The Callous Caretaker
When Margaret Thatcher died, social media sites in Britain exploded with polarized opinions. As well as splitting along obvious class lines, those either cheering a death or paying tribute to the ‘greatest leader in the post-war era’ could, to a large extent be grouped by geography: those of northern provenance tended to bunch differently from the rest. Some of the bile and vitriol of the first group was tasteless, no doubt. Predictably, those who professed outrage at such outpourings of hatred largely missed the point (sometimes quite deliberately) that the tastelessness was not simply vindictive, but born of a sense of righteous justification. Yet any victory for the haters was clearly pyrrhic. Thatcher’s death was at best a consolation; a booby prize providing the briefest of distractions from the fact that whilst the woman might be dead, her spirit lives on with a vengeance.
Altogether more interesting is the response from Thatcher’s admirers. We all knew the clichés already, and her death provided only an opportunity to rehearse them together at once. This was the woman who, as David Cameron put it, ‘saved Britain’, whilst according to Tony Blair, she was a ‘towering’ leader who put Britain on the track to prosperity by breaking the hold of the unions and ushering in economic modernity. This – the mythos of the right – is why she was a Great Leader. Compared to her, grumble many Tory ultras, her ideological descendants on the Government front bench are mealy wets of the sort Thatcher herself despised, unable to complete the great transformation she started. Inconvenient facts are, as ever, overlooked. The same Prime Minister who pledged to roll back the state consistently saw it swell in size and cost. The champion of British independence handed over, when she signed the Single European Act, more British sovereignty to European bureaucrats than anyone before or since. But those are details, and everyone either knows or ignores them and has done for a long time.
But what if the central plank of the right’s narrative of the great leader is simply wrong? What if Thatcher didn’t force through a period of radical economic change, but was merely the caretaker of processes much deeper and more powerful than she herself ever was? A caretaker, whose main contribution was to add cruelty and callousness to economic processes of change that were set in motion long before she came to power?
One obvious piece of evidence supporting this hypothesis is the brute fact of Ronald Reagan. The reforms Reagan oversaw in the 1980s fundamentally changed the American political and economic landscape, to the point where the two Democratic presidents that have held office since can comfortably be classified as to the right of Nixon. For despite going down in infamy thanks to the Watergate scandal, in practice Nixon continued the LBJ reforms of the 1960s, and his economic policies would now be regarded as a species of communism by much of what has – in no small measure, thanks to the legacy of Reagan – become the mainstream American right. Yet if the old economic adage that when America sneezes Britain catches a cold holds any truth at all, then the political-economic corollary certainly applies, too. Thatcher’s ideological soul mate wrought changes that redefined the US political landscape, and the impact has been felt on this side of the Atlantic. But then, this way of looking at things merely shifts the Great Leader hypothesis one stage further back. What if Reagan, too, was mostly caretaking?
Reasons for questioning the Great Leader hypothesis emerge if one delves into the murky waters of Britain’s complex relationship with its vast tax haven network in the 1960s and 1970s. Doing so opens up a startling story of how the growing power of international finance left governments vainly locking stable doors after horses had bolted, before eventually deciding to let them run as free as they liked.
A good place to start is with an internal memo sent by Inland Revenue officials to their Treasury colleagues on October 18th, 1967. Appalled at the huge levels of revenue being lost to illicit and barely-licit avoidance schemes by wealthy individuals and corporations, the Revenue desperately appealed to the Treasury’s greater might in shutting down such practices. They pessimistically noted that whilst we ‘do not suppose that the Treasury will be able to help us in this…we feel we must leave no stone unturned’. The desperation was palpable: ‘Even a piece of gossip that Mr X. was thought to have made such a transfer would be some help, because we might not hitherto have suspected Mr X. and we can then at any rate launch an attack on him by requesting information’. Despite initial scepticism that it could help, the Treasury soon became strongly sympathetic to the Revenue’s cause. Not, however, because it was especially concerned about tax revenues. During the 1960s, its main priority was capital controls.
