The Space Between Laws: The Problem of Corporate Crime in a Transnational

                       Context*

 

RAYMOND J. MICHALOWSKI, University of North Carolina at Charlotte

                                             RONALD C. KRAMER, Western Michigan University

 

From: Social Problems, Volume 34 Number 1, February 1987 Pp. 34-48

 

During the last two decades transnational corporations (TNCs) have significantly expanded their operations in the Third World. However, in many developing nations legal controls over injurious corporate activities have not grown commensurately. As a result, TNCs operating in developing host nations have engaged legally in a variety of injurious actions that would have been violations of criminal, regulatory, or civil law in their home countries. The differences in the laws of home and host nations, and the ability of TNCs to influence the legal climate in host countries, renders the laws derived at the level of nation-states an unsatisfactory basis for determining the scope of criminological research on TNCs. Attempts within the United Nations to redefine the meaning of corporate crime by creating codes of conduct for international business, and efforts by U.S. business interests to limit these codes, are examined as a specific case in the current debate over what constitutes corporate transgressions. Utilizing the concept of critical reflexivity, we argue that the study of corporate transgression by TNCs can legitimately embrace not only violations of law, but also violations of international codes and other injurious actions that are analogous in severity and source to violations of these codes.

 

Transnational corporations (TNCs) engage in a wide variety of socially-injurious actions (Barnet and Muller, 1974; Simon and Eitzen, 1986). These harmful corporate acts raise a number of important sociological questions. One central set of questions concerns the conceptualization of these corporate harms for purposes of criminological research. Some have argued that the concept of crime only refers to criminal convictions and violations of criminal law (Shapiro, 1983; Tappan, 1947). Others have proposed that the traditional definition of crime be expanded to include violations of civil and regulatory law, as well as violations of specific criminal statutes (Blum-West and Carter, 1983; Clinard and Yeager, 1980; Schrager and Short, 1978; Sutherland, 1940, 1949). Still others claim that state definitions are too restrictive and unduly influenced by corporate power, and therefore, should be abandoned in favor of broader social definitions of crime based on concepts such as human rights (Schwendinger and Schwendinger, 1970; Tift and Sullivan, 1980).

The increasing global reach of modern transnational corporations aggravates the difficulties of arriving at a satisfactory conception of corporate crime. TNCs at times engage in practices which, while they would be illegal in their home nations, are legal in a number of host nations. The ability of TNCs to have a significant influence on the legal climate in host countries further renders the particular laws of these nations an inadequate basis for the study of corporate crime.

The purpose of this paper is to contribute to the resolution of this conceptual dilemma. The first step, following Blum-West and Carter (1983), is to separate the study of the organization and causation of socially-injurious corporate actions from a consideration of the socio-political definition of these acts. This distinction creates two "research domains" (Blum‑West and Carter, 1983:552) or "paradigms" (Kramer, 1985:472). In the first paradigm, the objective is to explain (and eventually control) the harmful corporate actions of TNCs. Corporate crime researchers operating within this paradigm need to develop their own behavioral definitions to delimit the subject matter and identify cases for study. We will offer such a definition in this paper.

The definitional paradigm is concerned with the socio-political construction of legal definitions of corporate acts that cause social injury. The goal of this paradigm is to understand the historical origins and development of laws and political labels concerning harmful corporate behavior. This corporate criminalization process has been studied almost exclusively at the level of the nation state. However, we intend to show that the spread of TNCs requires that we broaden this focus in two ways: by examining the social construction of political labels in the international arena as exemplified by the development of United Nations codes of conduct for TNCs, and by incorporating what we term analogous social injuries within the scope of corporate crime research.

 

TNCs and the Relocation of Corporate Hazards

 

Over the last quarter century, foreign investment by TNCs has expanded dramatically (United Nations, 1978:36). In the 20 years from 1960 to 1980, the revenues of TNCs grew tenfold-from 199 billion dollars to 2,155 billion dollars-with U.S. based corporations accounting for 50 percent of this growth (Cavanaugh and Clairmonte, 1983:17). By 1983, the worldwide profits of TNCs had reached a record high of 130 billion dollars (Multinational Moni­tor, 1984:11). This internationalization of corporate activity necessitates an expansion of corporate crime research beyond its dominant focus on offenses by corporations in their home countries.

While, on a dollar basis, foreign investment in developed nations exceeds that in developing nations (Hamilton, 1983:3; United Nations, 1978:40; U.S. Department of Commerce, 1984:8), it is transnational investments in developing nations that pose the greatest likelihood of injurious corporate activity, and which raise the most perplexing problems for the definition and study of corporate crime. There are several reasons for this.

First, the most significant change in patterns of foreign investment since the Second World War has been the increased location of TNC industrial facilities in developing nations (United Nations, 1978:40-41). Three-fourths of all U.S. companies with sales over 100 million dollars had manufacturing facilities in other countries by 1975 (United Nations, 1978:222). By 1977, developing nations had surpassed developed ones in dollar value as locations for manufacturing by U.S. industries (U.S. Department of Commerce, 1981:159). Reimportation of over­seas assembly by U.S. companies increased five‑fold between 1969 and 1983, and in the textiles and electronics industries more than half of all current sales by U.S. corporations are now assembled abroad (Grunwald and Flamm, 1985:12-13). As TNCs export their industrial operations to developing nations, many of the hazards of industrial production and the associated possibilities for corporate crime are relocated from developed to developing countries. Moreover, as the fatal poisoning of over 2,000 residents of Bhopal, India dramatized (Hazarka, 1984:1), the settlement patterns, population density, and limited disaster preparedness of developing nations means that, when problems do occur, the human and environmental costs are likely to be greater than those resulting from similar incidents in developed countries.

