Comparison of Parental Leave Developments in Different Welfare States

Abstract

This dissertation is about parental leave developments in an archetypical liberal (the UK), conservative (Germany) and a social democratic (Iceland) welfare states. It aims to track back the changes in policy legislation in each country, understand the link between welfare-state regimes and family models, and indicate implications in the HR field.

The piece of work starts with a literature review of the major debates about parental leave, family policy and welfare states. Theory-based propositions are formulated. A cross-country comparison uses a case study research strategy and qualitative documentary analysis. The results’ chapter is divided into two parts. The first part gives a chronological overview of parental leave policies in the three countries. The findings are subject to convergence-divergence criteria to test prepositions. Part two focuses on the outcomes of major policy reforms and analyses leave trends. The last sections develop a business report and conclude with a discussion of the literature contributions.

The major findings suggest a converging course on parental leave policies. The reform outcomes, however, reveal mixed parents’ responses on the ground. A gap is found between targeted and actual take-up of parental leave and employment behaviour. A Parental Leave Scheme is designed for international HR practitioners to respond to emerging developments and address implementation challenges.

Glossary

Maternity leave. Only available to mothers, maternity leave is a period of leave before, during and after a birth and/or an adoption.

Paternity leave. Only available to fathers, paternity leave is a period of leave after a birth and/or an adoption. It is often available after the period of maternity leave expires.

Parental leave. A period of leave for both parents and/or other main carers. It can be claimed around the time of childbirth or following the maternity and paternity leave.

Childcare leave. A period of leave that is usually available in addition to parental leave and before a child reaches schooling age.

Introduction

Employment legislation typically entitles working parents with young children to compensated and job-protected leave from work for the purposes of caregiving.  The nation-state uses parental leave policies (PLP) as an effective tool to moderate high priority areas such as gender equality, fertility rates, skill supply, and labour participation. However, this paper finds that financial and perception barriers could discourage parental engagement with child-related leave measures and comprise government policy aims. The gender gap by take-up of parental leave, job re-entry, and family-friendly policies in organisations remains strong despite socio-cultural shifts in traditional gender roles. This makes issues related to parental leave a relevant Human Resources (HR) topic.

Literature review found omissions in the existing literature and theories. Questions about whether the dual-carer family model predominates in different countries and over time, remain unaddressed. There are two major debates in the field. Convergence supporters argue that the parental leave structure is getting unified on a global scale. On the other side, critics say that family policy is diverging across nations. Traditionally, the cross-cultural divergence by social policy has been accounted to a variance in the welfare-state type. These theoretical predispositions need to be tested. Therefore, this dissertation aims to fill the literature gap and conduct a comparison of the PLPs in three archetypical welfare states: the UK, Germany and Iceland. The framework of PLP before and after major policy reforms is compared to explore how policies have developed over recent years. The determined legislative tone in PLPs is contrasted with the parents’ responses in practice. The implications for the HR field are discussed afterwards. This dissertation concludes with evidence-based recommendations for HR Managers on how to improve organisational practices on parental leave and close identified gaps.

Literature Review

This literature review first highlights the benefits and challenges in the use of parental leave for relevant stakeholders. Then, the shift in attitudes towards the division of labour and in the general composition of PLP frameworks is discussed. A departure from the breadwinner model is contrasted with the cross-national varieties of PLPs and family models. A theoretical framework of the welfare-state typology, and the convergence-divergence debate on parental leave are introduced last.

Problem definition

Despite widespread benefits for different actors, multiple barriers challenge the parent’s use of parental leave.

Child-related leave has far-reaching advantages for working parents, children and institutions. Evidence suggest that it could be used to increase birth rates, labour participation, equality of opportunity and standards of working and living (EU Publications, 2010; 2016; CIPD, 2013; 2016a; Belle, 2016; Auth and Martinek, 2017). In recent years, family time and mental health received greater attention. Furthermore, medical and psychological studies focus on the health of birthmothers, and the breastfeeding and nursery care of infants (Belle, 2016; Moss, 2007). They further note the children’s positive development owing to father-child bonding and parental guidance during the formative years (O’Brien, 2009; Belle, 2016). Moreover, parental leave benefits and re-entry at work have the potential to increase organisational productivity and profitability through returns on investments, enhanced wellbeing and high commitment (Sánchez-Vidal, et al., 2012; Belle, 2016; Mickel and Dallimore 2009). The women returnees create value for the economy and institutions by fostering growth and alleviating skill shortages (Tomlinson, et al., 2009; Estévez-Abe, 2005; CIPD, 2016a; Belle, 2016).

However, opportunity costs could hinder parents’ decisions to take time off to care for dependent children.

Compared to men, women generally receive higher compensation and longer parental leave. As a result, the partner that receives lower income and higher parental benefits might be promoted to stay at home and look after children and household (Belle, 2016; CIPD, 2016a; Kaufman, 2008; Warren, 2015). Mothers more often than fathers trade off their career and exit the labour market (Belle, 2016; Fleetwood, 2007; Ray, et al., 2010; Fusulier, 2008; Eydal, et al., 2015; Özbilgin, et al., 2011; O’Brien, 2009). In the meantime, the cost and availability of day-care services influence the parent’s “right not to care” and the decision to return to work (Leitner, 2017, p.111). The prolonged economic inactivity and gender segregation could impact the post-natal reintegration, career progression opportunities and access to flexible time arrangements. To elaborate, women often return to part-time and low-paid work following childbirth (Ciccia and Verloo, 2012; Tomlinson, et al., 2009; Estévez-Abe, 2005; Belle, 2016; Ray, et al., 2010; Fleetwood, 2007). Furthermore, masculinity bias in the workplace might limit the male take-up of parental leave and the benefits of fatherhood (Kaufman, 2018; O’Brien, 2009; Belle, 2016; Gatrell, et al., 2013; Jančaitytė, 2006). The inability to balance work and family, especially by employees with high family-role importance could cause job and life dissatisfaction, stress, absenteeism and turnover intentions (Mickel and Dallimore 2009; Wolfram and Gratton, 2014; Staines, 1980).

