How does globalization affect women - Research Paper Example

How does globliztion ffect women [Nme of the [Nme of the techer] Introduction While women re obviously diverse group, compred to men they re overwhelmingly disdvntged economiclly. This is shown strkly nd redundntly in U.N. dt. The question here, however, is whether globliztion improves women's sitution or mkes them worse. The nswer, of course, depends on which women we re tlking bout nd wht is being mesured. This pper ddresses the question from two perspectives. First, it drws on the recent work of economists to provide n overview of globliztion, then it tkes close look t trends nd counter-trends regrding women's prticiption in the globl economy. Even the most robust economic model, however, cnnot convey the subjective experience of economiclly mrginlized women. The second prt of this section concludes, ccordingly, with series of brief nrrtives or "snpshots." 1. The Free Flow of Cpitl nd Free Trde "Globliztion" refers to the free flow of cpitl nd the removl of trde brriers between sttes, s well s to the ccompnying culturl trnsformtions nd exchnges. The reltionship between the globliztion of cpitl nd mrkets, on the one hnd, nd the globliztion of culture, on the other, vries depending on the context.) For present purposes, two generliztions usully hold: (1) the former drives the ltter, tht is, the globliztion of mrkets nd cpitl fuels the globliztion of culture including resistnce to this globliztion; nd (2) both forms of globliztion re in constnt flux nd re, therefore, unpredictble. Globliztion is the "constnt revolutionizing of production" nd the "endless disturbnce of ll socil conditions."(Joffe, 1999) It is "everlsting uncertinty." (Joffe, 1999) Everything "fixed nd frozen" is "swept wy" nd "ll tht is solid melts into ir." (Joffe, 1999) s these quottions from The Communist Mnifesto, written 150 yers go, indicte, globliztion is nothing new. In the 1320s, Englnd, then developing country, defulted on lons to the Itlin city stte of Geno. (Kristof, Wytt, 1999) For most of Western history, cpitl hs flowed freely. The end of the Cold Wr nd developments in finnce nd technology combined to qulittively chnge the gme during the pst ten yers. The filure of Soviet communism becme the triumph of free mrket democrcy, s formerly closed mrkets opened nd cpitl poured in t previously unimginble rte. In ddition, the election of President Clinton in 1992 put free mrket enthusist in the White House. The world hs never seen nything like the flow of cpitl during the eight yers of his presidency. Globliztion hs drmticlly incresed world income, but it hs lso incresed the polriztion between the "hves" nd "hve-nots." This is prt of longer term trend, beginning fter World Wr II. In other words, mrkets re soring to new highs nd plunging to new lows, bouncing from one to the other fster--nd less predictbly--thn ever before, nd drgging others with them, sometimes with ruinous consequences. s free trde hs been extended to smller countries with less regultory infrstructure nd experience with cpitl, this unprecedented cpitl flow often hs wound up in incompetent nd unsupervised hnds. In 1996, for exmple, the Thi Minister of Justice ccused his fellow cbinet members of tking $90 million in bribes for bnk licenses. In ddition to widespred corruption nd cronyism, wild investment schemes nd shky economy contributed to the 1997 collpse of the Thi bht. But there were contributing fctors outside of Thilnd nd beyond Thi control. Finncil institutions plyed criticl role through unrestrined specultion nd hedge funds. The G7, the seven mjor industrilized sttes, remined oblivious to the looming disster--despite Jpn's wrning--nd filed to ddress the emergency when it becme impossible to ignore. 2. Culture It is not just dollrs tht re flowing freely round the world, but Western culture --constitutionlism nd Coc Col, free mrket ideology nd Bruce Willis. Every stte hs hd tste of relentless, technology-enhnced consumerism, free mrket democrcy promoted by dvertising so cretive, so well done, tht no culture is impenetrble. It seeps in everywhere. In even the poorest sttes, welthy elite import Western luxuries. Sttes tht try to close themselves off re quickly condemned for denying free speech nd free expression, those bsic civil rights nd freedoms bcked by the United Sttes, the United Ntions, nd the full weight of the mrket. s Fredric Jmeson explined over fifteen yers go, mss production of goods hs been superseded by the mss production of imge, from mericn sop opers to McDonld's, proliferting in