Abstract
Global framework agreements (GFAs) have the potential to alter the practice of labour relations in multinational companies (MNCs). Analysis of the launching of GFAs and their negotiations, as well as their role in setting labour standards has already received much attention in the literature. This article extends these analyses by examining how GFAs’ procedural norms shape implementation in practice. Based on qualitative case studies of 12 MNCs, we develop a typology of procedural norms and analyse how they differ in terms of implementation. Our findings show that procedural design – particularly the distinction between event-driven and systematic monitoring and the establishment of distinct transnational arenas – is closely related to how implementation practices are organised. We conclude by discussing what these configurations imply for the potential to institutionalise transnational levels of labour relations in MNCs and further questions related to international industrial relations research and practice.
Introduction
From an industrial relations perspective, global framework agreements (GFAs) are an interesting instrument of transnational labour regulation, as they constitute a pathway towards transnational labour relations in multinational companies (MNCs). On the basis of private norms, GFAs allocate ‘rights’ related to information, monitoring, consultation and problem-solving to employee representatives. In the absence of GFAs, these options would not be available to unions because the legal obligations required for MNC regulation would be lacking. Two features in particular characterise GFAs: they apply to the operations of MNCs – and in some cases to their suppliers – and they are negotiated between multinational companies and Global Union Federations (GUFs) (Hadwiger, 2018). While the dissemination of GFAs has remained limited – 132 agreements were in force at 104 multinational companies by the end of 2020, the majority headquartered in Europe (Haipeter et al., 2021) – this sort of agreement serves as a pioneering model of transnational labour regulation inasmuch as it contributes to the recognition of (global) unions by MNCs as a negotiating party for transnational and global issues.
The relevance of GFAs for transnational labour relations in multinational companies depends crucially on their implementation. Therefore we ask: How do GFAs’ procedural norms guide the practice of implementing the agreements, and what do different procedural configurations imply for the constitution of transnational arenas of labour relations within MNCs? In an attempt to answer these questions, we first summarise the literature on GFA implementation around procedural norms and what these procedural norms ultimately imply for implementation. All GFAs contain two sorts of formal rules: substantive norms and procedural norms. Substantive norms typically codify what labour standards a GFA covers, for example, ILO core labour standards. Procedural norms, by contrast, specify how these standards are to be applied, monitored and renegotiated, including what happens in case of violations of substantive norms. The two types are thus closely interrelated, as procedural norms describe how the substantive norms are put into practice.
Second, based on detailed qualitative analysis of 12 selected European MNCs – predominantly, but not exclusively, with headquarters in Germany – we develop a typology of procedural norms. We differentiate between procedural norms as codified in GFAs in terms of the organisational structure designed for implementation – established arenas around extant bodies of worker representation vs distinct and independent embodiment of GFA-related issues – and process characteristics, referring to whether processes are envisaged to be event-driven or to be steered systematically. Third, we examine whether and how these norms vary across GFAs, and the extent to which different types of procedural norms cluster into distinguishable patterns of implementation practice. On these grounds, we discuss, fourth, what our GFA-based findings imply when it comes to the constitution of transnational arena(s) of labour relations in MNCs more generally, and what peculiar contribution the designing of procedural norms can make within such processes. We conclude by delineating the political implications of our findings and pathways for future research.
Procedural norms and implementation
In accordance with a longstanding definition in industrial relations, procedural norms are about how substantive norms on work and employment are developed and implemented (Dunlop, 1958). In the GFA context, this includes all norms concerning information, training, monitoring, consultation and joint problem-solving, as well as the formal set-up of the arenas in which management and trade unions – or other worker representatives – negotiate about these issues. Procedural norms are particularly important for understanding GFAs as a voluntary, private institution in a legal void when it comes to international law. GFAs are not legally enforceable through judicial or industrial action, such as strikes, and therefore are voluntary in nature (Seidman, 2007); at the same time, they establish an institutionalised dialogue between management and worker representatives, in contrast to CSR measures that are decided on unilaterally by companies alone (Lévesque et al., 2018). This intermediate status raises the question of how such agreements are implemented in practice, in terms of how the actors perform and organise around the procedures laid down in the agreements.
