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A multilevel initiative? The Global Compact approaches global governance problems on three interrelated levels: the international level (through dialogue and learning events), the national level (through the so-called local networks), and the local level (through the participants themselves). This raises the question of the means by which the Compact exercises governance on these three levels and how these means interrelate. On the international level, the Compact acts as a platform for dialogue and learning. Global governance, here, is primarily supported through consensus building and learning among participants regarding the meaning of the 10 principles in practice. Issue-specific engagement platforms (e.g. ‘Caring for Climate’) and/or specific tools (e.g. the Human Rights Impact Assessment Guide) reflect this global consensus and are supposed to stimulate further deliberations and actions. In practice, there are different loci for dialogue and learning on the global level. First, Global Compact Working Groups act as multistakeholder platforms to discuss specific issue areas (e.g. human rights) and to create mutual understanding about governance solutions on a global scale. Second, emerging differentiation platforms, such as ‘Global Compact LEAD’, bring together high-performing participants to share and define best practices, and thus create positive spillover effects for other firms. Third, the triennial Global Compact Leaders Summit brings together executives from business and nonbusiness participants to chart the strategic course of the Compact itself. Dialogue and learning on the international level create consensus-based solutions that are taken ‘downstream’ to the national level where Global Compact Local Networks (GCLNs) embed them in a particular national context. GCLNs are defined as clusters of participants who come together to collectively advance the 10 principles within a particular geographic context (Gilbert 2010). They not only help root the Global Compact within different national, cultural, and linguistic contexts but also deepen the learning experience of participants through activities and events that promote action in support of broaderUNgoals. Currently, GCLNs are fully established in 70 countries, with an additional 22 networks in development. The link between the wider global network of participants and GCLNs is vital for at least two reasons. First, although governance problems often require global consensus, their solution depends on accompanying and contextualized local actions; global principles need to be adapted to local circumstances. Second, GCLNs also act as innovators and can move locally developed best practices ‘upstream’ for global replication and multiplication. Although GCLNs provide arenas for collective action and knowledge sharing, there is not much interaction among local networks. If global governance is really to be addressed by the Global Compact, local networks need to develop a coordinated agenda by sharing knowledge and resources. Addressing global governance gaps, as envisioned by Ruggie (2001, 2002), who was one of the Compact’s architects, requires globally coordinated action. Although the Compact bridges the global–local divide, local actions are often too isolated in single networks, impeding potential spillover effects. Strengthening internetwork collaboration could make a significant contribution to reinforce the Compact’s contribution to global governance (e.g. through the coordination of collective action across networks). Last but not least, participants themselves represent the local level. Whereas GCLNs are clusters of participants attempting to manage implementation, bottom-line changes (e.g. altered business processes) can only occur at the local level via actions of each and every participant. Although there is some anecdotal evidence about how corporations implement solutions that were collectively developed on the global level (Global Compact 2007b,c), we still miss more robust results to judge the real impact of the Compact on the local level. It is remarkable, however, that context-specific partnership projects on the local level (e.g. among businesses, NGOs, and UN agencies) have not yet been very widespread (Global Compact 2007a: 22). A network-based structure? Kell & Levin (2003: 156) envision ‘the entire Global Compact initiative as an extensive wide network of loosely organized stakeholders’. On a basic level, the Compact consists of two types of networks: (1) the global network reflecting the initiative itself; and (2) the GCLNs reflecting clusters of participants from a specific country or region. Taken together, both types of networks stand for the collaborative steering mode that is often associated with global governance (Gilbert 2010). For the Compact, a network-based structure is essential as most of the addressed problems cut across conventional domains and industry sectors, making hierarchical governance neither feasible nor desirable. A network-based structure provides the necessary flexibility to cope with the diversity and fluid nature of the governance issues that the initiative addresses. For instance, it is widely acknowledged that labor monitoring in global supply chains can only be effective if businesses, NGOs, labor unions, and consumer groups start collaborating on a global and local level (Fung et al. 2001). Such collaboration needs institutional arenas where consensus-based solutions can be jointly developed. The Compact’s network-based structure is essential to avoid becoming trapped in a top-down governance approach and allows for establishing a collective capacity to simultaneously govern actions on a global as well as on a local level. A more hierarchical organization would limit the initiative’s ability to address governance gaps, as a ‘commandand- control type’ of steering undercuts the possibility of achieving an intersubjective understanding of global problems. Kell & Levin (2003: 152) put this in a nutshell by arguing that ‘network[s] constitute a viable mechanism for partially filling the governance void of the global economy by engendering consensus around critical social and environmental crises and providing the means to ameliorate them through cooperative action’. In this sense, the network-based character of the initiative is well aligned with its underlying core idea: to voluntarily unite business and nonbusiness actors, and allow them to combine their efforts to contribute to global governance. Although network-based modes of governance are, in principle, open to a variety of participants, such diversity by itself does not guarantee cooperation; actors also need to be motivated and willing to fully commit to the network. The number of recently delisted business participants (over 2,000 as of February 2011) indicates that many firms still fail to