endless itertions round the world. Cultures re open s never before to question, chllenge, nd influence from outside. No wlls cn keep out stellites nd cyberspce. Western culture is ubiquitous, but it is not lwys welcome. There is growing bcklsh--or rther, growing number of distinct, independent bcklshes--ginst Western culture, not only from Muslim fundmentlists but lso from those who question the U.S. model of lissez fire cpitlism, which "rescues Connecticut hedge funds but scrifices Indonesin children." Friedmn explins globliztion by juxtposing the Lexus-- new, fst, Western, expensive cr nd the emblem of consumer culture driven by chep gs--nd the olive tree, symbol of ncient loylties, rootedness, trdition, nd sustennce. His thesis is tht globliztion is inevitble becuse everyone wnts Lexus, or t lest the more mundne comforts of Western ffluence, such s electricity, running wter, toilets, nd refrigertors. ccording to Friedmn, the United Sttes is the primry beneficiry of these new mrkets nd should ccordingly ssume the responsibilities tht ccompny privilege. Some olive trees will hve to be cut down to mke rods, he recognizes, but perhps some cn be spred. Some people, he notes, will not be ble to "keep up" with the pce set by high-tech, knowledge-bsed consumer society. These "turtles," s he ptronizingly clls them, must be ssured sfety net. The Lexus nd the olive tree is reductionist but compelling metphor for neoliberlism. The Lexus nd the olive tree metphor is prticulrly pt here becuse so mny developing countries lck rods. Even where there re rods, women re often prohibited from driving on them, either through lw or custom. Even where there re no such prohibitions, few women in the world cn fford gs. Only token number, most of whom re in the United Sttes, could fford--or would wnt-- Lexus. The Lexus is coded Western "mle," while the olive tree is coded Third World "femle." The Intercontinentl Hotel offers more inclusive metphor for the impct of globliztion on culture in generl nd, more specificlly, on the women in those cultures. Sski Sssen describes the emergence of new interntionl society, comprised of those who direct the money flows described bove, nd women's role in tht society. lthough mny of its ctivities re virtul, this society hs n ctul physicl presence throughout the world, prticulrly in the cities tht serve s finncil cpitls. If cpitl flows to new region, representtives from this interntionl society must follow to inspect the site nd to meet the locl plyers. This cn produce dditionl investment in the region through tourism, including sex tourism. s Sssen explins, these trvelers require veritble rmy of interntionl support workers to mke them comfortble. This rmy is directed nd orgnized by multintionl hotel chins, which feminist economist Grci Clrk refers to collectively s the Intercontinentl Hotel. Its dvertisements re in every weekly U.S. mgzine. They promise the trveler ll the Western menities long with n uthentic experience of the region between meetings. Women, usully from the developing world, serve vitl role: By crefully replicting the culture nd infrstructure of the Intercontinentl Hotel worldwide, these support workers mke it possible for the globe-trotting executive to believe himself culturlly neutrl technocrt. Would-be elite cndidtes cnnot, in fct, decontextulize themselves, but must rely on the skill nd invisibility of these uncknowledged others to ccomplish it for them. Cleners, personl secretries, security gurds, repirers, nd deliverers meticulously remove nd bsorb ll trces of the ctul physicl nd culturl loction, which cn men solving quite different concrete problems depending on locl circumstnces. (nsley, 1998) rundhti Roy provides n unforgettble exmple in her Booker Prize-winning novel, The God of Smll Things. She describes the purchse of the History House in Kerl, Indi by n interntionl hotel chin. The History House ws built by British colonil officer who hd gone ntive nd, rumor hd it, freely indulged his pedophilic ppetites. The structure ws clled the History House by locls becuse of ll tht hd hppened there, from the molesttion of locl boys to the vicious murder of communist untouchble by the locl police. Locl culture, Roy shows us, is complex nd subjective construction, rich nd ncient, overlid with the postcolonil struggles of those still subject to brutl cste system, with vrious fctions grsping for control of the Indin government nd seeking to control the locl economy. In the 1990s, however, ll of this troublesome history is cuterized, replced by picturesque, snitized version of the Intercontinentl Hotel. Does the loss of history mtter Roy shows how robbing people of their history--especilly history of pin nd oppression--deprives them of ny possibility of coming to terms with it. s Jose lvrez hs pointed out, however, much of the lw tht fcilittes globliztion mkes the question impossible. In the NFT greement, for exmple, the chpter on investment does not distinguish between the sle of culturl icon nd tht of ny other commodity. 