Research Handbook of International and Comparative Perspectives on Diversity Management
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Research Handbook of International and Comparative Perspectives on Diversity Management

Edited by Alain Klarsfeld, Eddy S. Ng, Lize A.E. Booysen, Liza Castro Christiansen and Bård Kuvaas

This Research Handbook offers, for the first time, a comparative approach to current diversity management concerns facing nations. Spanning 19 countries and across Africa, it covers age, gender, ethnicity, disability, sexual orientation, national origin and the intersection of various dimensions of diversity. The multicultural and multi-country teams of contributors, leading scholars in their own countries, examine how the various actors react, adopt and manage the different dimensions of diversity, from a multitude of approaches, from national to sectoral and from tribes to trade unions, but always with a comparative, multi-country perspective.
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Chapter 4: Brazilian, South African and US work environments: a comparative analysis of equal opportunity, diversity management and inclusion practices

Lize A.E. Booysen, Gwendolyn Combs and Waheeda Lillevik


This chapter compares workplace equality legislation regarding marginalized groups, such as women, persons with disabilities, LGBTQ identity and racial/ethnic populations in Brazil, South Africa and the USA. It also contrasts these policies against each nation’s historical, social, political and legal contexts, and outlines future directions. These three countries share similar historical experiences in the positioning of power differentials between ruling classes, indigenous groups and those subjugated to legacies of inequality. In Brazil and the US the legacy of slavery endures, and in South Africa the vestiges of apartheid remains. All three countries still battle the influences of these measures on equity, diversity and inclusion of racial/ethnic and gender groups, and continue to struggle with the outcomes of everyday experiences of equality. Legislation aimed at anti-discrimination, promoting gender equality, disability and racial ethnic diversity varies between the countries, but is in existence. The concept of affirmative action is employed in each country in varying forms. Brazil imposes specific quotas for the employment of the disabled and women in certain areas. South Africa also has established quotas in the employment and training of designated groups – blacks, coloreds, Indians, women and the disabled – and in ownership, shareholding. Conversely, in the USA, affirmative action is used as a mechanism for achieving equality for racial/ethnic minorities, women and persons with disabilities, and quota systems are considered unconstitutional.

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