state

policies and the concurrent concept of ‘state feminism’ launched by Helga
Hernes in the late 1980s, was tied to a claim that Nordic democracies
embody a state form that makes it possible to transform them into
women-friendly societies. The concept was largely held to be synonymous
with ‘state interventionism’ aimed at the emancipation of women and the
creation of ‘women-friendly’ politics (see Bergman, 2004). State feminism
captured political settings where mobilisation ‘from below’ – i.e. feminist
movements – combined with ‘integration politics from above’ – i.e. party
political elites and institutions – in state initiatives where social rights
expansion, and party political inclusion, were the two sides of the same
transformation vision. In the women-friendly society, injustice on the
basis of gender would be largely eliminated without an increase in other
forms of inequality (Hernes, 1987: 15). State feminism coined a gradual
development of policies, which in the end would fulfil all claims embed-
ded in a principle of gender justice.
In my opinion, the concept of state feminism, as it was developed in
the 1980s, also mirrored actual feminist understandings of societies
being ‘on the right course’. There was a perception of a political ‘break-
through’ in the way political leaders approached gender equality. A fac-
tual alliance between women and the state was being formed (see the
discussion in Skjeie and Teigen, 2003). In the following decade, feminist
research elaborated on, and quarrelled over, the meaning, reality and
implication of Nordic state feminism (Borchorst and Siim, 2002). Political
elites have, however, to a large degree stuck with the promise of Nordic
exceptionalism.
Often, the framing of ‘gender equality’ in Nordic political debates is
one of ‘almost there’. As Anne Maria Holli has outlined regarding the
Finnish ‘national journey’:
It has become increasingly commonplace in the 1990s to regard

Finland as a ‘gender equal’ society par excellence already. The Finnish
people are considered to have internalised ‘gender equal’ values and
behaviour, in contrast to other people and cultures which have not
‘come so far’. The problems we observe in our country are not
considered serious, but as minor blemishes in an otherwise perfect
society.
(Holli, 2003: 17–18)
A similar observation is made by Annette Borchorst (2004) concerning

the Danish ‘national journey’. To this she adds the observation of a
90 Hege Skjeie
problematic ‘We’–‘They’ construction of recent gender equality rhetoric.

This is the claim that Danish citizens have already reached the end-
station of the equality journey. As of today, in Danish political rhetoric
dominated by a centre–right government, the ‘equality project’ is mainly
claimed to be of relevance to ‘Muslim countries’ or to immigrant minor-
ity groups now living in Denmark. In this kind of rhetoric, local gender
equality ‘exceptionalism’ thus mixes with nationalism in quite disturb-
ing ways.
In a comparison of French and Finnish parliamentary debates on equal
representation, the respective ‘parité’ ‘quota’ debates, Eva Raevaara (2005)
identifies a larger common content of nation-building in the rhetoric of
gender equality. It all tends to underscore the country’s ability to progress
towards a perfect democracy. The equality discourses have a common
content in that they model the road to gender equality as a route of
national exceptionalism. For instance, Raevaara describes one strand of
the parité debate as insistent on the particular French obligation to remain
a model of equality for all. After all, France is – as the world well knows –
the birthplace of human rights. The Finnish parliamentarians simply
maintained that Finland could also excel among nations when adopting
a gender quota law. This way, Finland would both prove its firm place
within the Nordic tradition of excellent equality, and hope to achieve a
status of first among equals.
Alternatives exist of course; these are dominant but not monolithic
public discourses. Anne Maria Holli (2003) comments on how a counter-
tendency is particularly notable, not least because of its prominence,
in Swedish official gender equality discourse (see also Borchorst,
Christensen and Siim, 2002; Freidenvall, Dahlerup and Skjeie, forth-
coming). Consensual ‘travel-talk’ is here challenged by an analysis of
structural gender discrimination which is framed as ‘the gender power
order’. ‘The gender power order’ is clearly more focused on concepts
of gender discrimination, systemic exclusions and misrecognition
(Eduards, 2002). It is a counter-tendency in gender equality discourse
which is not least inspired by the ‘genus system’ analysis of the Swedish
power commission from the late 1980s (Hirdmann, 1990) and the fol-
lowing official ‘women’s power investigation’ in the latter part of the
1990s. The ‘gender power order’ has also informed Swedish legislation
to combat violence against women, including the legal ban on buying
sex (Borchorst, Christensen and Siim, 2002; Eduards, 2002; Skjeie and
Teigen, 2003). Thus structural discrimination perspectives are clearly
more institutionalised in Swedish party politics than in other Nordic
‘state feminisms’.
The problem of institutional male dominance
In all these ‘best countries’ of gender equality, patterns of strong institu-

tional male dominance persist. This is, for instance, true in all the
Nordic countries, as quite comparable large-scale national surveys have
shown. In the research team in charge of the Norwegian ‘Power and
Democracy Study’, we made a comprehensive analysis of official gender
equality policies (Skjeie and Teigen, 2003). This analysis included a sur-
vey among institutional elite groups. Two thousand top leadership pos-
itions were identified, and the persons holding the leadership positions
were interviewed. The survey revealed an overall male dominance of
nearly 85 per cent in national elite positions, with variations from 60 to
65 per cent in party politics to 98 per cent in private business corpor-
ations. The statistics clearly show that male dominance is overwhelming
in the societal elites of current Norwegian society. Thus they bluntly
demonstrate that in elite levels of society, few ‘roads’ to gender equality
have yet been paved in Norway.
The top leaders in sectors such as business, state administration, party
politics, media, the church, the arts, academia, law enforcement and
defence were interviewed about attitudes to various aspects of gender equal-
ity policies. The survey documented what we call the problem of benevo-
lent non-commitment. Verbal support for gender equality combines with
strong male dominance in formal positions of power and influence. Today,
there is a broad political consensus at the rhetorical level about the signifi-
cance of gender equality for societal well-being. Yet a general consensus,
across different leadership strata, on the importance of gender equality pol-
icies combines with quite specific willingness to subordinate gender equal-
ity to competing principles or interests. This often happens when leaders
are asked about prioritising political issues which simultaneously pose con-
flicts of interests in areas of particular relevance to different leadership
strata. To give a few examples: business leaders often support affirmative
action in hiring processes in the public sector, but largely reject gender
quotas on the boards of private businesses. Most church leaders are eager
protagonists for quota regulations in politics, workplaces, higher education,
etc., but largely reject the idea that gender discrimination within in the
Norwegian state church should be prohibited by law.2 Labour party leaders
are clearly more supportive of a prohibition of gender discrimination
within the church, than of politics which prioritise wage increases in the
care professions of the public sector (Skjeie and Teigen, 2003).
In this study, we argue that the extreme male dominance in formal
positions of power and influence become more ‘manageable’ through
92 Hege Skjeie
the gender equality travel rhetoric. The ‘journey’ allows for problems of
gendered power to be ‘almost’ solved. The travel requires patience. Simply,
more time needs to pass for patterns of positional male dominance to
gradually evolve into patterns of positional gender balance. Strong (statis-
tical) male dominance in the leaders’ own organisations is not primarily
identified as a problem of discrimination, of dubious network recruitment
practises or of misogynistic attitudes towards women in positions of
authority. Most important, the leaders claim, is the fact that ‘too few
women apply’ for leadership positions (Skjeie and Teigen, 2003).3
In elite levels of society, gender equality is portrayed as a harmonious
common project. It is pasted into a language that creates images of
change in ‘the right direction’ happening all the time – even if/when
simple statistics clearly demonstrate more permanence than change.
There are, again, exceptions to the insistence on gradual progress. Dif-
ferent types of quota policies are controversial, but receive strong support
in several leadership strata. For several years, the male hegemony in top
leadership levels of large business corporations has been challenged by
gender equality policies as constituting an ‘unacceptable’ state of affairs.
Here, even cabinet ministers have declared themselves to be simply ‘fed
up’ with the situation. In 2004 a new law on the composition of the
boards of publicly owned corporations thus came into effect, establishing
a regulation minimum of 40–60 per cent female–male gender balance. If
private companies do not ‘sufficiently’ improve the gender balance of
their boards, the same regulation will apply to the private sector from the
year 2006. This law is the only one of its kind. No other government has
demonstrated similar interventionist ambitions as regards the governing
bodies of businesses. The law is modelled on the 40–60 regulation of gen-
der balance, which since 1987 has applied to all governmental appointed
boards and committees, and today also encompasses locally appointed
committees.
However, the politicians’ ‘own’ bodies, the parliament, and regional
and municipal councils, are exempted from similar legal regulations.
Here a vague argument about the voters’ right to decide the composition
of elected bodies, or else a similarly vague argument of ‘party autonomy’,
seems to support politics of non-interference. Furthermore, several party
political internal quota regulations are already in place. Generally speak-
ing, these suffice to produce an ‘acceptable’ national (statistical) gender
balance of about 30–40 per cent women among delegates. In the words
of the travel metaphor, political bodies have ‘already’ moved ‘sufficiently
far’ in ‘the right direction’, and consequently (if somewhat inconsist-
ently) need no permanent rule about their compositions.
Equality’s utility
In the Norwegian context of 1980s ‘state feminism’, Helga Hernes (1982,

1987) outlined three main arguments for political representation
demands. She distinguished between a ‘democratic right to participation’
argument, which she called ‘the justice argument’, an argument about
‘women’s important contributions’, which she called ‘the resource argu-
ment’, and an argument about ‘conflicting, gender structured, political
interests’, i.e. ‘the interest argument’. In actual political debate, all three
kinds of arguments were often intertwined. Yet the resource argument
can be seen to fit exceptionally well with portrayals of society’s harmo-
nious struggle to ‘achieve’ gender equality, in the sense that arguments
about ‘women’s contributions’ are consensus building, conflict avoiding
and thus non threatening political arguments.
My own analyses of party political conceptualisations of a ‘politics of
presence’ (cf. Phillips, 1995) in the late 1980s, which included interviews
with MPs and the then world famously mediated ‘Women’s Cabinet’
headed by Gro Harlem Brundtland, revealed the importance of what I
called a ‘rhetoric of difference’ supporting internal party quota policies
and gender sensitive nomination politics (Skjeie, 1992). The rhetoric of
difference stressed women’s and men’s different contributions to political
life, based on different (gendered) perspectives and experiences, as the
‘inclusion of women’ was here conceived to challenge and change estab-
lished political priorities within all the major political parties (although
in somewhat different, party specific ways).
Correspondingly, in the first attempts to regulate the gender compos-
ition of public boards and commissions, one major argument from the ini-
tiators (the committee preparing the legislation) was how women would
contribute to a broader presentation of ‘the public point of view’. When
‘reserved seats’ for female students were introduced in higher technical
education in Norway, ‘women’ were held to provide a new, and much
needed, focus on communication skills and user-friendliness. All over, we
can identify political arguments which stress that women are to enter
boardrooms, judicial offices, professorships, etc. in order to ‘save the
institutions’ – that is, a range of utility-oriented arguments which claim that
the inclusion of ‘women’ will better serve students, advance the climate in
the workplace, improve risk assessments, enhance the company image.
In the book Menn i mellom we also give an example from the debate on
formal regulations for gender balance on company boards, provided by
the Norwegian Equality Centre: ‘Gender balance on the boards of pri-
vate businesses means caring for businesses’ own interests, and this way
94 Hege Skjeie
also Norwegian interests … Affirmative action in this respect is an issue

of profits’ (Skjeie and Teigen, 2003: 200). In neoliberalist rhetoric the
utility argument easily turns into an argument on profitability. This has
been witnessed in much of the Norwegian equality debate during the
last decade. Anne Therese Lotherington (2002) has described how equal-
ity initiatives directed towards the private sector of the economy are
now mainly supported by arguments about ‘profit’. These mainly stress
how a continuing neglect of ‘competent women’ will hurt businesses as
they will not be able to realise their full profit potential. This kind of
profitability talk is by no means limited to the private sector. It is a gen-
eral argument in official gender equality talk: the ‘resources’ of ‘compe-
tent women’ are not fully ‘utilised’ in society (Skjeie and Teigen, 2003).
Anna Jónasdóttir (1991) has remarked that ‘utility’ is indeed the defin-
ing framework of the gender equality discourse, as utility considerations
are woven into a never-ending struggle to define the ‘gender essence’. Is
it sameness? Is it difference? Who are ‘women’? Two centuries of polit-
ical discourse have centred on defining women’s role, and correspond-
ingly, Jónasdóttir claims, elaborating what ‘good’ woman bring to
public life – to the order and stability of the state; to the pleasure of men;
to the transformation of politics (Jónasdóttir, 1991: 203). All too often,
as Martha Nussbaum has observed, women are not treated as ends in
their own right, persons with a dignity that deserves respect from laws
and institutions (Nussbaum, 2000). This holds true for much gender
equality rhetoric as well.
The complacent utility arguments are deeply problematic. When gen-
der equality is argued for as a means to secure competitiveness, the cat-
egory of ‘women’ becomes a representation of ‘means’ for companies
and organisations to use. This utility rhetoric puts equality on the
defence, as a field that must be defended with something else than its
own value. Such discussions circle around a far too old – and endlessly
patriarchal – requirement that women should contribute ‘as a gender’ –
with their collective empathy, their collective talent and their collective
reason. If not, what are we nagging about?
Equality’s duties to yield
Under the harmonising umbrella of the equality ‘journey’, and/or gen-

eral references to equality’s ‘utility’, quite specific political negotiations
and bargains take place. In the book Menn i mellom (Skjeie and Teigen,
2003) we describe these bargaining processes as producing a series of
pragmatic compromises where competing rights are prioritised, and the
equality ‘contract’ is frozen (cf. Hirdman, 1990). In Norwegian gender

equality politics, three major compromises are particularly notable, as
they are literally sanctioned by law. They can all be observed in the actual
phrasing of the Gender Equality Act 1978 which covers working life, pol-
itics, education, civil society and family life. Here, in an encounter with
the constitutionally recognised right to ‘religious freedom’, protection
against gender discrimination was set aside. In an encounter with the
‘freedom of negotiation’, the right to pay equity was adjusted. In an
encounter with the ‘freedom of association’, the right to equal participa-
tion was diminished.
The very restricted scope of the legally guaranteed right to equal pay
for work of equal value presents a subtle example of equality’s duty to
yield in Norwegian legislation. Until the Gender Equality Act was revised
in 2002 only identical work, performed by a male and a female employee
respectively, both employed within the same business/organisation,
could be compared under the regulation providing a right to equal pay
for work of equal value. The limited scope of the equal pay regulation in
the Gender Equality Act was due to intervention from the leadership of
the trade union movement. They demanded a ‘hands-off’ policy on
equal pay when their comrades in the Labour Party government prepared
the law in the mid-1970s. Any regulation that could impede the ‘right to
free negotiations’ was simply unacceptable, the trade union representatives
declared.4
The wage controversy was largely contained within the upper ech-
elons of the labour movement. The negotiations were secret, and threats
were being made about the trade unions’ possible withdrawal from all
‘cooperative’ work with the government. Yet the issue did undoubtedly
relate to a principal dispute over how negotiation freedoms could curb
legal interventions to secure equal pay for equal work.
The wage compromise reached in the mid-1970s defines a context
where ‘fair wages’ can also be seen to collide with concerns about
‘national productivity’. Resisting all attempts to change the definitional
boundaries of equal pay in the Gender Equality Act, the Ministry of
Finance, in the early 1990s, took care to list all its objections to a legally
based comparison of wages which moved beyond the ‘identical work’
limitation. According to the Ministry such changes would:
• contribute to rigidity in wage formation;

• prevent readjustments and new entrepreneurship;
• imply increases in the average wage level, and corresponding increases
of cost problems in the Norwegian economy;
96 Hege Skjeie
• contribute to weakened public budgets, or reduced employment

within the public sector;
• create negative competition conditions for employment and value
creation in the private sector of the economy (Skjeie and Teigen,
2003: 152).
And that was that. Only comparisons with International Labour

Organisation conventions, EU Directives and equal pay regulations in
other Nordic countries were able, in 2002, to change the Norwegian legal
interpretation of equal pay for work of equal value. Yet the Ministry of
Finance’s long list of reservations simultaneously, if indirectly, comments
on the European Commission’s concerns to release ‘productive potential’
in the EU (cf. the Introduction). Equal pay regulations in Norwegian law
was kept on a minimum level exactly because a fair law was perceived to
threaten productivity.
Religious exemptions to equality
In the Norwegian Gender Equality Act there is one generally stated rule of
exemption. The prohibition of gender discrimination applies to all areas
of society excepting the ‘internal conditions’ in religious communities.
The yielding duty of gender equality, when the principle clashes with reli-
gious beliefs, is an all too familiar theme. Historically, religious freedom
has implied safeguarding forms of worship from transgressions by a state
with the power to define the conditions for religious practise as well as
ensuring equal treatment of different religions (Ketcher, 2001). And mod-
ern liberal democracies typically hold the protection of religious freedom
to be ‘among the most important functions of government’ (Nussbaum,
2002: 168). But as such, ‘religious freedom’ has often been understood as
a special group right. That is, religion constitutes an area where a general
law might have limited application. This is the conventional understand-
ing of religious freedom in Norway, where religious communities have the
right to discriminate on the basis of gender, or on the basis of sexual orien-
tation, if and when such discrimination is rooted in religious conviction.
This exemption also encompasses the official state religion’s main institu-
tion; the Church of Norway (‘the state church’).
The general exemption was made politically possible through the col-
lective intervention of the whole state church establishment, including
the bishops, the theological colleges and the Ministry of Church Affairs,
during the preparation of the act in the mid-1970s. The Labour Party
government at first had no such general exemption plans; the plan was,
to the contrary, to regulate all equality matters of the official state

church firmly within the scope of this law. But the fury of the bishops
when faced with this infringement on the institutional autonomy of the
church, simply became too much for the government to handle.
In principle the exemption right in the Gender Equality Act means
that neither the general ban on discrimination, the obligation of author-
ities and employers to promote equality, the protective measures regard-
ing employment, dismissal and pay equity, nor regulations pertaining to
equal rights to and during education and training apply to the internal
affairs of religious communities.5 To paraphrase ‘travel-talk’ once more:
The Norwegian Gender Equality Act presents no road at all towards
equality for religious women. Within their own communities of faith,
they are, to the contrary, principally exempted from the protection of
the law.
In a new chapter on equality in working life in the Act relating to
worker protection and the working environment, religious communities
are correspondingly exempted from the general ban on discrimination
on the basis of sexual orientation. And in a new law prohibiting ethnic
and religious discrimination, corresponding exemption rules accommo-
date religious practices, although with a notable ‘exception to the
exemption’ for employment relations that have no religious aims.
One other ‘exception to the exemption’ is at least as noteworthy. This
relates to a recent controversy over the content of textbooks used in
Christian private schools in Norway, within the so-called Accelerated
Christian Education (ACE) scheme. Here religious utility considerations
of ‘women’ combine with instructions to subordination in clear contra-
diction of any gender equality principle. In social science classes in ACE
schools pupils would learn that:
When God had completed the creation, he saw that all was good. With
only one exception: It was not good for man to be alone. Man needed
a close community with other people, or he would be lonely. To
accommodate this need, God created woman and instated the family.
(http://www.kjonnsrettferdighet.no/Utdanning/62
[accessed 11 May 2005]).
Younger pupils in other social science classes were invited to mark the
best answer to the following multiple-choice assignment:
• Wives will be (sorry, sad, happy) to obey their husbands.

• (Wives, cats, dogs) shall obey their husbands.
98 Hege Skjeie
• A wife obeys God when (he, she, it) obeys the husband.
(http://www. kjonnsrettferdighet.no/Utdanning/62
[accessed 11 May 2005]).
These textbooks have, however, been declared to be in violation of the

Gender Equality Act. This decision, in 2001, by the Equality Ombud and
the Complaints Board was possible due to a separate clause in the Act
which stipulates that all teaching materials used in schools shall build
on gender equality (§7). In this case, the claim to a general exemption
right was simply overruled, with the complaints board’s decision inte-
grating state obligations following from CEDAW in its ruling.6
CEDAW in Norwegian law
CEDAW does not regard the relation between religion and women’s rights
as a legitimate area of exemption. Religious stereotyping and gender hier-
archies are directly challenged in the provisions of the Convention (see
Vuola, 2002; Børresen, 2004; Hellum, 2004). By ratifying the Convention,
states commit themselves to ‘take all appropriate measures to eliminate
discrimination against women by any person, organisation or enterprise’
(Art 2 e).
In Norway, a recent controversy over the formal status of CEDAW has
added to the cataloguing of gender equality’s yielding duties. In February
2004, the Conservative-Christian Democratic coalition cabinet decided
not to afford CEDAW the same legal status as other human rights con-
ventions have been given in Norwegian legislation. The Human Rights
Act 1999 incorporates four international human rights conventions rati-
fied by Norway directly into Norwegian legislation, with precedence
granted to the incorporated conventions in cases when a conflict arises
between these and other statutory provisions. These conventions have
thus been given what is often referred to as ‘semi-constitutional’ status.
The Human Rights Act incorporates the European Convention on
Human Rights, the Covenants on Civil and Political and Economic,
Social and Cultural Rights, and the Convention on the Rights of the
Child. Both CEDAW and the Convention on the Elimination of All
Forms of Racial Discrimination (ICERD) have, in accordance with the
parliament’s wishes, been in line for incorporation. But now the govern-
ment has decided that neither of them will be included in the Human
Rights Act. CEDAW will be incorporated into the Gender Equality Act,
and ICERD into new law which prohibits ethnic discrimination. This
decision simply means that no precedence clause will apply for CEDAW
and ICERD. In all probability it also means that when a conflict arises
between CEDAW’s protection and human rights’ guarantees that are
secured through the Human Rights Act, CEDAW guarantees will simply
have to yield.7
I have a personal interest in challenging this new hierarchy of human
rights in Norwegian legislation. The cabinet cites a final conclusion of
the Power and Democracy study as the prime reason behind this move.
This conclusion, which was made with my dissent, states that the
Norwegian political system is in a process of fragmentation, where
‘democracy’, understood as national majority rule through party polit-
ical representation and formal chain of governance, is disintegrating.
Many processes of change were interpreted as pointing in this direction.
In particular, however, this main conclusion stressed an increase in legis-
lation on citizen rights as contributing to a trend in which courts take
control of political issues. When human rights conventions are incorp-
orated in Norwegian law, the rulings of international courts become
increasingly important in defining the limits of national political decision-
making power. The expansion of legally binding human rights regimes,
particularly during the past decade, was thus portrayed as a threat to
‘democracy by popular will’. (NOU, 2003: 19, Østerud, Engelstad and
Selle, 2003).8
The formal status of CEDAW has been through an extensive process of
review and comment. Virtually all of the institutions and agencies con-
sulted during the review process in 2003 recommended that the con-
vention be incorporated into the Human Rights Act. Only two were
negative: the Legislation Department at the Ministry of Justice and the
Office of the Attorney General. Both declared that they were deeply
worried about the relationship between ‘judicialisation’ and the overall
political room to manoeuvre (Skjeie, 2004: 19–21).9
The stated objection to the incorporation of CEDAW into the Human
Rights Act is not, then, based on any form of substantive evaluation of the
significance of the convention’s equality principles. Incorporation into
the Human Rights Act is instead rejected on the basis of general consider-
ations about the appropriateness and/or danger of institutional power
shifts. The reasoning behind this particular instruction to yield might still
be assumed to go roughly as follows: The human rights safeguarded in
CEDAW are only of ‘minor importance’, because women’s rights are safe-
guarded ‘adequately enough’ in Norway already, while the discrimination
against which women are not protected, is generally viewed as not ‘too
harmful’. What this reasoning actually implies, is a political acceptance of
the relativisation of women’s human rights.
100 Hege Skjeie
Conclusion
There might be an overwhelming appeal to a gradualist way of thinking

and talking about gender equality. The travel metaphor can be seen to
offer both hope and optimism in its harmonious evolvement-oriented
outlook on society and life. But in important ways the equality journey
remains at odds with human rights based reasoning. Rights discourses
do not similarly engage in gender small talk, about the few steps remain-
ing, or the goal already in sight. Rather, they present equality as a prin-
cipal right. Although sets of rights are obviously – in actual political life
in different territorial bounded settings – gradually claimed, recognised,
rejected or reinforced, and very differently so, ‘the journey’s’ gradualism
remains at odds with a perspective of democratic rights and obliga-
tions. To set the opposition maybe far too bluntly, travel perspectives
advocate, or encourage, patience, pragmatism and local partial ‘solu-
tions’. Democratic rights stress principally non-negotiable, state/societal
‘obligations’. Interpretations of rights are not fixed, but rights perspec-
tives still resist ‘the journey’s’ pragmatism and partiality.
Rights discourses engage with ‘cultures of discrimination’ as clearly
contrary to democratic ‘cultures of equals’. Freedom from discrimination
forms one cornerstone of international conventions on human rights.
Women’s right to equality is at the heart of CEDAW. International
debates on democratic diversity, and in particular on multiculturalism,
are specifically focused on the problem of potentially conflicting rights
(cf. Okin, 1998, 1999; Kymlicka, 1999; Nussbaum, 1999).
Yet much work initiated under the umbrella of CEDAW also makes
more than abundant use of the travel metaphor. Opening the session of
the Commission on the Status of Women marking of Beijing ⫹ 10, UN
Secretary-General Kofi Annan leapt straight into the travel metaphor,
reminding the audience how ten years earlier women gathered in Beijing
‘took a giant step forward’. Over this decade, there has consequently
been ‘tangible progress on many fronts’ (Press Release SG/SM/9738).
UNIFEM’s gender equality webpages are, quite correspondingly, filled
with ‘travel’ allusions. For example, UNIFEM’s executive director,
Noeleen Heyzer, indicated UNIFEM’s key role in supporting countries to
‘move forward’ on all gender equality fronts. Yet UNIFEM has also seen
how ‘gains can be lost’, and ‘advances reversed’. ‘Four steps’ were high-
lighted in the preparation for Beijing ⫹ 10. Achieving gender equality
demands a ‘two-track’ approach – gender mainstreaming and renewed
investment in women’s human rights. And we all need to work together
to give countries a single, clear set of benchmarks for ‘monitoring
progress’ on the implementation of gender equality and women’s

empowerment (Heyzer, 2004).
The proposition advanced in this chapter is somewhat at odds with
this belief. Here I have argued that by encapsulating gender equality as a
common, step-wise, joint journey, the positioning of equality as an indi-
vidual and democratic right is at risk of being more easily ignored.
Prototypically, the state binding norms of CEDAW play almost no role in
Norwegian elite structured, travel-oriented gender equality discourse.
CEDAW’s specification of equality rights is mostly thought of as being of
relevance ‘abroad’.10 When women’s right to non-discrimination and the
concurrent discrimination ban in the Gender Equality Act are invoked in
debates otherwise informed by the travel metaphor, the issue soon
enough turns into one of ‘how big’ a problem discrimination ‘really’ is –
in ‘our’ society. The belief often stated is that it is ‘really not so big’.
Various ways of downplaying rights imply that the dominant gender
equality discourse also hesitates to address the actual political problems
posed by conflicting rights. Yet any law has to confront this challenge of
gender justice: How are cultural and religious claims to institutional auton-
omy, and specific, group differentiated, rights, reconcilable with women’s
right to equality? The harmonising strategies embedded in travel metaphors
and journey rhetoric have obvious difficulties in coping with these kinds of
democratic challenges. What is imposed in the absence of confrontation,
far too often turns out to be a tacit duty for gender equality to yield.
Notes
1. A similar research programme was carried out in Denmark during the same
period. Scandinavian governments have repeatedly initiated comprehensive
scholarly investigations of the state of power and democracy in their countries.
The tradition started with a ten-year long Norwegian ‘Power Study’ (1970–80),
followed by a five-year Swedish investigation (1985–90) and then these two
new parallel studies (1998–2003). Both surveys have, as did a Swedish investi-
gation ten years earlier, focused on gendered power relations. For an overview,
see Skjeie and Borchorst (2003).
2. With the notable exception of the few women church leaders.
3. Although quite dramatic differences in perceptions between men and women
in leadership positions should be noted.
4. Under no circumstances should gender structured wage differences which
followed from collective agreements by labour market parties be subjected to
scrutiny by the Equality Ombud. Such cases are referred to the corporatist
labour court; Arbeidsretten.
5. This, however, is not the Equality Ombudsman’s current interpretation of
the exemption right as regards the Church of Norway. But no discrimination
102 Hege Skjeie
cases within the Church have so far been tried by the Ombud and the
Complaints Board. A further presentation of legal assessments is offered in
Skjeie (2004, 2005).
6. Which was made with an interesting majority-minority voting pattern: the
women members of the complaints board formed the majority, the men the
minority. According to the minority, the constitutionally guaranteed right to
religious freedom ought to trump the gender equality act in this case.
7. In all probability this legal ‘solution’ also implies that the government’s earl-
ier statement about ‘no conflict’ between CEDAW and the general exemp-
tion clause in the Gender Equality Act will remain unchallenged (cf. Skjeie,
2004, forthcoming 2005).
8. In the final report to the government, I consequently made a largely dis-
senting argument, i.e. on the democratic importance of an (internationalist)
discourse and politics of rights, new majority-minority challenges, and
CEDAWs importance in balancing dilemmas of conflicting rights (NOU
2003: 19, 74–87).
9. And they both referred to the majority statement from the Commission on
Power and Democracy regarding how ‘judicialisation’ in general, and inter-
national human rights regimes in particular, shift power from the political
arena to the courts, thus adding to the breakdown of the democratic infra-
structure (see Skjeie, 2004: 19–21).
10. Two kinds of gender-based violations form an exception to this rule: inter-
national trafficking in women and children, and domestic violence and
abuse, which are officially framed as violations of human rights (NOU 2003:
31, Governmental Plan of Action against Trafficking, Skjørten, 2004).
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Part II
Applying New Insights
to Old Problems
6
Education and European Women’s
Citizenship: Images of Women in
Bulgarian History Textbooks
When speaking about the low level of women’s political participation

