Movements to Combat Sex-Trafficking: The Social Construction of a Global Problem and Its Solutions

Abstract

In this paper we analyze the international movements against sex-trafficking, identifiable for 150 years. We critically assess actor-centric approaches within IR that assume a tight connection between intentional actors and a singular norm. We build on critical research to develop a cultural institutional approach that focuses on the intertwining of actors and institutions and on how outcomes are loosely coupled from actors’ actions. Several empirical implications are delineated that guide and are assessed by our analysis of the anti-sex-trafficking history. Using the lens of cultural institutionalism, the resulting interpretative history identifies patterns that support the implications and utility of the theory and that actor-centric perspectives have slighted: actors and norms are embedded in institutions, change was multidimensional and repeatedly difficult to label as success or failure, outcomes often were long-term through weak connections, anti-sex-trafficking movements were affected by distinct issue areas, change occurred episodically through institutional workspaces from early conferences, and conventions of the League of Nations to Vienna 1993 and Palermo 2000. We discuss the contributions of our analysis and the implications for critical theories of how a social problem and its solutions are constructed leading to international socio-political change.

Les mouvements de lutte contre la traite à des fins d’exploitation sexuelle : La construction sociale d’un problème mondial et de ses solutions

Introduction

In 2000 the United Nations Convention against transnational organized crime instituted the Protocol to Prevent, Suppress, and Punish Trafficking in Persons Especially Women and Children (hereafter, the Palermo Protocol). This international instrument represented a milestone for the anti-human trafficking movement, resulting in nation-states legislating domestic laws criminalizing human trafficking. By March 2019, 173 countries had ratified the Palermo Protocol, and 168 had criminalized trafficking domestically. ¹ People are trafficked for sexual exploitation, forced labor, forced begging, forced marriage, for selling children and conscription of child soldiers, and for organs. Economic vulnerabilities including those caused by shocks such as a pandemic increases the risk of trafficking. ² The present research focuses on sex trafficking – predominantly of women and girls.

According to the United Nations 2020 ‘Trafficking in Persons’ report, 50% of all trafficked victims are used for sex exploitation; women and girls make up 92% of victims. ³ Since Palermo, thousands of organizations are addressing human trafficking by working locally and globally to form networks of coordination and partnerships with industries and private companies. ⁴ For example, companies in the tech and hospitality industries have been especially mobilized to combat the persistent presence of sex tourism. Social media have amplified celebrity and popular attention even as it creates challenges for combating sex-trafficking. At the same time, there are controversies and criticisms around anti-sex-trafficking action such as the definition of sex-trafficking, its relationship to other forms of trafficking, defining victims, criminalization, and the accuracy of data and estimates. From its beginnings, the international anti-sex-trafficking movement was fraught with contentions. Early international efforts against sex-trafficking were made by the International Abolitionist Federation (IAF) in 1875 – 125 years before the Palermo Protocol. ⁵ Throughout this history depending on historical context, actor interests, and organization, sex-trafficking was framed in different ways – as state-regulated prostitution, white slavery, violence against women, and international organized crime.

The history of the anti-sex-trafficking movement involves states, international governmental organizations (IGOs) and their policies, international non-governmental organizations (INGOs), transnational social movements, and myriad national and local actors attempting to influence international and national policies. This complexity is typical of global governance and norm development, and there has been a growing number of criticisms of actor-centric constructivist theories for positing autonomous individual actors and for not taking into account these complexities. ⁶ Criticisms have focused on the embeddedness of actors in interaction networks and on the interconnectedness of norms and international regimes. Independently, diverse scholarship has highlighted worldwide international or global institutional structures and movements: an international legal order; complex global governance regimes and networks; social movements organized transnationally influencing global governance and global-local dynamics; and global institutional environments that shape organizations and states. ⁷ Moreover, a world culture has been observed and theorized from early in globalization scholarship and associated with a world polity that encompasses these processes. ⁸ Subsequent scholarship using various approaches bring institutionalized culture front and center. ⁹

We analyze the transnational anti-sex-trafficking movements through the Palermo Protocol and its immediate aftermath while furthering these theoretical conversations to better understand how these movements developed, made progress, but also repeatedly seemingly failed. Put another way, we ask how a global problem and its solutions are socially constructed.

We use sociological institutionalism, using the term cultural institutionalism to emphasize the cultural nature of institutions. What distinguishes cultural institutionalism from actor-centric theories is that it theorizes how actors and norms are embedded in institutionalized culture and moreover, unlike both actor-centric and structural theories, it focuses on how the intertwining of institutions and actors produces change (or not) thereby short-circuiting the agency-structure polemic. We formulate this interplay by formally adapting concepts pioneered by Ann Hironaka: a bee swarm model of loosely coupled weak causal connections and international institutions as workspaces. ¹⁰ From this conceptual framework we identify several implications for what we expect characterizes the century-long anti-trafficking movements and which would be overlooked by other approaches.

We first evaluate problems with actor-centered theories addressing IR and sociological literatures in social movements, norm development, global governance, and agent-structure. We then present a cultural institutional framework, generating several implications that direct our attention and frame our questions in the historical analysis. Subsequent sections report the historical analysis, from the early movements in the late 19th century to the Palermo Protocol and its aftermath. We find that the cultural institutional implications help us identify important aspects of the long, multilayered history, and we argue that this framework proves useful in better understanding such movements. We discuss the advantages of a cultural institutionalist perspective and its distinctive emphasis on the intertwining of actors and institutions.

Perspectives on Global Governance and Social Change

Much scholarship of the interstate system focuses on the creation and development of norms that may (or may not) govern states, and prevalent approaches tend to be actor-centric. We address problems related to actor-centric models by developing a cultural institutional model.

