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A failure of Europeanisation? : A comparative case study of parental leave policy mobility in the European Union

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A failure of Europeanisation?

A comparative case study of parental leave

policy mobility in the European Union

Author: Sally Grahn

One-year Political Science MA programme in Global Politics and Societal Change Dept. of Global Political Studies

Course: Political Science Thesis ST632L (15 credits) Spring term; 2020

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Abstract

Parental leave policies have been shown to play a significant role in enhancing gender equality. The European Union has recognised this and has issued a Directive to its Member States, in order to instigate parental leave policy reform. However, not all Member States have sought to implement this. This thesis addresses this problem and seeks to answer the following research question: Why have progressive parental leave policies failed to transfer across the European Union? In doing so, this study also aims to explore the limits of Europeanisation.

The research question has been addressed through a qualitative comparative case study of four European Union Member States: Sweden, Denmark, Hungary and Greece. These states have been chosen on the basis of Most Different System Design. The thesis deploys a theoretical framework based upon concepts of Europeanisation and policy mobility and draws particularly on the work of Stone’s four core concepts of policy mobility: Diffusion, Transfer, Convergence, Translation (Stone, 2012).

The key factors that have been identified in this study as restricting the potential of a policy to transfer are: institutional surroundings, shared beliefs and norms, internal political dynamics and a lack of force/action from the European Union. These differences have acted to constrain the transferability of progressive parental leave policy across the European Union and therefore the process of Europeanisation in this area.

Keywords: Policy mobility, Diffusion, Transfer, Convergence, Translation, European

Union, Europeanisation, Progressive Parental Leave, Sweden, Denmark, Hungary, Greece, Welfare state regime, Esping-Andersen.

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Table of contents

1. Introduction ...1

1.1 Research problem ...3

1.2 Aim and research question ...3

1.3 Relevance to the field of Global Politics and Societal Change ...4

1.4 Structure ...6

2. Contextualising parental leave within the role of the welfare state ...7

2.1 Summary of the role of the welfare state ... 10

3. Theoretical framework ... 11

3.1 Europeanisation ... 11

3.1.1 Policy transfer from the European Union to the Member States ... 12

3.2 Policy Transfer / Mobility ... 14

3.2.1 Diffusion ... 15

3.2.2 Transfer ... 16

3.2.3 Convergence ... 16

3.2.4 Translation ... 17

3.3 Deeming a policy transfer as a success or failure? ... 18

3.4 Summary of the theoretical framework ... 20

4. Method and material ... 21

4.1 Why is this method used? ... 21

4.2 How is the research designed? ... 22

4.3 Material ... 23

4.3.1. What material is used in this thesis? ... 23

4.3.2. How was the material collected and analysed? ... 24

4.4 Limitations and discussion ... 25

5. Result and analysis ... 27

5.1 Factors that have constrained Europeanisation and Policy Transfer ... 28

6. Discussion ... 32

7. Conclusion ... 34

7.1 Contribution to the field of Global Politics and broader societal concerns and suggestions for further research ... 34

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1. Introduction

"No country can ever truly flourish if it stifles the potential of its women and deprives itself of the contributions of half its citizens."

– Michelle Obama, At the Summit of the Mandela Washington Fellowship for Young African Leaders 2014

In recent years, as Member States of the European Union have become continually more entwined into the Union polity over time, the study of Europeanisation has grown (Carpenter 2020). Europeanisation has been defined as: ‘the interplay between actors and institutions on the European and the city level, which leads to changes in local politics, policies, institutions, arrangements, discourse, actors’ preferences, values, norms and belief systems on both levels’ (Hamedinger & Wolffhardt 2010: 28). Thus, Europeanisation is the process where Member States progress to adopt rules, policies and/or programmes shaped by the European Union (Schimmelfennig & Sedelmeier 2005).

One of the ways in which the European Union is operating in order to influence and shape policies in the Union is by issuing directives. One of these directives was issued on the 8th of March 2010. The Council of the European Union issued a Directive

regarding a framework agreement on parental leave. The second paragraph of clause two of the directive states:

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The leave shall be granted for at least a period of four months and, to promote equal opportunities and equal treatment between men and women, should, in principle, be provided on a non-transferable basis. To encourage a more equal take-up of leave by both parents, at least one of the four months shall be provided on a non-transferable basis. The modalities of application of the non-transferable period shall be set down at national level through legislation and/or collective agreements taking into account existing leave arrangements in the Member States (Council of the European Union, Directive 2010/18/EU).

However, not all countries in the European Union have implemented this progressive part of the parental leave policy. The term progressive in this thesis is used because of the underlying purpose of this clause, which has been introduced in order to bring with it a more gender equal balance in the take/up of parental leave. This thesis aims to answer the question of why this policy has failed to transfer across the European Union and what this reveals about the process of Europeanisation

In order to understand why this has not yet been implemented across the Member States of the European Union, this thesis assesses parental leave policies of four Member States: Sweden, Denmark, Greece and Hungary. These four states have been chosen based on the construction of most different system design; the choice was particularly informed by these countries contrasting positions in the Gender Inequality Index, in which Sweden and Denmark are ranked as the top two countries in the European Union and Hungary and Greece are ranked as the bottom two (European Institute for Gender Equality, 2019) To answer the research question, this thesis is carrying out a comparative case study, utilising social scientific literature, news sources, and other relevant documents, in order to understand why progressive parental leave policies have failed to transfer across the European Union. Through this comparative case study, the thesis also seeks understand the process, and contextualise the limits, of Europeanisation.

The results of the study suggest that the reasons for this failure are deeply rooted in diverse attitudes towards social policy and the role of the welfare regimes. Furthermore, these differences demonstrate the social and cultural limits and restrictions of policy transfer and the process of Europeanisation.

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1.1 Research problem

As outlined above, the European Union has stated, via a Council Directive, that parental leave should be granted for a minimum of four months and that at least one of these four months should be non-transferable. The purpose of this is to encourage a more equal take-up of leave by both parents. Despite this, not all countries in the European Union provide this to their citizens. Thus, while all member states should be responding to the pressure that the European Union is placing in this area, they appear not to be.

1.2 Aim and research question

The aim of this thesis is to investigate why progressive parental leave policies have not been implemented across the European Union, and what this can tell us about the limits of policy mobility and the process of Europeanisation. This is examined through a comparative case study of four member states in the European Union: Sweden, Denmark, Greece and Hungary.

The research question of this thesis is as follows:

● Why have progressive parental leave policies failed to transfer across the European Union?