Research on GFA implementation has focused primarily on the monitoring of labour standards and the processing of cases – in other words, the handling of violations of minimum standards stipulated in the GFA – while neglecting an explicit comparative analysis of the procedural norms and how these shape implementation practice. Procedural rules have been interpreted as (i) a central prerequisite for GFAs to become an object of social practice in MNCs at all (Sydow et al., 2014); (ii) necessary for sustained monitoring by involving employee representatives in oversight bodies (Bourguignon et al., 2020); (iii) enablers of joint learning processes among management and unions in the MNC (Barreau et al., 2020); and (iv) a key for attributing moral-political authority to different actors and for dealing innovatively with labour rights violations on the ground (Casey et al., 2025). Yet, while this literature demonstrates that procedural arrangements matter, limited attention has been paid to the details of how different configurations of procedural norms shape implementation practices.
Another strand of literature focuses on the formal analysis of agreement texts (for example, Hadwiger, 2018). Such analyses usually examine the substantive topics covered by agreement provisions, the references made to multinational standards such as ILO conventions or OECD and UN guidelines, or the mentioning of single instruments, such as supply chain audits. Agreements are thus shown to vary, for example in terms of whether they contain labour rights beyond the ILO’s core labour standards, whether they include explicit rules for implementation, or whether the agreements apply solely to the contracting company or also extend to its suppliers. However, a textual analysis alone neither illuminates which norms are likely to shape implementation practices in precisely what organisational settings, nor what different procedural designs imply for the emergence and forms of transnational labour relations in MNCs.
However, previous research findings are indirectly related to our question, pinpointing a range of factors that may hinder sustained implementation practices under GFAs.
(a) Implementation is dominated by management. For example, monitoring measures conducted exclusively by management have proven to be of limited use with regard to implementation practices. Bourguignon et al. (2020) use the case of Orange to explain the limits of a management-dominated information channel, showing that the quality of the information can hardly be ensured without cooperation with local employee representatives. At the same time, Fichter and McCallum (2015) analyse the case of ISS, in which the trade union federation UNI Global Union completely handed over the reviewing of implementation to management, with the result that there was not a single report of a violation of the agreement at the time of the investigation (similarly Fichter et al., 2011).
(b) Implementation is dominated by actors at company headquarters. In an earlier paper, Davies et al. (2011) argue that monitoring by central actors alone can hardly lead to consistent practices across local sites. However, it remains unclear in their analysis how the active involvement of local employee representatives can be achieved in practice. For example, when violations of labour standards have been identified, a process of case handling ought to be initiated. In such cases, responses are often launched from headquarters to obtain more detailed information and to involve local stakeholders in resolving the issue (Mustchin and Lucio, 2017). Unsurprisingly, research highlights that the handling of violations can be a lengthy and uncertain process (Niforou, 2014; Williams et al., 2015) and that local issues must first be confirmed as sufficiently serious before they are escalated to the corporate level (Davies et al., 2011; Gregoratti and Miller, 2011). Furthermore, case handling can be influenced by institutional differences in employee representation at central level, such as the differences between monistic and dual systems of employee representation (Helfen et al., 2016).
(c) Implementation lacks a stable organisational anchor. Implementation and monitoring may not be anchored in an organisational unit and take place only indirectly in the form of regular meetings or even completely ‘ad hoc’. Fichter et al. (2011) observe that in around 41 per cent of the agreement texts they analysed, regular meetings serve as the only means of monitoring. Seignour and Vercher (2011) explain, using the example of Rhodia, that even site visits could not reliably guarantee the monitoring of local supply chain relationships. Another study emphasises that trade unions and employee representatives at company headquarters play a particularly important role in successful case management (Helfen et al., 2016). Other studies point out that weakly regulated approaches to case handling lead to delayed and hesitant responses to reported violations, undermining local actors’ confidence in the credibility of GFA implementation (Helfen and Sydow, 2013; Riisgaard, 2005).
(d) Implementation lacks resources. Even where organisational anchoring has been formally established, implementation practices may still be deficient because of capacity constraints or resource conflicts among local actors. Niforou (2012) describes how meetings of a forum agreed upon in the Endesa GFA failed to take place because competing local trade unions could not agree on who should represent them. Bourguignon et al. (2020) point out the practical difficulties of involving trade union networks when GUFs lack local affiliates or the resources needed to participate in or sustain the network.
However, while these authors argue that the realisation of GFAs depends less on formal provisions than on the situated practices of actors embedded in loosely coupled, multi-actor constellations, we contend that procedural norms play a more structuring role than previously assumed. In particular, there is limited comparative understanding of how procedural design shapes the organisation and routinisation of implementation activities that are relevant for transnational industrial relations in MNCs. While the literature has differentiated procedural arrangements in terms of unilateral versus joint approaches (for example, Sydow et al., 2014), monitoring versus more participatory approaches (for example, Bourguignon et al., 2020), or the presence of transnational union coordination (for example, Barreau et al., 2020), we propose to shift the focus to how procedural norms routinise implementation practices over time and through specific organisational structures.