4. Women in the Globl Economy . n Overview: Sttistics s Noeleen Heyzer, Director of UNIFEM, observed t the Beijing Conference on Women in 1995: It is not cceptble for women to constitute 70 percent of the world's 1.3 billion bsolute poor. Nor is it cceptble for women to work two-thirds of the world's working hours, but ern only one-tenth of the world's income nd own less thn one-tenth of the world's property.1 s Hrvrd economist mrty Sen hs demonstrted, the dt both oversttes nd understtes women's economic subordintion. First, such sttistics understte women's economic subordintion becuse they omit the women presumbly born who never pper in the sttistics. Sen summrizes the reserch showing substntil biologicl component fvoring women. If women re treted s well s men--tht is, if they receive proportionte mount of food, helth cre, nd other resources--there should be more women thn men. Using the sub-Shrn fricn rtio (1.02) of femles to mles, Sen estimtes the number of "missing women" t "more thn 100 million." (Sen, 1990) These re the bndoned infnt girls in Chin, the brides who die in kitchen fires in Indi, the bby girls in fric who re not tken to the clinic to be treted for dirrhe s quickly s their brothers--the women nd would-be women who hve been unble to clim enough of the world's resources to survive. Second, the picture shifts depending on whether, like Heyzer, we focus on commodities nd income or whether we focus on wht Sen clls "functionings nd cpbilities." (Sen, 1990) In Chin, Sri Lnk, nd Cost Ric, for exmple, communl helth services, medicl cre nd bsic eduction produce qulity of life superior to tht which would be expected by the income indictors. The exmple of the Indin stte of Kerl is illuminting: While incomes within this Indin stte re mong the lowest, residents hve the highest life expectncy t birth, comprtively very low infnt mortlity rte, nd higher level of litercy (especilly femle litercy, eighty-seven percent compred to the ntionl verge of thirty-nine percent). b. Closer Look: The Feminiztion of Lbor Recent reserch shows tht while smll group of women hve ernings on pr with men, the overwhelming mjority of the world's women continue to ern significntly less thn men. This is lrgely ttributble to (1) the kind of work women do, nd (2) their uncompensted "women's work," including their reproductive work. In ddition, reserchers deplore the reltive lck of gender-ggregted dt nd the resultnt economic invisibility of the world's women, especilly the most mrginlized.( Mehr, Gmmge , 1999) Women slry Women ern less thn men everywhere. They re pid less thn men for doing the sme work, nd they re limited to low-income sectors by widespred sex-bsed occuptionl segregtion. In Brzil, for exmple, income erned by women is equivlent to fifty-four percent of tht received by men. In Cost Ric, for exmple, the verge monthly slry of women ws eighty-two percent of tht of men in 1990. In Uruguy women erned seventy-five percent of the income received by men. Women's Work Globliztion hs trnsformed lbor: "The concept of regulr, full time wge lbor ... hs been giving wy to more diverse pttern, chrcterized by informliztion' of employment, through more outworking, contrct lbor, csul lbor, prt-time lbor, homework nd other forms of lbor beyond the protection of lbor lws." (OS, 2005) Sixty-one percent of the world's workers re employed in the "informl sector." (OS, 2005) This term includes "frming, cottge industries, tool-mking nd grment-mking, nd in urbn res, petty trding ... [fruit nd vegetble selling] nd smll-scle mnufcturing enterprises." (OS, 2005) s economist Mrth Chen notes, "80% of workers in low-income countries nd more thn 40% of workers in middle-income countries operte in informl nd rurl lbor mrkets, beyond the rech of trde unions nd direct government intervention."