To answer the research question, this thesis is conducting a comparative case study in order to investigate the different factors which can have restricted this policy from transferring across the European Union.

To aid in the understanding of the process of policy transfer, this thesis constructs an analytical framework based on existing research on policy transfer by Dolowitz and Marsh (2000), Stone (2012) and Begley et al (2019). The theoretical framework deploys four core concepts in order to explain how policies can transfer. These are: diffusion, transfer, convergence and translation. These four concepts will guide us in understanding how and/or why policies transfer, and from this we can seek to better understand why certain policies may fail to transfer, thus leading us towards an answer to the research question.

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1.3 Relevance to the field of Global Politics and Societal Change

This thesis is attempting to answer the question of why progressive parental leave policies have failed to transfer across the European Union. In doing so, it aims to provide an insight into the process, and potential limits of, Europeanisation. The works examines parental leave policies in the context of global governance and connects to the field of global politics by studying both national and transnational parental leave policies and laws through the lens of policy mobility.

On the European level, the European Union has recognised the importance of the reconciliation of paid work, care and equal opportunities and responsibilities for parental leave between men and women since the 1990s. By encouraging an increase in the take-up of family responsibilities among men (European Council Resolution, 2000), the European Union is also encouraging women’s employment and participation in the labour market (Knijn & Smit, 2009:497-498). Thus, the Directive that this thesis is focused on appears to show an attempt by the Council of the European Union to harmonise parental leave policies across the union in order to promote gender equality in its Member States. By establishing the European Pillar of Social Rights, the European Commission wants to create a more socially inclusive and gender equal Europe. One of the initiatives launched under the Pillar is called ‘New Start’ and its aim is to make it realistic and possible for parents to balance their family and work life as well as encouraging an equal uptake of parental leave between parents. The New Start initiative attempts to modernise the existing European Union legal framework by establishing new and/or higher minimum standards for parental and paternity leave. So, progressive parental leave policies are vital on the global political agenda, because they exemplify one of the ways in which we can achieve gender equality on the global scale. Ekberg et al. (2013) consider the family benefit system to be one of the cornerstones of the modern welfare state. Upon their introduction, the provisions of the family benefit system were intended to both improve children’s health and increase the fertility rate. Even though the authors argue that empirical evidence for this is limited, there seems to be support for the view that the mechanisms provided through the family benefit system, such as maternity or parental leave, have indeed helped to achieve the goals of improving children’s health and an increased in fertility rate. Concerns, however, have

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been presented that these family benefits tend to reinforce gender differences in the labour market (Ekberg et al. 2013).

Thus, progressive parental leave policies are central on the agenda for global politics and societal change, since such policies have been proven to strengthen women’s employment, reduce poverty risks and help reduce the gender pay gap. Parental leave is also important for the recognition of all non-traditional families and same-sex parents. “Non-traditional families, have by the European Commission been identified to include families with single parents, families with same-sex parents, families with adopted or fostered children, families with parents living apart, families with step-parents and step-siblings (‘reconstituted’ families) and families that consist of other relatives living together in ways outside the traditional formulation.” (European Commission 2019).

A gender equal uptake of parental leave by fathers is not only associated, as mentioned above, with positive outcomes on the labour market for women, but it is also closely related to an improved commitment in a child’s life and a more gender-equal share of housework (Gislason, 2010). When both parents are invested in the childcare and upbringing of a child it has been argued that it also brings positive effects for the child. This includes an improved cognitive improvement and educational achievements (Cools et al, 2015) as well as an improved social capacity, competence and general well-being (Harris et al, 1998). It has also been highlighted that fathers who are involved in the early stages of their child’s life have reported a greater life-satisfaction and have said they feel more effective and more self-confident as a parent (DeLuccie, 1996).

As this section has shown, paternal involvement in caring for a child is clearly linked to positive effects for children, fathers, as well as women’s position within the labour market. Paid parental leave is the key aspect in making this a possibility for more parents and children in the future. The European Union is therefore calling for a more gender-neutral parental leave policy that can help parents balance their work life and family life as well as increase women’s employment chances and reduce discrimination against women in the workplace, which can help to reduce the risk of family poverty

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(OECD 2016). The European Union also argues that parental leave is an incentive for a better work-life balance. A briefing report from the European Parliament states:

The current EU framework, consisting inter alia of directives on maternity and parental leave, needs to be ‘modernised’ and adapted to ‘today’s labour market, to allow for parents with children or workers with dependent relatives to better balance caring and professional responsibilities’ (European Parliament, 2017).

For the reasons set out above, progressive parental leave policies have been shown to have a positive effect in achieving and reaching gender equality, reducing the risk of family poverty and increasing the general well-being in a child’s life. Therefore, it is significant that progressive parental leave policies do transfer and essential to examine the reasons for why they fail to do so.

1.4 Structure

Having introduced the research question and explained the importance of progressive parental leave policies on a global political scale – this thesis now moves forward in chapter 2 to contextualising parental leave within the role of the different welfare states in the four selected countries. In chapter 3, the theoretical framework is introduced with a summary of previous research on Europeanisation and policy mobility, followed by a description of the four different ways in which policies can transfer. In chapter 4, the method and material used in the qualitative comparative case study is presented. Chapter 5 consists of the results and analysis of the material. Following the analysis of the result is the discussion in chapter 6, where particular focus is given to the factors which restrict policy transfer. The discussion continues by addressing the ways in which this study hopes to contribute to the field of research. Finally, Chapter 7 concludes the thesis and presents suggestions for further studies.

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2. Contextualising parental leave within the role of the welfare state

This chapter begins with a short descriptive section considering the terminology of current parental leave policies in the European Union. This is followed by a profile of the four member states selected for study in this thesis relating to the relationship between parental leave policy and the respective welfare regime, using Esping-Andersen’s classic models. There are, according to Esping-Andersen, three different welfare state regimes based on social and economic rights in a nation and the relationship between the market, the family and the state. The development of a welfare regime is based upon and influenced by the historical background of the political system in which it is embedded. The three different regimes are the Conservative, the Social Democratic and the Liberal model1 (Esping-Andersen 1990).