Second, the growth in consumer exports to the Third World, as well as the increased local production of consumer goods by TNCs in developing nations, has generated significant consumer safety issues. Differences in marketing practices of TNCs in home versus host nations, variations in the provision of information by TNCs regarding product hazards, and variations in cultural practices regarding product usage has led to unnecessary injury, illness, and death for Third World consumers of TNC products (Mattelart, 1983).

Finally, in comparison to developed nations, developing nations frequently have fewer legal controls over workplace, environmental, and consumer hazards of industrial production (Braithwaite, 1984; Castleman, 1975; Dewar, 1978; Vieira, 1985). Therefore, the potential for corporations to behave in socially injurious ways in developing nations is greater. For these reasons the growing internationalization of business points to developing nations as a significant emerging arena for injurious corporate activity.

 

TNCs and Corporate Deviance in the Third World

 

In recent years corporate injuries to workers, physical environments, and consumers in developing nations have revealed significant problems with respect to the control of corporate activity in these countries. We will explore each of these arenas, with particular attention to injurious actions that arise in the space between legal systems-actions which were prohibited in home nations, but permissible in the host countries where they occurred.

 

Working Conditions

 

According to the International Labor Organization (1985:55), industrial workers in TNCs in developing nations "suffer from more safety and health problems than similar workers in the developed countries." While in some cases TNC manufacturing operations provide better working conditions than locally-owned factories (Blake, 1980; International Labor Organiza­tion, 1985:44), it is the comparison between TNC operations in home and host countries, rather than between TNCs and local conditions, that raises the most perplexing questions for the study of injurious corporate activities.

In a number of instances, occupational safety and other working conditions in TNC operations have been found to fall below those mandated by law in more developed countries. The exposure of workers in electronics assembly plants to levels of carcinogens and other toxic materials beyond those allowed in the United States, for instance, has been one of the consequences of the exportation of this "clean" industry (LaDou, 1984). In the more obviously "dirty" industries such as asbestos and chemical production, foreign workers in U.S. subsidiaries have been knowingly exposed to toxic levels that were illegal in the United States. In 1972 for instance, Amatax, a Pennsylvania asbestos yarn mill, moved its entire production facility to Mexico to take advantage of the fact that Mexico had no laws regulating exposure of workers to asbestos fibers. Similarly, in 1974 Raybestos-Manhattan acquired 47 percent of the stock in a Venezuelan asbestos plant in order to take advantage of Venezuelan law which allows higher levels of airborne asbestos fibers than does the Occupational Safety and Health Adminis­tration (OSHA) in the United States (Castleman, 1979). In a similar case, Arasco, the only U.S. producer of arsenic, moved its entire operation to Mexico when OSHA lowered the U.S. limit for exposure to airborne arsenic from 500 to 4 micrograms per cubic meter of air (Mattelart, 1983:102). In the electronics industry, Third World workers in U.S. subsidiaries have been found to suffer eye strain and eye failure due to constant peering into microscopes without the benefit of rest breaks on company time required by law in the United States (Fuentes and Ehrenreich, 1983:6).

Industrial operations by some TNCs in developing host countries have used wage and employment practices prohibited in their more developed home nations. In some cases, work is contracted out to home workers at piece rates which require a level of effort comparable to nineteenth-century garment sweatshops. These contract workers enjoy no benefits in terms of holidays, health insurance, sick leave or pensions-all of which are legally-protected worker rights in more developed nations (Fernandez-Kelly, 1983:118). Likewise, the practice of using extended "probationary" periods during which workers (often women) are paid a lower wage rate and then "laid off"' just prior to completing this period would be illegal under U.S. labor law (Fuentes and Ehrenreich, 1983:9-10). As Fernandez-Kelly (1983:114) found in the "maquiladoras" factories of the Mexican border, a variation on this theme is to bring prospective workers in for a "test" during which they spend a day or more sewing garments for no pay in the hopes of possible employment. Ong (1983:431) suggested that employers also deliberately keep workers on "temporary status" for prolonged periods to minimize the risks of unionization. This strategy makes it easy to fire workers who organize or join unions.

 

Environmental Pollution

 

In some instances TNCs have located and/or relocated high‑pollution industries in less developed countries in order to escape the pollution control costs imposed by environmental protection laws in their home nation. Blake and Walters (1976:159) have suggested that TNCs "will be very sensitive to disparities among various [national] pollution control standards which affect production costs and competitiveness in international trade" as a means of ex­panding or protecting profit margins. This sensitivity reflects the fact that pollution control costs in the United States are higher than in most other countries (Pearson and Pryor, 1978:170). Robert Strauss (1978:451), President Carter's chief trade negotiator, warned in 1978 of a developing "pattern of flight" as U.S. companies are drawn to developing nations with less costly pollution control laws. Castleman (1978:3) similarly noted that "hazard export is emerging as a driving force in new plant investment in many hazardous and polluting industries." In some cases entire industries involving highly toxic substances such as asbestos, arsenic, mercury, and benzidene dyes have been exported to rapidly developing nations such as Korea, Mexico, Brazil, India, and Ireland (Leonard and Duerksen, 1981:55). Even computer and electronics assembly, once thought to be "clean" industries, often expose the environments of developing nations to a wide range of toxic substances that are more closely regulated in the United States (Cultural Survival, 1981; Dollars and Sense, 1984:6).