With Britain operating a fixed exchange rate and ‘Keynesian’ economic management, it was imperative to manage the movement of currency in and out of the British economy and the wider Sterling Area it controlled. Crucial to economic policy was control of the balance of payments (the difference between the value of imports and exports), which in turn allowed central government to run targeted taxation and spending policies so as to manage the overall level of demand in the economy, only possible with a minimum of external interferences. Employment and inflation were indelibly linked to the matching of national aggregate supply and demand for goods and services, which in turn depended on a well-managed balance of payments, achieved by keeping Britain’s exchange rate pegged at a fixed level. Government policy dictated that money could be moved in or out of Britain only with official permission. (Even withdrawing funds to go on foreign holiday required such permission. Professor Sol Piccciotto, of the University of Lancaster, once showed me his passport from the period, filled with pages of official stamps detailing how much currency he was entitled to take abroad at any one time). Yet Illicit and disguised avoidance schemes – especially of the scale the Revenue was reporting – directly undermined this central economic imperative by allowing individuals and corporations to move capital without government knowledge or permission, distorting and upsetting the balance of payments. Tax evasion (illegal) and tax avoidance (technically legal, but usually only with the help of good lawyers and accountants) were emerging as serious economic problems: such activities undermined British capital controls, and hence national economic policy.
Even worse, the territories facilitating such practices were frequently dependencies of the British Crown, meaning they were inside the sterling area but not under the direct control of Whitehall. They were also granted economic privileges such as the ability to set tax rates and decide banking legislation, which they rapidly began to exploit in the post-war era. Given that, just a month after Treasury officials were alerted to the tax haven problem, Prime Minister Harold Wilson would be forced into the humiliation of a sterling devaluation, it is safe to say that the activity of British tax havens would have come under increasing disapproval in Whitehall at that time. Although the Channel Islands and the Isle of Man would later emerge as leaders of the illicit financial secrecy world, in the late 1960s it was the Caribbean that appeared to pose the biggest threat. (Some fun facts: today there are over 18,000 companies registered to a single building in the Cayman Islands, whilst the tiny Channel Isle of Sark boasts 24 registered companies for every human being on the island. Safe to say that since the 1960s, the growth of world tax havenry, especially in British-affiliated territories, has only accelerated.)
The Caribbean was prominent for several reasons. Most important, however, was that because of the relatively desperate economic outlook of these territories, the more adventurous were increasingly prepared to co-operate in any way desired by wealthy outsiders seeking to hide money. Although Bermuda and the Bahamas were long-established as places to avoid estate dues, or to set up secret trusts to avoid domestically-owed taxes, in the 1960s the Cayman Islands emerged as promoter of the most aggressive schemes whose purpose, as one Revenue official put it, ‘blatantly seeks to frustrate our own law for dealing with our own taxpayers’. As Cayman brazenly expanded its activities, poorer neighbours wanted a piece of the action. The tiny Turks and Caicos Islands began emulating Cayman, much to the alarm of Revenue and Treasury officials desperate to avoid ‘yet another’ tax haven in the sterling area. Yet whilst we still mostly refer to these territories as tax havens, and tax avoidance and evasion are certainly something they facilitate, in reality what they’ve always more fundamentally provided is banking secrecy. Environments in which money can conveniently disappear and then reappear; in which companies that never do a day’s trading can be registered so that books elsewhere can be made to balance; where money can be squirrelled away without anybody asking – or even more importantly, telling – where it came from or where it is going. In the 1960s the Caribbean was hosting a race to the bottom as each territory offered more and more secrecy with less and less oversight, to whoever happened to have the cash. In the early Wild West days of Caymanian financial aggression, suitcases of money and diamonds were flown into micro airports before disappearing into ‘banks’ that were little more than brass plaques on walls, a practice established in Switzerland and Lichtenstein in the 1930s, as described in Nicholas Shaxson’s riveting book Treasure Islands. By the late 1960s, British tax revenues and capital controls were starting to seriously suffer. That made it a national economic issue.