As of 2018, all member states in the European Union offer maternity leave and some form of paternity and/or parental leave that can be used by the father (at least according to the law). The distinction between paternity and parental leave is not always clear and sometimes confusing. This happens when some countries do not offer paternity leave per se, instead they simply provide a part of the parental leave that is reserved exclusively for fathers; Sweden is such an example (Eurofound 2015). Paternity leave, however, is a leave reserved for the use of the father only, typically a shorter leave taken straight after the child is born. Maternity leave is the female equivalent of this leave, usually taken just before the child is born. Parental leave is the longer leave from employment which includes both parents and is the entire period of leave from employment to care for a child during its first years. There is, however, a large degree of variation in terms of the length of the leave, level of compensation and whether or not the leave is a family, individual or mixed entitlement. The family entitlement can

1 The liberal model is not expanded upon in this thesis due to it not being exhibited by the countries

selected for study in this work. By way of brief explanation, the liberal model is typically characterised by modest, means-tested assistance, and targeted at low-income, usually working-class recipients. The liberal welfare model is characterised by the central role of the market to divide assets, insurance and collective services; citizens have a basic protection in the form of insurance which is, however, financially insensitive and, in the majority of cases, residents need to supplement with private insurance. The liberal welfare state regime is typified by the state having one marginal role and the relationship between the state and the market is minimal. The inhabitants have themselves a responsibility to ensure that they are insured; it is not the state's role to provide this to its citizens (Esping-Andersen 1990:26).

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(in theory) be divided between the parents, individual entitlement cannot be shared and the mixed entitlement is part family and part individual entitlement (Eurofound 2015). Since the 1990s, the study of the relationship between the national state and family related policies in the field of comparative welfare state research has increased, for example in the work of Esping-Andersen (1999), Leira (2002) and Hantrais (2004). These studies show that states choose alternative ways in which to define the complex link between the state and the family, and this can explain the differences between the behaviours of the states and the family related policies thus implemented. In view of the strong link between parental leave policies and the wider welfare regime within they exist, this thesis will utilise the work of Esping-Andersen as it helps to provide a contextual understanding of why progressive parental leave policies may have failed to transfer between member states.

The Social Democratic welfare state regime in Sweden and Denmark

The social democratic welfare regime is characterised by its universalism and as a system that promotes an equality of high standards, rather than an equality of minimal needs. Residents have the opportunity to take out social insurance (Esping-Anderson, 1990). The social democratic welfare regime is thus typified by the central role of the state and the relationship between the state and the market is maximal. This model is based on all individuals and families being able to use and have insurance at their disposal; regardless of background, they must be guaranteed care, school, education and a social safety net (Esping-Anderson et al. 2002). The result of this welfare regime is that it does not only serve family needs, it also allows women to choose work rather than the household by taking responsibility for aspects of family life that are typically/traditionally the responsibility of women under conservative welfare regimes, such as nursery care (Esping-Andersen 1990:28). Parental leave is a mixed entitlement in Sweden, meaning it is part individual and part family entitlement and it is an individual entitlement in Denmark. The Swedish legislation around parental leave is written in a way which does not refer to gender. Fathers and mothers therefore have the same right to parental leave. Joint legal parenthood for same-sex couples is legal in both Sweden and Denmark. The progressive parental leave policies have been successfully implemented in Sweden and Denmark. In 1974, Sweden was the first

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country in the European Union to introduce a paid parental leave for which both parents were eligible. In the years following this the parental leave policy in Sweden has continuously been reformed in order to bring about a more equal parenthood (Duvander et al. 2005). Thus, in total, parents in Sweden are eligible for a total of 480 days to share between them. 90 days is, however, reserved for each parent and cannot be shared or taken over by the same parent. If the 90 days are not taken the parents will lose them. (Eurofound 2019). In total, parents in Denmark get 52 weeks of paid parental leave. Typically, the mother has the right to four weeks of leave directly before the planned birth and then to a further 14 weeks of leave after birth. The father is entitled to take two weeks of leave during the first fourteen weeks following the birth of the child. (European Commission 2019). Both parents thus have the right to 32 weeks of parental leave. They can choose to be on parental leave at the same time or in periods one after the other. However, even though each parent can take 32 weeks of leave, each family can only claim in total 32 weeks of leave cash benefit. (Bloksgaard & Rostgaard 2018). According to Valdimarsdóttir the introduction of paternity and parental leave in Sweden and Denmark has been a very large step forward for gender equality (Valdimarsdóttir 2006).

The Conservative welfare state regime in Greece and Hungary

The conservative welfare regime model is typically shaped by the Church and is devoted to preserving traditional family values. The social insurances in this model rarely include non-working wives, and the family benefits system seeks to encourage motherhood. Nurseries, day care and similar family services are often underdeveloped; the state will only interfere when the family’s capacity to serve its members is exhausted (Esping-Andersen 1990:27). Parental leave in Hungary is a family entitlement and an individual entitlement in Greece. Joint legal parenthood for same-sex couples is not legal in Hungary or Greece. Maternity leave in Greece is 4 months if the mother is employed by the private sector, and 5 months for public sector employees. Paternity leave in Greece is two days and can only be taken at the time immediately following the child’s birth. Parental leave for private sector workers is unpaid and is four months per child for each parent. For public sector employees the parental leave is still unpaid and can cover up to five years per parent. This is unpaid unless the family have three or more children (Eurofound 2019). Parental leave is a family entitlement in

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Hungary. This means that the parents can choose whether the father or the mother will stay with the child, although the majority is taken by the latter. The length of maternity leave in Hungary is 24 weeks and can start from four weeks before the child is born. Paternity leave consists of five days (in the case of twins – seven days) and it can be taken during the first two months of the child’s life. Parental leave can be taken during the child’s first three years (Eurofound, 2019).

2.1 Summary of the role of the welfare state

Thus, different welfare systems have different consequences for the citizens of the state, and thus also different consequences for both men and women. Laura Carlson highlight the significant impact of the role of the welfare state for gender equality in Sweden:

The welfare state created in Sweden provides a high degree of social justice, with a high minimum living standard, free education, free child care, free health care and available housing. This is an achievement that cannot be denied or negated, and has led to much of the praise with respect to the achievements regarding women (Carlson, 2007:357).

The directions these different welfare regimes take thus also has consequences for which policies are implemented and transferred successfully, meaning the progressive parental leave policies which are designed to bring with them an equal gender balance have more room to expand and find roots within the social democratic welfare regime that builds upon the concept of universalism and with an already existing network of social policy connection to parental leave, such as nurseries.

