Introduction

Due to its longevity and by many measures relative success, the Canadian approach to involving private actors and civil society in refugee resettlement is often taken as a model for private sponsorship schemes elsewhere (Krivenko 2012; Lenard 2016; Ugland 2018). After the Canadian government promised to “export” the private sponsorship model to other interested states at the UN Summit in New York in September 2016 (Hyndman et al. 2017), it has been very active in sharing its “history, experience, and leadership” in private sponsorship through, among others, the Global Refugee Sponsorship Initiative (GRSI n.d.). Through such networks, Canada encourages other governments to adopt its policy—a process which is commonly referred to as “policy transfer” (Dolowitz and Marsh 2000). What is more, its efforts in this respect are seen to have exerted considerable influence on the policy debate and the design of local private sponsorship schemes (PSS) in other countries, such as the UK (Kumin 2015). Most recently, Germany announced its latest pilot sponsorship project in May 2019, modeled partly on previous experiences and partly on the Canadian archetype (von Bullion 2019).

One of the risks of such an approach, though, is that it tries to directly copy a more or less intact program cross-nationally (Rose 1991). Such a tactic mistakenly presupposes the existence of a one-size-fits-all model for PSS that neglects crucial differences between countries. By taking the Canadian model as an unmediated inspiration for other countries, extant attempts to learn from the Canadian experience may suffer such exposure (Krivenko 2012). Beirens and Ahad (2018, p. 2) find that, in the field of refugee resettlement peer support among countries, direct copying leads to activities and policies “being recycled without clear evidence that they are effective.” In contrast, an adaptation approach to lesson-drawing and policy transfer seems to be more suitable since it usefully adjusts a policy for contextual differences (James and Lodge 2003). Laudably, more recently, the Canadian government has responded to such criticism and has revised its strategy as to incorporate more the system compatibility of PSS (Beirens and Ahad 2018). Appreciating the importance of institutional differences, the new approach takes account of the degree of centralism or federalism, directing attention more directly to the question of what the division of tasks should be between various levels of state in a private sponsorship scheme. Such an institutional approach is indeed crucial to effective policy learning (James and Lodge 2003). Moreover, respecting the plausible effects of prevailing anti-immigrant sentiments on resettlement policies, the Canadian approach now sensibly considers government commitment in the receiving country (Tyrberg and Dahlström 2018).

These adaptations to the Canadian transfer practice make room for involving pertinent contextual factors in the process of policy transfer design. In line with this recognition, we believe that this process will benefit from explicitly factoring in one additional crucial contextual element: societal culture. To the extent it takes into account contextual differences, the focus of the current policy transfer approach lies mainly on the governance structure in which the sponsorship scheme will operate, that is the “harder” aspects of the local context (Beirens and Ahad 2018). As a result, some of the “softer” aspects such as the cultural attitudes towards the design of PSS remain underexplored and undertheorized.

Admittedly, the importance of culture is generally well recognized in the field of refugee resettlement. But, when dealing with this all-important question, studies of PSS as well as policy practices have mostly concentrated on the cultural orientation of resettlement candidates and their sponsors, i.e., the compatibility between refugees and their hosts (Beiser 2006; Lenard 2016). This focus is sensible, as “placing refugees in the best areas for them” has shown to improve the effectiveness of PSS and to increase the wellbeing of refugees and communities (Jones and Teytelboym 2017). Likewise, support programs often provide cultural orientation sessions and intercultural training (Beirens and Ahad 2018). In contrast, the cultural impacts on the transfer process of PSS adoption have received less attention. Indeed, the entire field of cultural research has long been ignored to such a level that Geva-May (2002) labeled it “the neglected variable in the craft of policy analysis.” With exceptions (e.g., Ugland 2018), few studies take into consideration the cultural compatibility of concrete policy initiatives in the field of immigration and integration. And, although the policy transfer and institutional transplantation literatures increasingly recognize the potential influence of cultural attitudes on the success of a given policy transfer (Dolowitz and Marsh 2000; de Jong et al. 2002), their observations remain rather abstract. For that reason, it is still difficult to grasp whether and how cultural differences play a role in shaping concrete policy initiatives. We believe that there is more room, therefore, to usefully analyze the relationship between a particular design of a PSS and the cultural orientation of the receiving country.

