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Transparency and Neoliberal Logics of Corporate Economic and Social
Responsibility
Majia Holmer Nadesan
March 21, 2010
PUBLISHED
Nadesan, M. (2011). Transparency and Neoliberal Logics of Corporate Social
Responsibility. In O. Ihlen, J. Bartlett, S. May (eds.) The Handbook of
Communication and Corporate Social Responsibility (pp. 252-275). Malden, MA:
Wiley-Blackwell.
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Transparency and Neoliberal Logics of Corporate Economic and Social
Responsibility
Majia Holmer Nadesan
March 21, 2010
Abstract
Transparency has emerged as the primary mechanism for ensuring orderly and
efficient markets and socially responsible conduct among the world’s corporations and
organizations. Under neoliberalism, voluntary transparency regimes are preferred for
ideological reasons over more tightly regulated transparency regimes instituted and
governed by states. However, three decades of corporate fraud, culminating in the current
financial crisis, call into question the efficacy of the neoliberal paradigm of transparency
that prioritizes self-regulation as the central technology for ensuring corporate
responsibility. Yet, even in the wake of this crisis, the neoliberal paradigm of
transparency continues to reign in the business world as the preferred mechanism for
ensuring corporate accountability in relation to fiscal, environmental, and labor issues
and concerns. Accordingly, this paper critically explores the limits of contemporary
formulations and applications of transparency.
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Transparency and Neoliberal Logics of Corporate Economic and Social Responsibility
Transparency is a hot topic in the pages of public relations and management
journals (e.g., Christensen, 2002; Dubbink, Graafland, & van Liedekerke, 2008; Schipper
& Bojé, 2008). Transparency is represented as critical to corporate social responsibility.
As a fundamentally communicative phenomenon, the logics, discourses, and practices of
corporate transparency should be of interest to communication scholars, as well as to
those in management and organization studies. This chapter explores different
formulations of corporate and economic transparency and investigates the regimes of
government that inform “transparency” standards and practices. Discussion demonstrates
that transparency is not a free-standing condition. Rather, “transparency” must be
understood in relation to the social spaces that are targeted for visibility and the logics of
government that implicitly or explicitly dictate how transparency is defined and enacted.
The chapter begins by defining the “problem” of transparency and chronicling the
regulatory frameworks developed to promote organizational and market transparency
historically and within the late twentieth century neoliberal era. The chapter then
examines how advocates of corporate social responsibility have seized upon “neoliberal”
formulations of fiscal transparency as their solution frame for ensuring responsible
corporate labor and environmental operations. This chapter concludes by critically
evaluating how the neoliberal framing of corporate social responsibility has elevated
voluntary responsibility regimes over mandatory ones.
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The Problem of Transparency
Transparency is most broadly defined as “the degree to which information is
available to outsiders that enables them to have informed voice in decisions and/or to
assess the decisions made by insiders” (Florini, 2007, p. 5). As implied by this definition,
high transparency is believed to overcome informational asymmetries that enable insiders
to make self-interested decisions that might adversely impact “outside” stakeholders.
This faith in the role of transparency in promoting accountability presumes that
information availability is a, or even the, necessary precondition for reducing fraud,
corruption, and the abuse of power (see Christensen & Langer, 2007). Transparency is
therefore linked to the governance quality and stakeholder accountability of NGOs (non-
governmental institutions), corporations, financial markets, and democratic government
institutions, ranging from school boards to national governments (see Vishwanath &
Kaufmann, 2001). Most broadly, transparency is formulated as a security mechanism that
stabilizes macro systems by insuring the good governance of specific institutions and the
efficient, stable operations of financial markets.
Transparency operates as a security mechanism, or risk reduction device, by
promoting stable and efficient market operations. As succinctly put by Tett in The
Financial Times: “One of the founding principles of free market theory, for example, is
the idea that markets work best when there is a free flow of information” (2009). This
founding principle of free information is formally codified in the “efficient market
hypothesis,” which presumes that markets are populated by rational actors who set prices
that reflect all available knowledge accurately. Transparency of information affecting
pricing is therefore critical for markets to operate efficiently. Lack of transparency causes
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the misallocation of resources and can produce speculative bubbles. Adherents of the
efficient market hypothesis tend to advocate for self-regulating, laissez-faire (a.k.a.
“neoliberal”) approaches toward ensuring transparent markets over direct government
oversight and regulation (e.g., see Crovitz, 2009, p. A15).
As illustrated above, the process of rendering corporations and market
transactions “transparent” is currently understood as enhancing security and
accountability to shareholders. However, as Ronald Mitchell (1998) observed, “the
necessity for transparency has not been the mother of its invention” (p. 110). Mitchell’s
point is that transparency has rarely been achieved with ease. Moreover, measuring
transparency can be tricky. Transparency protocols, or regimes, vary in their demands for
information and the supply of information available. Transparency regimes also vary in
relation to obligatory requirements. Transparency regimes may be voluntary creations
structured, operated, and monitored by self-regulating agents. Or, transparency regimes
can be mandatory regimes imposed upon markets, organizations, and/or individuals by
formal governance entities. Obligatory transparency requirements strive to enforce
corporate accountability and implicitly subordinate market autonomy to the power of a
regulatory agency. However, even obligatory transparency regimes may not result in the
degree of information openness necessary for outside stakeholders to have access to
meaningful and relevant data about organizational/market operations and externalities
(see Christensen, 2002; Christensen & Langer, 2009; Heald, 2006). The obligatory and
voluntary aspects of transparency regimes and the challenges of information adequacy
are central foci of this essay’s discussion of the relationships across transparency,
corporate social responsibility, and efficient and secure markets. A brief look at the
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conflicted history of transparency requirements and regulatory control in western
corporations and financial markets points to what is at stake in current debates about
voluntary transparency as a preferred strategy for ensuring corporate social
accountability.
Transparency: Fiscal History
Transparency was thought first in fiscal terms. National governments in Europe
have since at least the seventeenth century had a stake in the fiscal transparency of
organizational entities and markets. European mercantile authorities sought to govern the
apparatuses of production directly and therefore created detailed statistics of productive
activities, thereby rendering market activity “visible” or transparent. Nation-states
eventually ceded mercantile control as laissez-faire logics of government arose in the
eighteenth century, but did not entirely cease efforts to render transparent and regulate
economic processes for the purposes of taxation, economic security, national
competition, etc. Laissez-faire advocates have for the last two hundred years persisted in
resisting “excessive” government oversight, which is viewed as interfering with business
freedoms and as producing systematic biases in the allocation of resources. This tension
between (1) the states efforts to render visible and regulate and (2) laissez-faire efforts to
promote economic autonomy and privacy shaped twentieth century economic history in
western nations (Nadesan, 2008).