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3. Theoretical framework

In this chapter the theoretical framework used in this thesis is presented. The chapter begins by focusing existing research on Europeanisation and literature on how policies transfer from the European Union to the Member States. This is followed by addressing current research on policy transfer and by presenting how the work will utilise the theories in the analysis. To understand why policies have failed to transfer to and across the Member States in the European Union, theories and models around policy transfer will be utilised. This is followed by a section focusing on four core concepts within policy mobility theory, describing different ways policies can travel; diffusion – they can be perceived as contagious and spread from states to states, transfer - by choice and copying of ‘best practice’, convergence – by supranational force or as a translation – by emphasising idea of experimentalism and ‘alteration’. Following this, the definitions of policy success and policy failure are presented. Finally, this chapter ends with a summary of the theoretical framework.

3.1 Europeanisation

As the Member States of the European Union are becoming more entwined in the Union’s polity, the research on Europeanisation has also grown (Carpenter 2020). Lawton defines Europeanisation as the transfer of power from the state to the European Union level and the distribution of power among the Member States and the European Union (Lawton 1999). In the Europeanization of Public policy, Radaelli states that Europeanisation consists of:

processes of (a) construction (b) diffusion and (c) institutionalization of formal and informal rules, procedures, policy paradigms, styles, ‘ways of doing things’ and shared beliefs and norms which are first defined and consolidated in the making of EU public policy and politics and then incorporated in the logic of domestic discourse, identities, political structures and public policies’’ (Radaelli 2003: 30).

Green Cowles et al. add that Europeanisation is the materialisation and expansion of structural governance on the European Union level. This incorporates the political, social and legal institutions that connect political issues, actors and policy networks that establish influential policies (Green Cowles et al. 2000). Schimmelfennig and

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Sedelmeier define Europeanisation as the process where Member States start to adopt the rules, policies and/or programmes shaped by the European Union (Schimmelfennig & Sedelmeier 2005).

Börzel has studied the process of Member States shifting power European Union and assigning its institutions with power and influence. Informed by this shift of power, Europeanisation is defined here as a “process by which domestic policy areas become increasingly subject to European policy-making”. In Börzel’s view the process of Europeanisation is strongly influencing national policymaking and programmes. Hence, membership in the European Union requires that national matters and problem areas are, to an extent, formed and controlled by the regulations and procedures of the European Union (Börzel 1999). It is argued that the concept of Europeanisation does not only refer to ‘the emergence and development at the European level of distinct structures of governance’ (Green Cowles et al. 2001:3), but that it is also a highly beneficial academic field to study when examining the influence of these policies or institutions on the domestic level and the ways that actors can make collective requirements noticeable on a global scale (Caiani & Graziano, 2018:1033).

Hamedinger and Wolffhardt (2010: 28) define Europeanization as ‘the interplay between actors and institutions on the European and the city level, which leads to changes in local politics, policies, institutions, arrangements, discourse, actors’ preferences, values, norms and belief systems on both levels’. (Carpenter at al. 2020:228).

3.1.1 Policy transfer from the European Union to the Member States

Börzel has identified several mechanisms through which the European Union can cause and /or create an affect in Member States in terms of a change to domestic policy. The author differentiates among institutional compliance, in which the European Union suggests an ideal that is enforced upon the Member States and by changing domestic opportunity structures, that means a rearrangement of resources among national actors, and finally policy framing, that modifies the attitudes and viewpoints of the national actors. (Börzel 2003).

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Interestingly, Börzel has found that some kind of ‘misfit’ or ‘mismatch’ between the European Union and the domestic policies or institutions is a crucial and necessary requirement for a domestic change to occur (Börzel 2003). The ‘goodness of fit’ as (Green Cowles et al 2001) refer to it or the similarity between the European Union and the Member States at national level decides the extent of pressure to adjust by Europeanisation upon the Member States (Börzel 2003). The author also highlights:

Only if European policies, institutions, and/or processes differ significantly from those found at the domestic level, Member States feel the need to change. The lower the compatibility between European and domestic processes, policies, and institutions, the higher is the adaptational pressure Europe exerts on the Member States. (Börzel, 2003).

According to Börzel, there are two kinds of misfits by which the European Union can apply pressure on the Member States. First, ‘policy misfit’, in which there is a mismatch between the European Union policies and the domestic policies. Policy misfits results in compliance problems. Policies from the European Union can challenge the domestic policy goals and adjust the desirable standard. The Member states defiance to adjust to domestic policies often results in intrusions in contradiction of legal requests from the European Union. Policy misfit may also result in adaptational pressure on institutions and political processes. Second, European Union can cause ‘institutional misfit’ that challenge domestic rules, procedures and the collective understandings that are attached to them (Börzel 2003).

Keck and Sikkink introduced the term boomerang pattern in order to describe how organisations such as the European Union can influence domestic organisations, and when an actor, network or organisation is constrained or overlooked on national level, it may turn to other countries and/or networks and via them “try to bring pressure on their states from outside” (Keck & Sikkink, 1998:12).

In order to deepen the understanding of policy mobility, this thesis now turns to look at the process more broadly than at European Union level. In doing so, theories on policy mobility developed and established by Dolowitz and Marsh (1996) are utilised, complemented by the four ways and concepts in which policies can move, as advanced by Stone (2012; 2017), and Peck and Theodore (2010) as well as a transnational case study by Begley et al. (2019). As the focus point within this work is to investigate why this certain policy regarding an aspect of parental leave has not transferred across the

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European Union, previous research on how policies are deemed a success or a failure conducted by; King and Crewe (2013), Kerr (1976), Bovens et al (2001) and McConnell (2010), will be referred to. This research is useful in order to build up the understanding of mechanisms around policy transfer and how these fits into the wider context of policy transfer (O’Dolan & Rye 2012).

3.2 Policy Transfer / Mobility

Policy transfer has been defined by Dolowitz and Marsh as “a process in which knowledge about policies, administrative arrangements, institutions, etc, in one time and/or place is used in the development of policies, administrative arrangements and institutions in another time and/or place” (Dolowitz & Marsh, 1996:344). The authors largely established this theory by developing a framework to explain how and why policy transfer occurs (Dolowitz & Marsh, 1996). Understanding this can perhaps help us understand why progressive parental leave policies have failed to transfer across all members of the European Union.

