Mario Draghi: Sovereignty in a globalised world
Speech by Mr Mario Draghi, President of the European Central Bank, on the award of Laurea
honoris causa in law from Università degli Studi di Bologna, Bologna, 22 February 2019.
* * *
It is a great honour to be speaking here today at the University of Bologna.
As Europe's oldest university, it has been at the heart of education and learning in Europe for
over 900 years. It has a long history of welcoming students from across the continent, including
Thomas Beckett and Copernicus. Erasmus studied here in 1506, and the University of Bologna
is today a leading participant in the student exchange programme that bears his name.
The Erasmus Programme is one of the many examples of the benefits of the close cooperation
within the European Union that enjoy widespread popularity. But we know that other elements of
European integration are more contested today.
At the root of this debate is the inherent tension between the clear gains of economic integration,
and the cooperation that is necessary to bring it about, which can sometimes be politically
difficult to achieve or explain. I would like to argue that, in many ways, this tension is illusory.
Rather than taking away countries' sovereignty, the EU offers them a way to regain it.
This does not mean we need the EU for everything. But in the face of globalisation, the EU is
more relevant than ever today. As Jean Monnet said, "we need a Europe for that which is
[1]
essential ... a Europe for what nations cannot do alone."
Sovereignty in an interconnected world
On the whole, European citizens appear to welcome the benefits brought about by economic
[2]
integration through the EU. The free movement of people, goods and services - that is, the
Single Market - is routinely seen by citizens as the EU's most positive achievement. In the euro
area, 75% of people are in favour of the euro and Monetary Union, and 71% of Europeans
support the EU's common trade policy.
Yet at the same time, public attitudes towards the EU's political structures seem to be hardening.
Average trust in the EU stands at 42%, down from 57% in 2007. This decline has taken place
against the backdrop of a general loss of faith in public institutions. Trust in national governments
and parliaments has dropped to just 35%.
This tension between economic integration and political cooperation is fuelled by a powerful belief
that there is an inherent trade-off between EU membership and the ability of countries to exercise
sovereignty. In this way of thinking, if citizens want to be able to exert more control over their
destinies, they have to loosen the EU's political structures. But this belief is wrong.
It is wrong because it conflates independence with sovereignty.
True sovereignty is reflected not in the power of making laws - as a legal definition would have it
- but in the ability to control outcomes and respond to the fundamental needs of the people: what
[3]
John Locke defines as their "peace, safety, and public good". The ability to make independent
decisions does not guarantee countries such control. In other words, independence does not
guarantee sovereignty.
Countries that are completely shut off from the global economy, to take an extreme but
instructive example, are independent but not sovereign in any meaningful sense - often relying
on external food aid to feed their people. Yet being connected through globalisation also
increases the vulnerability of individual countries in many ways.
They are more exposed to financial spillovers and to the aggressive trade policies of foreign
states, while increased competition makes it harder for states to coordinate with one another to
enforce regulations and set standards so as to achieve their social goals. This restricts their
control over domestic economic conditions.
In this environment, countries need to work together to exercise sovereignty. And this applies
even more within the EU. Cooperation within Europe helps protect states from external
pressures, and it helps enable their policy choices.
Working together to protect
Globalisation has profoundly changed the nature of global production and deepened the ties that
exist between countries. Cross-border holdings of financial assets are now around 200% of
global GDP, compared with about 70% in 1995. Foreign trade has increased from around 43% of
global GDP in 1995 to about 70% today. And around 30% of foreign value added is now created
[4]
through global value chains.
At the global level, this process has been driven not just by policy choices, but in large part also
by technological progress. Businesses have capitalised on the advances in transportation,
[5]
telecoms and computing that make it easier to trade globally and fragment production.
Previous policy decisions and geographic proximity make the EU by far the most important
trading area for European economies. The majority of world trade takes place within three main
trading blocs - the EU, the North American Free Trade Agreement (NAFTA) and Asia - and
though linkages have grown between those blocs, they remain relatively closed to one another.
[6]
The ratio of extra-regional trade to GDP in these regions is below 15%.
The EU is the most integrated of these blocs. Two-thirds of EU countries' trade is with other
Member States, compared with about half for the NAFTA region. Around 50% of euro area
crossborder financial holdings are from other euro area countries. Practically speaking, this means
that Italy exports more to Spain than to China, and more to Austria than to Russia or Japan. In
2017, German direct investment in Italy was five times higher than that of the United States.
