MYTH: Affirmative action is a U.S. policy that is peculiar to America.
FACT: Affirmative action is not the product of the U.S. In fact, affirmative action is an international phenomenon and is supported by human rights principles, including the International Covenant for the Elimination of Race Discrimination. In fact, some countries actually impose affirmative action hiring requirements that outstrip U.S. rules.
Around the globe, historically and currently, many countries have pursued and embraced affirmative action measures to address various forms of subordination and inequity that exclude or marginalize socially distinct groups.
Furthermore, in an increasingly globalized society and economy, affirmative action is supported and used by corporations and by their clients who recognize the competitive advantages of a workforce comprised of people from diverse backgrounds with a wide variety of skills and cultural competencies.
Affirmative action is neither unique to the U.S. nor limited to the particular society and history that the U.S. represents. Many countries around the world, each with different histories, ideologies and populations, employ various forms of affirmative action to advance social justice and full utilization of its citizens.
How various nations handle affirmative action
Let’s examine some of them:
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- Brazil – After a particularly difficult history of affirmative action which caused much unrest in the country, now Brazilian legislation does not provide for mandated preferences in hiring, except for some mandated preference in hiring physically disabled employees. Disabled employees have been granted special protection both under the provisions of the Brazilian Constitution and by statute. As a consequence, companies with more than 100 employees are obliged to fill 2 percent to 5 percent of their positions with either Social Security beneficiaries or skilled disabled employees.
- South Africa — The Employment Equity Act (EEA) requires so-called designated employers (those with 50 or more employees or whose annual sales exceeds a prescribed threshold) to apply affirmative action when making appointments or promoting people This involves giving preference to people from designated groups provided they meet the requirements of the job, even if they are not the best candidate for job Only Black persons (i.e. Black, Coloured or Asian), women, or people with disabilities can benefit as these designated groups are regarded as having been previously disadvantaged.
- India — One of the first countries to have affirmative action policies created after the country gained independence from Great Britain in 1947. In 1979, a commission recommended changing the country’s caste-based system to one based on income level and class. The definition of so-called “backward castes” preferential programs was to “backward classes” which could cover as many as 3,500 groupings based on such factors as income level, occupation and proximity to drinking water. Today, the Indian Constitution obligates the state it ensure that as far as public sector employment there is to be equal treatment of all citizens: hiring, promotion, ownership of material resources, concentration of wealth and equal pay for men and women. This does not apply to the private sector.
- Slovakia, Germany, Italy, Spain, Argentina and Brazil — All have laws requiring companies to give preferential hiring to disabled people as a certain percentage of the total workforce.
- United Arab Emirates — The UAE legislates hiring priorities in this order: UAE citizens first, nationals of other Arab countries second, and third are persons of all other countries.
- In Asia, Taiwan, Singapore and Hong Kong do not have any preferential hiring laws.
Developing a common global diversity platform
In developing affirmative action plans, multinationals can establish a common structure of practices and support programs at the global level and then customize the content to the needs of each country. GE, Microsoft and Motorola have developed effective global diversity programs that provide a common platform around the world, but at the same time provide the flexibility to adapt to specific needs of each country.
Maintaining and managing a diverse workforce and satisfying diverse constituents require that multinationals integrate differing affirmative action requirements and expectations effectively. Success rests on the ability of multinationals to effectively navigate the cultural, social and legal structures of varying countries.
Given that numerous countries have recognized the need to take affirmative steps toward inclusion and created a variety of affirmative action programs toward that end, it is impossible to conclude that affirmative action is an American export.
Yes, in the area of affirmative action, the United States is not the leader, but the outlier.