The Dangers of Laissez-Faire and the Keynesian Challenge
Over the last two hundred years, attitudes in countries such as the U.S., U.K., and
Australia about enforcing market and corporate transparency have shifted significantly.
Laissez-faire logics of government prevailed in most western nations during the late
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eighteenth and nineteenth centuries. For instance, U.S. joint-stock companies, from
which the modern corporation emerged, were regulated by state charters and state
legislation, but banks and the early American stock market were relatively free from any
form of direct control outside of capital requirements (Ferguson, 2008). Indeed, Ferguson
describes U.S. banking up until 1913 as a “natural experiment with wholly free banking”
(p. 57). This experiment eventually demonstrated the dangers of voluntary self-regulation
and ushered in formalized oversight and governance. A brief exposition of the events and
forces that overturned laissez-faire hegemony in the U.S context specifically, and the
western European context more generally, dramatizes how the opacity of unregulated
markets result in financial crises that eventually de-legitimize market auto-regulation.
Excessive leverage and risk taking occurred in European and U.S. banking and
securities markets in the nineteenth and early twentieth centuries for several reasons.
First, most western central banks were private and relatively unregulated until the mid
twentieth century, thereby allowing excessive leveraging. Second, securities markets in
the U.S. and European countries such as England, the Netherlands, and the U.S. had
operated extra-legally and/or with little regulation since their inceptions in the
seventeenth and eighteenth centuries (e.g., see Neal, 2005; Sylla, 2005). Third, evolution
of the modern corporation in the late nineteenth century—including the loosening of
governments’ charter requirements for corporations in the U.S. and U.K.; the
establishment of limited liability beginning in the 1850s; and the separation of
management and ownership in “join-stock” companies as ownership—fueled speculation
in securities. Fourth, due to the lack of uniform national and international accounting
standards, investors interested in purchasing securities largely had to rely on private
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rating agencies such as the U.S. Standard & Poor’s, established in the 1860s, to provide
background information about corporate financials. All of these factors obscured the
transparency of market information, thereby contributing to laissez-faire capitalism’s
destabilizing boom-bust cycles (Ahamed, 2009). The severity of these cycles was
exacerbated by lack of sovereign control over credit (Duménil & Levy, 2001).
Not surprisingly, the boom-bust cycles and the growth of unregulated finance
resulted in profound economic and social instabilities (see Duménil & Levy, 2001).
Within the U.S., efforts to limit banking crises involved establishment of the U.S. Federal
Reserve System, which was legislated in 1913 to regulate the nation’s money supply
through a network of privately controlled regional banks delegated government powers
(Greider, 1987). A Federal Reserve Board, appointed by the U.S. President in
Washington, was tasked with overseeing the semi-private reserve banks operated by the
private banking institutions. However, the early Federal Reserve Board’s allegiances
were to the private banks that made up the reserve system, rather than to the nation itself
(Duménil & Levy, 2001). In effect, despite some efforts to reign in market forces, laissez-
faire attitudes toward central banks, corporations, and securities markets largely
continued until the onslaught of the Great Depression, beginning in 1929.
During the later 1930s and 1940, Europe and the U.S. passed a variety of national
laws and international agreements aimed at enforcing greater transparency and regulation
of industrial corporations, banks, and financial markets. The regulatory framework
applied has since been termed Keynesian since it was significantly impacted by the work
of John M. Keynes, who sought to temper capitalism’s boom and bust cycles by reigning
in control over central banks (to allow the state to control credit), by regulating industry
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and finance, and by increasing aggregate demand through government spending. For
instance, the Bank of England was nationalized in 1946 and the U.S. passed the
Administrative Procedure Act of 1946 (P.L. 79-404), which served as the basis of the
Attorney General's Manual on the Administrative Procedure Act (1947), which imposed
public transparency requirements on the Federal Reserve system, as well as all
government agencies. International apparatuses, such as the Bretton Woods Agreement,
GATT, and the World Bank tempered laissez-faire by creating international frameworks
for monitoring, enabling, and governing the forces and operations of markets and capital
flows within and across nations. Laissez-faire was thus tamed by the regulatory state.
The Delegation of Transparency: U.S. Finance Evades Keynesian Constraints
A more focused look at the regulatory laws passed and agencies instituted within
the U.S. during the 1930s and 1940s provides a case study of the challenges of
transparency, even within more stringent regulatory environments. The Great Depression
prompted greater regulatory reform under F. D. Roosevelt’s New Deal in order to ensure
transparency and regulate risks. Private banking was regulated by the Glass Steagall Act
of 1933, which distinguished investment banks from commercial ones and imposed upon
the latter a tight regime (based on the standards of the time) of fiscal governance as
commercial banks were drawn into the newly created Federal Deposit Insurance
Corporation’s system. The Security Exchange Commission (SEC) set up in 1934 was
granted legal authority to establish accounting and financial reporting standards for
publicly held companies in order to ensure their transparency to outside investors.
The SEC illustrates how a government regulatory regime designed to ensure
transparent and orderly markets can essentially outsource its operations to private actors.
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The SEC delegated authority to various self-regulating agencies including: the National
Association of Securities Dealers, national stock exchanges (e.g., NYSE), and the
Financial Industry Regulatory Authority (FINRA) (“Self-Regulating,” no date). Perhaps
most importantly, the SEC delegated the responsibility to establish the accounting and
audit standards necessary for fiscal transparency to the private, American Institute of
Certified Accountants (AICPA). The AICPA created the Committee on Accounting
Procedures (CAP), which struggled to develop a structured set of accounting principles
applicable to all publicly-traded corporations in the period ranging from 1939 to 1959
(“Generally Accepted,” n.d.). In 1973, the private, Financial Accounting Standards Board
(FASB) replaced CAP and the AICPA. FASB regarded creation and auditing of
standardized accounting principles-- Generally Accepted Accounting Principles (GAAP)-
-as critical for ensuring corporate and market transparency, since the latter hinges upon
the former.
During the 1980s, few critics in the U.S. or U.K. questioned state delegation of
monitoring and compliance to self-regulating commercial entities (e.g., such as FASB).