In brief, child-related could work towards multiple social, economic, demographic, and organisational ends. However, the engagement might be less a viable option for fathers and the negative effects on the maternal employment might be substantial. Meanwhile, supportive organisational cultures and mechanisms for work-life reconciliation might be lacking. This means that a lot of discouraging forces and job uncertainties prevail around a crucial life moment for working parents.

Provisions

The two main avenues through which child-related leave is made available to recipients are, national and organisational provisions. The latter is typically complementary to or in the place of the former.

The nation-state is the main regulator of employment relations and a shaper of social policy (Baird, 2011; Kamerman and Moss, 2011). In this respect, governments pass employment legislation and set frameworks on parental leave (Baird, 2011; Baird and O’Brien, 2015; White, 2017; Ray, et al., 2010; Ciccia and Verloo, 2012). Thus, leave is usually received in the form of compulsory or “right to” entitlements (Moss and Deven, 2015, p.142; Fusulier, 2008). The extended financial support eases the income drop and allows parents to stay at home (Moss, 2007; Blum, et al., 2017). Besides, job-protection mechanisms preserve the employment status of parents and their right to return to work (Ciccia and Verloo, 2012). Due to the states’ interests of meeting various socio-economic goals, the coordination of PLPs typically stays high on the political agenda (Fusulier, 2008; Leitner, 2017).

Meanwhile, organisations need to comply with regulatory requirements (Fusulier, 2008; Baird, 2011; Baird and O’Brien, 2015; White, 2017). However, organisations could have own PLPs that go beyond the statutory minimum to attract and retain working parents. These “extra-legal family-friendly policies” could substitute limited national legislation (Fusulier, 2008, p.66; CIPD, 2016a). Although highly varied, measures could encompass flexible working and travel arrangements, childcare services, supplementary payments and extended leave periods (Fusulier, 2008; CIPD, 2016a; OECD, 2016a).

In sum, the state, organisations and parents are interconnected. Organisations have an important mediating function between passed policies and end beneficiaries.

Family model dynamics

Studies argue that societal shifts in patriarchal gender roles and emerging norms on gender equality transformed the directory of family policy.

(Post-) Industrial family model

The traditional division of labour focused on the caregiving role of women and the economic role of men.

The breadwinner-housewife dichotomy stipulated that women should stay at home or work fractionally to take care of dependents while men are the main earners (Moss and Deven, 2006; Wall, 2007; Estévez-Abe, 2005; Ray, et al., 2010; Fusulier, 2008; Eydal, et al., 2015; Kaufman, 2008; Özbilgin, et al., 2011). The structural power relations defined childrearing as a “women’s issue” (Fleetwood, 2007, p.353). This notion rested on widely held believes that motherhood consumes a large part of the women’s lives and it is incongruous with work. Meanwhile, maternal employment was also associated with negative effects on the child’s development and family life (Ray, et al., 2010; Ciccia and Verloo, 2012; Staines, 1980). As a result, the female’s womb and potential matrimonial responsibilities were stigmatised, especially by recruitment and job re-entry. Women were subject to a “child penalty” that impacted their career and promotional prospects (Belle, 2016, p.11; Gatrell, et al., 2013; Fleetwood, 2007; Özbilgin, et al., 2011; EU Publications, 2016). On the other side, breadwinner pressure in the workplace disregarded parenthood and caregiving as “men’s issues” (Eydal, et al., 2015, p.169; O’Brien, 2009; Raiden and Räisänen, 2013; Ford and Collinson, 2011; Gatrell, et al., 2013; Kaufman, 2018).

According to Wall (2007, p.31), the state apparatus generally responded to “mother home-centred” trends trough extended social care to mothers and children. Hence, the period was characterised with relatively long and compensated periods of maternity leave which served to protect the wellbeing of mothers and infants.

In other words, the socio-cultural norms in the post-industrial era made the access to parental leave gendered. According to family policy theorists, working and stay-at-home moms, and “feminine” dads were put in a disadvantaged position.

Contemporary family model

Since 1990, great social and political transformations have taken place in Europe. A change in the popular mind-set about gender shifted attention towards the experiences of benefit-receivers and the capability to integrate work and life spheres.

In the 90s, left-wing parties, social movements and “state feminism surged (Eydal, et al., 2015, p.168). Moreover, the national and international arena set objectives for female emancipation and economic participation (Baird and O’Brien, 2015; White, 2017; Eydal, et al., 2015; Ray, et al., 2010; O’Brien, 2009). The female employment and returnees following childbirth increased (OECD, 2016b).

At the turn of the 20^th century, issues around fatherhood started to attract the attention of political and academic circles. A higher number of paternity leave requests was recorded. Gradually a wave of “father inclusiveness” occurred (O’Brien, 2009, p.198; Eydal, et al., 2015). International Organisations (IOs) such as the ILO and OECD endorsed the division of caring responsibilities, and of paid and job-protected paternity and maternity leave (White, 2017; Ciccia and Verloo, 2012; Baird, 2011). The EU passed a Directive on Parental Leave in 1996 that obliged member states to provide minimum leave rights to both parents (EU Publications, 1996). In addition, principles for self-realisation and individual choices about how the time between work, home and leisure were to be divided came to the forefront (Jančaitytė, 2006; Gatrell, et al., 2013; Özbilgin, et al., 2011; O’Brien, 2009; Raiden and Räisänen, 2013).