By defining arenas, allocating responsibilities and specifying procedures, procedural norms provide organisational and institutional resources that shape how actors interact, exchange information and monitor compliance. This perspective does not deny actor agency and organisational dynamics, as resources can be used more or less extensively, responsibilities performed in different ways and different interpretations attributed to procedures. However, it highlights similarities between cases with similar process norms in terms of organisational structures and process characteristics, showing how procedural design structures transnational implementation practices in terms of arenas, responsibilities and routines, and how these arrangements shape ongoing interaction between management and labour representatives at transnational level. The following sections empirically explore this question in greater detail.
Methods
We draw on 12 case studies conducted as part of a research project funded by the Hans Böckler Foundation. The comparative case study design allows for an in-depth analysis of procedural norms and implementation practices across different MNCs. For reasons of comparability and feasibility, all cases are situated in the organisational domain of IndustriALL Global Union. The study focuses on GFAs with observable implementation activity, irrespective of scope or intensity. Agreements for which we could not identify any implementation practices were excluded.
Most cases are headquartered in Germany, complemented by two companies headquartered in Belgium and Sweden, respectively, but with substantial operations in Germany (Chemicals and Paper). This selection reflects the comparatively high prevalence of GFAs signed by German-based MNCs and allows the observation of variations in procedural design and implementation practices under similar institutional conditions, because the potentially observed variation is not driven primarily by institutional differences between countries. At the same time, analysing differences in procedural norms in terms of organisational structures and process characteristics between the cases allows us to identify patterns or procedural configurations of practices. Table 1 provides an overview of the companies in our study. To protect the identities of both firms and interviewees, company names are anonymised.
Overview of the sample.
Source: Authors’ presentation.
Company sizes range from fewer than 50,000 to over 100,000 employees. Five GFAs were signed in the early 2000s, while the remainder were concluded from 2012 onwards. In one case (Equipment), implementation structures were still in development at the time of data collection. At Composite the agreement centres on a formalised regional social dialogue underpinned by a transnational union network.
The case studies are based on 81 semi-structured interviews conducted with representatives from GUFs, national trade unions, members of works councils at national level, European works councils (EWCs) and – if existing – world works councils (WWCs) and, finally, local union actors at selected European and foreign sites (such as Tunisia, the USA, Chile, Brazil, India, China and South Africa) (Table 2). Wherever possible, interviews were also conducted with management representatives, primarily from HR departments at corporate headquarters who were responsible for GFA-related implementation processes. This was complemented by an analysis of the GFA documents for each case. The interviews focused on: (i) implementation practice, (ii) the roles and interactions of the various actors in implementing, and (iii) the application and effects of the GFAs at local level. Because of the COVID-19 travel restrictions in place at the time of data collection, the interviews were conducted online via digital video conferencing. The interviews were transcribed and analysed using qualitative content analysis, combining deductive coding with inductive insights to identify patterns in how actors engage with procedural norms.
Interviews.
Note: Some interviewees held multiple roles across organisational levels. Our classification is based on the primary function that was the focus of the respective interview.
Source: Authors’ presentation.
Procedural norms in global framework agreements
Our analysis examines the procedural norms of GFAs and implementation practice in our sample companies. We concentrate first on the configuration of these norms, which define both the organisational structures through which implementation occurs and the process norms regarding information-sharing, monitoring, consultation and joint problem-solving.
Regarding organisational structures, procedural norms specify the arenas and actors responsible for implementation. GFAs may establish distinct, separate bodies – typically in the form of steering or monitoring committees – to facilitate coordination between management and employee representatives. These committees provide a dedicated transnational arena around the GFA within the multinational company. Alternatively, the implementation of GFAs may rely on established arenas of communication and negotiation, such as the meetings of world works councils or European works councils. Although EWCs and WWCs are transnational in nature, GFAs are not the main purpose of these bodies and their existence is not tied to them. In German multinational companies such established arenas may also include group or central works councils, as well as the trade unions responsible for the respective sectors.
