The lobbying Dutchman : how do Dutch businesses use the domestic channels available to them to lobby the EU?

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The Lobbying Dutchman: How do Dutch businesses use the domestic

channels available to them to lobby the EU?

Marnix A. Kleinjan (11932554)

Supervisor: Philip Schleifer Second Reader: Jasper Blom

June 21, 2019

Master Thesis Political Science – Public Policy and Governance Word Count: 18 496

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‘I think the Dutch Permanent Representation in Brussels is always a part of Dutch companies’ lobbying strategies in the EU’

- Anonymous respondent at the Dutch Permanent Representation in Brussels in a personal interview for this study1

Abstract

This thesis analyses and explains the high level of Dutch corporate lobbying through the domestic channel of the Dutch Permanent Representation to the EU. Current trends and prospects for the future of Dutch corporate lobby are discussed in the framework of multi-level lobbying theory and socialisation theory. While research on lobbying in the EU is a complex topic in terms of transparency and gaining access to information, this essay adds a refreshing perspective to literature by using socialisation logic to explain a dynamic that is often overlooked in literature on lobbying: the role of domestic channels in corporate lobbies. This thesis explains why Dutch firms focus so heavily on lobbying the national Permanent Representation of the Netherlands in Brussels. Dutch firms are in fact increasingly using other venues than the Permanent Representation in Brussels, yet it is still easiest to use in terms of existing connections between businesses and involved ministries, the revolving door process between the Dutch public and private sectors, which is particularly strong in the Netherlands, and also in terms of ease of access to the policymaking process through the Permanent Representation.

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List of abbreviations

CEO – Corporate Europe Observatory DG – Directorate General

EC – European Commission

ECPR – European Consortium for Political Research EP – European Parliament

EU – European Union

FOI – Freedom of Information FTA – Free Trade Agreement FTE – Full-Time Employee FTM – Follow the Money IR – International Relations

NGO – Non-Governmental Organization

OECD – Organisation for Economic Cooperation and Development PermRep – Permanent Representation

SOMO – Centre for Research on Multinational Cooperations UK – United Kingdom

US – United States

VNO-NCW – Dutch Employers’ Federation WTO – World Trade Organisation

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1. Introduction

1.1. Research Overview

A quick glance at any international newspaper suggests that multinationals and interest groups are often successful in securing their interests at national and supranational institutions. Looking at the physical resources companies invest in lobbying at the EU, this idea is confirmed: estimates are that there are over 25,000 lobbyists working in Brussels at the headquarters of the European Union (EU) (Lundy, 2017: 3). This amounts to estimations of over €1.5 billion (…) spent every year on lobbying targets like the European Commission, the European Parliament, the Council of Europe as well as Brussels offices of national governments (Lundy, 2017: 3). This investment by companies in lobbyists and interest groups in Brussels suggests that there is a strong relationship between the multi-level lobbying efforts of firms or interest groups and policy outcomes at a European level. Yet, analysing the existing research, there are several problems. First, there is a plethora of information and theorisation on lobbying in the US and secondly there is an emerging literature on corporate lobby at EU institutions (Ehrlich & Jones, 2016: 469). The problem is therefore twofold: EU corporate lobby is a field that changes fast, both in terms of empirical research and regulation, but it is also notorious for the difficulty of gaining access to information (Bouwen, 2004: 337). To complicate matters, different European institutions receive varying degrees of attention when it comes to research, even though most theoretical research suggests lobbying is a multi-level process, where multiple institutions are targeted. In this light, national institutions that are involved in EU policy formation processes are consistently overlooked or deemed of relatively little importance in the existing literature on lobbying. This is an issue, as direct lobbying at EU institutions is extensively studied, but the indirect path remains more obscure, even though it may play an important part in corporate lobby strategies. This is, despite important exceptions (Hafner-Fink, Novak & Fink-Hafner, 2014; Beyers & Kerremans, 2012; Witteman, 2019), an unexplored aspect of lobbying in the EU that is indeed more difficult to study in terms of data collection and availability (Bouwen, 2004: 337), but one that is necessary to get a more complete understanding of corporate lobbying for favourable policy outcomes in the EU. Research on the domestic channels that lobbyists use becomes even more salient as lobbying is typically associated with secrecy and unfair advantage, while public pressure is rising worldwide to put lobbying regulation on the political agenda, as a lack of transparency may actually decrease public trust in institutions (OECD, 2014).

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Interestingly, lobbying at the national level is an important channel in EU lobbies (see Table 1). Partly because it is understudied how businesses lobby through the domestic channels, regulatory measures on lobbying activities are difficult to implement at national and European institutions. Similarly, there is also relatively little research on the strategies used by lobbyists at the national level, and to what extent these might differ from strategies used at the European level. This indirect path of lobbying through national institutions is defined in this study as the domestic pathway2, as it concerns lobbying for European policy outcomes at a national level and is considered to be part of a range of channels available to lobbyists. The goal for a lobbyist or interest group in using such a domestic pathway would be to influence the European policy formation process in such a way that the national government may act as a ‘middleman’ in it. This implies that the domestic pathway includes all national institutions of a target country, including permanent representations (PermReps) in Brussels. This thesis therefore uses the term domestic pathway to describe the aspect of lobbying where national governments may be mobilized to advocate on behalf of a certain company or interest group.

1.2. Research Aims

This research project aims to show three facets of Dutch business lobbying in the EU: firstly, there is the observation that the domestic pathway is a primary target in Dutch firms’ lobbying strategies, more so than for firms from other European countries. The second facet tries to explain this observation through theory-testing. Classical multi-level lobbying theory that stems from rational choice theory cannot fully explain the strong focus of the Dutch business lobby on the domestic pathway, however a combination of socialisation theory and multi-level lobby theory can. For this part of the study, I am using one illustrative case study on the Dutch Permanent Representation in Brussels and I explain the links to corporate lobby and the strong Dutch corporate preference for the PermRep. The last part of the study places the observations and explanations in a more transnational perspective, in which some factors are identified that play a part in how Dutch businesses shape their lobbying activities on a national and European level. In this research, as with any research on lobbying, transparency and access to information is a challenging problem. I refer to issues on transparency in the methodology section and the concluding remarks as to maintain the focus on the research

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question, yet it is important to be aware of this general difficulty of access to primary information on physical lobbying activities throughout the entire paper.