In other words, the traditional household type gave more room for “dual-career/dual-earner family model” (O’Brien, 2009, p.193; CIPD, 2016b; Belle, 2016; Leitner, 2017). Based on authors’ arguments, more emphasis was put on the take-up, work-family reconciliation, and flexible work arrangements (O’Brien, 2009; Fusulier, 2008; Özbilgin, et al., 2011; Ford and Collinson, 2011; Raiden and Räisänen, 2013; Gatrell, et al., 2013). These factors influenced the contemporary design of PLPs in affluent countries. Policies started to combine different elements such as extended and better-paid paternity leave, shorter periods of maternity and flexibility in use (Wall, 2007; Fusulier, 2008; OECD, 2017).

In sum, the shift in gender norms signalled the global decline of the breadwinner model and a rise of dual-carer model. Family policy literature stipulates that contemporary PLPs aim to elevate the position of working parents.

Varieties of PLPs

Another body of text, however, speaks about historical varieties of parental leave across countries.

The PLPs in developed countries have constantly changed since their initial introduction (Moss and Deven, 2015; DICE, 2015). A great variation in the main policy details (eligibility, duration, percentage of wage replacement and flexibility) of current versions could be found. Differences between men and women do exist on a national and cross-national level (Ray, et al., 2010; Moss and Deven, 2015; OECD, 2017; Blum, et al., 2017; Wall, 2007; Ciccia and Verloo, 2012; Bártová and Emery, 2018).

Based on an empirical study of 21 high-income countries, Ray, et al. (2010) write that statutory child-related is available to at least one of the parents nowadays. A recent 2017 OECD report suggests, however, that paid parental leave is entirely absent in 12 out of 35 member countries (OECD, 2017). The US and Australia are in this number despite recently introduced unpaid parental leave in Australia and extended financial support in a few American states (Baird and O’Brien, 2015; Moss and Deven, 2015; OECD, 2017).

The total length of parental leave varies between one week and two years in OECD countries. Countries on the high end of the spectrum include Slovakia, Estonia, Finland and Hungary However, most policies have a length between three months and one year. On average, maternity leave is 18 weeks and the paternity leave – eight weeks (OECD, 2017). Comparative analyses spot a rise in the duration and the prevalence of paid paternity leave (Baird and O’Brien, 2015; DICE, 2015; Blum, et al., 2017).

Most of the OECD countries cover above 50% of the parents’ average earnings. There is full or almost full compensation in a few predominantly Central and Eastern European countries. However, the long intervals of available leave are the expense of compensation in some countries. The salary replacements are below 30% after a cut-off period in the UK, Ireland, Slovakia and Finland (OECD, 2017).

In terms of flexibility, data show that the options to transfer leave between partners and to decide when and for how long to take leave before and after birth in the recent years have risen. More policies encourage the employer’s extension of flexible time practices. Nevertheless, flexibility options, especially for fathers are still limited in many countries (Blum, et al., 2017; Moss and Deven, 2015).

To sum up, an almost universal trend is observed towards an expansion rather than a contraction of parental leave benefits. However, a global convergence of PLPs has not yet been achieved based on literature interpretations. This means the PLPs in different countries and consequently, the family models that they sustain and are based upon could vary.

Theoretical framework

Comparative capitalist literature makes attempts to better understand the “antecedents of variation in social policy” (Ray, et al., 2010, p.196). Scholars argue that capitalist systems could explain the similarities and differences between families of nations (Wall, 2007; Schröder, 2013; Esping-Andersen, 1990; 1999; Hall and Soskice, 2001; Tomlinson, 2011).

In his notable work, Esping-Andersen (1990) groups countries into welfare-state regimes. The indicators for comparison are the degree of state intervention in private matters, expenditure on welfare, de-commodification of social policies, class stratification and extension of social rights. Political, historical and socio-cultural legacies are theorised to shape the cross-cultural variation (Esping-Andersen, 1990; 1999; Tomlinson, 2011; Schröder, 2013; Hall and Soskice, 2001). Esping-Andersen’s latter works, address earlier critiques about the lack of gender element in his welfare-state framework. Indeed, the author combines family and welfare state in 1999. According to Esping-Andersen (1999, p.73), the enriched typology is useful to cluster countries with comparable meeting points, including the “state, market, and households”. The state could be non-interventionist or participate in the work and family spheres (Esping-Andersen, 1990; 1999). Its functions in relation to parental leave are to ease or hinder the participation of mothers and fathers in work and parenting (Fusulier, 2008; Wall, 2017). Therefore, the PLP elements would encourage the parental employment or the caregiving (Estévez-Abe, 2005; Ray, et al., 2010; Ciccia and Verloo, 2012). Following this line of reasoning, Esping-Andersen (1990; 1999) defines three types of welfare states: Liberal, Conservative, and Social Democratic.