The understanding of successful and less successful policy transfers was contributed to by a case study – described in a book named Success and Failure in Public Governance (Bovens, et al. 2001). This multinational research project examined six European countries regarding four different policy areas, trailing specific policy tasks and challenges, and argues for a more nuanced view of the term success by factoring in the range of political and cultural factors that might affect the judgement of success, and the valuation of success could vary for different people at different times (Begley et al 2019). Bovens et al. conducted this transnational case study by gathering research covering the six countries of the study: France, Germany, The Netherlands, Spain, Sweden and the United Kingdom. The same four policies; the reconstructing of the steel industry, crises in the bank and finance sector, health care reforms and the issues the stroke these countries when HIV-contaminated blood infected individuals who had received blood-derived products or transfusion, was analysed in each country. The authors used this combination of cases and countries to set up their comparative analysis (Bovens, et al. 2001).

In this case study, Bovens et al. draw distinctions among countries with constitutional frameworks that can enable the construction of a strong policymaking process and the

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states where the constitutional framework is of a weaker and more dependent position. In the study, the United Kingdom, which has a Westminster system and France, which has a semi presidential and centralised government system falls into the first category. Germany, Netherland and Sweden fall into the second category, all with federalism and decentralisation, coalition governments and multiparty systems. The conclusion of this study is that countries with an aggregate constitutional framework that can allow and authorise a construction of a strong policymaking are more successful when implementing policies, rather than a decentralised government in coalition (Bovens, et al. 2001). However, Grønnegaard Christensen, questions this:

Even if we can categorise the national systems, as institutionalist often do, these broad classifications tell us very little about architecture of the political and administrative systems in specific countries. A constitutional framework that facilitates the creation of a strong executive is not tantamount to saying that the government is power always resorts to using its strong powers (Grønnegaard Christensen 2002).

In order to answer the research question of why progressive parental leave policies have failed to transfer, it is of importance to understand how policies can be transferred, in order to answer why they have not and what factors have acted to restrict their mobility. The section above and the case studies highlighted have contributed to an understanding of the basis on what policy mobility is and how it has been studied in the past. Stone, as mentioned above, identifies four different ways in which policies can move: diffusion, transfer, convergence and translation. These four are described below and will be analysed in further detail in chapter five.

3.2.1 Diffusion

The concept of policy diffusion was first established on the American political scene through an analysis of how several American states could emulate ideas and policy improvements from their neighbouring states. Berry and Berry defined diffusion as ‘the process by which an innovation is communicated through certain channels over time among members of a social system’ (Berry and Berry, 1999:171). Hence, diffusion simply describes a pattern of sequential adoption of a practice or policy (Stone 2017). Stone therefore argues that policies can be perceived as contagious rather than chosen

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and spread from state to state. The change of a policy is gradual and is altered over time (Stone 2012). “By identifying patterns of policy adoption, diffusion approaches are more concerned with the conditions for the spread of knowledge or norms rather than the substantive content of new policies” (Stone 2017:57-58).

3.2.2 Transfer

In this concept, actors have a role of agency and rationality. Policies can be adopted by choice, voluntary and by copying ‘best practice’ and a plausible likelihood for ‘multiplicity of lessons’. The focus here is on lesson-drawing and on copying policy. In this concept, there is a recognition that certain structural forces can push or force policies, but that actors can reconcile and choose to adopt some policies and not others, such as common goals, institutions, legal tools and ideologies can be selectively copied (Stone 2012).

An essential and significant factor when a voluntary rationality transfer occurs is that a state copies policy, programmes and/or institutions from another state with a belief that this transfer might lead to a success. Here ‘success’ is measured by the degree to which the transferred policy achieves the goals set by the state which borrowed it (Dolowitz & Mars, 2000). The process of voluntary policy transfer therefore starts when states actively participate in the pursuit of new ideas and concepts, when the policy makers recognise that a situation is particularly challenging, or when they are dissatisfied with the current situation. Networks, such as epistemic groups, support unions and/or policy transfer networks can therefore be involved in the search for, and evolving of, different policies and programmes (Unalan, 2009:440).

3.2.3 Convergence

Stone highlights that policy convergence is most importantly the outcome of a structural force, rather than a consequence of an agency, this is particularly true for the phenomenon of globalisation. This concept is challenging the ‘logic of choice’ with path dependencies and as a result of this is not always consciously spread (Stone 2012). Supra-national institutions play an important role when it comes to a coercive policy transfer. The European Union and the European court of justice are examples of

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supra-national institutions that can by structural force, force a policy transfer upon their member states. The European Union has pushed policies by using its power to issue directives and regulations, whilst the European Court of Justice can force governments to adopt policies, directives and/or regulations that have been issued by the European Union (Dolowitz & Marsh 1996:348).

A state can also be more or less indirectly pushed towards a policy transfer if the political actors involved feel that their state is falling behind the neighbours or competitors. Bennett argues: ‘fear of being left behind on an important public issue can trigger attention. The cumulative effect of action elsewhere may translate into a feeling of insecurity about being the odd-man-out’ (Dolowitz & Marsh 1996:349). A coercive policy transfer can occur when a government pushes or forces another to implement a policy, although a direct implementation of a policy transfer from one government to another is very rare (Dolowitz & Marsh 1996).

3.2.4 Translation

This concept is challenging the determinism of diffusion and convergence and the rationalist linearity of transfer while instead emphasising on the idea of ‘mutation’. The importance of this concept is the recognition that policies alter and change while or during a transfer, in creation, transmission, interpretation and or reception. Experimentalism in assembling policy is key, since the policies are very sensitive to the context they are being place in. What is distinct about this concept is that it also takes into account the transfers which are poor, incomplete and/or only partial alongside the notion of the non-transferability (Stone 2012).

Peck and Theodore adds to Stone’s concepts of translation, that policies, do not travel or arrive as a complete compendium. But rather more often they move bit by bit, - ‘as selective discourses, inchoate ideas, and synthesized models—and they therefore ‘‘arrive” not as replicas but as policies already-in-transformation.’ (Peck & Theodore 2010:170). The authors do also raise critique against the idea of ‘convergence towards homogeneity’. Thus, even the same policies will or can produce different effects in different effects in different locations due to societal, economic and institutional factors of the given environment. (Peck & Theodore 2010). As Stone suggests, policies alter when transferred dependent on the social context in which it is being implemented.

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Thus, as Stone also highlights, policies do not tend to transfer as a result of a ‘cut and paste’, but rather, they are modified in the process of transfer (Stone, 2012). Peck and Theodore demonstrate that policies can be changed when being transferred and are sensitive to the social context in which they arrive (Peck & Theodore, 2010).