and gender justice, one should pay special attention to the cultural and
institutional factors that propagate the old patriarchal notions about
‘woman’s nature’, ‘woman’s role’, ‘woman’s destiny’ and the discourse
of ‘essential difference’. Foremost among these factors of socialisation is
the education system which sustains the gender hegemony (in terms of
Gramsci and Althusser). Such institutions shape the dominant discourse
of the ‘feminine’ woman and posit certain standards and ideals of
womanhood.
In this chapter I will explore the character of school education and
especially of textbooks in some southeast European/Balkan states, with
special emphasis on Bulgaria, and their connection to civic education
and the formation of citizenship of the future generations from a gender-
sensitive perspective during the period of the so-called transition after
1989. As many scholars have argued, the well-known French sociologist
Pierre Bourdieu being one of them, the school institution is among the
major institutions – together with the Church and the State – responsible
for the preservation of old stereotypes and male domination (Bourdieu,
1998). Though it is clear that textbooks are not the only channels
responsible for education and socialisation of the young, it is impossible
to deny their important role in the cultivation and maintenance of the
prevailing gender order, attitudes and values. With their implicit con-
formity, textbooks (and school education in general) perpetuate the
existing social rules, roles, relations, actions and positions. Textbooks
and especially history ones have always served the ideological propa-
ganda of the politically powerful. Bearing in mind that they are products
of the rather conservative state system, it is hard to believe that innov-
ation would be encouraged.
107
108 Krassimira Daskalova
Here I will analyse some new Bulgarian history textbooks, pointing

out their one-sided way of depicting women. I will start with the polit-
ical changes in Eastern Europe after 1989 and their impact on the repre-
sentations of the past, history writing and the content of the history
textbooks. Then I will present some theoretical considerations in order to
justify my ‘resisting’ feminist reading and to show the explicit and implicit
biases of the textbooks’ authors. I will go on to an empirical analysis of
three textbooks: one for the fifth grade and two ‘alternative’ textbooks for
the eleventh grade. I will conclude by summing up the results of my
research.
Attempts at reforming school textbooks after 1989
Before 1989 there were ideological and structural differences within

the education of the countries in southeast European/Balkan states. Since
the fall of communism, school textbooks have been rewritten in many
of the former socialist countries to rid them of the ideological distortions
of the ‘old regime’ and to adjust history to current political events
(among the most suggestive cases being contemporary Serbian text-
books; Stojanovic, 2003). This process of rewriting went along with a dis-
cussion and re-evaluation of the educational systems, school curricula
and the contents of the textbooks (Deyanov, 1995). Several collective
undertakings of specialists from various European countries should be
mentioned in this respect, most of them dealing with history textbooks.
In the early 1990s the Bulgarian Ministry of Education and Science
and the ‘Intercultural Centre for Minority Studies and Cultural Inter-
actions’ commissioned a research project entitled ‘Rewriting the New
Bulgarian History in the High School Textbooks’. In the second half of
the 1990s one major undertaking in this regard was the ‘Southeast
European Joint Project’ (JHP), an initiative of the Centre for Democracy
and Reconciliation in Southeast Europe based in Thessaloniki, Greece
(Koulouri, 2001; 2002). What appears to be the main outcome of the
research and workshops organised by the JHP is the recognition that
without exception all educational systems in southeastern Europe/the
Balkans are ethnocentric, i.e. they favour the dominant national group.
The participants in the project pointed out striking similarities in their
national textbooks, especially in the way the Balkan ‘Other’ is presented
(versus national pasts). The overall aim of the project became to fight
the stereotypes, prejudices and old clichés in the history textbooks of
the region. Some of the participants saw this in terms of democracy and
human rights. Among all the texts included in the volumes with the
Images of Women in Bulgarian Textbooks 109
proceedings from the above-mentioned scholarly meetings, there are

only a couple of words about the importance of women’s oral history
sources and the portrayal of women in ‘history’.1 Thus what remained
missing from the critique developed by the participants in the JHP was
attention to the stereotypical portrayal of women.
There have been several more research projects dealing with the text-
books. One of them, sponsored by Koerber Stiftung, was dedicated to
rewriting East European history by developing new emphases and his-
torical fields. Another – sponsored by the British Council – resulted in the
establishment of national helpdesks for intercultural learning materials in
several European countries.2 But only a few of them paid attention to gen-
der dimensions within national education. A good example of the latter
was the research done on primary school textbooks in Croatia3 and
another project by Romanian colleagues entitled ‘Gendering Education in
Romania’.4 In both cases the findings reveal little awareness of gender
issues in school activities and no specific concern for these issues.5 In the
context of the ongoing reform of Romanian primary and secondary edu-
cation, most of the teachers interviewed showed that they were not pre-
pared for gender-sensitive education. They were predisposed to maintain
the cultural norms (including those based on gender) and rather act in a
conservative way than to be ‘(gender) norm breakers’.6 As far as Romanian
textbooks are concerned, according to the findings of the research project,
they are gender-insensitive and full of implicit and explicit sexist qualifi-
cations (e.g. the maintenance of old-fashioned myths of masculinity and
femininity in the textbooks’ texts and illustrations, the absence of educa-
tion for private and family life, etc.).
While history textbooks in the Southeast European countries are no
longer devoted solely to the narration of wars, diplomatic treaties and the
actions of monarchs and state officials, from a gender perspective their
content and the knowledge they offer concerning the economy, social life,
social groups, and culture are far from satisfactory. History textbooks are
still a long way from being means for the cultivation of critical assessment
of historical discourse; they still do not offer conceptual tools for a better
understanding of the conflicting interests of various social actors in history,
a knowledge that should help young people to understand better the cur-
rent social and political realities (Dragonas and Frangoudaki, 2001).
General considerations
Textbooks transfer, along with knowledge, the political, social and cul-
tural norms of society. Present-day history textbooks (rewritten after 1989)
in particular provide a new conceptualisation of the past. But even in

these new versions of history women are still ‘those who have no right to
history’, to borrow an expression from Lucien Febvre. The experience and
representations of women are still largely absent from the new national
history canon, demonstrating the sexist biases of the new educational
‘politics’ parading as civic and liberal. This is yet another example that the
so-called ‘turning points’ of history do not turn around the lives of
women and men in the same way. Whatever we teach must be honest, in
the sense that it must be true to the surviving ‘traces’ of the past. But this
should not prevent us as historians from seeing that the trace becomes
evidence in the process of using it to support an argument, i.e. interpret-
ation ‘prior to which, although it exists, it remains just an unused piece of
stuff from the past’ (Jenkins, 2003: 59).
Rewriting the Bulgarian history textbooks means starting a symbolic
‘civil war’ about the interpretations of the past that will affect school cur-
ricula. If until now women’s history researchers have accepted playing the
role of history’s objective analysts, it is no longer possible because what is
at stake is the formation of the civic identity of future generations. This also
means that the official discourse developed in the history textbooks can be
seen as a hidden programme for civic education. It is important to prob-
lematise the functions and selections of the historical matter presented
in history textbooks, to articulate the discriminatory silence that casts a
shadow on women’s historical existence and to overcome the silence about
the past of half of the population as this past is our ‘future’s past’.
Some of the well-known twentieth century’s scholars (starting with
Benedeto Croce7) questioned the claim of objectivity in social science, and
even Max Weber8 in his presumably value-neutral concept of social sci-
ence recognised the role of values. Others showed the manipulative and
ideological character of historical writing. History writing, according to
them, has a dual ‘nature’ – as scholarship and as a resource that legitimises
political power. As Marc Ferro put it, historical writing – in spite of its dec-
larations of ‘scientism’ – has two main functions: ‘divination’ and ‘fight’.
These ‘missions’, according to him, have been realised to a different
extent throughout history writing, but their meaning remains unchange-
able. He points out that the ‘scholarly quality’ and the methodology of
history serve as no more than ‘a fig leaf’ for ideology (Ferro, 1992: 8–13).
Dominick Lacapra likewise insists that ‘we could no longer rely on the
idea that objectivity is a normal given of historiography that is assured by
established procedures or that bias is a deviation from normality for
which we can simply “correct” ’. More than that: ‘the constructive place of
the historian’ in the ‘process of elaborating a range of subject-positions
(those of researcher, reader, and theorist or intellectual)’ should be recog-

nised and taken into consideration (Lacapra, 2000: 26). Using similarly
sobering critical language Bourdieu showed that the role of education for
cultural reproduction and social change, and for canonical scholarly writ-
ing, not only transmits but redistributes ‘cultural capital’ and power in a
society, as well (Bourdieu, 1978). Feminist historians, on the other hand,
have shown that women as a subject were ‘hidden from history’ and from
other humanities and social sciences, and that scholarship is far from
being ‘objective’ or ‘universal’ (Bock, 1991: 1).
Taking this into consideration, it is curious to follow how and why the
historical narrative is putting into relief, or ‘silencing’, certain periods or
aspects of the historical past. The fact that all history textbooks are ethno-
centric is well documented in the international historical scholarship; the
Bulgarian case is not a unique phenomenon. Here, however, I am not inter-
ested in this main ideological manipulation of Bulgarian historiography,
which is nationalistic and centred on the Bulgarians, without concern for
the historical past of the minority groups and the multi-ethnic character of
the territories considered as irredenta. I will pay attention only to the dis-
criminatory vision of women, implicit or explicit in the history textbooks’
narrative. Needless to say, in doing so, I am not claiming to be systematic
in any way. Rather, my opinion is based on a (directed, purposeful and
‘resisting’9) feminist reading and interpretation of the contents of some of
the new history textbooks published after 1989. That is to say, I do share
the opinion that scholarship in general, and history writing in particular, is
not ‘value-free’. Scholarly writing is to a larger extent ‘coloured’ by the the-
oretical, political and personal preferences of the author. Below are mine.
According to Pierre Nora, school textbooks – along with autobiog-
raphies – are among the ‘functional sites’10 of memory where every soci-
ety stores its memory for safekeeping or where it discovers it as a
necessary part of its identity. The discourse of the history textbooks
represents the official historical memory, which to a great extent is the
outcome of an inter-subjective agreement of a small group of people
belonging to the establishment. Hence the questions: whose memory
does the traditional Bulgarian historical narrative articulate and what
kind of historical knowledge does it offer?
Democratisation after 1989 and history narratives:

whose history?
The image of the ‘Other’ or the image of our own ‘self’ that lives in our
conscience and resides in our memory depends largely on how we were
taught history at school. That is why it is important to note that women

are not often mentioned as actors of history in the Bulgarian textbooks’
narratives. In the interplay between women’s ‘presence’ and ‘absence’
one can discover the development of a sexist vision of the Bulgarian
women’s past.
The silencing and misrepresentation of the second wave of Western
feminisms, the development of a negative image of ‘feminism’ and femi-
nists, combined with the firm belief of women under state socialism in
their ‘emancipation’ led to a lack of a sense of gender inequality among
Bulgarian men and women, historians included. This might suggest
why, with the ‘democratisation’ of society and scholarship after 1989,
the experience and the representations of women were not included in
the new national historical canon, confirming the political character of
history writing. So, even today, after the huge development and the
recognised influence of feminism and of women’s/gender studies –
women’s/gender history in particular – on the contemporary humani-
tarian paradigms in other parts of the world, women do not have a
historical existence for Bulgarian historical scholarship. Of course, the
historical narrative is ‘a selective view of the past’, but sometimes the
selection speaks much more for the present than for the past.
In what follows I would like to elaborate on the representation (or
absence) of women in the present-day history textbooks in Bulgaria.
My text has several limitations: 1) it is based only on textbooks about
national (Bulgarian) history; and 2) it is based only on recently pub-
lished history textbooks (after 1989, i.e. the beginning of the most
recent Bulgarian ‘transition’). However, the way of presenting world his-
tory is not very different, and one should assume that the representa-
tions and images of women that appear in world history textbooks are
of a similar kind, as the scholarly context and interests are similar for
most of the established representatives of the historical ‘guild’.
From about a dozen new history textbooks I have studied, all published
since 1989, I will analyse three: one history textbook for the fifth grade
and two ‘alternative’ textbooks for the eleventh grade, all of them first
published in 1996.
As is known, under communism there was only one unified history
textbook for every school grade. In the new conditions after 1989, in tune
with the ‘democratisation’ of society, several ‘alternative’ history text-
books from different authors or teams of authors appeared, all of them
approved by the Bulgarian Ministry of Science and Education. But all
changes notwithstanding, the Bulgarian historical scholarship today is
still traditional, which means that it is mostly a platform for the political
elite. It does not pay enough attention to the spheres outside politics –
such as the workplace, household and family – and women’s position
there.
Let me start by presenting briefly a history textbook for the fifth grade,
written by two women historians, both of them university professors. The
textbook (first published in 1996) deals with the Bulgarian history from
the fifteenth century until 1878 (i.e. the periods of Ottoman rule and the
so-called National Revival). The content of this textbook is quite different
from most history textbooks dealing mainly with political history. Out of
50 units, 21 are not traditional political history: they are devoted to eco-
nomic and agrarian history and ‘l’histoire des mentalités’. One should
point out, however, that only one out of all 50 lessons is dedicated to an
issue commonly referred to as ‘woman’s sphere’ – everyday family life.
Moreover, this lesson is not oriented towards every pupil as the authors
recommend it only to ‘the curious’ among them, and included it as add-
itional reading to the main historical corpus. Their decision to do so is
guided by the supposedly greater historical significance and ‘universal’
value of the political events and economic phenomena.
Under communism ‘an author’s history’ was unthinkable, impossible
and incompatible with the practice of textbook writing, as the authors
were expected to follow the one-sided and ideologically distorted, pre-
sumably Marxist ‘scholarly’ truth. The textbook under consideration
already shows the authors’ personal vision of Bulgarian history between
the fifteenth and nineteenth centuries as a result of their own research.
However, they did not pay attention to the most recent developments in
the Bulgarian social and cultural history.11
In this textbook, there is only one lesson dealing with an aspect of
women’s/gender history – everyday family life.12 Using the arguments of
the concept of ‘gender parallels’,13 the authors present the separate
spheres for men and women – public life for men and life within the
household for women.14 Implicit is their idea that within Bulgarian
agrarian society of the nineteenth century, there existed two spheres of
equal power: the home with its everyday domestic duties for women
and a separate, publicly oriented sphere for men. Though ‘the father
decided whether the children would go to school’ and how and when
certain work related to the household needed to be done, and his word
was quasi-law in most Bulgarian families, still, according to them, the
mother ‘was respected and loved by her husband’, because
All household matters depended on her, she was responsible [sic] for
the hygiene and the order of the house, for the meals of the children,
for the domestic animals and for the winter supplies. She was an
advisor and a supporter of her husband in difficult times.
(Mutafchieva and Gavrilova, 1996: 139)
In other words, according to these unconscious, unreflective and value-

laden opinions, women reigned within the home as undisputed
mistresses. And when ‘the man’ went away for seasonal work or on
business,
She remained both as a mother and a father … looked after the

workshop, commanded [sic] the children, span and weaved and sold
on the market all things produced by her to get money for household
expenditure.
(Mutafchieva and Gavrilova, 1996: 139)
No doubt a man would really have to love a woman very much in order
to honour her with so many obligations! The only implication about the
(hierarchical) construction of gender difference, told to the fifth-graders,
is the statement that from their early childhood ‘boys started to learn
man’s work’ while girls were taught ‘how to sew and knit’, ‘to weave and
spin’ and ‘how to bake bread’. But in spite of the separate domains, ‘the
whole family participated in the work on the fields’.
The quotation above sounds very much like a lecture on the
typical traits and mentality of the Bulgarian people – a principal concern
of the so-called ‘national psychology’, inspired by the German
Volkspsychologie. This type of knowledge has the pretence of scholarly
status and can be characterised as arch-patriarchal and traditionalist.
I would like to cite (for a comparison) some lines by a well-known
Bulgarian male writer, Konstantin Petkanov, who was educated in
Germany and was an admirer of Volkspsychologie. His article, entitled
‘The Spirit of the Bulgarian Woman’, was published in the authoritative
philosophical journal Filosofski pregled in 1933. Here are some typical
lines from it:
The Bulgarian woman has as the main goal of her life to give joy to
everybody. That is why she does everything one wants from her: she
gives birth, cleans, makes bread, washes, sews, weaves, ploughs, sows,
gathers in the harvest, digs, etc. … When she loves, she shows her
love through the work … her personality is nothing, her family is
everything for her…
(Petkanov, 1933: 386)
But the reader should not think that the limitations that patriarchy puts
on ‘the Bulgarian woman’ makes her unhappy or ‘a man’s slave’. Just the
opposite:
She neither complains about life and its difficulties nor tries to gain
her freedom.
(Petkanov, 1933: 387)
We can recognise implicit and even explicit in the writings of contem-

porary Bulgarian historians the old patriarchal ideology of the type of
‘folk psychology’. By reading and hearing in schools such essentialising
representations of the self-negating creature, existing through her chil-
dren and her family, the school girls and boys internalise them to the
point that they become ingrained in their minds as ‘habitus’.15 These
texts convey their messages indirectly, by simply assuming that, for
women, there are certain ‘right’ things to do and correct ways to behave.
What is more frustrating to me is that women historians partake in what
a Bulgarian male colleague of mine in another context very properly
defined as ‘self-colonising cultures’ (Kiossev, 1995). Those women histor-
ians themselves willingly subscribe to an ideology of ‘femininity’, and
thus become complicit in their own subordination.
‘Alternative’ history textbooks
In this section I would like to discuss two other ‘alternative’ textbooks for
the eleventh grade (again) published in 1996. The first is co-authored by
(four) male university professors (Giuzelev et al., 1996); the second was
written by a team of nine historians, who teach at the Department of
History at Sofia University ‘St. Kliment Ohridski’, four of them women
(Delev et al., 1996). The second textbook is better written and looks more
modern from a methodological point of view. The material is better
organised with citations of ‘prime sources’ and the main scholarly dis-
cussions, related to some of the presented topics. Thematically, however,
it is again a traditional narrative (63 out of 88 units are dedicated to
clearly political matters).
The his(s)tory in the first textbook begins with the prehistoric past of
‘the Bulgarian lands’ and goes up to December 1994, when the first gov-
ernment with a woman as prime minister (Reneta Indjova) was estab-
lished. Following the old Marxist clichés of history the narrative starts
with the Palaeolithic epoch (Stone Age) and shares the firm conviction
that gynocratic forms predominated at the dawn of civilisation; the
authors then introduce the image of ‘the woman’ from the ‘matriar-
chate’ – the epoch when ‘she’ presumably ruled the society. Convinced
that the matriarchate is a primitive stage in the progressive evolution of
society, the authors trace its replacement by a patriarchate (as the next
stage of the Bulgarian historical pageant) (Giuzelev et al., 1996: 13, 15).
In fact, one can see here a strategy ‘to relegate women’s power to the
remote past’, to assign them a place in ‘prehistory’, to associate them
with barbarian, ‘gynocratic regimes’ with their typical absence of law
and morality, all this meaning to ‘write women out of the picture’ (cited
in Georgoudi, 1992: 463),16 i.e. to exclude them from history. This is
what clearly happens in the Bulgarian case.17 One can observe that as
one goes forward in Bulgarian history and approaches the modern age,
the representations of women in the history textbooks become fewer.
The next mention of women comes in the medieval period when
women of noble birth appear as wives and daughters of the kings of
Bulgaria, of the Byzantine Empire or other neighbouring countries. The
princesses and queens, the most privileged of women (and fewest in
number), are presented either as passive actors in events directed by men
or as aggressive rivals and seductresses in the competition for power/the
throne. While it is clear that the ruler’s office was then a source of cultural
models that shaped social behaviour, it is not at all evident whether those
women had any public role. The representations of the queens who
belonged to the ethnic ‘Other’ are especially interesting. Foreign wives of
Bulgarian kings (tsars) are named by their ethnicity, e.g. ‘the Jewish
woman Sara’, ‘the Hungarian woman Ana’, ‘the Byzantine princess
Maria’, etc. This follows the patterns of xenophobic (especially anti-
Greek) nationalist writing constructed in the period of ‘National Revival’
(Danova, 2001) but also strengthened by the authentic language of the
religious misogyny of the medieval Christianity used by the authors. The
close citation of the medieval sources and the reproduction of character-
istics given to women there obviously demonstrate the authors’ under-
standing of ‘value-free’ and ‘universal’ scholarship.
In the second textbook for the eleventh-graders, Bulgarian women are
mentioned for the first time as historical actors in the ninth century,
when they were mobilised together with men in the wars against the
Byzantine Empire. Women (together with children and the elderly)
appear there not only as warriors but also as passive victims of the
Byzantine ‘invaders’. One story concerns the correspondence between the
Bulgarian king Boris I and Theodora, the mother-regent of the emperor
Michail III, a minor. Readers are informed that in a letter to Boris, she
wrote that she would inevitably emerge as a winner in the war between
them because even if he managed to defeat her, his victory would have
been gained against a woman. It is understandable that medieval sources
undervalue the political achievements of female actors in history in tune
with the prevailing ideology of the time. But one wonders why the
authors of the textbook favoured such a story and what its implicit
message to pupils is.
Women appear mainly as objects of dynastic marriages. They are men-
tioned only as daughters, granddaughters, sisters, etc. of the rulers, in
some cases even without their names, i.e. they are not presented as per-
sonalities but as relatives to a great man. Due to the masculine character
of medieval culture, women appear in documents and literary texts only
as reflections of male visions and fantasies about them. One of the
things that usually catches the attention of the medieval narrator – but
also of contemporary male historians – is the woman’s beauty. There is
a pervasive tradition in which women are portrayed and referred to as
objects of pleasure, whose qualities are discussed by men. In the text-
book under consideration there are several passages showing man’s
objectifying gaze towards ‘the beauties’.
Female actors once again become visible with ‘the Bulgarian contribu-
tion’ to the history of ideas through the medieval ideology of the
heretics, known as ‘bogomils’ (‘dear to God’). Readers are told that the
bogomils preached a negative attitude towards legal Christian marriage
and considered ‘the woman to be a creature equal to the man’. The
implicit message of those lines is that because only heretics believed in
equality between the sexes, it is wrong to believe in such equality; that
this way of thinking is peculiar to heretics, people deviating in their reli-
gious beliefs and behaviour from ‘the norm’. The bogomils, continue the
authors, held explicitly sexual views, such as that ‘one should not rebel
against human nature and the desire of the flesh’, and they preached that
people should obey the Devil, not God (Delev et al., 1996: 131). It is clear
that when put within the context of such scandalous ideas of the
‘heretics’, the idea of equality between women and men can provoke a
more puritanical mind.
The lesson on everyday life of medieval Bulgarians contains several lines
about women. They are represented as natural creatures, as reproducers,
whose main responsibility is childbearing and child-raising. According to
one of the textbooks, because of the ‘high child mortality rate and the
shortness of human life, people (and especially women) married early
(between 12 and 15 years)’ (Giuzelev et al., 1996: 88). Women are incor-
rectly presented as having the right to choose the time (and partner) of
their marriage while medieval marriage was largely a strategic manoeuvre
and usually an act of violence against the wills of both girls and boys in
line with patriarchalism and ingrained tradition. The authors of the
‘alternative’ textbook, however, reveal the true character of medieval
marriage – a deal planned by parents during their children’s early child-
hood. But it would be incorrect to interpret the lack of freedom to choose
a spouse as a form of oppression because similar limitations on the free-
dom of action were imposed on all so-called ‘dependants’.
As some women’s historians rightly point out, the specific oppression
of women in arranged marriages can be found in their becoming man’s
dependants, the strict control exercised over their bodies and sexuality.18
However, the reader cannot find evidence of ill treatment of women in
the first textbook. If she is curious enough (and looks for additional infor-
mation in the alternative textbook) she will ‘discover’ something about
women’s inferior status in the medieval family. She will read there that
during the Middle Ages among the grounds for divorce were ‘infidelity,
drunkenness, impotence but not the mistreatment of a spouse by her
husband’. Actually what the pupil learns is that the husband was allowed
to beat his wife. No author comments on this. (Of course, one cannot
expect that authors who pretend to present only ‘objective historical
truth’ would explicitly state their opinion on such a ‘marginal’ problem,
even less that they would present medieval marriage from a female
perspective, whatever that means.)
Last but not least, and not without connection to the maleness of the
authors of the textbooks (and with some national pride!), they write
that ‘the women’s traditional dress … accentuated the slender waist of
the Bulgarian woman’ (Giuzelev et al., 1996: 90). In other words, they
imagine and see ‘the Bulgarian woman’ from the past with the typical
objectifying male gaze. If the pupils read the ‘alternative’ textbook, how-
ever, they would be confused to discover that ‘everyday female dress’
was loose, and not nipped in at the waist ‘in order to hide the beauty
and the suppleness of the body’ (Delev et al., 1996: 148). What women’s
dress was actually like is irrelevant, since the implicit purpose in both
cases is to praise ‘the beauty of Bulgarian woman’.
Witchcraft in the Middle Ages interestingly is mentioned only once
and then in relation to a man – the so-called Boyan-Magiosnikut (Boyan
the Wizard), a son of the Bulgarian tsar Simeon I. No female witches are
mentioned.
Another reference to women comes in a section dedicated to family
life under Ottoman domination: the students learn that the Bulgarian
family is monogamous, the Muslim polygamous (Muslim men were
allowed to have up to four spouses).
The man, husband and father, was the main figure, the head of the
family. According to the laws, the family’s property belonged to him,
and he was the real master of the house. The spouse-mother was
responsible for the everyday work and for raising the children. She
participated equally with the man in the agricultural work but she was
also entrusted [sic] with responsibilities for the garden, the domestic
animals and the weaving of cloth.
(Delev et al., 1996: 140)
This is interesting. It appears that the male authors of this textbook are
more aware of the asymmetry and gender hierarchy in the traditional
family everyday life than the women historians already cited.
Women appear for the first time as public figures in this textbook dur-
ing the so-called period of National Revival. They are mentioned, how-
ever, only as participants in women’s educational societies (in one of
‘the alternative’ textbooks for the eleventh grade). Although there are
at least several publications on the role of women teachers for example,
not a word is written about their active participation in the communal
life of the time. Quite striking also is the lack of reflection on women’s
participation (as producers) in home industries, though it is well docu-
mented. Women do not appear even in the lesson about everyday life
during the period of the National Revival. The historical actor described
there is the depersonalised, non-gendered ‘Bulgarian’.
Several women in the creative professions – actresses, artists, poets,
pianists, and opera-singers – are mentioned in the period of the Bulgarian
liberal nation-state (1878–1944). The paradox is that in comparison with
the pre-modern, traditional society, women become even less visible in
modern times despite the fact that they become more active and publicly
visible (thanks to the better preserved written sources, and to the high
level of women’s literacy and education). Nothing is said even about the
enfranchisement of women in 1937 and 1938 (for local and parliamen-
tary elections).
Still, the authors report that in 1905 the Bulgarian National Assembly
voted in the first law for the protection of women and children’s labour.
Women and girls also appear on the pages of the ‘alternative’ textbook
as victims of sexual abuse (rape) in 1903 during the Ilinden uprising of
the Bulgarians of Macedonia and Thracia against Ottoman rule. The
authors report data on 3,122 Bulgarian women violated by Muslims. Of
course, I do not underestimate this fact but one wonders why women
are represented in school textbooks only as natural beings: as reprodu-
cing children or as victims of male sexual aggression. As many scholars
have shown, victimising victims contributes to the perpetuation of their

victimisation.
The last and only reference to women in the section on communist
rule explains the demographic problems of the country in the 1970s
with the migration of women of ‘fertile’ age to the towns. The migration
is presented as voluntary, and nothing is said about communist politics,
which mobilised and praised women either as ‘builders of socialism’ or
as ‘mother heroes’, depending on the priorities of the time.
Conclusion
I have analysed several new history textbooks (published after 1989) in

an attempt to suggest a gender-sensitive reading, interpretation and
questioning of the official history narrative that still prevails in the
Bulgarian educational and scholarly institutions. In this final section I
summarise the results of this study.
The images of women that appear on the pages of Bulgarian history
textbooks represent ‘woman’ as an immutable natural being. ‘She’ gives
birth and raises children, lives her whole life at home or in the fields,
takes care of the small things in everyday life, and is ‘protected’ from
being active in the public sphere, where power is exercised. The repro-
ductive (‘natural’) ‘function’ appears to be the main, if not the only, role
for Bulgarian women in the past – their ‘destiny’. What transpires in the
pages of the school textbooks is the sexist vision of ‘woman’ as a nat-
ural, passive and motherly creature, totally immersed in ‘her femininity’
while ‘man’ is gendered only in his relations to ‘woman’ and his attrib-
utes are considered to be universal. Men’s activities are considered to
be not biological but political – something that secures their place in
history.
The fact that some of the authors of the history textbooks are women
has in no way changed the ‘conservative’ and nation-centred spirit
prevalent among the members of the profession. Aware only of their own
successful professional career, women historians are not sensitive to their
own ‘femaleness’ and the limits of the existing power frames. The the-
matic professional choices of those women historians are conditioned
by the educational and scholarly institutions in which they work. The
topics and issues of their interests demonstrate that they unconsciously
internalise the objective social structures and norms, including scholarly
ones, which become what Bourdieu would call their habitus.
The very limited representations of women in history textbooks
can also be explained by the fact that social history in Bulgaria is
underdeveloped (if we exclude, that is, the ideologically distorted his-