There has been some disagreement over whether pollution control costs actually play a significant role in location decisions (Flamm, 1985:77-78; Randall, 1977:v). However, the debate over the relative importance of pollution regulations for location decisions speaks only to the question of corporate motivation, not the consequences of corporate behavior. Even if they are not actively seeking "pollution havens," in many developing nations TNCs remain legally free to expose the water, air, soil, and bodies of workers to hazardous substances at rates higher than those allowed in their home countries (Vieira, 1985).

In addition to the problem of pollutants produced by TNCs operating in host countries, hazardous waste produced in developed countries has begun to find its way into developing nations. Some TNCs have sought to avoid the costs of mandated controls on hazardous waste storage in their home nation by transporting wastes to countries which have few or no legal controls on hazardous waste disposal (Centre on Transnational Corporations, 1985:59-60). In these cases, the TNCs involved are clearly acting to circumvent laws in their home nations rather than simply being passive beneficiaries of the difference in laws between home and host nations.

 

Consumer Safety

 

According to the U.N. Centre on Transnational Corporations (1985:58) "the one issue that has generated the greatest emotion and controversy in the 1980s regarding transnational corporations . . . is the exportation of products deemed to be harmful to health and the environ­ment." Several cases in recent years have dramatized the kinds of hazards consumers in developing nations face when TNCs circumvent product regulations in their home nations.

The export of children's sleepwear treated with the carcinogenic flame retardant Tris, after the sale of such sleepwear was banned in the United States, was one of the first cases of knowingly exported consumer hazards to receive widespread attention (New York Times, 1978:26). In the late 1970s, A.A. Robbins Company arranged (with the help of United States Agency for International Development) for the distribution of the Dalkon Shield intrauterine device in a number of developing countries. This overseas market was sought after Robbins already knew that the Shield was responsible for 20,000 cases of serious uterine infection, that it had resulted in several thousand hysterectomies among its users in the United States, and that the product would soon be banned at home (Dowie and Johnston, 1976; Mintz, 1985). In another case, Parke-Davis, a U.S. pharmaceutical company, successfully promoted the drug chloramphenicol on a non-prescription basis in 39 nations but provided no information con­cerning its dangerous and sometimes fatal side effects‑even though the drug was banned in the United States and Japan (Mattelart, 1983:100-101).

In addition to the hazards posed by consumer goods, it is estimated that annually 375,000 people in the developing world are poisoned-10,000 of them fatally-through the misuse of industrial and agricultural chemicals exported from developed nations. There is evidence that much of this poisoning results from the failure of TNCs to provide adequate information on the hazards of their chemical exports, and from their active attempts to find markets for chemicals banned at home (Bull, 1982; Weir and Schapiro, 1981). In one such instance, paraquat was successfully promoted for use as a marijuana defoliant in Latin America after it was banned for that purpose in the United States (del Olmo, 1986).

Most of the injurious corporate actions described above were not prosecutable as crimes or regulatory violations in the nations where they occurred. Yet to omit them from the study of corporate crime on this basis does little to help us understand either the organization and causation of injurious actions by TNCs, or the definitional process by which these actions have been rendered legal in host nations. Moreover, as we argue in the next section, the ability of TNCs to influence regulatory climates in host nations may play a crucial role in keeping inju­rious actions by TNCs from being defined and prosecuted as crimes.

 

 

TNCs and Regulatory Climates

 

TNCs can influence the regulatory climates of developing host nations in indirect and direct ways. The logic of development in the free-market world necessitates that developing nations create hospitable environments for foreign investment. Simply by holding the eco­nomic keys to development, TNCs indirectly limit the political willingness of developing nations to establish strict controls over potential or actual corporate harms. At times, TNCs have also exerted pressure in more direct ways to forestall legislation contrary to their interests, and in some cases to subvert political movements or leaders deemed inhospitable to these interests. We now examine this relationship between TNCs and regulatory climates in closer detail, with a particular focus on labor policies.

 

Indirect Influences

 

Free-market nations that have followed a capitalist model of development based on foreign investment find their potentials for economic growth closely linked to their ability to attract TNCs. Domestic elites in developing nations frequently find that general economic improvement and political stability in their countries, as well as their own economic and political success, depend upon creating hospitable environments for investment by foreign TNCs. The deepening need for inflows of foreign investment in developing nations, and the pressures this places on domestic policy, have been extensively examined by a number of dependency theorists. The specific regulatory adaptations that have been made to attract TNCs have been examined in less detail. However, there is some evidence that the existence of a profitable double-standard which allows TNCs in host countries to do what they are prohibited from doing in their home nations is related to the desire of host nations to attract foreign investment by creating regulatory climates hospitable to the interests of TNCs.

Controls over the rights of workers to organize for improved wage and working conditions is a good example of how TNCs become the passive beneficiaries of policies designed to attract them. Labor costs represent one of the most significant factors in the location of manufacturing plants (Burns, 1984). For instance, assembly line workers in the United States often earn per hour what assembly workers in developing nations earn per day (Fuentes and Ehrenreich, 1983:5). The desire to take advantage of significant differentials in national wage rates has been the primary stimulus for the location of TNC production facilities in developing nations (Grunwald and Flamm, 1985:3-9). Leaders in some developing nations have used limitations on worker rights as a strategy to convince foreign companies that, if they do invest, they will enjoy continued benefits from lower labor costs. The belief that this will attract foreign investment has received a degree of confirmation from investment practices of TNCs. For instance, investment in Thailand by the U.S. semiconductor industry did not reach significant levels until 1977, the year following the installment of a military junta that ended a period of democratic government characterized by strikes and other movements for increased popular control over the economy. Similarly, foreign direct investment in semiconductor assembly in the Philippines entered a period of significant growth beginning in 1972, the year Marcos declared martial law (Grunwald and Flamm, 1985:77). In 1982, Marcos continued his efforts to create a profitable climate for these TNCs by issuing a decree banning all strikes in the semiconductor industry as being against the "national interest" (O'Connor and Wong, 1983).