3.3 Deeming a policy transfer as a success or failure?

Dolowitz and Marsh have categorised three ways in which policies are likely to fail (2000:17). Worth mentioning however, is that Fawcett and Marsh unfortunately, have argued that there is a gap in literature and research of analysis, which can link policy transfer processes with outcomes (Fawcett and Marsh, 2012:163). Nevertheless, the three way in which policies can be expected to fail are if the transfer is either uninformed and/or incomplete and/or inappropriate (Stone 2017). The uninformed transfer occurs when policies are transferred without sufficient knowledge about the degree to which, and why, it works in the jurisdiction from which it is being transferred. An incomplete transfer is the result when selected features of a policy are transferred, but others are not, and the success in the original jurisdiction depended at least in part on the feature(s) not transferred. Lastly, the inappropriate transfer occurs when contextual factors – cultural, political economic – are so very different, leadings to differences in policy outcomes in the two countries concerned (Stone 2017:59). By focusing of four previous studies on policy success carried out by Kerr (1976), Ingram and Mann (1980), Bovens, ’t Hart, and Peters (2001) and Prasser (2006), McConnell along with Fawcett and Marsh (2012) also discusses the relative lack of academic research on outcomes of policy success (McConnell 2010a). However, Begley et al. (2019) argue that there is more research concentrated on policy failure, among others: Bovens et al. (2001), Dunleavy (1995), King and Crewe (2013) and Moran (2001, 2003). Although the consistent part of the research in this area is the detection that whether the aims and objectives of a policy is met is the important aspect when evaluating the success of a policy, it has, remarkably, also been rather weak (Begley et al 2019).

The definition of policy outcomes does however vary and there is a discrepancy in the terminology used. The view that “a policy that does not fail is successful” (Kerr

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1976:362) may be fairly one-dimensional. Henceforth, McConnell introduced the noteworthy idea of a spectrum from “complete success” to “complete failure”. (McConnell 2010a). “Failure is the mirror image of success: A policy fails if it does not achieve the goals that proponents set out to achieve and opposition is great and/or support is virtually non-existent’ (McConnell, 2010b:356).” Just as ‘policy failure’ and ‘policy success’ are often portrayed as polar opposites in a binary distinction, so too policy transfer and diffusion approaches can suffer from similar binary distinctions.” (Stone 2017:67). However, Kerr argues that a policy could be successful, at least not fail, as long as it was either implemented, effective or normatively justifiable (Kerr 1976:359). She reflects on academic cases, where success or failure in all of these three different terms is feasible, and from her viewpoint, a particular policy might be implemented successfully but could still fail to be justifiable for the public. This is a key finding in relation to the research question in this thesis, even if policies have been implemented successfully, member states can behave differently towards it, thus even when implemented fail to be justifiable in the eye of the public, leading the states to behave differently (Kerr 1976). Nonetheless, Begley et al. (2019) stresses how important it is to be able to pinpoint the goals, aims and/or purpose of a policy in question, before it is achievable to contemplate if the goals, aims and/or purpose have been reached, which is not always a straightforward as it might look upon first glance (Begley et al 2019).

In 2013, research on policy failure was advanced by King and Crewe with The Blunders of our Government, a study of the United Kingdom over a period of three decades. They distinguished what they call “blunders” from different forms of policy failure, such as “policy disappointments”. The authors argue that blunders are policies that completely fail to achieve the aim and objective, they waste a large amount of money or create distress among the citizens. In line with Kerr’s research this argues that a policy therefore can be viewed as a failure or blunder even when the aims was essentially met, due to high costs or if they were not normatively defensible to the people affected by the policy (Kerr 1976). These judgements and assessments are naturally to a significant amount likely be subjective and/or change over time.

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3.4 Summary of the theoretical framework

The aim in developing this theoretical framework on policy transfer is to provide an analytical tool with which we can explore and investigate the process of policy transfer and, thus, lead up to the answer of why progressive parental leave policies have failed to transfer across the European Union. Thus, knowledge and previous research of policy success and failure can help us build a richer insight into the factors that may have hindered the transfer of progressive parental leave.

For welfare state policies to converge across the European Union can require welfare states to undergo a degree of reform. Europeanisation is therefore important to consider when we are studying domestic developments and policy change. The communication between the European Union and the Member States can be measured within the subject of Europeanisation (Vink and Graziano, 2007). Within the body of welfare state policies, this element incorporates studies on why and how member states decide to develop social policy initiatives at the European Union level such as the parental leave policies, thus making it important to look into Europeanisation to reach the aim of this thesis.

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4. Method and material

In this chapter, the material used in this thesis is presented, along with the method describing how the analysis of the material was conducted. This section also describes the methodological justifications for selecting Sweden, Denmark, Greece and Hungary to be part of the case study. The purpose of this chapter is to provide a thorough explanation for the method in order to show transparency.

4.1 Why is this method used?

As referred to in the previous chapter, Bovens et al. (2001) conducted a comparative case study among six European countries regarding four policies in order to assess the successful rate of policy transfer and implementation of policies. This method used was found to be particularity conducive to studying policy transfer across member states in the European Union. As such, this thesis is inspired by this previous study, and aims to apply a similar comparative case study, by analysing four different states in relation to a different policy. Begley et al. (2019) have also conducted a comparative case study by comparing two different policies in the United Kingdom. Informed by these studies, a comparative cross national case study is deemed an appropriate method to study the aim of this thesis. Therefore, this thesis is conducting a comparative cross-national case study in order to provide an answer to the research question set out in the introduction and produce coherent social scientific knowledge. As argued by Hantrais & Mangen (1996):

For the study to be cross-national and comparative, individuals or teams should set out to study particular issues or phenomena in two or more countries with the express intention of comparing their manifestations in different socio-cultural settings, using the same research instruments. (Hantrais & Mangen 1996:1).

To create an analysis that considers all characteristics of the institutional developments of the welfare state in each country studied is not possible within the constraints of this work. This thesis is therefore focused on a particular part of social policy from the welfare state – the parental leave policy. This comparative case study is developed in order to analyse one specific policy in detail – the policy pertaining parental leave – specifically the clause which deems that the parental leave in the European Union shall

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be granted for a minimum of four months and one of these four months shall not be transferrable. Grønnegaard Christensen argues that when selecting and observing the same policy in different countries, we can often comprehend the width of variation that is in each of the countries (Grønnegaard Christensen, 2002). Thus, making this a worthy phenomenon to investigate. A cross-national comparison is, as Hantrais and Mangen maintains, also a useful method on order to focus on a key element of study by shedding light on the matter from different perspectives as well as finding gaps for future studies:

Cross-national comparisons may also help to sharpen the focus of analysis of the subject under study by suggesting new perspectives, as demonstrated by many of the contributions to the present volume. They can lead to the identification of gaps in knowledge which prevent effective cross-national comparisons, thereby suggesting useful avenues for future research (Hantrais & Mangen 1996:3).

