...both rational and institutional explanations of organizational structure and management practices predict similarity among firms that operate in the same industry within the context of a single country...

From a rational perspective, firms pursue economic advantage through decision making and actions guided by...  bounded rationality.

Through various mechanisms of coercion, normative regulations, and imitation, organizations sharing the same environment are believed to become structurally similar as they respond to like pressure; that is, they will demonstrate isomorphism...

...the institutional model assumes dissimilarities not only in relation to industry differences but also dissimilarities rooted in the idiosyncratic national institutional regimes surrounding firms...

...the inertia of institutional structures is likely to inhibit the application of new management prescriptions whenever these are seriously at odds with existing legal rules and political conditions...

...human resource management practices are subject to idiosyncratic sets of national regulations as well as sensitive to the scrutiny of labor unions whose strength and attitudes toward management vary...

Despite their very different assumptions, both rational and institutional explanations of organizational structure and management practices predict similarity among firms that operate in the same industry within the context of a single country. From a rational perspective, firms pursue economic advantage through decision making and actions guided by unambiguous preferences and bounded rationality. Although one may expect differences between industries, within industries, firms will implement organizational practices that promote the maximization of economic goals. Thus, discounting sluggishness in the diffusion of best practices, it would be reasonable to expect that intraindustry management systems are to a large degree uniform.

...Through various mechanisms of coercion, normative regulations, and imitation, organizations sharing the same environment are believed to become structurally similar as they respond to like pressure; that is, they will demonstrate isomorphism...

While the rational model assumes that organizational practices are universal across national borders, institutionalism is sensitive to the possibility of cross-national institutional differences, which in turn generate significant crossnational differences in managerial systems... Rather than assuming that all organizations are alike, or when differences are found between organizations situated in varying social and cultural contexts, attempting to understate them or explain them away, current work is more likely to celebrate diversity and seek to account for the reasons why different forms arise...

The purpose of this paper is to study the impact of institutional determinants on firms' use of human resource management practices, using cross-national analysis. Whereas the broad rational model implies that there will be no crossnational differences beyond those that are ascribable to factors such as varying firm size and differing industries, the institutional model assumes dissimilarities not only in relation to industry differences but also dissimilarities rooted in the idiosyncratic national institutional regimes surrounding firms.

Cross-national dissimilarities in institutional structures are likely to create management practices that vary from country to country, regardless of the fact that management theories are often rapidly disseminated across national borders. Particularly in the human resource management field, the inertia of institutional structures is likely to inhibit the application of new management prescriptions whenever these are seriously at odds with existing legal rules and political conditions. This is due to the fact that human resource management practices are subject to idiosyncratic sets of national regulations as well as sensitive to the scrutiny of labor unions whose strength and attitudes toward management vary...

[I]n different countries, dissimilar organizational forms and practices may prove equally efficient, due to varying cognitive rationality criteria, legislation, and normative structures.

...human resources are "to be obtained cheaply, used sparingly, and developed and exploited as fully as possible in accordance with the demands determined by the overall business strategy...

...systematic use of individual performance appraisal, individual performance-related rewards, and outcomes-monitored training and development...

The hard model is... calculative approach... ensuring that production activities are at all times efficiently supplied with... human resources... such resources are essentially no different from any other variable economic factor...

...dependent on... treating each employee as an individual rather than as a member of a... union(s)... requires that management possess substantial autonomy within the firm... (and) that its power not be curtailed by strong regulative pressure...

The "soft" model... collaborative approach to human resource management... developmental or humanistic focus... explicit statements about the value of the employees to the firm and ethical matters related to the employment relation...

Rather than being passive inputs, employees are viewed as active partners and core assets...

...create and communicate a culture of partnership between employer and employee...

One major source of cross- national variation in collaborative practices is the volume and detail of specific legislative regulations of firms' employment practices...

An additional basic imperative of the strategic HRM model is to simultaneously fulfill the needs and goals of the firm and its employees harmoniously, with "an optimal degree of fit among these four components--the environment, organization, job, and individual" (Hall and Goodale, 1986: 4)...

As the above discussion suggests, the strategic HRM model contains within it an inherent duality between, on the one hand, strong economic, calculative considerations and, on the other, a more humanistic orientation (Sisson, 1994). In a recent review, Legge (1995) distinguished between HRM practices belonging to what she referred to as a "hard" model and practices that constitute a "soft" model (cf. also Storey, 1989)...