Anglo-Saxon countries (e.g. The UK, Canada and Australia) are liberal state representatives (Esping-Andersen, 1990; 1999). Based on the gendered welfare-state typology, the social care for children in Liberal welfare states is regarded as a private task of households. Parental leave arrangements are a subject to individual choices rather than state regulation in line with self-determination arguments. The state is minimalistic or intervenes only to fix market failures. The labour market is unprotected and fluid to allow easy entry and replacement at work (Esping-Andersen, 1990; Jančaitytė, 2006; Eydal, et al., 2015; Fusulier, 2008; Hall and Soskice, 2001). In general, the extended social rights would be limited and segregate low-income families. The lack of public-funded childcare services would prevent mothers with lower social status from labour participation (Jančaitytė, 2006). This means that the length of maternity leave would be moderate to support stay-at-home moms but low-paid to reduce government expenditure. The available social benefits would be means-tested. In contrast, the paternity leave would be non-existent due to a lack of income support and job protection for “wage-earners” during parental leave (Esping-Anderson, 1999, p.17; Jančaitytė, 2006). Considering, the clear work-life separation, flexible parental leave to support a reconciliation is not assumed. Therefore, the PLPs in liberal welfare states are expected to be market-led, gendered and stratifying. In other words, Anglophone countries would not preserve the employment of male and female parental leavers. However, the policies would be implicitly famialialistic because they would support the caregiving role of mothers compared to fathers (Jančaitytė, 2006; Esping-Anderson, 1999; Leitner, 2017).

France, Germany and Austria are typical continental countries, part of the conservative welfare-state world. Strong unionisation results in job-protecting mechanisms for the economically active (Esping-Andersen, 1990; Jančaitytė, 2006; Schröder, 2013; Hall and Soskice, 2001). The state has a complementary function to emphasise the right to care for women and the right to work for breadwinners. It cover the expense of home childrearing to encourage stay-at-home moms up to a child’s later age (Jančaitytė, 2006; Esping-Anderson, 1999; Leitner, 2017). In this vein, the PLPs are expected to be mother-centered. Thus, a generous length of maternity leave and moderate compensation for the full period is theorised. In contrast, paternity leave is expected to be short and low-paid to push fathers to return early to full-time employment. Only extended limited flexibility to enable parents to coordinate work and family life are anticipated. Hence, a family policy that is explicitly familialising and sustaining the traditional breadwinner model is assumed in continental countries (Esping-Andersen, 1999; Jančaitytė, 2006; Leitner, 2017; Estévez-Abe, 2005).

Scandinavian countries such as Sweden, Finland and Denmark are the archetypical examples of social democracies. This welfare-state regime rejects social inequalities such as gender discrimination, unpaid childcare and child poverty. Therefore, parenthood tends to be politicised and the state interferes in family and gender relations. The social benefits provided are usually tax-funded and universalistic. The labour market is inclusive and gender egalitarian (Esping-Andersen, 1990; 1999; Jančaitytė, 2006; Eydal and Ólafsson, 2008). High salary replacements would aim to replace the loss of income during the temporary drop out of the labour market; the moderate length of child-related would encourage an earlier re-entry at work. In this respect, both mothers and fathers are expected to receive equal “cash rights” and “time rights” (Leitner, 2017, p.111; Estévez-Abe, 2005; Ray, et al., 2010). The parents’ right to full-time work would be further sustained by substituting forms of care such as childcare services. In this vein, the flexible take-up and time measures are anticipated to be high to reconcile work and family responsibilities (Jančaitytė, 2006; Leitner, 2017). In other words, the PLPs in social democracies would be de-familialising due to their de-gendered and de-commodified nature. PLPs in support of the dual-career model are speculated (Leitner, 2017; Esping-Anderson, 1999; Eydal and Ólafsson, 2008; Schröder, 2013).

Some scholars (Tomlinson, 2011; Esping-Anderson; 1999; Leitner, 2017; Jančaitytė, 2006; White, 2017; Estévez-Abe, 2005) tend to agree that social democratic and liberal countries usually stay on both sides of the spectrum in terms of de-familialism, while continental countries are in the middle. This means that the aforementioned family model is expected to vary among welfare-state regimes, where either the breadwinner or dual-earner model is reinforced.

Table 1. PLPs variation in welfare states

Welfare   state	Family model	Main caregiver	Length		Payment		Flexibility
			m	f	m	f
Liberal	Market-oriented	f	/c	MDT	/c	Low	/c
Conservative	Familialising	f	Short	Long	Low	MDT	Low
Social Democratic	De-familialising	m/f	MDT	MDT	High	High	High

^c unexisting

Evaluation criteria

Eligibility

The main caregiving function is given to man (m); women (f) or man and women (m/f), depending on the gender that has the highest number of parental leave rights.

The scale of O’Brien (2009) is borrowed to differentiate levels of length and payment, and the scale of Eydal, et al. (2015) – levels of flexibility by parental leave. Length longer than 14 but shorten than 52 days, and salary replacement higher than 50% but lower than 80% are considered moderate.

Length (in days)

Short	X = or < 14
Moderate (MDT)	14 < X < 52
Long	X = or > 52

Payment (% salary replacement)^a

Low	X = or < 50%
Moderate	50% < X < 80%
High	X = or > 80%

^aTheweekly fixed rates compared to the average national salary will also be grouped low, moderate and high

Flexibility

Eydal, et al. (2015) defines “flexibility” as the freedom to choose when to take leave (after the statutory period expires) and how (on once, intervals, full-time or part-time).

Low	No/minor “when” and “how”
Moderate	Either “when” or “how”; Partial “when” and “how”
High	Both “when” and “how”

To sum up, the welfare-state typology of Esping-Andersen is a good theoretical framework to study the diversity of parental leave schemes. It interconnects family policy features and liberal, conservative and social democratic countries. The family-state link needs to be explored further.

The convergence-divergence debate

The two major opposing sides in comparative capitalist literature are the convergence and the divergence debates.