Europe has profited a great deal from this integration: it is estimated that the Single Market raises
GDP in the EU by around 9%, taking into account both the direct trade and competition
[7]
effects. But as countries become more interlinked, they also become more exposed to volatile
capital flows, unfair competition or discriminatory actions - and this necessitates greater
protection for their citizens.
That protection, which EU countries have created together, has allowed them to garner the
benefits of openness while limiting, to some extent, its costs. The EU's common structures and
institutions contain spillovers, ensure a level playing field and prevent unjust behaviour - in other
words, they respond to the needs of citizens and allow countries to exercise sovereignty.
Thus the Council and the European Parliament set common rules for the whole EU, the
Commission ensures they are observed, and the European Court of Justice (ECJ) provides for
judicial protection if they are violated. In the euro area, European banking supervision and the
Single Resolution Mechanism help to contain the effects of financial instability.
In this interconnected environment, seeking independence from EU institutions presents complex
trade-offs. Countries either have to accept rules decided by others to ensure continued access
to the European market, which gives them less control over decisions that affect their citizens'
interests; or they have to disentwine themselves from their most important trading partners,
which gives them less control over their citizens' welfare.
8% lower in Germany and 7% lower in Italy.
The case for working together to enhance sovereignty also applies to the relationship between
the EU and the rest of the world. Few European economies are sizeable enough to withstand
spillovers from large economies or to leverage power in external trade negotiations. But
cooperating at the EU level increases their potential to do so.
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The EU accounts for 16.5% of global economic output, second only to China, which gives
European countries a large domestic market to fall back on in the event of trade disruptions. EU
[10]
trade makes up 15% of world trade, compared with around 11% for the United States,
providing the EU with significant weight in trade negotiations. And the euro is the world's
secondmost traded international currency, which helps insulate the euro area economy from exchange
rate volatility.
[11]
Indeed, around 50% of extra-euro area imports are now invoiced in euro, which reduces the
pass-through of exchange-rate volatility to import prices. That in turn allows monetary policy to
focus more on euro area economic developments rather than having to react repeatedly to
[12]
external shocks.
For all these reasons, being outside the EU might lead to more policy independence, but not
necessarily to greater sovereignty. The same is true of the single currency.
Most countries would no longer benefit from local currency invoicing, which would exacerbate the
effects on inflation if they undertook large exchange rate devaluations. And they would be more
exposed to monetary policy spillovers from abroad - not least from the ECB itself - which could
constrain their domestic policy autonomy. In recent years, Denmark, Sweden, Switzerland and
central and eastern European economies have been affected by spillovers from our policy
[13]
measures.
In fact, spillovers from larger economies were one reason why the euro was created in the first
place. Under the European Monetary System that preceded the euro, most central banks had to
follow the policy of the Bundesbank. After more than a decade of disappointing, if not devastating,
experiences, it was deemed preferable to regain monetary policy sovereignty by launching the
[14]
single currency together.
Cooperation and economic policy
The second way in which globalisation constrains sovereignty is by limiting countries' capacity to
set laws and standards that reflect their social goals.
Global trade integration tends to reduce that capacity, because as production fragments through
value chains, there is a greater need for countries to agree on common standards. Those
standards are mostly set not within the World Trade Organization, but by large economies with
dominant positions in the value chain. Smaller economies tend to end up as rule-takers in the
[15]
international system.
Global financial integration can likewise reduce individual countries' power to regulate, tax and
uphold labour standards. Multinational firms can influence national regulations through the threat
of relocation, as well as arbitrage tax systems by shifting income flows and intangible assets
across jurisdictions. There can also be incentives for countries to use labour standards as a tool
of international competition - the so-called "race to the bottom".
This makes it more difficult for countries to enforce their core values and protect their people. It
also leads to corporate tax bases being eroded, which makes it harder to finance welfare
states. OECD analysis, for example, estimates global revenue losses from tax avoidance to
[17]
be in the range of 4% to 10% of corporate income tax revenues.
These effects occur when countries are not large enough to exercise regulatory power against
mobile capital or cross-border firms. But it is harder for this to happen at the level of the EU,
since it represents a market that companies can ill afford to leave. Having regulatory power at the
EU level enables EU countries to exercise sovereignty in the areas of taxation, consumer
protection and labour standards.