tory of the working class that was extensively researched under com-
munism). But even the political actions of women are not visible in the
textbooks.
Instead of the ‘silence of the Middle Ages’ one should properly speak
about the ‘silence of the Modern Ages’ regarding Bulgarian women’s his-
tory.19 Due to the lack of goodwill and scholarly (and political) interest,
women are almost absent from textbooks in spite of the existence of
many documents and archival material about Bulgarian women in the
nineteenth and twentieth centuries. ‘History’ remains mute when histor-
ians do not allow it to speak.
The presumably ‘universal’ and ‘value-free’ language of the textbooks
is not innocent but ideologically manipulative. It does not help over-
come the traditions of the patriarchal culture but supports their perpetu-
ation. It possesses huge symbolic power which builds images, forms
attitudes, values and modes of behaviour, and reproduces patriarchal
hierarchical relations in various social domains.20 This is the power that
selects some voices to be heard and causes others to be ignored, discip-
lined, rejected, ironised or ostracised.
The incorporation of women’s history in ‘the functional places of
memory’ (Pierre Nora) is an important part of the identity politics of
every society. For some Western societies, this was an issue of scholarly
debate and concern some 30–35 years ago, when the new wave of femi-
nism reached its peak and helped the establishment of women’s/gender
studies as a scholarly discipline. During the 1980s Western European
feminists denounced the sexism hidden in their national history
textbooks.21
Feminism, however, is almost nonexistent as social practice and
unknown or misrepresented as an ideology in present-day Bulgaria. As
everywhere in post-communist East European countries, there are ‘deep-
seated notions of gender difference’ combined with the idea of ‘a lack of
any real sense of gender inequality’ (Watson, 1993). That is why a myth
of ‘gender harmony’ is being elaborated by some East European scholars
and women’s activists in contrast to the Western feminist idea of uni-
versality of gender power relations. From here, it is not difficult to reach
the concept of ‘gender parallels’. It seems that communist propaganda
succeeded in silencing the ‘eruptions’ and ‘flows’22 of Western femi-
nisms. The communist notion of emancipation and equality (equated
primarily with ‘the right’ to work), inculcated by the ‘old regime’ in the
minds of many people, still prevails. Whoever expects different (femi-
nist) thinking on topics that have to do with women and gender will
have to wait until a new generation of East European feminist scholars

appears, well schooled in the new paradigms of today’s humanitarian
thought and free from the old Communist ideological dogmata.
To represent women as active social actors in the past means shatter-
ing the stability of the traditional history narrative. Reconsidered from
the perspective of women, history requires other signposts. To rewrite
Bulgarian (as well as southeast European) history means starting a ‘civil
war’ with existing ‘universalistic’ interpretations. But if we want our
contemporary education to build a tolerant and pluralistic society in the
future, women should enter History.
The notion of citizenship with its key idea that all individuals are born
free and equal – based on the liberal ideas of individualism and equality
developed during the seventeenth century – marked a radical departure
from traditional ideas of society as made up of natural hierarchies and
inequalities. Liberal ideology presents the modern abstract (‘universal’)
individual as a social actor without gender, but in fact this individual
still possesses all the qualities that women are assumed not to have
(Okin, 1979). Feminist scholars criticised the liberal (male) understand-
ing of citizenship which applies only to rights, entitlement and patterns
of participation in public institutions. They argue that it is important to
explore the history of the public-private divide alongside the history of
citizenship as the public and the private are valued differently, ruled by
a different logic of action, and gendered. Men’s citizenship – according
to feminist scholars – was constructed on the ‘fraternal social contract’
of women’s exclusion and on the domestic patriarchal power they were
given. And as the case with the Bulgarian history textbooks shows (as
well as textbooks dealing with a new subject called ‘civic education’
recently added to the school curricula23) a cultural change should be
made from social models where women are absent or are defined as
‘minors’, or mainly in relation to their reproductive capacities, to models
in which they are defined as persons and individuals, entitled to take
equal part in public institutions of modern society. Only then can one
expect that representations and images of women in contemporary
Bulgarian (and not only Bulgarian) textbooks would not essentialise
and dehistoricise women, but help overcome the implicit misogynistic
denial of women’s basic humanity.
Then, and only then, will it no longer be necessary to struggle to define
women’s rights as human rights. Then, and only then, women’s presence
in the (local, central and all-European) bodies of political power – in
municipal and parliamentary structures – will make a difference.
Notes
1. In Katz (2001) there is just a word about women’s oral history sources, espe-
cially p. 65. Hanna Schissler is the only one to pose the question: ‘How are
women portrayed? Do they play a role at all in “history” ’? See Schissler (2001:
especially p. 95).
2. On the idea for helpdesks, see Sercu (1999).
3. Reported by the Croatian participants at the Helsinki workshop on women’s
political participation in September 2003.
4. On this see: Stefanescu and Miroiu (2001). There is a chapter in English that
summarises the results: see especially pp. 60–96. See also Miroiu (2003).
5. Stefanescu and Miroiu (2001: 60).
6. Ibid., p. 75.
7. At the beginning of the twentieth century Croce wrote that most historical
writings pose the problems of their own time rather than of the epoch they
are supposed to be studying.
8. Weber (1959) outlined the limits of the possibility of ‘a value-free scholar-
ship’. See also Runciman (1978).
9. The terms ‘resisting reader’ and ‘resisting reading’ are due to Fetterleey (1978).
10. Sites of memory (‘lieux de mémoire’), according to Nora, are artificial and
deliberately fabricated. They exist to help us reveal the past and ‘to block the
work of forgetting’. He speaks about ‘the topographic’ (archives, libraries,
museums), ‘memorial places’ (architectural memorials and cemeteries) and
‘symbolic’ sites of memory (as commemorations, pilgrimages, anniversaries,
emblems) – all of them pretentiously universalistic, i.e. men-centred. See
Nora (1989).
11. About the publication related to the history of women, gender and family in
Bulgaria, see Daskalova (2002: 364–74).
12. On the ‘field’ of women’s/gender history, see Bock (1989: 7–30, especially p. 9).
13. Ida Blom has pointed out that one should keep in mind that, despite the idea
of ‘gender-parallels’, state legislation and popular traditions are subordinated
to male authority. See Blom (1991: 135–49, especially p. 140).
14. In another (already scholarly) publication, however, Raina Gavrilova claims
that ‘public’ and ‘private’ are ‘imported’ terms that ‘meet the resistance’ of
the local ‘historical reality’. See Gavrilova (2001: 98–107).
15. On this term, see Bourdieu (1977).
16. For a more recent analysis related to this topic, see Taylor Allen (1999).
17. In the other textbook considered here, no woman appears in the narrative
about prehistory. Absence and silence are what one finds as alternatives.
18. On this, see Opitz (1992).
19. Here I refer to the subtitle of Volume II: A History of Women in the West, edited
by Christiane Klapisch-Zuber (1992), Cambridge, MA: Belknap Press of
Harvard University Press.
20. On the symbolic power of language, see Bourdieu (1991).
21. See, for example, ‘Image de la femme dans les manuels scolaires’, and
‘Frauenbuild in Schulbuechern’, from the collections of the Historical Archive
of the European University Institute-Florence, Italy.
22. Those metaphors were coined by Offen (2000).
23. Probably it is suggestive to mention that the recently published textbook for
the twelfth grade of the Bulgarian secondary schools, entitled ‘The World and
the Individual’, which is supposed to give basic knowledge about society and
its citizens, does not differentiate between women and men citizens but speaks
in pretentiously non-gendered ‘universal’ terms that actually follow the old
clichés claiming that to be a ‘woman’ or a ‘man’ is biologically predestined. See
Grekova et al. (2002: especially pp. 112, 113 and 130). Speaking about the hier-
archy of identities, its companion book (Deyanova et al., 2002) does not even
mention that there are gender hierarchies in the contemporary societies (see
especially pp. 21–3).
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7
Strong Together? A Comparative
Study of the Impact of the
Women’s Movement on
Policy-Making in Finland
Anne Maria Holli
Introduction
Securing women’s political rights has become increasingly prominent in

international law and treaties on human rights. At the outset, starting
from the United Nations Declaration of Human Rights in 1948, the
focus was on ensuring women’s formal political citizenship rights only,
that is, suffrage and formal eligibility for public office. Over time and as
societies proved resistant to accepting women as fully-fledged political
actors, the focus gradually shifted to emphasising women’s inclusion in
all forms of decision-making, as well as incorporating gender equality
considerations in all the levels and stages of policy-making (gender
mainstreaming). The motivation is often that women’s increased partici-
pation is conceived as enhancing democracy. Paradoxically, however, as
this chapter illustrates, democracy may also be an important precondi-
tion which helps realise the participation of women’s constituencies in
public policy-making. It also shows that their inclusion indeed matters,
as it tends to produce more satisfactory policy outcomes.
This chapter explores the issue of women’s substantive representation by
focusing on the impact of women’s movements on Finnish public policy-
making since the late 1960s. The case study on Finland was completed as
part of a larger international comparative project, the Research Network on
Gender, Politics and the State (RNGS). My aim is to present a comprehensive
analysis of the results on Finland, illustrating which women’s movement
strategies and institutional mechanisms have contributed to Finnish
women’s relatively high policy success. The analysis highlights the adap-
tation and interconnectedness of women’s movement strategies and
127
128 Anne Maria Holli
activities to the political environment in which they function, showing

how Finnish women have found openings for ‘critical acts’ (Dahlerup,
1988) to improve women’s status in society. The steady increase of women
representatives in the legislature but also in other, related arenas, has
added to Finnish women’s opportunities to deploy system characteristics
for coalition-building and mutual strategic alliances (Halsaa, 1991). During
the last fifteen years, this has also led to more institutionalised forms of
cross-party co-operation for women’s party organisations and many joint
campaigns by women Members of Parliament (MPs) in the parliamentary
arena. At the same time, however, membership in the European Union
(EU) and concurrent shifts towards supra-national decision-making arenas
as well as other structural changes pose new challenges for Finnish
women’s opportunities to influence policy-making (see e.g. Kantola in
this volume).
The chapter is structured as follows. It starts by presenting the back-
ground RNGS theoretical approach, followed by a description of its
cross-cultural comparative results regarding opportunities and barriers
for women’s policy success. After that, the results of an analysis of twelve
Finnish policy debates are investigated, pointing out some specific pat-
terns revealed by the Finnish data and reflecting on their significance.
Analysing women’s movement impact on public

policy-making: the RNGS approach
The concepts of descriptive and substantive representation and their rela-

tionship have been of major interest to feminist political studies (e.g.
Jónasdóttir, 1988; Phillips, 1995; Young, 1990, 2000; Childs, 2004; see also
Pitkin, 1967). Descriptive representation refers to the idea that political
representatives are regarded as representing their electorate because of
shared traits or a similar background, for example, gender, class or ethni-
city. Substantive representation on the one hand refers to the ways in
which, for example, women’s interests are advocated by their democrat-
ically elected representatives and are included in the formulation of
public policies (Pitkin, 1967).
These concepts are fundamentally linked with core questions in femi-
nist politics: Does legislators’ gender affect their political activity and, if
so, how? Do women MPs and other political actors represent ‘women’s
interests’ (however these are defined) to any degree? Do women get what
they want out of public policy-making when are they successful, and what
are the barriers? What kinds of possibilities for social and political change
are implied by women’s increased mobilisation and political presence?
The Impact of the Women’s Movement on Policy-Making in Finland 129
Interested especially in the links between descriptive and substantive

representation, the Research Network on Gender, Politics and the State (RNGS),1
working since 1996, has developed a systematic, cross-cultural comparative
approach to the study of the impact of the women’s movements and
the role of state feminism in post-industrial democracies. In the RNGS
approach, several strands of theory – democratic representation, new insti-
tutionalism and social movement theory – are combined with an analysis
of gender and feminist politics. The focus of the study is the interaction
between women’s movements and the state, hypothesising that women’s
policy offices form a link between the two. The research project sets out to
analyse the impact of women’s movements on public policies (dependent
variable) and the role played by women’s policy agencies (intervening vari-
able) in this process. Variations in the dependent and intervening variables
are examined by two clusters of independent variables: women’s move-
ment characteristics (stage, closeness to the Left, priority of issue, cohesion
and strength of counter-movement) and the characteristics of the policy
environment (characteristics of the policy sub-system, party or coalition in
power and frame fit). The analysis applies the qualitative comparative
method to an in-depth analysis of a small number of cases (see e.g. Ragin,
1987; King, Keohane and Verba, 1994).
In the RNGS model, Gamson’s (1975) distinction between substantive
and procedural responses by the state to social movement demands pro-
vides the basis for the study of movement impact. Substantive response
refers to whether or not the state changes the substance of policy in order
to meet the demands of the movements. Procedural response, on the other
hand, refers to whether or not the state accepts the movement organisa-
tion as a legitimate representative of movement interests in the political
process. By analysing the impact of the women’s movements in the frame-
work of these two dimensions, the model sets up four possible outcomes
for movement effect on public policy (Table 7.1). Dual response thus refers
to a women’s movement success on both dimensions; no response to a fail-
ure on both accounts. The other two values (pre-emption and co-optation) are
Table 7.1 Typology for movement impact/state response
Women involved in Policy content coincides with

policy process women’s movement goals
Yes No
Yes Dual response Co-optation

No Pre-emption No response
Table 7.2 Typology for women’s policy agency

activities
WPA genders WPA advocates women’s

policy debates movement goals
Yes No
Yes Insider Non-feminist

No Marginal Symbolic
cases of partial movement success in regard to the substantive and proced-

ural responses respectively.
Women’s policy agency activities and characteristics are hypothesised
as an intervening variable in the analytical framework. The role of these
agencies is conceptualised on two dimensions: Is the women’s policy
office an advocate of women’s movement goals or not in the policy-
making process? Is it effective in gendering and changing the terms of
the policy-making process to coincide with those of the women’s move-
ments? Four possible types of women’s policy agency activity emerge
from the typology: insider, marginal, non-feminist and symbolic, representing
declining activism by the agency in the policy-making process under
investigation (Table 7.2). Moreover, the characteristics of the agency are
analysed as to its scope, type, proximity to power, resources, leadership and
policy mandate.
In sum, the RNGS project is interested in such questions as: Do women’s
movements achieve what they want as far as public policy-making is con-
cerned? When are their political initiatives successful? When do they fail?
Is a state women’s policy machinery to mediate and aid women necessary
if their efforts are to be successful in influencing policy-making? To pro-
vide answers to these questions, the project has systematically mapped
the values for the targeted variables in the policy debates, seeking to dis-
tinguish favourable and unfavourable political opportunity structures
from women’s points of view.
As my aim is to concentrate on the results of the research with a spe-
cial emphasis on women’s movement impact, I will limit the presenta-
tion of the methodology of this joint approach to pointing out some of
its advantages to the study of women’s substantive representation and
feminist comparative politics.2
First, in the RNGS approach the study of women’s movements is not con-
fined to what could be called ‘feminist movements’ only. Rather, the model
adopts a broader perspective on the concept, noting the various cultural
expressions of both ‘feminism’ and ‘women’s movements’. This is achieved

by targeting the participation and activity of women as individuals, groups,
organisations, networks and women’s publics in so far as they claim to
represent women or women’s interests in some manner in a given policy
process. In this way, the project is able to take into account the variations in
forms of women’s mobilisation in different countries and cultures, whether
they be ‘feminist’, ‘traditional’ or even ‘anti-feminist’, and whether they are
organised in autonomous movements, inside parties or institutions or, for
example, as informal ad hoc networks or actions (RNGS, 2004).
Second, in feminist studies it is quite common to be interested in laws,
public policies and policy sectors initially thought of either as advanta-
geous or disadvantageous to women. The question is whether this often
implicit choice of subjects also affects the outcomes of research. Do we get
too rosy a picture of women’s impact on public policies on the basis of
studying, for example, the introduction of new gender equality legislation,
where, as we know, women are bound to be very active? Or vice versa, is
the resulting picture too negative, if we decide to limit our study to, for
example, economic policy or foreign policy? The RNGS approach has tried
to avoid this implicit bias, first, by selecting a wide range of policy sectors
to study over time, and second, by utilising debate selection criteria which
emphasise issue salience and the variety of debates in terms of the debate
life cycle and decisional system importance (RNGS, 2004).
Third, in the RNGS model, the unit of analysis is the policy debate
instead of the more conventional choice of the country. Using this choice,
the model allows for comparisons across the issues and policy areas, as well
as for longitudinal studies on the women’s movements and their inter-
actions with the state, in a national setting, for instance. The methodology
makes any national differences between the countries a matter of empirical
study, not an assumption that is inherent in the model (see also Mazur and
Parry, 1998).
Finally, during the process the project has gathered rich qualitative
data on the policy debates, which is a source for further ideas and new
approaches. The careful groundwork done by individual researchers facili-
tates the construction of new hypotheses about women’s policy influ-
ence, and makes it possible to test them empirically. It also provides a
plateau for diversifying the analyses theoretically and methodologically
in new directions. For example, the overall results achieved by the RNGS
project are in the process of being converted to a quantitative data set,
which makes it possible to use statistical methods to assert causal pat-
terns in the service of theory-building. There also exist alternative, more
qualitative attempts at building on the work done so far.
When and where do women’s movements succeed?

Results of the cross-cultural comparative analysis
So far, the RNGS project has completed its results on four policy areas: job
training (Mazur, 2001c), abortion politics (Stetson, 2001c), prostitution
policies (Outshoorn, 2004c) and political representation (Lovenduski et al.,
2005b), with the remaining analyses due to be published over the next few
years. For the time being, the published data include analyses of 122 policy
debates over time from 15 post-industrial democracies and the EU.
Across the policy sectors, women’s movements achieved full policy sat-
isfaction (dual response impact) in 48 per cent of the debates in the terms
of the approach whereas they faced total failure (no response impact) in
21 per cent of them (Mazur, 2001b; Stetson, 2001b; Outshoorn, 2004b;
Lovenduski et al., 2005a). The remaining 31 per cent of partial outcomes
consisted of 21 per cent of co-optation impacts (no policy satisfaction
despite women’s involvement) and 10 per cent pre-emptive outcomes
(authorities adopting women’s movement demands fully or partly with-
out women’s involvement and access to the policy process). Thus, in
sum, women’s movement concerns were inserted in public policies in six
cases out of ten (dual response and pre-emption outcomes combined).
The results also illustrate that women’s and women’s movement involve-
ment in the process achieved a satisfactory outcome five times more often
than when they were excluded from it. Nevertheless, even when women
were included as active participants in the process, in two cases out of ten
for some reason they failed to achieve policy satisfaction.
These overall results from the RNGS project suggest a slightly more
pessimistic – but nevertheless quite remarkable – evaluation of women’s
potential to influence public policy-making than Mazur’s (2002) com-
parative cross-cultural analysis of public policies. There she, utilising a
different method for evaluating policy success and secondary sources on
policy debates, found a much higher feminist policy success rate, few
low success cases and no total policy failures at all.
One of the main observations of the RNGS project is that different pol-
icy sectors seem to offer very different political opportunity structures
from women’s points of view (cf. also Mazur, 2002: 184–5). Whereas in
job training full policy success (dual response impact) was achieved in
only 28 per cent of the debates, in abortion policy, prostitution policy
and debates on political representation the success rate was over 50
per cent (57 per cent, 53 per cent and 52 per cent respectively). The policy
failure rate (no response impact) suggests something similar: in job train-
ing policy women failed to obtain any response in 48 per cent of the
debates. In abortion policies the failure rate was only 7 per cent; in prosti-
tution 17 per cent; and in political representation 15 per cent (Mazur,
2001b; Stetson, 2001b; Outshoorn, 2004b; Lovenduski et al., 2005a). Out
of this range, job training was thus the most hostile to women’s demands,
abortion policy the most accommodating.
In their comparative analyses concerning the individual policy sectors,
Mazur (2001b), Stetson (2001b), Outshoorn (2004b) and Lovenduski et al.
(2005a) conclude that the independent variables – the characteristics
of women’s movements and the policy environment – seem to play a
decisive role on women’s impact. The probability of women’s policy suc-
cess is higher when:
• the policy sub-system in question is moderately closed or open3 in

character;
• the Left is in power;
• the women’s movement which is mobilised by the debate is close
to the Left, the issue is of high priority to the movement, and the
various strands of women’s movements are unified on the issue.4
In contrast, the likelihood of policy failure for women’s movements is

highest when the policy-making sub-system is closed and the Left is not
in power (Mazur, 2001; Stetson, 2001b).
Although the same variables appear important to all the policy sectors
studied, there are some variations in their relative weight. For example,
Mazur (2001b), Outshoorn (2004b: 288) and Lovenduski et al. (2005a)
stress the crucial significance of policy environment characteristics in
the areas of job training, prostitution and political representation. By
contrast, Stetson (2001b: 286) claims a prioritised role for women’s
movement characteristics in abortion policy. The varying emphasis
seems to reflect the in-built differences between opportunity structures
in those different policy sectors, as well as the distance of a policy issue
being a ‘women’s issue’ in the first place.
The RNGS studies also conclude that women’s policy offices constitute
effective links between women’s movements and the state. Women’s move-
ments have tended to be more successful where state structures for
women’s policy have acted as insiders in the policy-making process, that is,
they have gendered policy debates in ways that have coincided with
women’s movement goals. By contrast, the movements have been less suc-
cessful when women’s policy agencies have played some other role,
whether it be marginal, non-feminist or symbolic. Together, these results
make for a strong argument for the important role played by state feminism
Table 7.3 Country comparison by dual response/no response impact

across policy sectors
Country Dual response No response
Finland (N ⫽ 125) 58% 25%

Italy (N ⫽ 11) 55% 18%
USA (N ⫽ 12) 50% 33%
Canada (N ⫽ 9) 44% 11%
Spain (N ⫽ 11) 36% 27%
France (N ⫽ 14) 29% 43%
Average (all RNGS data N ⫽ 122) 48% 21%
in aiding women’s demands in public policy-making (Mazur, 2001b;

Stetson, 2001b; Outshoorn, 2004b; Lovenduski et al., 2005a).
The RNGS has so far focused on policy sectors. In this framework,
national patterns are not easy to discern because of the low number of
debates studied within each single country. Consequently, the RNGS
analyses have not found much evidence on nation-state patterns for pol-
icy outcome (Mazur, 2001b: 316–17; Stetson, 2001b: 292–4; Outshoorn,
2004b: 289–90; Lovenduski et al., 2005a). However, as the project is evolv-
ing and completing its database, it also becomes possible to investigate the
question of country-specific patterns more closely.
Table 7.3 presents data contrasting full policy success and full policy
failure in a set of countries analysed by the RNGS. The presentation is
limited to the countries where, first, job training was analysed, and second,
where there were about ten policy debates studied in the country. The aim
of the first restriction is to ensure that the sample of the debates in the
country not only concerned the more ‘women-friendly’ policy sectors but
had a sufficient span over differing sectors. The aim of the second limita-
tion is to ensure that there were enough policy debates studied across the
sectors in the country to lend some reliability to tentative conclusions.
Finland tops this list of nation-states with slightly more women’s full
policy success than the average, followed by Italy, the United States and
Canada. At the other end of the spectrum, Spain and France appear rela-
tively unresponsive to women’s movement demands; in particular, the
failure rate in France is high when compared with the overall average.6
The results – with the notable exception of Italy7 – broadly coincide with
what we would expect on the basis of earlier comparative studies (see
e.g. Norris, 1987; Sainsbury, 1994; Stetson and Mazur, 1995; Bacchi,
1996; Mazur, 2002: 188–9; Inglehart and Norris, 2003).
However, the results also clearly illustrate that there is no straightfor-
ward relation between the proportion of women’s political representation
and their policy success. In Finland, the proportion of women MPs has
been very high for a long time (in 2005, 37.5 per cent), combined with
high policy success. The United States (14.9 per cent), despite its very
active women’s movement, does not even reach the world average (15.8
per cent) in women MPs but displays a relatively high level of women’s
policy success nevertheless. In France the low number of women MPs
(12.2 per cent) and women’s low policy success seem to go hand in hand
(Interparliamentary Union webpages).8
These observations clearly point to some conclusions. First, the relation-
ship between women’s descriptive (understood in its simplest form as the
number of women MPs) and substantive representation (women’s move-
ment policy success) is neither straightforward nor simple. Earlier research
has illustrated that not all women are equally pro-equality or interested in
acting for women; for example, left-wing men often tend to score better on
scales of ‘women-friendliness’ than right-wing women, although the latter
tend to be invariably ‘more women-friendly’ than their male party col-
leagues. Tremblay and Pelletier (2000) note that feminist consciousness is
more significant than gender as such for the support for liberal and gender-
related issues in Canada. They remark pointedly that electing feminists
into office seems to be a much more efficient strategy on ensuring ‘women-
friendly’ policy outputs than paying attention to gender only.
The results of this country comparison indicate that, in addition to
women’s political representation, the mobilisation potential of women’s
constituencies and the responsiveness of the political and institutional
settings in which they function are crucial in explaining national vari-
ations in women’s policy success. However, the combinations of variables
producing this effect may vary vastly between individual countries. For
example, a highly favourable and responsive institutional setting might
combine with a weak women’s movement mobilisation in one country
to produce successful policy outputs, whereas in another country the
success can be a result of high rates of both state responsiveness and
women’s mobilisation. To be able to analyse and understand these pat-
terns better, we will next have a look at a specific combination of vari-
ables in a specific national context, that is, Finland.
When and how do women’s movements succeed in

Finland? Results of a country analysis
Context
We have already seen that in terms of the RNGS model, Finnish
women’s movements appear highly successful in their ability to reach
policy satisfaction across policy sectors. Before going into a detailed

analysis of the Finnish RNGS results, I will render a background descrip-
tion, illustrating that many of the crucial structural features highlighted
both by the RNGS and other studies exist as part of the Finnish political
context.
First, Finland is a prosperous, stable parliamentary democracy and a
Protestant country with evidence of both secularisation and the shift
towards postmaterialist values (Inglehart and Norris, 2003). Since the
early 1980s, Finnish women have in average been better educated than
men. They also continue working full-time even after marriage and hav-
ing small children, which is internationally quite exceptional (see also
Siaroff, 1994). Previous studies have shown that all these features are sig-
nificant either for a high political participation level or a high support for
egalitarian attitudes (Hayes, McAllister and Studlar, 2000; Inglehart and
Norris, 2003). The former is illustrated by the fact that Finnish women
have been more active voters than Finnish men in all the elections held
since 1983. The latter translates into a very high support for normative
gender equality in national and international surveys (Haavio-Mannila,
1986; Melkas, 1999, 2001, 2004; Inglehart and Norris, 2003), with women
consistently more aware of remaining inequalities.
Second, in a framework of an open-list proportional electoral system with
multi-member constituencies, mandatory preferential voting and quite
strong voter preferences for own gender, Finnish women’s representation
in the legislature has traditionally been among the highest in the world.
It was already 21.5 per cent (and consequently much higher than in most
countries even today) 34 years ago, in 1971, the time when the first of the
parliamentary debates analysed in this study took place. Women’s political
representation increased slowly and steadily at both the national and
local level since the Second World War, with no sudden electoral victories
or major downfalls. The gradual development makes it difficult for the
researcher to discern relations between the proportion of women and
their policy impact. However, with a longer timespan to study, as is the
case here, the more implicit patterns also become clearer.
Third, Finland is a very legalistic society and the nature of political
processes tends to be quite open and to facilitate policy deliberation and
access. Policy proposals are typically prepared in political or administra-
tive committees that often include representatives of political parties,
governmental bodies and interest groups. The committees also obtain
expert statements from various institutions and interest groups. Finished
proposals are sent to a remittal process to different state authorities and
interest organisations. The government, responsible for the final bill, is a
coalition of several political parties, which makes it necessary to negoti-

ate between different interests. When a bill is sent to Parliament, it is sub-
mitted to a parliamentary standing committee, which checks the bill
once more, and takes into consideration expert witnesses. Finally, Parlia-
ment makes any last-minute adjustments and the final decision on the
bill at its sittings. In all of these policy stages, a public debate about the
bill may affect the viewpoints of the participants on necessary amend-
ments and lead to the inclusion of new interests. In principle, although
not always in practice (see Holli, 2003: 162), these deliberative structures
also offer many openings for Finnish women’s constituencies to obtain a
descriptive or substantive representation of their interests.
Fourth, both the RNGS study and other previous research suggested
that left-wing parties tend to be more ‘women-friendly’ than right-wing
parties. They tend to have more women as candidates and elected repre-
sentatives than the right-wing ones and they have also been more willing
to include gender-related rules, such as internal or electoral quotas, in
their structures (Caul, 1999). In her comparative study of Western indus-
trialised democracies, Norris (1987) found that left-wing power had con-
tributed to the decrease of the horizontal and vertical segregation of the
labour market, whereas right-wing power tended to increase it. Hence,
Norris’s conclusion was that politics – and party power – do matter to
women. With regard to Finland, the relatively strong position of the Left,
especially the Social Democratic Party (which has been in government
with few interruptions since 1966), is an important favourable factor.
Fifth, we have to consider the country-specific characteristics of Finnish
women’s movements. From a comparative perspective, international
second wave feminism emerged late (1973–7) and then in a weak form
in Finland (Bergman, 1999, 2002). Finnish women’s movements have
also been considered to display clear integrationist tendencies in a field
strongly divided by the traditional Left/Right division. Working through
established political channels and structures has been seen as character-
istic to Finnish (and other Nordic) feminism (Gustafsson et al., 1997;
Bergman, 1999).
In Finland, women’s party sections (party feminism) have played a
central role in public policy-making, with a parallel moderate feminist
grass-roots movement which has seldom resorted to radical strategies
or mobilised politically to a significant degree. Women’s party sections
have been considered to be relatively independent organisationally and
financially (Haavio-Mannila et al., 1985; see also Christensen, 1999).
Over the years all of them more or less integrated into their agendas the
feminist ideas advocated, first, by the home-grown sex role movement
Association 9 (1966–70) and later by radical feminist groups and aca-

demic feminism (Nupponen, 1969; Alanen, 1981; Jallinoja, 1983; Holli,
1988; Katainen, 1994; Lähteenmäki, 2000). Feminist influence has never-
theless been most prominent in the ideology and demands expressed by
the left-wing women’s party sections (see also Westman, 2000: 288–96;
Carbin and Holli, 2002; cf. Siukola, 2004).
From the late 1980s onwards, there has been visible a new trend to
establish and institutionalise women’s co-operative activities across party
and organisational lines in Finland (Bergman, 1999). This can be regarded
internationally as extremely rare. The new trend was first apparent in the
establishment of NYTKIS, the Coalition of Finnish Women’s Associations
for Joint Action in 1988. It consists of all the women’s party sections, the
Central League of Finnish Women’s Organisations, the League of Finnish
Feminists and the academic Society for Women’s Studies. Their joint
membership is more than 600,000 persons, i.e. over 20 per cent of
the female population of Finland. Initially, NYTKIS acted as an informal
co-operative network, but decided however to organise formally in the
early 2000s. From the very beginning, NYTKIS adopted some radical
feminist organisational principles, such as the rotation of leadership and
consensus-oriented decision-making procedures, as its organisation model.
Its aim is to promote women’s political participation and gender equality
in Finland, lobbying political parties, the government and the parliament
in specific issues for this goal.
In 1991 NYTKIS was followed by another women’s cross-party alliance
when women MPs decided to establish a network of their own within the
parliament in the aftermath of the world-record high in women MPs and
a simultaneous shift in governmental power to a centre-right coalition.
Acting as an unofficial parliamentary standing committee, the Network
investigates and lobbies for issues considered as important to all women
regardless of party affiliation within the parliament (Ramstedt-Silén,
1999). The women MPs’ Network has also been regarded as relatively suc-
cessful in inserting women’s joint concerns in public policies (Ramstedt-
Silén, 1999; Aalto, 2003; Holli, 2004; Lejonqvist-Jurvanen, 2004; Aalto
and Holli, 2005; Holli and Kantola, 2005), however, the party political
division between women MPs poses the major problem for the cohesion
and effectiveness of women’s joint endeavours (Lejonqvist-Jurvanen,
2004).
In conclusion, in Finland many of the features (democracy, prosperity,
a high level of egalitarianism, women’s high socio-economic status, high
level of women’s representation) regarded as beneficial for women’s
political participation are in place. In particular, two of the structural
factors (left-wing power and moderately closed/open policy sub-systems)

evaluated by the RNGS as crucial to women’s policy success tend to be
available per se as part of the Finnish contextual framework. On the other
hand, the integrationist character of Finnish women’s movements and
the prominence of party feminism can be regarded – depending on one’s
viewpoint – either as a strength or as a weakness (cf. also Gelb, 1989). The
model provides easier policy access, but it also entails the real danger of
deradicalisation of women’s movement demands. As I have noted else-
where (Holli, 2001; Holli, 2003: 164–5), this model also seems to make
the articulation of gendered interests by women’s party sections very
much dependent on the larger political situation. This is important also
for understanding the patterns of women’s impact on Finnish policy-
making, as the next section will show in more detail.
Patterns of women’s policy impact in Finland