But the problem wasn’t just domestic. Alerted by the Treasury, the Foreign Office was also alarmed. Crown territories supplying secrecy to anybody who had the cash did not represent a prudent international strategy. For a start, the Americans and the French were growing increasingly upset about British territories undermining their tax regimes and exchange controls. The Americans were particularly aggrieved, ‘deploring’ British encouragement of tax havenry because the Caribbean’s proximity meant Island banks were deliberately targeting US investors. France ‘animadverted on the prevalence of paradis fiscaux as yet another undesirable feature of the Sterling area’. More generally, tax havens were themselves potentially deeply unstable. Small populations lacking well-run political and economic infrastructures might not cope well with vast influxes of cash and the corresponding social divisions that moneyed elites would bring. In an era of increased political identification across post-colonial ethnic lines, there was a significant race dimension to the potentially explosive politics of Caribbean territories. Most of the moneyed newcomers, brought into manage accounts and look after brass plates, tended to be white, unlike the impoverished island residents expected to wait upon them. And in the era of decolonization, it was particularly undesirable for emerging African dictators in failing regimes to be using British territories to hide ill-gotten loot they were stealing from their populations. By the end of the 1960s, the Foreign Office joined the Treasury and Revenue in determining to put an end to British provision of illicit financial secrecy.
But not everybody agreed. The then Ministry for Overseas Development (later to become the Department for International Development) objected that these territories simply had nothing else to offer: the only alternative for ‘colonial pensioners’ was a lifetime of dependency on the ‘British dole’. Overseas Development recommended instead that Britain send trained financial advisors to its territories, to teach them how to provide secrecy properly, to make sure it was done right. The Treasury and Revenue balked at such suggestions, closing them down. Much more important, however, was the Bank of England, to whom the Treasury appealed for data and expertise. For the Bank had very different ideas about where its priorities lay, and whose interests it existed to serve.
Repeatedly declining to co-operate with a working party established by the Treasury, Foreign Office, and Revenue, the Bank dragged its heels and refused to share meaningful information. When asked for data it would delay for months before sending across a handful of irrelevant numbers, citing confidentiality as an excuse. As the months dragged by, it became increasingly clear that the Bank had no intention of helping the Government. Acting as the champion of the interests of the City of London, the Bank protected the benefits British finance was steadily reaping from the exploitation of banking secrecy. For what British-affiliated tax havens facilitated was the ability for banks and other financial institutions to move money quickly, and without disclosure, in and out of the sterling area. This meant avoiding both the interest of government officials, but also the delays associated with having to acquire permission for capital movements. Due to the impact on the balance of payments this was of direct detriment to the British revenue and central economic policy. Despite being a nationalized institution, therefore, the Bank of England consciously and deliberately obstructed the attempts of Whitehall to administer economic policy in what was perceived to be the national interest. (La plus ça change, some might say.)
Realising that the Bank would not be forthcoming with assistance, the Treasury, Foreign Office, and Revenue pressed ahead under their own steam. Painstakingly putting together reports, organizing fact-finding visits to tax havens, and co-operating on cross-departmental lines, civil servants eventually produced a lengthy report on Britain’s tax haven problem, finalized and published in 1971. Although the bulk of the document was divided into three corresponding parts to reflect the relative concerns of each department, it nonetheless opted for a strong line in order to clamp down on British territories engaging in abusive financial practices. And at first the report appeared destined to become more than just another shelf-filler. Public awareness of tax haven issues was growing, with questions being raised in Parliament and enough of a head of steam built up within Whitehall for memos to emerge indicating that the Minister of Finance, and Treasury Ministers of State, were taking a direct interest, keen to implement the findings of the report and end the ‘quite uncivilized’ behaviour of Cayman and its emulators.
But just as all seemed about to change for Britain’s tax havens, it didn’t. At this point the historical record becomes decidedly murky, a clear picture hard to obtain. Noticeably, the individual civil servants who for years doggedly pursued the tax haven issue suddenly disappear from the records. Coincidence, or were they purposefully moved on? We’ll probably never know. In any case, their replacements thought the tax haven issue irrelevant, and promptly shelved the report it had taken four years to painstakingly assemble. But also, and undoubtedly more importantly, 1972 saw a fundamental change in the global economic game. In 1971 Nixon had ended dollar-gold convertibility, heralding the end of the Bretton-Woods era of international economic agreement that underpinned domestic Keynesian tax-and-spend policies. This decision had a massive impact on Britain’s ability to keep a fixed exchange rate and manage its balance of payments, and in turn its domestic economic management. Following Nixon’s action, in 1972 Britain contracted the Sterling Area and placed the Caribbean territories outside exchange controls, in a rearguard effort to keep a grip on the exchange rate. (One which would eventually fail: Wilson was forced into a second, credibility-eroding sterling devaluation in 1976.) The Treasury and Foreign Office lost their main incentive to care about the activities of Britain’s Caribbean tax havens, and interest immediately waned. Indeed, if anything the Treasury now began to see tax loss as small beans compared to the capital that could be diverted into the City of London out of North America and other countries via Britain’s tax haven network operating under the watchful guidance of the Bank of England. Nothing changed for the beleaguered Inland Revenue. But this minnow of a department could pack no punch on its own. (This conspicuously continues to be the case today: compare the political attention currently paid to the £1.3 billion lost annually to benefit fraud, to the £30 billion tax gap estimated by HMRC arising due to tax avoidance and evasion.) After 1972, the impetus died, and Britain’s tax havens received freer rein than ever.