Based on a comparative analysis of all GFA texts that are currently recognised as valid by the Global Union Federations, we have identified contrasting types of procedural norms that are mentioned explicitly in the texts. From these we derived two ideal-types of procedural norms, which we call ‘event-driven’ and ‘systematic’. Event-driven norms are related textually to reports of specific violations of labour rights. Detection of such violations may occur ad hoc, for example, through reports from affected subsidiaries or trade unions, or via single channels of communication, such as grievance hotlines that allow individual employees to report them, often anonymously. Systematic norms, by contrast, are textually related to organisational routines and operations. This includes, for example, regular site visits, or audits, but also provisions for developing or strengthening local employee representative structures and trade unions. In practice, GFAs contain a mix of both. For instance, while an individual complaint may activate an ad hoc process, it may also trigger an organisational routine for examining working conditions across different locations.
As already shown, alternative ways of characterising procedural arrangements have been proposed in the literature, including distinct unilateral and joint approaches, monitoring versus more participatory approaches, or the involvement of transnational union coordination structures. These perspectives capture important aspects of GFA implementation. The two dimensions used in this article, based on our GFA analysis, complement these approaches (event-driven versus systematic) by focusing on how procedural norms routinise implementation over time and through which organisational structures this routinisation is stabilised. This focus is particularly relevant for understanding what GFA implementation practice may imply for the potential to institutionalise new levels of labour relations in multinational companies.
Based on these two dimensions – whether implementation is primarily event-driven or systematic, and whether it occurs through distinct transnational arenas or in existing arenas – four varieties can be identified analytically, three varieties of which we observe across the 12 cases in our study (Table 3).
Procedural norms of the GFAs in the case studies.
Source: Authors’ presentation.
We did not find any cases in which systematic implementation was assigned to existing arenas. This absence suggests that systematic procedures may be difficult to sustain within arenas whose agendas are shaped by a broad range of issues and responsibilities. In addition, it should be noted that a four-fold classification is not all-encompassing and remains selective, particularly with regard to more recent agreements in which event-driven and systematic approaches are sometimes interlinked. The following section illustrates the different types and variations based on our case studies.
Type 1: event-driven process norms in established arenas
Construction is an extreme example of an event-driven approach. The agreement is brief; it spans just one page and includes only three key provisions regarding procedural norms: (i) the three signatories on the employee side – the GUF, the German trade union and the German central works council – support the company in complying with the agreed standards; (ii) violations are to be reported to the executive board for investigation and remedial action; and (iii) questions of interpretation regarding the application of the agreement are to be resolved jointly on a case-by-case basis. Overall, the GFA outlines an ad hoc handling of violations, in which unions report violations and the executive board is responsible for addressing and resolving them. Trade union involvement is limited to reporting violations and clarifying questions of interpretation in the application of the agreement with management.
The procedural provisions are somewhat more elaborate in the other three cases (Cables, Machines, Metal) of this type. In all three instances, the agreement stipulates that implementation and compliance with the principles of the GFA are to be included in the reporting and consultation processes during the annual meetings of the existing EWC (Cables, Machines) or WWC (Metal). The agreements provide limited details on these provisions, however, and do not specify concrete tools for monitoring or responding to violations of labour standards. In the case of Metal and Machines, management is, however, required to incorporate labour standard reporting into their management systems; here management-driven CSR approaches and GFA overlap.
Type 2: event-driven process norms in distinct transnational arenas
By contrast, GFAs that establish a distinct transnational arena exhibit significantly more detailed provisions. This is especially evident in the cases of Steel and Equipment, in which various grievance channels are specified for reporting violations. Steering committees constitute the centre of the GFA process in both cases. In the case of Steel it includes the chair and deputy chairs of the group works council, the chair of the EWC, and representatives from the German trade union and IndustriALL Global Union. The chief HR manager is obliged to report annually to the committee on implementation progress and reported and unresolved violations, for which the committee can then propose solutions. The committee is also authorised to conduct site visits in a selected country once a year. Similar arrangements can be observed in the cases of Paper and Electronics, in which dedicated transnational arenas have likewise been established to manage the implementation of GFAs, and the agreements set out procedures for handling complaints.
Type 3: systematic process norms in distinct transnational arenas
The third type of regulation combines new transnational arenas with systematic implementation procedures. In the case of Pencils, the core of the agreement is a monitoring process to be carried out by a steering committee composed of representatives of the company, the GUF and the German trade union. The committee is assigned the central task of monitoring compliance through biennial audits of all sites. Local trade unions may be explicitly involved. Additionally, the steering committee is required to meet at least once a year to discuss any unresolved issues and to agree on appropriate measures for their resolution.