Late twentieth century financial industry analysts and investors believed self-regulation
of financial markets and institutions worked because the financial products being sold by
industrial corporations and banks—such as stocks and bonds—were transparent since the
issuing corporations and institutions were required by law to submit financial reports
produced according to GAAP, which was overseen by FASB, whose activities were
supposed to be overseen by the SEC (FASB, no date,
http://en.wikipedia.org/wiki/FASB). Independent, private auditing firms, such as Arthur
Andersen Accountants, were believed to guarantee the accuracy of financial statements.
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Thus, the purported transparency of corporations’ financial standing guaranteed the
transparency of their bonds and stocks.
In an important sense, corporate level financial transparency was a critical
cornerstone of the efficient market hypothesis. Financial markets were regarded as
rational spaces delimited by generally accepted accounting standards for representing and
measuring wealth and risk. Investors were perceived as rational actors who had access to
reliable, accurate information that would enable rational market exchanges. The
marketplace was thus regarded as the most efficient space/mechanism for the distribution
of societal resources. Semi-private and private “watchdog” agencies had a vested interest,
or so it was believed, in ensuring the orderly and rational market. This logic prevailed not
only in the U.S., but also within the ever expanding scope of the global securities’
markets.
The technological and communication innovations of the late 1980s and early
1990s, coupled with the expansion and liberalization of capital and equities markets
around the globe, produced unprecedented levels of financial expansion and globalization
(Sassen, 1991). The lack of uniform international accounting standards presented
challenges for investors interested in purchasing stock in foreign companies. Rather than
create international governance structures for finance and transnational corporations
under the auspices of agencies such as the IMF or World Bank, market authorities across
industries promoted the creation of new, voluntary scales and protocols that could be
implemented.
Academics obligingly created and published new measures of corporate and
market transparency that could be applied internationally. For instance, Bushman,
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Piotroski, and Smith defined corporate transparency “as the availability of firm specific
information to those outside publicly traded firms” (2004, p. 207). They defined national
corporate transparency as “output from a multifaceted system whose components
collectively, produce, gather, validate, and disseminate information” (2004, p. 207).
Basically, the aggregate quality and quantity of firm specific information decided a
nation’s level of corporate transparency. Measures of national corporate transparency
could be used by investors seeking to make informed decisions about potential purchases
of foreign derived stocks, bonds, and derivatives.
Transparency had been transformed into a technical problem requiring only the
development of sophisticated measures that could be applied by investors worldwide.
This problem-solution frame derived in large part from the neoliberal orthodoxy that had
swept the imagination of business people and public policy makers alike.
The Neoliberal Revolution and the Crisis of Opaque Securitization
In the early 1980s free market economists of the Chicago school persuasion, such
as Milton Friedman and Alan Greenspan, claimed that rigorous accounting standards and
outside auditing together produced the fiscal transparency necessary for ensuring orderly
and efficient markets. This orthodoxy was accepted by politicians and the authorities of
international governance agencies in the U.S., U.K., Australia, and in many developing
nations (Rose, 1999). Yet, in the worlds of banking and finance the challenges to
transparency through self-regulation proliferated.
The neoliberal ideology and promise of transparent self-regulating financial
markets was troubled first by the Savings and Loan scandal of the late 1980s, which
resulted directly from de-regulation of savings and loan institutions. A series of corporate
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accounting frauds within Europe and the U.S. in the late 1990s and early twenty-first
century, including Tyco, Waste Management, WorldCom, and Enron (among others),
demonstrated the limits of the neoliberal pillars of transparency, including Generally
Accepted Accounting Principles (GAAP), outside auditing, and impartial ratings by
analysts. The sheer volume and scope of fraud in financial statements beginning in the
late 1980s called into question U.S. levels of corporate and market transparency.
Additionally, the globalized, computerized, integration of financial markets raised
concerns that financial turmoil stemming from fraud or lack of transparency in one region
would produce contagions capable of spreading around the world (see Heald, 2003).
Reform within the U.S. and U.K. aimed at ensuring financial transparency was
piecemeal because of neoliberal authorities’ resistance to regulation. The U.S. case
illustrates the challenges of enforcing transparency under neoliberal regimes of
government. The need for reform posed by the U.S. savings and loan debacle could not
be denied so the U.S. savings and loans were re-regulated. This was accomplished with
the Financial Institutions Reform, Recovery, and Enforcement Act of 1989. Later, the lax
and privatized nature of accounting oversight was reformed to combat fraud. The SEC’s
Regulation Fair Disclosure Act of 2000 and Sarbanes-Oxley, passed in the U.S. in 2001,
illustrate how more rigorous fiscal transparency requirements were pressed upon
corporations in the form of accounting rules. Regulators believed that greater
transparency in accounting and reporting standards alone would stabilize securities’
markets and thereby ensure an orderly and rational economy in the absence of more
direct regulatory oversight.
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The great irony of this period during the late 1990s and early twenty-first century
is that accounting standards and oversight of corporate financial statements were
tightened at the same time that government oversight of financial institutions (i.e., banks)
and securities markets was loosened. Neoliberal authorities such as Alan Greenspan
pushed for passage of a series of legal acts in the U.S.--including the 1999 Gramm-
Leach-Bliley Act (which overturned the Glass-Steagall Act), the 2000 Commodity
Futures Modernization Act, and the 2004 Voluntary Regulation Act--which operated
together to de-regulate commercial banks and securities markets (see Sherman, 2009).
This process of de-regulation occurred abroad, as well, as new international lobbying
groups advocated for de-regulation of international securities exchanges. For instance, the
G-30, a lobby group, argued persuasively that internationally operative derivative
markets did not require formal regulation in a context within which expanded financial
transparency was designed to substitute for direct government oversight and regulation of
operations (Das, 2006).
The financial crisis that began in the winter of 2007 dramatized the limits to
transparency of the products traded across global financial markets. The macro level
financial mess also called into question the fiscal standing and transparency of non-bank
corporations--such as General Electric--that had expanded their operations into the highly
profitable arena of financial services, and even countries--such as Greece--that had
hidden debt through derivatives contracts (see Schwartz & Dash, 2010). The sudden
opacity of credit instruments, securities, and markets made it difficult to value assets and
the fiscal impact of future liabilities (such as pension liabilities) for corporate and
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governmental entities. Nearly the entire financial infrastructure of global markets—from
bank balance sheets to national governments’ deficits—was suddenly rendered opaque.