The previous work on welfare state regimes by Esping-Andersen will contribute by providing an understanding of the social-cultural settings in each member state. This case study is applying a theory of policy transfer in order to provide an understanding and explanation for the fact that similar policies transfer differently – successfully or not at all, as well as the fact that even when transferred, said policy can/will have different results/effects in different locations based on cultural, societal, economic, and institutional factors and norms of the state and the time (Dolowitz & Marsh, 2000). This is crucial since the aim of this thesis is to understand why progressive parental leave policies have failed to transfer across the European Union.

4.2 How is the research designed?

This thesis is applying a Most Different System Design. In this design the strategy is to choose elements of research that are as different as possible in relation to each other. Anckar argues that especially in comparative studies, the most different system approach is a good logic of foundation for choosing units of analysis (Anckar 2008). Sweden, Denmark, Hungary and Greece have been chosen and constitute ‘most different’, for the following reason, their ranking on the Gender Equality Index. Sweden and Denmark are ranked as the best two states regarding gender equality in the European Union and Hungary and Greece are the bottom two. Many studies have shown that there is a strong correlation between a country’s gender equality and the

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country’s parental leave policies (Kamerman & Moss, 2009). These four member states have therefore been deemed suitable to compare in the thesis due to their dissimilar systems. These four states appear have widely different attitudes towards their consideration of the father role in parental leave systems. Sweden and Denmark have one of the longest and deepest traditions in including and reserving periods of time for the father in the parental leave policies. Greece and Hungary are states with the some of the most recent legislature around parental leave, and a minor consideration on the role of the father in these policies.

In summary, there is a link between gender equality and parental leave within a country. Thus, the choice of countries has been informed by the respective positions in the Gender Equality Index, where Sweden and Denmark are the two highest ranked countries and Greece and Hungary are the two lowest ranked in gender equality in the European Union (Gender Equality Index, 2017).

4.3 Material

4.3.1. What material is used in this thesis?

As mentioned in the introduction, this thesis is focused on one specific clause in the Council Directive 2010/18/EU on implementing the revised Framework Agreement on parental leave:

The leave shall be granted for at least a period of four months and, to promote equal opportunities and equal treatment between men and women, should, in principle, be provided on a non-transferable basis. To encourage a more equal take-up of leave by both parents, at least one of the four months shall be provided on a non-transferable basis. The modalities of application of the non-transferable period shall be set down at national level through legislation and/or collective agreements taking into account existing leave arrangements in the Member States.

The material used in this thesis has been selected, collected and because it can provide precise as well as esteemed data on the subject in question. Therefore, in order to answer the research question, this thesis is utilising legislation on parental leave in the four member states, theories on policy mobility and welfare state regimes. Central in this thesis is the theory on policy mobility, therefore, this thesis is utilising numerous or

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academic literature on this subject. Among others Dolowitz and Marsh (1996) who have established a foundation for the concept of policy mobility. Stone (2012, 2017) who have complemented by the four ways and concepts in which policies can move by Stone, in order to build up argumentations for how policies also can fail to be transferred. The literature on Europeanisation and European integration has been developed by authors such as Radaelli (2003) and Börzel (1999). Part of the material used consists of the report on the International Network of Leave Policies and Research, issued by Eurofound, an agency of the European Union, the European Foundation for improvement of Living and Working Conditions.

4.3.2. How was the material collected and analysed?

The majority of the material in terms of documents used in this thesis is collected from official websites run by the European Union and by organisations owned by the European Union. The details on the Council Directive 2010/18/EU was collected from EUR-Lex, on www.eur-lex.europa.eu. EUR-Lex is run by the Publications Office of the European Union and it provides an official and comprehensive access to legal documents from the European Union, such as: treaties, legal act from European Union institutions and European Union case-law, as well as international agreements and preparatory documents regarding European Union legislation.

The Gender Equality Index, which forms the basis and justification of the case study countries according to the Most Different System Design, is an instrument with which we can measure the development of gender equality in the European Union. This is established by the European Institute for Gender Equality (EIGE) and the data for the latest index is from 2017 and accessed on the EIGE’s official website: www.eige.europa.eu/gender-equality-index/2019.

The details on the parental leave in each of these four countries have all been collected from the 2019 report on the official website of International Network of Leave Policies and Research. It was accessed via: https://www.leavenetwork.org, where you can read each country’s parental leave profile as a whole. The International Network of Leave Policies and Research contains of 60 members, all of them experts on issues regarding leave policies and are from 45 different countries throughout the world.

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The material collected in policy briefing documents issued by Eurofound, an agency of the European Union, the European Foundation for improvement of Living and Working Conditions, have been collected on their official website:

https://www.eurofound.europa.eu, under publications.

The analysis of the material mentioned above is constructed by identifying the key arguments, barriers or factors restricting a policy transfer (from within the four core concepts in the theory section) and placed into context of Europeanisation among the Member States and their welfare regime.

4.4 Limitations and discussion

This thesis is limited to the sources that have been identified. I am from Sweden and therefore have an understanding and appreciation of Scandinavian cultures, norms and expectations pertaining parental leave, in a way that I do not have with Hungarian and Greek culture. In order, however to control my comparison, I will only consider equivalent documentation, this being the laws and regulations on parental leave from the four different member states. The law can be considered and compared to an equivalent level across these four member states. As such this thesis is for this reason utilising extra secondary material, such as policy briefing notes issues by Eurofound, the EIGE, European Commission and The International Network of Leave Policies and Research.

A disadvantage/critique of using the Most Different System Design is that, as with much policy research and comparative politics in particular, the researcher often uses countries and states as the component of the analysis and when doing so also treats the states as a consistent unit. One could argue, as Grønnegaard Christensen does, that: “Even if we can categorise the national systems, as institutionalist often do, these broad classifications tell us very little about architecture of the political and administrative systems in specific countries” (Grønnegaard Christensen 2002:458). Kuipers also questions the categorisation of using the state as a unit of analysis: “Often, ‘country’ is conceptualised as policy context or institutional setting. By ‘country’ researchers then really mean ‘state’. Countries, in this perspective, are essentially aggregates of

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institutions. But institutions do not emerge out of thin air. They emerge and change in interaction with each other, and with national traditions, habits, and conventions” (Kuipers 2013:21). However, in a cross-national comparative study, countries can be deemed as an appropriate component or unit of analysis, since parental leave policies are formed at the nation state level. Thus, in the scope of this study, this thesis aims to be able to produce coherent knowledge by conducting a transnational comparative case study, within the European Union.