Problems of Agentic-Centric Approaches: Bringing in Institutionalized Culture

Agentic constructivist approaches conceptualize actors with agency effectively creating a norm in a tightly coupled causal line. ¹¹ In international studies, political sociology, global governance, and related fields, there has been increasing criticism of linear, actor-centered interpretation of norms, by problematizing actorhood and agency and the singular norm, often in terms of the agent-structure relationship. ¹² One line of criticism and theoretical development conceptualizes actors and their practices in the context of social interactions, encompassing relational and actor-network theories, with agency emerging out of social interactions. ¹³ In contrast, sociological institutionalists criticize the common understanding of agency as an axiomatic quality of the actor by theorizing that institutions constitute actors, agency, and situated interactions. ¹⁴

We build on these developments by bringing culture in more explicitly: actors, practices, interactions, and relationship networks are embedded in institutionalized cultural structures. By embedded we mean that one cannot interpret actors (including states and international organizations), their intentions, desires, and actions without understanding the (international) institutionalized cultural order in which they find themselves. ¹⁵ Rooted in anthropology and sociology, this line of theorizing is traceable to analyses of cultural structures as a system of classifications and rules constituting categoric boundaries including actor identities. ¹⁶ Bourdieu furthers this line with his formulation of ‘structuring structures’, although with his concept of habitus he retains a socialized actor that carries those structures with them. ¹⁷ Lamont and Fournier in a collection of essays explore how symbolic distinctions are created and how they structure practices. ¹⁸ In critical International Relations theory, Epstein has argued that we need to bring language more prominently into our analyses. ¹⁹ In a study of the international anti-whaling movement, Epstein refers to the ‘structure of meanings and values’ as the nomos, following Bourdieu, and argues that the discourse of ‘speaking subjects’ simultaneously constitutes the actor’s position and actions strategies. ²⁰ Elsewhere, she argues ‘power . . . is lodged in the categories undergirding an issue-area of international politics’. ²¹ We use the term ‘embedded’ to encompass these ways in which institutional structures constitute, frame, and organize actors and their action strategies.

Thus, actors and their practices are embedded in networks of social interactions and relationships, and importantly actors, practices, and relational networks are embedded in cultural structures, accessible and observable in situated discourse. The distinction between embeddedness in social relations and in cultural structures can be explicated through two aspects of the different usages of institution and culture. First, in IR and other social sciences, ‘institutionalism’ conceptualizes institutions as organizations of roles and norms that govern interactions and function as incentive structures for individual actors. ²² A cultural approach argues that this is incomplete. What we refer to as cultural institutionalism conceptualizes institutions as cultural structures. The World Bank commonly referred to as an international institution is an organization whereas ‘private property’ and ‘development’ are institutions – cultural categories institutionalized throughout the world. The World Bank through its policies institutionalizes private property and development in particular ways thereby reproducing power relations, shaping actor interests and desires and also their interactions and relationships, whether or not a particular organizational policy is effective. Second, culture is not equated to actor preferences and values. Following diverse theoretical developments in the last 60 years, the consensus is that identities and rules are part of a structured ‘order of things’ that include situated strategized practices woven into narratives. ²³

Cultural institutionalism highlights the cultural aspects of sociological institutionalism: institutional structures are cultural in nature, constituting actor identities, and the rationales for actions, what Foucault refers to as the rationalities of institutions. The cultural aspects of institutions reflect broader culture, but in being built into institutional rules and procedures the broader cultural aspects are more concrete and particular. Hironaka refers to this as a ‘workspace’. ²⁴ Similarly, Merry, in her study of human rights activism against gender violence, analyzes the ways in which ‘transnational social spaces’ bring actors together ‘in a transnational setting that has its own norms, values, and cultural practices’. ²⁵ Moreover, an institution might be out of sync with the broader culture whether because it has resisted change or because it is pioneering change. What this perspective adds beyond an actor-centric approach is that it directs attention to how the institutional context not only functions as an incentive structure for actors, but also constitutes actors and interests, frames issues, and channels change. ²⁶

Analyzing the cultural contexts of international actors and norms connects with formulations of global culture. ²⁷ Merry conceptualizes a global culture that produces and is produced by institutions that establish spaces for the construction of human rights and that is translated (and modified) into local vernaculars. ²⁸ Although not using the term culture, scholars identify constitutive international structures; for example, Reus-Smit theorizes a constitutional structure of international society consisting of shared beliefs about states’ moral purposes, sovereignty, and procedural justice. ²⁹ Alasuutari documents how world cultural models of nation-state policies are adopted by national parliaments through domesticating them – making them consistent with national narratives. ³⁰ Sociological institutionalists have conceptualized a world culture broadly as instrumental rationalism that orients actors to instrumental means characterized by metrics of efficiency, technologies, professional experts, and individualism (e.g. human rights), and narratives of progress. ³¹ Above all, this rationalism and narratives of progress drive actors to identify social problems and their solutions.

Theoretical developments have tended to focus on the embeddedness of actors, but norms also are embedded in an order of things, which highlights another problem with agentic-centric approaches: research commonly is organized around a singular norm that marks the intention and success of the actor. While a singular norm might for analytical purposes be identified, it cannot be analyzed adequately apart from its institutional context. ³² There is a long history of critiquing the concept of a singular norm as imprecise or abstracted from everyday life. ³³ More recently, Pratt argues that IR scholarship would benefit from ‘de-reifying’ or focusing less on the singular norm and more on their relations to other norms; their arrangements; configurations; and value orientations. ³⁴ This echoes other scholars who have used the concepts of ‘norm bundle’ or ‘norm cluster’ in international relations. ³⁵ Regime complexity is another approach that has showed anti-trafficking activism and policies being affected by different issue areas such as migration and labor. ³⁶ Thus actor-centric models have difficulties because norms are not just related to other norms in clusters, or bundles, but also that norms are associated with different issue areas.

This complexity also involves different meanings and frames. Jurkovich writes that ‘for the most part constructivist scholarship in the field of IR speaks of a “norm” as a single concept, without qualifiers’ and it assumes that a norm is shared across actors and contexts with little ambiguity. ³⁷ Jurkovich explicates distinct aspects of the cultural-structural complex surrounding a norm such as, ‘oughtness’, types of actors (identities), and types of actions. ³⁸ The different international issue areas operate on various meanings of the norms in question. This can involve cooperative interactions and mutual reinforcement, but it can also create contention over how to define a global social problem, the normative solution, and who has authority over the management of the solution. ³⁹

Promoting a norm thus involves promoting a cultural package – an order of things that includes identities, scripts, and other norms. This is what we refer to when we say that a norm is embedded. Thus, one cannot change a norm without changing other aspects of the culture, and one does so within the given cultural reality. For example, using the present case, movements might work to define sex-trafficking so as to eradicate it, but they do so by strategizing lines of action within the institutionalized culture. If sex-trafficking is defined in terms of threats to national gene pools and security, it is difficult to formulate a norm based on identifying the trafficked person as a victim. Moreover, whether the person trafficked is identified as a person, laborer, woman, or child and whether trafficking is associated with sex, affect what norms if any might be formulated to regulate or ban the practice. ⁴⁰ In other words, these identities and norms inform the social construction of a global problem and its solutions.

