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University of Amsterdam Graduate School of Social Sciences Comparative Labour and Organisation Studies

Recruiting Nurses:

An Investigation of Trade Union Recruitment Mechanisms in

the United Kingdom, Germany and Belgium

Candidate: Alison Jones; Student number 11600306 Supervisor: Prof. Dr. Johan De Deken (University of Amsterdam) Second reader: Prof. David Marsden (London School of Economics)

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Abstract

This thesis set out to investigate some of the institutional mechanisms that facilitate or restrict trade unions’ ability to recruit new members by exploring these factors in large trade unions from three different European countries. A qualitative constructivist grounded theory approach informed the research framework and methodology, encouraging understanding of the topic and sensitizing the researcher to relevant concepts before interviews were conducted thus ensuring the role and point of view of interviewee and researcher are considered during interview analysis. Semi-structured interviews were conducted with employees of large trade unions that represent nurses in the United Kingdom, Germany and Belgium. These countries were selected for their divergent structural, social and institutional factors as well as varied historical industrial relations systems. A framework of structural and social factors provided support for a mechanism-based explanation for the institutional factors of: individual goods and services, collective agreement expansion, workplace representation and rival trade unions. Finally, the thesis argues that Ghent system does not inform trade union density in situations of high employment, the presence of a workplace representative facilitates it and the presence of negative labour relations legislation has a detrimental role on recruitment.

Key words: trade unions, constructivist grounded theory, mechanisms, England, Germany, Belgium.

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Acknowledgements

I would like to thank the trade union employees who agreed to be interviewed for this dissertation Val Johnston, Angela Lysons, Colenzo Jarrett-Thorpe, Kalle Kunkel, Jana Seppelt, Ben Stotz, Luigi Wolf, Mark Selleslach, Olivier Remy and Jan-Piet Bauwens. I cannot express in words my appreciation that many agreed to be interviewed in English, without your input this dissertation would not have been possible.

I would like to express my gratitude to my supportive and insightful Professor De Deken, I could not have asked for a more dedicated supervisor, and would like to thank my second reader Professor Marsden whose considerate guidance was invaluable during my exchange in London. In addition to my friends and fellow classmates, Petar Marčeta, Fabio Ferrari, Tom van De Haar, Simone Schneider and Ruth Eyles who went through this thesis writing adventure with me and who were pillars of support throughout.

I would like to thank my mother, my brother, my in-laws and the rest of my friends and family for their continuous and unconditional support. Last but not least, I would like to thank my partner Erin Fitzsimmons, who came on this journey of discovery with me and who has probably learned more about industrial relations then he wanted to, for providing me with unlimited love, encouragement and freshly ground coffee.

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Table of Contents

Introduction ... 6

Chapter 1: Structural and Social Factors Influencing Trade Union Density ... 12

1.2 Influence of the Business Cycle ... 13

1.3 Impact of the State ... 15

1.3.1 Political Affiliation ... 15

1.3.2 State Regulations ... 20

1.4 Employer Alternatives ... 23

1.5 Structure of the Labour Force ... 25

1.6 Group Identity ... 27

1.7 Individual Perceptions of Trade Unions ... 28

Chapter 2: Design and Methods ... 31

2.1 Introducing Grounded Theory ... 31

2.1.1 Classic Grounded Theory ... 31

2.1.2 Straussian Grounded Theory ... 32

2.1.3 Constructivist Grounded Theory ... 33

2.2 Applying a Constructivist Grounded Theory ... 34

2.2.1 Phase One - The Literature Review ... 34

2.2.2 Phase Two - Planning the Qualitative Analysis Phase ... 35

2.3 Mechanisms as Explanations of Processes ... 38

2.4 Interview Strategy ... 39

2.5 Limitations of Approach ... 44

Chapter 3: Analysis ... 46

3.1 Individual Goods and Services ... 46

3.1.1 The Individual Goods and Services Mechanism ... 47

3.1.2 The Ghent Booster ... 50

3.2 Collective Agreement Expansion ... 53

3.2.1 The Free Rider Mechanism ... 53

3.3 Workplace Representation ... 57

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3.3.2 The German Counterfactual ... 61

3.4 Rival Unions ... 63

3.4.1 The Rival Union Mechanism ... 65

Conclusion ... 69

Bibliography ... 73

Annexes ... 79

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Introduction

Trade union1 density2 has been declining across Europe for the last 40 years and there is no indication that this decline will slow or reverse in the near future. After the height of industrial strength in the 1970s, trade union density started to decline across Europe in the 1980s and into the 1990s, falling 23.8 percentage points between 1990 and 2016, and continuing this downward trend to the present day (OECD, 2018). Although European countries have many similarities in that they are highly industrialized, participate in open markets and possess nearly identical technology, the relationship of trade unions with the government, employers, members and the general public vary widely depending on the historical evolution of their industrial relations systems and their unique social, structural and institutional factors. (Gumbrell-McCormick and Hyman, 2013, 2). The overarching purpose of this thesis is to investigate key social, structural and institutional factors that have caused divergence in trade union density decline across three different European countries; the United Kingdom (UK), Germany and Belgium, which were selected because they present different factors and because they have divergent trade union density.

Pedersini (2010) distinguishes three groupings of countries to illustrate the divergence of trends in trade union density and trade union membership3 indicators based on particular factors. The first group of countries consists of those that show a positive trend in trade union density, in trade union membership or both and includes countries such as Italy, Spain and Belgium (Spain and Belgium provide an example in Figure I.1).

1 The Webbs first defined trade unions as a “continuous association of wage-earners for the purpose of

maintaining or improving the conditions of their employment”. This largely economic focused definition was later broadened to encompass social and political transformation, including ‘mutual insurance’, providing financial benefits when members face adversity and ‘legal enactment’, putting pressure on governments for favorable action for wage-earners (Gumbrell-McCormick and Hyman, 2013, 1).

2 Trade union density relates to the ratio of wage and salary earners that are trade union members divided

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Figure I.1 - Trade Union Density, Group 1 Source: OECD (2018)

The second consists of countries that have experienced only limited losses in terms of both indicators, and illustrate a more stable trend. This group includes the Nordic countries, France, Slovenia, Austria, Germany and the UK (Germany and the UK provide an example in Figure I.2).

Figure I.2 - Trade Union Density, Group 2 Source: OECD (2018)

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The third and final grouping, Figure I.3, consists of Central and Eastern European countries where both union membership and density have decreased sharply (the Czech Republic and Slovenia provide an example in Figure I.3).