1.3. Lobbying: A brief description

Evidently, the meaning and context of lobbying in this study needs to be clear, as many studies analyse lobbying under different circumstances and as a profoundly different process (mostly in terms of institutional context & strategies). While the section on the theoretical framework elaborates on the elements to – and the theory of – lobbying, it is useful to briefly establish what lobbying entails, as it is often dependent on the institutional context.

This study uses the relatively broad Encyclopaedia Britannica’s definition of lobbying being ‘any attempt by individuals or private interest groups to influence the decisions of government’. While the involvement of individuals, NGOs and private actors all fall under this definition, the scope of this paper is limited to any attempt by private firms (companies) to influence the decisions (and subsequently policy outcomes) at the European level through the domestic pathway. In the context of this research paper, to lobby the EU therefore means to attempt to influence European policy outcomes and the focus here is on the national channel. The chapters on the literature review and theoretical framework further engage with literature on lobbying in the EU and establish the unique and multi-level aspect of it.

1.4. Research Question and sub-questions

The research question of this paper is: How do Dutch businesses use the domestic channels available to them to lobby the EU?

This question is largely descriptive and consists of three underlying questions that this paper seeks to answer. These questions guide the work throughout the thesis, and link the empirical findings to existing research and theorisation on lobbying in the EU:

- What venues/institutions are part of the ‘domestic pathway’ that Dutch firms use in their lobbying efforts? (descriptive & illustrative case selection)

- How do the lobbying venues that Dutch businesses use relate to multi-level lobbying theory? (analytical & explanatory)

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This research assumes that European policy goals are by definition not always aligned with private actor policy goals, sometimes resulting in more difficult cooperation between private actors (or firms) and European institutional actors. This may also explain, to an extent, grouping under the umbrella of sectoral interest groups, as firms may herewith generate more attention (Ainsworth, 1993). Another assumption of this research project is that there are indeed different pathways for influencing European policy formation processes, and that such pathways are by no means mutually exclusive (Public, 2019), this assumption is closely related to multi-level lobby theory. The national pathway is one that is significantly different from the other pathways that firms may use in terms of dynamics between the companies and institutions involved and in terms of lobbying strategies. However, this path is also complementary to other channels of lobbying.

1.5. Societal and Academic Relevance

Perhaps more so here than in previous studies, questions concerning lobbying influence across European institutions are of societal and academic relevance. The same is true for lobbying efforts and influence across the national institutions of member states. Lobbying in the EU involves more institutions and different layers of governance (Panke, 2012;Beyers & Kerremans, 2012; Klüver, 2011, 2013). Revealing the links between lobbying efforts and policy outcomes can have consequences for the cooperation between the private and the public sector, but also for transparency regulations at different institutions and people’s trust in national and European institutions (Witteman, 2019b). It is certainly true that European institutions have become more transparent in the last years, yet if research suggests that firms can influence policy outcomes to an unreasonable extent and that this influence has only grown despite such regulations, public trust in national and European institutions may still be damaged. The other side of this argument is of course that total transparency is also not ideal, as policymakers need to be able to operate with the freedom of thought (Wolfs, 2019; Public, 20193). The relevance of this study, however, stretches further than paving the way for more effective regulation of business interests in domestic channels. The societal relevance of this paper is not only that it investigates the relationship between Dutch corporate lobbies and State institutions and the relevance of this on a European level, but also as it studies the strategies that firms employ and questions their nature. By implication, this study is therefore

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This contributor’s name has been anonymised on their request. Information was obtained in a personal interview.

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both societally and academically relevant because it discusses the overall trends in Dutch corporate lobby strategies within the EU, and links this to a theoretical framework to explain such developments

Different stakeholders interviewed for this research project (including an investigative journalist, a researcher, an ex-lobbyist and a diplomat from the Dutch PermRep in Brussels) confirmed that the public interest in private actor lobbying efforts has steadily grown, and so has the influence and power of European institutions that are involved in policy formation processes. Following this trend, companies’ interest in EU institutions as targets for lobbying efforts has also increased (Wolfs, 2019). For a part, this development might explain the cooperative attitude corporate lobbyists take in communications with European and national policymakers, and the relative difficulty in researching more competitive corporate lobby practices (Bouwen, 2004). Examples of more competitive lobbying strategies include donations, funding, blurring or delaying policy decisions (Woll, 2012; Witteman, 2019b). Interviewees and academics alike also confirm that research on the national channels of lobbying lags behind research on lobbying in Brussels. Additionally, interviewees stated that in theory, national and European transparency directives are a good way to increase public trust in institutions, but in practice, requests for information such as notes, email conversations, or donation information is delayed, denied and/or heavily redacted (see e.g. Appendix 1 for a delayed FOI request to the European Commission). Furthermore, one respondent addressed the legalisation of the FOI procedure that makes it impossible to obtain any information or documents without legal support or advice (Wolfs, 2019). This suggests that the societal relevance is also in mapping the FOI request procedure and suggesting points of improvement.

At an academic level, the research investigates in what ways Dutch firms try to influence policy outcomes (both in terms of venues and interaction modes) and if they behave as the existing literature on EU corporate lobby suggests. The academic relevance here is that this approach combines theories into an overarching analytical framework and makes a start at empirically examining and explaining Dutch firms’ lobbying methods and techniques. Similarly, it engages with the wider debate about industry influence in Brussels and tries to establish the link between lobbying efforts and policy outcomes. In doing so, this paper creates an overarching framework on multi-level lobbying theory and socialisation theory within which lobbying venues and strategies can more systematically be observed. As mentioned before, such an overarching analytical framework has up till now been missing in

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broader research on lobbying and attempts at making such a framework have only been used in studies that see lobbying exclusively as a communication or networking strategy (Milbrath, 1960: 32; Ainsworth, 1993: 44; Princen, 2011: 927; Chalmers, 2013: 475). This paper acknowledges the importance of such literature as it describes an aspect of lobbying techniques that is also used in the case of Dutch firms. However, I also seek to contribute to the gradual re-conceptualisation of what is meant by “influence on policy outcomes” in contemporary literature and transparency registers alike. Such a re-conceptualisation aims to demonstrate that lobbying strategies are not limited to communication or networking events, nor are they limited to a single institution. In fact, such efforts can be categorised into two distinct “sides”, one being to maintain the status quo (or stopping unwanted change) and the other to encourage change (Baumgartner, 2009). That being said, this research suggests that Dutch companies’ lobbying strategies do in fact rely mostly on communicative lobbying as opposed to competitive lobbying. The academic contribution of this paper is relevant, as it takes into account the changing theoretical perceptions of lobbying. In addition, the normative focus of studies on corporate lobbies has relied primarily on the EC (Bouwen, 2004; Klüver, 2013), and more recent literature has focused on the EP (Marshall, 2010; Panke, 2012; Marshall & Bernhagen, 2017) and the Council (Panke, 2012). While more classical theories recognise lobbying as an act that takes place in all branches of government (executive and legislative), the observations of this study suggest a slightly different conceptualisation.