Calculative HRM. The hard model is rooted in a calculative approach aimed at ensuring that production activities are at all times efficiently supplied with the necessary input of human resources. In these terms, such resources are essentially no different from any other variable economic factor. Associated with this model are a range of efficiency-seeking devices aimed at ensuring that each employee's contribution to the firm is assessed and thereafter rewarded accordingly through individual performance appraisals and individually oriented reward systems. Investment in employee development will also be carefully monitored to evaluate its benefits for the business strategy. Thus, for example, the effectiveness of training is likely to be assessed. Any such calculative approach is dependent on the feasibility of treating each employee as an individual rather than as a member of a collective entity protected by collective bargaining contracts and strong unions. It is reasonable to expect that the adoption of calculative practices requires that management possess substantial autonomy within the firm. In turn, such autonomy requires that its power not be curtailed by strong regulative pressure at the firm level in the form of laws and agreements or by influential labor unions or similar employee bodies (Hakim, 1990; Legge, 1995)...

Collaborative HRM. The "soft" model represents a collaborative approach to human resource management in that it has a distinctly more developmental or humanistic focus, often based on explicit statements about the value of the employees to the firm and ethical matters related to the employment relation. Rather than being passive inputs, employees are viewed as active partners and core assets, not least in terms of creativity and innovation. Ideally, they are viewed as participants in a project premised on commitment, communication, and collaboration. The collaborative emphasis is hence characterized by efforts to create and communicate a culture of partnership between employer and employee as well as among employees. One important device for achieving such integration is represented by management's attempts to formulate an overarching direction, including a corporate vision, which is communicated to the firm's employees in the form of a mission, goal, or strategy statement. In addition, management will regularly seek to communicate the strategy of the firm via briefings of employees at various positional levels. Underpinning such efforts will be an explicit employee communication policy...

One major source of cross-national variation in collaborative practices is the volume and detail of specific legislative regulations of firms' employment practices...

In Germany, wages and working hours are the exclusive territory of the labor unions in a system of regional, industry-wide bargaining...

...over 90 percent of the workforce is covered by collective bargaining agreements...

...attention should be drawn to the elaborate German system of co-determination, which is regulated at the plant level by the Works Constitution Act of 1972 and at the enterprise level by the Works Constitution Act of 1952...

...works councils.. are powerful, employee-elected bodies that are legally entitled to co-determination, consultation, and access to important information, and hence restrict the degree of managerial autonomy...

...substantial size of German personnel departments is... a response to... rights enjoyed by the works councils... can demand written information on any aspect of personnel policy...  veto changes in working hours, training agreements, recruitment of personnel, and disciplinary procedures...

...highly formalized and standardized procedures...

...numerical flexibility is largely alien to the German context. Firms seeking such flexibility have tended to shift labor-intensive operations to foreign locations...

FRANCE

... French firms [are] hierarchical and Tayloristic with elitist "grandes ecoles" educated managements...

...based on the principle of control with power concentrated at the top...

...a general lack of trust between employer and employees...

...French unions have little influence over corporate management...

...they do have a substantial impact on the work of the personnel function....

...collective bargaining agreements are extended by law to nonunionized workers...

...a complex and detailed system of wage bargaining that is carefully scrutinized by antagonistic unions...

...the Inspection du Travail, a public body that rigorously checks that companies are not contravening employment legislation, particularly with regard to the use of temporary labor...

...legal arrangements... oblige firms to annually invest [in training] a sum equivalent to at least 1.2 percent of their wage bill so as not to be punished financially through the tax legislation...

Denmark and Norway

Strong managerial autonomy has never been a feature of Danish employment...

...the labor union movement... even in relatively small enterprises has been too powerful to permit this...

...Denmark is distinguished by... cooperation and negotiation...

Changes in employment practices are subject to bipartite agreements, with the state functioning... as a mediator and a guarantor...

...institutionalized local pattern of cooperation has resulted in relatively informal employer-employee relations at the firm level...

...there is still considerable identification with the worker collective...

...an assumption of divergent and conflicting interests between employer and employees at the firm-level... an ongoing resistance to calculative practices...

...a strong and pronounced framework intended to ensure that conflicts are resolved at the firm level...

Labor unions are legally entitled to be consulted on issues relating to major structural changes...

...in Denmark and Norway, labor unions generally both possess and exert considerable influence on the management of firms...

...the general autonomy of management is significantly restricted...

SPAIN

...the authoritarian legacy of the Franco regime (1939-1975), during which there was an absence of free labor unions...

With Spain's change to democratic government... institutional structures still remain weak, thereby granting management great autonomy...

...the bargaining effectiveness of unions varies widely between provinces and regions...

The main focus of the two big labor federations... has been on limiting changes to the rules governing employers' liability to redundancy costs...