The Finnish RNGS data include twelve policy debates from four policy
areas: job training, prostitution, political representation and childcare
policies (Holli, 2001, 2004; Aalto, 2003; Aalto and Holli, 2005; Holli and
Kantola, 2005). The sectors include both those considered to have a high
feminist success rate (political representation) to those with a medium
and low feminist success rate (job training policy) (Mazur, 2002). Notably,
the Finnish data do not include any debates on abortion policy, which
proved to be the most accessible policy sector from the women’s move-
ment point of view in the RNGS comparison (Stetson, 2001b; cf. Mazur,
2002, 184–5). Instead, the Finnish data include two debates on childcare
policy, which, according to Mazur (2002: 184–5), cross-culturally has
appeared as the policy sector with the lowest feminist policy success rate.
Consequently, the data on Finland are more slanted to low success policy
sectors than the RNGS average.
The Finnish data were gathered by following the RNGS criteria strictly
in order to include representative debates and with an explicit aim to
avoid the temptation to include at the outset ‘feminist successes’. In the
early stages of the project, the Finnish data were gathered and analysed
by one researcher only, that is, myself. In the later stages of the project,
a team of researchers (Johanna Kantola and Terhi Aalto) co-operated in
the data collection and analysis. At both stages, extreme care was placed,
on the one hand, to guarantee that the same criteria of debate selection
and analysis were applied to all the policy debates, and, on the other, to
retain a detailed knowledge of the qualitative richness of the data. The
homogeneity of the Finnish data in this respect can be regarded as
enhancing the validity and reliability of the results.
Table 7.4 Summary of the results for Finland by date of end of decision
Policy outcome Women’s movement

impact/state response
1970s
Employment Act 1971 Dual response
Adult Further Training Act 1975 No response
Change in Electoral Law 1975 No response
1980s
The repeal of the Vagrant Act 1986 Dual response
Gender Quotas in SKDL 1987* Dual response
Employment Act 1987 Dual response
1990s
Labour Market Subsidy Act 1993 No response
Day Care Act 1994 Dual response
Gender Quotas in the Equality Act 1995 Dual response
Subsidies for Home Care of Children 1995 Co-optation
The Sex Crime Act 1998 Dual response
The Helsinki Municipal Ordinance 1999** Co-optation
* Debate took place inside a political party and thus deviates from the majority of
debates which took place at the national level.
** Debate took place at the local level and thus deviates from the majority of debates
which took place at the national level.
In the following presentation, I will focus on two aspects: temporal

change and the variables explaining patterns of women’s policy success.
In order to be able to analyse the emerging patterns in more detail, I will
draw on both context and qualitative data.
The debates investigated a thirty-year period, that is, 1969–99 (see
Table 7.4). It is also the period since the rise of second-wave feminism
and the establishment of a governmental women’s policy machinery in
the country. It covered the various stages in the development of women’s
movements and feminism, from a growth period during the 1970s and
1980s to a consolidation in the 1990s. It was also during this period that
the Social Democratic, ‘women-friendly’ Finnish welfare state was estab-
lished in the 1970s, expanded in the 1980s and gradually streamlined
during its reconfiguration phase in the aftermath of the 1990s economic
recession.
A longitudinal comparison of the Finnish debates suggests that
women’s movements seldom succeeded in placing their concerns into
public policies in the 1970s, consistently did so in the 1980s, and con-
tinued to be quite successful in their policy aims during the 1990s,
although with more variation as to policy outcome (Table 7.4). This
interpretation corresponds to the stage of overall feminist activism and

the phase of welfare state evolvement, which both were at a peak during
the 1980s in Finland. It also corresponds to the existence of a ‘critical
mass’ of women MPs (over 30 per cent) since 1983 in the parliamentary
arena (cf. Holli, 2003: 162–3).
Table 7.5 presents the Finnish results on the crucial RNGS variables:
policy environment characteristics, women’s movement characteristics
and women’s policy agency activities. Three different patterns emerge in
the analysis, each explaining a specific policy outcome.
First, in Finland, women seemed to be successful in their policy demands
(dual response) when they just managed to mobilise in a sufficient degree in a
moderately closed policy sub-system framework.9 The prerequisites to suffi-
cient mobilisation included the active participation of left-wing women’s
political organisations, cohesiveness of movements (different strands of
women’s movements were not openly in dissension about the proposal
or issue) and a high priority issue. Left-wing power in government con-
tributed to favourable outcome, but from the 1990s onwards, did not
seem necessary for it. The same applies to the role of women’s policy
agencies, which appear extremely effective, but since the 1990s no
longer necessary for successful policy outcome. Before, Finnish women’s
policy successes were invariably accompanied by state equality agencies
playing an insider role in the policy processes (Table 7.5). The important
exception of the 1990s was the debate about the Day Care Act 1994,
where the women’s policy offices remained totally symbolic. Instead,
the watchdog’s role was now taken up by the Women MPs’ Network in
Parliament, illustrating the new significance of the latter. The activity of
women’s new institutionalised cross-party co-operation structures was
prominent in most of the 1990s debates (see Aalto, 2003; Holli, 2001,
2003, 2004; Aalto and Holli, 2005; Holli and Kantola, 2005).
The significance of left-wing power and support for women’s substan-
tive representation went further than the clear-cut division of govern-
mental and parliamentary power which was the variable systematically
targeted by the RNGS model. Notably, some degree of left-wing support
for women’s demands was distinctive to all of the Finnish women’s pol-
icy successes investigated by this study, regardless of whether the Left
was in power or not. However, the latter condition was only realised
between 1991 and 1995 when there was a right-wing government in the
country. During this period, many important policy debates took place
that mobilised women’s movements against the governmental line.
For example, the subjective right to municipal day care for pre-school
children (Day Care Act 1994) and a new gender quota paragraph in
Table 7.5 Variables explaining the impact of the women’s movement in Finland
Policy outcome Policy Policy Women’s Women’s Women’s Women’s Women’s

environment: environment: movement movement movement policy movement
policy Left in power closeness issue cohesiveness agency impact/state
sub-system to Left priority activities response
characteristics
Policy success
(dual response)
Employment Act 1971 Moderately closed Yes Close High Cohesive Insider Dual response
The repeal of the Moderately closed Yes Close Low Cohesive Insider Dual response
Vagrant Act 1986
Gender Quotas in Closed Yes Close High Cohesive Symbolic Dual response
SKDL 1987*
Employment Act 1987 Moderately closed Yes Close High Cohesive Insider Dual response
Day Care Act 1994 Moderately closed No Close High Cohesive Symbolic Dual response
(dividing)
Gender Quotas in the Moderately closed No Close High Cohesive Insider Dual response
Equality Act 1995 Non-
feminist
The Sex Crime Moderately closed Yes Close High Cohesive Insider Dual response
Act 1998
Partial outcome
(co-optation)
Subsidies for Home Moderately closed Yes Not Close High Divided Symbolic Co-optation
Care of Children 1995
The Helsinki Municipal Moderately closed No Not Close High Cohesive Symbolic Co-optation
Ordinance 1999**
Policy failure
(no response)
Change in Electoral Moderately closed Yes Close Low Cohesive Symbolic No response
Law 1975
Adult Further Closed Yes Close Low Divided Symbolic No response
Training Act 1975
Labour Market Closed No Close Low Divided Symbolic No response
Subsidy Act 1993
* Debate took place within a political party and thus deviates from the majority of debates which took place at the national level.
** Debate took place at the municipal level and thus deviates from the majority of debates which took place at the national level.
the Equality Act 1995 were achieved by women’s active pressure politics
in spite of the right-wing government’s resistance. The mechanisms for
women’s policy success in these debates included women MPs allying
across the right-left division, and forming a winning coalition in Parliament
with the opposition left-wing male MPs.
This factor also makes clear why it was important to include the left-
wing women’s organisations in Finnish women’s mobilising efforts in
order to gain results. First, since they have been more influenced by femi-
nist thought than the right-wing ones, they were more prone to act as
starting motors in furthering women’s interests in public policy-making.
Second, they almost invariably succeeded in securing both considerable
party support and male votes (often in toto) from their own ranks for
their demands in the parliament. The analysis of the Finnish overall
data also showed that right-wing women’s party organisations did not
obtain similar support from their own party groups and male colleagues
when they did mobilise on an issue.
This also provides the key for the second set of policy outcomes,
namely those of co-optation. When right-wing women mobilised on an issue
by themselves, without managing to recruit the left-wing women actively
(because of, for example, different or conflicting priorities or left-wing
disinterest) they were bound to be disappointed at the outcome. This seemed
to occur despite otherwise favourable policy environment characteris-
tics.10 Nor were there insider women’s policy agencies lending their sup-
port to right-wing women’s demands. From a more comprehensive
perspective, almost all of the Finnish policy debates investigated over
time witnessed right-wing resistance (especially men’s) towards the
women’s movement demands, regardless of topic or policy sector. From
this perspective, it is extremely interesting to observe the emerging gap
between right-wing women and men during the 1990s as right-wing
women started to mobilise on gender grounds and even to shift their alle-
giance from party to gender on several crucial occasions (see above;
cf. also Siukola, 2004).
The third set of policy outcomes were the total failures (no response) in
terms of the RNGS model. By contrast to the successes, then, the policy sub-
system was more often closed, and there were definite problems in women’s move-
ment mobilisation (low priority of issue and the divided character of the
movement). Nor was there any insider support by women’s policy agen-
cies. What is most significant, though, is that Finnish women’s movements
did not offer gendered opinions on the issues or attempt to gender policy-
making. Consequently, women’s policy failure in the Finnish context
mainly seems to correspond to the failing ability or willingness of women’s
movements to analyse the issue from a gender perspective or to articulate gendered

concerns in a specific policy debate.
Why and when did women’s constituencies not offer gendered analy-
ses of the issue – or if they did, why did they keep silent in public? The
failures took place either in the policy sectors concerning economics (job
training) or political representation (electoral law), and thus core issues
from the point of view of the conventional left/right party division and
interests. All three policy failures also occurred in political or economic
national crisis situations (Holli, 2001, 2003; cf. Räsänen, 1984), and in
periods or specific debates displaying quite exacerbated left/right con-
flicts. It is also there that we find the explanation for the passivity of
women’s movements, i.e. its predominant form as party feminism. The
party women’s opportunities for standing as women and acting for them
were then very much restricted by their role as party representatives, too
(see also Childs, 2004).
The Labour Market Subsidy Act 1993 illustrates well the mechanism of
silence produced by party political imperatives. The right-wing govern-
ment proposed a bill, which quite incidentally included remedies to some
major problems in married women’s unemployment benefits – a fact that
the government did not even notice. In that process, there were indica-
tions that the whole of the left-wing – women included – were aware of
the gendered implications of the proposed reform all along, but refrained
from bringing them up. As the left-wing parties objected to the right-wing
government’s ‘incorrect formulation’ of the Labour Market Subsidy Bill in
its totality, they did not want to give it any ammunition by pointing out
the positive consequences of the reform for women. This was brought up
only after the left-wing had finally lost the battle against the reform. This
example shows clearly how party political concerns may prevent women
from gendering policy debates in Finland.
Thus, my analysis suggests women’s movement characteristics being the
crucial explanatory set of variables for Finnish women’s policy success or
failure. Policy environment characteristics (open/closed character of the
sub-system, left in power) play an important role for policy outcome, but
also, in the final analysis, some other characteristics of the specific policy
debates (notably, political/economic crisis situation, degree of party con-
flict) might be equally significant, as they seem to shape the opportunities
and barriers for Finnish-type integrationist feminism to be able to
mobilise on gender grounds.
As already mentioned, before the 1990s successful women’s movement
mobilisation invariably coincided with the insider activity of a women’s
policy agency. Elsewhere (Holli, 2002; 2003: 165) I have suggested that
this can be understood via the idea of ‘strategic partnerships’ (Halsaa,

1991; see also Mazur, 2002: 190–1), referring to the way in which various
elements of women’s movements mobilise and co-operate on specific
issues and pragmatic problems. Finnish state equality agencies have been
integral partners in such alliances, which have also always included
women MPs and often women working in the state bureaucracy.
Sometimes the women’s policy agencies initiated the formation of such
partnerships by offering a gendered analysis of a specific social problem;
sometimes they were mobilised along as an issue was brought up by
others. Last but not least, between 1972 and 1986, then the sole women’s
policy agency, the Council for Equality between Women and Men, was
organised as a composite of all political parties, that is, it was made up
mainly by party women. The Council provided a forum for seeking out
common interests. Notably, the empirical data indicate strongly that if
the women’s party sections were divided on an issue, so was the Council,
with no policy line for it to pursue in the debate.
From the second half of the 1980s onwards, there was a series of signifi-
cant changes affecting the status of women’s policy offices and especially
their position in women’s strategic partnerships. First, their number pro-
liferated from one to three, as the Equality Ombudsman’s Office was
established in 1987 and a Ministerial Gender Equality Unit (for the prep-
aration of governmental gender equality policy) in 2001. Their mandate
and contacts with women’s organisations were by the nature of their
activities more limited. Simultaneously, there were constant administra-
tive re-organisation efforts and diminishing resources, which affected
especially the status of the previously influential Council for Equality. Its
possibilities of investigating gender equality problems and proposing
reforms are in practice barred by the fact that its personnel today consists
of a General Secretary, and some part-time or hourly-paid secretaries for
topical working groups. Also the politically nominated council shifted
character in the mid-1990s, as it became a gender balanced (40–60 per cent)
body of women and men as decreed by the Quota Law of 1995, and no
longer a party women’s meeting ground.
Finnish EU membership from 1995 affected the activity of all the
Finnish women’s policy agencies as their work turned towards imple-
menting EU directives and guidelines in the national framework and par-
ticipating in the technical preparation of EU gender equality reforms both
in national and EU arenas. In a context of scarce personnel resources, this
considerably shifted the focus of gender equality policies. Zwingel (2005)
has shown how the 1979 United Nations CEDAW convention was
deployed maximally by Finnish women’s movements and the Council for
Equality in the 1980s and 1990s to initiate domestic gender equality

reforms. She surmises that EU policies may have assumed a similar trans-
formative significance for Finnish national policies. Kantola’s (2004)
study of the impact of EU discourses on violence against women for
Finland points towards a similar conclusion. However, the multiple and
possibly contradictory gendered impacts of Europeanisation on Finnish
policy-making, women’s movements and state feminism remain still very
much uninvestigated.
This analysis of Finland points to the conclusion that the new women’s
institutionalised cross-party co-operative structures (NYTKIS, Women
MPs’ Network in Parliament) have partly come to replace the formerly
indispensable – but now diminished – role played by women’s policy
offices in women’s strategic partnerships. They provide the new platforms
for seeking out common interests and building coalitions for women’s
joint action in a context of politically divided feminism. Such alternative
coalition-building by women is made possible because there are structural
openings for it in the Finnish political system. For example, individual
MPs are less dependent on their party (for re-election, for instance,
because of the open list PR system) and parliamentary party discipline
tends to be less restraining than in some other countries. The strengthen-
ing of women’s cross-party co-operation can be regarded as the answer
offered by women’s organisations to the structural changes (shift of power
to the right-wing, a deep economic recession and welfare state retrench-
ment, partly closing opportunity structures and the diminishing role of
women’s policy agencies) that posed new threats both to women’s status
and their possibilities to influence policy-making in Finland in the 1990s.
Conclusion
In this chapter, I have presented the results of a RNGS analysis of twelve

Finnish policy debates from 1969 to 1999. The analysis illustrated that in
Finland women’s movements have been quite successful in achieving
policy satisfaction. A comparison of the cross-cultural RNGS results and
Finnish results both point to similar conclusions, namely the significance
of policy environment characteristics, women’s movement characteristics
and the existence of an insider women’s policy agency. However, the
country-specific analysis of the Finnish debates over time makes this
interpretation more nuanced and partly modifies it for Finland.
Some policy environment characteristics (relative openness of policy
sub-systems and left-wing power) regarded by the RNGS to contribute to
women’s movement impact tend to exist as structural features of the
Finnish political context. Women’s policy impact followed three different

patterns there, my analysis highlighting the pertinence of women’s move-
ment characteristics for policy outcome. Over time, there occurred def-
inite changes in both movement strategies and the patterns of women’s
policy influence. For example, during the 1990s a split between right-wing
women and men in their concern for gender became visible. Women’s
joint action over party lines increased in parliament and the co-operation
acquired institutionalised forms which served partly similar functions in
women’s strategic partnerships than women’s policy offices did earlier on.
This observation gives a new slant to some of the insights offered by the
RNGS project: certainly, specialised women’s policy agencies are very
effective in aiding women’s movements achieve policy satisfaction, but
there also exist alternative roads towards that objective.
This chapter also pinpoints many of the difficulties and barriers that
Finnish-type integrationist, politically divided women’s movements face
in their struggle between gender and party concerns. It shows how they
have nevertheless managed strategically to deploy the openings of the
political system to make workable strategies and initiate reforms. Despite
new problems, the abilities of Finnish women’s movements to gender
policy debates seem actually to have increased over time and especially
during the 1990s, which, as the logic of my analysis suggests, gives good
prospects for their continued success in public policy-making.
Notes
1. The project consists of over 40 country specialists studying 15 countries in

Europe and North America as well as the supra-national decision-making of
the European Union.
2. For more information about the methodological choices, see RNGS (2004);
Mazur (2001a); Stetson (2001a); Outshoorn (2004a); Lovenduski (2005);
Mazur and Parry (1998).
3. Building from the concept of iron triangles and taking Heclo’s (1978) notion
of issue networks into consideration, the RNGS model conceptualises differ-
ent types of policy sub-systems along a continuum, with ‘open sub-systems’
(amorphous networks, wide participation of actors, no clear chain of com-
mand), ‘moderately closed sub-systems’ (organisation more clearly defined,
several actors trying to dominate), and ‘closed sub-systems’ (participation
limited, one major set of actors controls policy space and the parameters of
the arena).
4. Moreover, the RNGS study also points out that policy success is more likely
when the movement frames the issue in matching or compatible terms with
those utilised in the dominant discourse of the policy sub-system. However,
this factor will be excluded from my analysis in this article.
5. The Finnish data include the published case studies on policy debates (see
Holli, 2001, 2004; Holli and Kantola, 2005) as well as the data gathered by
Aalto (2003) for her thesis on child care policies.
6. However, the methodological problems inherent in doing joint comparative
analysis across cultures must be taken into account when considering the
reliability of these results. The relatively small number of individual country
cases, possible bias (for example, towards ‘women’s successes’ in the selec-
tion process or selecting debates that were at the outset gendered) in debate
selection, the different number of debates selected from different policy sec-
tors and the overall composition of policy sectors studied, or individual
different ways of interpreting the common research criteria in spite of efforts
to avoid exactly that, all affect the reliability of results especially at country
comparison level.
7. The high women’s policy impact by Italy in this classification is somewhat
surprising and needs closer investigation, as it deviates from the results of
related studies (e.g. Stetson and Mazur, 1995; Hayes, McAllister and Studlar,
2000; Mazur, 2002).
8. If we were to take into account the other countries where fewer policy
debates on fewer sectors have been studied, especially Sweden and the
Netherlands emerge as particularly responsive to women’s demands (with
their dual response rate 83 per cent and 78 per cent respectively), followed
by Austria (67 per cent) and Great Britain (56 per cent). The same discrep-
ancy between women’s political representation and policy success comes
again forth: whereas Sweden (45.3 per cent) and the Netherlands (36.7
per cent) appear successful on both accounts, for example the United
Kingdom combines a relative high policy success by women with a low num-
ber, only 17.8 per cent, of women MPs (2005) (Interparliamentary Union
webpages).
9. I exclude the debate concerning Gender Quotas in SKDL 1987 from this
explanation since it took place within the extreme left-wing party (closed
policy sub-system) which also made the debate remain outside the mandate
of the women’s policy agencies by prevalent definitions of possibility of state
intervention and internal party democracy.
10. However, there was only one debate in the data combining right-wing power
with right-wing women’s mobilisation (Helsinki Municipal Ordinance,
1999) in a moderately closed policy sub-system, which can be regarded as
the most accessible policy environment for right-wing women.
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8
Transnational and National Gender
Equality Politics: The European
Union’s Impact on Domestic
Violence Debates in Britain and
Finland
Johanna Kantola
Introduction
The aim of this chapter is to investigate transnational gender equality

politics and its meaning to national politics. In order to do this, the
chapter will explore the relationship between violence against women and
gender equality in two European Union (EU) member states, Finland
and England, and in the EU itself. The link between domestic violence
and gender equality has been strong in Britain and weak in Finland, and
is emerging at the EU level.
The EU’s gender equality policies develop within a framework of dif-
fering national understandings of what gender equality consists of, what
is crucial for gender equality and how to achieve it. These differing con-
ceptualisations have, in turn, taken very different institutional forms in
the member states. As there is no universal understanding of the con-
ception of gender equality, even amongst feminists within Europe, the
EU plays an important role in negotiating new conceptions of gender
equality. In this process, the EU member states learn from one another
and new EU level conceptions of gender equality emerge.
The entry of the two Nordic countries, Finland and Sweden, into the
EU in 1995 was generally perceived as enhancing the status of gender
equality in the Union.1 It has also been noted that the Nordic countries,
especially Sweden, were worried that entry to the EU would bring down
their high national standards on gender equality (Bergqvist and Jungar,
2000). For example, in Finland the gender equality model relies on some
154
The EU Impact on Domestic Violence Debates in Britain and Finland 155
key characteristics of the women-friendly welfare state, namely women’s

full-time participation in the labour market, extensive public sector child
care arrangements, individual taxation, and universal welfare benefits
(Anttonen, 1997).2 Whilst Finland has appeared as a pioneer in gender
equality in relation to these fields, Britain has lagged behind. It has been
EU legislation that has shaped British policies on retirement, pay and
pensions, maternity and parental rights, sexual harassment in the work
place and protective legislation (Meehan and Collins, 1996: 226–9).
Some commentators, such as Gösta Esping-Andersen, suggest that the
Nordic welfare state model and its gender contract could be a model for
all Europe (quoted in Borchorst and Siim, 2002a: 69). In the face of such
prescriptive tendencies, it is important to explore the limits and restric-
tions of the model and its gender equality discourse.3 One way to do this
is to focus on violence against women, which has not been an integral
part of the gender equality policies in the Nordic countries (Ronkainen,
1998; Lindvert, 2002).
Domestic violence is not a typical area of study for scholars interested
in EU gender equality policies either. The EU competence in the field is
low and can use only so-called soft policy instruments, such as recom-
mendations and action plans, to tackle the problem. However, some
important insights are to be gained by focusing upon domestic violence
debates. First, recognising the importance of violence against women for
gender equality exposes some of the limits of the Finnish gender equal-
ity discourse and institutions and challenges the pioneer status of
Finland in achieving gender equality. This, in turn, raises interesting
questions about which and whose models we should follow when aspir-
ing for gender equality in the EU. Second, the recent EU attempts to
tackle violence against women point to the ways in which EU equality
policy is widening from the original narrow concerns with economic
equality to new areas. Feminist scholars have directed their energies to
studying the EU’s role in shaping women’s social and economic rights
(see, however, Elman, 1996). It could be argued that this buys into pre-
vailing assumptions about gender equality and results in an emphasis
on liberal and economic, legal and political categories, and, therefore, a
narrow understanding of gender equality. A focus on violence against
women has the potential to broaden the debates on gender equality and
on the role of the EU in achieving gender equality.
A number of scholars use the concept of Europeanisation to study the
impact of the EU on member states’ politics. The term captures the way
in which a European dimension becomes an embedded feature framing
politics within European states (Featherstone, 2003: 3). Europeanisation
156 Johanna Kantola
is a process of convergence towards shared policy frameworks which

does not, however, require uniformity or imply an erosion of the domes-
tic or an overriding of member state’s internal processes (Liebert, 2003:
15, 16; see also Caporaso and Jupille, 2001). Study of Europeanisation
has often been located within a broadly institutionalist discourse and
domestic institutions are viewed as filtering the impact of EU-level innov-
ations (Cram, 2001: 606). Whilst recognising the importance and con-
tributions of institutionalist analysis, this chapter wishes to combine
institutional analysis with discourse analysis. British, Finnish and EU
debates on domestic violence are compared and contrasted on the level
of discourses, institutions and actors. The aim is to capture the interplay
of diverse discourses and processes of institutionalisation in the two
countries and the EU.
The chapter will proceed as follows. In the first section, I will analyse
the domestic violence debates in Britain and Finland respectively and
focus on the discourses, institutions and actors that have shaped domes-
tic violence policy in these countries. The section will show the differ-
ences between national gender equality discourses in the two member
states. In the second section, I will concentrate on the EU policies on
violence against women. This will illustrate the ways in which the EU is
emerging as a transnational actor in the field. In the third section, I will
consider the meaning and the impact of the EU policies on Finland and
Britain. Finally, I will draw some conclusions about the relationship
between the national and transnational gender equality policies.
Gender equality and domestic violence in

Finland and Britain
The aim of this section is to show the strong national discourses about
domestic violence that exist in member states. The British refuge move-
ment, Women’s Aid, grew out of and drew on radical feminist ideas.4 It
became the most prominent actor of the women’s movement on the
issue of domestic violence and started setting up a network of refuges for
battered women in the 1970s. By 1977, there were nearly 200 refuges in
the UK for women escaping domestic violence. Women’s Aid articulated
a universal domestic violence discourse. In this discourse, any woman
could experience domestic violence – it was not a problem of working-
class families or alcoholic men only:
Until men no longer see women as their possessions, but as people

with equal status and rights, women will always be beaten. We are
fighting not only to stop battering, but also to change the position of
women in our violent society.
(National Women’s Aid Federation, 1978: 2)
Women’s Aid’s feminist explanation saw domestic violence as a reflection

of unequal power relations both in society and in personal relationships
and domestic violence as a symptom of the more general male violence
and domination over women (Hague and Malos, 1993). In other words,
for Women’s Aid, domestic violence was a serious societal problem and
its root causes could be tackled only by making the general position of
women in society better (Coote and Gill, 1977; Weir, 1977).
In relation to the state, these feminists drew on an autonomy discourse
that was underpinned by distrust of the state as an institution and a belief
in the autonomy of the women’s movement. Autonomy from the state
was important in order to maintain and discover feminist ways of work-
ing (National Women’s Aid Federation, 1978). Women were made strong
through self-help and through sharing experiences with other women in
similar life situations. Women’s Aid was for women and by women, and its
feminism was inspired by a ‘women-only’ strategy. Women were treated
not as victims but as survivors in order both to challenge victim-blame and
to make visible women’s resistance strategies (Kelly and Radford, 1996: 20).
The Women’s Aid organisation was non-hierarchical and was based on
democratic functioning. In the autonomy discourse, every engagement
with the state was regarded as having its price. For example, a turn to the
state might result in compromising on societal critique and feminist prac-
tice (Rose, 1985).
Feminists in academia not only endorsed Women’s Aid’s discourses on
domestic violence and the state but also radicalised them and provided
academic research and theories to back up the arguments. Liz Kelly
(1987) employed the concept of the continuum of sexual violence which
emphasised that sexual violence exists in most women’s lives and only
the form sexual violence takes, how women define events and the impact
of the events on them at the time and over time, vary (Kelly, 1987: 48).
Feminist academics confirmed the importance of autonomy and empower-
ment as strategies to deal with domestic violence and warned against
tokenistic and divisive reforms executed by the state (Hanmer, Radford
and Stanko, 1989: 11).
In Britain, however, the discourses on domestic violence were diverse.
Competing discourses explained domestic violence in terms of individ-
ual pathology and emphasised that women were also violent (Pizzey,
1982).5 The parliamentary debates in the 1970s demonstrate that there
158 Johanna Kantola
was deep unease among Conservative male members of parliament

(MPs) about the appropriate means to deal with domestic violence.6
They were particularly worried about the role of the police in transgress-
ing the public/private distinction and intervening in ‘domestic disputes’.
Their arguments drew on a nuclear family discourse, where the unity of
the family should be respected by the police, and on a scarce resources
discourse, which questioned whether it was justified to increase the
burden on the police. Courts, in turn, stressed men’s property rights.
These ideas were extremely important in explaining resistance to feminist
discourses.
Diversity also existed within feminism. Black feminist theorising high-
lighted black women’s different experience of ‘universal’ domestic vio-
lence (Southall Black Sisters, 1989). Also non-feminist actors, such as the
Women’s National Commission, Victim Support, the Home Office and the
Law Commission, started to contribute to the debates. Their discourses in
turn impacted on and shaped Women’s Aid’s feminist discourses, but also
showed the impact that the feminist discourses had had on the public
debates (see, for example, Home Affairs Committee, 1993).
In comparison to Britain, the lack of feminist discourses on domestic
violence in the 1970s and 1980s in Finland was striking. Domestic vio-
lence was a silenced problem (Ronkainen, 1998) and there were very few
feminists in Finland who would have considered violence against women
as pivotal for gender equality. Feminist activists or theorists did not set the
domestic violence agenda; it was set by non-feminist actors, who argued
that domestic violence was caused by dynamics in the family.
In direct contrast to British feminist discourses, in the family violence
discourse, the relationship between the perpetrator and the victim was
the most important factor causing domestic violence (Peltoniemi, 1984:
159). Whilst feminists in Britain succeeded in establishing that domestic
violence occurred regardless of differences in class, race, ethnicity or sexu-
ality (see Home Affairs Committee, 1993), in Finland it was argued:
Almost all research shows that family violence accumulates more to

the lower social groups than might be expected statistically. This is
not surprising because all criminal violence is more common in lower
than higher social groups.
(Peltoniemi, 1984: 46)
According to Peltoniemi, domestic violence was not caused by the struc-

ture of the patriarchal society, as emphasised by the British feminist
discourses, and, therefore, the solution to the problem of ‘family violence’
was also to be found on the individual level (Peltoniemi, 1982, 1984:

230). At best, domestic violence was seen as a social problem which
required practical social policy solutions. As a social policy problem,
‘family violence’ became just a small part of bigger social problems such
as alcoholism or mental problems.7
The discourse constructed a strong dichotomy between the family
dynamics model and the feminist model (see Table 8.1). The family
dynamics approach became the superior norm in Finland. In this dichot-
omous way of thinking, the family dynamics model was moderate, sensi-
ble, reasonable and prudent, in contrast to the irrational, extreme, feminist
men haters outside society. The dichotomy was persuasively established
and it effectively silenced feminist voices on domestic violence in Finland.
There was hardly any space for positive understandings of the meaning
of feminist ideas about autonomy and empowerment as in the British
context. The first feminist discourses on domestic violence in Finland
started to emerge in the beginning of the 1990s, almost twenty years later
than in Britain. In feminist journals of the 1990s it was finally argued
that ‘violence against women is a clear sign of unequal gender relations’
(Uusi Nainen, 1991, 1992).
On the international level domestic violence had been taken increas-
ingly seriously since the mid-1980s and various bodies and organisations
were condemning domestic violence as a serious human rights violation
Table 8.1 Differences in refuge ideologies
Family dynamics Feminist approach

approach
Concept Family violence Battered women

Relationship to feminism Negative Highly positive
Cause of family violence Relationship problems Patriarchal society
Nature of family violence Social sickness Crime
Victim Both woman and man Only woman
Children Very important Less important
Openness of the activities Very open Very closed
Accepting men Accepted as personnel Not accepted at all
and visitors
Form of action Private conversations Groups
Target of action Family Women’s self-confidence
Personnel Professional Non-professional
Relationship to the state Co-operation Independent
Participation in politics Weak Strong
Source: Table in Peltoniemi (1984: 210); translation JK.