The financial crisis was precipitated by investment vehicles that suddenly lost
transparency (see Gorton, 2009). In the U.S., private rating agencies such as Moody’s and
Standard & Poor’s had ranked derivatives created from subprime mortgages as relatively
risk-free, facilitating the global dispersion of what turned out to be highly risky assets.
After the assets began to lose value as the underlying mortgages went into default,
appalled investors discovered that their purportedly low risk investments—such as
collateralized debt obligations--were in fact complex and opaque instruments that lacked
fundamental transparency (see Morris, 2006). No one seemed to know how many of
these complex derivates had been created, nor could their ownership be accounted for.
Corporate bonds and stocks were suddenly rendered opaque because financial statements
had lost clarity, making it difficult for corporations to acquire loans and to issue bonds.
Investors began to lack confidence in the value of their stocks and stock markets began
collapsing in value in the wake of huge sell offs during the first half of 2009.
The financial havoc of the global economy in 2008 and 2009 produced calls for
more stringent and formal regulation of financial markets, especially in the U.S., which
was widely regarded as the source point for the global contagion. Rigorous accounting
standards alone had failed to produce a rational and transparent marketplace. Self-
regulation of banking and securities had enabled strategic opacity, precluding investors’
capacity to rationally assess the value of securities. The social fall out in the forms of
layoffs and bankruptcies warranted a new round of reforms. Analyst Andy Xie (2009)
argued that “the ultimate objective for financial reforms is to make leverage transparent.”
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Specific reforms outlined by the Obama Administration in 2009 stressed enforced
transparency of securities and outside regulation of banking and finance (Dennis, 2009)
Despite calls for reform, as of February 2010, little has changed, as reported by the New
York Times: “Even minor changes, like requiring banks to disclose more about the
derivatives they own, are far from certain” (Berenson, 2009). Efforts to impose more
external surveillance and regulation of banking institutions and financial markets appear
stymied.
Concluding Thoughts on Efficient Markets: The Illusion of Transparency
This section has provided a brief chronology of the efforts to legally prescribe and
enforce corporate financial transparency, banking transparency, and market transparency.
Although complete transparency in corporate financial affairs is impossible since it might
compromise competitive secrets (Hannah, 2009), regulation of corporations’ accounting
practices and financial statements has been understood as necessary for guaranteeing the
transparency of assets—securities—bought and sold in financial markets. Regulation of
commercial and investment banking practices has also been perceived as necessary for
ensuring an orderly, efficient, and transparent economy. Yet, historically, efforts to
mandate government regulation have met resistance, resulting in de-regulation.
Moreover, regulatory enforcement has typically been delegated to private and semi-
private organizations, calling into question their insistence on transparency. The financial
crisis that began in 2007 again dramatizes that many of the cornerstones of the rational
market are in fact, opaque, blind, and self-interested.
Transparency on Environmental Issues, Labor Issues,
And Supply Chain Management
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Although the project of instituting fiscal and market transparency has met with
more failure than success, it did help inspire other transparency movements.
Transparency was transformed by these movements from a technical issue designed to
lubricate efficient markets to a moral issue, the focus of which embraced environmental
safety and workplace rights (see Henriques, 2007). For instance, Henriques (2007)
describes efforts in the 1940s and 1950s to render corporations’ non-financial data
transparent using “social audits” (pp. 75-76). These audits implied companies’ everyday
labor operations should be transparent, thereby transposing the previously held position
that corporate data should ordinarily remain private. Over time, the range of issues
targeted for enhanced transparency by activists grew. Environmentalists demanded
greater transparency pertaining to corporate emissions, spurring the creation of NGOs
that press for full disclosure by reporting organizations and relevant government
agencies, such as Friends of the Earth, founded in 1969. Consumer protection activists
demanded greater transparency of product ingredients, production processes, and product
safety, as illustrated by U.S. crusader Ralph Nader’s consumer protection campaigns.
Activists demanded greater transparency pertaining to corporate dealings in, and with,
nations responsible for human rights violations, as illustrated by disinvestment campaigns
aimed at apartheid in South Africa. Labor activists demanded greater corporate
accountability in relation to the labor conditions of the evolving global assembly line.
These other movements linked transparency directly with corporate citizenship and
corporate social responsibility.
Corporate social responsibility arose as a problem in search of solutions in a
neoliberal context of privatization, financialization, and globalization (see Nadesan,
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2008). Influential neoliberal advocates such as Milton Friedman (2005) disdained the
entire project of corporate social responsibility, arguing that corporations have no
responsibility beyond those associated with financial obligations to shareholders. In this
neoliberal context that has prevailed over the last twenty years, voluntary transparency
regimes have been seen as the most viable solution to the demands of diverse
stakeholders for enhanced corporate social responsibility. For instance, Rodríguez and
Master (2010) urged that corporate social responsibility disclosure in the U.S. be
voluntary and unregulated in order to prevent the “risk of imposing American ideological
standards on foreign companies” (p. 370).
Voluntary corporate social responsibility protocols and campaigns did proliferate
over the last twenty years as corporations sought to reassure consumers and investors in
the wake of well-publicized public relations crises, such as those deriving from overseas
supply chains’ reliance on child and/or exploited labor. However, critical analyses of a
number of these campaigns reveal a variety of limitations, constraints, and contradictions
that call into question the efficacy of voluntary, transparency-based mechanisms for
ensuring corporate social responsibility. Today the two main non-fiscal corporate
transparency issues are “ethical trading” and “corporate codes of conduct” (Sadler &
Lloyd, 2009, p. 613). Each of these components will be examined separately in relation to
“voluntary” transparency and accountability protocols, beginning with corporate codes of
conduct pertaining to environmental issues before turning to human rights and ethical
trading. This analysis concurs with the conclusion forwarded by Christensen and Langer
that [voluntary] transparency is a necessary, but often inadequate mechanism, for
ensuring corporate social responsibility.
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Environmental Transparency
Activists’ demands for corporate transparency on environmental issues are
relatively recent in origin. For much of the twentieth century, few if any environmental
accountability demands were placed upon corporations. The earliest demands for
environmental accountability emphasized worker safety. For instance, early
environmental health studies began to link occupational exposures to lung cancer in the
late 1950s (Haenszel, 1956), but research did not widely explore the public’s
susceptibility to environmental hazards outside of the workplace before the 1960s. Rachel
Carson’s, Silent Spring played an important role in educating the public about the dangers
of industrial chemicals beginning in the 1960s. Scott Frickel (2006) explains that terms
such as “genetic toxicology” and “environmental mutagenesis” began circulating in
academic research after 1966 (p. 190). In 1969, the U.S. National Institute of
Environmental Health Science (NIEHS) was founded with the mission of directing basic
research on the effects of environmental factors on human health. Also, in response to
growing environmental activism, the U.S. passed the National Environmental Policy Act
(NEPA) of 1969, which initiated policy actions addressing biological and ecological
impacts of synthetic environmental chemicals (Frickel, 2006). NEPA mandated creation
of the Environmental Protection Agency (EPA) and the Council for Environmental
Quality. NEPA requires an annual report on the state of the environment and
environmental impact assessment using data collected from the EPA.