The societal and academic relevance of this paper hence concerns a combination of three factors: 1) it addresses a research gap in literature on corporate lobbying, 2) it considers the strategies business interests use in lobby efforts (both in terms of methods and techniques) and respective effects and 3) it discusses how normative theory on lobbying can only explain a portion of the findings of this research project, and therewith uses socialisation theory to contribute to the gradual re-conceptualisation of the process of lobbying in the EU.

1.6. Structure

The thesis is structured in the following way: Chapter 2 presents a literature review on lobbying strategies in the EU and recent developments in terms of diversification of lobbying targets. It explores different pathways available to lobbyists to influence policy formation processes, and points to several gaps in the literature on lobbying. These gaps mostly concern

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the relevance of lobbying through the domestic pathway, in particular in relation to strategies used by lobbyists to secure national support on EU legislation. Chapter 3 continues to set out the theoretical approach of the research project. It provides the conceptual definitions that are used throughout the thesis, such as the institutional context, and continues to explain lobbying in relation to multi-level lobby theory, where firms seek to maximise their impact by selectively lobbying a range of institutions on all levels. As a supplementary explanatory theory, this thesis introduces socialisation theory in lobbying, where companies are thought to be socialised within a specific national system, and where this is mirrored on an international (EU) level. Chapter 4 includes the methodological considerations of the research project, such as a discussion on the research approach, research design, elements of study, validity and reliability concerns. This chapter is particularly important as it describes the difficulty of gaining access to information in studies on lobbying, and the considerations that were made in the research process. Chapter 5 and 6 are the empirical chapters. Chapter 5 presents the illustrative case studies and the choice of strategies that lobbyists took in these. This gives a clearer picture of how Dutch firms attempt to influence European policy outcomes through the domestic pathway. The last chapter discusses the relative success of Dutch firms in influencing policy outcomes through the domestic pathway, and it integrates these findings into a discussion which connects the empirical discoveries to the theoretical debate on lobbying. This chapter also debates the transparency of institutions on a national and European level, with some suggestions for improvement. The last chapter then summarises the research project and rounds off with lessons learned, adding to the academic and societal relevance.

2. Literature Review

Concerning the existing literature on lobbying in the EU, it is a rapidly expanding field with increasing focus on the different institutions that are targeted by lobbyists in Brussels. It is not always evident in what ways and to what effect European and foreign firms attempt to influence policy outcomes at a European level (in other words, what the actual lobby strategies are), but some authors suggest frameworks where lobbying is either presented as a communication strategy (de Bruycker, 2014; Eising et al., 2017) or a more in-depth influencing strategy that includes more competitive mechanisms (Rasmussen, 2015). It seems however, that there is no generally accepted framework which connects the different

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tactics available to lobbyists (Princen, 2011: 928, de Bruycker, 2014: 4), nor is there significant overarching research that connects companies’ lobby efforts at different European institutions involved in European decision-making processes. Another problem is that the domestic pathway is understudied. This paper uses the term ‘pathway’ to describe different lobbying targets in attempts by business interests to influence policy outcomes. A problem that emerges throughout multiple studies, is that there is a need for more of ‘a shift from exploratory or descriptive interest studies to more confirmatory theory testing’ (Coen, 2007; 333). While it is absolutely necessary to describe an observed trend in the context of this study, this paper seeks to test multi-level lobbying theory in the case of Dutch institutions that are part of the EU policy formation process. As such, this paper uses multi-level lobby theory and socialisation theory to contextualise Dutch businesses’ lobby efforts through the domestic pathway and uses an illustrative case study to explain the theory. The illustrative case study used in this thesis is the Dutch PermRep in Brussels.

There are different European institutional pathways for lobbyists to use, such as the European Commission and its’ open consultations process, the European Parliament, or the Council, and there is also the national pathway (including the permanent representation of a country in Brussels) (Van Hecke, Bursens & Beyers, 2016). In emerging literature on the institutional context of lobbying EU institutions, the national pathway has not received much attention, but I show that this does not mean that it is not important. In fact, the national pathway provides a means of lobbying that allows for more subtle influence and sometimes different tactics than those observed at the EU level. This paper looks at the strategies of Dutch companies in the ‘domestic pathway’ of lobbying at the EU, but it is nonetheless important to connect these strategies to an overarching framework of lobbying theory. This way, it becomes easier to define in what ways the domestic pathway differs from lobbying at other European institutions, and what makes it such an important aspect of lobbying efforts. This approach also highlights that the domestic pathway does not stand alone in a lobby strategy but is one that is often complementary to campaigning at other EU institutions.

This paper hence considers lobbying at a national level that is generally part of firms’ broader strategies in influencing European policy outcomes. In that sense, a comparable trend takes place at EU institutions and at national institutions alike, namely one of more physical spending on lobbying efforts and simultaneously closer collaboration between institutions and firms (Coen, 2004: 188; Documenten Rijksoverheid, 2018; Witteman, 2019b; Wolfs, 2019). Although spending on lobbyists at the national level as opposed to the EU level is

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presumably significantly lower and details are indeed sometimes more difficult to access, it appears that there is also a link between lobbying efforts4 and policy outcomes at the national level. It is not as if increased spending equates to more influence over policy outcomes, but it is often a cause for concern over the integrity of any institutions targeted by lobbying activities (Witteman, 2019b). Specifically in the case of national institutions across EU member states, there is a sharp contrast between countries’ level of regulation, and although the Netherlands has more recently passed stricter regulation of lobbying activities, it remains a country where business interests enjoy a relative ease of access to the policy-making domain5. This may form an issue if national parliaments (in the form of scrutiny) and governments (including ministries and permanent representations) alike play an important role in the European legislative process (Witteman, 2019b; Wolfs, 2019), as these may in fact be the weaker links in terms of transparency and regulation of lobbying. Although the process of lobbying at various European institutions such as the European Commission and the European Parliament has progressively gained more attention in academic literature and amongst investigative journalists studying transparency (Wolfs, 2019; Witteman, 2019a, 2019b), the focus of lobbyists may have diverged towards national institutions of member states of the European Union. With lobbying at European institutions on the one hand and lobbying at national institutions on the other hand sharing a lot of similarities, it is mostly the complementarity of the different practices that remains understudied. The problem with research on lobbying at national institutions is evidently also that it is often more difficult to access for researchers, with possible barriers in language, transparency or availability of research and information.