(OS, 2005) In every country, more women thn men re employed in such mrkets. The informl sector is crucil to the economic survivl of poor women, s well s the economies of developing sttes. In dynmic, export-oriented subsectors, informl workers subsidize cpitlist growth "by providing infrstructure, tools, equipment nd often working below minimum wges in highly insecure nd contingent employment." In ddition, s Sssen observes, women subsidize the "wged lbor of men through their household production nd subsistence frming." (lston, 2004) Homework is n importnt prt of the informl sector becuse it enbles women to prticipte in the mrket economy, however mrginlly, nd still do their unpid work, including reproductive work, in the home. Home-workers comprise lrge nd growing segment of the lbor force in mny countries. Wherever sex-ggregted dt is vilble, it shows tht more women thn men re employed in homework. In Greece, Irelnd, Itly, nd the Netherlnds, for exmple, up to 95% of home-workers re women. Women re lso plying lrger role in griculture. Becuse of expnding opportunities for men outside griculture, lnd degrdtion, drought, nd other fctors tht reduce frm yields, men hve bndoned their frms, leving the women in chrge in Hondurs, Nepl, southern nd estern fric, nd Yemen. Women frmers, however, generlly hve less ccess to resources such s credit nd frm implements. They lso hve historiclly been neglected by griculturl extension services. Some economists theorize "tht it is the spred of more flexible nd informl employment tht ccounts for most of the upwrd trend in the femle shre of the lbor force," noting tht women predominte "[in] industries where profit mrgins re protected by reducing lbor costs, extending hours nd decresing the numbers of forml production workers...." s economist Guy Stnding notes, flexibility mens opportunity, but it lso mens insecurity. (Clrk, 2003) Women with dependent children my be desperte for opportunity, but they re lso especilly vulnerble; rpidly chnging mrkets put not only their businesses, but lso their children t risk. Thus, some feminist economists urge tht "reproduction nd unpid work be recognized [s] economic ctivities." (Clrk, 2003) Becuse women frequently work in the home, benefits nd other socil ssistnce/insurnce should be the concern of brod public policies nd not just ... linked to employers or enterprises. c. Lck of Dt Dt ssessing the impct of globliztion on women remins lrgely unvilble. In Southest si, for exmple, the Women Leders Network (WLN), recently deplored the bsence of the "sex-disggregted dt nd nlyses ... essentil to effective policy-mking, nd the success of PEC progrms nd projects." .(Clrk, 2003) rguing tht women hve borne the brunt of finncil nd economic turmoil in the region, the group insists tht the full impct of the crisis on women nd women's livelihoods hs to be fully understood nd ddressed. The lck of dt on women reflects the widespred invisibility of women's work, s well s stte pthy. Women's efforts to compenste for declining household incomes during recession, for exmple, re "not lwys picked up in officil dt" becuse such efforts re often concentrted "in the unrecorded informl sector." (Mehr, Gmmge, 1999) 5. Snpshots Subjective experience cnnot be cptured in sttistics. The next section consists of four brief nrrtives, or snpshots, tht show few of the wys in which globliztion ffects not only mrkets but individul women. While the following snpshots do not purport to be representtive, the problems ech of these women fce ffect mny others s well. The importnce of such snpshots, moreover, is incresingly recognized. They suggest rnge of experience otherwise omitted, nd the experience of the mrginlized is prticulrly t risk of being lost. . Teenger in the Mquildors Ofeli erns bout thirty dollrs for forty-four-hour week (eight hours dy for five dys week, four hours on Sturdys) working in mquildors fctory on the U.S.-Mexicn border. She lives in npr, coloni (neighborhood) in rw settlement emerging on top of lndfill right cross the border from El Pso, Texs. The houses in npr re mde of crdbord, discrded industril pllets, utomobile body prts, dobe, nd cst-off sbestos bord. There is no running wter. Rther, the people in npr depend on truck to bring them wter. They store the wter in "n elborte collection of continers tht llow for holding, using, nd reusing wter in vrious sequences.... Used chemicl drums (with plenty of English-lnguge wrning lbels) mke hndy wter brrels." She begn working in the fctory when she ws sixteen. b. Womn nd Her Children in the Moscow Subwy The photogrph shows hevy-set womn, probbly in her erly thirties, lening ginst the wll in Moscow subwy, pssively begging. Her two children re t her feet-- six- or seven-yer old is lying down, her hed on the cement floor, nd slightly older girl is sitting up. No one is pying much ttention to the photogrpher. This fmily is clerly mong the