First, the EU gives its members the capacity to prevent multinationals from avoiding corporation
tax by exploiting loopholes or extracting subsidies.
This is a complex area, but some recent progress has been made on this front. New European
rules have entered into force this year to eliminate the most common corporate tax avoidance
[18]
practices. And while the ECJ recently ruled against the Commission in a tax exemption case,
it also recalled that special tax deals between multinationals and individual countries can
[19]
constitute illegal state aid, which the Commission has the right to examine.
Second, the EU offers much greater possibilities to defend consumers' values and ensure that
they are treated fairly within the European market.
This has been visible in the EU's ability to enforce its values concerning privacy through the
[20]
General Data Protection Regulation. It has been visible too in EU regulations to bring down
[21]
mobile phone roaming charges for consumers within Europe, or to ensure that they cannot be
charged more for cross-border payments in euro within the EU than they would be for national
[22]
transactions.
The third advantage is that countries have the possibility to coordinate within the EU to defend
social protections without imposing trade restrictions.
Through the Charter of Fundamental Rights, EU law has reduced the possibility of unfair
competition from jurisdictions with laxer labour laws. And it has also helped raise labour
standards within the EU. A case in point is the European Directive on Part-time Work in 1997,
which reduced certain forms of discrimination that were still in place in 10 of the then 15 EU
[23]
Member States, including Italy. OECD analysis finds that, over time, the introduction of equal
treatment laws was associated with an increased likelihood of people being awarded permanent
[24]
contracts.
The same protections do not exist at the global level or are much weaker in other regional trading
blocs such as NAFTA. The history of the United States itself illustrates the difficulty of aligning the
approaches of individual states to improve working conditions.
In the early 20th century, there was a growing concern in several US states about the lack of a
social safety net, especially for the elderly. But individual states feared that providing social
security would impose, in the words of the time, "a heavy tax burden on the industries of the
state that would put them at a disadvantage in competition with neighboring states unburdened by
[25]
a pension system."
The lack of coordination created a severe underprovision of social security, which was
exacerbated by the Great Depression. In 1934, half of the population over 65 were in
[26]
poverty. This was only resolved through the passing of the federal Social Security Act in 1935,
which enabled states to coordinate in providing social security.
In a similar way, the EU provides a powerful coordination function that allows countries to
achieve goals that they could not realise alone. And the EU is able in turn to export some of its
standards globally.
The EU is the top trading partner of 80 countries, compared with just over 20 for the United
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States. That allows the EU to insist on higher labour and product standards abroad via trade
[28]
agreements, as well as protecting local producers at home. The recent trade agreement with
Canada, for example, protects 143 European geographic indications.
The EU also has regulatory power that goes beyond trade agreements. As exporters to the EU
must meet its standards, economies of scale result in the application of those standards to
[29]
production in all countries. This is known as the "Brussels effect". In this way, the EU de facto
sets the global rules across a wide range of areas.
All this gives EU countries another unique capacity: to ensure that globalisation is not a race to
the bottom on standards. Rather, the EU is able to pull global standards up to its own.
Institutions and rules
In an integrated regional and global economy, the case for European countries to work together
to exercise sovereignty is clear. But while many would agree on the need for cooperation, views
differ over how best to organise it.
Some would argue that looser, more transactional cooperation led by national governments is
sufficient. And there are indeed several historical examples of successful agreements being
forged by the coming together of willing states. Where all parties benefit equally, loose
cooperation can be sustainable. One such example is the Bologna Process, which has helped
align higher education standards and ensure mutual recognition of university degrees across
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members of the Council of Europe.
But it is also clear that in cases where cooperation is more necessary, the conditions for loose
cooperation would not hold. Spillovers between larger and smaller economies are typically
asymmetric. Coordination problems arise because there are incentives for countries to free-ride
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or to undercut one another. In these instances, deeper modes of cooperation are essential to
align countries' interests.
The EU has thus far employed two methods of governance to facilitate cooperation. In some
cases, we have invested common institutions with executive power - such as the Commission
for trade policy or the ECB for monetary policy. In others, executive power remains with national
governments, with cooperation through common rules, such as the framework for fiscal and
structural policies.