Figure I.3 - Trade Union Density, Group 3 Source: OECD (2018)

Some fluctuation in trade union density can be explained by particular country-level changes such as the sharp fall in union membership in Central and Eastern European countries after the collapse of the Soviet communist system in the 1990s. That ended what up to that time was an almost compulsory union membership. But reasons for general divergence are more difficult to uncover from quantitative research4 (Crouch, 2017, p. 49; Visser, 2007, p. 99). Theorists have sought to explain fluctuations in trade union density at various points in history. Some, like Olson (1971) and Kelly (1998), have taken a micro approach and argued that individual needs and desires drive trade

4 In addition to not being able to explain the reasons for the decline in density are concerns about the data

itself and the oversimplification of using quantitative data to perform comparisons between and among countries. Key issues in the use of quantitative research in comparative trade unionism include: membership data is provided by trade unions themselves so there may be issues with their calculations, union definitions of a member can vary across unions and countries, definitions of employment and employed can vary across countries and countries themselves witness many internal changes in collection of information (Kittel, 2006, p. 663; Gumbrell-McCormick and Hyman, 2013, p. 5). Therefore quantitative research was undertaken to demonstrate a general downward trend in trade union density and country divergence but qualitative analysis will be used to explain the reasons for the divergence.

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union membership numbers. Olson (1971) argued that individuals are rational actors who will join a union if they are either forced or if the union provides incentives that are of higher value than the cost of joining. On the other hand, Kelly (1998) posited that an individual needs to experience a sense of injustice towards their employer and a charismatic union leader to organize them in the pursuit of justice to join a union and others, such as Dunlop (1958), Kochan, Katz and McKersie (1986) and Ebbinghaus and Visser (1999) suggested that international and national macro factors such as political power, changes in the economy and employer alternatives to trade unions influence trade union membership density. Dunlop (1958) proposed a systems model to explain trade union density consisting of the environmental contexts that affect employment relationships, economic forces, political power which would have an impact on density while Kochan, et al. (1986) suggested structural changes in the economy and labour force are the most obvious explanation for declines in union membership (both in Kochan, Katz & McKersie, 1986).

Ebbinghaus and Visser (1999) had a unique approach to explaining union growth and decline. They acknowledged that it is too complex a phenomenon to explain with only one point of view so they divided the etiological factors into three groups. The first of these groups are cyclical factors such as the impact of the business and political cycles, the second are structural factors including changes in the social structure of the labour force and changes in social values of workers. Finally, their third group includes configurational factors such as the institutional context that describes the extent the union plays a function in the administration of welfare benefits, the role the union takes in the workplace and employer strategies to support or undermine union activities.

This thesis will take a meso or mid-level approach to investigate the structural, social and institutional factors that influence trade union density. It will investigate questions of why trade union density is declining in some countries while others are able to maintain trade union density levels. It will begin by offering a unique framework of structural and social factors that influence trade union density informed by the academic literature and inspired by Ebbinghaus and Visser’s (1999) acknowledgement that trade union

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membership is a complex phenomenon including both historical and institutional factors. This framework is important as it explores the impact of historical conditions and the impact of trade union relationships (with the government, employer, trade union member and the general public) on shaping unique trade union landscapes in different countries. The influence of institutional factors will be explored through interviews with trade union employees in the UK, Germany and Belgium. Interviews were transcribed, analyzed and used to explain how specific institutional factors, when viewed as a phenomenon or a mechanism, influenced a trade unions ability to recruit members within the country context provided by the structural and social factors outlined in the framework.

The results of this thesis will be of particular interest to trade unions, policymakers, academics and other stakeholders because trade union members are a valuable resource to trade unions providing not only financial resources in the form of membership dues but recognition, legitimacy and the industrial strength needed to further employee interests with employers or the government. Trade union density and membership numbers are crucial indicators of the effectiveness industrial relations systems and are linked to the viability and effectiveness of collective bargaining5, the ability to engage in social dialogue with employers and the government and the ability to represent members (Pedersini, 2010).

This thesis will proceed as follows: Chapter 1 will outline an explanatory framework that contains both structural and social factors that are expected to influence trade union density. Those factors range from the impact of international pressure to individual perceptions of trade unions. The research design and methods will be discussed in Chapter 2 and the argument will be made of the usefulness of identifying social mechanisms in sociological research. Chapter 3 will provide analysis that draws on the material in Chapters 1 and 2 to put forward an explanation of how specific institutional factors under certain conditions can facilitate or hinder the ability of a trade union to

5 Collective bargaining extends to all negotiations that take place between an employer, a group of

employers or employer organizations with one or more worker organizations to determine working conditions, terms of employment and to regulate relations (OECD, 2017).

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recruit new and retain existing members. These arguments will be substantiated by qualitative evidence provided by trade union employees in the UK, Germany and Belgium. Lastly, conclusions will be drawn regarding the impact of structural, social and institutional mechanisms on trade union recruitment.

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Chapter 1: Structural and Social Factors Influencing Trade Union Density

Possible explanations of the factors that influence trade union density were discussed in the Introduction - this chapter will present a more encompassing framework of the structural and social factors that influence trade union density. Structural factors relate to the organization of parts as dominated by the general character of the whole and include: the effect of international pressure, influence of the business cycle, impact of the state, employer alternatives and structure of the labour force; while social factors refer to the interaction of the individual and the group and encompass group identity and individual feelings towards trade unions (Merriam-Webster, 2018). Structural and social factors vary widely depending on the country, making any individual factor untenable as a stand-alone explanation for fluctuations in union membership levels; however, the unique combination of factors in each country are important to understanding the factors that influence the trade union landscape. The UK, Germany and Belgium will be used as examples throughout this chapter to illustrate variation in factors as well as providing background information on the country cases that will be explored later.