At Chemicals, the steering committee is composed on a global basis and consists of company representatives, representatives of IndustriALL Global and company employee representatives from North and South America, Europe and Asia. GFA compliance is monitored through annual site visits conducted by the steering committee. Local union representatives and employees may be involved, reinforcing the participatory character of implementation. The cases of Retail and Composite deviate slightly from those already mentioned. In Retail, procedural norms focus primarily on capacity building at suppliers, while in Composite the agreement centres on South America and establishes new transnational communication and problem-solving mechanisms in this region.
The practice of implementing the agreements
This section explores whether and how the procedural standards stipulated in the GFA influence implementation as a social practice. For this purpose, we analyse the specific patterns of action according to the three types of procedural norms identified in our case studies.
Implementation practice in type 1
In cases in which GFAs include only event-driven process norms and do not establish distinct transnational arenas, implementation tends to be highly contingent on actors’ priorities and attention. The following quote from Construction represents an extreme instance of such contingent implementation: Of course, that’s a question that has to be weighed against other concerns that you’re dealing with in the company. Let me put it this way: if you’re in the final phase of a collective bargaining round and somehow this and that is pending, then you’re not going to place an individual GFA case in that moment. (Construction, Headquarters, Trade Union)
In the absence of more detailed procedural guidance, implementation practices remain highly contingent on situational factors and actor discretion. Complaints and violations are typically addressed by a local trade union with the GUF, which then contacts the German trade union at its headquarters. The national trade union then assesses the relevance of the complaint in light of broader strategic priorities. Union representatives emphasise that local labour conflicts gain traction at headquarters only when they receive wider international attention.
The Metal case falls under this type but shows somewhat more active implementation practice. Nevertheless, practice in this case is highly contingent on the company’s CSR initiatives and the more active role of the German group works council. As part of CSR audits, which are carried out by the corporate compliance department, labour standards are occasionally reviewed by auditing on-site, with sporadic participation from employee representatives. At the same time, the German group works council is typically informed in cases of violations of labour standards, often in direct encounters with management.
Emanating from the national employment relations arena at headquarters, these actors tend to intervene to address GFA-related issues. This illustrates how different implementation practices can emerge even within the same institutional context, depending on how GFA procedures interact with parallel governance arrangements, such as management-driven CSR. For both corporate CSR and the works council, however, GFA implementation remains an exceptional issue rather than routine. Management attributes only a limited additional value to the GFA compared with the company’s CSR initiatives. At the same time, works councils do not stress a more reliable implementation practice either, because the company’s WWC prioritises locational issues and corporate decisions, relegating GFA implementation to a marginal role in the body’s meetings.
Implementation activities at Machines and Cables fall somewhere in between. In the case of Cables, as stipulated in the agreement, the EWC is involved in implementation. However, implementation at this level is in practice limited to an annual review with management, during which management presents the number and type of reported cases, and the measures taken. Employee representatives are not involved in problem-solving or substantive case handling.
At Machines, information on emerging issues is generally channelled to the group works council through the German trade union, the GUF, or directly by affected employees. The group works council then follows up on complaints and engages in dialogue with company management to address unresolved issues. However, this engagement remains contingent on its willingness and capacity to act in each particular instance of a complaint. This case also pinpoints the issue of resource constraints. The German works council lacks the capacity to engage in comprehensive and systematic monitoring across multiple global regions. These resource requirements are not explicitly accounted for in the GFA procedural norms, either in terms of process rules or organisational structures.
Implementation practice in type 2
A different pattern of implementation practice can be observed when GFAs explicitly introduce distinct transnational arenas responsible for GFA implementation. Compared with the first type, implementation is less dependent on situational priorities within existing arenas, as responsibilities for handling cases are concentrated in a dedicated steering committee. At Steel and Equipment, employees can file complaints via an electronic reporting system, or issues can be raised by unions to the GUF, the German trade union or the works council within the steering committee if local resolution fails.
In both cases, reported violations of labour standards are reviewed at least quarterly in face-to-face meetings of the GFA steering committee, with extraordinary meetings convened in urgent cases. Investigations typically follow two parallel paths. While management attempts to obtain further information on the management side, employee representatives reach out to the complainant and local trade unions to clarify the case. The steering committee jointly assesses the findings and determines follow-up measures, including potential site visits, which so far have taken place mainly in countries in which conflicts were reported.