A large part of the existing literature on lobbying can be roughly divided into two categories, namely one on lobbying in the US and the other being lobbying in the European Union. While theories on corporate influencing can be applicable in both the EU and the US, the institutional context (and therefore the lobbying strategies, as these are dependent on the institutional context) is distinctly different in both cases. For the purpose of this paper, the literature review looks exclusively at studies on lobbying in the EU, while the chapter on the theoretical framework is broader in that it includes theories that come from experience with lobbying in the US as well as the EU. This ensures that all literature that is referenced is applicable.

4_{For the purpose of this study, ‘lobbying efforts’ is used as the umbrella term for all tactics as displayed in} Table 2 (Appendix 1)

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There is ample of literature and resources on lobbying in the EU, with a heavy focus on the lobby of interest groups at the European Commission (Klüver, 2013; Bouwen, 2004). Indeed, interest groups, including those representing private actors, can frame a debate in such a manner that it ‘has an impact on the policy options that are considered by decision makers and on the final outcome of a legislative debate’ (Baumgartner & Mahoney, 2008; Klüver et al., 2015: 482). The primary academic attention to debates with – and within – the EC can be explained by the EC’s right of initiative in the legislative process, whereas the EP and the Council have a co-legislative role. One increasingly used venue to upload policy preferences is indeed the open consultations process organized by the EC (van Hecke et al., 2016: 1434; Chalmers, 2018). The increased attention from interest groups in the EC and other EU institutions such as the EP and the Council is confirmed by increased overall spending on lobbying in the EU (Lundy, 2017: 3). This interest in EU institutions as opposed to national institutions can be explained as EU institutions have become significant policy actors, ‘with interests focusing on agenda-setting and formulation of EU directives at the European institutions, and the implementation of directives and ‘day-to-day’ regulatory monitoring in the member states’ (Coen, 2002: 199). Additionally, interest groups indeed have a bigger voice in EU policy formation processes than individual companies might have (Ainsworth, 1993; Baumgartner, 2010; Berkhout et al., 2017). This also explains why more recently; research looks at the different venues of lobbying in the EU and combines these to form a broader picture of how lobbyists go about their influencing strategies. Such research indicates more generally that the key institutions in policy formulation are the Commission, member states and, increasingly, the European Parliament (Coen, 2002: 201). Even though these are the key institutions in policy formulation, research focuses mostly on the EC and research on member states is only emerging more recently (Beyers & Kerremans, 2012; Hafner-Fink, Novak & Fink-Hafner, 2014; Witteman, 2019a).

There is also an emerging research in lobbying by private firms (in isolation from interest groups) at the EC and other European institutions such as the European Parliament. Such research explains how institutional conditions such as formal constraints in the European Parliament’s committees shape lobbyists’ strategic behaviour (Marshall, 2010: 572). Surprisingly, there is relatively little combined research on the extent and reach of lobbying throughout different European institutions and national institutions, even though this could provide valuable insights into the resources, tactics and goals of lobbyists in and outside Europe (Coen, 2002; Binderkrantz & Rasmussen, 2015; Corporate Europe

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Observatory, 2019). Similarly, on the European executive and legislative levels, there is an array of different national and institution-specific checks and balances to guarantee transparency, accountability and independence6. By implication, primary research for this paper suggests that these different checks and balances still allow for a high level of influence over different institutions that are all part of European decision-making processes. This suggestion will be further elaborated on in the discussion chapter. Furthermore, some research suggests that corporate lobbyists in particular are active and exercise a stronger influence over policy formulation and agendas than traditional consumer and environmental groups do in all relevant European institutions (Grant, 2000; McCormick 2001). Here, it is important to underline that this is in comparison to consumer and environmental interest groups, while sectoral industry interest groups are not studied (Grant, 2000; McCormick 2001). Corporate lobbyists then seem to have an advantage over traditional consumer and environmental groups in both the EC and EP. A feature that nonetheless seems to be recurrent in much of the existing literature is that it fails to supply an overview of lobbying strategies per institution and it likewise fails to suggest credible measures to (re)balance the interests of both the executive power and the lobbyists. This essay therefore suggests a model where lobbying through the domestic pathway is recognised as an important and beneficial factor in European decision-making, yet one that needs to become more transparent and regulated through European standards as opposed to institution-specific or even party-specific standards in order to guarantee accountability of all actors involved in the process. The next chapters look at the lobbying framework in the EU and associated lobbying strategies at the national and EU level.

2.1. The Debate on Lobbying in the EU

European institutions such as the European Commission - and more recently the European Parliament - are studied in light of their exposure to lobbying and its relative success (Klüver, 2011, Chalmers, 2018). The focus of such studies is on the policy formation stage, and a common finding is that lobbying success lies in the nature of the business position – and the power of the industry – and to a lesser extent the messaging of firms (Klüver, 2011, Chalmers, 2018). This suggests that lobbying success – or effective influence on policy outcomes – is largely dependent on the stage at which a business attempts to influence policy

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decisions, but also on the importance of an industry to national or European public interests (i.e. in terms of international competitivity and jobs provision). A striking aspect here is that the messaging of companies in indeed a strategy that is considered of importance to lobbying success, but studies rarely elaborate on other strategies that firms use besides communication, and their relative effect. This is distinctive of much of the literature on lobbying, as a company or industry’s power in relation to institutions are considered primary determinants of lobby success, independent of what lobby strategies a firm or sector may use (Marshall, 2010; de Bruycker, 2014; Hafner-Fink et al., 2014). Furthermore, literature mostly agrees that the earlier in the policy formation a business tries to influence policy outcomes, the bigger the impact may be, but the choice in channels or strategies is not elaborated on in much depth (Chalmers, 2018, Damania & Fredriksson, 2003).