1.1 Effect of International Pressure

International pressure caused by an increase in fiscal globalization that pulls international economies toward neoliberal convergence, is a popular reason put forward by academics to explain the general trend of trade union decline starting in the 1980s (Ruysseveldt and Visser, 1996, p. 164; Visser, 2007, p. 98; Western, 1997, p. 157). Increased competition with other suppliers as well as a drive to generate greater profits increases employers desire to drive down labour costs, a large, if not the largest, expense they have. Technical innovations are introduced where possible to replace employees and reduce the size of the workforce, employee wages and benefits are diminished or frozen and employers fight to have an increasingly flexible workforce with more temporary and contract jobs and less stable employment, also known as ‘atypical’ work (Ebbinghaus and Visser, 1999, p. 135). In the UK, a growing emphasis on short-term ‘shareholder value’ drives the trend towards reduced labour costs, increase in flexible work, longer work hours and ‘atypical’ work (Gumbrell-McCormick and Hyman, 2013, p. 102). To reduce costs, some companies also outsource work activities to countries where labour is cheaper. For

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example in the 1990s the German labour market was characterized by high wages and generous vacation time, increased financial pressure made employers move production of many industrial items (ex. cars, washing machines and microwaves) to countries in the former Eastern Block who could produce the items at similar quality but without the same generous employment terms (Ruysseveldt and Visser, 1996, pp. 163-166). Neoliberal convergence gave way to divergence in the 1990s and 2000s as each country and trade union adjusted to financial globalization according to the institutional, structural and social factors unique to that country resulting in different outcomes to the same financial globalization pressures. Even in the countries where trade unions were able to protect employment advances made by trade unions, or where they were able to maintain membership levels, increased competition put more pressure on employers and made bargaining increasingly difficult in a fast changing world (Western, 1997, p. 157).

1.2 Influence of the Business Cycle

The impact of the business cycle on union density provides an economic explanation of trade union trends. Marx and Engles observed that “the favorable effects of works’ resistance organizations are limited to times of average and brisk trade” in other words, trade unions are in a better position to recruit members when there is economic prosperity, and in a weaker position when the economy is weak (Marx, Engles & Lapides, 1987, p. 160). Two theories will be discussed on the influence of the business cycle on trade unions as well as their impact on trade union density, business cycle theory and neoclassical economic theory. First, business cycle theory espouses the supply and demand function of the economy as applied to and influencing trade union density. When the economy is strong, demand for products and services is high and demand for labour is correspondingly high to provide these products and services. A strong economy with high employment levels places trade unions in strong bargaining positions with employers because employers do not want to lose any production hours to industrial action; and with high levels of employment comes more potential members who may become members of a trade union. The more members a union has the stronger inducements unions are able to offer individuals and the more likely they are to join (Booth, 1986, p. 42; Western, 1997, p. 103). Conversely, when the economy is weak, there is an increase in competition

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for products and services, consumers demand lower prices and the supply of labour shadows demand causing high levels of unemployment. To minimize decreasing profits employers shift their priorities from maintaining labour peace to controlling labour costs. This shift places employers in a much more advantageous position to request bargaining concessions from unions who are in a weaker bargaining position as withholding employee labour, in the form of strike action, has less of an impact when employees can be easily replaced (Kochan, et al., 1986, p. 53). In addition, many individuals leave the trade unions once they are laid off, even if the union provides a lower subscription rate. This further reduces the trade unions’ bargaining power and their financial resources raising costs and/or lowering benefits for remaining members (Ebbinghaus and Visser, 1999, p. 139). When trade unions and the economy are strong, unions have the opportunity to use their strength to negotiate better terms and conditions with employers and pressure the government in power to pass labour-friendly legislation (be it for union recognition, lower work weeks or overtime provisions). However, structural factors that facilitate an awareness of power do not actually generate an awareness of power leading to many trade unions not recognizing and acting on the opportunity to take advantage of their relative strength while the economy and union is strong (Kelly, 1998, p. 11). This suggests that business cycle theory can be visualized by long wave theory; long waves are identifiable patterns over time. Similar to a wave, at the crest when the economy is strong, high union density follows and at trough when the economy is weak trade union membership falls. Kelly (1998) was interested in comparing the position of the economic wave in relation to employees feelings of injustice, Jacobi (1988) examined the waves more generally and Gordon et al, (1982) looked for specific behavior such as strike action as an extension of power (all in Kelly, 1998, p. 86). The common theme in these examples is the consideration that other factors can have an impact on labour market fluctuations, none of which can be reduced solely to business cycle fluctuations, leading to the conclusion that shifts in trade union density are caused by more than fluctuations in the economy.

The second theory regarding the influence of the business cycle on trade unions is neoclassical theory that adds another dimension by considering the institutional context

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in addition to economic conditions. This perspective takes a more contextual approach to demonstrate that the labour market is shaped by economic conditions filtered through the prism of surrounding institutions, such as political party affiliation, presence of a union administered unemployment system, etc. (Western, 1997, p. 4). From a historical perspective, Commons (1918) argued that institutional context should be able to mitigate the effects of economic conditions, particularly of a weak economy, on trade union strength (in Olson, 1971, p. 115). Institutional factors such as centralized bargaining and union administered unemployment schemes insulate unions from the pressure of surrounding economic systems making trade union density less responsive to cyclical changes in the economy and acting like a cushion lessening the impact of the economy on trade union recruitment and density (Western, 1997, p. 102). Business cycle theory does not go far enough to explain trade union decline in terms of economic pressure exerted upon the employer and trade union. The influence of laws, customs and structures that have built over time that establish the institutional features of the relationship must also be considered as is done in neoclassical theory (Kochan et al., 1986, p. 15).

1.3 Impact of the State

Trade unions are not just economic actors but are necessary protagonists in the political arena (Gumbrell-McCormick and Hyman, 2013, p. 132). The impact of the state as facilitator or resistor of trade union activities is comprised of two components, the influence of the political party currently in power and the effect of state regulations that can outlive the party that legislated them. Both components will be discussed with examples provided to illustrate their effects.

1.3.1 Political Affiliation

Marxist analysis traces collective action back to solidarity within groups and conflicts of interest between groups, industrial strife is seen as a conflict of interest between classes and is closely linked to political conflict (Korpi, 1983, p. 161; Tilly, 1978, p. 14). This conflict can be visualized as tripartite societal bargaining between workers (represented by the union), employers and the government. Depending on the political party in power the government can either align its interests with the trade union and workers or the