two-thirds of the Russin popultion in need of some form of socil ssistnce. The odds re good tht the womn hs been bused by her spouse nd tht she hs hd t lest one bortion, becuse bortions outnumber live births in Russi two to one. While her children (t lest the two with her) re not yet mong the growing number of street children in Russi, they hve probbly felt the impct of the "degrdtion of the eductionl system." The Russin stock mrket plunged eighty-four percent lst yer. c. Womn Leving Her Children in Centrl Prk In 1997, Lori-nn Willimston left her three-yer old nd eight-month old dughters in stroller in plyground in Centrl Prk in New York City. The stroller ws pcked with cerel, bby formul, clothing, nd toys. She told her children tht she ws going to get them ice crem nd left. fter forty-five minutes, nnny tking cre of nother child in the plyground clled the police. The children were plced With Children's Services. Willimston ws rrested t the prtment where she pid $100 per month for portion of the living room, where she lived with the two girls. The tennt nd her teenge son occupied the prtment's two bedrooms. When Willimston ws rrested, she explined tht she hd been depressed. Unble to find work tht llowed her to tke cre of her children, she sid she "knew tht if [she] left the children in the prk, the police would tke cre of them."2 d. Young Girl in Thilnd thirteen-yer old girl--who looks ten or eleven--gzes up t the photogrpher from her homework. She is former prostitute t rehbilittion center in Cmbodi. She sys she ws sold to brothel when she ws nine, but she ws ble to escpe two months go. The owners of the other brothels described in the rticle hve purchsed or kidnpped girl children in order to stisfy the incresing demnd for ever younger sexul prtners. The businessmen, the mngers nd representtives of the MNCs who support the lucrtive "sex tourism" trde believe tht younger girls re less likely to be infected with IDS or other sexully trnsmitted diseses. This is not lwys true. 6. The Culturl Logic of Lte Cpitlism: Women s Workers/Consumers/Investors Women workers cn no longer rely on interntionl unions or the ILO to ssure them decent working conditions, benefits or wges, if indeed they ever could. The premises of industril lbor lw re incresingly irrelevnt s lw to most of the world's women, including the growing numbers in the informl sector. The norms to which such lws hve contributed, on the other hnd, my well be useful. mericn reders re likely to wince, for exmple, t the prospect of sixteen-yer old working forty-four hours per week in fctory. t the sme time, postmodernist would question the orthodoxy of forty-hour week t fmily wge. How mny hours per week do other Mexicns work Is fmily wge, with its presumption of sty-t-home mother, good for women Women lso hve tremendous potentil leverge s consumers nd investors, despite their poverty. Even the poorest women in the poorest countries cn exercise some leverge s consumers becuse, s Debor Spr points out, non-pprel MNCs re "in the end" looking for locl mrkets. Since buying food nd other necessities for their fmilies is typiclly prt of women's unpid work, women cn support "socil lbeling" nd the businesses tht support women s workers. Women in the industrilized world obviously hve even more leverge s consumers. In response to such leverge, over 100 U.S. compnies, including Reebok, Sers, Levi-Struss, Gp nd Home Depot, hve dopted codes of conduct to ssure consumers tht their business prctices re consistent with humn rights. Women lso hve substntil leverge s investors, especilly in view of the incresing independence of the pension funds in which they prticipte. Investors like Mry Jo Poni, the Midwestern secretry quoted bove, ffect globl investment nd, given n explicit choice, re unlikely to mximize profits t the expense of humn rights. 7. The Roles of Lwyers . ccess to the Superstore Under the clssic conception, the lwyer's job is to trnslte the client's story into legl clim. Under the postmodern conception, in contrst, the lwyer's job is to provide spce in which the client cn tell her story. This provides wider scope for lwyers, but it distnces them from the ressuring uthority of the fmilir legl mchinery. While legl expertise remins importnt, it no longer wgs the dog. Since the objective is to provide mrginlized women with ccess to the Superstore, lwyers' roles re open-ended. In Senegl, for exmple, the ssocition for Women nd lterntive Communiction is lunching women's rdio sttion to educte women bout their legl rights nd similr mtters. In the SIL rdio series on