Our analysis starts from the presumption that the cultural orientations of a society codetermine the opting, adopting, and adapting of political institutions and policies (Geva-May 2002; Maleki 2015). In this sense, our intention is to integrate cross-cultural theories with the literature on policy transfer, exploring possible connections between the two and contributing to closing knowledge gaps. In doing so, we will set the scene by briefly outlining the emergence and recent diffusion of private sponsorship schemes in the field of migration policy (“The Proliferation of Private Sponsorship Schemes” section). An original effort to integrate cross-cultural theories and policy transfer studies follows in “The Role of Societal Culture in the Policy Transfer Process” section, theorizing affinities and interconnections. The “Dimensions of Societal Culture” section seeks to introduce the two operationalizations of societal culture at the national level adopted in this study, the Hofstede dimensions and the Global Leadership and Organizational Behavior Effectiveness (GLOBE) model. “The Influence of Cultural Factors on Design Choices of Policy Transfer: the Case of PSS” section casts a comparative light at specific design features of PSS and associates them with their respective cultural contexts. After revisiting some preliminary points as regards cultural compatibility and policy success in light of our findings in The “Cultural Factors and Policy Transfer Success” section, we provide some concluding remarks and policy recommendations in the “Conclusion” section. Notably, our approach is markedly comparative, qualitative, and explorative in nature.

The Proliferation of Private Sponsorship Schemes

For a long time, PSS have been unique to Canada, where the sponsorship of a refugee or refugee family has been an integral part of the country’s refugee policies for over 40 years. When the 1976 Immigration Act formalized the existing practices, private sponsorship had already been operating in an ad hoc manner for a decade. Two years later, the official Private Sponsorship of Refugees Program (PSRP) started, allowing private citizens, in groups of five, or in cooperation with governmentally recognized community organizations, so called “sponsorship agreement holders”, to identify a vulnerable refugee for whom they would be willing to bear full emotional and financial responsibility for 1 year (Treviranus and Casasola 2003, p. 184). Among others, this includes assistance in finding appropriate accommodation, language lessons, health care, foreign credential recognition, and support in understanding the labor market. In their application for sponsorship, the sponsors can either name a specific individual or accept a referral by the visa officer of a refugee in need. Notably, the selected privately sponsored refugees arrive in Canada as regular residents and are granted permanent asylum (Labman 2016).

In 2013, the Canadian government amended its private sponsorship regulation to add a new component, termed the “Blended-Visa Office Referred (BVOR) program” (Labman 2016; Lenard 2016; Labman and Pearlman 2018). This addition enables refugee support in the form of a more explicit public–private partnership between specific citizens and the Canadian government. Whereas the original PSRP invites Canadian citizens to select individuals abroad and to raise the full cost of their first year in Canada, the BVOR program offers to share the financial costs between private groups and public agencies. Another difference concerns the selection process: in consultation with the UNHCR (which recommends refugees for resettlement), the government pre-identifies refugees in need and clears them for travel. Canadian citizens who have themselves been approved for sponsorship are then provided with the “BVOR list,” which characterizes refugees by some basic demographic information, including country of origin, age, family structure, sex, and specific medical (including mental health) needs. The sponsors then ask for a “match” with an individual or family, whose requests are considered by a “matching center” responsible for finding appropriate “matches” (IRCC 2018a). In sum, whereas Canadians participating in the regular PSRP select refugees on their own and take on the full costs of the first year, sponsors in the BVOR select among refugees pre-vetted by the government of Canada in collaboration with the UNHCR. And, while they still bear the full emotional challenges of settlement for the year, the financial costs are split with the government.

Over the course of time, several countries have taken up on the idea of private sponsorship. Adoption, however, was never extremely widespread in all parts of the world. In 2013, a comparative study on best practices in the integration of resettled refugees found no example of such a program in Europe (Papadopoulou et al. 2013). In 2015, Kumin identified only a handful in the EU (Kumin 2015). And, by that time, some of the existing schemes had already been terminated as they were devised as temporary initiatives. In the last few years, however, the Syrian refugee crisis seems to have provided a renewed impetus for the introduction of PSS in various regions (ICMC 2017). Recently, a group of six countries (Canada, UK, Ireland, Argentina, Spain, and New Zealand) reaffirmed their pledge to private sponsorship in a joint statement, attesting to the earnestness of ongoing initiatives (IRCC 2018b).

