Business and Human Rights (BHR) scholarship has long been dominated by two modes of analysis: doctrinal and policy-oriented accounts of norms—the UN Guiding Principles, due diligence legislation, the draft treaty—and structuralist critiques that treat accountability as impossible within the foundational arrangements of capitalism. What both approaches tend to obscure is the people who make accountability happen. Norms and public policies, as Raluca Grosescu and John G. Dale remind us in their introduction, ‘do not enact themselves’ (p. 3). This open access volume, an output of the European Research Council CORPACCOUNT project on transnational advocacy networks, is the first collection to examine critically the role, limitations and internal fragmentation of social activism for corporate accountability across Africa, the Americas, Asia and Europe. It is a welcomed corrective.
The editors define corporate accountability expansively, as the wide set of legal and non-legal mechanisms designed to denounce corporate abuses and enforce binding duties, sanctions and remedies—explicitly excluding voluntary self-regulation and corporate social responsibility. On this basis, the fourteen chapters advance three interlocking claims. First, civil society and social movements—rather than corporate self-governance or state determination—are the principal drivers of corporate accountability today, particularly where activists build coalitions across borders and professional sectors. Second, the global corporate accountability movement is fragmenting along ontological, ideological, regional and professional lines, divided over the very meaning of, and solutions to, corporate violence. Third, transnational activism is a ‘Janus-faced paradigm’: indispensable for the survival and visibility of local struggles, yet marked by unequal power relations, discursive domination and funding dependencies between Global North and Global South organisations.
The volume’s three parts develop these claims through diverse case studies. Part I interrogates corporate accountability as a fragmented global cause. Andru Chiorean contrasts two coalitions advocating a binding UN treaty—the anti-capitalist Global Campaign to Dismantle Corporate Power and the socio-liberal ESCR-Net—showing how ideological divisions inherited from Cold War struggles over a New International Economic Order continue to structure treaty advocacy. Henry Rammelt’s quantitative analysis of 260 organisations demonstrates that left-leaning discourse coexists with moderate, litigation-centred repertoires shaped by the search for funding and legitimacy. John G. Dale traces how the Indigenous-led rights of nature movement in Ecuador reshaped corporate accountability strategies in the United States, while Raluca Grosescu examines the tension between liberal vocabularies of Western NGOs and Indigenous narratives in post-civil war Guatemala. Part II turns to transnational campaigns against corporate impunity: East Asia’s war redress movement, where cross-border trial support groups won court victories and fostered regional reconciliation (Timothy Webster); Argentine trade unions and their intersectoral alliances against the economic accomplices of the dictatorship (Victoria Basualdo); the contested Volkswagen do Brasil settlement (Juan Pablo Bohoslavsky and Juan Cruz Goñi); civil society under authoritarian constraint in the East African Community, where Rasul Ahmed Minja identifies a troubling dominance of ‘upward’ over ‘downward’ accountability; due diligence coalitions in France, Germany and Luxembourg (Caroline Omari Lichuma); and strategic litigation in the Netherlands (Thomas R. Becker). Part III examines grassroots activism, including the Roșia Montană anti-mining movement and the investment arbitration that followed it—which Stephanie Triefus and Irina Velicu read as prospective environmental injustice, a community’s legal victory prolonged into ‘green crime’ through arbitration—and memory struggles over forced labour under Franco, (Fernando Mendiola and Juan Carlos García-Funes).
For readers of this Journal, the volume’s most valuable contribution may be its insistence that fragmentation is not merely an obstacle. The editors argue that internal diversity—of experiences, local understandings of (in)justice and repertoires of action—is also the condition under which new critical narratives emerge. The position avoids both the romanticism of accounts depicting global movements as unified communities of principled activists and structuralist fatalism. The chapters on the VW do Brasil settlement and on Guatemala are exemplary here: both show activists splitting over whether negotiated settlements and liberal rights vocabularies constitute meaningful justice or ‘corporate wash’, without resolving the dilemma artificially.