Spanish employers, essentially conservative and paternalistic and uninhibited by union influence...

...wide range of contractual arrangements generated a complex system, in which clear, common rules did not exist...

UNITED KINGDOM

The United Kingdom is unique in the European context in that during the 1980s its employment legislation was subject to radical changes...

...curbed the unions' right to recognition, outlawed the closed shop and secondary picketing, and narrowed the freedom of unions to call strikes...

...result was a considerable increase in general managerial autonomy...

...proportion of workers covered by collective bargaining declined from 75 percent in 1980 to 45 percent in 1994...

...British firms generally are confronted with neither detailed regulative pressures nor labor unions with any significant influence on management...

Germany. In Germany, wages and working hours are the exclusive territory of the labor unions in a system of regional, industry-wide bargaining. Although unionization in German worklife has dropped considerably since the 1970s, and in 1994 was down to 30 percent, over 90 percent of the workforce is covered by collective bargaining agreements (Economist, 1997; see also Scholz, 1996). In addition, attention should be drawn to the elaborate German system of co-determination, which is regulated at the plant level by the Works Constitution Act of 1972 and at the enterprise level by the Works Constitution Act of 1952, which was extended in 1976 (cf. Hollingsworth, 1997). As a consequence of this legislation, employers need to maintain positive relations with the works councils. These are powerful, employee-elected bodies that are legally entitled to co-determination, consultation, and access to important information, and hence restrict the degree of managerial autonomy (Wachter and Stengelhofen, 1995; Scholz, 1996).

The generally substantial size of German personnel departments is primarily a response to the detailed legal rights enjoyed by the works councils, which at any time can demand written information on any aspect of personnel policy and veto changes in working hours, training agreements, recruitment of personnel, and disciplinary procedures (Bennett, 1997). The role of the personnel department is in general largely restricted to providing such information and to ensuring that the firm is not in breach of any of the numerous regulations that constitute national employment law and agreements. Hence, the primary task of the personnel department is to engineer highly formalized and standardized procedures as well as to supervise and implement the comprehensive collective bargaining agreements with the unions. Thus, in the case of Germany, personnel managers and departments have to cope with the burden of a comprehensive and detailed legislative regime, which in turn leads to a highly operative focus that is expected to inhibit the use of collaborative practices.

It is this narrow, operative focus, Wachter and Stengelhofen (1995) argued, that largely prevents any large-scale adoption of more recent international human resource management practices in Germany. As they pointed out, a German parallel to or a direct translation of the term human resource management does not even exist. This is not to say that various calculative techniques associated with the rational HRM model are completely absent, but their potential use has invariably been subject to the critical eye of the works councils (Lane, 1994; Marginson and Sisson, 1994). In large measure, these councils have also sought to preserve the strong traditions of social welfare that have characterized employers' treatment of their human resources. Thus, for example, numerical flexibility is largely alien to the German context. Firms seeking such flexibility have tended to shift labor- intensive operations to foreign locations, with 25 percent of manufacturing companies having relocated production abroad in the period between 1993 and 1996 (Financial Times, 1996b).

France. Brunstein (1995) characterized French firms as hierarchical and Tayloristic with elitist "grandes ecoles" educated managements. Similarly, van der Klink and Mulder (1995) and Lane (1994) described French companies as being based on the principle of control with power concentrated at the top. According to these writers, a consequence of the strong managerial autonomy is a general lack of trust between employer and employees. Managers seem to be reluctant to grant employees access to information about the production process and managerial matters, since asymmetric information is a precondition for maintaining power. This lack of trust and mutuality is exacerbated by the role of the labor union movement, not least the communist-oriented CGT, which has traditionally been in strong opposition to corporate management (Slomp, 1995).

Although French unions have little influence over corporate management, they do have a substantial impact on the work of the personnel function. Despite the fact that unionization is currently only slightly higher than 10 percent in France, collective bargaining agreements are extended by law to nonunionized workers. This has meant that resources that might have been used by personnel departments to develop collaborative practices are concentrated on overseeing a complex and detailed system of wage bargaining that is carefully scrutinized by antagonistic unions (Brunstein, 1995). Hence, the personnel department has been obliged to have a high level of legal expertise.

An additional factor that constrains French personnel departments in developing collaborative practices is that they are also charged with the important task of maintaining good relations with the Inspection du Travail, a public body that rigorously checks that companies are not contravening employment legislation, particularly with regard to the use of temporary labor (Financial Times, 1996a).