Another strategy used in developing nations to attract foreign investment at the expense of labor rights protected by law in developed nations is the creation of economic free zones (EFZs). In some cases these zones are little more than labor camps "where trade unions, strikes and freedom of movement are severely limited, if not forbidden" (Fuentes and Eher­enrich, 1983:5). For example, advertisements for Caribbean Assemblies, a set of EFZs in Haiti and the Dominican Republic, promise foreign companies a "large, urbanized, low-cost labour pool" and "strict anti‑strike and labour regulation laws" (Mattelart, 1983:106). A promotional document by the South Korea government offers this description of its EFZ:

 

The zone has the characteristics of a reserved territory in which the application of laws or relevant

regulations is partially or totally suppressed or attenuated .... It is an industrial territory in which a series of fiscal and legal privileges are offered to firms of foreign capital (Medawar, 1979:62).

 

Promotional materials such as these make it abundantly clear that limitations on the rights of workers are part of the bait that EFZs offer to foreign companies in some developing nations.

Lim (1983:14) has argued that locating TNC industrial facilities in developing countries is beneficial to workers in nations where unemployment and poverty are widespread, even if the rights of these workers are minimal. This perspective is manifest in the June 6, 1980 issue of Fortune magazine which asks, "Even though the people working on Castle and Cooke's banana plantations in Central America earn far less than the U.S. minimum wage, would they be better off if the company decided to move elsewhere?" However, the economic conditions that TNCs "improve" cannot be analyzed in isolation from the economic domination by foreign business interests that characterizes the history of many developing host nations. Moreover, while the factory work provided by TNCs may improve the incomes of some workers, the dependent development it represents generally results in a distorted economy, a split labor market, and exploitation of women who are the primary laborers in these factories (Amin, 1974; Frank, 1975; Nash, 1979; Wallerstein, 1979).

 

Direct Influences

 

In addition to benefiting indirectly from restrictive labor climates, TNCs have at times actively used their economic power in developing nations to limit the rights of workers to organize into unions to protect and promote their interests. In some case, TNCs have used the threat of the runaway shop to discipline workers. For instance, when the Malaysian govern­ment indicated in 1983 that it might permit the formation of a union for electronics workers, U.S. electronics firms in Malaysia indicated that, should this happen, they would consider moving their plants elsewhere. Subsequently, the Malaysian government shelved its plans for the union. In a similar case, Control Data Corporation closed a Korean production facility in response to attempts by workers to unionize (O'Connor and Wong, 1983). Such threats or actual incidents of capital flight can have a chilling effect on both labor activism and govern­mental support for labor rights in nations dependent on foreign investment.

Besides attempts to influence specific policies, some TNCs have used their economic and political power to alter the flow of broader political developments in host nations. In some cases, TNCs have contributed to the elimination of progressive or socialist governments in favor of conservative ones. Activities of this sort are often based on clandestine contacts between TNCs and governments in home or host nations. As a result, relatively little is known about their scope or frequency. However, cases such as ITT's contributions to the overthrow of Allende in Chile, the participation of United Fruit, International Railways of Central America, and Electric Bond and Share in bringing about the downfall of the progressive leader, Jacobs Arbenz, in Guatemala in 1954, and the more recent financial support provided by some U.S. corporations to the Nicaraguan contras in their efforts to overthrow the socialist government there, indicate that TNCs are not above using their power to alter the flow of political events in developing nations (Bonner, 1983; Jensen, 1973; Kenworthy, 1973; LaFeber, 1984; Langley, 1985:142‑43).

Overall, the combined effects of economic pressures to create a favorable climate for for­eign investment, and support by transnational corporate capital for governments or political parties hospitable to their interests, can create a set of structural/legal conditions which allow TNCs in host countries to do what would be illegal in their country of origin. We are not suggesting that all TNCs have taken full advantage of these favorable structural/legal climates, or that all actively engage in efforts to create these climates. We are suggesting that researchers must always be sensitive to the political influences of TNCs on the political climates and legal frameworks of host countries. Accordingly, the laws governing corporate behavior in these nations are a poor starting place for setting the scope of inquiry into corporate offenses a transnational context. In the following sections, we consider an alternative definitional framework for research on injurious actions by TNCs: the U.N. codes of corporate conduct.

 

The U.N. Code as International Politics

 

Multinational business is now international politics. Multinational companies are increasingly being

forced to operate in a framework not just determined by the laws of supply and demand . . . but also by a

proliferating set of intergovernmental arrangements specifically targeted at them (Robinson, 1983:3).

 

Recognizing that the political power of TNC's is truly transnational and hegemonic, and that independent national action is limited, many developing countries have come to believe that the only way they can confront and control TNCs is through the creation of international standards. The two most far-reaching attempts to establish worldwide standards for TNCs have been undertaken by the United Nations with the Draft Codes of Conduct on Transna­tional Corporations and the Guidelines for Consumer Protection. The development of these codes is a unique and highly relevant empirical case for a theoretical examination of the political definition of harmful corporate actions.

     The definitional process that created the U.N. codes supports Robinson's (1983) assertion that multinational business is now international politics. The code development process has brought into sharp focus the fundamental differences of perspectives and interests between developed and developing nations, and between free-market and centrally planned economies. Charles Lindblom (1977:ix) succinctly characterized these differences when he wrote:

'Aside from the difference between despotic and libertarian government, the greatest distinction between one government and another is in the degree to which market replaces government or government replaces market." The formation of the draft codes for consumer protection and transnational corporate behavior at the United Nations represents an attempt to replace markets with politics. That is, through the political mechanisms of the United Nations, non-aligned and less developed nations are seeking to implement a set of rules governing the market relations between TNCs, and the citizens and governments of the nations in which they operate. This process assumes the primacy of politics over markets, and in this way, transnational business has indeed become international politics.