The ongoing relation between Britain and her secrecy jurisdictions was not, however, without irony. Having initially shelved the original working party report, the next generation of Treasury civil servants soon found themselves drawn into the morass of tax haven skullduggery. As outrage at offshore financial activities grew, the issue was forced back onto the agenda. In 1974 the so-called Lonhro scandal erupted, revealing extensive tax evasion and corporate corruption centering on Caymanian financial services, but indelibly connected to UK individuals and companies. A flurry of activity in Whitehall followed as government ministers prepared to face tough questions in Parliament about the extent to which the UK did not adequately control territories facilitating corruption in the metropole. Around the same time, Chancellor Dennis Healey received a correspondence from an outraged constituent on the matter of tax avoidance and evasion, along with a copy of the magazine Tax Haven Review, apparently intended for bankers, lawyers and accountants, which had mistakenly fallen into the constituent’s hands. (We know that Tax Haven Review was not intended for a wider audience, because the subscriber information promised that to ‘maintain the confidentiality of this privately circulated newsletter, the full name of Tax Haven Review will not appear on the envelope’. Tax haven activities were accorded the public unacceptability of something like pornography: going in for this sort of thing was clearly best kept private.)
During the 1970s the Channel Islands and Isle of Man came into their own as leading providers of financial secrecy, co-operating overtly with the Bank of England in hosting conferences advising individuals on how to avoid UK-owed tax. The MP Tony Benn indignantly forwarded a letter from one of his constituents on to Healy, which objected to the Bank’s openly colluding in tax avoidance schemes in a process that was surely ‘just a bit too sordid to be true’. By the mid-1970s it was apparent that contracting the sterling area had not put the genie back in the bottle. On the contrary, Britain’s tax haven network was still leaking capital and damaging the UK balance of payments, due to the secrecy it provided. The Channel Islands had now joined the game at maximum pace. The Treasury was still powerless in getting things under control. The new generation of civil servants, who in 1972 had dismissed their predecessors’ working party as irrelevant, belatedly came to admit that the findings of the earlier report remained troublingly relevant, and ought to be revived.
But in 1979 the changes made in 1972 were effectively repeated, but now at full throttle. Following the collapse of Bretton Woods, and the perceived failure of Keynesian economic policy at home, the new Thatcher government abandoned capital controls and moved the UK to a floating exchange rate. It is worth asking why capital controls had to be abandoned. Certainly, the perceived and real failure of Keynesianism, and the ushering in of the era of monetarism – which demanded open borders and floating exchange rates as taxation and spending were superseded by the setting of base interest rates as the primary tool of economic management – can only be explained via myriad complex and interconnected factors. Of particular importance is the end of the post-war boom, American economic policy after the decision to abandon dollar-gold convertibility, and the oil shocks of the early 1970s. But not insignificant is the fact that by the end of the 1970s the enforcement of capital controls was anyway becoming impossible for clunking government administrators of all nations. The invention of the telex machine, in conjunction with cheap access to transoceanic phone lines, meant that those willing to bend and break financial rules could move money in and out of jurisdictions far faster than government officials could chase it down or keep track of it. Tax havens, and the secrecy they provided, played a crucial part in this. One did not need to physically fly money into the Caribbean if one had a trustworthy banker with a good telex connection, and space for a brass plate. In significant measure capital controls were abandoned by the end of the 1970s because they had anyway became increasingly unworkable, in no small measure thanks to global finance deepening its ongoing love affair with cross-border technology.
By 1979, capital controls increasingly couldn’t be maintained, because multinational financial institutions, in conjunction with secrecy jurisdictions, were helping make state regulation of currency flows across borders all but impossible.