Movements often focus on these aspects, attempting to change the assumed cultural reality of targeted actors and institutions. In his comparative study of national parliamentary debates, Alasuutari formulated this process as ‘epistemic governance’ whereby actors in situated contentious debates attempt to influence the ontologies governing the situation. ⁴¹ Epstein shows that the anti-whaling movement’s success was not because of persuasion but because it changed the ontological categories in which actors such as states strategized their practices. ⁴² In the present study, as long as sex is viewed in terms of groups (whether traditional kin groups or modern national gene pools) and as long as women are defined predominantly in terms of social roles revolving around reproduction, it is difficult to recognize sexual violence against women seen as individuals and to formulate rules against it. ⁴³ The anti-trafficking movements early in the 20th century contested and eventually changed institutionalized cultural definitions (from seeing sex-trafficking as a threat to national gene pools to seeing it as a threat to individual women) more than effecting any singular norm.

A Cultural Institutional Model

Running throughout these theoretical conversations is the sociological dialectic that actors create cultural institutions which constitute actors – their identities, desires, goals, and practices. Precisely how to formulate this dialectic commonly is caught up in the agent-structure polemic (often associated with culture/institution vs. practice), with calls to favor one over the other. This polemic tends to distract from the task of historical analysis of how change results from the intertwining of actors and institutions. Emphasizing the cultural aspects of sociological institutionalism, the cultural institutionalist approach we are proposing is an integrative approach with the purpose of short-circuiting this polemic. It directs the researcher to conceptualize how this dialectic unfolds in practice in institutionally situated interactions. To move from this meta-theoretical level to a more concrete model, we draw on the recent work by Hironaka who theorizes this intertwining in terms of international institutions as ‘workspaces’. ⁴⁴ It is well known that IGOs provide arenas in which states negotiate and form coalitions and provide platforms for various actors. As institutional workspaces though, international organizations are more than merely arenas for fully formed rational actors. Institutional workspaces constitute actors and provide cultural and social elements for defining and thereby constructing problems and their solutions. ⁴⁵ They bring diverse actors together around an issue area over which they dispute, negotiate, and collaborate. Workspaces provide much agency for actors to construct problems and solutions, and simultaneously they restrict and channel the direction of change. The concept of workspaces brings into focus the dialectic of social relations within an organized space embedded in institutional culture, consistent with Merry’s conceptualization of transnational social space. ⁴⁶

In theorizing how workspaces work, Hironaka takes on an additional problem with agentic constructivism – the assumption that actors successfully produce an intended norm in a tightly coupled causation. Hironaka labels this a ‘smoking gun’ model and contrasts it with what she terms a ‘bee swarm’ model. ⁴⁷ The effects of institutional structures and actors occur in messy, indirect ways through weak mechanisms in which the intentions of actors and outcomes are loosely coupled. ⁴⁸ In analyses of international environmental movements, she shows that while the efforts of any one actor or movement could not be determined as ‘successful’, the swarm of actors in international workspaces produced substantial change.

A tightly coupled conception of particular actors and an unembedded singular norm furthermore organizes research around a binary outcome: either intentional actors are successful in establishing an intended norm, or not. Failure is defined often implicitly in the literature as states failing to adopt or internalize a singular norm. ⁴⁹ Yet, many attempts to bring about change have mixed outcomes or otherwise fail in this short-term binary sense, but such ‘failures’ often affect the institutional context for subsequent action and eventual ‘success’. Social change might not result in a singular norm being internalized by nation-states, but it can involve the institutionalization of moral categories and new identities. Early anti-trafficking movements that brought about change in the framing of trafficking and later movements that came to define the individual person as the victim (and not groups) but with no clear norm outlawing trafficking would in these terms be viewed as failures even though they brought about broad institutional change. For example, scholars agree that the 1949 UN convention on anti-sex-trafficking did not result in the UN as an organization or states implementing it, but as we will see it institutionalized definitions of trafficking that were no small accomplishment and that had subsequent effects. Moreover, success marked by establishing a norm that is adopted by states involves myriad aspects from how the problem is framed to the particular solution to varieties and degrees of implementation, some of which might work at cross-purposes with the intent of the norm ⁵⁰ – as we will see with Palermo.

In Figure 1, we illustrate in simplified fashion a model that constructs theoretical explanations of social change based on a tightly coupled causation: intentional actors bring about an intended singular norm.

Figure 1.

Tightly coupled actor-norm model.

Most scholars in practice use a more complex version of this basic model, such as the norm life cycle model pioneered by Finnemore and Sikkink presented in Figure 2.

Figure 2.

Adaptation of the norm life cycle model.

In contrast, a cultural institutional approach builds theoretical interpretations based on conceptualizing the interplay between institutions and actors which results in social change through weak connections between particular actors and particular outcomes (Figure 3).

Figure 3.

Loosely coupled cultural institutional model.

Hironaka conceptualizes this interplay as a ‘bee swarm’. ⁵² Each individual action of particular actors is a bee sting, which may or may not have significant effects, but taken together over the years and across settings there is a swarm of actions that through loosely coupled and weak connections produce change. Figure 4 presents a more detailed depiction of institutional workspaces and interactions and loosely coupled effects through weak mechanisms.

Figure 4.

Cultural institutional model detail.

The cultural institutional model contextualizes the achievements of particular actors who were proximately instrumental in bringing about change and includes and elevates the many actors across time and contexts, who otherwise might be overlooked, as contributing a ‘bee sting’ that was part of a ‘swarm’ that brought about global social change. ⁵³

Implications of the Cultural Institutional Model

Cultural institutionalism is an integrative perspective or paradigm that is useful in bypassing either/or polemics such as actor versus structure by directing attention and analysis to the interplay between institutions and actors. It carries empirical implications, distinct from actor-centric ones, for how the intertwining of actors and institutions plays out; these guide our historical analysis. The general guiding implication is that actors and norms are embedded in institutions. Accordingly, we do not frame our analysis in terms of a singular norm but rather ask how a global problem and its solutions are identified and defined in institutional-historic contexts. We delineate several particular implications for patterns that actor-centric theories likely would miss, that we expect to observe, and that we assess in our analysis of the history of anti-sex-trafficking movements.