 

Historical Background

 

The politicalization of international business, and the origins of the U.N. codes, have their roots in the "multinational debate" of the 1960s that reached its climax in the confrontation between developing and industrialized nations in the early 1970s (Robinson, 1983). The developing nations, many of them recently enfranchised, made claims concerning the harmful practices of TNCs and called for a New Economic Order and some form of binding control over TNCs. Throughout the 1970s, the United Nations led the crusade for a comprehensive, legally binding international code of conduct for TNCs. Within the United Nations, this crusade was led by the developing countries grouped together as the so-called Group of 77-­international trade unions, and some small, developed nations, such as the Scandinavian states (Hamilton, 1983).

The U.N. code of conduct on TNCs has its direct roots in a 1972 decision of the United Nations Economic and Social Council (ECOSOC) to establish a group of "eminent persons" to make recommendations for international action on TNCs (Robinson, 1983). Their report, "The Impact of Multinational Corporations on Development and International Relations," was published in May, 1974, and it provided the rationale for the subsequent development of the code. In December, 1974, ECOSOC created a Commission and Centre on Transnational Corporations. The Commission was charged with the job of drawing up a set of recommendations which could become the basis for a Code of Conduct dealing with TNCs.    

          The Commission on Transnational Corporations met annually from 1975 into the 1980s.  However, the economic downturn associated with the 1974 oil crisis and the corresponding increased need of the developing nations for foreign investment tempered the Commission's work (Robinson, 1983). The multinational issue was no longer a debate-it had become a negotiation. The principal forum for the negotiations was the "Intergovernmental Working Group on a Code of Conduct" which first met in January, 1977, and its reports to the Commission on Transnational Corporations.

          As the Intergovernmental Working Group began its task, several other international groups issued guidelines for TNCs. In 1976, the Organization for Economic Cooperation and Development (OECD) established its Guidelines for Multinational Enterprises, and, one year later, the International Labor Organization (ILO) approved the Declaration of Principles Concerning Multinational Enterprises and Social Policy. In 1980, the United Nations Conference on Trade and Development (UNCTAD) promulgated the Set of Multilaterally Agreed Equitable Principles and Rules for the Control of Restrictive Business Practices, and the World Health Organization's (WHO) International Code of Marketing of Breast Milk Substitutes was passed by the General Assem­bly in May of 1981.

          The ILO, UNCTAD and WHO guidelines are all sectoral codes for international business within the United Nations. They were developed to deal with specific problems that may arise from TNC activity and must be understood in the context of the more general negotia­tions occurring within the United Nations concerning TNCs. The OECD guidelines were a preemptive Western strike at the general UN codes. As Robinson (1983:7) points out:

. . . the guidelines are a calculated compromise by Western governments between, on the one hand, the need to sensitize firms to their social, economic, and political responsibilities and, on the other, the need to make the rest of the world aware, and in particular the LDCs negotiating a UN code of conduct for transnational corporations, that the West is not prepared to see excessive constraints imposed on their major creators of wealth.

          Despite the passage of these other international guidelines, the U.N. code of conduct re­mains in draft form. The Intergovernmental Working Group concluded its work on the code in May, 1982 at its seventeenth session. However, at this time the code has not yet been adopted by the General Assembly. On the other hand, the Consumer Code promulgated by the Economic and Social Council, was approved by the General Assembly in November, 1984.

                      Key Actors and Issues in the Definitional Process

 

          The primary impulse behind the U.N. codes was the desire of the developing countries­ the Group of 77‑to establish a "New Economic Order" and some mechanism for legal control over TNCs. Their manifesto for a U.N. code, produced in 1976, included a 21-point list of grievances and criticisms concerning the behavior of TNCs (Robinson, 1983). Their position, to use Lindblom's (1977:ix) terms, was that international politics must replace markets. The economic crisis of the mid-1970s mellowed the ideological tenor of the Group of 77 and they increasingly came to realize that to have any chance of success they would need to compro­mise with the developed countries. The major issue on which they compromised was the binding character of the code. They acknowledged that any code of conduct must be volun­tary and not legally binding at this point in time.

          The major ally of the developing countries was the international trade union movement centered in Western Europe. In fact, the unions and the TNCs were key interest group partici­pants in the political struggle to shape the U.N. codes. As Robinson (1983:195) points out,

. . . there is no doubt that the war of influence that has engaged the trade unions and multinational business since the start of the TNC debate in the 1960s, has an often determining impact on the treasures being drawn up in . . . the UN and its specialized agencies.

 

The trade unions favor increased regulation of big business and are supportive of attempts to increase public control of the international economy. In addition, the European unions generally bring to the debate over the codes an overt anti-capitalist ideology which broadens the framework of discussion. Furthermore, Robinson (1983) points out that the trade unions have a streamlined and interlocking organization that allows them to significantly influence inter­national policy.

The industrialized or developed countries, including the United States, West Germany, and the United Kingdom, have generally taken a much more conservative stance toward the whole idea of a code of conduct for TNCs. As the home countries of the majority of TNCs, these states have a much more positive assessment of TNC behavior. They have been con­cerned with making the codes voluntary arrangements that provide stable conditions for in­ternational investment. They have argued that the code of conduct must include a statement about the general treatment of TNCs by the countries in which they operate. They have also been concerned about the issues of nationalization and compensation.