These areas of economic policy were considered too specific to the situation of individual
countries to be entrusted to a common body. It was felt that the only possible form of governance
was for countries to exercise national sovereignty, thereby respecting their own specific set of
circumstances. A rules-based approach was seen to be the only solution that was consistent
with this vision. But it is worthwhile to reflect on how successful this choice has been.
For the cases where executive power has been invested with institutions, most would agree that
the institutions have performed relatively well. Trade policy has been effective in opening up
access to new markets: the EU has in place 36 free trade agreements, compared with 20 for the
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United States. Monetary policy has successfully fulfilled its mandate.
But for the areas that use a rules-based approach, some shortcomings have been revealed. The
fiscal rules have provided a framework for assessing fiscal policies but have at times proven
difficult to enforce and hard to explain to the public. In the area of structural policies, the Country
Specific Recommendations have had a limited impact, with less than 10% of recommendations
being substantially implemented each year.
The disparity between the outcomes of the two methods does not stem from any difference in
the quality of European and national authorities. Instead, it is a consequence of the inherent
difference between rules and institutions. There are two reasons why institutions have proven
superior.
First, rules are generally static and require countries to adhere to specific actions, whereas
institutions are required to achieve prescribed objectives. Rules therefore cannot be updated
quickly when unforeseen circumstances arise, whereas institutions can be dynamic and employ
flexibility in their approaches. That distinction matters hugely when underlying parameters and
economic relationships change - as they often do. The distinction also matters for citizens, who
ultimately care most about the results of economic policy rather than the actions taken by
governments.
The ECB's monetary policy during the crisis is an example of the greater flexibility of action
afforded by an institution-based approach.
The ECB was faced with a range of challenges that few could have predicted when our mandate
was defined. But the Treaty combines our mandate for price stability with discretion over the
tools we could use to achieve it. This allowed us to deploy a range of unconventional policy tools
to ensure that inflation remained in line with our aim. Neither operating monetary policy according
to a fixed rule nor restricting ourselves to conventional policy tools would have sufficed.
Discretion and flexibility in the use of our tools helped to strengthen our credibility. Flexibility and
credibility were, in this instance, mutually reinforcing.
By contrast, rules lose credibility if they are applied with discretion. Rules will be undermined if
countries find reasons to circumvent them or rewrite them as soon as they bind. But
circumstances will always arise which were not foreseen at the time the rules were written and
which call for flexibility. In the case of rules, there is an inevitable trade-off between credibility and
flexibility.
This is why there are always tensions when it comes to economic policies that follow the
rulesbased approach. But the transition to an institutions-based approach requires trust between
countries. And trust is based on strict compliance with the existing rules, but also on the ability of
governments to reach mutually satisfactory compromises when the circumstances call for
flexibility and to explain them adequately to their citizens.
That transition nevertheless remains necessary.
The European Commission's recent initiative on the international role of the euro provides a
further example of the need to move from the current framework of various laws and ad hoc
rules to a system based on harmonisation and institutions. Rising trade tensions and the growing
use of sanctions as an instrument of foreign policy have meant that the laws of the United States
are increasingly being applied outside its jurisdiction. This takes the form of penalties for
societies outside the United States and the prevention of access to the US payment system and
is based on the central role played by the US financial system and the US dollar in global trade.
Several European governments believe that this situation could be mitigated by increasing the
international role of the euro. But if markets are to entertain the possibility of an enhanced role for
the euro, we need to consider what the conditions are that underpin the dollar's dominance. The
list is long, but the fact that the dollar is an expression of an integrated capital market is certainly
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one of those conditions. For the EU to meet that condition - which, at this stage of its
development, is more achievable than others - would require a complex programme of
legislative and institutional harmonisation, which however could be put in place in short order.
The second reason why an institutional approach can help produce better outcomes is that
institutions and their actions can be subject to more clearly defined democratic control. Precisely
because those institutions are invested with a mandate and defined powers, it is possible to
make a more direct link between decisions and responsibility.
The EU already has many channels through which its citizens can exercise democratic control,
via national authorities in the EU Council and Members of the European Parliament, who hold EU
institutions accountable on behalf of the people who elected them. In fact, for the first time on
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record, a majority of Europeans now feel that their voice counts in the EU.