The EPA was afforded additional regulatory authority with the passage of the
1976 Toxic Substances Control Act (TSCA), which enabled the EPA to control
chemicals known to pose unreasonable risks to human or environmental health. The EPA
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today requires companies to report emissions of substances (beyond set levels) known to
be harmful to human and/or environmental health. However, the EPA has not always
disclosed reports publicly and seldom investigates the authenticity of corporate reporting.
Environmentalists and consumer activists are frustrated by their limited access to
corporate data. Corporations are defined as legal persons in many if not most western
industrialized nations and are therefore subject to privacy protections (Calland, 2007).
Consequently, corporations are typically not required to disclose their government
mandated environmental reports directly to citizens. For instance, Calland explains that
U.S. courts have consistently failed to hold private entities accountable under the U.S.
Freedom of Information, thereby limiting citizens’ direct access to environmental data.
The public’s lack of direct access to unfiltered EPA data, and the perceived
inadequacy of available data, led to greater demands for corporate transparency
pertaining to environmental risks in the last decades of the 20th century. Environmental
activists needed detailed data on pollution and product ingredients because environmental
legislation had to be pressed against considerable opposition and therefore required
substantial evidence of risk. Environmental NGOs grew in response to a widely
perceived need to monitor the environment for health risks (e.g., lead, dioxin, etc.) and to
educate the public about these risks. Environmental groups such as the Sierra Club,
founded in 1892, expanded their mission beyond conservation to include this new form of
environmental activism in the 1960s onward.
Growing international concern about information availability of environmental
data shaped a 1972 United Nations conference on “The Human Environment” (Haklay,
2003). The United Nation Environmental Programme (UNEP) emerged from this
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conference. UNEP prioritizes environmental data collection and its Global Environment
Monitoring System produced Infoterra, the International Environmental Information
System, which locates sources of environmental information through computerized
searches (Haklay, 2003). Infoterra’s mission statement is to “Provide access to
authoritative information on environmental matters and promote information exchange
among all countries worldwide” (http://www.unep.org/infoterra/). Infoterra is essentially
a network, as explained on its website that operates through a “system of government-
designated national focal points,” which are usually located in the agency or ministry
charged with environmental protection. The current 177 focal points provide national
environmental information products and services “including environmental
bibliographies; directories of sources of information; query-response services;
environmental awareness leaflets; and access to Internet services.
(http://www.unep.org/infoterra/overview.htm).
Infoterra is premised on the assumption that government is responsible for
making environmental information accessible to citizens. However, governments vary
considerably in their reporting requirements and their mechanisms for enforcing
compliance with environmental standards. Lax requirements and/or enforcement
compromise the quality of information available, even when systems such as Infoterra are
available to citizens.
It may be surprising to U.S. citizens to learn that their nation suffers from what
environmentalists perceive as lax requirements. In August of 2007 the U.S. Government
Accounting Office (GAO) published a report comparing the lax U.S. regulatory
framework for chemicals with a recently enacted European framework, REACH. The
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GAO report, titled, “Chemical Regulation: Comparison of U.S. and Recently Enacted
European Union Approaches to Protect against the Risks of Toxic Chemicals” (GAO-07-
825), explains that under the current regulatory system in the U.S., companies do not
have to develop information on the health or environmental impact of chemicals unless
specifically required by EPA ruling. Consequently, the EPA relies on voluntary programs
for gathering information from chemical companies in order to evaluate and regulate new
chemicals under the provisions of TSCA. The GAO report found TSCA inadequate in
comparison with REACH’s reporting requirements. Moreover, as encapsulated in the
GAO executive summary:
TSCA places the burden of proof on EPA to demonstrate that a chemical
poses a risk to human health or the environment before EPA can regulate
its production or use, while REACH generally places a burden on
chemical companies to ensure that chemicals do not pose such risks or that
measures are identified for handling chemicals safely.
The GAO report’s recommendation that the burden of risk be shifted to the chemical
companies was not adopted by the George W. Bush Administration. Government
reluctance to scan rigorously for, and regulate, environmental risks is not restricted to the
U.S.
Believing that public pressure for environmental regulation follows naturally from
the disclosure of environmental risks, activists have sought to establish international
guidelines for ensuring that environmental data are collected and made transparent to
stakeholders. Principle 10 of the Rio Declaration adopted at the U.N. Conference on
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23
Environment and Development in 1992 includes a statement on the public’s right to
information on the environment
At the national level, each individual shall have appropriate access to
information concerning the environment that is held by public authorities,
including information on hazardous materials and activities in their
communities, and the opportunity to participate in decision-making
processes. (cited in European Environment Agency
http://www.eea.europa.eu/publications/92-9167-020-0/page010.html)
Chapter 40 of Agenda 21, adopted at UNCED, also calls for attention to the quality of
information made available and the ease with which users can find appropriate and
accurate information. The United Nation’s Economic Commission for Europe established
guidelines for environmental transparency in Sofia, Bulgaria in 1995, titled, “Guidelines
on Access to Environmental Information and Public Participation in Environmental
Decision-making.” Information technology specialists have responded to these calls for
greater public access to government stores of environmental information by developing
specialized, publicly accessible environmental information systems, such as Infoterra (see
Haklay, 2003).
In 1997 the Global Reporting Initiative (GRI) was established by the U.N.
Environment Programme and the Coalition for Environmentally Responsible Economies
(CERES) (Sadler and Lloyd, 2009). This initiative attempted to set a series of voluntary
environmental standards for corporations. GRI's mission is to “create conditions for the
transparent and reliable exchange of sustainability information through the development
and continuous improvement of the GRI Sustainability Reporting Framework”
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24
(http://www.globalreporting.org/AboutGRI/). The first full version of GRI’s reporting
framework was released in 2000. Today GRI collaborates with the UNEP and the United
Nations Global Compact, the latter of which will be discussed in the next section. GRI
membership is voluntary and members help recreate reporting guidelines annually. GRI
reporting is seen as enhancing a corporation’s transparency and social responsibility, but
the GRI’s accuracy is contingent upon the integrity of corporate reporting.