Of course, the TNCs themselves are significantly involved in trying to shape the U.N. codes. At the beginning of the definitional process, the TNCs appeared to be resigned to the prospect of international codes of conduct and their strategy was to try to shape codes that they could at least live with. More recently though, big business and its lobbies (the International Chamber of Commerce in particular) have stepped up the attack on the fundamental principles that lay behind the codes. The TNCs are more forcefully asserting the primacy of markets over politics in the debates on the code. The election of Ronald Reagan in 1980 may provide a partial explanation for the aggressive stance of the TNCs. The Reagan administration has been quite vociferous in its condemnation of the codes and its support of markets over politics. As Caplan and Malcomson (1986:108) note, ". . . it is clear that the international business community, alone and in partnership with the Reagan Administration, is engaged in an active and effective assault on U.N. initiatives that are perceived as threats to corporate profits."

Speaking before the American Enterprise Institute in December, 1983, Jeane Kirkpatrick, then U.S. Ambassador to the United Nations, stated that the "proliferation of activities aimed at the regulation of international business (is] a very big problem" (Kirkpatrick, 1983). These regulatory efforts, she said, arise not from hazards posed by TNCs, but from "ideological distor­tions," such as the view of poor nations that they are victims of exploitation by TNCs. She went on to say that such regulation would result in "global paternalism" by the United Nations, a view similar to that expressed by the Reagan Administration in its opposition to the Infant Formula Code (Kirkpatrick, 1983). Echoing Kirkpatrick's concern, Murray Weidenbaum (1983:1), former chairman of President Reagan's Council of Economic Advisors, has accused the United Nations of trying to become a "global nanny," and warned that "the United Nations is in a growth phase in its attempts to control private enterprise" (1984:13).

Advertising Age, the trade paper of the advertising industry, worried that the consumer codes could limit the free choice of consumers in Third World countries as well as the freedom of merchants to promote their wares in the way they deem most effective (1984:58). Chemical Week, the trade organ of the U.S. chemical industry, expressed a similar concern (1981.:15). In perhaps the most strident attack on the U.N. activities, the Heritage Foundation warned that “a new wave of extremist, anti-free enterprise consumer organizations" is using "distortions to undermine the multinational corporations and the private sector approach to development." This threat to free enterprise results, they say, from the fact that:

 

Various consumer, union and church organizations have been banding together and refining and sharing their techniques .... They are developing international networks that allow them to draw attention to targeted issues . . . forcing multinational firms to pay closer attention to their corporate activities (Heritage Foundation, 1983).

 

Emerging Political Definitions and Their Significance

 

Out of the sharp political and ideological conflicts within the United Nations, and despite the opposition of the international business community, a Draft Code of Conduct on Transna­tional Corporations has been produced. This code, along with the consumer code, constitutes a set of international norms for the conduct of transnational business-a new set of political definitions concerning the behavior of TNCs. While space does not permit a full description of the code of conduct, the outline in Table 1 highlights the major areas and topics covered by the code. The specific standards formulated under the topic headings in the draft code have one key notion running through them-accountability. As Robinson (1983:224) notes:

 

By accountability is meant the accountability of business to new constituencies-to governments, to the general public, and, above all, to the workforce. And being accountable to such new constituencies, the multinational company is forced into a new context of political and social responsibility.

 

Caplan and Malcomson (1986) offer another perspective on the code when they observe that it modestly seeks to universalize much of what we in the United States have already achieved in imperfect form-consumer protection, safeguards against exposure to hazardous products, control over national resources, corporate accountability, and economic sovereignty.

 

 

 

 

Table 1                            Activities of Transnational Corporations Covered by U.N. (Draft) Code of Conduct

__________________________________________________________________________________________

A. General and Political

     1.Respect for national sovereignty and observance of domestic laws, regulations and administrative practices

     2. Adherence to economic goals and development objectives, policies and priorities

     3. Adherence to socio-cultural objectives and values

     4. Respect for human rights and fundamental freedom

     5. Non-interference in internal political affairs

     6. Non-interference in intergovernmental relations

     7. Abstention from corrupt practices

B. Economic, Financial and Social

     1. Ownership and control

     2. Balance of payments and financing

     3. Transfer pricing

     4. Taxation

     5. Competition and restrictive business practices

     6. Transfer of technology

     7. Consumer protection

     8. Environmental protection

__________________________________________________________________________________________

Source: CTC Reporter, 1982:3‑4, 23‑24

 

It is important not to overestimate the significance of the codes. The code of conduct on TNCs has not yet been adopted by the General Assembly. Neither code is legally binding or enforceable. The code of conduct also sets standards for the treatment of TNCs by the coun­tries in which they operate. Some observers believe that the impact of the codes has already been eviscerated by the international business community (Caplan and Malcomson, 1986). Another observer ,warns that the codes may actually benefit TNCs by securing a stable international business framework and, by placing them on an equal footing with government, legitimize their activities in the eyes of their critics (Hamilton, 1983).

Whatever the truth of these observations, the real significance of the U.N. codes is that they create transnational standards for evaluating the behavior of TNCs. A worldwide set of general principles has emerged out of the political definitional process within the uniquely distinctive setting of the United Nations. Just as broader conceptions of human rights and corporate crime emerged in the United States through class struggle and the political mobilization of a wide range of interest groups (Coleman, 1983), the United Nations has provided a global arena for political struggles between developing and developed nations and between the trade union movement and the international business community over the dominance of politics or markets, and the appropriateness of specific actions by TNCs. Finally, even though we have noted the hegemonic process of legal definition in developing nations, the legitimacy of transnational standards in conjunction with the political power of the United Nations may allow the U.N. codes to serve as model legislation to be enacted within specific developing nations.