It is to be hoped that accountability arrangements to hold EU institutions in check continue to be
strengthened, because the perception of the legitimacy of their actions depends on it. The role of
the European Parliament is vital here. Of the institutions with a democratic mandate to exercise
control, it is the only one with a European perspective.
The European Court of Justice provides a second avenue of democratic control. Its role in
ensuring that EU institutions are following their mandates becomes all the more important in the
absence of a European government.
Adherence to the judgments of the ECJ is a necessary condition of the rule of law. Consistency
and uniformity in the interpretation of EU law across 28 Member States are the bedrocks of EU
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law as an effective and autonomous legal order. A basic function of the law is to stabilise
expectations by providing a reliable foundation upon which citizens and companies can organise
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their activity and plan for the future. And such predictability and certainty is especially
important for Economic and Monetary Union today.
Conclusion
In today's world, technological, financial and commercial interlinkages are so powerful that only
the very largest countries are able to be independent and sovereign at the same time, and even
they cannot do so entirely. For most other nation states, including the European countries, these
two characteristics do not coincide.
The European Union is the institutional framework that has allowed the Member States to be
sovereign in many areas. It is a shared sovereignty, which is preferable to none at all. It is a
complementary sovereignty to the one exercised by individual nation states in other areas. It is a
sovereignty that Europeans like.
The European Union has been a political success built within the international order that emerged
after the Second World War. It has been a faithful interpreter of the values of freedom, peace and
prosperity on which that order was founded.
The European Union has been an economic success because it has provided an environment in
which the energies of its citizens have created widespread and lasting prosperity founded on the
Single Market and protected by the single currency. The last decade has dramatically highlighted
the shortcomings of national policies and the need for cooperation to evolve both within the EU
and beyond.
A long global economic crisis, unprecedented migration flows and inequality exacerbated by
large concentrations of wealth resulting from technological progress have given rise to rifts in a
political and economic order that was thought to be set.
Change is necessary, but there are different ways of bringing it about. One prospect is that
ageold ideas that have shaped most of our history are revived, such that the prosperity of some
cannot be achieved without the poverty of others; international and supranational organisations
lose their relevance as places for negotiating and finding compromise solutions; the affirmation of
the self, of the identity, becomes the first requirement of every policy. In such a world, freedom
and peace become accessories which can be dispensed with as needed.
But if we want these values to remain essential, fundamental, the path is a different one:
adjusting existing institutions to change. This process of adjustment has so far encountered
resistance because the inevitable national political difficulties always seemed to be above such
need. This reluctance has resulted in uncertainty about the capacity of institutions to respond to
events and has strengthened the voice of those who want to pull down these institutions.
There should be no doubt: this adjustment will have to be as deep as the phenomena that
revealed the fragility of the existing order, and as vast as the dimensions of a geopolitical order
that is changing in a way that is not favourable for Europe.
The European Union wanted to create a sovereign where there was not one. It is not surprising
that in a world where every point of contact between the great powers is increasingly a point of
friction, the external challenges to the existence of the European Union become increasingly
threatening. There is only one answer: recovering the unity of vision and action that alone can
hold together such different countries.
This is not only a hope, but an aspiration based on political and economic advantage. But there
are also internal challenges that have to be faced, which are no less important for the future of
the European Union. We need to respond to the perception that it lacks equity, between countries
and social classes. We need first to listen, and then to act and explain.
So, unity and equity are needed, above all, as a guide for policymaking in Europe.
I would like to recall in closing the words of Pope Emeritus Benedict XVI in a famous speech held
38 years ago:
"To be sober and to do what is possible, and not to claim with a burning heart the impossible has
always been difficult; the voice of reason is never as loud as an irrational cry... But the truth is
that political morals consist precisely in resisting the seductions of magniloquent words... It is
not moral the moralism of adventure... It is not the absence of all compromise, but the
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compromise itself that is the true moral of political activity".
Footnotes
[1]
Reflection paper by Monnet, J. (1965), Les Portes, Archives de la Fondation Jean Monnet pour
l'Europe, August.
[2]
European Commission (2018), "Public opinion in the European Union", Standard
Eurobarometer 90 - Autumn 2018, Directorate-General for Communication, European
Commission, Brussels.
[3]
John Locke, An Essay concerning the true original, extent and end of civil Government, 1690.
[4]
UNCTAD (2018), World Investment Report 2018: Investment and New Industrial Policies.