Change Is Not Binary But Multidimensional and Consequential

Movement outcomes are not essentially successes or failures because change is a multidimensional process with positive and negative consequences across time. Social movement actors might bring about changes in identities, moral and social categories, and definitions of a problem but not establish a particular norm. From the point of view of a tightly coupled model of a singular norm, this looks like failure. We expect, however, that such changes have subsequent effects, with actors even decades later taking up these institutionalized elements to press for policy changes. Moreover, we expect that successes have limitations and even negative aspects.

Institutions Are Distinct From Organizations

If a movement influences an organization to adopt a policy or to issue a resolution, this might institutionalize an identity, moral category, goal, or practice – even if the organization or member states do not follow through on the change. We expect such cases to have subsequent effects. In particular, we will propose just such an interpretation of the UN 1949 Convention.

Issue Areas Are Influenced by Other Issue Areas

By broadening our attention from a tight causal link between proximate actors and a norm, we see that an issue is affected not only by organizations, meanings, and social categories, within that issue area but also by those in other issue areas. This factor complicates how the problem of sex-trafficking gets defined and what solution-based actions are adopted and implemented. Actions in other issue areas (e.g. migration or labor movements) can reinforce, compete and contend with, or even reframe or co-opt anti-sex-trafficking movements. We will see that issue frames are especially important for interpreting anti-sex-trafficking conventions, protocols, and bureaucratic shifts within organizations throughout the time analyzed.

Change Occurs Episodically Through Institutional Workspaces

Institutional workspaces take the form of international conferences, as actors in specific historical contexts organize to effect changes. Thus, change is episodic in character. We focus on periods and episodes that scholars have identified: late 20th century through the League of Nations leading up to the UN 1949 Convention; the 1949 Convention and the following of a silent period in the 1950s and 1960s; 1970s: Decade for Women, Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), Barry’s book including INTERPOL data and lead up to Vienna 1993; 1993 Vienna: violence against women; Post Vienna, Beijing and lead up to 2000 Palermo.

Anti-Sex-Trafficking, 1875–1937

Anti-sex-trafficking organizations were created during a period of broad institutional change in Europe and North America toward the end of the 19th century. The Christian social, moral reform framework as well as global humanitarianism increased support in the effort ‘to protect women from sexual exploitation’. ⁵⁴ Abolitionist narratives against sexual exploitation, were advocated for and upheld by the IAF established in 1875. Together with traditional purity reform movements, they worked to create space to question lawful prostitution as state-regulated brothel systems were said to enable trafficking. ⁵⁵

Another British-based organization, the International Bureau for the Suppression of the White Slave Traffic (hereafter IB) established formally in 1899 (originally the National Vigilance Association of 1886) addressed the exploitation of women differently. The rhetorical weight of the term white slavery importantly drew on racism and the new sciences of social hygiene which quickly dominated the narrative. The use of white slavery defined the anti-trafficking movement for racialized Western national interests by viewing migrant women, such as Slavic prostitutes as threats to European genetic pools. ⁵⁶ While the IAF looked to challenge state sovereignty and regulation, the IB created international policy that supported the state to protect the ethnic make-up of the nation by keeping ethnic lines separate vis-à-vis the control of reproduction. ⁵⁷ Social purity reform itself merged into the scientism of sexual disease and social hygiene, reinforcing the rhetoric of white slavery and calling for state regulation. ⁵⁸

The broad shift in institutional frames from civil society and social reform to state-centric scientism, eugenics, and social purity captured by ‘white slavery’ favored the IB and regulation. Regulated prostitution dominated discourse, and the IB developed an international agreement in 1904 to combat white slavery. The League of Nations included anti-trafficking in its charter within the scope of humanitarian care especially for women and children, and in 1922, it adopted all existing white slavery accords. ⁵⁹ Although the IAF with its abolitionist position was the first international anti-sex-trafficking institution, it had to adapt to changing institutional cultural contexts by modifying its discourse and priorities. ⁶⁰

Although the IAF seemingly failed, it continued abolitionist efforts at the League, as some of its members were recognized by the League as subject-matter experts and participated in the League’s Trafficking in Women and Children Committee. ⁶¹ This committee conducted and published reports and oversaw on-the-ground investigations which were used as a basis for future standard-setting. ⁶² In 1927 the IAF was able to sway the League and the IB to adopt abolitionist language in part based on the League’s Committee report of evidence that state-regulated prostitution was associated with increased trafficking of persons. Subsequently, the IAF helped draft the 1937 Convention for the Suppression of the Trafficking in Persons and of the Exploitation of the Prostitution of Others. ⁶³ However, the 1937 Draft Convention gained little momentum, something commonly attributed to the outbreak of World War II. ⁶⁴

We are immediately struck by a number of aspects of these movements. The history is episodic with particular moments such as the League’s 1922 policy adoptions, the 1927 report, and the 1937 Convention. An actor-centric approach that looks for tight connections between actors and outcomes may be helpful in focusing on interactions and effects in the short time frame of an episode, but over a longer period the approach is less helpful and depends on what singular norm is identified. For example, one might follow Lochner and define norm emergence at the turn of the 20th century and a tipping point in 1922, but it is a very different norm from what the IAF wanted and from the 1937 Convention. ⁶⁵ If one focuses on the decade leading up to Palermo 2000, a different specific norm still, all of this can be swept under the rug of ‘pre-history’. ⁶⁶

Significantly, what is a failed or successful norm? The 1922 League adoptions might have marked the failure of the IAF to get abolitionist discourse adopted, but it was successful for the IB, and with the aid of the 1927 report the IAF influenced the 1937 Draft Convention. Was the 1937 Draft Convention a failure? It was never adopted, and a norm certainly was not internalized by states.

A cultural institutionalist approach interprets these efforts as part of an institution-actor nexus creating institutional discourses and spaces in which future actors organize for change. Shifting frames from ‘white slavery’ to the victimization of ‘persons’ is a major change in cultural identities and a substantial accomplishment that redefined the problem and affected what solutions were possible. In short, the period from 1875 to World War II supports a nuanced historical narrative based on the intertwining of institutions and actors.