What has all this to do with Thatcher’s disputed status as a great leader? The point is to ask whether Thatcher stood to the entire British economy as the Treasury stood to capital controls and the desperate attempts to secure the sterling area in the 1970s. Was the game already up by 1979, the times well and truly a-changed? Was ‘Keynesian’ economic management dead, a move to monetarism and open border capital flows inevitable in a globalizing world in which financial technology dictated a change in the rules? If so, when Thatcher imposed monetarism at home, it was not a brave decision taken by a visionary leader, but a political-economic inevitability anybody in Downing Street would have been forced to follow sooner or later. What wasn’t inevitable was the way the transition was conducted. The assault upon industrial communities. The spy operations and violent confrontations against trade unions. The wholesale removal of worker rights and protections. The deliberate abandonment of entire swathes of the population to poverty and misery. The vindictiveness with which desolation and destitution was permitted to destroy the lives of the no-longer-working poor, told they had nobody to blame but themselves. The labeling as ‘enemies within’ individuals who were trying to protect their families and livelihoods. An ideology of selfishness and greed trumpeted as enlightened benevolence. The ‘Big Bang’ in financial services, which didn’t so much give the horses free reign as pump them full of steroids and put them on the long stampede that would eventually take them over the cliff of 2008.
But if, indeed, none of those things needed to happen, what is left of Thatcher’s legacy, and especially the mythos of her party? Certainly, there is not much substance to the idea of her as a great leader, an economic visionary with the iron will required to see through change that would otherwise not have occurred. No matter how much strategic acumen she demonstrated in her confrontation with the trade unions, there is scant evidence that she and her chancellors were ever really in control of the economic changes they presided over. Instead is the image of the heartless caretaker, indifferent to the suffering of communities whose economic base was being removed almost overnight with nothing put in its place, that comes out most clearly.
It is a platitude to say that Thatcher reshaped British politics. In some ways it is of course immeasurably true: Tony Blair is proof enough of that (although without Reagan there would have been no Clinton, and that matters to the New Labour story also). The current coalition government has taken up Thatcher’s spirit with vigour, whatever the more extreme sections of its backbenches claim. Indeed, after the pause afforded by New Labour – those 13 years were at best an interlude and no sort of reversal – they are taking it far further. The present crop of Tories (the Lib Dems are largely an irrelevance when it comes to hard policy-making) has done what even Thatcher didn’t dare: launch a frontal attack on the NHS, and begin the slow process of dismantling and siphoning off that will probably end in privatization and some sort of insurance-based system.
But again, we must be wary of the cult of the individual in political explanation. How much is down to the personalities of Cameron, Osborne, Lansley, Willetts et al? It is a persistent misperception that the British welfare state was enacted out an egalitarian spirit of socialist goodwill. If that had been the case, no government would ever have managed to secure the broad support required to establish or sustain it. Rather, Tony Judt got things right when he wrote that:
the twentieth-century ‘socialist’ welfare states were constructed not as an advance guard of egalitarian revolution but to provide a barrier against the return of the past: against economic depression and its polarizing, violent political outcome in the desperate politics of Fascism and Communism alike.
The welfare states were thus prophylactic states. They were designed quite consciously to meet the widespread yearning for security and stability that John Maynard Keynes and others foresaw long before the end of World War II, and they succeeded beyond anyone’s expectations. Thanks to a half-century of prosperity and safety, we in the West have forgotten the political and social traumas of mass insecurity. And thus we have forgotten why we have inherited those welfare states and what brought them about.With the collapse of the communist regimes in 1989-90 went also (albeit unfairly) much of the plausibility previously attached to social democratic welfare liberalism (another point made by Judt in his final works). With the supposed ‘end of history’, what has come to be known as neo-liberalism has marched ever onwards. But why? Because of Thatcher and Reagan and their courageous personalities? Or because of the rise of global financial power, as accelerated immeasurably by technology – think of what the internet is now to the telex machine – changing the way the game can be played between sovereign nations and global finance, the backbone of modern capitalism, as 2008 made painfully clear. It is both a platitude to say (and yet, perhaps, remarkably under-explained and –appreciated outside of specialist circles), that the rise of the multinational corporation changes the nature of international political economy, and the options available for leaders of sovereign nation states. What the failure of British civil servants to get a grip on the activities of tax havens in the 1960s and 1970s illuminates is the period of transition between what we might think of as western post-war industrial capitalism of the period 1945-79, and the financial services driven capitalism which came to replace it in the 1980s down to today.