In addition, the European Commission has picked up on the idea and has adopted a more proactive attitude towards PSS. The 2017 State of the Union of European Commission by President Jean-Claude Juncker reads: “[…] the Commission encourages Member States to set up private sponsorship schemes allowing private groups or civil society organisations to organise and finance resettlements in accordance with national legislation. To this effect, the Commission has invited the European Asylum Support Office (EASO) to coordinate a pilot project on private sponsorship schemes with interested Member States” (European Commission 2017). In 2018, EASO reported that 13 member states had shown preliminary interest in taking part in this pilot project (EASO 2018). We may, therefore, foresee the introduction of new PSS in the near future. Their erection, however, is still uncertain and the policy design features of these schemes are as yet unknown. The EASO pilot, though, shows the timeliness and relevance of an exercise that analyzes the cultural compatibility of sponsorship schemes.

Acknowledging the fact that there is no uniformly endorsed definition of PSS and considering that there are various types of private sponsorship (Kumin 2015), we have chosen to focus on sponsorship as part of government-managed resettlement efforts and sponsorship as an additional resettlement channel, in contrast to purely private initiatives (Fratzke 2017). In this paper, we compare the characteristics of PSS in a number of countries—most of which are EU member states—through the lens of societal culture. In addition to European countries, we have included Canada as the earliest adopter and main policy donor of private sponsorship to the comparison, as well as Australia, which has been an important extra-European adopter of the Canadian model (Kumin 2015). Moreover, incorporating Australia into the analysis broadens the geographical scope of our study and could hint to a more general applicability of our findings outside of the European framework. We mostly draw on data from a recent study of the European Commission that scrutinized and compared all private sponsorship programs initiated within the last decades within the EU (European Commission 2018).

The reasons for lying the main focus, although not exclusively, on EU member states are at least threefold. First, the EU has acted as a forerunner in pushing for private sponsorship within its member states, as illustrated above. Scrutinizing policies adopted in EU member states is therefore of particular pertinence to current practice in migration policy. Second, next to Canada and Australia, the selected EU countries present an interesting diversity of national cultures, thus enabling a meaningful comparison based on cultural differences. Third, the spread of PSS has so far mainly been limited to European countries, with only few examples outside that geographical context (notably Argentina, Australia, and New Zealand). Finally, the chosen compilation allows us to show the diversity of ways governments can collaborate with private actors in resettlement efforts (Seawright and Gerring 2008), from which a number of core policy design choices can be derived (ICMC 2017).

Since there is an abundance of scholarship on Canada in particular, we aim to diversify the picture and to broaden the current state of knowledge by including less well-known, potentially equally valuable models. Although Poland, the Slovak Republic, and the Czech Republic briefly had private sponsorship schemes in place, these are excluded from our analysis because they were small in scale, limited in time,Footnote 1 and focussed on offering refuge to a particular group of persecuted Christian minorities only. Table 1 shows an overview of the size and durations of PSS in the analyzed countries.

Table 1 Overview of PSS in nine analyzed countries
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The Role of Societal Culture in the Policy Transfer Process

Many governments and public institutions across the world face similar policy challenges. In their quest for fitting solutions, inspiration and advice are increasingly drawn from other countries and contexts. This widespread phenomenon has received considerable attention and a rich variety of different labels in the policy analysis literature, including “lesson-drawing” (Rose 1991), “institutional transplantation” (de Jong et al. 2002), “policy diffusion” (Simmons and Elkins 2004), “policy mobility” (McCann 2011), “policy translation” (Stone 2012), and “institutional bricolage” (de Jong 2013). The commonalities of all of these approaches are conceptualized by the work of Dolowitz and Marsh (1996, p. 344), who propose the term “policy transfer” to describe “a process in which knowledge about policies, administrative arrangements, institutions etc. in one time and/or place is used in the development of policies, administrative arrangements, and institutions in another time and/or place.” Policy transfer scholars have identified a wide array of external and internal factors that impact when, why, how, and to what extent a given policy is transferred and adopted. Dolowitz and Marsh (2000) and later de Jong et al. (2002) introduced their own frameworks for analyzing policy and institutional transfer. Table 2 presents the similarities and differences of our nine cases on four core factors extracted from these frameworks.

Table 2 Policy transfer framework
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As the table indicates, all cases under study have voluntarily adopted the policy. In addition, all countries have adapted the features of the transferred policy to their specific context, as opposed to direct copying. The precise differences of these will be elaborated at greater length in later sections. Of course, there are more nuances behind this binary classification, in that some countries remain closer to the Canadian original (Australia, UK, Ireland), whereas others have adjusted the core policy in order to better respond to local needs (notably France and Italy).