Post-World War II Movements

The United Nations

In the aftermath of World War II, the United Nations charter and the Universal Declaration of Human Rights promoted cultural categories of universalistic individual rights, generally benefiting global economic development and women’s rights movements which favored universal criminalization of prostitution. ⁶⁷ In 1944, the IAF and the IB collaborated to revive the 1937 Draft Convention, encouraging the United Nations to take it up. ⁶⁸ It informed the preamble to the UN’s 1949 Convention for the Suppression of the Traffic in Persons and of the Exploitation of the Prostitution of Others which sought to abolish prostitution and trafficking universally. ⁶⁹ The 1949 Convention deemed that prostitution and traffic in persons were ‘incompatible with the dignity and worth of the human person and endanger the welfare of the individual, family, and community’ stating:

Article 1: The Parties to the present Convention agree to punish any person who, to gratify the passions of another:

(1) Procures, entices or leads away, for purposes of prostitution, another person, even with the consent of that person;

(2) Exploits the prostitution of another person, even with the consent of that person. ⁷⁰

Although newly independent post-colonial states signed the 1949 Convention, the United States and many European states marginalized it and did not sign. The UN struggled to create an effective system for gathering information and monitoring compliance of member countries. ⁷¹ Relatively few countries supplied requested reports, allowing for the claim that trafficking was uncommon and thus not a priority. ⁷² Scholars agree that after the 1949 Convention there were decades of ‘silence’ regarding sex-trafficking. ⁷³ Scholarship using agentic constructivism interprets this as failure, with some defining it as a failed norm cascade and internalization that gets ‘resurrected’ later, while others simply refer to the norm becoming ‘dormant’. ⁷⁴

There are several reasons for this period of silence, and it is not unreasonable to call this a failure; however, a cultural institutionalist perspective suggests that as an institution, the UN 1949 Convention was part of a major cultural shift that established the basis for future work. Moreover, the reasons for this silence contributed to future success. It is necessary to move beyond the consensual interpretation and see that in fact much happened even if unrelated to and in the short-term distracting from sex trafficking as a social problem but which in the long-term were factors in renewed mobilization and change.

Two factors came to dominate this early cold-war period: economic development and human rights. Economic development became the overriding mandate for states. The Bretton Woods system imposed particular models of development on less developed countries, and movements in the Third World engaged these directives. In a way, any new policy priority would have to engage development or be marginalized. At the same time, human rights grew in importance, evidenced by the burgeoning of INGOs marking the emergence of global civil society that institutionalized individualism. ⁷⁵ It commonly is thought that Western core states imposed human rights discourse on the rest of the world; yet, empirical evidence suggests that during the 1950s and early 1960s powerful Western states human rights discourse did not differ in degree from other regions but focused on liberal economic rights. ⁷⁶ Regarding sex-trafficking, DoCarmo documents that capitalist core states still were oriented to old institutional forms such as security and white slavery. ⁷⁷ Less-developed states pressed human rights, but largely around post-colonial issues and apartheid. ⁷⁸ The non-aligned movement that emerged in the Global South in the 1950s was preoccupied with political independence movements and economic development.

Women’s movements pressing for women’s rights flourished in the Global North with a focus on equality, while activists in the Global South focused more on development and local empowerment. International women’s movements led by Global North voices focused on issues of equality and did not pursue anti-sex-trafficking. ⁷⁹ The Commission for the Status of Women (CSW) established in 1946 by the UN’s Economic and Social Council did not take up the issue. By the 1960s an international movement against female genital cutting/mutilation led by the Global North gained strength but was not consistently framed in human rights discourse or violence against women until later. ⁸⁰

Unlike other treatments of this period a cultural institutionalist analysis draws attention to the expansive activism in distinct issue areas that developed diverse cultural elements that became part of the international institutional landscape some of which hindered anti-sex-trafficking mobilization in the immediate term but which facilitated future movements: the 1949 Convention, sex-trafficking defined as a human right issue, women’s rights, women’s empowerment, violence against persons, and development. In the next section we argue that the anti-sex-trafficking movements in the 1970s are interpretable based on these distant indirect and unintentional events that established institutional contexts and actor agency.

International Women’s Movement, 1970s and 1980s

The various elements and activities did not have to produce eventual change, which is historically contingent, but they appear to have come together through several factors including the linking of women’s rights and development, the UN Decade for Women 1976–86, CEDAW – Article 6; and the publication of Kathleen Barry’s book in 1979.

Berkovitch documents that in this period women’s rights were integrated with economic development, exemplified by the overlap of the Second Decade for Development and the Decade for Women, 1976–85. This both mainstreamed women’s rights and reinforced the priorities of the women’s movement in the Global South. At the same time, the UN Decade for Women, the 1979 UN CEDAW, and the CSW broadened the scope of women’s issues. Merry described CEDAW as a ‘transnational social space where actors come together’ and CEDAW monitoring as a ‘powerful site of cultural production’. ⁸¹ The culture produced is a transnational culture constituting spaces such as CEDAW which incorporate and bring together locally situated actor. ⁸² In present terms, they are international workspaces for a range of international women’s activists and provide the institutional context for the revival and formulation of anti-sex-trafficking. In such contexts, differences between Global North and South are not uniformly hindrances but are part of the dynamics pushing the movement forward.

At the same time, activists such as Kathleen Barry forcefully pressed the issue. Barry’s book Female Sexual Slavery published in the year CEDAW was adopted, was influential in reasserting the issue of trafficking and reformulating it as specifically a woman’s issue. Part of its influence is attributable to its inclusion of a 1974 INTERPOL report prepared for the UN Division of Human Rights that had not been released publicly. The INTERPOL report defined traffic in accordance with previous agreements and conventions of 1904, 1910, the League’s 1933 Convention, and the UN’s 1949 Convention. ⁸³ Moreover, the League’s Trafficking in Women and Children Committee and its 1927 data report also influenced future ‘standard-setting’. ⁸⁴ Although weak and not effective, the structures in place made up the institutional landscape during the period of silence. With Barry’s use of the INTERPOL report, we see the intertwining of actor and institution: the power of systematic data and the apparatus to collect those data are both the evolution of the institutionalized culture belonging to past actors and actions and the institutional context for contemporary actors.