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employers; generally, left-leaning political parties support union activities whereas right-leaning political parties try to limit union strength (Ebbinghaus and Visser, 1999, p. 138; Korpi, 1983, p. 181). Historically, most unions had close, sometimes formal, links to left-leaning political parties because they shared similar ideology, recruited from and mobilized the same social base and because they needed the support of the other to achieve their aims (Gumbrell-McCormick and Hyman, 2013, p. 132). On the other hand, right-leaning political parties strengthen the role of the capitalist state in regulating the workplace and enjoy relative autonomy from engaging in working class struggles (Edwards, 1986). Hayward (1980) defined and structured these connections, identifying four different kinds of relationships between trade unions and political parties. The first is the ‘Leninist model’ where a political party seeks to control the policies and actions of an associated union. Secondly, the British case where the trade union created the Labour Party and initially saw its task as dictating political party policies. Thirdly the general social-democratic pattern involving interdependence and symbioses and finally, the position where trade unions refuse any alliance with political parties (Hayward, 1980, p. 5,6). Although social, political and economic changes may have altered trade union/political party relationships over the years, the relationship structure that has been incorporated into the wider society remains an obstacle to profound and immediate change (Ebbinghaus, 1995, p. 54). Trade unions are inevitably involved in political behavior and will remain so as they need to influence the way the state shapes the rules of the labour market “game”, including their right to exist, bargaining collectively and mobilize collective action (Gumbrell-McCormick and Hyman, 2013, p. 132). Trade union’s ability to influence policy largely depends on how well they can influence political parties and how successful those parties are at moving policies through government (Western, 1997, p. 67).

Trade unions across Western Europe had a role in the labour market regardless of the political party in power up to the 1970s supported by corporatist institutions, neo-corporatist income regulation and Keynesian full employment policies, in the 1970s. Different structures and institutions caused countries to display divergent trends in the balance of power between trade union and political party (Ebbinghaus and Visser, 1999,

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p. 141). This section will describe the impact of a changing political landscape on trade unions ability to function, to first facilitate then constrain in the UK and to facilitate in Belgium and Germany.

In most European countries, socialist political parties helped create trade union movements−in the UK trade unions created the Labour Party, which remains one of the most influential political parties in the country though its links to trade unions were irrevocably cut by “New” Labour in the 1990s (Ruysseveldt and Visser, 1996, p. 61). The British Labour Party was formed in 1900 at a meeting of the Trade Union Congress (TUC) to provide a distinct group in Parliament to advocate for the interests of labour (Hyman, 2001, p. 82). For decades trade unions provided financial backing and helped garner votes for Labour candidates in exchange for advancing trade union interests in parliament (Galenson, 1961, p. 67). The election of Thatcher’s Conservative government in 1979 represented a break in the post-war consensus between employees (trade unions), employers and the government, up till then both Conservative and Labour governments recognized trade unions and accepted their position in the economy (Ruysseveldt and Visser, 1996, p. 47). Thatcher’s Conservative government promoted a deregulated, low wage economy to attract foreign investment and granted employers more autonomy and flexibility in the workforce (Ebbinghaus and Visser, 1999, p. 140; Howell, 1999, p. 31). Employment regulations had always been largely voluntary and Thatcher’s government passed legislation that sought to abandon corporatist practices and reduce industrial action, promoting an individualization of industrial relations where union and collective bargaining had a minimal role (Ruysseveldt and Visser, 1996, p. 79). These regulations did not simply weaken trade unions but led to a strategic reconceptualization of British politics (Howell, 1999, p. 27). In the 1990s British trade unions realized they could no longer depend on their own industrial strength to influence politics and in 1994 the TUC broke its formal ties to the Labour Party declaring they would be a campaigning body that would attempt to influence any party and any government (Howell, 1999, p. 41,42).

The UK made the most radical break with corporatist tendencies of all European countries as the power of trade unions has been driven back, democratic influence on

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economic policy terminated and the role of the government in the economy greatly reduced (Ruysseveldt and Visser, 1996, p. 42). In contrast, links between trade unions and political parties in Germany and Belgium have never abated due to structural and institutional mechanisms that keep them operating together and they both have a “general social-democratic pattern” trade union/employer relationship based on interdependence and symbioses though with some differences (Gumbrell-McCormick and Hyman, 2013, p. 13; Hayward, 1980, p. 5,6).

German trade unions are grouped into federations that represent union and worker interests on social, political and economic issues to the government and influence public opinion but are not engage in bargaining (Gumbrell-McCormick and Hyman, 2013, p. 15). Deutscher Gewerkschaftsbund or the Federation of German Trade Unions (DGB) is the largest federation in Germany and does not formally allow any partisan activities within its ranks though it still maintains strong links to the Sozialdemokratische Partei Deutschlands or Social Democratic Party of Germany (SPD). The left leaning SPD introduced a number of reforms to support the trade unions including the Mitbestimmungsgesetz (Co-Determination Act6) that gave trade unions more support and prestige despite the 1974 international recession (Ruysseveldt and Visser, 1996, p. 133, 139). Right-leaning governments, led by the Christlich Demokratische Union Deutschlands or Christian Democratic Union of Germany (CDU), attempted to increase flexibility for employers but their efforts were limited to liberalizing atypical work and sick pay and reducing subsidies for early retirement. Generally, German political parties respect the central principle of bargaining autonomy, the presence of trade unions in boardrooms and the foundation of co-determination (Silvia, 1999, p. 87,88). Although German trade unions did not experience a full-frontal attack on their right to exist, by the 1990s it became evident that trade unions’ ability to influence the activities of political parties was limited, and as a result they started to explore the extent of their own power through bargaining and social mobilization. German trade unions also broke with the

6 Co-determination is one pillar in Germany’s dual system of industrial relations (the other is Collective

Bargaining as defined in the Introduction) and refers to the activities of the works council. The works council consists of members elected by all employees in a workplace to represent them in workplace-level

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post-war tradition of non-partisanship to embrace a political strategy that was little more than “praying” for a friendly government (Silvia, 1999, pp. 95-98).

Of the three countries, trade unions in Belgium have always had and maintained the closest links to political parties and thus influence in the political process, likely as a result of Belgium’s political and social pillars7. The government is based on coalitions between the Walloon, French-speaking community and the Flemish, Dutch-speaking community that lead to a minimal amount of ideological swings and there are explicit links between political parties and trade unions, these ideological and organizational links make governing against trade union interests difficult as at least one party in the coalition will have close ties to a trade union (Ruysseveldt and Visser, 1996, p. 210). The Socialist trade union movement (ABVV/FGTB) has traditionally had ties with the Socialistische Partij or Flemish Socialist Party (SP) and the Parti Socialiste or Walloon Socialist Party (PR). The Roman Catholic trade union federation (ACV/CSC) has clearly recognizable links to one of the political wings of the Roman Catholic Christelijke Volkspartij or Christian Democratic Party (CVP) (Ruysseveldt and Visser, 1996, p. 210). The government became more involved in industrial relations after World War II when the trade unions and employers found it increasingly difficult to agree on wages and employment conditions. The government supports partnership between employers and trade unions by facilitating bargaining practices, bolstering the position of the union by making collective agreements binding for a given sector as well as granting bargaining monopolies to the appropriate Employer’s Association or trade union (Gumbrell-McCormick and Hyman, 2013, p. 142; Ruysseveldt and Visser, 1996, p. 214). Belgium also experienced trade union upheaval in the 1990s when the center-left leaning government tried to introduce wage-indexing reform to combat high wages. There was large-scale social unrest demonstrated by two general and several regional and sectoral strikes that employees organized without the support of the trade unions - relations between trade union federations and allied political parties were at a low point with the