160 Johanna Kantola
and demanding national governments to take action (Keck and Sikkink,

1998). It was via the international level influence that the importance of
tackling domestic violence as a gender equality question came to Finland.8
To meet the international pressure the Council for Equality established a
committee to study violence against women in 1990 (the Violence Sub-
committee). The Committee argued that it had been difficult in Finland to
accept the existence of domestic violence because:
it fits so badly to the image we have of the status of the Finnish women.
It is commonly assumed that the status of the Finnish women is the
best in the world and that gender equality has already been achieved in
Finland.
(Naisiin kohdistuva väkivalta, 1992: 1)
The Committee formulated a gendered violence discourse and used the con-
cept of violence against women in contrast to family violence to challenge
the hitherto dominant idea that domestic violence was gender neutral.
However, these feminist discourses on violence against women did not
represent a real alternative to the women-friendly welfare state discourse.
They pointed out that the dominant understanding of Finland as a
women-friendly welfare state had worked against recognising the extent
of violence against women in Finland but at the same time they drew on
the dominant discourse and argued that women-friendliness demanded
that the state had to tackle to problem. The state had to take responsibil-
ity in confronting violence against women. In contrast to Britain, there
was little space to formulate discourses on autonomy or empowerment.
The strong national discourses underpin the institutional frameworks
for tackling domestic violence in these two countries. On the one hand,
in Britain, domestic violence legislation was drafted and implemented
much earlier than in Finland, and it was possible to obtain injunctions
by the end of the 1970s when the Domestic Violence and Matrimonial
Proceedings Act 1976 was passed (see Maidment, 1985: 8; McCann,
1985: 76). On the other hand, the refuge network, established in accord-
ance with the ideas of empowerment and autonomy, received no national
funding and faced severe funding problems. At the same time, police
practice improved slowly and the Home Office issued guidelines for
better practice in the beginning of 1990s (Home Office, 1990).
The situation was quite different in Finland. At the beginning of 1990s,
domestic violence could only be dealt with under the 1889 criminal law.
It was not legally possible to obtain injunctions and the police had no
guidelines on how to deal with domestic violence. The law distinguished
between violence in the public and private spheres and rape in marriage
was not criminalised. Research into domestic violence was mostly non-
academic and no statistics existed to reveal the extent of the problem.
Furthermore, in Finland, refuges did not grow out of the women’s
movement or feminist activism as in Britain, but developed from former
child welfare institutions. The provision for battered women did not
take place outside the public sector but was complicit with its services.
When a family came to a refuge, the partner who stayed at home was
contacted. Refuges organised family discussions which the perpetrator
was invited to participate in (Leskinen, Mäkinen and Peltoniemi, 1982).
Domestic violence only entered Finnish public debates in the 1990s
and the institutions reflected its late arrival. However, when reforms
started to take place, they were often swift, in contrast to the incremen-
tal developments in Britain. Legal developments included criminalising
rape in marriage in 1994. In 1995, prosecution in domestic violence
cases became the responsibility of the general attorney and the Act on
Restraining Order was passed in 1998. The Social Affairs and Health
Ministry took up its role as the leading governmental department on the
issue. New statistics showed that 40 per cent of Finnish women have
experienced physical or sexual violence or the threat of violence by men.
Only a quarter of women who had experienced violence had sought
outside help, mainly from hospitals or the police in cases of severe injury.
Only 2.8 per cent had sought help from refuges (Heiskanen and Piispa,
1998).
In conclusion, the discussion shows that there were strong and varying
national discourses about one aspect of gender equality in the two mem-
ber states, that of violence against women. These discourses defined the
content of gender equality – the link between gender equality and
domestic violence – and the scope of gender equality politics. They also
underpinned the domestic violence institutions of these countries. In
sum, the discussion shows the importance of the national context that
transnational policies and strategies confront.
Gender equality and domestic violence in the EU
In the mid-1990s, some scholars argued that violence against women

was a high priority issue for the UK women’s networks but not for those
of the EU (Sperling and Bretherton, 1996: 309). Since then, however, the
issue of violence against women has gained in prominence in the EU.
In this section, it becomes evident that the EU does not just filter
discourses between the EU member states, but synthesises and brings
162 Johanna Kantola
different discourses together in novel ways. The point relates closely to

the emergence of new actors and institutions, which articulate and
embody the new discourses.
Sonia Mazey suggests that the EU plays an important role in the cre-
ation and legitimation of new policy actors with whom national gov-
ernments have to deal (1998: 132–3). The European Women’s Lobby
(EWL) emerged as a key actor in articulating discourses about violence
against women at the EU level in the 1990s. It was the largest coalition of
women’s non-governmental organisations in the EU representing over
3,000 affiliated organisations from member-states as well as European-
wide women’s organisations. It was established in 1990 to promote equal-
ity between women and men and to ensure that gender equality and
women’s rights were taken into consideration in all EU policies (Hoskyns,
1996: 185–6).
In 1997, the EWL developed within its existing structures a European
Policy Action Centre on Violence against Women. The goal was to provide
a forum for women’s NGOs and to enable them to take a leadership role
in engaging policy and decision-makers to tackle violence against women.
An Observatory on Violence against Women was also formed. It was an
expert group composed of fifteen women, one from each of the member-
states of the time, with extensive expertise in the area of violence against
women. The task of the Observatory was to advise the EWL on strategies
to address violence against women within the EU. The aim was to extend
lobbying beyond national boundaries and to achieve European-wide
responses to address violence against women. The EWL argued that the
work of the Policy Action Centre, with the input of the Observatory, was
instrumental in facilitating and developing a co-ordinated approach to
violence against women within the EU (EWL, 2002).
In her evaluation of the network, Catherine Hoskyns suggested that
the EWL was biased towards educated and professional women (1996:
203). European networking touched only a fraction of women’s activity
throughout the EU, and distances, lack of resources and the abstraction
of EU processes deterred many women from participating. The EU was
seen as having little to offer women concerned with sexual politics and
violence against women (Hoskyns, 1996: 203). The EU’s strong focus on
employment policy had shaped EWL’s priorities. With its new struc-
tures, however, the EWL was able to reach out to new constituencies and
accommodate new concerns in its agendas.
Women Against Violence Europe (WAVE), in turn, formed a bottom-up
forum for women’s organisations. WAVE was a European-wide NGO net-
work against violence against women and children. The establishment of
its organisational structure benefited from the EU Daphne Initiative

in 1997 (discussed below). The network comprised approximately 1,000
women’s organisations combating violence against women and children
in Europe. The aims of the network included taking common action and
promoting feminist analyses of violence against women. The network
was more critical of the EU, its patchy funding and commitment than
the EWL (WAVE, 2000: 9).
Another channel and form of access for women preventing domestic
violence was the European Parliament and the European Commission
(see Footitt, 2002). Since the 1970s, female members of the European
Parliament (MEPs) constituted an important part of the women’s lobby
at the European level, and since 1981 there was a standing committee
for women’s rights within the European Parliament (Mazey, 1998: 142).
Individual female commissioners were important actors in domestic vio-
lence debates. Anita Gradin, Swedish Commissioner between 1995 and
1999, took initiatives on a number of issues, and in September 1999
Anna Diamantopoulou was appointed as a commissioner with specific
responsibility for gender equality (see Hubert, 2001: 159).
These actors articulated feminist discourses about violence against
women and ensured their presence at the EU level. The universal domes-
tic violence discourse, as identified in the discussion on Britain, was also
endorsed at the EU level:
Violence affecting children, young people and women is present in

all societies, regardless of the level of development, the political sys-
tem, culture or religion.
(European Commission, 2001: 3)
A significant element of the universal discourse, which suggested that

domestic violence results from differences in power between men and
women, was emphasised by the female actors in particular (see EWL,
2003). Gradin stated in the European Parliament: ‘Violence against
women is the most extreme expression of the lack of equality which exists
between women and men’ (European Parliament, 1997). This was also
argued by other female MEPs in parliamentary debates.9 Maj-Britt Theorin
(Committee on Women’s Rights and Equal Opportunities of the European
Parliament) argued on another occasion:
Long-term precise studies in all spheres of society will unveil that vio-
lence against women is not random, accidental, or a private matter.
Rather it is structural. It is both a manifestation of the power balance
164 Johanna Kantola
between women and men, and a social mechanism which forces

women into continuing subordination.
(2001: 16)
The universal domestic violence discourse drew on the idea of a con-

tinuum of violence (Kelly, 1987). Violence against women was linked with
other issues, such as prostitution and trafficking in women, and govern-
ments were criticised for not treating all aspects of violence against women
in a coherent way: ‘Prostitution cannot be dissociated from other forms of
male violence perpetrated against women’ (EWL, 2003a).
The feminist discourses found their way to the documents of the
Commission (European Commission, 2001: 3). In parliamentary debates,
however, it was left mainly to the female MEPs to articulate and represent
feminist discourses, and even to debate the topic. In the 1997 debate,
only one of the 14 MEPs who spoke in the debate was a man (European
Parliament, 1997). In 1999, three out of the 17 MEPs who spoke in the
debate were men (European Parliament, 1999). This suggests that vio-
lence against women was seen as a women’s issue, although Gradin
explicitly attempted to reframe violence against women as a man’s prob-
lem (European Parliament, 1999). The EWL was also worried about a new
trend where feminist definitions might be losing ground.
Evidence of the depoliticisation of the public discourse on violence

against women is emerging at both national and European level. This
means that increasingly the feminist analysis of violence against
women as a manifestation of the unequal power relations between
women and men and the institutionalisation of these power rela-
tionships in all areas of public and private life is being eroded.
(EWL, 2003)
Another feminist strategy involved appealing to a human rights discourse

and articulating violence against women as a breach of women’s rights.
The human rights discourse emerged from the debates that had taken
place at the United Nations (UN) level since the early 1990s. For example,
the 1993 Vienna Declaration was pivotal in recognising women’s rights
as human rights (UN, 1993; Pietilä, 2002: 27) and facilitated under-
standing violence against women within this framework. The European
Women’s Lobby argued:
An important part of the EU population is submitted to torture, slavery,

humiliation, violence and degrading treatments precisely because they
are women … The persistence of violence against women, in all its

forms and throughout the whole life cycle of women, is a fundamental
barrier to the enjoyment by women of their fundamental human
rights and freedoms and to the achievement of equality between
women and men.
(EWL, 2003a)
Diamantopoulou stated: ‘Violence against women … has political reper-

cussions since it is a violation of the fundamental human rights’ (in
Lisbon, 4–6 May 2000). In the human rights discourse, domestic vio-
lence was articulated as an international problem, as opposed to a
domestic or national problem, and the discourse gave a role to the inter-
national actors, such as the EU or the UN, in tackling the problem.10
A third discourse, namely a public health discourse, where violence
against women was conceptualised as a public health problem, emerged
at the EU level. At the UN level, it was endorsed by the World Health
Organisation (WHO), which argued:
A growing body of research evidence is showing that sharing her life

with an abusive partner can have a profound impact on a woman’s
health … Although violence can have direct health consequences,
such as injury, being a victim of violence also increases a woman’s
risk of future ill health.
(WHO, 2002: 100)
In this discourse, domestic violence was conceptualised as harmful to

women’s health. The harm done to women’s health was argued to have
public and national level repercussions: it led to an increase in sick
leave, in health care costs and in lost working hours. Institutionally, the
influence of this discourse could be seen especially in the fact that pub-
lic health was made the legal basis of the new EU Daphne Programme
in 1999. As a consequence, tackling violence against women in the
Daphne Programme had to be made to fit the frame of protection of
public health. The public health discourse was criticised by female MEPs
for being narrow and for reducing violence against women to a health
problem (European Parliament, 1999). However, the EWL adopted the
discourse and tried to work within it.
Violence is a leading worldwide public health problem … EU action

is urgently needed to prevent all forms of violence, in particular vio-
lence against women, in order to protect women’s human rights, and
166 Johanna Kantola
to reduce the consequences for the health of women, men and chil-
dren, and for socio-economic development.
(EWL, 2003b)
This quotation is an indication of the prevalence of the public health

discourse at the EU level. It also shows that feminist actors adopted the
discourse and used it when combating violence against women. The
MEPs’ cautious remarks, in turn, suggest that adoption of the discourse
was not without problems; it might narrow violence against women to
questions of public health protection.
The EU’s domestic violence policy and institutions developed within
the boundaries of ‘soft law’ – guidelines, recommendations and action
plans – and not with legally binding directives (‘hard law’) (Elman, 1996: 8;
Shaw, 2000: 423). This led some commentators to conclude that the EU
impact on member states was not significant in the field of domestic
violence (see, for example, Sifft, 2003: 154). The low competence was ini-
tially combined with a lack of interest, and feminists questioned the EU’s
willingness to interfere in the domestic violence policies of member
states. Jalna Hanmer (1996: 143) argued that the EU agenda was one that
excluded most of women’s lives, in particular, the complexity of the con-
nections between family, work, welfare, and the labour market, without
which violence against women could not be understood.
It is undeniable that the EU mainly concerned itself with work-related
equality and women’s rights in the workplace. In addition, feminist
scholars tended to concentrate on areas other than domestic violence
when studying the role of the EU.11 However, domestic violence did
emerge as a concern at the European level as early as the 1980s (European
Parliament, 1986).12 This was well before it was regarded as an important
issue in Finland but later than in Britain. Since then significant develop-
ments have taken place that have raised the profile of domestic violence at
the EU level. A few key developments are outlined below to illustrate this.
For instance, the human rights provisions of the EU were strengthened
with the Amsterdam Treaty 1997 (which came into force on 1 May 1999),
which turned equality for women and men into one of the explicit tasks
of the European Community (Article 2). The Treaty allowed sanctions to
be taken against member states violating in a ‘serious and persistent’ way
liberty, democracy, respect for human rights and fundamental freedoms
and the rule of law (Article 7) for the first time. The promotion and pro-
tection of the human rights of women thus became an essential part of
the EU’s human rights policy (European Commission, 2000: 9; Hubert,
2001: 156–7). This signals that the original commitment of the EC member
states to equal pay for equal work was widened to recognise equality
between women and men as a fundamental principle of democracy for
the whole EU (Hubert, 2001: 145).
In December 2000, the European Commission adopted the European
Charter of Fundamental Rights of the European Union. The Charter set
out for the first time in EU history the Union’s obligation to promote
a whole range of civil, political, economic and social rights of European
citizens and all people resident in the EU. Articles 20–27 address issues
of equality and guarantee to protect and ensure the right to equality
between women and men (European Commission, 2002: 4–5). The new
Framework Strategy on Gender Equality was implemented in 2001, fur-
ther integrating the issues of violence against women and trafficking in
women within the general framework designed to promote gender equal-
ity in all aspects of social and civil life (European Commission, 2002: 4–5).
Both developments suggest that it is possible to articulate violence
against women as a women’s right issue within the human rights dis-
course. Accordingly, the EWL called on the EU to establish a firm legal basis
on violence against women within the new EU Treaty/Constitution (2003).
Within the boundaries of soft law, some EU actions illustrated a
strengthened commitment to tackle violence against women. Austria,
Germany, Finland, Portugal and Spain hosted conferences on the topic
during their presidency and each of them adopted EU-wide recommen-
dations or statements. The Stop Programme was set up in 1996 to
strengthen co-operation to combat trafficking in women and children
and it was followed by the Daphne Initiative (1997–9) to support and
promote close cooperation of NGOs active in this field, to improve stat-
istics and information on violence against women, to encourage pre-
ventive measures and to strengthen the protection of victims of violence
(European Commission, 2001). A new Daphne Programme followed
(2000–3). It was open to public bodies in addition to NGOs and had a
budget of 20 million euros (European Commission, 2000a: 19).
In July 1997, the European Parliament adopted a ‘Report on the need
to establish a European wide campaign for zero tolerance of violence
against women’ (the rapporteur was Marianne Fredriksson on behalf of the
Committee on Women’s Rights). The campaign was launched in 1999 by
the European Commission, together with the European Parliament, mem-
ber states and NGOs (European Commission, 2001: 5; Theorin, 2001: 17).
In the context of the campaign, a large, cross-national survey on attitudes
towards domestic violence against women was carried out (European
Commission, 1999). At the same time, statistics revealed that at least one
in five women in the EU experience violence by their intimate male
168 Johanna Kantola
partner and 95 per cent of these acts of violence take place within the
home (EWL, 1999).
In conclusion, this section has illustrated the emergence of new actors
(EWL, WAVE, European Parliament and European Commission), new dis-
courses (public health, human rights), and new institutions (Stop and
Daphne Programmes) at the EU level. These developments took place
beyond state borders, but had the potential to influence member states’
domestic violence policies. In other words, member states have to deal
with the new actors, discourses and institutions. Similarly, feminist actors,
discourses and strategies are now situated in this multi-level governance
framework. The EWL and WAVE are two examples of the ways in which
feminists are engaging with new institutions and levels of governance.
This suggests that it is important that feminist scholars and activists grasp
the importance of these new developments.
The EU discourses in the contexts of Finland and Britain
In this final section, I focus on the potential meaning of the EU dis-

courses for domestic violence debates in Finland and Britain. It is often
noted that EU policies are thwarted by problems of non-implementation
and non-compliance. National policy styles form a dense ‘hinterland’ of
detailed programmes, policies and institutions and it takes a very long
time for EU institutions and policies to permeate and change this hin-
terland significantly (Mazey, 1998: 145). As noted above, on the issue of
domestic violence, the EU did not even resort to hard law (binding
directives or regulations) but remained in the field of soft law, which did
not require similar actions from the member states. Domestic violence
institutions remain different in the member states and the EU does not
attempt to influence them radically. Therefore, my main focus is on the
three discourses on domestic violence that have been predominant at
the EU level; universal domestic violence, human rights and public health
discourses; and their meaning for domestic violence debates in the two
countries examined here.
When comparing the discourses on violence against women in the
EU, Finland and Britain, it is evident that the feminist explanatory dis-
course, the universal domestic violence discourse, was strong in Britain,
and had relatively many representatives in the EU, but had not been
influential in Finland. The legitimacy of the feminist discourses in
Britain and the EU contrast strongly with the predominant family vio-
lence discourse in Finland. In Britain, since the beginning of 1990s, both
female and male MPs, on the Left and Right, argued in parliamentary
debates that domestic violence was a universal phenomenon. In other

words, feminist discourses had filtered through to the state level in that
member state.
In Finland, by contrast, the universal domestic violence discourse was
not recognised by non-feminist or state actors. The significance of the rela-
tively late recognition of the problem of domestic violence is illustrated
by the following statistics (European Commission, 1999). A significant
percentage of the Finnish respondents (39.1 per cent) knew of a woman
in their circle of friends and family who had been a victim of domestic
violence. The figure for the UK was 32.8 per cent and the EU average was
only 19.3 per cent. Also, 40.1 per cent of the Finnish respondents knew
a perpetrator in their circle of friends and family. In the UK, the corres-
ponding figure was 27.4 per cent and the EU average was 16.5 per cent
(see Tables 8.2 and 8.3).
The figures indicate that domestic violence was widespread in
Finland. Yet, when asked whether domestic violence was common in
Table 8.2 Proximity of domestic violence to which women

are victims (1)
The respondents were asked: Do you know of a woman who has

been a victim of some form of domestic violence in your circle of
friends and family?
Yes (%) No (%)
Finland 39.1 56.9

UK 32.8 63.3
EU 19.3 76.3
Source: European Commission (1999: 111).
Table 8.3 Proximity of domestic violence to which women

are victims (2)
The respondents were asked: Do you know of someone who has

subjected a woman to some form of domestic violence in your
circle of friends and family?
Yes (%) No (%)
Finland 40.1 56.1

UK 27.4 68.8
EU 16.5 79.2

170 Johanna Kantola
Table 8.4 How widespread is domestic violence against women?
The respondents were asked: In general, do you think domestic violence against women
is very common, fairly common, not very common or not at all common in your
country?
Very Common Fairly Common Not Very Common

(%) (%) (%)
Finland 8.3 55.1 30.6

UK 32.1 48.9 11.2
EU 24.0 49.5 18.3
their country, only 8.3 per cent of the Finnish respondents thought that
it was very common, in contrast to 32.1 per cent of the UK respondents,
the EU average being 24.1 per cent (Table 8.4). 30.6 per cent of the Finns
thought that domestic violence was not very common in contrast to
11.2 per cent of UK respondents. In sum, there seemed to be a lack of
recognition about the seriousness of the issue in Finland. Statistics about
the frequency of violence against women in Finland had not influenced
public opinion in Finland. This indicates that despite the positive insti-
tutional developments in Finland, the status of combating domestic vio-
lence was not very high. In such a context, support and pressure from,
for example, the EU have an important role to play.
Hence, the EU discourses offer important support for feminist dis-
courses in Finland.13 First, the universal domestic violence discourse sup-
ports an understanding that violence against women results from unequal
power relations. Second, the human rights discourse stresses that in mat-
ters of bodily integrity the individual’s negative rights (freedom from) are
as important as positive rights (freedom to). Traditionally in the Nordic
countries, the latter have been more important and anti-discrimination
laws have not played a central role in achieving equality. It is only recently
that the legal position of an individual has been influenced by human
rights discourse and that there has been an increased consciousness of
legal rights in Finland (Nousiainen and Niemi-Kiesiläinen, 2001: 2). The
EU has been an important source of legal developments in this field
(Nousiainen, 2004).
Arguably, the human rights discourse also has a role to play in Britain.
Under New Labour since 1997, a process of ‘domestication of international
human rights law’ has taken place, which denoted the incorporation of
parts of the European Convention on Human Rights and Fundamental
Freedoms (the Convention) into internal UK law and the adoption of the
Human Rights Act 1998 (Millns, 1999: 182–3). Susan Millns (1999: 198)
suggested that some of the decisions reached in the European Court of
Human Rights indicate that the state could not always draw the boundaries
of public and private sphere activity as narrowly as it might desire. She fur-
ther argued that EU human rights law was already proving significant for
combating sexual violence in the UK and might provide a new source of
legal arms for female prisoners, recipients of welfare benefits, victims of
sexual harassment, single mothers and individual concerned about the
politics of sexual identity (Millns, 1999: 209).14
The public health discourse has not traditionally been very strong in
Finland or in Britain, although in England the Women’s Aid’s website con-
tains statistics on domestic violence and health.15 In the EU, by contrast,
the discourse was prominent and was debated in the European Parliament.
This signals the ways in which the EU is synthesising ideas, for example,
from member states and the international level (UN, WHO). Member states
have to deal with these new discourses in complex ways, for example,
when national organisations apply for EU funding from the Daphne
Programme, which is underpinned by the public health discourse.
Conclusion
This chapter has explored national discourses about gender equality on

the one hand, and emerging transnational discourses on the other. The
chapter focused on one particular aspect of gender equality – violence
against women – in two EU member states, Finland and Britain, and in
the EU itself. The two member states were shown to have strong national
discourses on the topic. These discourses, however, now interact with the
transnational discourses that are emerging at the EU level.
In the context of different national discourses about violence against
women, the EU emerged as an important mediator between member
states. It was a new transnational arena for actors, discourses and insti-
tutions. First, the EU provided the member states with new actors, such
as the European Women’s Lobby (EWL). Second, on the level of dis-
course, the EU discourses provided support for feminist analyses of vio-
lence against women in Finland. In addition, the EU brought forward
discourses, such as human rights and public health discourses, which
were not prominent in the two member states analysed here prior to EU
intervention. Third, on the institutional level, the developments of the
EU domestic violence policy remained rather weak to date but some
important programmes were put in place (Daphne and Stop).
172 Johanna Kantola
Importantly, the evaluations of the influence of the transnational dis-