Critics are often skeptical of voluntary corporate reporting of environmental
information. Environmental critics are particularly skeptical of the use of voluntary
reporting practices in developing nations that lack adequate infrastructures for regulating
and monitoring corporate environmental emissions and extractions. Research and
postings by the NGO Global Witness dramatize the weaknesses of environmental
accountability standards in many developing countries. Global Witness’ mission is to
publicize incidences of environmental and human rights corruption:
Global Witness exposes the corrupt exploitation of natural resources and
international trade systems, to drive campaigns that end impunity, resource-linked
conflict, and human rights and environmental abuses. Global Witness was the first
organisation that sought to break the links between the exploitation of natural
resources, and conflict and corruption; and the results of our investigations and
our powerful lobbying skills have been not only a catalyst, but a main driver
behind most of the major international mechanisms and initiatives that have been
established to address these issues; including the Kimberley Process and the
Extractive Industries Transparency Initiative (EITI).
(http://www.globalwitness.org/pages/en/about_us.html)
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25
Global Witness’ strategy of “transparency” can pose public relations nightmares for
named western corporations, sometimes resulting in reforms. Yet, the success of
organizations such as Global Witness depends upon publics’ readiness to response to
“outings” with demands for accountability.
Strategic and anticipatory public relations by corporations likely to face
environmental scrutiny may erode public activism when these corporations are linked to
environmental concerns. For instance, Dow Chemical Company pursued a well-financed
public relations campaign in 2008 published in National Geographical magazine. The
campaign is organized around the idea of Dow “caring for man,” as illustrated by an ad in
the magazine’s November 2008 issue. Pages 3 and 4 of the issue feature a Dow chemical
ad stating, “Caring for man is caring for the future of mankind. And that is what Dow
Chemical Company is all about.” Ironically, Dow Chemical does not have the cleanest
environmental record, even in the U.S. where its operations are regulated. For instance,
the environmental site, Scorecard, records severe environmental hazards stemming from
the release of mercury and carbon tetrachloride at Dow’s Freeport Facility in Freeport
Texas in 2002 (http://www.scorecard.org/env-
releases/facility.tcl?tri_id=77541THDWCBUILD#major_chemical_releases). Dow’s
strategic public relations campaigns in National Geographic may work to erode the
public’s willingness to sanction Dow, despite evidence of a poor environmental record
available on environmental web pages.
In sum, the movement to organize environmental activism around transparency
may be limited by a number of constraints. First, transparency is limited because
corporations are not subject to freedom of information guidelines. Public access to
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26
environmental information is mediated by governments. Governments vary in the degree
and quality of their environmental reporting requirements and the degree to which they
make environmental information available to publics. Complex information data bases
must be created and maintained to make environmental information publicly accessible.
The accuracy and utility of these information data bases depend upon willing
governments capable of monitoring emissions and extractions in both developed and
developing nations given the transnational operations of most large contemporary
corporations. Although NGOs have played an important role in trying to make
environmental data accessible to stakeholders, they rely on publics’ receptivity to data
and publics’ willingness to agitate for stricter environmental legislation. The space of
public environmental activism is a battleground within which corporate public relations
vies with environmental activist messages.
Ethical Trading and Human Rights
Demands for corporate social responsibility and transparency extend well beyond
environmental and sustainability issues. Labor abuses, corruption, and product safety are
major issues of concern. Although most western, industrialized nations have regulatory
agencies that monitor corporate behavior in these arenas, no mandatory, supra-regulatory
frameworks or institutions exist to govern and monitor transnational corporate behavior.
This section addresses efforts to render transparent corporate behavior as it pertains to
human rights, ethical trading, and labor concerns.
Perhaps the closest approximation to an international governance institution for
labor and human rights concerns is the United Nation’s International Labour
Organization’s (ILO), founded after World War I. The ILO has attempted to create
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27
international labor standards applicable to ratifying states. In 1998, the International
Labour Conference adopted the Declaration of Fundamental Principles and Rights at
Work, outlining fundamental rights surrounding freedom of association, collective
bargaining, discrimination, and forced and child labor. The ILO’s supervisory bodies—
the Committee of Experts on the Application of Conventions and Recommendations and
the Conference Committee on the Application of Standards--examine codified labor
standards of ILO member states and can initiate complaint procedures against states that
fail to comply with ratified conventions. Yet in practice, these bodies lack the resources
and executive power to adequately monitor and enforce labor conventions in ILO
member states.
The ILO’s efforts to redress the worst reported instances of abusive labor
practices are often stymied by lax or non-existent national regulatory agencies, especially
in the developing world. For instance, the ILO has been relatively powerless to halt child
labor, particularly when that labor occurs in domestic contexts that entirely lack
transparency to government investigators. In 1992 the ILO founded the International
Programme on the Elimination of Child Labour, which operates in nations world wide.
Unfortunately, the ILO’s has failed to halt the most egregious cases of labor abuses
because the organization lacks the resources and authority to enforce compliance and
must rely on the capabilities and commitments of host nations. Even the U.S. and the
U.K. have been slow to respond to ILO criticism of labor practices and relations (e.g., see
Hepple, 2002).
Surprisingly, workers in wealthy nations often lack adequate protections of labor
standards. A new survey found that low-wage workers in the U.S. are routinely denied
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overtime pay and are often paid wages beneath federal minimum standards (Greenhouse,
2009). As reported in The New York Times the study “Broken Laws, Unprotected
Workers” found in its survey of 4,387 workers in a variety of low-wage industries
numerous instances of wage violations, averaging 15 percent in lost pay. The study found
that over one quarter of workers had been paid less than minimum wages the week before
being surveyed and an additional 76 percent of workers were not paid overtime properly.
The U.S. Labor Department’s reticence over the last 8 years to enforce worker rights and
workplace protections suggests that even nations with well established institutions in
place (aimed at ensuring transparency and compliance) often fail to enforce standards.