The treatment of the Janus-faced character of transnational activism is similarly nuanced. Several chapters document how Global North NGOs, in order to gain support for Global South causes, must translate demands into vocabularies familiar to Western societies—translations that can distort social realities and, as Grosescu shows for Guatemala, channel funding through Western intermediaries in ways that tie Indigenous movements to liberal agendas rather than to projects of autonomy. Lichuma adds a legislative dimension: European due diligence laws were adopted with little consultation of the Global South communities they ostensibly protect, reproducing the asymmetries they claim to address. Yet the volume resists caricature, offering equally convincing evidence—from East Asia and the Southern Cone—that cross-border cooperation can generate trust, solidarity and concrete judicial outcomes.
I should disclose my position in this debate. The editors engage directly—sympathetically but critically—with the actor-focused research agenda that Leigh A. Payne, Gabriel Pereira and I have developed on corporate accountability and transitional justice ‘from below’, suggesting that earlier work, including ours, depicted pro-accountability activism as ‘rather monolithic’ (p. 2).Footnote 1 Chapter 13, by Pereira and Payne, extends that agenda within the volume itself. Drawing on the Corporate Accountability and Transitional Justice database and the ‘La Fronterita’ litigation in Tucumán, Argentina, they propose a ‘domestic boomerang’: victims located far from urban centres—‘from below the below’—amplify their demands through transnationalised institutional innovators in national capitals, sometimes obviating international pressure altogether. The argument refines both Keck and Sikkink’s classic boomerang and our Archimedes’ lever framework, and it resonates strongly with my own doctoral research on Colombia, which found that variation in the relative power of victims and companies—rather than international pressure alone—explains why an ‘unlikely’ case became a regional leader in judicialising corporate complicity,Footnote 2 and with our subsequent findings on Argentina.Footnote 3
A quieter thread running through the volume deserves emphasis: the constitutive role of academia within these networks. Becker expressly counts epistemic communities—alongside lawyers, political activists and journalists—among the professional groups whose cooperation makes strategic litigation possible, as does Lichuma in her account of the coalitions behind the French and German due diligence laws. Pereira and Payne go further, documenting how Argentine tribunals have admitted historians and social scientists as expert witnesses in crimes against humanity trials, how a governmental corporate accountability unit was staffed by prominent academics, and how a research agreement with the National Research Council was mobilised as part of the accountability strategy—indeed, the authors participate directly in the litigation they analyse. The lesson for this Journal’s readership is direct: scholars are not external observers of corporate accountability struggles but actors within them, whose research, testimony and convening power can help lift the weight of accountability in favour of victims. The volume is an invitation to understand—and to assume—that role.
The volume nonetheless leaves avenues open, several of which the editors themselves identify. South–South cooperation remains weak and understudied, and the hypothesis that funding structures explain this awaits systematic testing. The collection’s engagement with the legal architecture of BHR is also uneven: readers primarily interested in the UN treaty negotiations or due diligence legislation will find sustained analysis in the chapters by Chiorean and Lichuma, while other case studies engage the field’s doctrinal debates only lightly—a consequence of the volume’s deliberately sociological ambition rather than a flaw. And as this research agenda develops, Colombia—where the Justice and Peace process and the transitional justice system have produced a singular record of evidence and judicial outcomes on business complicity in armed conflict—would offer fertile ground for testing the fragmentation thesis, given the competing institutional avenues through which accountability has been pursued there simultaneously.
None of this diminishes the collection’s achievement. Grosescu and Dale have assembled a genuinely global, methodologically plural (ethnographic, historical, statistical and comparative) and theoretically coherent volume that moves BHR scholarship beyond methodological nationalism and beyond depoliticised accounts of norm formation. Its actor-focused perspective restores agency—and ambivalence—to the analysis of corporate accountability, showing that the movement’s internal contradictions are as consequential as the veto power of business. That the book is open access should ensure the wide readership it deserves, not least among the Global South activists and institutional innovators whose work it documents. It is essential reading for scholars of BHR, transitional justice and social movements, and for practitioners seeking to understand why some accountability campaigns coalesce and succeed while others fracture.