The divergence school of thought stipulates that the cross-national variance might effectively hinder a convergence of social policy. National affairs reflect the country context. As a result, the countries’ policies will be in line with the predominant capitalist regime and cultural norms. These factors have implications for domestic industrial relations, training provisions, levels of employment protection (Estévez-Abe, 2005; Ray, et al., 2010; Esping-Andersen, 1990; 1999; Hall and Soskice, 2001; Schöder, 2013). Hence, the social policy of countries belonging to different welfare-state regimes will diverge from one another. Keeping this in mind, the domestic affairs would not move far from the archetypical welfare-state type under globalisation and other international pressures. This process is associated with path-dependence (Moss and Deven, 2006; Hall and Soskice, 2001; Esping-Andersen, 1990; 1999). In other words, the welfare-state system serves as a major building block with a nearly irreversible course.

In contrast, the advocates of convergence argue that people, labour and capital cross boundaries and unify the international landscape (Scullion, et al., 2007; Pudelko, 2005). Pudelko (2005) and White (2017) note cross-national learning of best practices and converging institutional practices, independently from the cross-country variations. This entails that countries are headed towards relatively internationalised practices (Pudelko, 2005; Scullion, et al., 2007). A crucial part of the process is the search of “one best way” (Pudelko, 2005, p.2068; Boxall and Macky, 2009; Fusulier, 2011). This means that the countries’ affairs could move away from their archetypical welfare-state core over time and under various contextual factors (Pudelko, 2005; White, 2017; Bártová and Emery, 2018).

The literature review suggests that the major convergence-divergence debate in relation to parental leave is built around a few major themes. Proponents of divergence (e.g. Moss and Deven, 2006; Esping-Andersen, 1999) argue that amendments to the original PLPs speak about the path-dependence rather than a completely reversed direction. On the other side, critics examine whether the Nordic state is not depleted and even becoming neo-liberal in line with right-wing political agendas (Eydal, et al., 2015). Similarly, another circle of authors (e.g. Baird and O’Brien, 2015; Baird, 2011; White, 2017; Ray, et al., 2010) examine whether Anglophone countries are taking a Nordic direction under liberal party governments and guidelines of IOs. In this vein, the third group of convergence supporters (Erler, et al., 2011; Pudelko, 2005; Fusulier, 2011; Leither, 2017; White, 2017) suggest that the features of PLPs in different European countries are becoming more homogeneous mostly related to EU legislation.

Overall, cross-country variations in social policy continue to spark convergence/divergence questions among scholars. A validated convergence would contradict divergence arguments and vice versa.

Methodology

The internal research objective is to generate explanatory knowledge about the PLP reforms and outcomes, and to discuss HR-related implications in three welfare states: the UK, Germany and Iceland. The external objective is to generate evidence-based recommendations for HR practitioners. The relevance and reliability of the Esping-Andersen’ typology need to be verified. A comparative case study strategy and qualitative documentary analysis are chosen. The method to test theoretical propositions using the formulated evaluation criteria is explained.

Research questions

Central research question: How did the PLPs of the UK, Germany and Iceland develop and what the implications for HR Managers are?

Sub-questions:

1. What major PLP changes took place in:
   1. the UK?
   2. Germany?
   3. Iceland?
2. What outcomes did the reforms bring in regards to:
   1. take-up of parental leave?
   2. maternal/paternal employment?
3. What are the implications of parental leave trends for HR Managers?

Research philosophy and approach

Considering the research questions, a historical analysis of the PLPs in each country is conducted first. Next, the parents’ responses towards policy developments and the implications for HR domain are concluded.

In this respect, the analysis begins with an objectivist position. The ontological assumption is that the reality is objective, and parents and organisations uphold to PLP legislation. However, a constructivist position assumes in the second part that the use of parental leave is a negotiated process among social actors (Bryman and Bell, 2011). Lastly, a “functionalist” paradigm delivers problem-solving recommendations to HR Managers using best practices from the PLPs in the three countries (Bryman and Bell, 2011, p.24; Burrell and Morgan, 1979).

A “post-positivist” epistemology derives a sound knowledge (Howe and Eisenhart, 1990). Theoretical propositions are tested before the findings to be deemed acceptable. Thus, the research is looked at from a positivist point of view and falls on the deductive side (Bryman and Bell, 2011; Hussey and Hussey, 1997; Saunders, et al., 2009). However, an interpretative perspective applies in the second part. Indeed, supplementary quantitative and qualitative data from documentation is used (Howe and Eisenhart, 1990; Eisenhardt and Graebner, 2007; Yin, 2006). Some common themes are analysed more openly resulting in non-theorised conclusions. Therefore, the research philosophy incorporates some inductive elements as well (Bryman and Bell, 2011; Hussey and Hussey, 1997; Saunders, et al., 2009; Howe and Eisenhart, 1990). In brief, the research epistemology could be characterised as “theory-laden” “nonpositivism” (Howe and Eisenhart, 1990, p.8). A deductive approach generates and tests some data, and an inductive approach – analyses another and draws conclusions (Eisenhardt and Graebner, 2007).

Case Study Research Method

The PLP developments in different countries need to be explored intensively and theoretical propositions to be tested. The case study research method is best suitable to study a small but “strategic sample” of “real-life” policies (Verschuren, et al., 2010, p.178; Yin, 2008, p.18). In this paper, a case study is defined as an empirical inquiry that tries to “illuminate” (Yin, 2009, pp.17-18) the context of policy change, the results of developments and their implications.

Sampling Strategy

A “maximum variation sampling” is used (Palys, 2008, p.697; Yin, 2009; Bryman and Bell, 2011; Kamerman and Moss, 2011). The PLPs in the UK, Germany and Iceland were selected because of the expected maximum variation of family policy models in the three welfare states. The UK is a liberal, Germany – conservative and Iceland – social democratic welfare state of the Nordic family of nations (Eydal and Ólafsson, 2008; Esping-Anderson, 1990; 1999). The theoretical propositions are that the expressed family model of the British PLP is market-oriented, of the German PLP – familialising, and of the Icelandic PLP – de-familialising. Persisting welfare-state features of policies are claimed.