 

The Search for Alternative Frameworks

 

The evolution of U.N. codes for the conduct of TNCs returns us to our central problematic-that the laws of nation-states represent theoretically inappropriate frameworks for the study of injurious actions by TNCs. The need for criminological researchers to derive behavioral standards independent of law is not a new concern for criminologists. Nearly a half­-century ago Thorsten Sellin (1938:104-5) argued that criminologists should not limit their in­vestigations to "categories set up by the criminal law," because these categories "do not arise intrinsically from the nature of the subject matter," but instead, reflect the "character and interests of those groups in the population which influence legislation." In recent years some criminologists have responded to this challenge by employing various concepts of "human rights" in constructing alternative definitions of crime (Schwendinger and Schwendinger 1970; Tift and Sullivan, 1980). These "human rights" definitions of crime, in turn, have generated their own set of criticisms.

The central critique of "human rights" definitions of crime has been that researchers who utilize them simply substitute their personal moral concerns for those contained in law. Shapiro (1983:307) argues that corporate crime research that extends beyond the boundaries of what is illegal is inevitably flawed because it is suffused with the "moral agenda" of the observer. A more trenchant criticism is offered by John Braithwaite (1985:18) who suggests that:

 

Those who choose to study violations of "politically defined human rights," or some other imaginative definition of deviance, will deserve to be ignored for indulging their personal moralities in a social science that has no relevance for those who do not share that morality.

 

The typical rejoinder to criticisms of this type is that relying upon law to define the boundaries of criminological inquiry is no less suffused with moral choice than is choosing definitions based on concepts of human rights. For instance, Schwendinger and Schwend­inger (1970:142) argue that:

 

No scholar involved in the controversy about the definitions of crime has been able to avoid direct or indirect use of moral standards in the solution to this problem .... In light of this, the claim that moral judgments have no place in the formulation of the definitions of crime is without foundation.

 

While the observation that law contains no less a moral and political agenda than any other definition of transgression may be correct, it provides no particular guidance regarding why we should choose one particular framework for defining the parameters of study over another. We suggest that the first step beyond this set of mutual accusations is to distinguish between the positivist concept of lack of bias and critical theory's concept of reflexivity. Within a positivist conception of social science bias is a preference for one set of social outcomes over another. This should be avoided in favor of a value-free science in which the researcher holds no brief with respect to the world in view.

The presumed attainability of a science without bias arises from the attempt in positivist epistemology to separate the powers of human reason from the inevitability of human com­mitment to the social world. This separation of reason from commitment, according to Habermas (1974:264), produces the goal of unbiased inquiry through which reason is applied to developing the technical means of control over environments and people, but from which the application of that same reason to inquiry regarding the purposes of that control is ex­cluded. Within this framework, social scientists who reveal preferences for some social agendas over others are suspected of allowing ideology to distort science, that is, commitment is thought to compromise reason.

The positivist commitment to a world developed through technical application of scientific rationality, by contrast, is interpreted not as commitment but as reason:

 

            Efficiency and economy, which are the definitions of this [positivist] rationality cannot, in turn, be     themselves conceived as values, and yet, within the framework of positivism's understanding of itself, they can only be justified as though they were values (Habermas, 1974:269).

 

The search for a social science devoid of bias is a misdirected and futile endeavor. As Karl Heilbroner (1974:23) observes:

 

The position of the social researcher differs sharply from that of the observer of the natural world. The latter . . . is not morally imbedded in the field he scrutinizes. By contrast the social investigator s inextricably bound up with the objects of his scrutiny . . . bringing with him feelings of animus or defensiveness to the phenomenon he observes.

 

In contrast to positivist notions of unbiased science, critical reflexivity is a mode of analy­sis that recognizes the existence of moral preferences in ourselves and others, and demands of us that we analyze the nature and construction of those preferences so that they contribute to rather than detract from our ability to achieve the purposeful understanding we seek and the type of social world to which we are committed. Rather than following the path outlined by a positivist model of inquiry presumably shorn of moral commitments, the study of injurious actions by TNCs should be guided, we suggest, by principles of critical reflexivity. This perspective provides a theoretically-grounded way to expand the scope of study beyond the limits of the law, and to incorporate a positive commitment to the reduction of social injuries by corporate actors within the framework of research concerns.

Critical reflexivity according to Habermas (1973:15) develops when we examine what he terms taken for granted "validity claims" and "redeem or dismiss them on the basis of argu­ments." Because of their taken for granted nature, however, validity claims are only revealed through discourses where "participants, themes and contributions are not restricted except with reference to the goal of testing the validity claims in question," and where "no force except that of the better argument is exercised" (Habermas, 1973:108).

Law is a socially and historically legitimated authority system. The validity claims im­plicit in laws‑including the assumption that law is the final arbiter of transgressive-action ­have been established not through the type of discourses described above, but through the historical interplay of a variety of economic and political forces. If law is used to define the scope of corporate crime studies, the possibilities for a critical understanding of transgressive actions is negated by the consequently unanalyzed history of power relations imbedded in law. Moreover, alternative discourses which perceive the validity claims of established laws as problematic are omitted from our inquiry, further narrowing our ability to analyze the transgressive actions of TNCs from a critically reflexive standpoint.