As regards the broader context within which the transfer occurs, de Jong et al. (2002) roughly distinguish between regular situations on the one hand and emergency situations on the other. The latter are characterized by a sense of urgency creating a unique policy window, including national crises, political turmoil, and systemic transformations. All but the Canadian PSS were adopted in response to, or at least in a context heavily framed by the Syrian civil war and subsequent migration flows (ICMC 2017; European Commission 2018). Although some of the countries studied were more affected by the Syrian crisis (e.g., Italy, Germany, France) than others (e.g., Australia, Switzerland, Ireland), all of the adopted policies were influenced by an “emergency” narrative to some extent, whether perceived or real (see e.g., Mushaben 2017).

Finally, we observe important cultural differences among the cases as evinced in the variety of cultural families as identified in the well-known GLOBE project (House et al. 2002). To employ the methodological jargon of comparative research, this setting roughly resembles a Most Similar Systems Design where multiple control variables are constant across different case studies to account for the role of one particular independent variable (Anckar 2008). This study introduces societal culture as an important factor to be considered within the policy transfer framework so as to co-explain differing design choices.

Dolowitz and Marsh (2000) contend that the ultimate success or failure of a policy transfer is contingent upon one or several factors within this broader conceptual framework. In this regard, they explicitly acknowledge the role of context, including culture, but fail to elaborate on this aspect in more detail. We believe that within the theory on policy transfer, culture plays an overlooked and underexplored role. Employing societal culture as an independent variable in shaping the processes and outcomes of policy transfer has the potential to contribute to a better understanding of the dynamics and ultimate success of policymaking (Geva-May 2002; Peck 2011). In conceptualizing the role of societal culture within the existing policy transfer framework, two interrelated, complementary models come to mind (Steiner-Khamsi 2014). On the one hand, societal culture may influence the extent to which a policy outcome would succeed or fail. In this outcome-centered perspective, culture effectively operates as an ex post determinant of policy success, measured in terms of policy acceptance and effectiveness (Fawcett and Marsh 2012; Maleki and Bots 2013; Batory et al. 2017).

On the other hand, societal culture plays an undeniable role in shaping the input and throughput sides of policy transfer processes. For example, a number of researchers have explored the role of individual policy entrepreneurs in “translating” (Sakai 2006) between cultures and shaping the learning process more generally (Stone 2004; Lendvai and Stubbs 2007; Randma-Liiv and Kruusenberg 2012). Similarly, policy mobility scholars assume context dependency and highlight the crucial role of “translators” for the adaptation of urban policies (Peck 2011; Zapata and Zapata Campos 2015). Stone (2000) identifies at least eight different types of agents involved in the transfer process, including politicians, bureaucrats, experts, pressure groups, and international organizations. All of these actors are inevitably influenced by their immediate cultural environment in their preference formation (Wildavsky 1987; Weyland 2006). Evans (2009) stresses how culture may function as a “cognitive obstacle” in the pre-decision phase. In the same vein, policy makers may be more attracted to culturally proximate policies and practices: “[T]here are in-built cultural prejudices towards certain jurisdictions,” leading to implicit selectivity in the lessons drawn (Stone 2017, p. 60). In institutional theory, seminal literature on “institutional bricolage” goes even further by contending that formal and informal institutions are deeply intertwined and often cross-fertilize each other. As Cleaver (2002, p. 13) puts it, “‘bureaucratic’ institutions may be ‘socially embedded,’ but are not inevitably so, while processes of bricolage may result in the bureaucratisation of ‘traditional’ cultural or social arrangements.” In this sense, integrating culture into policy transfer means combining informal and formal features to gain a better understanding of the “institutional whole.” More recent studies on such bricolage activities confirm how policy actors explicitly and strategically employ cultural sensitivity when absorbing foreign institutions (de Jong 2013; Frick-Trzebitzky 2017; Koppenjan and de Jong 2018). In culturally diverse societies, these choices may well be reflections of majority culture and power relations at large, as critical institutionalists have argued (Cleaver and Whaley 2018). In a nutshell, before and throughout the policy process, brokering entities mediate between different knowledges and cultures, with decisive implications for the outcomes (Daniell 2014). Finally, given the pervasiveness of culture as a social force (Kluckhohn 1951; Hofstede et al. 2010), it is difficult to imagine any aspect within the policy transfer framework that is completely isolated from cultural influences.