courses are likely to depend on national discourses and policies. For
example, the importance of the EU domestic violence discourses was
possibly greater in Finland than in Britain. Britain has a well-established
domestic violence policy and the EU discourses are likely to be either
less important or to meet more resistance in that member-state.
It is often assumed that developing countries benefit from international
influence in terms of advancing gender equality. This chapter, in contrast,
has pointed to some of the ways in which a country that is thought to be
a pioneer in gender equality can benefit from transnational gender equal-
ity discourses. The chapter illustrates ways in which the EU could con-
tribute to the advancement of gender equality in Finland. The discussion
showed that Finland lagged behind in recognising violence against
women as an integral part of gender equality, and it was only in the
mid-1990s as a result of international pressure that the Finnish authorities
began to address the problem. This international influence is proving to
be important still in the 2000s and a significant part of it comes from the
EU, as the discussion illustrated.
A focus on domestic violence points to the positive impact of the
transnational discourses represented by the EU. Notably, a focus on other
aspects of gender equality might result in more negative conclusions
about the relationship between the national and the transnational. In
Finland, women and feminist voices are incorporated to the decision-
making processes at the national level through women’s policy agencies
and women’s high representation in the parliament. However, the same
is not the case at the EU level, where Finnish women’s voices are not
heard equally well. In other words, although the EU has an impact in
redefining violence against women in more feminist terms in Finland,
this does not increase the chances of Finnish women’s movements to act
at the EU level. The discussion here has pointed to merely redefining par-
ticular discourses about domestic violence, not providing women with
more spaces within which to act.
It is possible to draw some more general conclusions about studying
the EU as a transnational actor. I studied the EU discourses, actors and
institutions in terms of one specific policy area, namely domestic vio-
lence. A focus on some other aspect of gender equality might result in
different conclusions. Therefore, it is crucial to note that the ‘EU’ and its
policies do not form a homogeneous field. This suggests that EU gender
policies can only be captured by studying different fields, revealing the
contradictory effects and differentiated nature of the EU and its policies
on the member states.
Finally, the analysis about the EU discourses not only shows the import-
ance of the transnational but also points to the continuing power of
national discourses. For example, in Finland, the EU debates on domestic
violence had the potential to challenge the women-friendly welfare state
discourse, but there is no indication of this happening. Nevertheless, the
EU was a source of new discourses for Finland and the Finnish women’s
movement could look to the EU. On the topic of domestic violence
Britain and its women’s movement did not look to the EU, one reason
being the country’s well-established national discourses on this topic.
Notes
1. For such evaluations see Stratigaki (2000: 30), Banaszak (2003: 145) and Rees
(1998: 5).
2. For a recent discussion on the ethnocentrism of the women-friendly welfare
state discourse and its other problems see Borchorst and Siim (2002).
3. Differences and similarities between the five Nordic countries are constantly
debated, and these debates question the existence of one Nordic model and
challenge attempts to portray the countries as aligned (see for example
Bergqvist et al., 1999). In this chapter, I focus only on Finland, and do not
attempt to argue that the same arguments pertain exactly in the same way in
relation to the other Nordic countries.
4. A detailed discourse analysis is beyond the scope of this chapter but forms
part of my PhD thesis (Kantola, 2004a), on which this paper is based. See also
Kantola (2004b).
5. For a classification of different explanations, see Smith (1989) and Hague and
Malos (1993).
6. See for example the debate in the House of Commons, 13 February 1976.
7. The power of the discourse could be seen in the few publications in the
1980s that dealt with domestic violence, for example in a special issue of the
Finnish Social Security journal, Sosiaaliturva (24/1981).
8. Developments that were particularly influential in Finland included a con-
ference organised by the Committee of Ministers of the Council of Europe
on Social Measures Concerning Violence in the Family (15 January 1990),
the First Conference of European Ministers on Physical and Sexual Violence
against Women in Brussels (14–15 March 1990), the United Nations study
Violence Against Women in the Family (UN 1989), and the UN declaration
20 December 1993 on violence against women.
9. Since 1996, there have been two debates on violence against women in
the European Parliament and two debates on trafficking in women: 16
September 1997, Debate on Violence against women, 15 December 1997,
Debate on Trafficking in Women for the purpose of sexual exploitation, 8
March 1999 debate on Violence against Women – Daphne programme, and
18 May 2000 Debate on Trafficking in Women.
10. Feminists have been sceptical about the appropriateness of the human rights
discourse for feminist struggles. For a discussion of different positions, see
Charlesworth and Chinkin (2000).
174 Johanna Kantola
11. See for example Hantrais (2000), Mazey (1998), Meehan and Collins (1996).
12. For example, in 1986, the European Parliament’s Women’s Committee produced
a report on violence against women (European Parliament, 1986; Hanmer, 1996:
139; Hoskyns, 1996: 155). The report led the European Parliament to enact a
‘Resolution on violence against women’ on 14 July 1986.
13. One example of a productive encounter between Finnish and wider EU com-
munities active on the topic was the EU expert meeting on Violence Against
Women in November 1999 in Jyväskylä, Finland, which brought together
activists and scholars from EU countries (see Keeler, 2001). Another one is
the fact that the Coalition of Finnish Women’s Associations is currently in
the process of translating the EWL domestic violence guide (2002a) into
Finnish. The guide draws explicitly on the feminist perspective, where “vio-
lence against women is considered a structural problem, the cause of which
is a direct result of gender inequality” (EWL, 2002: 3).
14. See also Millns (2003) for a more cautious analysis of the capacity of the
Human Rights Act to improve women’s lives in Britain.
15. See http://www.womensaid.org.uk/dv/dvfactsh2.htm (accessed 18 April 2005).
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9
Implementing Gender Equality:
Gender Mainstreaming or the
Gap between Theory and Practice
Petra Meier 1
Strategies to improve women’s participation in politics and to promote

their full citizenship not only focus on the physical presence of women
on the political scene, but also address the achievement of gender equal-
ity through public policies. Public policies can indeed help women to
overcome barriers to their entry in the political sphere, but they are espe-
cially targeted at achieving gender equality in society at large. For a long
time, gender equality policies were limited to ensuring equal treatment of
both sexes in legislation. Later on, they developed into what are often
called specific gender equality policies. While the former approach was
meant to correct existing discrimination (in legislation) and to make citi-
zens formally equal, the latter recognised that equal rights do not neces-
sarily mean equal opportunities or even equal outcome, because of the
structurally different starting positions individuals face in everyday life.
Specific measures, such as positive action, were introduced to mitigate
structural, though not legal, inequality and to promote equality (Nelen
and Hondeghem, 2000). Since the fourth UN women’s conference held in
Beijing in 1995, gender equality policies have increasingly been reoriented
towards a broader and more structural approach of gender inequalities,
with countries like the Netherlands being precursors in this field. Next to
specific or targeted gender equality policies, other public policy areas are
also meant to promote gender equality, not the least by recognising how
previous and current policies contain biases (re)producing gender inequal-
ity and how these can be overcome. Gender mainstreaming is in sum
meant to gender the mainstream public policies.
From the outset, there were high expectations about gender main-
streaming and the possibilities it raised for achieving gender equality.
179
180 Petra Meier
Disappointment about the results of former policies to promote gender

equality increased hopes that the new structural approach of gender
mainstreaming might be more successful. But there were also critical
voices underlining that gender mainstreaming would not be the magic
spell or potion. A decade after the introduction of gender mainstream-
ing feelings are still mixed. Whereas many believe in its ‘revolutionary
potential’, the results cannot be evaluated to be an overwhelming suc-
cess despite numerous political statements. This raises some questions.
Why do political decisions about gender equality measures so often
become watered down or forgotten when they reach the implementa-
tion stage? Why do institutions not change in the intended manner?
And what factors contribute to these problems of implementation or
rather, of non-implementation? How could they be amended, which
institutional characteristics – or women’s strategies for that matter – could
contribute to gender equality issues being taken seriously in various –
political and bureaucratic – institutions?
The aim of this chapter is to address these questions. The focus is
thereby not so much on what has been achieved, but on what could be
achieved. Hence, the focus is on the potential of gender mainstreaming to
achieve gender equality taking the political and institutional setting of the
public policy context into account. I will first start with an analysis and
discussion of the definition of gender mainstreaming, or, of what it prom-
ises. The basic underlying assumption is that what is considered to be a
success or failure depends to a large extent on the definition of the goal
to be achieved (see also Walby, 2004). Much of the existing literature on
gender mainstreaming concentrates on evaluating gender mainstreaming
attempts and draws lists of factors contributing to the potential success of
gender mainstreaming in achieving its goal (see, for instance, Woodward,
2003). Many of these factors come close to what the Council of Europe
(1998) has called ‘facilitating conditions’ or ‘necessary prerequisites’ for
gender mainstreaming. On the whole, these factors are considered to
determine at least partially the potential success of gender mainstreaming.
However, they are ideal criteria, which have been defined from the per-
spective of what is required, not from that of what is available in public
policy making practices. Because these factors are intrinsically related to
the definition of gender mainstreaming, this definition imposes on them,
and I have to discuss them together with the definition itself.
Second, I turn to public policy literature in a broader sense, more
specifically to what are considered to be the sufficient conditions for an
effective implementation of public policies. I will compare the prerequis-
ites for an effective implementation of gender mainstreaming with these
Implementing Gender Equality 181
conditions. Implementing public policies is never smooth; the perfect

implementation of public policies simply does not exist. The problems
observed in (the implementation of) gender equality policies should not
be overestimated or all defined as being entirely caused by the issue at
stake, namely the achievement of gender equality. However, gender
equality policies in general, and gender mainstreaming in particular, face
specific problems. We should distinguish between particular implemen-
tation problems related to gender equality issues and those related to the
implementation of public policies in general. Comparing the prerequis-
ites for the implementation of gender mainstreaming with the sufficient
conditions for the effective implementation of public policies as they
have been defined by the mainstream public policy literature, helps to
make this distinction. In a broader sense, I think that it is also relevant
not to study gender mainstreaming or gender equality policies as separate
entities, but to try to link them to ‘mainstream’ public policy studies.
Finally, I will confront the literature with the everyday practice of
policy-making, because the literature defining sufficient conditions for the
implementation of public policy encounters the same problem as earlier.
The conditions thought favourable for implementation are ideal criteria.
The final question addressed focuses not so much on what is ideally
required but on what is available and on what we can learn from that situ-
ation for further thinking on gender mainstreaming, both in theoretical
and in political terms.
The promises made by gender mainstreaming
The most common definition of gender mainstreaming is the one for-

mulated by the Council of Europe. It reads as follows:
Gender mainstreaming is the (re)organization, improvement, devel-

opment and evaluation of policy processes so that a gender equality
perspective is incorporated in all policies at all levels and at all stages,
by the actors normally involved in policy-making.
(Council of Europe, 1998: 15)
This definition is without doubt the most widespread and adopted, both
by practitioners and scholars of gender mainstreaming. Therefore, I will
start by analysing this definition to see what it is that gender main-
streaming promises.
Although gender equality policies and women’s policy machineries
(Stetson and Mazur, 1995) have many names, the concept of gender
182 Petra Meier
equality has broadly speaking evolved from a legalistic approach of

equal rights, to equal opportunities supported by positive action, to
what is called a more structural conceptualisation of gender equality.
In the feminist literature gender mainstreaming represents this latest
approach. It implies an underlying model of equality that is based on
assigning new standards for gender equality not only for women but
also for men (Rees, 1998). Although not all scholars agree on this far-
reaching definition as being the sole model of gender equality in gender
mainstreaming (see, for instance, Booth and Bennett, 2002), there is a
tendency to argue that equality should not be defined as sameness,
whereby male standards are accepted without discussion and the aim
consists of upgrading the societal position of women to equal that of
men. Neither should equality be defined as an equal valuation of differ-
ence between the sexes whereby women (and men) might still be stuck
in traditional role patterns. Gender mainstreaming rather implies that
new standards are defined for both sexes that are neither male nor neces-
sarily confirm traditional role patterns. Verloo (2001) argues that gender
mainstreaming stands for the recognition of the impact of gender biases on
the reproduction of gender inequality. Her description of this dynamic
suggests that both gender inequality itself and its mechanisms of repro-
duction have a structural basis. Similarly, Liebert (2002) argues that
gender mainstreaming widens the gender equality frame by expanding
thinking about the structural and institutional causes of inequality.
Neither the definition of equality as sameness, nor its definition as the
equal valuation of differences between the sexes is considered to fully
recognise the structural causes of gender equality.
As mentioned before, gender mainstreaming is often considered to
have a ‘revolutionary potential’. ‘This strategy implies a much more
complex and widespread political action, and a revolutionary change
in the process of policy-making’ (Bustelo, 2003: 384). ‘Gender main-
streaming requires a radical redefinition of policy values and practices’
(Woodward, 2003: 65). Other scholars, too, refer to the fact that gender
mainstreaming is a potentially revolutionary (Verloo, 2001) or radical
(Mazey, 2000) strategy. The revolutionary or radical potential of gender
mainstreaming does not only refer to the underlying model of equality
and hence the outcome of the policy-making process, but especially to
what a gender mainstreaming strategy would do to the policy-making
process itself. Gender mainstreaming is meant to lead to a critical review
of deeply embedded cultural values and policy frames (Mazey, 2000) or
practices (Woodward, 2003). It requires new perspectives, new expert-
ise and the change of established operating procedures (Pollack and
Hafner-Burton, 2000). It actually addresses political, policy and bureau-

cratic systems and structures themselves (Rees, 1998). It implies more
complex and broader political action (Bustelo, 2003), in order to come to
a transformation of the existing policy agenda (Verloo, 2001). In the end,
gender mainstreaming means that its principles and practices become
part of the routine of policy formulation and implementation, that they
become part of the deeply embedded rules or practices of institutions
(Bretherton, 2001).
Taking a closer look at the Council of Europe’s definition of gender
mainstreaming leads to a similar conclusion on the expected revolution-
ary potential of gender mainstreaming regarding the policy-making
process. First, gender mainstreaming organises, reorganises, improves,
develops and evaluates policy processes. Hence it is meant to intervene in
the existing policy-making process. The minimal result is that the policy
process is challenged, for instance by the addition of new elements or by
a minor reorganisation. The maximum is that the policy-making process
becomes completely revised and remodelled, adding major new dimen-
sions to it. Second, gender mainstreaming requires that a gender equality
perspective be incorporated in all policies at all levels and at all stages.
Again, this involves major changes since gender equality policies have trad-
itionally been confined and limited to the competencies of the women’s
policy machinery meant to develop sector policies. The mainstream of the
policy-making process was not required to adopt a gender equality per-
spective. Furthermore, a gender equality perspective was not applied to all
stages of the policy-making process. Third, gender mainstreaming implies
that a gender equality perspective is adopted and incorporated by the actors
normally involved in policy-making whereas formerly gender equality
policies were confined to the women’s policy machinery.
The impact gender mainstreaming should have on the policy-making
process is reflected in it being labelled as an agenda-setting approach
(Jahan, 1995) as opposed to an integrationist one. Gender mainstream-
ing is supposed to reorient the mainstream political agenda because
it fundamentally rearticulates policy paradigms, ends and means from
a gender perspective and it prioritises gender objectives. While the
agenda-setting approach transforms mainstream policies, an integra-
tionist approach does not challenge the mainstream itself. It would
merely limit itself to inserting a gender perspective, to adding women to
the mainstream, without questioning the underlying policy paradigms
(Lombardo, 2005). Feminists prefer the agenda-setting approach and argue
that gender mainstreaming is precisely about challenging and transform-
ing the mainstream.
184 Petra Meier
The articulation of gender mainstreaming as an at least potentially

revolutionary strategy, and its prevailing conceptualisation, are indica-
tors of the expectations fostered. They promise a lot and raise high
expectations. Lombardo (2005) clearly reveals these promises through
a list of indicators developed in order to recognise whether a gender
mainstreaming strategy has been adopted. In order to study the extent
to which the processes preceding the two recent European Conventions
on the Future of Europe and the Charter of Fundamental Rights fol-
lowed a gender mainstreaming strategy, she defined five shifts in the
policy-making process that at least partly have to occur in order to be
able to speak of the existence of gender mainstreaming.
A first shift concerns concepts underlying the policy-making process.
Gender mainstreaming implies a shift to the broader and more holistic
concept of gender equality discussed above, with a focus on gender and
not only on women, and the aim of achieving substantive equality. A typ-
ical element of such a shift is that structural causes of the reproduction
of inequality, such as the male standard, the patriarchal system or men’s
behaviour, are focused on too. A second shift implies that the mainstream
policy agenda has to be reoriented in order to give priority to achiev-
ing gender equality. Policy objectives and measures meant to achieve
substantive gender equality have to get a relevant place in meaningful
policy initiatives and fields. Gender equality objectives and targeted
policies of special relevance for women should get priority. A third shift
requires that a gender perspective is built into the larger or mainstream
political agenda, as has also been discussed before. Policy measures have
to be screened regarding their effects on both sexes. Policy ends and
means have to be thought through and rearticulated from a gender per-
spective. A fourth and related shift concerns the institutional and organ-
isational cultures of political decision-making, implying shifts in the
policy process, in policy mechanisms and regarding policy actors. This
involves acquiring the necessary gender expertise and knowledge on the
mechanisms causing and reproducing gender inequality as well as on
the necessary remedies. It entails more cooperation among actors of dif-
ferent policy areas and from civil society, as well as the development and
use of new policy tools. A fifth and final shift implies parity between
men and women in decision-making bodies and processes, hence, a shift
towards the inclusion and participation of a higher number of women
in political decision-making.2
Advocates and scholars of gender mainstreaming acknowledge that
such shifts do not occur by themselves. For the change to occur, a set
of necessary prerequisites needs to be in place. These are the necessary
political will to define gender equality as one of the main policy object-
ives and to question prevailing paradigms, structures, processes and
policies reproducing gender inequality. These conditions also imply the
necessary knowledge on the current gender relations and on gender
issues. Special emphasis is put on the availability of statistics and data
segregated by sex. Furthermore, as mentioned before, policy processes
have to be reorganised or developed in order to be able to cope with
gender mainstreaming. Another condition for gender mainstreaming is
the availability of the necessary financial means, human resources, etc.
Finally, gender mainstreaming requires the presence of complementary
specific gender equality policies, of a women’s policy machinery and of
the participation of not only men but also women in political decision-
making. All these necessary prerequisites or facilitating conditions are
considered to set the framework for gender mainstreaming. It is argued
that gender mainstreaming is difficult to implement without them. In
this respect the definition of gender mainstreaming promises a lot and
raises high expectations, but it is also – and this is commonly recognised –
very demanding. It is a fact that the conceptualisation of gender main-
streaming itself is a source of possible deception when it comes to results.
Conditions for an effective implementation of

public policies
There are different policy styles between countries, regions or levels of

policy-making, due to differences in political, administrative or juridical
systems, their paradigms, organisational and cultural processes or rou-
tines, as well as fundamental norms and values prevailing in society at
large. The successful implementation of public policies is also directly
related to former steps in the policy-making process and there are dif-
ferent ways to approach the question of how to implement public pol-
icies. None the less, the public policy literature on implementation
theory defines a number of conditions for an effective implementation
of public policies or of constraints to be avoided (Hogwood and Gunn,
1984; Hill and Hupe, 2002). They can be summarised in two sets of con-
ditions, external and internal factors. Internal factors are directly related
to the implementation stage of public policies, their presence or absence
having a direct impact on the effective implementation of public pol-
icies. External factors affect the implementation stage of public policies
even though they are no direct part of it. Generally, they are related to
stages preceding the implementation of policies or they are part of the
larger framework in which policy-making takes place.
186 Petra Meier
A first external factor affecting the implementation stage is the require-

ment that public policies be based on a valid theory of cause and effect.
This implies that there is a correct analysis and understanding of the pol-
icy problem lying at the basis of policy intervention. It also implies that
this should be translated into an adequate prognosis of how to solve the
problem at stake. There need be not only a correct diagnosis itself, but
also a correct understanding of the principal factors and causal linkages
affecting the policy objectives defined. The relationship between cause
and effect should be as direct as possible, preferably without any inter-
vening links or with as few as possible. Attempts to translate policy
problems into policy objectives through very complex patterns of
dependency with (various levels of) intervening variables hamper effect-
ive implementation. Second, there should be a complete understanding
of and agreement on the policy objectives to be achieved. Policy object-
ives should not be vague or evasive but easy to identify, clear and specific.
They should be consistent, mutually compatible and supportive. And
they should be understood and agreed upon by all parties involved.
Third, sufficient competence and jurisdiction over the target groups and
other points of leverage is essential. Finally, circumstances external to the
implementing process should not have a constraining effect on it. The
relative priority of the policy goals formulated should not be undermined
by the emergence of conflicting public policies or by other external con-
ditions undermining effective implementation, such as changes in rele-
vant socio-economic conditions or the lack of political will on behalf of
important policy actors to achieve the goals set. The literature underlines
the need for substantial commitment to and active support of the policy
objectives or statutory goals set.
The second set of conditions for the effective implementation of pub-
lic policies focuses on internal factors directly related to the implemen-
tation stage. First, the implementation process should be sufficiently
structured. The implementing agency should have an adequate hier-
archical integration. Tasks should be fully specified; it should be precisely
defined who does what in moving towards the objectives. There should
be a perfect communication and co-ordination of the various actors and
elements involved in achieving the policy goals set. Preferably there
is but one single implementing agency and otherwise dependency
relationships should be reduced to a minimum. The more agreement
needed in the stages of the implementation process, or the greater the
number of actors involved, or both, the less predictable the policy out-
come becomes. Second, the implementing agency should be sympa-
thetic to the issue. Third, adequate time and sufficient resources in terms
of money, of human resources, of substantial skills, etc. should be made

available. There must not only be enough overall resources but also
the necessary combination of resources needs to be available at every
stage of the implementation process in order to avoid postponement or
abandonment.
Even though Hogwood and Gunn (1984) produce a policy analysis for
what they call ‘the real world’, they underline that their conditions are
those for a perfect implementation of public policies, thereby recognis-
ing that they do not occur in practice. It is an illusion to believe that
policy making happens under ideal circumstances. None the less, con-
trasting the prerequisites for gender mainstreaming with the conditions
for effective implementation as defined in the public policy literature
can help to detect potential implementation problems regarding gender
mainstreaming.
Conditions for the effective implementation of public

policies and gender mainstreaming
Gender mainstreaming definitely shares with public policies more gen-

erally the external constraints affecting the implementation stage from
the outside. The very need for gender equality policies basically resides
in the fact that problems of inequality are not perceived at all or that
they are wrongly perceived. If the causes of gender inequality had been
correctly assessed and addressed there would simply be no need for pol-
icies meant to achieve gender equality. For instance, for a long time it
was not considered a problem that women had no right to vote, to prop-
erty or to the same employment, salary and pension rights as men, and
this is still the case in certain areas. These differences on the grounds of
sex were (or are) not perceived as being problematic and it took a long
struggle by feminists to get them recognised as such. The problem of
gender inequality is also a very complex one. Its causes are multiple and
they can be found in the organisation of all spheres of society: citizen-
ship, labour and intimacy. It goes beyond the individual, a certain loca-
tion or even one time frame. Gender inequality is fed by layers of causes,
which are related to each other and subject to change. The evolution in
the recognition of the causes of gender inequality also means that gen-
der mainstreaming faces important constraints when it comes to an easy
translation of the relationship between cause and effect as there are
many intervening links. The interconnectedness between gender inequal-
ity and other social inequalities such as those based on race, ethnicity
and sexual orientation, make it difficult to simplify the problem into a
188 Petra Meier
single simple diagnosis and prognosis, which is meaningful for policy

purposes. Simplification in this case often leads to abstraction; a reduc-
tion of the problem leads to simply recognising that gender inequality
exists and that the solution is to strive for the achievement of gender
equality. This might be the bottom line of the issue but such a simplistic
articulation is not helpful from the point of view of the formulation of
policy objectives. Hence, the complexity of gender inequality issues
might make it difficult to come to clear, specific and consistent policy
objectives. However, the growing complexity of policy problems does
not only concern the issue of gender inequality but is a feature charac-
terising society at large. And the accumulation of insights into the
causes of gender inequality certainly facilitates the formulation of more
effective policies.
This does not alter the fact that the diagnosis of gender inequality issues
faces the problem that it interferes with broader normative concerns. As
with many other policy questions, the issue of gender inequality is
analysed within the setting of a – often at least partially unarticulated –
normative view of the correct or ideal society, including perceptions of
women’s and men’s societal roles. The difficult separation of normative
assumptions from a problem diagnosis of gender inequality issues makes
a correct estimation of the actual situation more difficult. The correctness
of a certain analysis is never anything but relative because it is related to
the normative conceptualisation of society. Normative assumptions
might blur the diagnosis of gender inequality but moreover they might
have implications for the prognosis; for the policy objectives defined. The
danger that policy objectives do not in the end correspond to the prob-
lems as such might reside in the fact that they are blurred by normative
assumptions about the positions men and women should occupy.
Both the complexity of the problem of gender inequality and its articu-
lation within normative settings on what male and female societal pos-
itions should look like, potentially undermine the necessary ‘perfect’
understanding of and agreement on the policy objectives to be
achieved. They make it unlikely that policy objectives on gender equal-
ity are understood and agreed by all parties involved. This is even more
true in the case of gender mainstreaming, because it requires an under-
standing of more complex causes and patterns of inequality, a shift to a
broader model of gender equality and a prioritisation of gender equality
issues within a broad range of policy fields formerly not implied in the
achievement of gender equality. Gender mainstreaming puts into ques-
tion prevailing policy paradigms, both when it comes to gender equality
and when it comes to other paradigms. Even if fully understood by all
parties involved it is unlikely that the transformations gender main-

streaming involves will be agreed upon by all of them. Gender equality
policy objectives have seldom been awarded relative priority, and the
requirements of gender mainstreaming make it even less likely that it
will be put on the top of the political agenda. Gender equality policies
will probably continue to come off worst in the competition between
conflicting public policy objectives (for a very good illustration of the
priority of the supply side of the labour market see, for instance, Rubery,
2002; or Stratigaki, 2004; see also Bretherton, 2001).
Gender mainstreaming does not only share the constraints affecting
the implementation of public policies from the outside. It is especially
affected by the factors directly related to the implementation stage and
it is at this level that we can mainly find problems particular to gender
mainstreaming. The effective implementation of public policies is sup-
posed to require a sufficiently structured process, implying a minimum
number of dependency relationships and preferably just one imple-
menting agency. Gender mainstreaming, like all horizontal policy
approaches, fundamentally challenges this principle. The basic idea of
gender mainstreaming is that a gender equality perspective is incorp-
orated in all policies at all levels and at all stages, and that all policy
actors contribute to the achievement of the gender equality objectives
set. In this respect, implementation in the gender mainstreaming
approach resembles a governance paradigm, whereby the focus is more
on network management and less on a vertical chain-like relationship.
This means that a multitude of actors is involved in the implementation
of policy objectives and not a single policy agency, and that these actors
are located in all policy fields and at all levels. An effective implementa-
tion of gender equality policies therefore requires a comparatively high
degree of communication and co-ordination of the various actors and
elements involved in achieving the policy goals set. It also requires a
more elaborated and very precise definition of responsibilities and tasks
between the different actors involved in the implementation process.
These supplementary efforts require extra resources: knowledge and
expertise, both on gender issues and on the management of the imple-
mentation process; actors who actually execute all these tasks; tools and
instruments to do so; in sum: money and time. But gender mainstream-
ing requires more than resources. It involves a remodelling of implemen-
tation processes. All these supplementary efforts, which are required by
horizontal approaches to policy-making, stand in sharp contrast to the
fact that gender equality policy objectives are often not considered to be
a priority. Policy outcomes can further be hampered by the fact that the
190 Petra Meier
inclusion of all policy fields implies non-hierarchical working relation-

ships. The multitude of actors, and especially the inclusion of actors for-
merly not involved in gender equality issues, also increases the likelihood
that not all of them are sympathetic to the issue of gender equality.3
Finally, gender mainstreaming challenges the relative importance of the
women’s policy machinery. On the one hand, it might move towards
centre stage, because of its comparably high expertise and crucial coord-
inating role. On the other hand it loses its privileged status as an expert
on gender equality policies.
In sum, gender mainstreaming shares the external constraints affect-
ing the implementation of public policies in general and in addition
it faces particular internal ones. This conclusion puts the problem of the
weak implementation and unsatisfactory outcomes of gender main-
streaming policies into perspective. But it also illustrates that what the
literature on gender mainstreaming defines as being necessary prerequis-
ites or facilitating conditions are relevant claims.
Gender mainstreaming and the gap between

theory and practice
Attempts to implement gender mainstreaming confirm that many of

the constraints can be found in typical policy making. An ongoing
analysis of various types of policy documents related to political partici-
pation, family policy and domestic violence in six European countries
and at the EU level over the last decade (see www.mageeq.net [accessed
19 April 2005]) reveals that such documents in many cases do not follow
a rigid rational problem analysis (Krizsán et al., 2004; Meier et al., 2004;
Verloo et al., 2004). The policy documents do not necessarily provide for
a coherent problem analysis. They are even less likely to extrapolate it to
a clear prognosis of how to solve the problem and with what it means.
In cases where a problem analysis is present it is often limited to listing
a long number of problems without necessarily relating them to each
other or searching for their underlying causes. In many cases policy docu-
ments limit themselves to prognosis, which often takes the form of
‘shopping lists’ of wished measures. These measures are frequently unre-
lated to the problem in need of a solution, and they do not specify who
is supposed to do what and which means are necessary to attain the
objectives set. Finally, many policy documents lack a clear role attribu-
tion in diagnosis and prognosis of who caused the problem, who should
solve it and which are the target groups of the policy to be implemented.
Policy documents actually reflect that they are generally as much a
result of political compromises as of a rational analysis of the policy

issue at stake. Policy documents have to be agreed upon by a large num-
ber of actors, hence, priority might be given to achieving the necessary
political consensus rather than producing an analytically consistent pol-
icy document. More than the analytically correct goal, policy docu-
ments reveal the politically acceptable objective.
The acceptability of the goal is related to prevailing assumptions about
gender equality. As Bretherton correctly underlines, gender mainstream-
ing ‘is not an attempt to remedy an absence’ (Bretherton, 2001: 62). The
organisation and functioning of society is imbued with understandings
about gender. ‘In consequence, attempts to “mainstream” gender equal-
ity are confronted by pervasive understandings and practices supportive
of male dominance’ (Bretherton, 2001: 62). Liebert (2002), for instance,
argues that the widening of the prevailing equality policy frame through
gender mainstreaming in Germany collides with the frame of the male
breadwinner. The German tax system, nurseries, schooling provisions,
parental leave allowances and other systems strongly stimulate a (male)
bread winner and a (female) care giver who has renounced paid employ-
ment and they do not correspond to a model of equality required by
gender mainstreaming. Such pre-existing gender regimes have a strong
impact on the implementation and impact of gender mainstreaming
(Walby, 2004). To a certain extent they determine the degree of openness
to gender mainstreaming and the extent to which it can contribute to
change. Conservative perceptions of gender roles by some actors under-
mine the adoption of far-reaching gender equality objectives and putting
them into practice as recent Belgian (Plasman and Sissoko, 2004) and
Spanish (Lombardo, 2003) policy initiatives have shown.
Existing gender regimes do not only set the general context for gender
mainstreaming. The existence of different and eventually conflicting per-
ceptions of gender equality can lead to policy documents including vari-
ous models of gender equality. The European Commission, for instance,
bases its policy recommendations on many different models of gender
equality such as equality as sameness, an equal valuation of difference,
and the request to set new standards for both sexes (Walby, 2004). The
analysis of policy documents related to political participation, family pol-
icy and domestic violence in six European countries and at the EU level
revealed that whereas one definition of gender equality can lead to the
formulation of different policies, different definitions can also lead to the
very same suggestion for a policy solution (Meier et al., 2004). The ques-
tion is to what extent this conjunction of gender equality models and
unrelated concrete objectives is a conscious choice, the ignored outcome
192 Petra Meier
of political negotiations or the consequence of a lack of insight in gender