7 The Belgium industrial relations system was historically built on ideological fragmentation that separated

the two main confederations into the Socialist and Catholic pillars (Gumbrell-McCormick and Hyman, 2013, 19). Pillarization (verzuiling) also extended into the political sphere with political parties falling into Socialist and Catholic pillars (Ruysseveldt and Visser, 1996, 205).

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unions position seriously undermined. The structure of the Belgian political system prevailed; the partners took several months to discuss and came to an agreement that all parties could manage (Ruysseveldt and Visser, 1996, p. 216).

These examples of how political parties can influence trade union activities in England, Germany and Belgium illustrate how different these interactions can be and question the assertion of Ebbinghaus and Visser (1996) and Korpi (1983) that a right-leaning government is detrimental to trade unions as structural and institutional factors in Germany and Belgium protected trade unions from inimical political parties and allowed them to continue to have an impact even with right-leaning governments in power.

1.3.2 State Regulations

State regulations are closely tied to political affiliation, as they are the legislation and corresponding regulations that political parties enact when in power. Political affiliation is strongest when the affiliated party is in power whereas state regulations can outlive the government that legislated them and do not necessarily reflect the ideological stance of the government currently in power. This section is complementary to the previous section and will use the same country examples to illustrate the impact of state regulations on trade unions ability to function in the UK, Germany and Belgium.

The UK has a tradition of voluntarism where politics and industrial relations are seen as separate spheres, and no legal system of positive rights exists with regards to union representation, bargaining or strike action (Hyman, 2001, p. 68). Trade unions’ “legal rights” have been developed as exceptions to the common-law or negative ‘immunities’−unions bargain without legal recognition from the state. This means there is no legal provision for an employer to recognize a trade union and as a result, employers can refuse or withdraw recognition and employer associations cannot require an employer in their association to adopt a collective agreement (Gumbrell-McCormick and Hyman, 2013, p. 25; Western, 1997, p. 47). Legislation is limited to providing supplementary protection for those outside the reach of trade union influence and it is the only country in Europe without any form of statutory minimum wage regulation

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(Ruysseveldt and Visser, 1996, pp. 42-55). A good example of the influence of state regulation on trade union functions is the presence of the “closed shop” or compulsory membership in a trade union as a condition of employment. A workplace with a closed shop meant that all employees had to belong to a union, offering the union(s) financial stability through union dues and the ability to use their industrial strength more effectively as they had influence over an employer’s entire workforce. As Webb and Webb pointed out in the early 20th century, the closed shop was becoming rare in Britain but were still present and more important the possibility of a closed shop existed until 1988 when Thatcher’s government passed the Employment Act that made closed shops illegal (in Olson, 1971, p. 68). Logically, trade unions should have opposed this reduction in their power resources however the TUC and its affiliates were true to voluntaristic doctrine and were officially against closed shops on the grounds that if trade union membership was made compulsory then the government has an implied right to control conditions of trade union membership.

When British trade unions had high membership density and political influence via the Labour Party they used that power to maintain their freedom of action against government intervention in their activities and did not push for a legal framework to operate within, feeling that industrial strength was enough to keep them protected. Minimal state intervention was preferable and it was felt that to enforce their role with legislation what could not be achieved by collective action would be an admission of weakness (Ruysseveldt and Visser, 1996, p. 44). The significance of this is that when British trade unions had the ability to push for recognition and protection they did not do so with the result that when they became weak they did not have any structures or institutions to support them.

In sharp contrast, German relations between government, trade union and employer are enshrined in legislation and regulations. For instance, employers and trade unions have the constitutionally granted autonomy to negotiate collective contracts, which determine wages and employment terms and conditions. Legally, these collective agreements only apply to members of trade unions but in practice employers broaden pay, and terms and

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conditions for all employees (Ruysseveldt and Visser, 1996, p. 145). Streek (1992) argued that Germany’s positive and protective employment legislation, particularly related to dismissals, made trade unions more willing to cooperate with productivity improvements and to more flexible work arrangements (in Gumbrell-McCormick and Hyman, 2013, p. 14). This cooperation allowed manufacturers to easily make the shift from Talyorist or Fordist mass-produced low-quality goods towards more diversified high quality production (Ruysseveldt and Visser, 1996, p. 161). However, recent legislation has divided trade unions and employers, the Tarifeinheitsgesetz or Act on Collective Unity, passed in May 2015 allows an employer or trade union to request that there only be one collective agreement per workplace, the one collective agreement would be negotiated by the trade union with the most members in the workplace. This makes it more difficult for unions who represent a smaller proportion of workers in a workplace to gain more members, as they may not be able to bargain with the employer. Some affiliates of the DGB support the legislation but the majority does not as it will limit their legal capacity to negotiate collective agreements, particularly for the smaller unions (Kraemer, 2015; Vogel, 2017).

Legal rights and restrictions mostly implemented by governments that are no longer in power dictate German industrial relations, these state regulations shape the context in which trade unions and employers function legitimizing them both and putting them on a more equal footing so the balance of trade union power is not as important to continued relations. Belgium also provides extensive regulations that support the partnership between government, trade union and employer. After World War II these three groups drafted a “social pact” to determine the demarcation of authority; employment terms and conditions were the purview of collective bargaining, while economic issues such as capital investments, rationalization and work organization remained at the discretion of the employer (Ruysseveldt and Visser, 1996, p. 235). The state developed legislation to institutionalize both group’s rights but has interfered with wage bargaining over the years. The Competitiveness of Industry Act of 1989 gave the government the right to intervene in wage bargaining if wages rose more sharply than its closest trading partners. The government used the Act in 1993 when Belgium experienced an economic downturn

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and spiraling unemployment, it instituted a wage freeze, reductions in already negotiated wage rates and limits to future wage increases (Ruysseveldt and Visser, 1996, p. 215).