Studies also seek to explain the apparent divergence of attention to European Parliament lobbying and the different approach dependent on the institution (Marshall, 2010; Rasmussen, 2015). An interesting aspect in such descriptive studies is that strategies are considered in more depth than in studies on determinants of lobbying success. In these studies, the multi-level aspect of lobbying is considered of more importance (Scharpf, 1997). Similarly to the aforementioned studies, the apparent switch of attention from one institution to another can partially be explained by firms wanting to be present at every stage of the policy formation process, but also at the institutions that deal with the specific policy fields and formation of policies (Witteman, 2019b; Corporate Europe Observatory, 2019). Table 1 shows what institutions are targeted by lobbyists in European policy-formation processes, and includes the domestic pathway, which has not been considered by the aforementioned studies. In short, such studies indicate that companies are often present at different stages of the policy formation process, and at different institutions. This is relevant to the research question concerning Dutch businesses and how they use the domestic channels available to them to lobby the EU, as a divergence in approach by companies may in fact signify an increased interest in domestic channels in attempts at increasing lobbying success in the EU institutions.

Before turning to existing literature on the role of different domestic channels in corporate lobby practices, the following argument needs to be underlined: states are not only ‘recipients’ of lobbying activities. There is emerging literature on the pro-active role states can play in lobbying efforts. Such literature maps state lobbying efforts in the EU and analyses conditions under which states are likely to engage in such activities (Panke, 2012;

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Witteman, 2019a; Corporate Europe Observatory, 2019). This literature adds a new dimension to lobbying efforts – previously a blind spot in studies concerning lobbying – that includes the role of state advocacy or lobbying at an EU level. Such state lobbying may concern policy fields where state advocacy is logical (i.e. FTAs or environmental regulation). State lobbying efforts may also concern policy fields where state advocacy at first sight seems less obvious. The focus of such literature is most often on the dynamics between EU institutions and EU28 member states and the factors that lead to state lobbying (Van Hecke et al., 2016). It is true that lobbying is an informal strategy to gain influence on policy outcomes, where policy outcomes are influenced via contacting key decision-making actors and disseminating reasons to make them support one’s own interests (Panke, 2012: 145). Yet what is left out of such analyses is still the indirect path, where key decision-making actors or bodies are not per se targeted, but rather state institutions that essentially act as middlemen. While these dynamics are a good object of study to better understand the role of states in EU policy formation processes, the reasons for these state advocacy efforts are not always clear, and the strategies employed by companies in lobbying states are not always clear either. This is a significant gap in research, as a possibility that such work does not seem to consider possible is that the practice of state lobbying may be much broader to include state lobbying with, for, or in cooperation with companies.

Next, there is research on the role of different domestic channels in corporate lobby practices. The informal relationship based on mutual interests between states and firms on a national level has been established to be significant in the Dutch case. In the Netherlands, journalistic efforts have played a major role in investigating and establishing this connection on a purely national level (van der Lugt, 2017; van Teeffelen, 2018; van Beek, Beunder & Mast, 2018; "Shell Papers", 2019; Witteman, 2019a). Similarly, a 2013 article in a major Dutch newspaper quoted the CEO of the largest Dutch employers’ association VNO-NCW saying, ‘specifically in the areas where business is going well, the government is shutting down sales organisations’ ("Werkgevers: sluiten ambassades 'fundamenteel fout'", 2013). With the term ‘sales organisations’, he referred to permanent representations and embassies, and this gives a clear indication of what the goal of embassies and PermReps is, according to organisations such as VNO-NCW. All this research establishes that Dutch businesses and employers’ associations are primarily concerned with using domestic channels to lobby for domestic regulation, or withdrawal thereof, and the only transnational aspect thus far is when Dutch business interests are at risk because of actions by the Dutch government. This lobby

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behaviour generally follows theoretical suggestions about lobbying efforts in terms of the lobby focusing on maintaining the status quo or moving away from it (Baumgartner, 2009). However, the studies on lobby efforts themselves remain limited (to the extent that information is accessible) to lobbying for national policy outcomes on a national level.

One clear example of lobbying at national institutions for policy outcomes on the national level is the case of Unilever. This case is particularly interesting as it establishes lobbying in The Netherlands is extensive and firms communicate with different domestic institutions. Following this example, we can reason that Dutch firms may lobby through the same institutions on EU policy. Over the course of 2017, 2018 and early 2019, the Dutch government unexpectedly opted to abolish a dividends tax, a controversial move had not been part of the public debate prior to that (de Witt Wijnen, 2019) and was largely deemed unnecessary. Further investigation by several newspapers concluded that Dutch firms such as Unilever had in fact been lobbying the Dutch government since at least 2005 in attempts to revert the dividends tax ("Lobby voor afschaffen dividendbelasting al sinds 2005 bezig", 2018; De Witt Wijnen, 2019; Documenten Rijksoverheid: 9). While this case of attempts at influencing tax law was ultimately not successful (partly due to public scrutiny), it certainly raises questions on how (and to what extent) Dutch firms attempt to influence Dutch politics on this and other themes, but also raises questions on their involvement in European politics and policy-making, and the role of national institutions in this process.

On a more academic level, the debate on the role of different domestic channels in corporate lobby practices is most prominently concerned with the choice of whom to lobby and the relative influence on policy outcomes a company may exert: ‘If a firm wishes to influence EU policy, they can choose to lobby their home government which has a vote on the EU Council and, depending on party structure and composition, may have influence on the home delegation to the European Parliament’ (Ehrlich & Jones, 2016: 467). If a company is a multinational, it may do so in different member states to increase influence over the policy outcomes. Indeed, the choice of lobbying venues is important in companies’ lobbying strategies, as ‘policy actors seek to push their issues to one or another institutional venue depending in their estimate of likely success’ (Baumgartner, 2010; 524). The choice of venues is hence well established in literature, and will be part of the theoretical framework, as it is indeed a choice that can explain the extent to which firms use the domestic channels available to them to lobby the EU. The relationship between states and European institutions (both the formal and informal relationship) has been studied on an academic level. Yet the

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relationship between firms and states, where states may act as a ‘messenger’ or a ‘middleman’, has – with a few exceptions – not been well-researched and established yet, and it could be a crucial factor in European policy formation. When business interests dictate state behaviour in the EU, this leads to the question of societal relevance whose interests the EU eventually protects. The choice in lobbying interaction modes is hence a new aspect of the literature that this paper seeks to describe, and theories on this will be discussed in the theoretical section.