equality issues. In many cases the assumption that women have to catch
up with men is still very much on the agenda and many objectives essen-
tially refer to women, even though the policies are officially labelled gen-
der mainstreaming (Service public fédéral Emploi, Travail et Concertation
sociale et al., 2002, 2003; see also Benschop and Verloo, 2000; or Nelen,
2000, who report similar cases and conclusions). An analysis of the post-
civil war reconstruction of Bosnia-Herzegovina revealed that not only a
lack of sensitivity to gender equality but also erroneous gender stereotypes
about men and women led to poor policies (True, 2003). The further away
from the femocrat centre or the women’s policy machinery that gender
mainstreaming attempts travel, the more frequently the term gender
mainstreaming is misunderstood (Woodward, 2003).
No matter the causes for the absence of a clear vision of gender equal-
ity, the point is that this absence makes it possible to adapt the defin-
ition of gender equality to a particular situation. Rubery (2002) points
out the clear absence of such a definition at the EU level, which allows
the member states to define very different policies within the same pol-
icy field. While some member states take the role of women as the pri-
mary caregiver for granted and design policies meant to facilitate and
not to change women’s dual role in employment policies, others chal-
lenge traditional gender roles. The problem then is that what is labelled
as gender mainstreaming might not actually be gender mainstreaming,
leading to policies that are sold under the wrong label, not necessarily
bringing substantive gender equality closer.
Existing gender regimes, especially conservative perceptions of gender
roles, also stimulate strategic framing on behalf of the advocates of gen-
der mainstreaming. Advocates of gender mainstreaming try to extend
existing frames or to construct links with existing frames, by connecting
gender mainstreaming to the language, values and objectives of the
dominant prevailing policy frames (Verloo, 2001; see also Lombardo,
2005). There is evidence that the more gender mainstreaming is strategic-
ally framed in accordance with dominant policy frames, the more open
the political system is towards it (Pollack and Hafner-Burton, 2000; see
also Benschop and Verloo, 2000; Plasman and Sissoko, 2004; or Rubery,
2002, for concrete examples of strategic framing). Benschop and Verloo
(2000) point out a related strategy, that of self-censorship. In a gender
mainstreaming approach the approval of various actors is often required
all along the policy-making process. This can lead to a form of self-
censorship on behalf of the advocates of gender mainstreaming in order
to anticipate possible negative reactions and to prevent conflict.
But strategic framing and preventive self-censorship can have the

boomerang effect that the message is not passed, relevant details on how
gender relations should change or even the basic assumptions of gender
mainstreaming do not necessarily get across. This makes it more likely
that key elements of the message of gender mainstreaming do not find
their way into a sound problem analysis or even formulation of policy
objectives. In the end, strategic framing and self-censorship might
undermine the putting into practice of gender mainstreaming. The
problem is that the more hostile the policy context is likely to be
towards gender mainstreaming, the greater the chance that advocates
will try to frame it strategically, which might then in itself decrease the
likelihood of having a sound gender mainstreaming approach adopted.
However, there is no short-term solution for this dilemma, especially
since gender equality is seldom a priority, other than a rhetorical one
(see for instance Lombardo, 2003; Plasman and Sissoko, 2004). Or, as
Stratigaki points out with respect to EU policies:
Analysis of the barriers to implementing gender mainstreaming show

that the problem was not that it was newly established and needed a
‘grace period’ for policy actors to assimilate it. Barriers are primarily
erected because gender mainstreaming is infiltrated by feminist concerns
suggesting fundamental changes in ways of thinking and under-
standing society. Gender mainstreaming can potentially challenge
and transform gender-biased public policies. However, this policy goal
interferes and clashes with other dominant policy frames of the EU based
on hierarchical gender distribution of power.
(Stratigaki, 2005: 15, emphasis in the original)
Therefore, at the point of departure for the implementation of gender

mainstreaming a sound problem diagnosis is often not available, the
concrete link between diagnosis and policy objectives may be weak,
with policy objectives being in themselves ambiguous and the larger
policy environment may not be in favour of fundamentally altering pre-
vailing gender relations when this collides with other policy priorities.
An analysis of the routine practice of policy-making also reveals many of
the constraints directly related to the implementation process.
For example, in 2001 each minister of the federal Belgian government
set a policy objective in order to mainstream a gender perspective and to
promote gender equality within his or her competencies (Service public
fédéral Emploi, Travail et Concertation sociale et al., 2002). Despite the
doubling of the initial timeframe from one to two years, many of the
194 Petra Meier
objectives were not met. A major reason resided in the clash between
the need for a transversal approach and the sector-based reality of the
Belgian (federal) policy making structure. The clash between the hori-
zontal approach of gender mainstreaming and vertical structures leads
to a dependency on third actors not involved in a vertical dependency
relationship. The making operational, implementation or follow-up of
the gender mainstreaming objectives often turned out to be the respon-
sibility of another authority. This could be a regional or local authority
but meeting the objectives set could also come under the competencies
of another Minister and hence another vertical power structure. This
was further complicated by the fact that the putting into operation and
implementation of the objectives was generally attributed to actors at a
low level in the hierarchy, which made it difficult for them to have an
impact on external actors on whom they depended for meeting the
objectives (Plasman and Sissoko, 2004).
This problem is the more succinct in multi-level systems involving a
supranational level. For instance, EU policies on structural funds have to
be implemented by national and regional authorities within the mem-
ber states (Rossili, 2000). Rubery (2002) shows that policy areas requir-
ing change in the workplace have generated but a limited government
involvement, most of it being left to the discretion of the social partners.
The weakness or lack of interest of the trade unions to advocate sub-
stantive change in existing gender relations led to the issue being left as
the employers’ sole responsibility.
Existing problems of implementation are further amplified by the fact
that gender mainstreaming policies often rely on soft policy tools: targets,
benchmarking, discretionary guidelines, (informal) codes of practice, and
the exchange of good practice. As the name indicates, soft policy tools
do not have a compelling character. They are malleable and rarely require
justification. Even though their malleable character facilitates testing,
learning and adaptation of the tools and instruments, they are relatively
ineffective when it comes to fostering or enforcing change in a hostile
environment (Mazey, 2002). Also, gender mainstreaming cannot rely on
many procedural blueprints or cut-and-dried tools and instruments on
how to implement it. This increases the relatively large discretion of
policy-makers to render it operational and to implement it (Liebert, 2002).
In sum, in many cases vague policy objectives regarding gender equal-
ity go hand in hand with a considerable amount of discretion when it
comes to making them operational and implementation in a gender
mainstreaming approach. The first problem is external to the implemen-
tation process of gender mainstreaming and goes for public policies in
general. The second problem is directly related to the implementation

process, but is to a large part specific to the horizontal approach and
relative newness of gender mainstreaming. The point is that the different
problems mutually reinforce each other. A tighter implementation process
with the necessary expertise at its disposal could more easily absorb and
counterbalance problems external to the implementation process itself.
Implementation problems due to a large amount of discretion would
have less importance in cases where there is better problem analysis, a
more direct relationship between cause and effect and more substantive
priority awarded to the achievement of gender equality.
Conclusion
The concept of gender mainstreaming promises a lot and it raises high

expectations, but it is also a very demanding task. In this respect, the con-
ceptualisation of gender mainstreaming itself is a source of possible
deception when it comes to results. What is considered to be a success or
failure depends to a large extent on the definition of the goal to be
achieved. However, contrasting the prerequisites for gender mainstream-
ing with what are considered to be sufficient conditions for an effective
implementation of public policies, shows that gender mainstreaming
shares the typical external constraints affecting the implementation of
public policies but that it also faces particular internal ones. Furthermore,
contrasting such ideal conditions with everyday practices of policy-making
shows that the different problems related to the implementation of gen-
der mainstreaming mutually reinforce each other. This conclusion puts
the problem of the weak implementation and outcomes of gender main-
streaming policies into perspective. The problems observed in (the imple-
mentation of) gender equality policies should not be overestimated or all
defined as being due to the issue at stake, namely the achievement of
gender equality. A distinction should be made between implementation
problems related to gender equality issues and those related to the imple-
mentation of public policies in general.
Hence, the question of why political decisions about gender equality
measures so often become watered down or forgotten when they reach
the implementation stage, can be easily answered pointing at the fact
that the same applies to many public policies. But yes, part of the prob-
lems in implementation is due to the fact that the issue is about gender
equality. The question then arises what can be done about it. What can
we learn from the present state of the art for thinking further on gender
mainstreaming, both in theoretical and in political terms?
196 Petra Meier
It might be important to focus not so much on the lack of material

results or their weakness. Instead, we should re-orient our focus on the
policy-making process itself and how it works, as research is starting to
do to a growing extent. In order to achieve a better implementation of
gender mainstreaming we need to know precisely how the process works
and what mechanisms play a role in it. This approach implies that we do
not so much start with the ideal conditions and see to what extent they
are fulfilled but rather focus on institutional practices and see what we
can learn from them. Within this context it is also important to distin-
guish between the different stages of the policy-making process. It is true
that the conditions for the implementation of public policies are partly
products of what has happened before. It is also impossible to draw gen-
eral conclusions because so much depends on the larger political system,
on bureaucratic traditions and cultures, on specific policy issues. Policy
problems are not only related to issues but also to specific contexts. But
it is important to be able to locate precisely the causes of implementa-
tion problems. For instance, the clear and unambiguous articulation of
gender mainstreaming objectives is not underlined as much in the litera-
ture as the need for political support or necessary resources. Research
can and should play a crucial role in analysing gender mainstreaming
processes because the evaluation of public policies and policy-making
processes still receives less attention than it needs in order to be effect-
ive. All this will help us clarify the conditions favourable for a substan-
tive implementation of gender mainstreaming, which will favour its
concrete implementation in everyday policies.
Notes
1. With special thanks to Theo Jans and to Anne Maria Holli for their very help-
ful comments and suggestions.
2. Lombardo (2005) does not clarify the precise link between a shift towards parity
democracy as an equal participation of both sexes in political decision-making
and gender mainstreaming. Parity democracy could actually be seen as one of
the outcomes of gender mainstreaming, because gender mainstreaming is a tool
to achieve substantive equality. Substantive equality implies an equal share of
power between men and women. It is however arguable whether there needs
to be a shift from a minimum presence to an equal share of women in political
decision-making in order to be able to speak of gender mainstreaming. Lombardo
is not alone in underlining the need for a sharing of power between the sexes and
gender mainstreaming (see, for instance, Council of Europe, 1998).
3. Increasing the number of actors involved in the achievement of gender equal-
ity also raises the possibility that actors favourable to gender equality but trad-
itionally not involved in such issues receive a platform for action.
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10
Good Governance and Good for
Business Too? Equality and
Diversity in Britain
Judith Squires
In this chapter I want to argue that where the pursuit of gender equality in
Britain was previously framed by arguments for social justice and inclu-
sive citizenship – but limited in focus to the labour market – it is now
increasingly addressed as part of a wider ‘equality and diversity’ strategy,
framed by arguments for economic productivity and applied widely
to all aspects of social, economic and political citizenship. I want to sug-
gest, via an exploration of both gender mainstreaming and diversity
management in Britain and the EU, that whilst both mainstreaming and
diversity have theoretical appeal to radical political democrats and the-
orists, they are conceived, defended and implemented in ways that aim
to appeal to business sector interests. Although quite different in their
derivation, both the diversity and mainstreaming discourses share cer-
tain features. Both are increasingly framed by considerations of good
governance and economic competitiveness such that they marginalise
broader issues of social justice and egalitarian citizenship.
Women and political decision-making
The British public is sceptical about the idea of positive action in pursuit
of gender equality and is more comfortable with the idea of equal oppor-
tunities for all. Researchers have found that when asked to speak of gen-
der equality people use the language of ‘fairness’, ‘tolerance’ and ‘having
the same chances in life’ (Howard and Tibballs, 2003: 7). There is little
support for the idea that women, as a group, are unequal in society today
and sex inequality was not seen as a priority issue. The concept of femi-
nism is seen virtually unanimously in negative terms as old-fashioned.
199
200 Judith Squires
However many people (and young women in particular) liked the idea of
promoting ‘women’s rights’ (Howard and Tibballs, 2003).
The implications of this approach to equality can perhaps be seen most
clearly in relation to debates about women’s political representation.
Whilst the political parties each have their own doctrines and ethos within
this, generating discursive controversies regarding the pursuit of represen-
tative gender equality, the basic citizenship practices of the British polity
operate within a liberal discursive frame that privileges formal equality of
opportunity. Parties that embrace the ideal of minimal equality of oppor-
tunity (Swift, 2001: 91–132), including the Conservatives and the Liberal
Democrats, have eschewed the use of gender quotas, choosing to affirm the
ideals of meritocracy and individual opportunities. As Ian Duncan Smith,
the then leader of the Conservatives, stated: ‘All-women shortlists have not
been a success for Labour, because instead of getting people who are high
quality, what we’ve actually got in is people who haven’t really performed
as politicians for the Labour Party’ (Perkins, 2001). Employing a similar
discursive frame, the Liberal Democrats rejected a motion at their 2001
conference for all-women shortlists. Delegates argued that the shortlists
proposal was ‘illiberal and unworkable’, depriving local parties of their abil-
ity to choose the most able candidate and making women into ‘tokens’. As
a woman from the Lib Dem Youth and Students group argued: ‘The pro-
posers are telling me I cannot fulfil my dream of becoming an MP without
this motion. They underestimate me’ (Ward, 2001).
Parties that adopt a more radical conception of equality of opportunity
(Swift, 2002), such as the Labour Party, have been more willing to adopt
gender quotas. The Labour Party has long been characterised by a com-
mitment to equality, though this commitment has always been accompan-
ied by intra-party debates as to whether equality should be understood
as equality of opportunity, equality of income or equality of regard (see
Drucker, 1979: 45–67). None the less, arguments for positive action meas-
ures regarding women’s representation were consonant with certain
equality discourses that had a clear lineage within the Party. This commit-
ment to equality of presence within the Party was manifest in the General
Secretary’s statement to the 2002 conference: ‘My personal ambition is to
see equal representation for women at all levels of public office. I believe
the party should adopt measures that ensure the selection of more women
candidates and if that means all-women shortlists, then that’s what we
should do’ (Treisman, 2002).
So gender quotas are discursively constructed as one particular solution
to the problem of gender inequality in relation to public participation
in parliamentary politics, but one that appears to its critics to rely on a
problematic conception of equality of outcome that undermines the pursuit

of justice as ‘fairness’ (Wolff, 1998). Moreover, concern about the possible
essentialism implied by quota policies, coupled with scepticism that there
is a link between descriptive and substantive representation, means that
arguments for quotas in Britain have tended to focus on a ‘justice’ argu-
ment, rather than arguments that women’s interests remain unfulfilled or
that democracy is likely to become atrophied (Phillips, 1995: 62–3). The
justice argument implies that numerically equal representation of women
and men in legislatures is itself an indication of parity, regardless of the
beliefs of those present or the policies enacted. Given the ongoing discur-
sive controversies surrounding notions of equality, it is unsurprising that
gender quotas remain controversial in Britain.
The implementation of gender quotas initially took the form of a Labour
Party policy to require all-women shortlists in half of all winnable seats
in the 1997 general election. Following devolution, quota policies – in the
form of twinning and zipping – were also adopted by the Scottish and
Welsh Labour Parties. The two nationalist parties, the Scottish Nationalist
Party and Plaid Cymru, also implemented zipping. Implementation proved
difficult in Westminster elections given the majoritarian electoral system
that operates with single-member constituencies and a first-past-the-post
formula for determining electoral success. The policy of all-women short-
lists was devised as a way of implementing party-based gender candidate
quotas within a majoritarian electoral system. The key challenge to its
implementation has proven to be incumbency (the difficulty of displacing
sitting MPs) and resistance from constituency selection committees.
Implementation was complicated, but also dramatically facilitated, by
the devolution process, which allowed parties to develop different quota
systems appropriate to the mixed electoral system introduced in Scotland
and Wales. It allowed Scottish and Welsh parties to implement zipping on
regional lists. It also allowed for the creation of a new quota strategy appro-
priate to the newly established assemblies with no incumbent representa-
tives, ‘twinning’. Implementation was further complicated by the legal
uncertainty surrounding gender quotas following a ruling in 1996 that
all-women shortlists contravened equal opportunity employment legis-
lation. This uncertainty was later removed by the passing of the Sex
Discrimination (Election Candidates) Bill in February 2002, which allowed
parties to introduce positive action policies without risk of legal challenge.
As a consequence of the all-women shortlists and twinning policies
Britain has witnessed a dramatic rise in the overall numbers of women
present in national legislatures since 1997. This increase is due in large
part to the policies of a single party – the Labour Party – which has
202 Judith Squires
gained a large proportion of the overall vote during this period. However,
the other major political parties (Conservatives and Liberal Democrats)
have neither followed the Labour Party in introducing gender quotas,
nor substantially increased the numbers of women elected within their
party (see Krook, Lovenduski, and Squires, 2005; Squires, 2005 for further
details). This suggests that gender equality is still primarily conceived in
Britain in terms of formal equality of opportunity. However, there have
been significant new developments in the way in which New Labour has
approached gender equality policies and institutions.
Gender mainstreaming
Whereas the under-representation of women in Westminster represents

the most identifiable area of concentrated work by feminist political sci-
entists in British politics (Mackay, 2004: 99–100), New Labour’s com-
mitment to gender mainstreaming has been subject to little analysis.
None the less, there have been important developments in relation to
the establishment of a ‘gender machinery’, which is responsible for
gender mainstreaming and this is an increasingly important aspect of
gender equality policies in Britain.
The UK government adopted gender mainstreaming as its gender pol-
icy in 1998 (Cabinet Office, 1998) and since then has been developing a
series of policy instruments to implement this policy. Its approach to
gender mainstreaming is perhaps best exemplified through the work of
the Women and Equality Unit (WEU) (see Beveridge et al., 2000; Squires
and Wickham-Jones, 2002, 2004).
The Women’s Unit (WU) was established in June 1997, following Tony
Blair’s landslide election victory. The Unit was charged with scrutinising
legislation to promote sexual equality and with promoting female-
friendly policies. A WU publication stated: ‘At the centre of its work is
the drive to put women’s interests into the mainstream of government
policy, including for civil servants through guidance and training’ (WU,
1998: 25). Emphasising the different roles of the unit, including policy-
making and consultation, Harriet Harman was quoted: ‘For the first
time, women’s issues are put firmly at the heart of government. I will
open a new dialogue with women’ (Ward, 1997).
In November 1998, New Labour’s commitment to mainstreaming was
formalised with the publication of ‘Policy appraisal for equal treatment’
guidelines. The guidelines stated, ‘We must understand how policy can
have a different impact on different groups in society’ (Cabinet Office,
PAET guidelines, 1998). The guidelines offered advice to civil servants
on how to monitor the impact of policy proposal through the collection

of data, consultation, assessment, and, if necessary, action. Civil servants
should not assume that policy measures were gender-neutral:
gender impact assessment challenges the assumption that policies and

service affect everyone in the same way. It puts people at the heart of
policy-making and leads to better government by making gender
equality issues visible in the mainstream of society.
(Cabinet Office, 1998)
The WU would provide advice on the implementation of the guidelines.

In 1999 the Unit carried out a large-scale consultation exercise,
‘Listening to Women’: ‘Government has never communicated with
women in this way before. We will circulate our findings in the autumn to
all parts of the government so that they can use them in their own policy
making and will develop women specific guidelines for service providers’
(Prime Minister and Minister for the Cabinet Office, 1999: 27). This exer-
cise was followed with further research and the publication that year of
a magazine, Voices, aimed at disseminating information to women. The
Unit also organised consultations with women’s groups in civil society,
including the Women’s National Commission.
Originally, the WU lacked resources and was poorly integrated into
Whitehall policy-making (see Squires and Wickham-Jones, 2004: 81–99).
It was also subject to criticism by women’s organisations and the press
(Perkins, 1999). As a result many commentators predicted the demise of
the WU before the June 2001 general election (Hinsliff, 2000). However,
the WU was not abolished: it was restructured as the Women and Equality
Unit. As such it took responsibility for policy on gender equality issues
(‘coordinating policy on women and gender equality issues’, Cabinet
Office, 12 July 2001), including the sex discrimination act and equal pay.
The Unit’s remit was to improve the position of women in ‘measurable’
ways and to promote equality generally regardless of gender or sexual orien-
tation. The WEU announced five priorities: reducing the pay gap, work
life balance, women in public life, domestic violence and public services.
In May 2002, the WEU was moved from the Cabinet Office to the
Department of Trade and Industry. In the same month the government
announced its intention to abolish the separate commissions for race
equality, disability rights and women’s opportunities and replace them
with a single equalities body. Angela Mason, formally executive director of
Stonewall (which campaigns for gay and diversity rights) was appointed as
the new Director of the Unit in November 2002. She is a strong advocate
204 Judith Squires
of the creation of a single equality body (Pink Paper, issue 738, 24 May
2002) and is currently overseeing the development of the WEU into an
Equality Unit.
These developments have subsequently worked to redefine the main-
streaming project in Britain, which is increasingly focused on the labour
market and bound up with the pursuit of economic productivity, and is
also now framed as part of a wider ‘equality and diversity’ agenda.
Equality and diversity
In October 2002 the government launched ‘The Equality Institutions

Review’, which it described as ‘the most significant review of equality in
over a quarter of a century’. As part of the review it produced various con-
sultation documents, including Equality and Diversity: Making it Happen,
which explored long-term options for the priorities and role of equality
institutions in Great Britain, and invited responses from end-users, busi-
nesses, service-providers and equality experts.
The government announced, on 30 October 2003, its plans to establish
a single Commission for Equality and Human Rights (CEHR). The White
Paper ‘Fairness for All’ states that the role of the CEHR will be to bring
together work related to several different aspects of equality, including
age, sexual orientation, disability, race, religion and gender. Government
affirmations of this new integrated approach to equality emphasise the
importance of respecting diversity as well as promoting equality: the gov-
ernment’s consultation paper on the Single Equality Body was, for example,
entitled ‘Equality and Diversity: Making it Happen’. This discourse is also
prevalent throughout the wider society: 2002 saw the formation of The
‘Equality and Diversity Forum’ to promote dialogue across the equality
strands; the Learning and Skills Council offers ‘Equality and Diversity
Guidance’; Advisory, Conciliation and Arbitration Service (ACAS) has
‘equality and diversity advisers’; major banks have ‘equality and diversity
strategies’ and most universities now have ‘equality and diversity teams’.
The establishment of the CEHR will further institutionalise the ‘equality
and diversity’ discourse that has emerged so swiftly onto the British policy
agenda.
In 2003 the European Commission also launched a five-year, EU-wide
information campaign, ‘For Diversity – Against Discrimination’, aiming
to ‘promote the positive benefits of diversity’ (EC Green Paper, 2004: 13).
This provides the framework for an integrated equality strategy ‘based on
the premise that equal treatment and respect for diversity are in the inter-
ests of society as a whole’ (EC Green Paper, 2004: 10). This indicates that
the pursuit of equality is now increasingly held to entail a respect for

diversity, both in the EU and in Westminster.
The equality consultation and current plans for a new Commission,
whilst perhaps consonant with New Labour’s wider policy commitments
and political ideals, were in large part instigated in response to directives
from Europe (in particular Article 13 of the Employment Directive) which
extend the grounds for protection against discrimination in employment
and training to include sexual orientation and religion by 2003 and age by
2006. In light of these Directives the government has had to consider how
best to widen existing equality legislation and remits of the three existing
equality commissions. These new directives gave an added impetus to
long-standing calls to review the equality legislation in operation in
Britain, which is a complex patchwork of piecemeal legislation introduced
largely in response to previous European directives.
The principles of equal treatment and non-discrimination are at the
heart of the European Social Model and gender equality in particular has
long been recognised as one of the EU’s core objectives (see Rossilli, 2000).
The founding European Treaties include a right to non-discrimination on
the ground of sex. Various Treaty revisions subsequently advanced more
specific principle of gender equality (Bell, 2005). The EC Treaty right to
equal pay for women and men was strengthened, most notably to include
the concept of equal pay for work of equal value (EC, 1975, Art. 141(1)).
Protection for positive action was incorporated (Art. 141(4)) and a duty to
‘promote equality between men and women’ in all activities was inserted
(Art. 3(2)). The non-discrimination employment Directives issued by the
European Union following the adoption of Article 13 of the Nice Treaty
1997, focusing in particular on the EU Directives on Racial Equality and
Employment Equality in 2000 and the following community action
programme to combat discrimination, 2001–6 (Beveridge and Nott, 2002;
Hoskyns, 2000; Rees, 2002). As Jo Shaw states:
Gender equality – initially in the limited form of a guarantee of equal

pay for equal work of equal value for women and men, and subse-
quently in the form of a more wide-ranging equal treatment principle
applying to all aspects of employment and training, and most aspects
of welfare – is deeply rooted in the EC and EU Treaties, in legislation,
and in an extensive case law of the Court of Justice.
(Shaw, 2005: 1)
In the context of both the EU’s particular commitment to gender equal-

ity, and also the distinctly British focus on race equality, the Labour
206 Judith Squires
governments of the 1970s introduced equality laws designed to remedy

discrimination on the basis of both sex and race: The Equal Pay Act
1970, the Sex Discrimination Act 1975 (SDA), the Race Relations Act
1976 and the Fair Employment (Northern Ireland) Act 1976. The Equal
Opportunities Commission (EOC) and Commission for Racial Equality
(CRE) were established to uphold these laws. More recently this twin
focus on sex and race in Britain’s equality laws was augmented by a
newer focus on disability. The Disability Discrimination Act was intro-
duced in 1995 and the Disability Rights Commission (DRC) established
in 2000.
The introduction of further new equality legislation – The Employment
Equality (Sexual Orientation) Regulations 2003 and the Employment
Equality (Religion or Belief) Regulations 2003 – implement other European
Employment Directives which outlaw discrimination on grounds of sexual
orientation, religion or belief, disability and age in employment and voca-
tional training.
This piecemeal approach of using European directives to update UK
equality laws has created a complicated array of equality laws. Equality
is presently addressed by a patchwork of at least 30 Acts of Parliament,
38 Statutory Instruments, 11 Codes of Practice, 12 EC Directives, and fur-
ther complicated by the devolution statutes of 1998–9. The sheer com-
plexity of this legislative framework is itself a source of inequality. As
Julie Mellor, then chair of the EOC, argued: ‘Britain’s equality laws are in
a mess. Inconsistent and incomplete, they offer different levels of pro-
tection for different groups and none at all for others’ (Mellor, 2002).
However, the announcement of the intention to create the new
Commission came without mention of a single Equality Act. Announcing
the plans for the new Commission, Patricia Hewitt (Trade and Industry
Secretary and Minister for Women) claimed that the new CEHR would
‘give greater support and more joined-up advice to individuals, businesses
and communities to crackdown on discrimination, and promote equality
and diversity’ (Hewitt, 2003). She continued: ‘Tackling discrimination in
the twenty-first century requires a joined-up approach that puts equality
in the mainstream of concerns. As individuals, our identities are diverse,
complex and multi-layered. People don’t see themselves as solely a
woman, or black, or gay and neither should our equality organizations’.
The pragmatic motivation to create a single Equality Commission was
clearly greater than the motivation to streamline the existing equality
legislation. As Barbara Roche (then Deputy Minister for Women) stated,
when announcing the consultation: ‘We cannot have six separate com-
missions dealing with six separate strands’ (Roche, 2002). Many of those
engaged in the consultation agreed with this: with both the EOC and
CRE initially offering tentative support for the idea of a single equality
body, the DRC articulating the most anxiety about the plans (as the most
newly established and highly funded of the Commissions) and advocates
of the three ‘new strands’ welcoming the proposal with enthusiasm.
However, as the Task Force set up to establish the remit and structure of
the Commission developed its proposals, tensions and antagonisms
grew. In July 2004 the Commission for Racial Equality announced its
‘unequivocal rejection’ of the merger of the three existing commissions.
A spokesperson said: ‘The CRE isn’t in support of a Commission for
Equality and Human Rights when racial issues are at the top of the polit-
ical agenda’ (Blackstock, 2004). This suggests that the ‘equality and diver-
sity’ discourse deployed by both the EU and the British government is
meeting stiff resistance in some quarters from equality professionals
committed to a prior group discrimination discourse.
The EOC, on the other hand, appears to have embraced the ‘diversity’
agenda that underpins the proposed creation of the CEHR wholeheart-
edly, stating on its website that:
The EOC is committed to challenging discrimination in all its forms,

particularly racism, and at an institutional level. We will positively pro-
mote diversity and equality of opportunity, recognising that we are
here to serve a diverse and multi-racial society. We are committed to
the view that organisations make better decisions if they are truly rep-
resentative of the wider community. Our ambition is to understand
and respond to the needs of all women and men, which we can only
do if we are sensitive to differences of sex, race, disability, sexual orien-
tation, age and religion, and free of discrimination as an employer and
contractor.
(http://www.eoc.org.uk/cseng/abouteoc/equalityscheme.asp)
Institutionally, it is the EOC that has been most proactive in facilitating

the government’s attempt to establish the CEHR, with its equalities
remit. This signals the extent to which the issue of gender equality has
been subsumed in Britain within the wider ‘equality and diversity’ dis-
course. It is therefore particularly important to interrogate the framing
and limitations of both gender mainstreaming and ‘equality and diver-
sity’ discourses, as each represent new ways of engaging with gender
equality issues.
Mark Bell points out that a ‘patchwork of models’ of equality has
emerged in the context of EU equality law and policy (Bell, 2003: 91–110).
208 Judith Squires
However, whilst many gender theorists have viewed EU equality policies

as comprising three key phases – equal treatment, positive action and gen-
der mainstreaming (Rees, 2002: 48; Booth and Bennett, 2002) – Bell views
the patchwork as comprising three main strands: formal equality as anti-
discrimination, substantive equality as positive action, and managing
diversity (Bell, 2003: 91–110). Whilst there is agreement about the multi-
plicity of approaches to equality within the EU, some focus on gender
mainstreaming as the most recent development, others on diversity man-
agement. In fact both are probably right: both gender mainstreaming and
managing diversity have emerged as central elements of the EU equality
agenda, at more or less the same time, but apparently unconnected – both
conceptually and institutionally (see Squires, 2005 on the former; and
Shaw, 2004 on the latter).
Both the concept and practice of EU gender mainstreaming has been
extensively researched in recent years (see Hafner-Burton and Pollack,
2000; Mazey, 2000; Verloo, 2001; Beveridge and Nott, 2002; Booth and
Bennett, 2002; Rees, 2002; Rubery, 2002; Jacquot, 2003; Lombardo, 2003;
Walby 2004. See also Meier, in this volume). However, as Jo Shaw rightly
notes, ‘the concept of diversity has played generally a much more hidden
(and less intensively studied) role in the development of EU law’ (Shaw,
2005: 2). As a result, there is little sustained reflection on what ‘diversity
mainstreaming’ might entail (though see Hankivsky, 2005; Squires, 2005;
and Shaw, 2005). More generally, there has been surprisingly little analy-
sis of the derivation and implications of the ‘diversity management’
emerging from the EU.
Good governance
Both gender mainstreaming and diversity managements might perhaps

be understood as two elements in a new form of governance, which is
emerging as an institutional response to globalisation. Lewis and Giullari,
for instance, suggest that the Open Method of Co-ordination is a ‘new
form of governance’ that emerges in parallel with a linkage of economic
and social policy (Lewis and Giullari, 2005: 80). Within this mode of gov-
ernance hard instruments, such as Directives, are replaced by common
objectives and performance indicators.
This Open Method of Co-ordination shares many core features with
both gender mainstreaming and with New Labour’s commitment to
‘joined-up government’. All are emergent forms of governance that are
associated with the horizontal co-ordination of policy making in the name
of efficiency, and all are presented as part of the process of modernisation.
Significantly, gender mainstreaming has been most successful in