Failures across the globe to reign in labor abuses prompted an important UN
resolution outlining corporate social responsibilities. On August 13, 2003, after a four
year consultative and drafting process, U.N. Sub-Commission on the Promotion of
Human Rights adopted resolution 2003/16 (the Norms on the Responsibilities of
Transnational Corporations and Other Business Enterprises with Regard to Human
Rights) (Calland, 2007). The resolution calls upon corporations to respect human rights,
to eliminate all forms of discriminatory treatment and to avoid profiting from war crimes
and crimes against humanity, torture, etc. Specifically, the resolution identifies the
following rights for workers:
Transnational corporations and other business enterprises shall not use
forced or compulsory labour. . . . shall respect the rights of children to be
protected from economic exploitation. . . .provide a safe and healthy
working environment. . . .provide workers with remuneration that ensures
an adequate standard of living for them and their families. . . .ensure
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29
freedom of association and effective recognition of the right to collective
bargaining. . . .act in accordance with fair business, marketing and
advertising practices and shall take all necessary steps to ensure the safety
and quality of the goods and services they provide. . . .
(available http://www1.umn.edu/humanrts/links/norms-Aug2003.html)
This resolution clarify that business enterprises have human rights obligations to workers,
communities, and customers but fails to mention transparency or any right to access
information (Calland, 2007, p. 223). Perhaps most critically, this resolution has no
vehicles for enforcement.
Advisory and voluntary proclamations and charters proliferate as the calls for
international guarantees on worker rights increase in volume. Perhaps the most expansive
voluntary framework for monitoring and gauging corporate social responsibility is the
United Nation’s Global Compact, which was launched in 2000. The compact is described
on its webpage as follows:
The UN Global Compact is a strategic policy initiative for businesses that
are committed to aligning their operations and strategies with ten
universally accepted principles in the areas of human rights, labour,
environment and anti-corruption. By doing so, business, as a primary
agent driving globalization, can help ensure that markets, commerce,
technology and finance advance in ways that benefit economies and
societies everywhere. (http://www.unglobalcompact.org/AboutTheGC/)
Membership today includes over 5,200 corporations and stakeholders from over 130
countries. The compact aims to mainstream its ten principles in business activities
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30
throughout the world and to promote actions in support of U.N. goals such as the
Millennium Development Goals. The ten principles encompass human rights, labor, the
environment, and anti-corruption (see
http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html).
Adherence to these principles is voluntary and the accuracy of reporting is not verified.
Critics charge that the United Nations Global Compact serves more effectively as
a public relations tool than it serves to monitor and enforce corporate social responsibility
and transparency. Moreover, critics charge that publicity surrounding corporations’
participation in the Global Compact can serve to erode support for the creation of a true
regulatory body with the executive power to directly monitor and enforce labor,
environmental, human rights, and corruption abuses. The NGO Corporate Watch has
been particularly critical of the voluntary and implicitly anti-regulatory nature of the
Global Compact (Bruno & Karliner, 2000).
Academic public relations’ analysts are often critical of voluntary protocols and
mechanisms. DeTienne and Lewis’ (2005) analysis of Nike’s campaign around overseas
production and Livesey and Kearins’ (2002) analysis of the “transparency” of
sustainability reports issued by the Body Shop and Royal Dutch/Shell point to the limits
and tensions of voluntary, information-based approaches to corporate social
responsibility. Thus, Christensen and Langer (2009) concluded that although
transparency is essential for trust and accountability in the area of corporate social
responsibility, extant institutionalizations for transparency can produce or enable closure
over openness. David Sadler and Stuart Lloyd (2009) also express strong criticism of the
voluntary and anti-regulatory nature of transparency programs such as the Global
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31
Compact, contending that their promises may undermine legal reforms that would
monitor and enforce responsible conduct. For instance, they note that programs such as
Global Compact are not, in fact, transparent since the names of participating businesses
are not available to the public and the compact has no mechanism for verifying
compliance. They cite a report by Christian Aid urging that voluntary compliance be
replace with “mandatory international regulation of companies’ activities” coupled with
clear mechanisms for enabling domestic redress for individuals adversely affected by
corporate conduct overseas (cited in Sadler & Lloyd, 2009, p. 620).
The global nature of supply and production chains has complicated corporations’
willingness and ability to comply with voluntary and mandated labor, environmental, and
safety requirements. Ciliberti, Pontrandolfo, and Scozzi (2008) found that in order for
corporate social responsibility to occur, corporations had to ensure that all of their supply
chain complied with socially responsible guidelines. They outline two strategies
companies can use to ensure corporate social responsibility. The first approach involves
setting clear standards for suppliers and then monitoring compliance. This approach
requires that supply chains be fully transparent to the contracting company. The second
approach is described as “capacity building,” which works to build the suppliers’
capacities for addressing CSR issues. However, a prerequisite for this latter approach is
the willingness and commitment to building long term close relationships with suppliers.
(p. 1580). Significantly, both of these approaches presume suppliers’ willingness to
participate in corporate social responsibility codes, even when compliance is more costly,
and presume the transparency of their operations to the contracting business. The
researchers’ case study found many obstacles to the enactment of corporate social
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32
responsibility including cost concerns, corruption, and lack of concern for environmental
and poor labor rights protections and oversight in developing countries.
The lack of transparency in supply chains is in many cases deliberate by suppliers
and corporations alike. Corporations that outsource aspects of their production may not
be interested in their suppliers’ labor conditions so long as suppliers’ costs are low.
Suppliers may outsource their production in order to make some level of profit when
margins are tight. Consequently, corporations may be misled about the true conditions
under which their supplies are actually being produced. These types of conditions create
obvious transparency issues that can allow egregious labor conditions and can
compromise product safety.
In 2006, the U.S. Global Labor Strategies organization released a report
denouncing U.S. corporations for opposing legislation in China aimed at enhancing
worker rights in export-oriented production chains (Barboza, 2006). Tim Costello, a
representative of Global Labor Strategies, was reported as stating: “You have big
corporations opposing basically modest reforms. . . This flies in the face of the idea that
globalization and corporations will raise standards around the world” (cited in Barboza).
This conflict between labor advocates and U.S. corporate interests illustrates corporate
unwillingness to allow regulatory agencies actual power over labor conditions in
“developing” countries, particularly when changes to the status quo involve requirements
that corporations recognize labor unions.
Although some corporations resist efforts to mandate transparency, others have
taken steps to facilitate the transparency of their operations in order to fend off potential
charges of labor abuses. One of these latter types of organizations is Liz Claiborne. This
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33
corporation participates in the Fair Labor Association’s (FLA) monitoring program, as
revealed on their corporate webpage. Factoring monitoring by the FLA involves
unannounced visits by independent and accredited monitors. The FLA also insists
workers be made aware of their rights by requiring participating organizations to post the
FLA’s Standard of Engagements. The FLA claims it networks with local civil rights
groups to ensure workers are adequately educated about their rights
(http://www.lizclaiborneinc.com/web/guest/workersrightsoverview).