It is significant that CEDAW included anti-sex-trafficking Article 6: ‘States Parties shall take all appropriate measures, including legislation, to suppress all forms of traffic in women and exploitation of prostitution of women’. ⁸⁵ CEDAW came to reflect Global North concerns of discrimination in the workplace, gender representation, maternity leave, and access to childcare, slighting Global South concerns of violence against women – domestic violence, bodily harm, rape, and abuse. ⁸⁶ Article 6 thus is something of an anomaly in CEDAW for two reasons. First, by including trafficking, it put an issue prioritized by the Global South on the agenda of the institutional workspace, thereby establishing a new channel of discourse –violence against women – that eventually takes root in Vienna in 1993. Second, Article 6 reflects the 1949 Convention but breaks with its referencing ‘persons’ and reintroduces sex-trafficking as a woman’s issue in part through the influence of women in the Global South. Thus, this history is characterized by weak connections backward to 1949 and forward to policy developments focusing on violence against women.

Articulating Sex Trafficking and Violence Against Women

Increased activity occurred throughout the 1980s and 1990s leading to momentum for the anti-sex-trafficking movement: feminist activists, agency bureaucrats and politicians, academics and experts, workshops and conferences, as well as networks and alliances multiplied. Scholars using an agent-centric constructivism have labeled various of these entrepreneurs. ⁸⁷ Despite this problematic labeling, their research importantly supports an approach that views myriad interactions within cultural institutional contexts leading through loosely-coupled connections to policy outcomes. In particular during this period, the institution-actor nexus led up to the 1993 Vienna Declaration.

Vienna Declaration and Program of Action 1993

The 1993 Vienna Declaration and Program of Action on Human Rights (hereafter Vienna 1993) showcased violence against women. It followed shortly after the CEDAW committee’s 1992 General Recommendation No. 19 to include gender-based violence in the definition of discrimination against women. In contrast to the 1949 Convention which spoke primarily of trafficking in persons, Vienna 1993 explicitly recognized sex-trafficking as an instance of violence against women. ⁸⁸ Later the same year, the UN General Assembly adopted the Declaration on the Elimination of Violence Against Women, reinforcing Vienna and enhancing CEDAW. ⁸⁹ These developments articulated the issue of the crime of sex-trafficking in women with broader gender-based human rights violations and particularly violence against women including rape, sexual harassment, and exploitation; they laid the groundwork for the 1995 Beijing Conference on Women which furthered this linkage. The Vienna conference thus was a significant episodic point in any interpretative narrative.

Problems arise with a tightly coupled narrative because conceptualizing violence against women was not planned at the conference nor intentional but was emergent:

We observed in that . . . the workshops on issues related to violence against women were the most successful . . . they were the workshops where women did not divide along north-south lines, that women felt a sense of commonality and energy in the room, that there was a sense that we could do something to help each other. . . It wasn’t that we built the network in that moment. It was just the sense of that possibility. ⁹⁰

Working within actor-centric constructivism, Keck and Sikkink attribute this emergence to psychological factors: violence against women as a frame ‘caught on’ because it ‘made sense and it captured the imagination’. ⁹¹ Assuming the accuracy of this assessment, it is important to recall that such social psychological dynamics are shaped by institutionalized cultural structures – something ‘makes sense’ in a social order and context. ⁹² Norms, concepts, and policies diffuse when they fit in the institutional structures of a social setting and result in hybridity when articulating with local settings. ⁹³ In Merry’s analysis, the global culture of human rights is translated into and made active in a situated vernacular. Actor-centric approaches importantly analyze the agency of individuals such as Charlotte Bunch at Vienna, and a cultural institutionalist approach emphasizes that their agency is embedded and channeled.

Vienna and the activity leading up to it comprised international institutional workspaces within which women activists with diverse priorities came together resulting in establishing violence against women as a constitutive frame. By defining sex-trafficking as a problem of violence against women, Vienna 1993 marks two large steps from mid-century: sex-trafficking is a woman’s issue and it is violence. The cultural institutionalist interpretation, based on the intertwining of institutions and actors effecting change through weak connections often in unintended, episodic ways, highlights the continuity of the actions of myriad actors and not just the proximate actors within an episode.

Fourth World Conference on Women, Beijing 1995

The articulation of violence against women and sex-trafficking was further institutionalized during the Fourth World Conference on Women held in Beijing in 1995 which consistently labeled trafficking in women and forced prostitution as violence against women. It referenced the UN 1949 declaration, recommending that it be ‘reviewed and strengthened’. ⁹⁴ The CSW worked to implement 12 critical areas of concern into Beijing’s Platform for Action, one being violence against women. The Beijing Platform for Action adopted three strategic objectives; the first two (D.1 and D.2) are to take actions to prevent and eliminate violence against women and to study the causes and the effectiveness of measures to combat violence against women. The third strategic objective is D.3: ‘Eliminate trafficking in women and assist victims of violence due to prostitution and trafficking’. ⁹⁵ The Beijing Declaration in general and strategic objective D.3 in particular firmly established the elimination of sex trafficking as violence against women.

Disarticulating Sex Trafficking and Violence Against Women

Gender Mainstreaming and Bureaucratization

The Beijing Declaration and Platform of 1995 was also significant for promoting women more broadly within all UN bodies. It contains language that connects sex trafficking to forced labor, drug and arms trafficking, and international organized crime, and it appeals for strengthening enforcement authorities. The general effect was gender mainstreaming: the call to include a gender perspective in all policy areas that became a mandate within the UN for managing agencies. ⁹⁶ It resulted in organizational and bureaucratic changes in anti-sex-trafficking involving several agencies. The Beijing follow-up report of the Secretary-General gives an intimation of the changes required:

The High Commissioner has identified trafficking in women and children for purposes of sexual exploitation as a priority issue. . . . Cooperation will be sought with the Centre for International Crime Prevention at the United Nations Office at Vienna to cover action to combat international trafficking in women and children. Both the Division and the Office of the High Commissioner will contribute to the study on the criminal aspects of trafficking in human beings, which is being prepared by the United Nations Interregional Crime and Justice Research Institute on behalf of the Office for Drug Control and Crime Prevention. ⁹⁷

Gender mainstreaming and the prominence of bureaucratic management illustrate the difficulty in labeling an outcome as a success or a failure because they have mixed effects. Arguably, anti-sex-trafficking policy is strengthened because it is incorporated into other anti-trafficking operations such as immigrant smuggling, money laundering, drug trade, and trafficking in weapons. ⁹⁸ At the same time, implementing gender mainstreaming in all policy areas tends to blur the focus on anti-sex-trafficking as a violence against women issue and shifts advocacy from grassroots women organizations to bureaucrats and technocrats. ⁹⁹ Gender mainstreaming unraveled the articulation of the issues of sex trafficking and violence against women – sex trafficking was framed as transnational organized crime, rather than gender violence.