Both processes of reception and translation along the transplantation cycle push the culture issue to the forefront, calling for increased empirical research. In this regard, the seminal work of Steiner-Khamsi (2014) lays out the various normative and analytical questions involved in undertaking such a task.

After defining and operationalizing societal culture for the purposes of this study, we seek to shed light on its concrete manifestations in the selected case study of private sponsorship diffusion. Following the above-introduced dichotomy, the focus of our analysis will lie on the influence of culture on the input and throughput phases of the policy transfer process. Specifically, we propose that culture informs particular choices in the design of transplanted policies. Although the output side will be briefly touched upon in the “Cultural Factors and Policy Transfer Success” section , any definitive conclusions in this regard are not (yet) feasible in the selected case study due to a lack of empirical evidence. Regardless of that restriction, policy transfer theory would suggest that cultural bearing on policy design choices ultimately relates to the success or failure of the transplanted policy (Dolowitz and Marsh 2000).

Dimensions of Societal Culture

In political and policy sciences, societal culture is considered an “informal institution” as a set of unwritten rules, values, interpretations, and behaviors which are shared and learned in a society. However, the concept of culture has proven notoriously difficult to grasp and categorize theoretically. As a social construct, it escapes clearly definable boundaries, rendering culture a somewhat elusive phenomenon that is highly contextual. This ambiguity has contributed to a bulk of controversial, conflicting, and complementary definitions and conceptualizations (Kluckhohn 1951; Keesing 1974; Rayner 1991; Douglas 1992; Triandis 1996; Hofstede et al. 2010). We will not reiterate these legitimate debates here and point to the work of other scholars who have taken up that task (Hofstede et al. 2010; Daniell 2014).

An equally fervent scholarly dispute has evolved around the notion of “national culture,” that is, the common cultural bond felt between individuals within a nation in terms of norms, behaviors, and underlying values. While some dismiss the idea of a somewhat homogeneous cultural identity confined to the purely administrative borders of nation-states as illusionary and inaccurate, citing examples of arbitrary border drawing in Africa and elsewhere (Wallerstein 1990; Anderson 1991; McSweeney 2002), others contend that many nations have indeed historically developed as whole social constructs (Minkov and Hofstede 2012). Admittedly, it is impossible for the variety of cultural expressions to be fully captured through a methodological focus on states only.

Acknowledging this limitation, however, nations do constitute the institutional, political, and administrative frameworks in which policies are created (Ronen and Shenkar 1985). In our view, this renders comparisons between countries, a legitimate and useful tool to understand public sector differences. A number of different, competing frameworks have been introduced to operationalize national culture for comparative research (see Maleki and de Jong 2014 for a comprehensive overview). For the purposes of our analysis, we have adopted two distinct cross-cultural models as empirical instruments to dissect the role of societal culture in the proliferation of PSS.

Hofstede’s Model

One of the most widely accepted and commonly used approaches has been introduced and continuously updated by Dutch sociologist Geert Hofstede, who defines culture as “the collective programming of the mind that distinguishes the members of one group or category of people from others” (2001, p. 9). Drawing on data gathered from global surveys of IBM employees, Hofstede initially identified four cultural dimensions (i.e., individualism vs. collectivism, power distance, uncertainty avoidance, and masculinity vs. femininity) and adopted two others in later years, assigning each country an individual score that can be employed for comparative ends (Hofstede et al. 2010). Although both his reasoning and methodology have been criticized from multiple angles (McSweeney 2002), his dimensional framework continues to be influential in the field of cross-cultural research, with Hofstede himself having addressed much of the criticism faced (Hofstede et al. 2010; Hofstede 2011).

Considering the set of countries of this study, many of them show similar scores on Hofstede’s dimensions of individualism and power distance, making their comparative analysis less interesting for the purpose of this study. Other dimensions show more variety. Out of Hofstede’s dimensions, our analysis relies on uncertainty avoidance. In a nutshell, uncertainty avoidance deals with a society’s tolerance for unknown and unfamiliar situations. Highly uncertainty avoidant societies are likely to favor clear structures, behavioral codes, and rules, even if not obeyed. Uncertainty is perceived as a “threat” that must be controlled (Hofstede 2011).

We restrict our focus to this one dimension for a number of reasons. First, uncertainty avoidance tends to be one of the rather uncontroversial and clearly defined of Hofstede’s dimensions. Second, we hypothesize uncertainty avoidance to be of particular relevance to policy making in general and policy transfer in particular. Much bureaucratic activity is geared towards creating foreseeability and stability, in contrast to private sector organizations who are more inclined to take occasional risks. Third, uncertainty avoidance is related to public regulation in that government is expected to structure public life and minimize ambiguity (Hofstede 2011).