Summaries of findings are posted on the FLA webpage http://www.fairlabor.org/.
Organizations such as the FLA and the Fair Trade Organization (http://www.wfto.com/),
which focuses on fair compensation and treatment of suppliers, serve as important
transparency vehicles for organizations committed to upholding standards of fair
treatment for workers and suppliers. Yet, these organizations remain “voluntary” and
have no power to enforce conditions.
In sum, voluntary compacts may be seen as strategic public relations for home
countries and may be perceived as a tactical strategy for evading establishment of more
rigorous labor protections and requirements. Real transparency in corporations’ overseas
operations is lacking. Although corporations have a vested interest in maintaining
transparency in supply chains in order to protect product quality, they may
simultaneously have vested interests in obscuring the labor conditions of their supply
chains. The evidence suggests that corporations often prefer voluntary labor and
environmental regimes over mandatory ones that enforce transparency and compliance.
Yet, even mandatory regimes fail to enforce legislated conditions when laissez-faire
attitudes erode regulators’ commitments and vigilance. Of course, some corporations take
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34
social responsibility seriously, but to date few institutions exist that can assist
stakeholders in sorting out the truly committed from those intent on misleading
stakeholders through misrepresentations and selective reporting.
Conclusion: Transparency and the “Free Market”
The argument organizing this chapter is that the role of transparency in promoting
corporate social responsibility hinges upon undergirding logics, definitions, and material
deployments. Transparency’s capture by neoliberal discourses and logics of government
is evidenced by the “voluntary” nature of most national and international transparency
regimes. Neoliberal theories and models such as the efficient market hypothesis presume
that markets are populated by rational actors who set prices and pursue purchases based
on available knowledge. Financial transparency through formalized accounting standards
alone is believed to ensure optimal, efficient, and secure market operations. This market
based model of transparency drives international efforts to establish measures of national
(aggregate) corporate transparency. In effect, transparency is an essential problem-
solution frame under neoliberal economic governance. However, by emphasizing the
standardization and availability of financial data, this neoliberal model of corporate and
market transparency de-emphasizes the claims to information access made by other types
of stakeholders (e.g., environmentalists and labor activist). This type of selective bias
against social and environmental stakeholders is aptly illustrated by operations of
neoliberal governance institutions such as the World Trade Organization, which relies on
political appointees, concerns itself solely with fiscal and trade concerns, and operates in
secrecy.
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35
Neoliberalism frames corporate social responsibility as optional and therefore
favors establishment of non-binding, voluntary transparency regimes to satisfy the
information demands of other types of stakeholders. Voluntary transparency regimes for
labor and environmental data are represented as equivalent in efficaciousness to
government-mandated regulatory regimes. However, voluntary regimes rarely require
authentication of corporate self-reported data. Moreover, voluntary regimes typically lack
executive power to enforce compliance or penalize offenders, even among members.
Voluntary transparency regimes therefore serve a legitimizing function that may, in
practice, deflect activist or worker criticisms by inoculating publics against negative
accounts of corporate behavior. Finally, two decades of financial fraud demonstrate that
voluntarily enacted and/or self-policing transparency protocols are prone to create
opportunities for deliberate distortion and corruption.
The capture of transparency by neoliberal logics of government has produced
resistance as other corporate stakeholders, including environmentalists and labor
activists, have sought to redefine the intent and operations of transparency protocols.
Resistance to the dominant interpretive frame is heterogeneous in character, but resistant
practices share a common belief that corporations have responsibilities beyond
maximization of shareholder value. This belief is central to social-welfare logics of
government that seek to develop policies and protocols that operate to maximize the well-
being of the population at large. Social-welfare logics of government tend to view
transparency as an important mechanism for reigning in the abuses of corporate power.
However, social-welfare goals can be subverted by voluntary transparency protocols,
such as the Global Compact, because they lack force and are easily stripped of the power
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36
to enforce contracted corporate accountability to labor and environmental standards of
good governance. Therefore an expansive notion of good corporate governance that
includes social-welfare outcomes must mandate transparency, authenticate corporate
data, and have the executive power to enforce compliance.
In essence transparency can regarded as a necessary, but insufficient mechanism,
for promoting corporate social responsibility. The very meaning and efficaciousness of
transparency derive from the system of governance informing operations and
institutionalizations. The laissez-faire approach to environmental and labor transparency
promoted in neoliberal logics of government can be contrasted with the stricter and
mandatory transparency regimes associated with the “social-welfare” government logics
illustrated by the European Union’s approach to chemical regulation (i.e., REACH).
Comparative analysis reveals the core value hierarchy driving competing transparency
regimes. The laissez-faire neoliberal regime prioritizes corporate autonomy and privacy
while the stricter, mandatory regimes also prioritize environmental safety and labor
rights, thereby shifting accountability directly to corporate entities, which must
demonstrate compliance. Neoliberal transparency regimes, such as the ones guiding U.S.
policy and law for the last thirty years, collapse and constrain responsibility while social-
welfare logics of government are more likely to mandate transparency, for the purposes
of regulation, across a wide array of social-economic spaces in the name of both social
and economic security.
This chapter concludes by pointing to new beginnings. More research is needed to
study and develop protocols for socially responsible corporate behavior that include
authentication and enforcement mechanisms. Researchers need to articulate those
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37
dimensions of corporate conduct that must be rendered transparent, both to governments
and to outside stakeholders (e.g., supply chains). This investigation demands detailed and
critical examination of the strengths and limitations of current voluntary and mandatory
regimes in relation desired social outcomes, including fair labor practices and
environmental accountability. Establishing transparency protocols over supply chains
will, no doubt, arise as a critical concern. However, the success of efforts to render intra-
and-inter-organizational relations transparent hinges upon establishment of national and
inter-national mandatory monitoring and compliance regimes. Furthermore, successful
efforts will entail institutionalization of mechanisms for disseminating compliance
records. Dissemination of data pertaining to the strengths and limitations of existing
protocols and compliance records will facilitate activist efforts to identify and justify the
types of political reforms necessary for mandating and enforcing greater transparency.
International governance agencies such as the WTO must be held accountable to, and
play a role in implementing, these political reform processes. Transparency research is
inherently political in intent and effect in that it acknowledges limitations in existing
formulations of corporate social responsibility and outlines reform agendas.
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