[5]
There is some debate as to whether technology will evolve in the future in ways that make
global value chains less important. Technologies such as 3D printing or robotics could allow the
local production of many more goods. Some scholars find that technological change has so far
only mildly slowed offshoring, while others see a more significant reversal ahead. See Koen De
Backer, K., Menon, C. Desnoyers-James, I. and Moussiegt, L. (2016), "Reshoring: Myth or
Reality?", OECD Science, Technology and Industry Policy Papers, No 27, OECD Publishing;
and Baldwin, R. (2016), The Great Convergence: Information Technology and the New
Globalization, Harvard University Press.
OECD (2018), OECD Economic Outlook, Volume 2018, Issue 1, Chapter 2.
[7]
in 't Veld, J. (2019), "Quantifying the Economic Effects of the Single Market in a Structural
Macromodel", European Economy Discussion Paper, No 094, European Commission, February.
[8]
This scenario assumes a counterfactual in which trade reverts to WTO-rules, and applies
Most Favoured Nation (MFN) rates as tariffs on goods. For non-tariff barriers, it relies on
estimates calculated for trade between the EU and the US. See in 't Veld, J. (2019), op. cit.
[9]
As measured by PPP-adjusted GDP.
[10]
Excluding intra-EU trade.
[11]
For further details, see ECB (2015), The international role of the euro, Frankfurt am Main, July.
[12]
See Gopinath, G., Itskhoki, O. and Rigobon, R. (2010), "Currency Choice and Exchange Rate
Pass-Through", American Economic Review, Vol. 100, No 1, pp. 304-336.
[13]
See Falagiarda, M., McQuade, P. and Tirpák, M. (2015), "Spillovers from the ECB's
nonstandard monetary policies on non-euro area EU countries: evidence from an event-study
analysis", ECB Working Paper Series, No 1869; Potjagailo, G. (2017), "Spillover effects from
Euro area monetary policy across Europe: A factor-augmented VAR approach", Journal of
International Money and Finance, 72(April):127-147; Bäurle, G., Gubler, M. and Känzig, D.
(2017), "International inflation spillovers - the role of different shocks", Swiss National Bank
Working Papers, No 7/2017.
[14]
See Draghi, M. (2018), "Europe and the euro 20 years on", speech by Mario Draghi, President
of the ECB, at Laurea Honoris Causa in Economics by University of Sant'Anna, Pisa, 15
December 2018.
[15]
See Blind, K., Mangelsdorf, A., Niebel, C. and Ramel, F. (2018), "Standards in the global value
chains of the European Single Market", Review of International Political Economy, 25:1, 28-48.;
Nadvi, K. (2008), "Global standards, global governance and the organization of global value
chains," Journal of Economic Geography, 8(3): 323-343.
[16]
See Devereux, M. et al. (2008), "Do countries compete over corporate tax rates?", Journal of
Public Economics, Vol. 92(5-6), pp. 1210-1235.
[17]
OECD (2018), OECD Economic Outlook, Volume 2018 Issue 1, OECD Publishing, Paris.
[18]
See European Commission, "New EU rules to eliminate the main loopholes used in corporate
tax avoidance come into force on 1 January", press release, Brussels, 30 December 2018.
[19]
Joined Cases T-131/16, Belgium v Commission and T-264/16, Magnetrol International v
Commission, judgment of the Court of 14 February 2019.
[20]
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of
27 April 2016 on the protection of natural persons with regard to the processing of personal data
and on the free movement of such data, and repealing Directive 95/46/EC (General Data
Protection Regulation).
[21]
COMMISSION IMPLEMENTING REGULATION (EU) 2016/2286 of 15 December 2016 laying
down detailed rules on the application of fair use policy and on the methodology for assessing the
sustainability of the abolition of retail roaming surcharges and on the application to be submitted
by a roaming provider for the purposes of that assessment.
DIRECTIVE (EU) 2015/2366 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of
25 November 2015 on payment services in the internal market, amending Directives
2002/65/EC, 2009/110/EC and 2013/36/EU and Regulation (EU) No 1093/2010, and repealing
Directive 2007/64/EC,
[23]
Belgium, Denmark, Finland, Germany, Greece, Ireland, Italy, Spain, Sweden and the United
Kingdom.
[24]
OECD (2010), "Have equal-treatment la