Finally, the function of the personnel department as a means of coping with the legislative context peculiar to France is particularly pronounced in the area of training. Whereas the rational HRM model assumes that training is driven by the firm's inherent needs for increased competence and flexibility through employee development, in the case of France it is difficult to overlook the impact of the legal arrangements that oblige firms to annually invest a sum equivalent to at least 1.2 percent of their wage bill so as not to be punished financially through the tax legislation. As Brunstein (1995) pointed out, in practice this has often resulted in firms preferring to hand over the economic monitoring of their training obligation to the Fonds d'Assurance to ensure that they remain within the boundaries of the law (see also Jenkins and van der Wijk, 1996).

...[B]ecause union power is limited to collective bargaining, management in French firms is able to pursue a tradition of autonomous, non-consultative decision making. Because personnel departments are exposed to comprehensive and detailed legal regulations combined with a distrustful union movement, however, their scope for human resource management innovations has been limited. This leads to the following hypotheses:

Denmark and Norway. Strong managerial autonomy has never been a feature of Danish employment (Kristensen, 1992; Bevort, Pedersen, and Sundbo, 1995), in large part because the labor union movement, with delegates firmly entrenched even in relatively small enterprises (Slomp, 1995), has been too powerful to permit this. Instead, Denmark is distinguished by a closely linked institutional system of cooperation and negotiation (Bevort, Pedersen, and Sundbo, 1995). Changes in employment practices are subject to bipartite agreements, with the state functioning both as a mediator and a guarantor.

A recent survey conducted among European companies through the Euronet-Cranfield research program and covering the period 1991-1995, indicates no significant changes in the balance of power between unions and management in Danish firms. The 23 percent of firms reporting a decrease in local union influence are outweighed by the 77 percent either reporting an increase or no change (Nordhaug, 1997). The stability of the labor union influence in the Norwegian system appears to be even more entrenched than that of the Danish, with only 8 percent of the Norwegian firms reporting any decrease in local union influence in the period 1991-1995 (Nordhaug, 1997).

The institutionalized local pattern of cooperation has resulted in relatively informal employer-employee relations at the firm level, but this collaborative approach must not be confused with commitment, in the sense that individual employees uncritically identify with the aims of the firm and view their personal and professional competence development as being at one with these aims. On the contrary, there is still considerable identification with the worker collective, particularly among low-level male employees. In other words, there remains engrained in Danish as well as Norwegian worklife an assumption of divergent and conflicting interests between employer and employees at the firm-level and, therefore, an ongoing resistance to calculative practices.

In a comparison of the legislative environment for worklife in Denmark and Norway, Graver (1995) observed that in both countries there is a strong and pronounced framework intended to ensure that conflicts are resolved at the firm level. Labor unions are legally entitled to be consulted on issues relating to major structural changes, such as downsizing, outsourcing, and potential mergers. Graver (1995) concluded that there is a distinct Scandinavian model of employment law that is sufficiently general to permit personnel departments to experiment with and implement human resource management practices of the collaborative type. Concomitantly, the law preserves the rights of labor unions to withdraw their cooperation in the case of disagreement with the management. As Borgen (1995) indicated, the sense of security granted by the national framework of government- guaranteed agreements makes it possible for labor unions to involve themselves in the development of collaborative, firmlevel solutions designed to contribute to enhanced functional flexibility (Simensen and Isaksen, 1995; Gooderham and Nordhaug, 1997).

In summary, in Denmark and Norway, labor unions generally both possess and exert considerable influence on the management of firms. Together with the fact that individual rights of employees are strongly protected by laws and agreements, this means that the general autonomy of management is significantly restricted. At the same time, the legislative framework is so general that personnel departments are not burdened with having to oversee the mass of detail that their German and French counterparts have to deal with. Consequently, the personnel function has the opportunity to innovate in terms of collaborative practices...

Spain. In their account of the human resource management field in Spain, Florez- Saborido, Gonzales-Rendon, and Alcaide-Castro (1995) pointed to the authoritarian legacy of the Franco regime (1939-1975), during which there was an absence of free labor unions and a wide scope for lawful dismissal. With Spain's change to democratic government, the major focus of personnel management was on the reduction of labor conflict, which resulted in a series of agreements on procedural rules governing the contents of collective bargaining in the first half of the 1980s. Nevertheless, institutional structures still remain weak, thereby granting management great autonomy (Lucio, 1992).