With respect to the study of corporate crime, critical reflexivity does not mean seeking out some set of definitions that are free of moral implications. We are never without preferences with respect to outcomes in the social world. However, we can begin to develop critical reflexivity by using and entering into less restricted discourses which question rather than accept those validity claims that either the law or other conceptions of human rights treat non-problematic. The evolving U.N. codes for the conduct of TNCs represent this type of expanded discourse, and offer a broader framework for the study of injurious actions by TNCs than does limiting our inquiry to the laws of nation states.

 

Conclusion: Toward a Definition of Corporate Transgressions

 

Where injurious actions by TNCs violate existing national laws there is little conceptual difficulty in placing them within the purview of corporate crime studies. However, only by roving beyond national laws can we begin to study transgressions that arise in the space between national legal systems. The study of injurious actions by corporations that operate at the level of the world system requires a conception of transgression developed through discourse at the same level, and which is capable of adapting to changing forms of injurious corporate action. With this in mind we offer the following expanded framework for the study of corporate wrongdoing:

Corporate transgressions by TNCs encompass any action in pursuit of corporate goals which violates national laws, or international standards such as codes of conduct for TNCs developed within the U.N., or which results in social injury analogous in severity and source to that caused by corporate violations of law or international standards.

We have substituted the term corporate transgressions for the more common phrase corporate crime for two reasons. First, the term transgressions avoids the semantic and theoretical problems that arise when corporate actions that are not specifically adjudicable under law are defined as crime. Second, the concept of transgression retains a sense of fundamental wrongfulness similar to that associated with "crime." This references our commitment to the reduction of avoidable, injurious actions committed against people by organizations in the pursuit of capital accumulation. We prefer the concept of corporate transgression to that of "corporate deviance," which can encompass any action that offends any organized constituency, whether it be consumers or stockholders (Ermann and Lundman, 1982:16‑19). The term corporate transgressions is less relativistic and better conveys, we feel, the severity of harm that can arise from the actions of TNCs.

The general principles outlined in the U.N. codes, as well as the specific provisions under each, provide a conceptual framework which allows us to expand the scope of inquiry without the epistemological hazards of definitions derived from personal conceptions of human rights. The U.N. codes represent the current stage of political struggle to refine the concept of human rights, and rights of national sovereignty, vis-à-vis large, transnational, corporate insti­tutions. As such they are the appropriate reference point for understanding what constitutes transgressions by these institutions.

In addition, definitions of corporate transgressions evolved at a world level through a process in which all members of the world community participate represents a type of ex­panded discourse. This expanded discourse offers greater possibilities for the development of critical reflexivity where injuries by TNCs are concerned than do the laws of individual nations. The U.N. codes are not products of Habermas' ideal form of discourse conducted in the absence of all force except the better argument. However, they represent concepts of transgression negotiated in a context freer of the political pressures and limitation on viewpoints that surround the more hegemonic processes of national legislation. The discourse surrounding the U.N. codes incorporates a broader range of voices, some of which are silent within individual nation states. Representatives of the non-aligned developing nations, the developed free-market states, and the developed and developing planned economy states have each had opportunities to articulate their conceptions of corporate transgression, and to negotiate for provisions consistent with their views (U.N. Chronicle, July, 1983:103). This interplay of perspectives provides a climate wherein the normally hidden validity claims of legal systems in different nations are revealed for critical assessment.

We recognize that truly equal input into the deviance defining process is not easily or likely to be achieved in any political context, including the United Nations. However, the political process surrounding the development of the U.N. consumer and corporate codes brings together into a single communicative forum a wider range of participants and perspec­tives than national debates. Consequently, a broader range of validity claims regarding the control of corporate activities is revealed for examination than in national forums. For those whose interest is the definitional process underlying concepts of corporate deviance, the op­portunity to examine the conflicting validity claims that arise within the context of interna­tional debate regarding the behavior of TNCs is invaluable.

The inclusion of injuries that are demonstrably analogous in severity and source to those which violate national laws or international standards even if they do not violate these laws or standards advances both the behavioral and the definitional research domains in the study of injurious corporate actions. Corporate crime studies regarding the organization and causation of injurious corporate actions are primarily concerned with explaining and eventually controlling these injurious actions. As shown by cases such as Nestles' marketing of breast milk substitutes (Chetley, 1979), or the current spread of genetic engineering beyond the reach of existing national laws (Schneider, 1986a, 1986b), new forms of injurious corporate actions can emerge more swiftly than laws or standards aimed at controlling them. Excluding analogous forms of corporate injuries because they have not been politically defined as transgressive confounds the behavioral paradigm with inappropriate definitional criteria. It places the behavioral paradigm under the authority of political processes. Inclusion of analogous corporate injuries advances the behavioral paradigm within corporate crime studies in another way. It makes it possible to compare the organization and causation of injurious actions that are defined as transgressive with those that are not. Comparisons of this type will improve our understanding of the relationship between causation and control of corporate behavior.

Inclusion of analogous forms of corporate injury is essential for any real development within the definitional research domain. A necessary component of any mature inquiry into the application of meaning to corporate behavior is comparative analyses of the processes whereby some corporate injuries are selected for control while others are defined as acceptable or necessary consequences of economic practices. Excluding injurious activities from defi­nitional studies because they have not been politically defined as transgressive closes off this crucial area of inquiry. The study of injurious actions by TNCs can make substantial contribu­tions to the definitional paradigm in corporate crime studies-but only if our conceptualiza­tions do not prohibit us from examining the processes by which some forms of corporate injury are defined as transgressive at either the national or international level and others are not. In general, we suggest that researchers interested in the study of corporate crime by TNCs maintain a clear distinction between behavioral and definitional research domains, recognize the limitations of legal criteria for setting the scope of study, and expand existing frameworks to include both violations of international standards of corporate conduct and all other analogous forms of corporate transgression.