Palermo Protocol 2000

This shift in anti-sex-trafficking was profoundly affected by international regimes in migration, labor, and human rights, which had distinctive approaches and meanings not framed by gendered violence. The shift was formalized bureaucratically with the Palermo Protocol (the Protocol to Prevent, Suppress, and Punish Trafficking in Persons Especially Women and Children), which relocated anti-sex-trafficking from the original women-oriented organizations and agencies to the auspices of the UN Office of Drugs and Crime. On the one hand, this bureaucratization strengthened the institutionalization of anti-sex-trafficking and the likelihood of authorities taking enforcement seriously. On the other hand, it institutionalized the reframing of anti-sex-trafficking which becomes one of many crimes any agency must consider. ¹⁰⁰ It promulgated new definitions and language.

‘Trafficking in persons’ shall mean the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs. ¹⁰¹

The Palermo Protocol’s definition is broader than Vienna and Beijing as it returns to the 1949 language of ‘person’ and away from ‘women’. It also groups sex trafficking with other types of human trafficking (e.g. migrant smuggling) and trafficking more broadly such as drug and weapon trafficking. The disassociation of sex-trafficking from violence against women is stark. For example, the phrase ‘violence against women’ is never mentioned in the Palermo Protocol. The words ‘violence’ and ‘rape’ are never used. ‘Sexual exploitation’ and ‘prostitution’ are stated once (in the above excerpt) and never mentioned again. The Palermo Protocol does not explicitly mention the historical roots of how trafficking was defined as discrimination against women in Article 6 of CEDAW. Additionally, the word ‘women’ is only used 8 times in the 10-page document and always in the phrase ‘especially women and children’ as seen in the title. There is no section of the document dedicated to women-specific concerns of human trafficking. Finally, the focus on crime makes the language surrounding the attention to victims much thinner than the Beijing Declaration. For instance, the latter calls for ‘actions to be taken’ including addressing root factors such as tackling the industry of sex tourism and refers to an array of pro-active rehabilitation and healing initiatives. ¹⁰² Palermo is less action-oriented and rather suggests state parties ‘consider implementing measures’ to assist with recovery. ¹⁰³ The discourse used in previous international documents clearly shifts under the Office of Drugs and Crime.

Was the aftermath of Beijing with gender mainstreaming and bureaucratization culminating in the Palermo Protocol a success or failure? Palermo led to a cascade of international agreements and state legislation. It was successful in empowering anti-labor trafficking efforts in addition to sex-trafficking. Yet, hand-in-hand with gender mainstreaming it had mixed effects and unraveled the articulation of sex-trafficking from violence against women, arguably a setback. Success or failure? The reality is more complicated, and this is the point: any theoretical approach needs to take this complexity into account through interpretative narratives that eschew binary labels. It is imperative to understand not only the cultural institutional contexts (the immediate workspaces) of the actors but also the broader world institutional contexts.

The history of the anti-sex-trafficking movement suggests that the Palermo Protocol cannot be viewed as an end point. We introduced Palermo as such to dramatize that the historical analysis shows it to be neither a clear success or failure nor a definitive end point. It is not the intended culmination of the short-term narrative (CEDAW, Vienna) let alone the 100-year history, nor does the history stop with it. Instead, the lead up to Palermo, Palermo itself, and its aftermath illustrate the messy twists and turns and ongoing intertwining of actors and institutional contexts that we attempt to understand.

Theoretical Discussion

What differentiates cultural institutionalism from actor-centric approaches is that it focuses on the intertwining of actors and institutions. We have used this perspective to analyze how the interweaving of institutions and actors produced a 100-year history of international movements against sex-trafficking. The resulting interpretative history identifies patterns of influence that support the implications of cultural institutionalism and that other perspectives have slighted or missed: actors and norms are embedded in institutions, change is multidimensional with institutional effects that often are long-term and not easily labeled as success or failure, an issue area is affected by its weak connections to other issue areas, change occurs episodically through institutional workspaces as actors in specific historical contexts organize to effect change. We discuss these contributions of our analysis, highlighting the contrast with an actor-centric approach.

Actors and Norms Are Embedded in Cultural Institutions

Actor-centric theories rely on actor agency as the driving force for socio-political change, and they assume tight connections between intentional actors and intended outcomes. They make strong assumptions about actor rationality and efficacy and direct our attention to short time frames and to prominent figures proximate to a focal outcome, commonly a singular norm. This approach is problematic given that actors and norms are neither autonomous nor singular but rather are embedded in institutional structures shaped by prior often temporally distant actors. In contrast, a cultural institutionalist perspective emphasizes this embeddedness. Using this perspective to guide our analysis of the long-term history of the anti-sex-trafficking movement, we have identified and modeled the intertwining of intentional actors and the contextual effects of institutions: how institutions constitute and direct actor agency through which actors can produce new institutional elements. Similarly, normative goals are not the same throughout the history of the anti-sex-trafficking movements and any identifiable norm cannot be analyzed separately from its institutional context – from the order of things in which meanings are constructed. The anti-sex-trafficking movement was created during an era of competing INGOs; evolved under the League of Nations, the early United Nations and the Universal Declaration of Human Rights; setting the context for the Decade for Women, CEDAW, the Vienna Declaration, and the Beijing Declaration amongst others. Exemplary actors such as Kathleen Barry were empowered after decades of effort, organization and institutionalization, and the emergent results often were unintended. The power of a cultural institutional approach is seen in that if we began our analysis in the 1970s with the prominent activists and major international successes, we would have a limited understanding of global governance change.

Multidimensional Change and Institutional Effects

Global social change is multidimensional involving definitions, frames, goals, and obligations that define the social problem and possible solutions. Cultural institutionalism places these institutional structures as central to any analysis and identifies patterns that would have been missed otherwise. The present study shows that the early history of anti-trafficking involved cultural categories of social hygiene, eugenics, white slavery, and anti-immigrant sentiments. These group-centered definitions of the problem were replaced with a more individualist formulation in the 1937 Draft Convention and then in the 1949 Convention. Neither produced a norm taken up by IGOs or states. An actor-centric approach that focuses on anti-trafficking as a singular norm internalized by actors assumes binary outcomes – actors are either successful in bringing about a norm or not – and would label these changes as failures, pushing them to the margins. A cultural institutionalist approach, in contrast, drawing attention to the multidimensional nature of norms and change interprets these changes as major historical accomplishments and results in identifying connections to subsequent successes that otherwise is overlooked.