Whitehall where it has been depicted as a part of the government’s
wider commitment to ‘modernisation’. Within the New Labour lexicon, as
Alan Finlayson has shown, ‘modernisation’ ‘is an “up” word, that makes
things sound exciting, progressive and positive … [Its] usage helps generate
an appearance of structured and unified thinking … It helps to render “nat-
ural” and un-contestable that which is not necessarily so’ (Finlayson: 2003:
67). It is used most frequently in relation to public sector reform, ushering
in what Stuart Hall has called ‘the new managerialism’ (Hall, 2003: 16).
As part of its modernising agenda, on its election to office in May 1997,
Labour promised to reform the machinery of government. A central fea-
ture of this modernisation, the administration argued, was the introduc-
tion of ‘joined-up government’. This notion was based on the conclusion
that too often policy initiatives were constrained by departmental bound-
aries. The way that individual departments interpreted responsibilities
meant that proposals were not assessed in their full context. Richards and
Smith conclude: ‘The notion is that the policy arena has become a more
crowded environment with numerous actors competing for political
space, so the government’s ability to maintain some semblance of control
has been curtailed’ (Richards and Smith, 2001: 6, 239–50). Whilst prob-
lems frequently require more than one department in the design of any
solution, the departmental system is ‘administratively and culturally ill-
equipped to reconcile conflicting departmental objectives or encourage
cross-cutting policy formation’ (Flinders, 2002). As Tony Blair noted:
‘Government is organised vertically, with departments based on the func-
tion they perform … But people’s problems are rarely so neat’ (Blair,
speech ‘Modernising Public Services’, 26 January 1999). He suggested that
joined-up government, side-stepping departmental boundaries (and the
differing norms), would overcome the problem (Taylor, 2000: 55–7). One
means by which Labour proposed to deliver joined up government was
through the establishment of cross-cutting departmental units, including
the Women’s Unit. The success of the Unit in its pursuit of mainstreaming
is therefore bound up with the success of the broader project of
modernising government and pursuing good governance.
Similarly the government has depicted the establishment of the CEHR
as a part of its wider modernisation process. The Government states that
it want ‘the CEHR to contribute to building an inclusive, fair and pros-
perous society where there is respect for the dignity and worth of every
individual, and where no-one is held back by prejudice and discrimin-
ation’. It has been concerned to find an institutional form that will allow
the CEHR ‘to work in an integrated way across the equality and human
210 Judith Squires
rights spectrum’, taking an evidence-based approach (DTI, 2004). As

with the WEU, the aim is to establish an institutional framework for a
form of governance that emphasises horizontal integration, perform-
ance indicators and auditing.
Good for business
Another shared feature of gender mainstreaming and diversity manage-

ment has been the extent to which they are both justified with refer-
ences to a ‘business case’ rather than one of egalitarian citizenship.
For instance, the ‘Gender Impact Assessment’ document used in the
government’s gender mainstreaming practices is framed by a discussion
of ‘Inclusive Policy Making’, which is depicted as part of the govern-
ment’s programme of public service reform, the ultimate goal of which is
to put the consumer first. Here mainstreaming becomes a way of think-
ing about users as distinct groups with differing needs, characteristics and
behaviours, which matters if one is concerned about delivering customer
and user satisfaction. In other words, the ‘business case’ for mainstream-
ing is the case most frequently offered for why equality matters. As the
Department for Trade and Industry states on its website:
Unfair discrimination in employment is wrong. It is bad for the indi-

viduals who are denied jobs and access to vocational training, who suf-
fer victimisation or harassment, because of prejudice. It is bad for the
businesses which are denying themselves access to the widest pool of
talent and not sharing in the benefits – such as increased motivation,
lower turnover of staff, and access to wider markets – that a diverse
workforce and effective equality policies can bring.
(http://www.dti.gov.uk)
Meanwhile, Barbara Roche told an Institute for Public Policy Research

conference that equality and diversity ‘are good for business too’ (Roche,
15 May 2002). A couple of months later she asserted: ‘The benefits of real-
ising this [equality] agenda are enormous, not just for individuals but for
Britain as a whole. And the business for diversity is becoming harder to
resist as a diverse workforce [brought forward by equality] gives employ-
ers a competitive edge’ (Roche, 15 July 2002).
At an economic summit held in May 2003, Patricia Hewitt argued that
there is a business case for companies to pursue gender equality in the
workplace. The debate focussed on the impact of women’s participation in
the labour force on the UK’s productivity. Subsequently the Department
of Trade and Industry (DTI) produced a leaflet entitled ‘The Business Case
for Diversity and Equality’ in which it put forward the case for diversity in
terms of the need for business to respond to the fact of increasingly com-
petitive and mobile labour markets by treating its employees fairly to
retain their services, and in terms of the potential for businesses to ‘iden-
tify more closely with its customer base’ by employing more women,
more older people and encouraging a wider ethnic mix (DTI, 2004). In
a country with a diverse population, in which ‘every single person is a
potential business customer’ it stands to reason ‘that businesses with a
diverse workforce are likely … to provide a more tailored service to meet
individual needs.’ They are also likely to improve recruitment and reten-
tion, staff morale and performance (DTI, 2004: 2). All of which suggests
that gender equality in Britain is now primarily conceived in terms of the
extent to which the pursuit of ‘equality and diversity’ will facilitate social
inclusion in paid employment.
Even recent research into domestic violence, commissioned by the
WEU and written by notable British feminist academic, is approached in
terms of its economic consequences. As the WEU ‘Interim Findings’
document states:
Two women each week are killed by a partner or former partner, a

total of over 100 deaths each year. The cost of the domestic homicide
of adult women is an estimated £112 million each year … Domestic
violence is a complex social problem with devastating consequences.
It drains the resources of public and voluntary services and of
employers and causes pain and distress to women and their families.
The purpose of providing a figure for the ‘cost’ of domestic violence
is to more clearly show its importance, by finding a way of translat-
ing these hardships into a common unit of account.
(WEU, 2003)
That the common unit of account is financial, is of course not surprising.

Analyses of New Labour’s approach to equality have focused attention
on the refusal to overtly address economic inequalities. It has focused
instead on ‘social inclusion’, which has generally amounted to an injunc-
tion to all citizens to become disciplined, productive, paid workers (see
Levitas, 1997; Armstrong, 2003). Social inclusion comes to be perceived
in this New Labour discourse as both the right and the responsibility to
develop marketable skills to perform paid work. As such it becomes a part
of the project of creating and maintaining a ‘flexible’ employment
market (Armstrong, 2003: 412). Whilst individuals are enjoined to pursue
212 Judith Squires
economic opportunities as an answer to social exclusion, structural

inequalities are left un-interrogated (Levitas, 1997: 7). The meritocratic
system generated by a commitment to this conception of equality as
inclusion in the labour market is compatible with, and indeed appears to
generate, a society with huge disparities in income and status in which a
talented elite dominates whilst the disadvantaged are deemed to have
failed as a result of their own personal deficiencies.
A second significant critique of this framing of equality policies as inclu-
sion in paid employment is to be found in feminist concerns about the
emergence of the adult work model, replacing the previously dominant
male breadwinner model, in which men took primary responsibility for
paid work whilst women were assumed to be responsible for unpaid care
work (Lewis, 2001). The rapid increase in female labour market participa-
tion has led the government to assume that care work will increasingly
move to the formal, paid sector (Lewis and Giullari, 2005: 77). This
extends the logic of the market into a sphere previously governed by an
informal care logic, which is a cause of anxiety for many commentators
(see Duncan and Edwards, 1999).
Employment growth is also seen as a key social policy goal at the EU
level. Here too participation in the paid labour market is viewed as a
means of promoting both social inclusion and economic competitiveness
(Lewis and Giullari, 2005: 79). The 1993 White Paper of the Commission
on growth and competitiveness made precisely this case, and identified
the care sector as a source of new jobs. This approach assumes a direct
linkage between economic and social policy, whereby ‘social policies are
justified in terms of the social investment that is necessary to sustain com-
petition and growth’ (Lewis and Giullari, 2005: 80).
This suggests that at both a European and British level the pursuit of
gender equality is increasingly framed by a strategy of social inclusion,
which is itself viewed as a means to a greater economic productivity. In
this way, gender equality policies are to be viewed in the context of a
neo-liberal trade agenda, which seeks to establish frames for trade and
investment at the regional and national level in the context of the
global political economy (Gamble and Payne, 1996).
It is, of course, the case that a concern with multiple equality ‘strands’
resonates with the theoretical work on ‘intersectionality’ articulated
most clearly by black feminists (see Hill Collins, 1990), and with wider
cultural and political changes in the 1990s, including the expansion of
gay and lesbian politics, the growth of the disability rights movement,
and the increasing tensions surrounding multiculturalism and anti-
racism (see Cooper, 2004). In this context ‘diversity politics’ is associated
with a radical democratic political agenda, which seeks to engage with
the ‘claims of culture’ and the ‘strange multiplicity’ of our global era (see
Benhabib, 2002; Young, 2000). And yet, it is also worth noting that
‘managing diversity’ strategies were also promoted by business sector
human resource managers in the United States from the mid 1990s (see
Kandola and Fullerton, 1998; Kirton and Greene, 2000; Harvard Business
Review, 2001). Diversity initiatives are widely argued amongst human
resource managers in the business sector to improve the quality of
organisations’ workforces and act as a catalyst for a better return on
companies’ investment in human capital. They are also argued to help
businesses to capitalise on new markets, attract the best and the bright-
est employees, increase creativity, and keep the organisation flexible (see
Cartwright, 2001). The 1998 Society for Human Resource Management
‘Survey of Diversity Initiatives’ found that 84 per cent of human
resource professionals at Fortune 500 companies said that their top-level
executives thought ‘diversity management’ to be important, reflecting
the current corporate emphasis on diversity policies as an important
complement to equal opportunity policies (Price, 2003). In this context
‘diversity management’ is associated not with radical democratic politics,
but with the corporate pursuit of economic productivity.
Conclusion
In these ways the early conception of gender equality, manifest in both

the EU and in Britain, as equal treatment between men and women pri-
marily within the labour market required by hard instruments such as
directives and laws, now seems to be more complex. It now appears to
embrace the possibilities of equal treatment, positive action and/or
gender mainstreaming strategies; it is conceived at times as focused
on equal participation in the labour market, at other times as entailing
equal participation in decision-making and public life more widely; and
it also appears to straddle both the distinct pursuit of gender equality,
and the more inclusive pursuit of ‘equality and diversity’, in which gen-
der is but one strand amongst many. Amongst the complexity of these
developments, two key features emerge: the pursuit of equality is bound
up with modernisation and the practices of a new form of governance;
and the conceptual framing of equality is shifting from a concern with
egalitarian citizenship to one of economic productivity.
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Index
acquis communautaire 47 citizen vs. inhabitant 38

Algeria 17 citizenship
Amsterdam Treaty 39–40, 46, 48, 166 as agency 43
asylum seekers 40 and democratisation 20
Austria 57 denied 40
entitlement to 16, 19, 20
Balkan ‘Other’ 108 European 4, 15, 39–40, 46–9
Barendt, R. 70 as exclusionary 19–20, 40, 42
Belgium 44 gendered 3, 40–4
gender mainstreaming in 193–4 historical models 3
Blair, T. 202, 209 postcolonial 20
Bohley, B. 74 post-national 47
Borchorst, A. 89–90 as rights, belonging and
borders, borderless world 23 participation 38
boundaries 4 social 3
Bourdieu, P. 107, 111, 120 and social relations 19
Bretton Woods institutions 4, 24, 25 terminology 37–9
Brundtland, G. H. 93 women’s claim to 18, 40, 42–3
Bulgaria 61, 107–24 civic identity 8
civic education in 8, 122 civil law 40, 49n
democratisation 111–15 civil rights
feminism in 121 activism 43
National Revival 113, 119 entitlement to 38
representation of family life in civil society 59–62
113–14, 118–19 as democratic space 5
representation of women in engagement in 5
textbooks 112–20 gap 79–80
rewriting history textbooks in and gender mainstreaming 67ff
108–9, 113–14, 114–20 gendered order 41
xenophobia in 116 idealisation of 79
networking 15
capitalism trap 61, 79
and gender equality 57–9 communitarianism 54
and patriarchy 62 contract, freedom of 39, 50n
Centre for Democracy and Convention on the Elimination of All
Reconciliation in South East Forms of Racial Discrimination
Europe 108 98
childcare 77 Convention on the Elimination of all
loss of 78 Forms of Discrimination against
as unpaid labour 79 Women viii
see also women’s sphere Convention on the Rights of the
Chile, women’s movement in 17 Child 98
China 17 Croatia 109
217
218 Index
Croce, B. 110 gender gap 69

cultural capital 111 NGOs in 60–1
cultural rights 6, 7 rejection of feminism in 58
cultural values and political unemployment in 57–8
participation 8 women in 55–7
culture see also European Union, accession
of equals 86 to; and under individual country
patriarchal 121 names
traditional 54 economic policy, gender-sensitised 22
Czech Republic 71 education 8
gendering 109
Daskalova, K. 8, 107–24 role of 111
decision-making 30–1 system, socialisation of 107
women and 199–202 see also Bulgaria
Defrenne judgment 44–5 egalitarianism 68
democracy Einhorn, B. 5–6, 61, 67–82
deliberative 30–1 emancipated subject 39
democratic deficit 23, 47 empowerment 5, 74, 157
democratic governance 24 equal opportunities 182, 200
democratisation 21 equal pay, EU legislation 44–5
gendered 3 equality
and political participation 15 and diversity 204–8
Denmark 89–90 postcolonial 20
descriptive representation 128 religious exemptions to 96–8
Diamantopoulou, A. 163, 165 equality politics 31
difference 74, 81n ethical trading initiatives 22
gender-based 17 ethnic Other 89, 116
and power 54 see also Balkan ‘Other’
rhetoric of 93 ethnocentricity
among women 27 of education system 108
discrimination 69 of welfare state 173n
gender-based viii Europe, as community of law 4
indirect 45 European Commission 26
structural 90 Directives on equality 45, 205
disengagement 26, 28 gender equality report 88
diversity 11, 204–5 information campaign on diversity
business case for 210–11 204
diversity management 11 European (Draft) Constitution 4, 46–9
divorce viii equality provisions 48–9
domestic violence 9–10, 58, 69, 74, European Convention of Human
154ff Rights 73, 98, 170
donors, international 6 European Court of Human Rights
dress codes viii, 118 73, 171
Duhacek, D. 75 European Court of Justice 44, 45
European Parliament, women’s
Eastern Europe representation in 48
economic transition 2, 8, 58, 67ff, European Policy Action Centre on
74, 80n Violence against Women 162
Index 219
European Social Model 205 cross-party alliances 138

European Union 44, 73 Day Care Act 141
accession to 8, expectations of 59 domestic violence; discourse 158,
Charter of Fundamental Rights incidence of 169–70
47, 167 Equality Act 144
Daphne Initiative/programme 165 Equality Ombudsman 146
enlargement 2, 4, 8, 70, 72 family violence 158–9, 168
Framework Strategy on Gender Gender Equality Unit 146
Equality 167 Labour Market Subsidy Act 14
gender equality policies 154 legal procedures 136–7
integration, dynamics of 47 party feminism 9, 137
women’s rights in 44–6 Quota Law 146
European Women’s Lobby 47, 162, secularisation 136
164–5 strategic partnerships 146
Europeanisation 155–6 as woman-friendly welfare state
exclusion 3, 8, 17, 29, 40 140, 155, 160
women’s movements 137
Fair Employment (Northern Ireland) women’s political representation
Act 206 135, 136
family 40 women’s refuges 161
dynamics model 159 Fodor, E. 57
life, representation of 113 folk psychology 114–15
reconciliation with professional France, parité debate 90
life 45 franchise, exclusion from 43
violence 158–9; see also domestic Fraser, N. 73
violence; violence against women free trade agreements 25
family law 40, 41, 50n
Febvre, L. 110 G7 26
feminism gender budget groups 22
anarchist 4 gender equality 4, 9, 73–4, 86ff,
diversity 158 181–2
indigenous 59 and domestic violence 156–68
NGOisation of 6, 61, 79 duty to yield 86, 87, 94–6
Northern/Southern difference 54 and EU accession 8
post-socialist 4 false rhetoric of 2
rejection of in Eastern Europe 58 implantation of 179ff
theorising 16–22 in Nordic states 7, 8
third world 53–4 objectives 184
Western 5, 55, hostility to 54, and profitability 94
58–9, 75, universalising nature religious exemptions to 96–8
of 55 strategies for 76–80
Ferro, M. 110 travel metaphor 86, 88–90
Fichte, J. G. 40–1, 42 utility of 9, 93–4
Finland 9–10, 90, 127, 154–5 gender essence 94
abortion policy 132, 133 gender harmony, myth of 121
Council for Equality between Men gender hegemony 107
and Women 146, gender inequality 187
Violence subcommittee 160 gender justice 9
220 Index
gender mainstreaming 2–3, 10, integration 37

24–5, 26–7, 71, 76–7, 80, 81n, international aid 6, 61
179–96, 202–4 see also non-governmental
defined 181 organisations
impact 183 International Bill of Rights of Women
implementation 185–90 viii
revolutionary potential 182–3 International Monetary Fund 60
theory/practice gap 190–5 international relations 15
gender parallels 121 Iran 16
gender pay gap 74
gender power order 90 justice as fairness 201
gender regimes 192
Gerhard, U. 3–4, 37–50 Kant, I. 38, 39
Germany 71 Kantola, J. 9, 154–74
gender mainstreaming in 191 KARAT coalition 70, 73, 79–80
global governance
and democratisation 23 labour market
feminist approaches to 24–5 access to 77
gender in 25 participation 212
global institutions 23–4 Lacapra, D. 110
global sisterhood 54 Latvia 61
globalisation 3–4, 15, 19, 22–6, 68, left-wing power and women’s
69–70 policy success 9, 137, 141,
governance 11, 73, 208–10 144
Gradin, A. 163, 164 liberal democracy 5, 6, 60
gradualism 88 liberal feminism 4, 56, 57
Guatemala 17, 20 liberty, individual 68
gynocracy 116 Lister, R. 18, 39
Lithuania 71
love
Hellsten, S. 4–5, 6, 53–63
as mutual but unequal 41
Hernes, H. 89, 93
and state theory 42
Herstal, equal pay strike 44
women as representative of 40
Hewitt, P. 206, 210
history writing, purpose of 110
Maastricht Treaty 39
see also Bulgaria
male dominance, institutional 91–2,
Holli, A.-M. 9, 89, 90, 127–49
107
human agency 39
marginalisation 54, 69
human rights 6, 7, 16, 73
marriage viii, 41
discourse viii, 73, 170
arranged 118
Hungary 77
marital contract 40, 41
Huntington, S. 16
marital rape 161
Marx, K. 16
identity politics 121 Mason, A. 203–4
immigration viii, 15 matriarchate 116
inclusion 3, 9, 18, 127 Meier P. 10, 179–96
incrementalism 88 memory, school texts as functional
Indian national movement 16 sites of 111, 125n
individualism 54 Mexico 20
Index 221
migration 23 parity democracy 196n

and citizenship 40 participation, effectiveness 28–32
and EU enlargement 72 Patemen, C. 40
and workers’ rights 74 paternalism 57
modernisation 209 patriarchy 6
motherhood 17, 77 and capitalism 60
‘organised’ 43 and domination 43
and state oppression 21
NAFTA 25 Phillips, A. 86
national psychology 114 Poland 70–1, 72, 77
nation state 8, 22, 73 Poland Women’s Rights Centre 76
emergence of 39 policy
nationality and 39 implementation 189
relationship with the EU 15 objectives 186
natural law 40 outcomes 189
Network for European Women’s style 185
Rights 1, 55 policy-making 9
Nice Treaty 205 political associations, women
non-governmental organisations prevented from joining 42
(NGOS) 6, 21, 25, 26–7, political institutions
30, 59 quotas in 21
in Eastern Europe 60–1 social movements as 29–30
international donors 61 political obligations 38, 39
as politically neutral 6 political participation viii, 3, 15–18
professionalisation of 79 effectiveness 28–32, 78
as political engagement 5 and globalisation 22–6
in transitional societies 59–62 as language of inclusion/exclusion
Nora, P. 111, 121, 123n 16
Nordic states 6–7, 89, 154 as stabilising 26–8
Norway 86, 93 sustainability 30
Accelerated Christian Education political representation 81, 132,
scheme 97–8 133
CEDAW, and Norwegian law and policy success 134–5
98–9 political rights, entitlement to 38
equal pay in 95 population control 27
Gender Equality Act 95–8 positive action 3, 182, 199
Human Rights Act 98–9 poverty, feminisation of 69
Power and Democracy Study 91 power
quota policies 92, 93 hierarchies, cooption of women’s
Norwegian Equality Centre 93 group to 27
nuclear family discourse 158 paradigms 27–8
NYTKIS (Coalition of Finnish property rights 39
Women’s Associations for Joint prostitution 58, 132, 164
Action) 138 public appointments, regulation of 93
public health 165–6
occupational segregation 74 public law 40
Open Method of Co-ordination 208 public vs. private sphere distinction
Ostrogorskij 42–3 17–18, 38, 40, 158
Otherness 69 democratisation of 18, 24
222 Index
public policy social inclusion 211–12

impact of women’s movements on social inequality 187
129–30, 132–5 social justice 5, 6, 11, 24, 54, 68, 69
implementation 185–90 gender-neutral 7
social movements 29
quotas 3, 21, 29, 76, 77, 93, 200 social order 42
twinning and zipping 201 social science, objectivity of 110
social security 72
Rai, S. 3, 15–36, 73 socialism as woman-friendly 57
refugee policies viii, 40 socialist feminism 54, 60
Regulska, J. 70, 73 society, women-friendly 89
religious freedom 86, 96–8 Socrates 16
and exemption from equality soft law 166, 167, 168
legislation 86 soft policy 155, 194
religious fundamentalism 23 South Africa 20
reproductive rights viii, 69 Squires, J. 10, 199–213
rights state feminism 89, 129
vs. obligations 38 state
privatisation of 94–5 accountability of 22
RNGS (Research Network on Gender, changing role of 21–2
Politics and the State), analysis of discourse, autonomy from state 157
the impact of women’s formation 20
movements 127–47 retreat of 69
cross-cultural analysis 132–5 strategic framing 192–3
Finnish analysis 135–47; see also strategic partnerships 146
Finland structural adjustment programmes
typologies 129–31 23, 30
Roche, B. 206, 210 substantive representation 128
Romania 75–6, 109 suffragette movement 16
Rousseau, J.-J. 16, 41–2 supranational institutions 74
Russia 20 Sweden 90, 154
Schlegel, F. 41 Theorin, M.-B. 163–4

Schleiermacher, F. 41 third world, feminism in 54
Scotland, Scottish National Party trafficking 58, 69, 164
201 STOP programme 167
second wave feminism transnational regulatory bodies 78
and barriers to women 7
in Finland 137 UK
negative image of 112 all-women shortlist 200, 201
SEWA 21 CEHR 204–5
sexual contract 40, 42 Commission for Racial Equality
sexual division of labour 39, 42, 114 207
sexual harassment 77 devolution 201
sexual violence, continuum of 157 domestic violence 156–7,
Skjeie, H. 6, 86–102 incidence of 169
Slovenia 61 equal opportunities 199
social control 16 Equal Opportunities Commission
social entitlement 57, 77 206–7
Index 223
Equal Pay Act 206 WAVE 162–3

Equality Act 206 Weber, M. 110
Equality and Diversity Forum 204 WEDO 25
Equality and Institutions Review welfare state 6
204 downsizing 6
female labour market participation woman-friendly 155, 160
212 well-being 23
gender equality 155 WID 27
Gender Impact Assessment 210 WIEGO 21
gender mainstreaming as official women policy agency activities 130
policy 202 women
Human Rights Act 171 absence from texts 112
human rights law 170 historical representation of 8
joined-up government 209 involvement in civil society 61
Labour Party 200, 201–2; representation of in texts 110
commitment to equality 200 role of 107
as meritocracy 200, 212 subordination of 40, 41
political representation of women’s sphere 113–14; see also
women in 200 public vs. private sphere
Race Relations Act 206 distinction
Sex Discrimination Act 206 see also childcare; citizenship,
Sex Discrimination (Election denied; citizenship, women’s
Candidates) Bill 201 claim to; difference among
Women and Equality Unit 203 women; domestic violence;
women’s refuge network 160 Eastern Europe, women in;
women MPs 201–2 feminism; love; marriage;
Women’s Aid 156–7 motherhood; political
women’s refuges 160 participation; second wave
women’s rights 200 feminism; sexual contract; sexual
Women’s Unit 202–3 division of labour
United Nations 21, 24, 25 Women’s Eyes on the Bank 25
UN Declaration of Human Rights women’s interests 128
127 women’s movement 9
universal domestic violence discourse impact on policy-making see RNGS
156–7, 163–4, 168, 170 women’s rights viii, 4, 5, 164
utility rhetoric 94 activism 43
in post-Soviet Europe 53ff
victim-blame 157 World Bank 27, 60
Vienna World Conference on Human funding to NGOs 29–30
Rights viii lobbying 29–30
violence against women viii poverty assessments 27
as breach of human rights 164, women’s engagement with 29
167 world communities 23
as public health issue 165–6 World Conference of Women
Beijing 76, 79, 179
Wales, Plaid Cymru 201 Mexico 45
Washington Consensus 81n world feminism 54, 55

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Women’s Citizenship and

Sirkku K. Hellsten, Anne Maria Holli and Krassimira Daskalova (editors)

Christien L. van den Anker and Jeroen Doomernik (editors)

Women’s Rights in Europe Series

Customer Services Department, Macmillan Distribution Ltd, Houndmills,

Anne Maria Holli

List of Tables vii

Notes on the Contributors xii

Part I Theoretical Feminist Perspectives 13

2. European Citizenship: A Political Opportunity for Women? 37

3. Can Feminism Survive Capitalism? Challenges Feminist

4. Citizenship, Civil Society and Gender Mainstreaming:

5. ‘Gender Equality’: On Travel Metaphors and Duties to Yield 86

Part II Applying New Insights to Old Problems 105

7. Strong Together? A Comparative Study of the Impact of

9. Implementing Gender Equality: Gender Mainstreaming

10. Good Governance and Good for Business Too?

7.1 Typology for movement impact/state response 129

This series is a timely initiative to counter the mounting opposition and

increased attention from researchers, NGOs and policy-makers through-

This series is the result of the involvement of a large number of people

Krassimira Daskalova teaches Modern European Cultural History at the

Barbara Einhorn is Reader in Gender Studies and Director of Graduate

Ute Gerhard is Emeritus Professor of Sociology and Director of the

Sirkku K. Hellsten is Reader in Development Ethics and the Director of

Anne Maria Holli is Researcher (Academy of Finland) at the Department

Petra Meier is research fellow at the Politics Department of the Vrije

Francophonie, with Bérengère Marques-Pereira, Academia-Bruylant, 2005;

Shirin M. Rai is Professor of Politics and International Studies at the

Hege Skjeie is Associate Professor at the Department of Political Science,

Judith Squires is Professor of Political Theory at the University of Bristol.

ACAS Advisory, Conciliation and Arbitration Service

WHO World Health Organisation

This book is part of a four-volume series based on the findings of a

1. Equality discourses and the importance of a normative debate.

5. Accountability and implementation strategies.

European policies on gender equality; quotas are the subject of highly

Hellsten argues that the various Western formulations of feminism, for

Sweden, Norway, Iceland and Denmark), there has been a tendency to

the transition of Central and Eastern Europe to post-communism, the

civil society in the future, women should enter The His(s)tory. As

of European women’s rights and full citizenship. In the field of domes-

1. U. Gerhard, ‘Gendered Citizenship: a Model for European Citizenship’. Paper

In an ‘era of globalisation’ political participation and citizenship are

against the state – freedom of speech, movement, association, what we

Feminist theorising participation: movements, citizenship

Feminist theorising has largely supported the importance of the partici-

human rights in Chile, Guatemala and other states, where violence as a

modern citizenship is inserted into a social field … [where] freedom,

Citizenship is thus embedded in the dominant social relations in particu-

two ways: first, by denying national citizenship to individuals it can

state as part of the problem of patriarchal oppression of women rather

organise differently. While the state continues to be a central focus of

Globalisation and the terms of political participation

effectiveness of global institutions, especially the UN system and the

many as the dynamic, creative response to the forces of economic con-

Political participation: a new stabilising ethic?

According to Clark (2002) the following reasons contributed to the NGO

a strategy for making women’s as well as men’s concerns and experi-

Assessing mainstreaming of gender agendas, Jahan has pointed out that

approach which would lead to a fundamental change in the mainstream

institutions of power function are minimal. Multilateral institutions as

Indicators of participatory effectiveness