The Individul nd Globliztion, lwyers helped crete spce in which women in the developing world told their stories to brod udience. In Ecudor, lwyer skilled in medition enbles n indigenous group to void the expense of ntionl courts. Postmodern lwyers cn even pproprite dvertising. Pierre Schlg describes Mobil dvertisement, for exmple, in which the oil compny exploits refugees to enhnce its corporte imge. Whtever its objective, the dvertisement my well contribute to Rorty's "sympthy"--unfocused, sentimentl, but sympthy nevertheless. b. Representing Clients The postmodern ttorney represents her client in new wy. Unlike the clssic lwyer, she does not seek to simply represent her client's interests before the pproprite tribunl. Rther, she recognizes tht those interests my not be cognizble under the lw. The economic rights of mrginlized women re rrely recognized in ntionl lw nd only vguely suggested in interntionl lw. The postmodern ttorney must find other wys to support her clients. Cmpign for Economic Justice, for exmple, ws orgnized by women who hd been on welfre themselves. They filled bus nd trveled cross the country for two months, stopping for series of crefully orchestrted meetings, rllies, nd slide shows. They concluded their cmpign t the United Ntions, where they presented petition demnding recognition of their economic rights. They needed lwyers for such simple things s permits nd ccess to udiences. Yle lw students provided both during 1998 Conference on Criticl Rce Theory. 8. The Roles of Women Frgmenttion nd Discontinuity: Women s Subversives Women everywhere re prt of tht vociferous constituency Virgini Lery hs described s "clmoring t the gtes"(320) of the WTO, outrged by its neglect of their humn rights. From clssic perspective, the ccophony t the gtes precludes coherent systemic response. From postmodern perspective, this is not necessrily bd. Rther, it deters the confltion of disprte, even conflicting, clims. It requires tht ech distinct clim be herd nd supports frgmentry, discontinuous, subversions. s Huyssen explins: We re witnessing ... mssive delegitimiztion' of the mster codes in society, desuetude of the metnrrtives ... the most bleful exmple [of subversion] is the rmpnt terrorism of our time. But subversion' my tke other, more benevolent, forms such s minority movements or the feminiztion of culture, which lso requires decnoniztion. Women cn exploit economic rights lw to further such benevolent forms of subversion, nd thus further their respective clims in different wys in different contexts. On ntionl level, for exmple, women in Russi cn use the Economic Covennt to embrrss their leders nd to demnd t lest prtil re-weving of socil sfety nets. On the interntionl, s well s on the ntionl level, women cn join ny of the innumerble Nongovernmentl Orgniztions (NGOs) tht hve sprung up to chllenge ntionl governments, IOs, nd MNCs. few of the Mjor Plyers re receptive. The World Bnk now holds yerly meetings with the Externl Gender Consulttive Group. ECOSOC hs extended consulttive sttus to interntionl NGOs which meet certin stndrds nd the Committee on Economic nd Socil Rights (CESCR) hs lredy opened its doors to NGOs. s the delegtes t the Fifth nnul NGO Forum on World Bnk nd IMF Lending concluded, however, NGO "colitions hve succeeded only when efforts to pressure the Bnk by "working within the system'... hve been ccompnied by the mobiliztion of populr movements;" tht is, the mechnisms of humn rights lw my well be useful, but only s prt of broder politicl effort. Bibliogrphy: 1. Josef Joffe, One Dollr, One Vote, N.Y. TIMES, pr. 25, 1999, [sections] 7 (Book Review), t 14 (citing KRL MRX & FREDERICK ENGELS, THE COMMUNIST MNIFESTO). 2. Nichols D. Kristof & Edwrd Wytt, Who Went Under in the World's Se of Csh, N.Y. TIMES, Feb. 15, 1999, t 1. 3. mrty Sen, More Thn 100 Million Women re Missing, N.Y. REV. BOOKS, Dec. 20, 1990, t 61, cited in HENRY J. STEINER & PHILIP LSTON, INTERNTIONL HUMN RIGHTS IN CONTEXT: LW, POLITICS, MORLS 896 (1996). 4. Rekh Mehr & Srh Gmmge, Trends, Countertrends, nd Gps in Women's Employment, 27 WORLD DEV. 533, 533 (1999). 5. OS, REPORT OF THE INTER-MERICN COMMISSION ON THE STTUS OF WOMEN IN THE MERICS 28-29 (2005). 6. Philip lston, The Committee on Economic, Socil nd Culturl Rights, in THE UNITED NTIONS ND HUMN RIGHTS: CRITICL PPRISL 473 (Philip lston ed., 2004). 7. Grci Clrk, Implictions of Globl Polriztion for Feminist Work, 4 IND. J. GLOBL LEGL STUD. 43, 47 (2003) 8. Frnces Lee nsley, Rethinking Lw in Globlizing Lbor Mrkets, 1 U. P. J. LB. & EMPLOYMENT L. 369, 385 (1998) Read More