Although the unions in Spain have increased their influence since 1975, the degree of influence over managerial decisions enjoyed by Scandinavian unions or German unions and works councils remains much greater. Moreover, the bargaining effectiveness of unions varies widely between provinces and regions, in large part because of their relatively poor financial and organizational resources (Lucio, 1992). The main focus of the two big labor federations, the UGT and the Workers' Commissions, has been on limiting changes to the rules governing employers' liability to redundancy costs. But their general weakness has simply resulted in employers side-stepping the legislation to achieve numerical flexibility by negotiating individual employment contracts. Hence, in 1996 only 4.1 percent of all new employment contracts were for full-time permanent jobs, bringing the total of all wage earners in temporary employment to more than onethird (Financial Times, 1997). Furthermore, it must be expected that Spanish employers, essentially conservative and paternalistic and uninhibited by union influence, will have a particular propensity for adopting calculative human resource management practices.

With regard to collaborative practices, a comprehensive and detailed regulative pressure on Spanish firms in the field of human resource management has evolved during the 1980s and 1990s as a response to the many variations of employment contracts. As noted by Florez-Saborido, GonzalesRendon, and Alcaide-Castro (1995: 240), "this wide range of contractual arrangements generated a complex system, in which clear, common rules did not exist .... The government followed a gradualist type strategy in introducing greater contractual freedom, but the process also produced unnecessary administrative complexity and legal insecurity for the employer." In addition to this operational constraint, the personnel function in Spanish firms has also historically been underdeveloped and generally has had no other function than to serve relatively autocratic managements. Hence, personnel practices in Spain have exhibited a reactive and highly operatively oriented character, with specialist personnel departments in possession of scarce resources and limited status. As Baruel (1996) noted, Spanish firms have substantially disregarded novel developments within the human resource management field, meaning that collaborative practices can be expected to be rare.

As indicated, Spain is characterized by weak labor unions without any significant influence on worklife and by a substantial managerial autonomy. At the same time, the personnel function has traditionally been highly operatively oriented, lacking the opportunity to introduce collaborative human resource management practices.

The United Kingdom. The United Kingdom is unique in the European context in that during the 1980s its employment legislation was subject to radical changes. Most notably, this legislation includes the Employment Acts of 1980, 1982, 1988, and 1990 and the Trade Union Act of 1984, which impose severe civil penalties. Together, these acts curbed the unions' right to recognition, outlawed the closed shop and secondary picketing, and narrowed the freedom of unions to call strikes, for instance, by requiring that a secret ballot of the members be called first. The result was a considerable increase in general managerial autonomy (Edwards et al., 1992).

At the same time, union membership dropped from more than half of the workforce in 1979 to less than a third in 1995 (Economist, 1996), and, more significantly, the proportion of workers covered by collective bargaining declined from 75 percent in 1980 to 45 percent in 1994 (Economist, 1997). The continuing ebb in the power of unions is clearly indicated by the finding that 38 percent of British firms in 1994 reported a decrease in local union influence (Nordhaug, 1997). These changes in union power have provided "wide scope for managerial innovation in employment and labour strategies" (Rubery and Wilkinson, 1994: 11), thereby paving the way for the introduction of calculative practices (Hendry and Pettigrew, 1990).

Not only did the changes in the United Kingdom effect an erosion of the bargaining power of labor unions and a concomitant increase in managerial autonomy (Edwards et al., 1992), they also provided the impetus for a shift in the role of personnel departments in British firms. Throughout the postwar period, but particularly in the 1970s and early 1980s, personnel specialists had, with some success, emphasized their role as industrial relations experts (Legge, 1995). With the demise of this role, personnel departments have been under pressure to develop a broader range of professional services, which in large part has included the various techniques associated with the collaborative approach. To a large extent, they have reacted by seeking to preserve their credibility by attempting to become facilitators preoccupied with issues related to training and development, internal communication, and integration of business strategy and human resource management (Marchington et al., 1994)...

In summary, British firms generally are confronted with neither detailed regulative pressures nor labor unions with any significant influence on management...

...societies' modes of economic governance and management practices are highly path dependent and system specific...

...there are serious limitations in the extent to which a society may mimic the forms of economic governance and performance of other societies...

...both regulative and power- related structures seem to be paramount in explaining the complexity and multitude of international variations in organizational forms and practices...

On the basis of our findings, the major thrust of an institutional critique of the rationally grounded strategic HRM model is twofold. First, this model assumes a much greater degree of organizational and managerial autonomy than is the case for most firms, regardless of national setting. In other words, the critique questions the implicit assumption that management actually possesses sufficient freedom to develop human resource management practices according to the specific economic or strategic interests of the firm. Second, it questions the assumption of employer-employee unanimity. This may vary across different institutional settings, in large part according to the strength and behavior of labor unions. Instead of regarding firms' choice of personnel practices as primarily reflecting rational choices, proponents of the institutional perspective view them as stemming from firms' attempts to acquire legitimacy in relation to the government and other public bodies, the law, industry associations, labor unions, other firms, or the broader political culture (Edelman, 1990; Powell and DiMaggio, 1991)...