The European lobbying strategies themselves are also studied comparatively. As such, their soft-spoken style compared to American lobbying strategies jumps out (Woll, 2012). Throughout this research project, it is therefore important to differentiate between European lobbying efforts and lobbying efforts in the US, as the difference between institutional context, strategies and the level of ‘normalization’ of lobbying efforts is still very much different in both continents (Woll, 2012). Whether less soft-spoken lobbying strategies – including for instance competitive lobbying strategies – will be more normalized in the EU policy-formation processes in the future is difficult to predict. However, as Lise Witteman suggested in a personal interview in Brussels, lobbying in the form of party donations may be at a turning point today, where it either becomes more normalized soon, or donors may take a step back in the face of public scrutiny. This implies that research on lobbying strategies in the EU is important because it can indicate, in terms of relative success, whether lobbying is indeed becoming more ‘normalized’.

Several studies highlight the recent institutional developments at the European level that have increased the power of institutions such as the EP. According to such studies, the increasing power of institutions such as the EP has subsequently redirected or diversified lobbying efforts to these institutions (Chapter 2.2 analyses this). Such studies also suggest a reaction by the EC and EP in attempts to regulate lobbying activities (Bunea, 2018). This implies that an increase in lobbying activities and venues leads to an increase in public scrutiny and subsequent efforts to increase institutional transparency. A remarkable feature in this dynamic is the role of civil society and civil advocacy groups that have not only gotten more power in EU policy-formation processes, but which have also increased their presence outside of the policy formation domain, such as in media outlets (Cann, 2016). Because transparency registers today do not cover lobbying efforts through media outlets (i.e. influencing public opinion), it is difficult to pinpoint whether and if so how companies use media outlets in their lobby efforts, but it seems that civil advocacy groups are increasingly

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vocal and use such communication tools to increase transparency at European institutions (Cann, 2016). Developments in regulation of lobbying activities include Mandatory Transparency Registers (also used in this study as primary sources) and they are part of the reason that lobbying strategies diverge their approach to institutions such as the European Parliament, as the checks and balances for lobby influencing are still less strict here, and so are the transparency guidelines (Witteman, 2019b; Wolfs, 2019). Following this logic, domestic channels may also be targeted for lobbying activities, as these differ in terms of transparency and regulation, dependent on the member state. As opposed to influence, which is difficult to measure, we may study access of business interests to the European Commission, the European Parliament, the Council of Ministers and national institutions, as well as the strategies companies use. Mere access indeed does not need to imply influence, but it certainly implies a level of credibility and importance that is given to business interests (Bouwen, 2004). One comparison that was made between the domestic and the EU lobbying context and perceived agenda-setting influence in the multi-level system of the European Union, suggests that ‘embeddedness into domestic decision-making is primarily an asset for securing perceived influence on the national rather than the EU agenda, whereas group resources matter more at the EU than the national level’ (Binderkrantz, 2015). These findings indicate that business interests may well secure influence in EU policy outcomes if they lobby for this nationally rather than at the EU level. Additionally, this implies that group resources (i.e. sectoral interest groups) are important to lobby the EU, and indeed to gain access to EU institutions. The European Commission has the right of initiative and is therefore a crucial factor in starting a new policy decision. While literature has to an extent focused on the two layers that can amend policy proposals (EP, Council), this paper highlights strategies firms may take in lobbying, and the importance of lobbying at national institutions, as the PermRep can act as a middleman in policy decisions.

2.2. Dutch Corporate Lobby Europeanisation

There have been several studies into the Europeanisation of national organisations’ lobby strategies. A surprising conclusion of such research is that Dutch organisations have different strategies to companies from other member states (Beyers & Kerremans, 2012: 263). The venues of lobby efforts are studied relatively well, as well as the relative importance companies attach to specific venues, yet there are less studies on the lobby interaction modes used. An interesting finding in such studies is that companies’ preferred venues differ per

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country (Beyers & Kerremans, 2012: 263). As such, it is ‘surprising (…) that French organizations develop extensive multi-level strategies while the strategies of Dutch organizations are rather weakly Europeanized’ (Beyers & Kerremans, 2012: 263). Such findings are from 2012, but they still suggest that national patterns are very different in terms of venues, targets and research. Additionally, Hafner-Fink, Novak & Fink-Hafner (2014) use a regression analysis to look at the factors of lobbying intensity at the various venues in the EU and conclude that there is a trend that suggests that organisations from The Netherlands primarily lobby the national executive, national parliament and the European Parliament. This is in contrast with organisations from e.g. the UK, which lobby the European Commission and the European Parliament significantly more (Hafner-Fink, Novak & Fink-Hafner, 2014). Beyers & Kerremans (2012: 275) ‘observe a distinction whereby venues located farther (such as Geneva, or other member states’ PermReps) away are less likely to be contacted when more proximate venues (such as national PermReps, national MEPs) have already been contacted’. In my results section, I argue that the proximity of venues is not a factor that has any significant influence on venue choice. Rather, the socialisation model I use can explain the venue choice of Dutch companies. Beyers & Kerremans also implicitly agree with Hafner-Fink et al. (2014) as their findings also suggest that the Dutch lobby is strongest with national MEPs, in the PermReps in Brussels and Geneva, and Commission DGs respectively. Additionally, there is evidence that Dutch companies have increased their lobby efforts in the national PermRep in Brussels since 2012 (Witteman, 2019a, 2019b). While the research by Beyers & Kerremans (2012) contradicts theories on multi-level lobbying which prescribe influencing all available channels, or at least the channels where success is most likely (Baumgartner, 2010; 524), socialisation theory may fill this gap. In short, these findings confirm that Dutch companies are relatively active in lobbying through the domestic channels (see Table 1). A relevant point is that the data in Table 1 was collected by survey, directly from companies, so data may be slightly skewed from reality. More recent research, however, such as that by Witteman (2019a), but also evidence from interviews conducted for this paper, confirms that multi-level lobbying practices are increasing at the Dutch national PermRep in Brussels. Therefore, it seems evident to take the Dutch PermRep, national MEPs, and Commission DGs are primary lobbying targets for Dutch companies, yet how they lobby these institutions (i.e. the strategies they use) remains vague.

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Table 1: Ranking of Venues Situated at Multiple Levels

(Guttman Scaling, Overall Ranking, and Loevinger’s H) with Dutch ranking according to Guttman Scaling above 0.50 highlighted.