Implementation practice at Electronics is fairly similar. Site visits are also conducted jointly by employee representatives and central management, but often focus on specific issues raised in individual cases. The visits include plant tours and discussions with employees and local management. Interviewees from both central management and the German central works councils highlight three aspects of these visits: they signal the relevance of the GFA to local management and help to promote its dissemination; they offer valuable insights into local working conditions, and they foster personal relationships and transnational networks.
In contrast to these three cases, implementation practices are more limited at Paper. No site visits are conducted, and although a steering committee exists, it meets only once every two years (more frequent meetings are possible if required). Overall, more structured monitoring procedures are largely lacking. The committee primarily responds on an ad hoc basis to violations brought to its attention. Cases are typically raised by local unions via IndustriALL Global Union or national union federations. The committee is seen less as an enforcement body than as a forum for dialogue: If a problem is brought to us, we do not have to look in the agreement and check which paragraph applies to make them [the management] solve it, we just tell them ‘there is a problem with this or that’, and they try to solve it. [. . .]. So, it’s more of a dialogue. (Paper, Headquarters)
A common feature of all these cases is that the employee representatives based at headquarters play a pivotal role in GFA implementation within the dedicated established transnational arena. This central involvement is also reflected in the composition of the steering committees, which consist of actors located at headquarters either entirely or predominantly (with the exception of GUF representatives). These actors maintain close ties to senior management and serve as key actors in facilitating implementation processes more broadly.
Implementation practice in type 3
Type 3 shows an even more comprehensive pattern of implementation, in which a broader range of organisational routines defined by process norms shape the activities of the actors situated in the transnational arena. Pencils exemplifies this extended implementation practice. Here, regular monitoring of labour standards takes place, organised in the form of audits that are conducted across all sites and executed by the steering committee. The feasibility of the audits is supported by a smaller number of sites, allowing for the inclusion of all locations in the biannual audit cycle. The audit cycle – covering all sites every two years – has been consistently maintained over the past two decades, except during the COVID-19 pandemic. Key components include an initial briefing, review of documents, presentations given by local management, site inspections, and discussions with employees and local trade union representatives. Trade union representatives play an active role in the process as auditors. They not only review documents but engage directly with local unions and employees to gain an authentic understanding of working conditions at the sites, as emphasised by the HR manager: Although we go through points and documents in meeting rooms, we always make a point of involving the employees on site. That means the trade unions take the lead in talking to people and asking: ‘Hey, what’s it really like with your pay?’ (Pencils, Headquarters, Management)
Violations of labour standards in most cases referred to repression of unionisation, as at the site in Peru, where employees were dismissed because they had joined a trade union. These cases were uncovered during the visits, and local management had to rehire the relevant employees. At the same time, the regular on-site audits have helped to strengthen relations between local trade unions, the GUF and the German trade union. Importantly, the actors involved have drawn on the experiences gained through these audits to deepen cross-border collaboration. Over time, this has led to the development of a stable transnational union network that both supports and complements the audits, enabling continuous information exchange across locations. This communication has strengthened both the network’s operational capacity and the overall implementation of the GFA.
The Chemicals case is also characterised by comprehensive implementation practice with regard to the GFA. At the centre of implementation is the transnational steering committee, which also conducts joint annual site visits. When selecting locations, both recent developments and an equitable geographic rotation across world regions are considered. Each visit typically includes reports from local management, plant inspections, discussions with local trade unions and employees, and concludes with a joint debriefing session involving both union and management representatives.
One of the site visits revealed that trade union representatives at two locations in Mexico lacked even the most basic resources necessary to fulfil their representative roles. Similarly, during a visit to India, it became evident that no adequate structure existed to facilitate communication and coordination among representatives across the company’s Indian sites. In response, the establishment of a ‘national platform’ was agreed during the visit, enabling representatives from different sites regularly to meet and exchange information on their working and employment conditions.
Because of its transnational composition, the steering committee serves not only as a coordination body but also as a hub for transnational communication. Representatives from different world regions channel information from local contexts into the transnational arena, facilitating reciprocal flow of knowledge and experience. This dynamic reflects a degree of transnational integration that is largely absent from committees dominated by actors at headquarters and, at the same time, was the starting point for further transnational ‘institution building’ (Djelic and Quack, 2003), which in turn has a reinforcing effect on GFA implementation practice. Although parallels can be drawn with the development of the transnational trade union network at Pencils, in the case of Chemicals this process centres on the WWC. On the one hand, implementation of the GFA is a standing agenda item at the annual meeting of the WWC, which serves as a key hub for information and communication, enabling a continuous exchange of implementation-related updates and local-level issues from across the company’s global operations. On the other hand, the WWC has also played an active part in transnational labour governance, successfully negotiating global agreements with corporate management, most notably on global minimum standards for employees’ social security.