Indeed, the fundamental point made in this paper is that under varying regulative and political conditions, firms are likely to implement divergent organizational practices and forms... societies' modes of economic governance and management practices are highly path dependent and system specific and that "there are serious limitations in the extent to which a society may mimic the forms of economic governance and performance of other societies." ...

...both regulative and power-related structures seem to be paramount in explaining the complexity and multitude of international variations in organizational forms and practices... with respect to human resource management, there are powerful institutional barriers that hamper the large-scale international diffusion of particular practices...

REFERENCES

Baruel, Joseph 1996 "Spain in the context of human resource management." In Timothy Clark (ed.), European Human Resource Management: 93- 117. Oxford: Blackwell.

Bennett, Roger 1997 European Business. London: Pitman.

Bevort, Frans, John S. Pedersen, and Jon Sundbo 1995 "Denmark." In Ingrid Brunstein (ed.), Human Resource Management in Western Europe: 31-58. Berlin: de Gruyter.

Borgen, Svein O. 1995 "Samarbeid om bedriftsutvikling: hvilke krav stilles til Iokale fagforeninger? (Cooperation on firm development: Demands to local unions.)" In Dag Olberg (ed.), Endringer i arbeidslivets organisering (Changes in the Organization of Work Life): 211-231. Oslo: Fafo.

Brewster, Chris 1994 "The integration of HRM and corporate strategy." In Chris Brewster and Ariane Hegewisch (eds.), Policy and Practice in European Human Resource Management: 2235. London: Routledge.

Brewster, Chris, Ariane Hegewisch, Lesley Mayne, and Olga Tregaskis 1994 "Methodology of the Price Waterhouse Cranfield Project." In Chris Brewster and Ariane Hegewisch (eds.), Policy and Practice in European Human Resource Management: 230- 245. London: Routledge.

Brewster, Chris, OIga Tregaskis, Ariane Hegewisch, and Lesley Mayne 1996 "Comparative research in human resource management: A review and an example." International Journal of Human Resource Management, 7: 585-604.

Brunstein, Ingrid 1995 "France." In Ingrid Brunstein (ed.), Human Resource Management in Western Europe: 59-88. Berlin: de Gruyter.

Cole, Robert E. 1989 Strategies for Learning: SmallGroup Activities in American, Japanese, and Swedish Industry. Berkeley, CA: University of California Press.

Dessler, Gary 1997 Human Resource Management, 7th ed. Upper Saddle River, N J: Prentice-Hall.

DiMaggio, Paul J. 1983 "State expansion and organization fields." In R. H. Hall and R. E. Quinn (eds.), Organization Theory and Public Policy: 147-161. Beverly Hills, CA: Sage.

DiMaggio, Paul J., and Walter W. Powell 1983 "The iron cage revisited: Institutional isomorphism and collective rationality in organizational fields." American Sociological Review, 48: 147160.

Dobbin, Frank, John R. Sutton, John W. Meyer, and W. Richard Scott 1993 "Equal opportunity law and the construction of internal labor markets." American Journal of Sociology, 99: 396427.

Economist 1996 "A survey of Britain's new politics: The Thatcher revolution." September 21: 8-11. 1997 "Beer, sandwiches and statistics." July 12: 78. Edelman, Lauren 1990 "Legal environments and organizational governance: The expansion of due process in the American workplace." American Journal of Sociology, 95: 1401-1440.

Edwards, Paul, Mark Hall, Richard Hyman, Paul Marginson, Keith Sisson, Jeremy Waddington, and David Winchester 1992 "Great Britain: Still muddling through." In Anthony Ferner and Richard Hyman (eds.), Industrial Relations in the New Europe: 1-68. Oxford: Blackwell.

Financial Times 1996a "Pushing the point with research." February 6: 7. 1996b "Germans flee high labour costs." December 11: 9. 1997 "Spanish labour deal irks employers." April 7: 6. Fisher, Cynthia, Lyle E. Schoenfeldt, and James B. Shaw 1993 Human Resource Management. Boston: Houghton Mifflin.

Florez-Saborido, Ignacio, Manuel Gonzalez-Rendon, and Manuel Alcaide- Castro 1995 "Spain." In Ingrid Brunstein (ed.), Human Resource Management in Western Europe: 231-258. Berlin: de Gruyter.