The primary challenge in the data collection process is the language barrier. I am limited to an understanding of Swedish and English, and reliable translation of policy documents in Danish, Greek and Hungarian was not possible within the constraints of this research process. Furthermore, the member states have all use different terminology and structures around their parental leave. This can create ambiguity when a transnational comparison is made. For example, not all countries have a leave reserved for the father that is separate from further family related leave and clearly named ‘father’s’ or ‘paternity’ leave’. (Eurofound 2019). In Sweden for example, there is a period of leave reserved for the father but it is not referred to as paternity leave but rather it is a part of the parental leave. To mitigate this issue, I have limited the data to official documents from the European Union in English, since there is a consistency in the terminology used in these documents.

In certain circumstances, parents are not eligible for parental leave in the state they live in. The eligibility can depend on different criteria such as employment history, which sector they work in, if they live in a same-sex couples, if they are adoptive parents or if the parents are migrants. Which might be reflected in the statistics of uptake on parental leave. This thesis recognises that but it is not in the scope of this research to study parent’s possible eligibility for parental leave in countries other than that within which they live. Nor is it in the scope of this thesis to investigate the differences between biological parents and/or adoptive parents, carers or other. In order however to develop a response to the research question, the material is selected and collected for the purpose of extracting the key factors for what might restrict a progressive parental leave policy from transferring across the European Union.

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5. Result and analysis

In this chapter the result of the comparative case study is presented. The aim of this thesis is to investigate why progressive parental leave policies have failed to transfer across the European Union and to explore what this can tell us about the limits of policy mobility and the process of Europeanisation. To achieve this aim, an analysis is conducted here of what factors have constrained the process of Europeanisation in the specific form of the transfer of progressive parental leave policy.

For the purposes of clarity, here follows a short summary of the current parental leave policies in each of the four Member States that are the subject of this case study (Eurofound 2015).

State Summary of leave Welfare state

model

Meets the requirements of Directive 2010/18/EU Sweden Parents in Sweden are entitled to a total of

480 days to share between them. 90 days is reserved for each parent and cannot be shared or taken over by the same parent.

Social Democratic

Yes

Denmark Parents in Denmark get 52 weeks of paid parental leave to share between them, with four weeks reserved for the other parent.

Social Democratic

Yes

Hungary Maternity leave in Hungary is 24 weeks and paternity leave is five days (in the case of twins – seven days).

Conservative No

Greece Maternity leave in Greece is 16 or 20 weeks dependent on private or public sector. Paternity leave in Greece is two days.

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Directive 2010/18/EU states that parental leave should last for at least four months and that one of these months should be reserved and not be transferable to each parent in order to promote equal take up of leave. There is a clear ‘misfit’ or ‘mismatch’ here between the parental leave policies of Greece and Hungary and the requirements of the European Union, as outlined in the Directive. This is the type of mismatch that Börzel (2003) highlighted as a crucial and necessary requirement for a domestic change to occur. This change, however, has not yet occurred. In contrast, the policies of Sweden and Denmark (policies which pre-date the Directive), go even further than the requirements of the Directive, and stand as clear examples of progressive parental policies within the EU.

This chapter now continues by addressing the key factors that analysis of the results reveals to have constrained the transfer of progressive parental leave policy within the European Union, and thus the process of the Europeanisation.

5.1 Factors that have constrained Europeanisation and Policy Transfer

Institutional surroundings

Policies are sensitive to their surroundings; this sensitivity can act as both an enabler and a constraint of Europeanisation and policy transfer. This is because the process of policy translation is aided and facilitated by a similar political system (between origin and destination states), as well as the bureaucratic and/or economic resources that can be used to implement said policy. As Esping-Andersen emphasises: “The institutional frameworks of national welfare systems are historically ‘locked in’ and any realistic move towards common objectives must presume that such, if accepted, will be adapted to national practice” (Esping Andersen 2002:25). As Dolowitz & Marsh similarly note: “Policy transfer is dependent upon the transferring political system and possessing the political, bureaucratic and economic resources to implement the policy” (Dolowitz & Marsh 1996:354). Within Sweden and Denmark, there exist a framework of institutional resources that enable the effective implementation of a progressive parental leave policy. This includes taxation systems that provide the required economic resources and an employment structure that has grown accustomed to managing the challenges presented by the policy (Esping Andersen 2002).

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Thus, we can see that in order to implement a more progressive approach to parental, states such as Greece and Hungary would also require the bureaucratic and economic resources to implement it, as well as the institutional frameworks within which to embed it. Such requirements thus act to constrain the mobility of this type of policy.

Shared beliefs and norms

As Radaelli stated, for Europeanisation and policy transfer to occur there needs to be shared beliefs and norms. With different welfare state models and attitudes to social policy, such shared beliefs and norms do not appear to exist, in the across the countries studied here, in regard the correct approach to parental leave. The Social democratic model in Sweden and Denmark, characterised by its universalism and as a system that promotes gender equality, stands in contrast to the conservative models in Hungary and Greece, models that are shaped by the Church and are devoted to preserving traditional family values (Esping-Andersen 1990). Thus, we can see that ‘full’ Europeanisation is constrained by differing beliefs and norms among Member States in regard to the role of the family and the welfare state (Radaelli 2003). Sweden & Denmark are part of political union with Hungary & Greece, yet do not appear to share a common belief or norm around parenting.

Returning to Bennett’s argument that the “fear of being left behind on an important public issue can trigger attention” and thus lead to a change in policy, one can question whether this holds true for the issue at hand. When it comes to questions of family life within a conservative society and welfare regime, does “the cumulative effect of action elsewhere… translate into a feeling of insecurity about being the odd-man-out”? (Dolowitz & Marsh 1996:349). Within a conservative welfare regime, this does not seem likely. Conservatism, which is defined by seeking to uphold tradition, is less likely to swayed by a concern of being left behind; this is particularly apparent in the realm of family life and thus the application of the welfare regime in this area. Reminding ourselves that: “Each Member State has its own welfare policy legacy, distinct system of interest organizations, and democratic polity” and that “it is within such diversity that actual, concrete welfare reform will be undertaken” (Esping-Andersen 2002:25),

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