The GLOBE Project

Another influential operationalization of societal culture comes from the GLOBE study (House et al. 2004). It sees culture as the “shared motives, values, beliefs, identities, and interpretations or meanings of significant events that result from common experiences of members of collectives and are transmitted across age generations” (House et al. 2002, p. 5). Methodologically, GLOBE relied on global surveys of roughly 17,000 managers in different industrial sectors, with a particular twist: instead of only describing their perspective of national culture, respondents were also asked for their normative views, that is, how should be rather than how is. Inspired by Hofstede’s earlier work, the GLOBE scholars introduced nine dimensions of national culture (i.e., in-group collectivism, institutional collectivism, power distance, uncertainty avoidance, performance orientation, assertiveness, humane orientation, gender egalitarianism, and future orientation), some of those mimicking and confirming the Hofstede categories (Hofstede 2011). While a few of them are perceived as problematic and confusing (Hofstede 2006; Venaik and Brewer 2010), others seem innovative and unique (Maleki and de Jong 2014).

In assessing cultural influences on policy transfer design, our focus lies on the future orientation dimension, defined as “the degree to which individuals in […] societies engage in future-oriented behavior such as planning, investing in the future, and delaying gratification” (House et al. 2002, p. 6). Although there is a conceptual association between GLOBE’s future orientation and Hofstede’s uncertainty avoidance (Maleki and de Jong 2014), a notable difference between the two can be discerned since the former focuses on a more general attitude towards future commitments.

The Influence of Cultural Factors on Design Choices of Policy Transfer: the Case of PSS

There have been multiple attempts at comparing different models of PSS by means of categorizing specific policy choices (Kumin 2015; ICMC 2017; Fratzke 2017; European Commission 2018). Rather than replicating those classifications, we seek to focus on features that may be affected by the national cultural context. More generally, differences among PSS can be divided into sponsor-related choices on the host side and beneficiary-related choices on the applicant’s side.

In matching cultural properties with institutional arrangements, we aspire to determine degrees of cultural (in)compatibility. Considering the contested nature of the concept of culture, as elaborated previously, this is a necessary simplification. The idea that full cultural congruency with a given transplant can be established is illusory. For this very reason, we refrain from making a binary distinction between compatibility and incompatibility. Rather, there is a wide spectrum of thinkable interactions between cultural features and policy choices. In acknowledging and addressing this limitation, the arrangements under study are tentatively positioned on a low–mid–high scale that evaluates the compatibility of PPS design choices and the dominant cultural orientation of a country. Here, a high compatibility indicates that a particular design feature is quite compatible with what we would have predicted when looking at the societal culture. A “low” score means that we see a low compatibility between the two. In the case of a “medium” score, the relation between design choice and societal culture is less evident. Below, elaborations that are more detailed are provided for the various scores.

Sponsor-Related Design Choices

Regarding the nature and commitment of the sponsors, we propose that three policy choices show a relevant link to culture in general and to a country’s score on Hofstede’s uncertainty avoidance dimension in particular (Table 3). This selection is also motivated by comparative considerations, in that other sponsor-related design features are difficult to categorize and less likely to be culturally dependent.

Table 3 Sponsor-related design choices and cultural scores
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First, there are differences in the sponsoring entities. Italy, France, and Portugal, for example, allow only pre-vetted organizations and NGOs to function as sponsors. Countries like Canada, Australia, or UK, in contrast, have mostly relied on groups or communities to share the sponsoring responsibilities, although some involvement of professional organizations is sometimes required (Labman 2016). Finally, in Germany, Switzerland, and Ireland, individuals usually incur the full responsibility alone. In our view, this organizational model is the most apt to prevent uncertainty because the organizational resources in terms of knowledge, staffing, and financial means increase professionalism and reduce the risk of failure during the transitional process.

Second, some countries require sponsors to be legal residents of the destination country, whereas others do not (European Commission 2018, 52). Presumably, allowing only legally resident citizens to act as sponsors decreases uncertainty and risk for the government and the proper functioning of the program.