Note. Adapted from Domestic Embeddedness and the Dynamics of Multilevel Venue Shopping in Four EU Member States (p. 275), by Beyers, J., & Kerremans, B. Retrieved from

2.3.Trends

To conclude the literature review, literature on corporate EU lobby has so far largely been explorative and descriptive. Studies on lobbying are extensive in the US, but theorisations have limited applicability to the EU framework, where the institutional context is significantly different. Studies on lobbying in the EU have progressively focused on other institutions than merely the EC, to include the EP and Council. There has been a remarkable lack of empirical studies that focus on theory-testing, in particular in relation to the domestic channels that are involved in EU policymaking processes.7 Limited empirical research has

7_{Some exceptions include: Beyers & Kerremans, 2012 & Hafner-Fink, Novak & Fink-Hafner, 2014. These do} not conduct meaningful theory-testing and are also largely explorative.

*NB: higher values mean higher lobby priority

All Data, N = 567 H = 0.45 Belgian, n = 157 H = 0.44 Dutch, n = 157 H = 0.44 German, n = 134, H = 0.36 French, n = 145 H = 0.53 PermRep in Brussels (other

member states) 0.46 0.39 0.76 0.25 0.67 Non-European PR Geneva 0.37 0.33 0.41 0.23 0.54

The Council Secretariat 0.44 0.42 0.39 0.31 0.52

Trade Committee in the EP 0.38 0.29 0.47 0.30 0.44

PermRep of the EU in

Geneva 0.49 0.46 0.44 0.27 0.59

Other Committees in the EP 0.42 0.37 0.35 0.32 0.50

The Council Committee 133 0.32 0.30 0.32 0.22 0.46

Secretariat of the WTO 0.43 0.28 0.39 0.40 0.55

MEPs (other member states) 0.43 0.47 0.37 0.43 0.42

The national PermRep in

Geneva 0.48 0.40 0.53 0.38 0.54

Commission Cabinets 0.47 0.51 0.37 0.38 0.54

The national PermRep in

Brussels 0.42 0.48 0.34 0.33 0.48

Commission DGs 0.57 0.67 0.57 0.50 0.50

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been conducted on national corporate lobbies, with a focus on surveying companies’ lobbying efforts. There has been no empirical research that studies the accumulation of lobbying efforts at institutions, nor has any of the recent literature conducted theory-testing on empirical research on lobbying at domestic channels.

3. Theoretical Framework

Business lobbying in national and European institutions is both diverse and complex, which makes reliable theoretical generalizations very difficult to make (Bouwen, 2004: 337). By extension, this makes theory-testing a difficult task as well. The theoretical framework of this thesis therefore proposes an approach that takes the domestic pathway in lobbying as the unit of analysis, and then uses the research results to both describe and explain the lobbying process using existing theory. This means that the illustrative case study on the PermRep, along with acquired policy documents, memos and interviews are considered as empirical results and these are used to test the theory below, perhaps warranting an expansion or re-conceptualisation of lobbying theories. The intention is to test whether theories on lobby strategies in the EU hold up at the domestic channel of the Dutch PermRep in Brussels and to reach a better understanding of how Dutch firms attempt to influence EU policy outcomes through the domestic channels. This gives the opportunity to investigate how the national aspect of EU lobbying – which has previously been understudied – is important to Dutch corporate EU lobby strategies, and to test whether the results confirm existing theory on lobbying. This also allows for a contribution to the gradual re-conceptualisation of corporate lobbying in the EU.

The theoretical framework proposes two logics that drive the development of a firm’s lobbying strategies. These logics are considered as mutually complementary analytical tools to understand Dutch corporate lobby in the EU as a multi-level, multi-channel and adaptive process. The theoretical framework uses the notion of lobbying strategies as an umbrella term for these two logics. The theory of multi-level lobbying strategy serves as a descriptive theory that is used to test empirical results. In other words: do our observations confirm multi-level lobbying theory or do they raise certain questions? The second theory, on socialisation theory, is not frequently used in lobbying literature, yet it serves as a possible explanatory theory for our empirical results. As socialisation theory is not a theory that is often used in the context of lobbying practices, it serves to explain a dynamic that we observe

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in Dutch corporate lobby venues, as an explanatory factor for Dutch companies not conducting lobbying practices as multi-level lobbying theory prescribes.

3.1. Multi-Level Lobbying Theory

Within the study on lobbying in the EU, there is a real need for ‘a shift from exploratory or descriptive interest studies to more confirmatory theory testing’ (Coen, 2007: 333). A theory that is most frequently used in the context of lobbying is that of multi-level lobbying, which stems from multi-level governance and rational choice theory and is associated with game theory (Scharpf, 1997). Multi-level lobbying theory is in many respects prescriptive; like game theory, it is designed to prescribe strategies for the maximisation of profit, or in our case the maximisation of influence on policy outcomes. To analyse strategic action by political actors – including lobbyists which are by definition political actors – we need to avoid falling in the trap of overly reductionist rational choice assumptions (Woll & Jacquot, 2010: 110). It is however possible to create a comprehensive analytical framework using multi-level lobbying theory without falling over the stumbling block of a superficial theoretical analysis, and without writing an entirely new paper on the application of game theory in the context of lobbying.

Several authors have analysed the EU as a multi-level governance structure in the context of lobbying (Beyers & Kerremans, 2012; Hafner-Fink et al., 2014; Binderkrantz, & Rasmussen, 2015; Marshall & Bernhagen, 2017). Multi-level lobbying theory is derived from the framework of multi-level governance, where actors are assumed to act rationally and out of self-interest, as they do in rational choice theory (Kohler-Koch, 1998). Additionally, a crucial link to game theory is the profit maximisation logic (Lowery, 2007). Businesses’ lobbyists themselves are political actors within the EU policymaking process and as such, they are assumed to be ‘tied up in a stable negotiating system’ (Kohler-Koch, 1998). Within this negotiating system, parties do have common as well as opposing interests and accordingly act within or independently of interest groups (Scharpf, 1991: 63). If lobbying is part of policymaking processes within a system of multi-level governance, we can expect lobbyists to act rationally and out of the interest of the group they represent, and we can also expect them to try to maximise chances of successfully influencing policy outcomes, possibly by using multiple lobbying channels such as the EC, the EP as well as national institutions. This dynamic is called multi-level lobbying, and the theoretical debate is a rather functional

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one, on the mechanism of influence maximisation and venues that are best suited for this (Scharpf, 1997). Multi-level lobbying theory has so far not been concerned with normative arguments on transparency, or equality of access to decision-making processes. According to Kohler-Koch (1998: 3), the debate on level governance – and by implication multi-level lobbying – turns normative ‘when research touches upon the question of whose interests prevail in European politics and whether the system has a structural bias to privilege some group of actors over others’. This normative discussion is shortly touched upon in the concluding remarks of the thesis, but our interest here is to establish a set of analytical guidelines by which we can test multi-level lobbying theory on the empirical case study of the Dutch PermRep in Brussels.