Implementation practices at Composite and Retail do not show the same intensity and scope observed in the other two cases, though for different reasons. The level of activity at Composite is high, but geographically limited to South America because of a lack of resources to enable representatives at headquarters to extend these activities to other regions. Nonetheless, several developments are noteworthy that would not have taken place without the agreement’s procedural norms: the establishment of social dialogue with a previously anti-union management, the formation of trade union structures, and the creation of a network of trade unions spanning multiple countries and company sites within the region. In contrast, implementation at Retail focuses entirely on the suppliers. What distinguishes this agreement is its explicitly proactive approach: it seeks to prevent conflict before it arises by enhancing local actors’ capacities. In this context, workshops are held with employees of the suppliers and local trainers to equip employees with the skills to articulate their interests and pursue solutions through social dialogue. Because it is not feasible to extend this process to the entire supply chain simultaneously, priority countries have been selected and tailored implementation plans were developed accordingly, which are then implemented at national level.
Key findings on the role of procedural norms in GFA implementation and the development of transnational labour relations
Our analysis shows that the configuration of procedural norms in GFAs is closely related to how implementation unfolds in practice. Both the distinction between event-driven and systematic process norms, as well as the differentiation between different organisational structures – whether responsibility is assigned to an existing or to a GFA-created separate arena – have proven useful for understanding variation in the social practices of implementation across our case studies. Procedural norms shape how labour standards are monitored, how violations are detected and how related conflicts are addressed. In other words, what is regulated in a GFA – and how – is far from inconsequential.
Contingent implementation practices are observed in cases in which GFAs lack process details and do not establish a distinct transnational arena. In the case of Construction, for example, the agreement does not contain any detailed process norms for dealing with problems or monitoring labour standards. Therefore, violations of labour standards are addressed only when unions raise violations informally, and whether such issues are pursued further depends on political and strategic considerations rather than due process. The contingent character of these practices can be set off to a certain extent by non-GFA sources, such as company-driven CSR initiatives which enable more regular reporting, for example, as observed at Machines and Metal. However, this practice at the same time disconnects monitoring and problem-solving – assuming it takes place at all – from employee involvement.
More continuous implementation practice is found in cases in which event-driven norms are combined with the creation of distinct arenas. Here, steering committees act as focal points for coordination, monitoring and conflict resolution, and thereby promote continuity in establishing regular interactions in meetings with company management. A key element of defining a distinct arena lies in the allocation of resources, such as covered travel costs. However, gradual differences can be observed within this type as well. At Steel, for example, the steering committee meets at regular intervals with the company’s labour director and deals with problems arising from the complaints system. In the case of Electronics and Paper, however, implementation is more contingent because processes for gathering information are less sophisticated. In the former, this gap is partially bridged through frequent site visits; in the latter, ad hoc responses dominate because systematic information gathering is lacking.
The clearest instances of routinised and comprehensive implementation practices are associated with systematic procedural norms coupled with distinct organisational structuring into an independent arena dedicated to GFA implementation. This is most evident in the cases of Pencils and Chemicals. At Pencils, procedural norms influence implementation practices primarily by connecting the systematic monitoring of working conditions with joint audits by the GFA actors at the company’s sites. Similarly, Chemicals combines structured monitoring with regular site visits, involving a steering committee with a transnational composition. This arrangement is further strengthened by the formation of a WWC, which also supports broader transnational coordination and negotiation. In both cases, procedural norms reinforce each other in implementing the GFA locally.
In the other two cases of this type, implementation is less comprehensive because the actors lack resources and in the case of Composite, for example, GFA implementation is confined to South American locations because of the lack of resources available at headquarters to integrate other regions, as mentioned in Section 5 above. At Retail, implementing the GFA is hampered by the weak involvement of local trade unions.
Table 4 summarises implementation practice across the different types. Our findings indicate whether and how procedural norms in terms of process characteristics and organisational structures enable continuous monitoring, meaningful employee participation and regular communication with management at the transnational level. This – and this is our core finding – highlights how procedural design shapes the organisational conditions under which implementation is carried out, including the institutional resources that actors are able to mobilise in these processes.
Implementation practice across types.
Source: Authors’ presentation.