Furthermore, the identified high take-up of paternity leave in Iceland compared to the low take-up in the UK, and the delayed female re-entry at full-time work in Germany make these countries’ PLPs, interesting cases for comparison.

Case study: Advantages and Disadvantages

A distinctive feature of the case study strategy is the ability to generate a comprehensive insight of the PLPs in distinctive countries. Like experiments, each PLP is a unique unit of inquiry and treated in isolation. Additionally, this research method makes the analysis more delineated. For example, it focuses on non-manipulative variables such as historical events in employment legislation (Bryman and Bell, 2011; Yin, 2009; Eisenhardt and Graebner, 2007). Compared to surveys or experiments, however, case studies are more flexible and allow more room for ongoing research and alterations (Verschuren, et al., 2010; Yin, 2009). Yin (2009) additionally comments that case studies are a sound choice to go back and forth between theory, literature and findings and test theory-based propositions. Thus, the case study method fits the research objectives (Yin, 2009; Bryman and Bell, 2011; Eisenhardt and Graebner, 2007). Moreover, the concluded “general picture” (Verschuren, et al., 2010, p.184; Yin, 2009) could be replicated to other welfare states.

Conversely, the case study research method has some inherent weaknesses. To elaborate, case studies unusually focus on small units of analysis. At the expense of depth, the study might lack necessary breadth (Bryman and Bell, 2011; Yin, 2009; Verschuren, et al., 2010). Bryman and Bell (2011) find that case studies particularise better than generalise. Besides, in contrast to surveys and interviews, the absence of a “holistic” approach might prevent more “abstract” “measures or data” (Yin, 2009, p.50). Therefore, contrary to the arguments made, the individual cases might not be able to replicate if the analysis is not rigorous enough (Bryman and Bell, 2011; Verschuren, et al., 2010; Shah and Corley, 2006).

Analytic techniques

The PLPs in the UK, Germany and Iceland are the three main units of analysis. A multiple-case compared to a single case design fits the cross-country comparison (Yin, 2009; Eisenhardt and Graebner, 2007; Bryman and Bell, 2011; Verschuren, et al., 2010). Moreover, an embedded case study analysis touches upon separate sub-units (policy reforms, take-up and employment) (sub-question 1 and 2). A comparative case study variance is applied. The research results are described first and then compared. The uncovered resemblances and differences generate content to test propositions and discuss implications (Yin, 2009).

A documentary qualitative analysis sorts out the most relevant and reoccurring information. Secondary quantitative and qualitative data is grouped and labelled using a thematic analysis technique (Bryman and Bell, 2011). An iterative approach revisits the pieces of documentation, theoretical propositions, data, and interpretations (Yin, 2009; Bryman and Bell, 2011; Verschuren, et al., 2010).

Past archives and “historical analysis” help to investigate the chronological evolution of policies (Bryman and Bell, 2011). The nature of pre- and post-reform policy developments and reform outcomes are compared to better understand the complex phenomenon. By tracing back events, the contemporary direction and trends by child-related are better interpreted

Content Analysis

Method: The legislative changes in each country are presented since the introduction of PLPs and until 2017 which is the last fiscal year for which data is available. Country notes and comparative policy reports serve as background information. Reforms are considered the breakthroughs in the history of both maternity and paternity rights. Attention is paid to the pace, level of complexity and scope of policy change (Blum, et al., 2017; OECD, 2017; Belle, 2016; Kamerman and Moss, 2011).

Secondary statistical and sample data from official online archives and national Bureaus of Statistic is used in the second part of the analysis. It overviews the effect of policy reforms on the female/male take-up percentages, and the average beneficiary periods in the three countries. Similarly, the variation in the employment behaviours (part-time and full-time employment), and in the timing for job re-entry are noted next. Parental employment is measured as the proportion of employed men and women between 15 and 64 years old with children aged 0 to 6. Excel software develops infographics to illustrate extracted secondary data.

The implications and recommendations to HR Determents for improved parental leave practices are drawn upon major conclusions (sub-question 3). The supporting information at that stage are taken from research databases, government documents and CIPD reports.

Testing propositions

The findings rest on tested theoretical propositions. The formulated theoretical propositions are tested using the formulated evaluation criteria (Yin, 2009; Verschuren, et al., 2010). The goal is to confirm whether the family policy model of the PLPs in the studied countries converged or diverged since set major policy reforms. The results verify or falsify the relevance of the Esping-Andersen’s gendered typology in the case of parental leave.

Method: Keeping the welfare-state type constant, the variation of the family policy model pre- and post-reforms is evaluated by tracking the change of policy elements (main carer, length, payment and flexibility) (Table 1). Next, a “rival expiations” tactic sorts out withstanding, converging or diverging patterns (Yin, 2009, pp.139-140). Due to the mutually exclusive nature of these dependent variables, the verification of one rules out the others. Comparison tables illustrate the findings. The contrasting differences test the theoretical expectations (Yin, 2009).

Documentary analysis: Advantages and Disadvantages

One of the biggest strengths of documentary analysis is that research documentation and archive sources are accessed quickly and easily at the library or via the web. Furthermore, the texts offer “stable” information to which to refer (Yin, 2009, p.102; Bryman and Bell, 2011). The large quantity and broad coverage of the available materials also enable sorting and selection. Additionally, the official records from the archives of reputable institutions such as the OECD are authoritative, precise and detailed. Academic research bases offer top-ranked and peer-reviewed books and journals (Bryman and Bell, 2011; Verschuren, et al., 2010; Yin, 2009).