Finally, countries differ in the duration for which sponsors commit themselves. The incursion of responsibility ranges from 90 days only in Switzerland to 3 years in Germany (European Commission 2018, p. 75). Again, it is assumed that a shorter commitment increases uncertainty, whereas a long commitment reduces associated risk.

aThe scores for both the Hofstede dimension on uncertainty avoidance and the GLOBE dimension of future orientation have been simplified into a three-tiered scale (low–mid–high) in order to allow for cross-comparison. The full scores can be accessed at https://www.hofstede-insights.com/product/compare-countries/ and http://globeproject.com/results, respectively.

Putting these three features together, we propose that uncertainty avoidance serves as the main cultural co-determinant in opting for sponsor-related design features. Societal culture may not directly inform a specific choice, but rather a set of choices. That means that a seeming cultural misfit with a particular feature is deliberately offset by other design choices. For example, the German choice for individual sponsors is offset by imposing a high commitment in terms of the duration of responsibility assumed. This way, the German program is indeed co-shaped by prevalent uncertainty-avoiding culture.

Beneficiary-Related Design Choices

On the receiving end, the main dividing line among various PSS concerns the legal status granted to applicants upon arrival. Broadly speaking, some countries equip refugees with a special national protection status directly upon arrival, typically allowing the beneficiary to work and reside in the country for a limited period of time.

Countries in this category include the policy donor Canada, Australia, Germany, UK, and Ireland. In essence, these visas differ in name and form, but their contents tend to be similar. For example, all countries analyzed grant beneficiaries a residence permit for a considerable period of time, usually renewable after expiry; access to the labor market; access to the education system, etc. (European Commission 2018, 70).

A second class of countries, among them France, Italy, Portugal, and Switzerland, require refugees to apply for international protection status as harmonized in various EU directives post-arrival before the full rights associated with that status are borne. This distinction may seem trivial at first sight, but if one takes into consideration that application procedures before the state authorities can drag on for months or years (AIDA 2016), a requirement to apply for asylum can weigh heavy in the integration process.

Particularly, applicants may be barred from accessing the labor market for a sustained time period, which is in turn likely to affect integration success, as the integration literature suggests (Council of Europe 1997; Nakhaie 2018). Given the probable effect of this design choice on a policy’s long-term success, we argue that countries with a high score on the GLOBE project’s future orientation dimension are more inclined to grant a work permit upon entry. The study of our nine selected case studies corroborates this hypothesis as presented in Table 4. We can see that the adopted decision of whether or not to grant a work permit is culturally compatible for all countries, except for Switzerland. Presumably, refusing the issuance of work permits during a sustained period is incompatible with the high future-oriented culture of Switzerland.

Table 4 Beneficiary-related design choices and cultural scores
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Cultural Factors and Policy Transfer Success

Policy transfer theory hints at the vital importance of a fit between policy design and cultural factors for the successful outcome of a given transfer (Dolowitz and Marsh 2000; Fawcett and Marsh 2012; Batory et al. 2017). This link has been made more explicit in studying models of democracy and institutional transfer, underscoring the value of cultural compatibility (Maleki and Hendriks 2015). The novelty of most PSS and the resulting lack of data on outcomes make an evaluation of the success of these transplants unfeasible, for the time being. Nevertheless, the preceding sections allows for the identification of a few obvious “misfits” between policy design and cultural orientation, or what Dolowitz and Marsh (2000) would attribute to the broader notion of “inappropriate transfer,” i.e., an ignorance of contextual factors in the transfer process with negative effects on outcomes. The most outstanding example in this regard is Switzerland. The Swiss PSS created a high level of uncertainty and ambiguity by allowing individuals, legal residents or not, to sponsor refugees for a period of 90 days only. This was in clear conflict with Switzerland’s mid-range score on uncertainty avoidance. That is, the choice of conferring the sponsoring responsibility upon individual citizens who were not required to be legal residents, and doing so for the short period of 90 days only, created friction with Swiss culture that is somewhat inclined towards avoiding uncertainties of such sort. On the beneficiaries’ side, the program did also not provide for a work permit upon entry, in stark contrast to the country’s long-term orientation. Theory suggests that such an incompatibility would materialize in negative effects on the policy’s overall success. And indeed, the Swiss sponsorship program was stopped after 3 months only. The exact reasons behind the discontinuation remain unknown, but it has been suggested that authorities were overwhelmed by a flood of applications (Kantor and Einhorn 2016). On the other hand, many models with culturally compatible adaptations to the Canadian model seem to show preliminary signs of success. For example, both Ireland and Germany are said to have new PSS in the making (Hueck 2018), building on previous experiences.