Belgium’s economy is seen as the ideal ideological underpinning for peaceful and cooperative relations between labour and capital with legislation-sanctioned state interference when determined to be necessary. Germany also has extensive state regulations controlling the activities of trade union and employer but are left to function free of additional state intervention and England is the wild west of industrial relations with no protective state regulations and an industrial relations system where trade union and employer are only on the same level only when trade unions are strong. As demonstrated state regulations play a large role in trade unions ability to function, be it positively or negatively, long after the government that passed them has left power.

1.4 Employer Alternatives

After the world recession of the mid-1970s employers went on the offensive against trade union influence seeking to increase their profitability and to reassert managerial prerogative over their workforce−resulting in a number of strategies aimed at reducing trade union power (International Monetary Fund, 2009; Kelly, 1998, p. 61; Kochan et al., 1986, p. 58). Employer strategies to curb trade union power fall into two main categories, supressionist and substitutionist.

Suppressionist strategies can only be used in workplaces where no formal trade union representation exist and aim to suppress existing or expected attempts to organize a workplace that include preventing trade union employees from entering the workplace and laying off employees who are also union organizers (Gall and McKay, 2001, p. 99). The effectiveness of this strategy depends largely on the state regulations of the country. For example, in the UK employers can deny trade unions access to the workplace and there is very little dismissal protection to provide employees recourse in cases of wrongful dismissal, whereas in Germany trade unions are legally allowed to enter a workplace during normal working hours and there is strong dismissal protection,

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particularly for employees engaged in union organizing activities (McCracken and Sanderson, 2004, p. 279).

Substitutionist strategies are more encompassing and consist of employer attempts to supplant the need for trade union representation by being proactive and reactive to employee needs. Strategies include having an “independent” process for resolving employee grievances with the employer and establishing mechanisms for employees to have a voice in the organization (Gall and McKay, 2001, p. 102). A side effect of this kind of strategy is that employee commitment to the employer is increased and perception of the need for trade unions is reduced (Gumbrell-McCormick and Hyman, 2013, p. 37). Both Marxists and anti-Marxists believe the focus on substitutionist strategies represents the demise of the old adversarial system of industrial relations with the birth of new forms of union-employee relations (Kelly, 1998, p. 109). This belief is supported by the growing field of human resource management (HRM) and changes in the focus of industrial relations academic literature.

The rise of HRM specialists trained in behavioural science poses a challenge to the traditional configuration of employer, union and employee as the employer can insert HRM specialists between themselves and the trade union so they do not need to communicate with the union directly (Kochan et al., 1986, p. 62). Through their position in the organization HRM specialists can also propagate suppressionist or substitutionist strategies at the behest of management. There is also a growing body of literature around management strategy, how to change worker attitudes towards unions, etc. with a corresponding decline of literature written about employee organization and mobilization (Kelly, 1998, p. 20,42). An antagonistic employer point of view creates additional challenges for trade unions, for instance it is difficult to construct a partnership with an organization that would prefer you did not exist and employees are typically less willing join a trade union if they perceive their employer is opposed to their membership and it risks their position, be it their reputation with supervisors or diminished work opportunities (Cardador, Grant, Lamare & Northcraft, 2017, p. 562; Kelly, 1998, p. 63). The impact of substitutionist strategies has been called into question by Storey (1994)

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who studied 15 major employers and found little evidence of a radical shift in traditional personnel policies towards a new integrated HRM strategy (in Ruysseveldt and Visser, 1996, p. 73). Similar to the other structural factors discussed thus far, employers exploring alternatives to trade unions, through suppressionist or substitutionist strategies, in itself is not a convincing reason for facilitating or restricting trade union density, however when combined with other factors does have an influence.

1.5 Structure of the Labour Force

Change in the composition of the labour force8 provides the most obvious explanation for trade union decline according to Kochan et al. (1986). As the composition of the labour force changed from the 3M world of manufacturing, manual and male that dominated Western Europe after World War II, trade unions were not willing or able to adapt to recruit new types of workers such as women, white-collar professionals and youth, so membership levels fell.

Trade unions were at peak density in the 3M world of standard employment contracts, full time work and a reasonable expectation of continued employment with an employer until retirement; members were easy to recruit as trade unions were recognized by state and employers, and employees were centrally located, worked in similar roles and had a collective identity based on their position in society (Ebbinghaus and Visser, 1999, p. 137; Gumbrell-McCormick and Hyman, 2013, p. 33; Visser, 2007, p. 107). As the number of service jobs grew this world became the minority, structural changes since the 1960s contracted traditional union strongholds with the fall of mass employment in the 3Ms and growth in white-collar corporations, the feminization of the workforce, the rise of small and medium organizations, the disbursement of workplaces, an aging membership with youth uninterested in unionization, and an increase in flexible and temporary employment (Ebbinghaus and Visser, 1999, p. 141; Gumbrell-McCormick and Hyman, 2013, p. 33; Kochan et al, 1986, p. 53; Western, 1997, p. 150). The responses of

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trade unions to these shifts in the labour force had an impact on their ability to recruit new groups of workers.

England has been historically weak at recruiting new members particularly in new areas of employment (Howell, 1999, p. 56). The TUC launched the “Organizing Academy” in 1998 to train specialist organizers, typically from underrepresented groups, its explicit purpose was to promote the recruitment and organization of groups underrepresented in English trade unions, specifically: women, young workers, service workers and ethnic minorities. In the 1990s recruitment campaigns were expanded to include migrant workers, atypical workers and private sector professionals. Strategies varied across unions and differed depending on the industry, size and resources of the union. For instance UNITE took a coordinated sectorial approach that also involved training trade union organizers in recruitment methods (Simms, 2010).

German trade unions also neglected recruitment outside of the traditional manufacturing strongholds until the 1990s. Early responses to economic crisis focused on saving the core-manufacturing stronghold or “insiders” and in the process robbed the rest of the economy of its core industry lead. In order to protect the “insiders” unions agreed to allow for a lower-tier of employment based on non-standard or ‘atypical work’ creating “outsiders” within their membership (Palier and Thelen, 2010, p. 7,39). To date, Germany still has the largest gender gap between unionized women and men in Western European countries but in recent years trade unions have launched campaigns to target employees in the private sector, young workers, women and part time workers (Dribbusch, 2010).