Gooderham, Paul N., Olay A. Kvitastein, and Odd Nordhaug 1996 Strategier for menneskelige ressurser--oorske bedrifter i europeisk perspektiv (Strategies for human resources: Norwegian companies in a European perspective). Bergen: Foundation for Research in Economics and Business Administration (SNF).

Gooderham, Paul N., and Odd Nordhaug 1997 "Flexibility in British and Norwegian firms: A comparative institutional study." Employee Relations, 19: 568- 580.

Gooderham, Paul N., Odd Nordhaug, and Kristen Ringdal 1998 "When in Rome, do they do as the Romans? HRM practices of US subsidiaries in Europe." Management International Review, 38: 47-64.

Graver, Hans P. 1995 "Reguleringsmodeller i arbeidsretten (Regulatory models in labor law)." In Dag OIberg (ed.), Endringer i arbeidslivets organisering (Changes in the Organization of Work Life): 131-153. Oslo: Fafo.

Hakim, Cathrine 1990 "Core and periphery in employers' workforce strategies: Evidence from the 1987 ELUS Survey." Work, Employment & Society, 4: 157- 188.

Hall, Douglas T., and J. G. Goodale 1986 Human Resource Management. Strategy, Design, and Implementation. Glenview, IL/London: Scott, Foresman.

Harrison, Rosemary 1993 "Concepts and issues in human resource management." In Rosemary Harrison (ed.), Human Resource Management: Issues and Strategies: 35- 66. Wokingham: AddisonWesley.

Hendry, C., and A. Pettigrew 1990 "HRM as an agenda for the 1990s." International Journal of Human Resource Management, 1: 17-25.

Hollingsworth, J. Rogers 1997 "Continuities and changes in social systems of production: The cases of Japan, Germany, and the United States." In J. Rogers Hollingsworth and Robert Boyer (eds.), Contemporary Capitalism: The Embeddedness of Institutions: 260282. Cambridge, MA: Cambridge University Press.

Hollingsworth, J. Rogers, Philippe Schmitter, and Wolfgang Streeck 1993 Governing Capitalist Economies: Performance and Control of Economic Sectors. New York: Oxford University Press.

Jenkins, Alan, and Gilles van der Wijk 1996 "Hesitant innovation: The recent evolution of human resources management in France." In Timothy Clark (ed.), European Human Resource Management: 65-92. Oxford: Blackwell.

Jepperson, Ronald L., and John W. Meyer 1991 "The public order and the construction of formal organizations." In Walter W. Powell and Paul J. DiMaggio (eds.), The New Institutionalism in Organizational Analysis: 204231. Chicago: University of Chicago Press.

Kalleberg, Arne L., David Knoke, Peter V. Marsden, and Joe L. Spaeth 1996 Organizations in America: Analyzing Their Structures and Human Resource Practices. Thousand Oaks, CA: Sage.

Kristensen, Peer Hull 1992 "Strategies against structures: Institutions and economic organizations in Denmark." In R. Whitley (ed.), European Business Systems: Firms and Markets in their National Contexts: 117-136. London: Sage.

Lane, Christel 1994 "Industrial order: Britain, Germany and France." In Richard Hyman and Anthony Ferner (eds.), New Frontiers in European Industrial Relations: 167195. Oxford: Blackwell.

Legge, Karen 1995 Human Resource Management: Rhetorics and Realities. London: Macmillan.

Lucio, Miguel Martinez 1992 "Spain: Constructing institutions and actors in a context of change." In Anthony Ferner and Richard Hyman (eds.), Industrial Relations in the New Europe: 482-523. Oxford: Blackwell.

Mabey, Christopher, and Paul lies 1996 "Human resource management in the UK: A case of fundamental change, facelift or facade?" In Timothy Clark (ed.), European Human Resource Management: 34-64. Oxford: Blackwell.

Marchington, M., A. Wilkinson, P. Ackers, and J. Goodman 1994 "Understanding the meaning of participation: Views from the workplace." Human Relations, 47: 867-894.

Marginson, Paul, and Keith Sisson 1994 "The structure of transnational capital in Europe: The emerging Euro-company and its implications for industrial relations." In Richard Hyman and Anthony Ferner (eds.), New Frontiers in European Industrial Relations: 15-51. Oxford: Blackwell.

Mokken, Robert J., and Charles Lewis 1982 "A nonparametric approach to the analysis of dichotomous item responses." Applied Psychological Measurement, 6: 417-430.

Molenaar, I. W., P. Debets, K. Sjitsma, and B. T. Hemker 1994 MSP User Manual. A Program for Mokken Scale Analysis for Polytonomous Items. Version 3.0. Groningen: iec ProGRAMMA.