But if neo-liberalism, and the sort of western democratic society that goes along with it, is the only available option for modern states – and nothing else is on the table, China clearly not being a desirable alternative for people anything like us – the future begins to look bleak. We have (thankfully) lost the external and internal threats of communism and fascism that provided the impetus for the provision of the welfare states we have inherited. But neo-liberalism is cruel, cold and powerful. It does not, if allowed to flourish in isolation, support systems of support for the destitute, at least above the bare minimum needed to prevent domestic unrest out of sheer desperation. The task now is to prevent, or at least mitigate, outbursts of the sort witnessed in the riots of London and other British cities in August 2011. It is not to counter organised political revolutionaries with a structuring ideology. This new task can be achieved relatively easily, with a repressive state apparatus operating via police and punitively retributive courts, and by emphasizing the threat of the ‘feral’ underclass to the no-longer-so-prosperous classes just above them. What it does not require is a genuine welfare state: an NHS and a safety net providing support for the unemployed, the disabled, the unlucky.
This goes a long way towards explaining why the present government is removing the welfare state inherited from a different era. It is not a pretty picture. Hardly inspiring, either, fostering as it does a significant sense of hopeless powerlessness. And here I disagree with Judt. His diagnosis was accurate, but his belief that we could revert to the social democratic welfare states he championed strikes me as hopelessly naïve: a relic from a different era of capitalism that is not coming back.
David Runciman has recently argued – most publicly in the London Review of Books – that democratic regimes are typically criticized from one of two directions: as being either a confidence trick, or as falling into a self-defeating confidence trap. According to proponents of the confidence trick view, democracy is a sham, a façade behind which a ruling elite more or less secretly sits. When the chips are down, true power shows its face, and illusions of rule by the people are dispensed with. On the confidence trap view, by contrast, democracy is all too real, but that is precisely why it is terminally incapable of dealing with crisis. The people are shortsighted, greedy, selfish and cowardly: when faced with real crises, democracies put off tough decisions and either collapse outright, or cease to be democracies in order to survive. In either case, say its detractors, democracy is not build to last.
Runciman does a convincing job of showing that both these attacks are misguided. Modern representative western democracies are dynamic entities that learn from their mistakes when they need to, and exhibit such multifaceted qualities that they always prove to be more nimble – as well as complex – in practice than their detractors paint them in theory. With the possible – and significant – exception of the challenge faced by climate change, Runciman is confident that not only is democracy for real, but it has the most advantages, and is best placed, to see out the century, even when compared to the emerging rival of a Chinese model which looks, in the short term, to have the upper hand.
But there is another vision, neglected by Runciman, which tracks his view quite closely in all but its final optimism. This view agrees that western representative democracy is dynamic, nimble and adaptable. But it also emphasises that democracy is umbilically connected to modern capitalism, and that the interplay between the two is one of the things that makes democracy good at surviving and renewing itself. But surviving and renewing itself in what form? Democracy may well continue, but if the trajectory of the past 30 years is extended for the foreseeable future (and there’s every reason to think that’s what will happen), the world we are faced with is one of rampant inequality, growing destitution for the increasingly disenfranchised and expanding underclass, political mistrust between the haves and haven-nots, and the expansion of the reign of selfishness and greed to all areas of public life. On this view, the danger is not that democracy – coupled as it must be with capitalism – will fail, but that it is altogether too well placed and adapted to succeed.
In the recent science fiction film ‘Looper’, a society of the near-future is depicted with unnerving clarity. In tomorrow’s America, the vast majority live in a semi-lawless existence, abjectly poor and scraping out survival through violence and desperation, whilst a tiny super-wealthy elite live apart, as though in another world. That future West has decayed, is atrophying almost to the point of breakdown. The momentum of history has moved to China, a society more prosperous than ours, but hardly more desirable in its social constitution. The disturbing thing about ‘Looper’ is how near – in both chronology and trajectory – it looks. When America catches a cold, what happens to Britain? In any case, the future is not bright. There are forces on this earth far more powerful than caretakers, however callously they sweep.
A correction was made to this article on November 17th 2013 at 18:08. It originally suggested that Thatcher signed the Maastricht Treaty (which she didn’t), rather than the Single European Act (which she did).