In contrast, with a trade union density of over 50% in Belgium, member recruitment is not considered a priority. Men and women have been and remain fairly equally represented in trade unions as well as equally represented in different age groups and sectors. Instead of focusing on the recruitment of members trade unions focused on encouraging members to be active by participating in the trade union and acting as representatives in workplaces (Van Gyes, 2010). The Belgium example counters the

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assertion made by Kochan et al. (1986) that trade union decline is due to changing structure of the labour market, the Belgian labour market has shifted in composition just as in other countries, but has managed to maintain a high membership rate. This is not to say that the changing structure of the labour market did not have an influence in Belgium, it may be that trade unions were already attractive to new groups in the labour market or other factors. For many Western European countries, including the UK and Germany, falling membership rates creates a cycle, as trade union membership continues to shrink trade unions find it difficult to allocate adequate resources to recruit members from a heterogeneous workforce who are more dispersed - particularly with diminished funds from a shrunken membership (Dølvik and Waddington, 2004, pp. 17-20; McCracken and Sanderson, 2004, p. 277).

1.6 Group Identity

Over time the group identity of working people or the working class has changed from a collective identity based on common needs and desires to a more individualistic identity where individual interests take precedence (Gumbrell-McCormick and Hyman, 2013, p. 34). The identity of the collective working class was forged by a combination of historical conditions in the 19th century; poverty, job insecurity and high unemployment led the working class to take a strong collectivist outlook. Workers came together against the common threat of the employer; in their subordinate position they stood in solidarity for changes in pay and working conditions (Gumbrell-McCormick and Hyman, 2013, p. 79). Trade unions provided a necessary function by helping the working class define their collective interests and facilitating the achievement of those interests through organizing strike action, collective bargaining and/or employee representation. This collectivist outlook with high trade union involvement was strengthened by the concentration of housing in working class communities, and mutual dependence and solidarity in large factories performing similar work (Kelly, 1998, p. 39). After World War II, many Western European countries, with the exception of the UK who held onto its voluntaristic ideals, institutionalized class conflict into modern capitalist societies, with trade unions gaining organizational stability and recognition by both state and employers (Ebbinghaus and Visser, 1999, p. 137). However, by the latter half of the 20th century the collectivist

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tradition, onto which the industrial relations system had been built, had largely eroded. Work took place in smaller workplaces, work activities became increasingly varied, workers become more affluent causing the rise of the middle-class and they dispersed from working class neighborhoods with the rise of affordable transportation and housing (Kelly, 1998, p. 40). The main device for worker self-improvement was shifted from engaging in collective organization to investing in individual education and training. As class boundaries became fuzzy and individual interests took precedence, individuals were no longer willing to combine their interests with a more broadly defined class identity. Durkheim supported this assertion before the decline in collective interests, saying that the division of labour threatens the shared consciousness of individuals who share similar needs and demands of society, with a new consciousness based on independence sharing a consciousness of similar need and demands is problematic and slow to emerge (in Tilly, 1978, p. 17).

Group identity is a social factor limiting trade union density as workers with a purely individualistic view have trouble seeing how they would benefit from collectivist action and tend to prefer to rely on own knowledge, skills and abilities to further their interests and achieve their goals.

1.7 Individual Perceptions of Trade Unions

The last factor influencing trade union density is a more abstract grouping of perceptions of trade unions. Individuals may view trade unions as a means to assist with feelings of injustice towards an employer, feelings of moral duty towards the collective and the body that bargains on behalf of the worker, feelings of social belonging and group identity or feelings of maintaining a family tradition of participation. They may also fear the trade union as any association will result in retribution from their employer, individuals may feel that they do not need a trade union because they are good at their jobs or that they should not join a trade union as they already receive many trade union benefits as employers expand collective agreements to non-members. These perceptions are just some of the millions of individual perceptions of trade unions that can either have a positive a negative effect on trade union membership. Examples of individual perceptions

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in relation to reputation, injustice and social norms will be provided to illustrate this factor. Booth and Chatterji (1993) found that to a certain level of union density trade union membership was considered to have a positive effect on an individual’s reputation encouraging a positive effect on trade union membership. On the other hand, under a certain density level union membership was seen to have a negative effect on one’s reputation in an organization resulting in a corresponding decline in a trade unions ability to recruit members. Kelly (1998) proposed that trade union density decline could be attributed to fewer employees experiencing injustice at work, caused either by employees having increased trust in management or protectionist legislation. However he found the amount of complaints against employers to the Citizens Advice Bureau was increasing and data from the UK demonstrated that employee distrust in management was rising significantly, demonstrating that there is still the need for trade unions. A social norm of membership based on collective interests allow trade unions to recruit individuals who will become loyal members embedded in a group with reputation and prestige benefits (Goerke and Pannenberg, 1998, p. 1; Visser, 2007, p. 112). Research in West Germany and Great Britain found that social aspects and feelings play a crucial role in individual decisions to join trade unions for example in West Germany if a father is/was in the trade union the son is much more likely to be a member as well (Goerke and Pannenberg, 1998, p. 17). This last factor has presented a scattering of ideas but has illustrated that individual perceptions do indeed play a role in trade unions ability to recruit members.

The framework presented consists of the structural and social factors that impact a trade unions ability to recruit members and therefore influence trade union density. Developed though literature review it provides an encompassing range of factors that may influence a trade unions ability to recruit members, for better or worse. The effect of international pressure, influence of the business cycle, impact of the state, employer alternatives and structure of the labour force, group identity and individual feelings towards trade unions, are not able to individually explain causes for trade union decline but when considered as a whole series of interwoven factors they offer insight into the complexities of trying to explain the reasons for trade union decline. This framework will be referenced frequently

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in Chapter 3: Analysis to provide context to the institutional mechanisms under investigation.

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Chapter 2: Design and Methods

Investigation into the mechanisms that facilitate or constrict trade union recruitment underwent two phases, the literature review and qualitative investigation involving employees of trade unions that represent nurses in the UK, Germany and Belgium. The first phase consisted of literature review to provide sensitizing concepts to facilitate and generate areas of inquiry into the topic being explored and provided a framework of structural and social factors that impact trade union density, results provided in Chapter 1. The second phase encompassed qualitative research in the form of semi-structured interviews with trade union employees who work for unions that represent nurses. The structure and analysis of these interviews was guided by Charmaz’s (2001) constructivist grounded methodology applied for a mechanism-focused approach. This chapter will proceed by introducing the concept of grounded theory and its evolution towards constructivist grounded theory, outline the application and limitations of the methodology and will then discuss mechanisms and the interview strategy.