Nordhaug, Odd 1993 Human Capital in Organizations. New York: Oxford University Press. 1994 Strategisk personalledelse, 3rd ed. (Strategic Human Resource Management). Oslo: Tano Aschehoug. 1997 "Annerledeslandet Norge (Norway: A deviating country)." Working paper, Norwegian School of Economics and Business Administration.

Orru, Marco, Nicole Woolsey Biggart, and Gary G. Hamilton 1991 "Organizational isomorphism in East Asia." In Walter W. Powell and Paul J. DiMaggio (eds.), The New Institutionalism in Organizational Analysis: 361-389. Chicago: University of Chicago Press.

Pfeifer, Jeffrey 1994 Competitive Advantage Through People: Unleashing the Power of the Work Force. Cambridge, MA: Harvard Business School Press.

Poole, M., and R. Mansfield 1992 "The movement towards human resource management: Evidence from a national sample." Paper presented to the Annual British Academy of Management Conference, Bradford, England.

Powell, Walter W., and Paul J. DiMaggio (eds.) 1991 The New Institutionalism in Organizational Analysis. Chicago: University of Chicago Press.

Pugh, D. S., and D. J. Hickson 1976 Organizational Structure in Its Context: The Aston Programme I. Lexington, MA: Heath.

Reich, Robert 1993 The Work of Nations. New York: Knopf.

Rubery, Jill, and Frank Wilkinson 1994 Employer Strategy and the Labour Market. Oxford: Oxford University Press.

Scholz, Christian 1996 "Human resource management in Germany." In Timothy Clark (ed.), European Human Resource Management: 118155. Oxford: Blackwell.

Scott, W. Richard 1995 Institutions and Organizations. Thousand Oaks, CA: Sage. 1998 Organizations: Rational, Natural, and Open Systems, 4th ed. Upper Saddle River, N J: Prentice-Hall.

Simensen, Magnar, and Arne Isaksen 1995 "Mot et mer fleksibelt arbeidsmarked? (Towards a more flexible labor market)." Sokelys pa arbeidsmarkedet, 1: 73- 80.

Sisson, Keith 1994 "Personnel management: Paradigms, practice and prospects." In Keith Sisson (ed.), Personnel Management, 2d ed.: 3-50. Oxford: Blackwell.

Sjitsma, Klaas, P. Debets, and I. W. Molenaar 1990 "Mokken scale analysis for polytomous items: Theory, a computer program and an empirical application." Quality and Quantity, 24: 173-188.

Slomp, Hans 1995 "National variations in worker participation." In Anne-Wil Harzing and Joris van Ruysseveldt (eds.), International Human Resource Management: 291-317. London: Sage.

Sparrow, Paul, and Martin Hiltrop 1994 European Human Resource Management in Transition. New York: Prentice Hall.

Storey, John 1989 New Perspectives on Human Resource Management. London: Routledge.

Strang, David, and John W. Meyer 1993 "Institutional conditions for diffusion." Theory and Society, 22:487-511.

Sutton, John R., Frank R. Dobbin, John W. Meyer, and W. Richard Scott 1994 "The legalization of the workplace." American Journal of Sociology, 99: 944-971.

Tichy, N.M., C. J. Fombrun, and M. A. Devanna (eds.) 1984 Strategic Human Resource Management. New York: Wiley.

van der Klink, Marcel, and Martin Mulder 1995 "Human resource development and staff flow policy in Europe." In Anne-Wil Harzing and Joris van Ruysseveldt (eds.), International Human Resource Management: 156178. London: Sage.

Walton, Richard E. 1985 "Toward a strategy of eliciting employee commitment based on policies of mutuality." In R. E. Walton and P. R. Lawrence (eds.), Human Resource Management, Trends and Challenges: 35-65. Boston: Harvard Business School Press.

Wachter, Hartmut, and Theo Stengelhofen 1995 "Germany." In Ingrid Brunstein (ed.), Human Resource Management in Western Europe: 89-112. Berlin: de Gruyter.

~~~~~~~~

By Paul N. Gooderham Norwegian School of Economics and Business Administration , Odd Nordhaug Norwegian School of Economics and Business Administration and Kristen Ringdal Norwegian University of Technology and Science

We are grateful for valuable comments from Stephen R. Barley, Olav A. Kvitastein, and three anonymous ASQ reviewers as well as for the financial support of the Norweigian Research Council and the Ministry of Labor in Norway. Our names are listed in alphabetical order.

Source: Administrative Science Quarterly, Sep99, Vol. 44 Issue 3