When an IGO promulgates a new definition of a problem and its solutions, when it adopts a policy or issues a resolution, it is both reflecting and affecting the broader cultural landscape. It creates an institutional workspace in which a variety of types of actors with different normative position can work on the issues. When a formal policy is adopted and states formally sign on, if neither the IGO nor states actually act on a policy, it is reasonable to view the policy as failed, especially from the point of view of social movements that have pressed for that policy. Nevertheless, once established, these new institutionalized elements can be taken up and reasserted. This distinction is illustrated in the UN’s 1949 Convention. Neither the UN nor the member states implemented it. Yet, its definition and framing of the problem influenced activists, the UN, and states to come together 30 years later to identify and solve the problem of sex-trafficking. Viewed in terms of institutional workspaces, the 1949 Convention institutionalized the issue as the rights of the individual person, and the subsequent innovation was the reframing in terms of the right of women in the language of CEDAW, Article 6. During the later period we see the powerful effects of the INTERPOL report published in Barry’s book as part of a loosely coupled and global institutionalized progression of how data collection and reporting practices evolved from the United Nations and the League of Nations. To reiterate, the cultural institutional perspective directs our attention to just such weak, long-term connections that actor-centric theories focusing on direct, intentional links would miss.

International Issue Area Complexity

The institutional model, and in particular Hironaka’s concept of a bee swarm of distinct influences, looks beyond those actors who explicitly identify as working against sex-trafficking to understand the effects of weak connections. The revival of attention to sex-trafficking, whether in terms of Barry’s work or CEDAW, did not happen out of thin air. The successes of women’s movements in the Global North, the expansion of human rights discourse led by the Global South, the burgeoning of INGOs worldwide, the convergence of women’s rights and development in the UN and mainstreamed in development IGOs, and Global South women’s movements all contributed to this revival. Moreover, the Palermo Protocol was in part the result of gender mainstreaming and bureaucratization that consequentially disconnected sex-trafficking from its association with violence against women and instead categorized sex-trafficking as transnational organized crime. This in turn handed responsibility and influence over to the UN Office of Drugs and Crime, the International Office of Migration, and the International Labor Organization. By understanding better the cultural institutional effects that can work at cross-purposes, we are in a better position to understand the current controversies even among activists surrounding anti-sex-trafficking.

Institutional Workspaces in Episodic Change

Long-term change in global governance is episodic in character. Actor-centric theories draw our attention to a particular episode, guiding the research to identify a successful outcome and construct a linear story that directly connects it to proximately prior intentional actions. Although insightful, this approach misses the episodic character of change and the connections from one episode to another and thus the need for a longer-term interpretative narrative. Even in the short time frame of a particular episode, these approaches have difficulty interpreting emergent and unintended qualities of change. A major contribution of our analysis is a compelling narrative of the social forces converging in a particular episode, illustrated by Vienna 1993 and subsequently Palermo 2000.

We use the concepts of institutional workspaces and the swarm of myriad actors to capture these dynamics leading up to Vienna 1993. International conferences organized by IGOs comprise a time-framed institutional workspace often defining episodes. There are various intentional actors pursuing their interests and goals, often at odds with each other. The tensions between international frames and local ones, between the different priorities of women from the Global North and South were present in Vienna. The conference’s defining sex-trafficking as violence against women was an emergent outcome and illustrates the intertwining of actors and institutions and the bee swarm dynamic: the outcome could not have happened without agentic actors pursuing particular goals, but the outcome cannot be tightly linked to any given autonomous actor. Neither was the outcome a singular norm, but rather a definition and a set of solutions.

The episodic character of change and the problem of defining a singular end point is illustrated in our analysis of the disparate forces converging at Palermo 2000. Palermo reframed sex-trafficking in terms of criminal trafficking generally and moved authority over the problem and solutions to crime agencies involving the bureaucratization of solving the problem through anti-crime. While in many ways successful, in other ways it comprises yet another twist and turn in the continuing history of anti-sex-trafficking.

Conclusions

We developed a cultural institutionalist approach that builds upon recent theoretical innovations in the field and, consistent with critical theory, problematizes not only socially created norms and institutions but also the socially constructed modern subject. We adapted theoretical concepts of workspaces and bee swarm to conceptualize actors within institutional contexts. We used this perspective in the interpretative historical analysis of international anti-sex-trafficking movements, from the late nineteenth century to the Palermo Protocol and its aftermath. The advantage of cultural institutionalism is that it avoids the polemic of institution/structure versus actor and is curious about how they are dialectically related. The power of this perspective is seen in its utility in identifying the several empirical patterns in the international anti-sex-trafficking movements and global governance changes, which heroic narratives of actor-centric theories would have missed.

Institutionalist and actor-centric approaches technically are meta-theories or paradigms that define proper theoretical explanation and what the researcher should look for. They are judged by how useful they are in developing and testing theories that produce innovative findings. Once pointed out, such findings can be translated post hoc into the language of a competing paradigm, but the latter was not the source of the theoretical research to make those connections in the first place. Even then, such translations often are strained. The findings of our historical analysis might be translated into an actor-centric approach albeit with some difficulty, but it is not suited to ask the kinds of questions that would have brought us to these findings in the first place. ¹⁰⁴

The cultural institutionalist perspective and the historical narrative are significant not just for theoretical research but also for critically engaging social and policy changes. By bringing in institutions – the cultural order of things – in this way, we are able to more adequately critique them. When faced with the very real global problem for women and girls that is sex trafficking, and the contentions over the nature of the problem and of the policy solutions, we must critically interrogate the frameworks, categories, and bureaucracies that shape and address the problem. It is important to see how they shape the subjectivities, intentions, and efficacy of actors, and how the intertwining of institutions and actors construct a global problem and its solutions. A theoretical approach that recognizes the embeddedness of actors and global governance policies and the loosely coupled relationship between actors and outcomes is necessary. We offer the present analysis using a cultural institutionalist approach as a step in that direction.