It is important to note that cultural compatibility is not a panacea for an effective transfer. We observe some design choices that are in line with the societal culture of a country, but paradoxically, this compatibility may turn out to be detrimental to the success of policy transfer. Cultural analysis can co-explain why different countries adopt different design choices. However, that does not mean that a fit between the cultural orientation of a country and a specific design choice is always and necessarily beneficial to the effectiveness of the transfer. For example, some of the analyzed countries’ policy of withholding sponsored refugees’ work permits upon entry (i.e., France, Italy, Portugal) may actually contribute to the failure of integration of the applicants while being perfectly compatible with (and likely influenced by) cultural orientations. While we have shown that societal culture informs such choices, the solutions adopted may be irrational and at odds with widely recognized scientific insights. This is what Dolowitz and Marsh (2000) describe as “uninformed transfer”.

Thus, bringing cultural analysis into the field of policy transfer design will help policy makers in two ways: first, to recognize essential choices that should be culturally compatible for a successful transfer and second, to recognize other critical choices that might be replaced with harmful culturally preferred options. In this case, integration literature (Council of Europe 1997; Nakhaie 2018) suggests that granting work permits during the transition period is a crucial design choice that should be adopted even by those countries leaning towards a short-term orientation, e.g., France or Italy. Essentially, this paradoxical situation epitomizes a conflict between the public acceptance of a transferred policy, which is likely increased by a cultural fit (Karimi and Toikka 2018), and the broader effectiveness of a policy depending on a wide range of factors on the other side (Czaika and De Haas 2013).

Conclusion

Culture is widely recognized to play a key role in migration policy. We hope to have added to this line of research by showing how societal culture co-determines the design of transferred policies. Private sponsorship of refugees is one such policy that is currently debated, transferred, and adapted across many different countries and contexts. In understanding the dynamics of these transplantations, cross-cultural theories provide a valuable tool for comparative research. Our study of PSS in nine different countries has shown that the cultural dimensions of uncertainty avoidance (Hofstede) and future orientation (GLOBE) can co-explain specific design choices. Clearly, the limited scope and the interrelatedness of the variables employed severely constrain the general applicability of our findings. Rather, the study design provides a starting point for a more thorough and systemized inquiry into the cultural dimension of the transplantation or translation process.

Based on policy transfer and cross-cultural theories literature, we predict that countries where low cultural compatibility between design and culture is found will likely face more challenges in the implementation of the transferred policies, as seen with the case of Switzerland. But should cultural compatibility be the guiding principle for policymakers involved in transfer processes? In our view, culture does not merely serve as a normative criterion with a view to generating cultural “fits.” While cultural compatibility may positively contribute to the effective outcome and the success of cross-national policy transfer, it also informs design choices in the policy formulation and throughput phases, where it can have negative effects on the efficacy of the transferred policy by fuelling a conscious or unconscious bias towards culturally preferred decisions.

Whatever the effects, our study advocates the need for policy makers to be aware of societal culture as a mostly hidden parameter in policy transfer. In the case of PSS, we argue in favor of adopting a culturally sensitive perspective more often and more explicitly when transferring the Canadian model to other contexts, recognizing both the positive and the negative effects of cultural co-determination. In a nutshell, societal culture matters, and accounting for its role allows policymakers to avoid pitfalls and design more effective policies when drawing lessons from the experiences of other countries.

To repeat, our study has ventured into unchartered grounds, both conceptually in bridging the previously separate fields of cross-cultural theory and policy transfer literature as well as empirically in analyzing a fairly recent case study on migration policy. Considering the limited number of PSS in place, the exclusive application of two selected cultural dimensions, and the novelty of our analysis, we do not claim that our findings are directly generalizable. We do, however, believe that cultural compatibility provides a relevant and original perspective on PSS that allows us to usefully identify meaningful affinities between the designs of such schemes on the one hand and societal cultures on the other. In our view, these affinities are worthy of being taken into consideration when transferring the idea and the designs of PSS from one country to another in order to increase policy-makers’ cultural awareness and ultimately ensure a successful policy transfer. Finally, the integration of societal culture as a distinctive contextual feature into the theory of policy transfer promises a relevant extension of existing models.

As more detailed data becomes available about the outcomes of PSS in the selected countries, the arguments put forward here will require reconsideration and further refinement. Similarly, institutional transplants in other policy areas could benefit from increased research on the particular effects of cultural variables. Finally, the undertheorized role of societal culture deserves a more thorough conceptual embedment in the policy transfer literature.