2.1 Introducing Grounded Theory 2.1.1 Classic Grounded Theory

Grounded Theory (GT) was developed in 1967 as the result of collaboration between Barney Glaser and Anselm Strauss who felt that sociological study had become too focused on verifying theory and quantitative “facts”. These authors advocated for a reemergence of theory generation based on interviews, observations and qualitative analysis. Glaser and Strauss published The Discovery of Grounded Theory: Strategies for Qualitative Research in 1967 to describe their approach (Glaser and Strauss, 1973, p. 10; Kenny and Fourie, 2014, p. 2). Theoretical underpinnings of GT are based on the merging of the authors’ areas of expertise. Glaser’s rigorous quantitative training, epistemological assumptions, logic and systematic approach with Strauss’s pragmatic philosophical tradition and close links to symbolic interaction, process, actions and meaning, made them an ideal duo to marry the popular quantitative approach with the underappreciated qualitative approach (Charmaz, 2001, p. 336). This merging of methodology is visible in the defining components of GT: simultaneous data collection and analysis, constructing analytic codes and categories developed from the data not from

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preconceived ideas about the data, performing constant comparisons to continually advance theory development, memo-writing to explore and define categories and conducting literature review only after developing independent analysis (Charmaz, 2014, p. 7).

In the 1970s and 1980s, Glaser and Strauss separately published GT guides with their individual theoretical background emphasized in each text. This schism resulted in the branching off of Strauss’s Straussian Grounded Theory, discussed in the next section, and left Glaser defending what he considerd to be “true” GT commonly referenced as Glasserian or Classic Grounded Theory (Kenny and Fourie, 2014, p. 4). Glasserian GT does not acknowledge its pragmatist roots and maintains a heavy emphasis on positivism and on not reading any literature on the topic of interest so as not to allow it to influence the direction of the research (Flick and Charmaz, 2017, p. 37; Glaser, 1992, p. 31). Glaser emphasized not ‘forcing’ data but allowing themes to emerge from research conducted in the field (Glaser, 1992, p. 3).

2.1.2 Straussian Grounded Theory

Strauss published the first book on his branch of GT in the 1970s and by the 1990s had formed an academic partnership with Juliet Corbin and together they refined the features of Classic GT. They developed a more rigorous coding framework guided by the philosophy of pragmatism and symbolic interactionism, and challenged the tenet of abstaining from literature review prior to analyzing data, emphasizing the difference between an “open mind” and an “empty mind” (Kenny and Fourie, 2014, p. 4). The theoretical foundation of pragmatism and symbolic interactionism are worth discussing at this point to ensure an understanding of the basis and benefits of grounded theory. Pragmatism is an American philosophical movement marked by a view of reality as fundamentally social and processual, life is social and in process, reality is fluid and indeterminate and stability is problematic (Corbin and Strauss, 2015, p. 17; Flick and Charmaz, 2017, p. 38). On the other hand, symbolic interactionism is the study of how individuals use and interpret symbols, not only for communication but also to create and maintain impressions of ourselves, and create and sustain what we perceive as reality

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(Corbin and Strauss, 2015, p. 17). Symbolic interactionisms rests on three main premises: that individuals act toward things on the basis of the meaning they feel toward those things, that meaning of such things is derived from the social interaction individuals have with other individuals and that meaning is handled in and modified through an interpretative process used by people in dealing with the things they encounter (Blumer, 1969, p. 2).

Strauss and Corbin (2015) accept that meaning is a social product generated by individual interactions with other individuals and advocate for the recognition that the researcher acknowledge that they have perspectives, training, knowledge, assumptions and bias that shape how they see the world as do those they are interviewing. A researcher should therefore aim for sensitivity, as objectivity is not achievable. Therefore, an “open mind” describes being sensitive to what the data is actually saying and not forcing conclusions derived from literature review upon it and an “empty mind” is what you would have if you had not conducted any preliminary research.

2.1.3 Constructivist Grounded Theory

Inspired by Straussian GT, Charmaz applied postmodernist and post-constructivist paradigms to the methodology to develop constructivist GT, published as Constructing Grounded Theory (2006) almost 40 years after GT was first introduced to the sociological world (Corbin and Strauss, 2015, p. 25; Kenny and Fourie, 2014, p. 6). Constructivist Grounded Theory (CGT) adopts the original tenants of GT and translates them into contemporary research paradigms. Like Strauss, Charmaz rejected Glaser’s underlying philosophy of discovering an implicit theory, taking the pragmatist view that we do not discover but construct GT through our past and present involvement with people, perspectives and research practices (Charmaz, 2014, p. 10). Unlike Strauss, Charmaz found highly systematic coding process overly prescriptive and proposed flexible guidelines, which would raise questions and outline strategies and possible routes, as an alternative (Kenny and Fourie, 2014, p. 6). CGT is an emergent method that differs from Classic and Straussian GT by: assuming a relativist epistemology; acknowledging the researchers and the research participants multiple standpoints, role

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and realities; adopting a reflexive (cause and effect) stance toward a researchers background, values, actions, situations, relationships with research participants and representations of them; and situating research in the historical, social and situational conditions of its production (Charmaz, 2017, p. 299).

2.2 Applying a Constructivist Grounded Theory

Constructivist grounded theory provided an ideal framework for this thesis as it outlines a discovery method involving literature review, interviews, coding, analysis, memos and constant comparison; where research results inform mechanism development and the participants standpoint, role and reality is considered. The research was conducted in two phases, the literature review and the qualitative analysis phase.

2.2.1 Phase One - The Literature Review

As advocated by Strauss and Corbin (2015) and Charmaz (2014) the first phase of investigation involved an extensive literature review to determine the research that had already been conducted around factors influencing trade union density. To become sensitized to the topic, a review of the literature was also conducted on the historical context of industrial relations systems, and explanations of trade union density decline was investigated from the social sciences and other disciplines such as economics and business. The research conducted by social scientists and other disciplines was analyzed and synthesized into a unique framework of structural and social factors that influence trade union recruitment, described in Chapter 1.

Sensitizing concepts around institutional factors were used to develop the mechanisms under investigation in the qualitative analysis phase. Historical support and examples are provided where appropriate to illustrate the validity of the mechanism and to provide contextual support on the countries being compared. Though an extensive literature review took place before interviews were conducted it was performed to generate sensitizing concepts and informed, rather than directed the research. A criticism of Classic GT, shared by Charmaz (2014), is that it is impossible for researchers to come into a situation without any prior knowledge or thoughts, their academic and

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