However, a critical review is necessary to prevent bias from changing the course of research (Yin, 2009; Verschuren, et al., 2010; Eisenhardt and Graebner, 2007). Indeed, Bryman and Bell (2011) and Verschuren, et al. (2010) warn against an author’s bias. To elaborate, the authors of the original work often wrote it for a different purpose and audience. This means that some information might be less suitable if it is not adjusted to fit the research objectives. Furthermore, the “documentary reality” could diverge from the social reality (Bryman and Bell, 2011, p.559). Therefore, policy legislation should not be mistaken with the parental leave realities and experiences on the ground (Fusulier, 2008; O’Brien, 2009).

Data quality

Validity and Reliability

Owing to secondary data collection, an active involvement with human subjects is absent. This means that first-hand opinions and observation in organisations are not gathered when there are uncertainties or omissions in the analysis (Bryman and Bell, 2011; Verschuren, et al., 2010; Yin, 2009). Hence, the research and research questions are limited only to data that is ready-made and available. However, secondary sample data from interviews and surveys would aim to address some of the concerns for the internal validity (Verschuren, et al., 2010; Eisenhardt and Graebner, 2007). The historical analysis and the “pattern matching” analytic technique would also aim to add to the internal validity (Yin, 2009, p.136). Moreover, conclusions about contemporary parental leave dynamics (Z) are inferred from the analysed past events/outcomes (X) and the tested direction of PLPs (Y) (Yin, 2009).

To reiterate, the small research sample also raised concerns about generalisability. However, the triangulation of quantitative and qualitative data enhances the external validity (Verschuren, et al., 2010; Bryman and Bell, 2011; Yin, 2009; Shah and Corley, 2006). The multiple-case study achieves “literal replication” (Yin, 2009, p.54) because of the anticipated similar PLP direction in countries from the same welfare-state regime. In this vein, the case study findings are analytically generalisable and could apply to other countries with PLP transformations. Next, a rigorous quantitative analysis also generalises (Shah and Corley, 2006; Bryman and Bell, 2011). The usefulness, “transferability”, “credibility” and “theoretical contribution” of the research add to the rigidity (Shah and Corley, 2006, p.1829; Verschuren, et al., 2010). First, a useful account of cross-country PLP developments and relevant HR implications is given. The findings contribute to the Esping-Andersen’s gendered typology, debates on divergence-convergence, and family models. The main practical contributions fall within the domain of organisational policies on parental leave. Further, “close adherence” to raw and accurate data such as years, numbers and names generates credibility and avoids author’s bias (Eisenhardt and Graebner, 2007, p.25; Yin, 2009). Last, the case study research is reliable and transferable because the research, sampling and analytic strategies are described in detail and are easy to reproduce (Verschuren, et al., 2010; Yin, 2009).

Case-study results

Historical Overview

The following section outlines the evolution of the PLPs in the UK, Germany and Iceland. It shows that amendments radically transformed policy content.

The British PLP

Despite being introduced relatively late, the British PLP progressed at a fast pace and incorporated ample rights for both parents since the 90s.

The first job-protected laws for mothers in the UK were some of the latest introduced in Europe (Moss and Deven, 2006; Kaufman, 2018). In 1976, a statutory maternity leave of 40 weeks was granted to British women at 90% salary replacement for the first six weeks and at a flat rate for another 12 weeks. Fathers did not receive any leave entitlements (DICE, 2015; Finch, 2003; 2008). According to Finch (2003; 2008), the British family policy closely aligned with the philosophy of T.H. Marshall for civil rights and good citizenship.

The Employment Protection Act remained untouched between 1979 and 1990 during Thatcher’s cabinet. In the meantime, the British Government opted out of the 1996 Parental Leave Directive that was first put on the agenda of the Maastricht Treaty in 1989. The period was marked by a strong emphasis on market deregulation and self-determination (Baird and O’Brien, 2015).

Some major policy developments took place since the election of the Labour Government in 1997. The eradication of children and mothers’ poverty was prioritised (Moss and Deven, 2006; Finch, 2008; Baird and O’Brien, 2015). One of the main policy goals was for parents “to spend more time at home, as well as support their children financially” (O’Brien, 2009, p.198). Moreover, the UK became a signatory of the EU Directive in 1999 as part of government’s efforts for international synchronisation. However, it met only the minimum requirement for 13 weeks of unpaid parental leave per parent (Moss and Deven, 2006; DICE, 2015; Finch, 2003; 2008).

The largest wave of change took place in 2003. Pressures from IOs for child prosperity and a gender-balanced labour market had a strong impact on the British family policy (White, 2017; Finch, 2003; 2008; Moss and Deven, 2006; Tomlinson, et al., 2009). A new Bill protected the rights of paid parental leave and shared household responsibilities. Fathers received two weeks at a flat rate. In comparison, maternity leave was extended to one year (52 weeks). However, only 26 up from 18 weeks were compensated: the first six weeks at 90% and then remaining at a weekly flat rate of £100. The paid period was called an Ordinary Parental Leave (OPL) and the unpaid – an Additional Parental Leave (APL). Low earners received 90% wage replacement for the OPL period (Finch, 2003; 2008; Kamerman and Moss, 2011; Moss and Deven, 2006; Blum et al, 2017). The child-related leave have been taken up once, or in blocks of minimum of one and maximum of four weeks a year (Finch, 2008; O’Brien and Koslowski, 2017; DICE, 2015). Parental leavers were not allowed to work part-time (Moss and Deven, 2006).