One aspect that comes forward prominently in theorisations on lobbying in the EU is the choice in venues and strategies, which are connected to literature on profit maximisation. According to Lowery (2007: 33), much of the empirical research (..) has been founded to a greater or lesser extent on the transactions perspective of lobbying’, which is also labelled the “profit maximizing model”. This profit maximizing model suggests that businesses will target those venues where their chance at success is highest, as well as a multitude of venues if need be. Theory on profit maximisation in lobbying is essentially synonymous to maximizing policy influence. While Lowery (2007: 30) suggests that collective action is essential in maximizing influence – or so-called “profit” – more recent research suggests that organisations can also lobby effectively independently from interest groups (Marshall & Bernhagen, 2017: 981; Eising et al., 2017). A universal difficulty in the theory of maximizing influence on policy output through corporate political participation is evidently that it is difficult to qualify – let alone quantify – successful policy influence (Bouwen, 2004). Essentially, ‘scholars have not been very successful in linking the political participation of business to policy benefits’ (Hansen, Mitchell & Drope, 2005: 150). Yet for this study, it is not necessary to link political participation directly to policy benefits. Our interest lies in the functional concept of venue choice, as multi-level lobbying theory suggests a lobby through multiple institutions. Following this rationale of multi-level lobbying and profit maximisation, we would expect companies to lobby institutions 1) that are involved in the making process in the first place, 2) that have an important role in the decision-making process and 3) where chances of convincing the institution of certain lobbying points are highest. As such the mere number of contact moments with lobbyists at various institutions may be indicative of what venues are used to maximise policy influence, as well

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as insights from policy documents and interviews. In answering how Dutch businesses use the domestic channels available to them to lobby the EU, we can therefore use multi-level lobbying theory in combination with primary data to assess whether domestic channels are considered of importance to lobbyists in the first place, and what the role of domestic channels may be in the broader picture of lobbying efforts. In a nutshell, multi-level lobbying theory – or the profit maximising model – is prescriptive in terms of approaching venues where chances of success are highest and where lobbyists have the biggest impact on policy outcomes.

The unique aspect of the theoretical approach to multi-level lobby is also that it not only suggests companies engage in lobby activities on multiple levels of governance (multi-level) and at multiple institutions (multi-channel), but also that it implies that other organisations, including states, are not simply passive actors (Panke, 2012; Witteman, 2019a; Corporate Europe Observatory, 2019). This suggests that recipients of lobby activities actively engage with lobbyists to form policy, but also reach out to industry representatives and in a way exchange access to the policy formation process for ‘goods’ such as expert knowledge for this access to the policy-making process (Bouwen, 2004). This makes multi-level lobby a dynamic process, with a multi-level of interaction between the target and the company, and this suggests that lobbying is not simply a “sending” process. Similarly, this dynamic logically allows lobbyists to ‘focus their advocacy effort on institutional venues that they perceive as biased in their favour while avoiding those in which their political standing is poor’ (Marshall & Bernhagen, 2017: 981; Eising et al., 2017). Pieter Bouwen (2004) indeed suggests that ‘it has become accepted practice by European affairs directors that [both] collective and direct strategies, [but also] national and European mobilization are all simultaneously required, if influence is to be maximized in the Brussels arena’. This gives a concise overview of multi-level lobbying theory; however, this does not explain empirical findings in this research project or why ‘in many cases even the wealthiest firms with the greatest lobbying firepower lose lobbying battles and operate under regulatory rules that do not necessarily reflect their ideal preferences’ (Chalmers, 2018: 275).

3.2. An Alternative: Socialisation Theory

In a 2010 article, Woll and Jacquot argue for a more systematically sociological consideration of strategic action in the study of European transformation, introducing the notion of ‘usage’

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of the EU. Such a sociological consideration of strategic action is not limited to policymakers but extends to business action in the context of lobbying and consultation processes, as businesses are essentially also political actors in EU policy formation processes. Such a consideration includes strong arguments for the rationality of political actors but seeks to highlight more social constructivist IR theorisations as being explanatory factors in EU transformation and policy formation processes (Pouliot, 2004: 320). Like multi-level lobbying, socialisation theory has its’ roots in rational choice but can serve to ‘study the social construction of rational or strategic behaviour’ (Woll & Jacquot, 2010: 111). It hence provides an explanatory theory for observations that cannot be explained by multi-level lobbying theory alone. Socialisation theory is therefore an explanatory theory that has a focus on social facts. While it is true that there are significant differences among IR scholars on constructivism, a common question that is asked is how social facts are socially constructed, and how they affect global politics (Pouliot, 2004: 320). The new aspect of constructivist theory – and by implication socialisation theory – is that it considers businesses as groups of actors that are socialised within a domestic context. As such, actors that seek to influence policy are socialised within a certain national system and know venues and lobbying strategies where policy influence can be maximised (Wolfs, 2019). This conforms to multi-level lobbying theory, but socialisation theory considers the transnational dynamics, arguing that actors remain socialised within their national lobby “systems”, and mirror tactics and venue choice in their EU lobbies (Idem.). As such, national institutions may also frequently be targeted in EU lobbies, even if they may not necessarily be very effective policy actors or “middlemen”. Other EU institutions where the so-called “profit” – or policy influence – would be higher can hence be overlooked (Idem.). The socialization approach sheds light on the complex relationship between EU28 member states, institutions, and businesses. In our case, socialization theory is a social theory that uses both rational choice and social constructivism. Although it is not often referred to in theorisations on lobbying, socialization theory can explain why actors (including businesses) mirror experiences from lobbying nationally to an EU level.

Socialisation does not only apply to venue choice alone, but also to lobbying strategies. Lobbying strategies are most often formed within a national context, and it is thus not surprising that comparative literature notices a ‘frequently aggressive advocacy approach in the US and a more consensus-oriented informational lobbying in the EU’ (Woll, 2012: 193). Approaches differ per national context simply because some approaches work better in some

The lobbying Dutchman : how do Dutch businesses use the domestic channels available to them to lobby the EU?