This does not exclude differences within the patterns of implementation observed in our empirical cases in terms of actors’ strategies, capacities and power resources; but it seems to restrict these differences to variations within these patterns. As our analysis has shown, procedural norms constitute one important resource in this regard. By establishing dedicated transnational arenas, GFAs can provide organisational resources that strengthen actors’ capacities. As illustrated by the cases of Chemicals and Pencils, these organisational settings can serve as platforms for transnational communication and coordination. Beyond supporting GFA implementation, such arenas also bear the potential to enable the development of new strategic capacities and institutional pathways for employee representatives in terms of transnational institution-building.
Summary and perspectives
Procedural norms and their design are of central importance for the implementation of GFAs. According to our findings, a combination of two procedural norms is associated with more routinised and less ad hoc implementation: (i) systematic processes and (ii) dedicated and separate transnational arenas. These norms enable the implementation of GFAs in terms of organisational structures and process characteristics by identifying the relevant actors, delineating their responsibilities and rights, and defining concrete implementation procedures and resources in terms of how information on violations of labour standards is gathered, how it is verified and interpreted in consultation with management, and how problems and conflicts are addressed. The stronger these norms are, the less implementation practice is dependent on ad hoc priorities and more firmly embedded in organisational routines.
Dedicated arenas are typically established through transnational steering committees whose explicit task is the oversight and implementation of the GFA. These bodies make interaction between labour and management continuous and foster accountability. Addressing the GFA is no longer just one item among many on the agenda of a busy EWC or a central or group works council meeting. Instead, it becomes the sole purpose of separate and continuous meetings between employee representatives and top management. This interaction can be considered genuinely ‘transnational’, as it focuses on linking local developments with decision-making processes at the global level of multinational companies. These arenas not only enhance implementation but also generate new organisational capacities and strategic opportunities for employee representatives.
Although our analysis is based mainly – though not exclusively – on cases from German MNCs, the implications of our findings are not confined to a Germany-based institutional setting of headquarters and their actors. First, the variation across our cases is so pronounced that we consider the significance of a country effect to be low. Rather, our explanation for this variety is that actors neither have ready-made templates available for designing implementation procedures nor reliable prior knowledge of which procedures would ultimately be viable in practical terms. In this process of experimentation, actors rely on the procedural norms they have created. Against this backdrop, we explain variation by examining how procedural norms allocate responsibilities, define arenas and thereby structure interactions and implementation practice in situations of uncertainty.
This also extends, secondly, to the institution of works councils as an institutional idiosyncrasy of German multinational companies. One might expect GFAs to be attached to existing work council bodies. However, one of our core findings is that GFAs based on the establishment of new bodies at transnational level result in the most substantial changes in practices, transcending existing national bodies. At the same time, the role of works councils in implementation exhibits a wide range of practices. Looking at our two ‘model’ cases, Pencils and Chemicals, in the German company (Pencils) implementation is driven by the trade union, whereas in the Belgian case (Chemicals) the European works council plays the leading role. This supports our interpretation that the decisive factor is not the institutional structure of the country in which the HQ is based, but rather the process of interaction both on the employees’ side and between labour representatives and management, which are shaped to a considerable extent by the procedural norms laid down in the GFAs.
Within the context of broader debates around global labour regulation and transnational institution-building in employment relations, we conclude from our findings that the design of procedural norms in GFAs has the potential to become more important than merely a way of formalising implementation. Procedural norms in GFAs can be understood as a proto-institutional element (Helfen and Sydow, 2013) that may foster recurring interaction between management and labour representatives at transnational level. In this sense, they structure arenas and practices through which transnational labour relations may emerge within multinational companies more generally.
In conclusion, while not all GFAs give rise to transnational labour relations, the design of procedural norms plays a critical role in determining whether such relations develop at all, even if conditions are generally conducive to this end. These norms thus function as both enabling and constraining as they provide actors with opportunities to act transnationally. However, they do not guarantee the emergence of transnational labour governance on their own. The emergence of transnational labour relations also depends on sustained organisational support, actor commitment and the availability of resources. The political climate and MNC strategies in relation to their workforces and social sustainability also matter a great deal when it comes to engaging in social dialogue and reaching agreements with employees in the first place. Future research should therefore explore how procedural norm design interacts with organisational dynamics across the multi-level system of industrial relations in MNCs.
Footnotes
Funding
The authors disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: The empirical study presented in the article was funded by the Hans Böckler Foundation [grant number 2019-615-3].
Declaration of conflicting interests
The authors declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.