In 2005, a game-changing development for fathers was introduced: The Shared Parental Leave (SPL). The provision allowed the transfer of unused maternity leave (maximum three months) after the first six weeks and before the child’s first year. The transfer was conditional upon the return of mothers to work before the fathers’ take-up (Moss and Deven, 2006; Finch, 2008). The sharable period increased to six months in 2009 (DICE, 2015; Kaufman, 2018; Baird and O’Brien, 2015).

The 2010 Equality Act prohibited gender discrimination. A proposed shortened maternity leave and non-transferable paternity leave of four weeks were disapproved by the elected Conservative Party despite austerity measures. In 2013, the unpaid period per parent up to the child’s fifth year increased to 18 weeks in line with the revised EU Directive (Baird and O’Brien, 2015). The Government launched “Keep In Touch” (KIT) days and British employers were obliged to respond to parents’ requests for flexible working up to the child’s 18^th birthday (O’Brien and Koslowski, 2017, p.414).

In 2015, the whole period of maternity leave became sharable (except for the first two weeks). The current version of PLP is comprised of 52 weeks of which 33 weeks are paid at a flat rate of £140.98 (about €160) and six at 90% (O’Brien and Koslowski, 2017; Kaufman, 2018). In the case of the SPL, a flat rate or 90% salary replacement (whichever is lower) is paid up to the 37^th week. Since 2017, the British Government initiated 30 hours of free childcare services and a tax-free return of £2 for every £8 invested in childcare (O’Brien and Koslowski, 2017).

In brief, the original British legislation resulted in gender-imbalanced parental leave, however, in recent years the gendered approach seems to be weakening. By the end of 2013, both the possibility of sharing between partners and the period of unpaid leave per parent have been extended. The first state involvements in subsidised childcare (albeit marginal) and extended flexible time arrangements were also noted.

The German PLP

The German family policy had different historical swings. However, it radically changed in 2007 and 2015.

The initial German PLP focused on the social protection of the mother’s and child’s life. Germany was the first European country to prohibit work around the time of childbirth in 1878. In the following decades, the length of maternity leave became 14 weeks (Erler, 2011; DICE, 2015; Leitner, et al., 2008).

During the occupation, a 1986 Law on Parental Leave (Bundeserziehungsgeldgesetz) in West Germany granted eight months to married parents. The employed and unemployed received child-raising cash (Erziehungsgeld). The initial six months were paid at a flat rate and the remaining period was income-tested. Homecare was associated with positive benefits for the children’s development (DICE, 2015; Erler, 2011; Leitner, 2017; Huebener, et al., 2016). Care services for children up to three and full-time places for children above three years old were limited. In the meantime, multiple childcare centres opened in East Germany that allowed career interruptions for a maximum of one year (Erler, 2011; Leitner, et al., 2008). After the reunification, the Western subsumed the Eastern PLP (Erler, 2011). Between 1992 and 1993, the Christian Democratic Party extended the total length from 18 to 24 months. The first two months were exclusive to women. Parents were protected from dismissal during the period of leave and had the right to an additional 12-month unpaid leave up the child’s third year (DICE, 2015; Erler, 2011; Huebener, et al., 2016).

The Social Democratic-Green Party suggested a reform in 2000 to increase fathers’ engagement with parental leave. As a result, parents could have worked 30 hours part-time per week. Next, the childcare allowance was fixed at €300 for 24 months and at €450 for 12 months. The latter was named the “Budget option” (Kluve and Marcus, 2013; Erler, 2011; Auth and Martinek, 2017; DICE, 2015). The policy aimed to divide work and caregiving responsibilities equally (Leitner, et al., 2008).

The German PLP underwent a “paradigmatic shift” in 2007 (Moss, 2007, p.60). Falling birth rates were a major moving force for a reform of the family policy (O’Brien, 2009; Erler, 2011). In 2005, the elected Christian Democratic-Social Democratic Government criticised that old laws were failing to meet families’ needs (Auth and Martinek, 2017; Erler, 2011). In 2007, the cash-based payments were replaced by an income-tested system named Elterngeld (parental money) to reduce the “opportunity cost” of take-up (Erler, 2011, p.8; Kluve and Marcus, 2013). The salary replacement was 67% of annual earnings or 100% of income below the threshold. The maximum ceiling was €1800. Unemployed and ineligible persons received a fixed rate of €300. Noticeably, the total length was curtailed from one to two years. However, each parent received individual 12 months and two additional months were added (12+2) if fathers took a minimum of two months leave. The period was splittable the first three years of the child’s life except for the first eight weeks of maternity leave (DICE, 2015; Huebener, et al., 2016; Baer, 2008; Erler, 2011; Reimer, et al., 2017; Kluve and Marcus, 2013; Auth and Martinek, 2017). In 2013, plans for more childcare places, especially in former West Germany were put on the government agenda. The Christian Democratic Party expressed a policy concern due to the perceived discouraged homecare of children (Erler, 2011).

The so-called Elterngeld Plus version came out in 2015 which allowed parents to work with reduced time for 24 months. Compared to the 2001 framework, parents received half of the statutory payment on top of part-time earnings from the newly-introduced policy. The partners’ bonus doubles if parents simultaneously pursued part-time parental leave (24+4 months). Parents could choose between Elterngeld, Elterngeld Plus, or a combination of both (Leitner, 2017; Auth and Martinek, 2017; Huebener, et al., 2016; Reimer, et al., 2017). The PLP’s main purpose was to make parenthood more attractive and congruent with work responsibilities, considering Germany’s fast-ageing population (Kluve and Marcus, 2013; Erler, 2011).

To sum up, various political turns and agendas made the German policy varied during and after the West-/East-German situation.