London — Nearly a decade ago, Britain passed its Sex Discrimination Act, which had Fleet Street columnists in jokey paroxysms over renaming Manchester ''Personchester.'' At the same time, a 16-year-old Suffolk farm girl decided not to follow in her mother's footsteps by marrying the boy next door, but to go up to London and become a banker.
Today that farm girl is a vice-president in an American bank in London. As for Britain, it has been found in violation of European Community equal-rights requirements, while London celebrates its first female lord mayor in eight centuries with a Broadway show tune - ''There's Nothing Like a Dame.''
It is the kind of paradox that characterizes life for many professional women here in Britain - public negligence and private determination.
Britain, to be sure, has had its feminists since before the days of George Bernard Shaw. But unlike the United States, which boasts a long tradition of independent feminists, Britain has traditionally lumped feminism in with the political left. It's an attitude, observers here say, that has deprived politically moderate but career-minded women of a forum for their views: Even with Conservative Prime Minister Margaret Thatcher in office, critics contend, her unwillingness to address women's issues is symptomatic of the nation's public indifference.
Twelve years separates Britain's equal-pay legislation from that of the US, and affirmative-action rules have yet to be enacted here. Combine this with Britain's recent economic woes, which have hit hardest those occupational areas where women have made the most recent gains, and which have fostered a renewed attitude that women do not have the same needs for paying jobs, and life becomes especially challenging for the growing numbers of British women entering the work force.
Observers on both sides of the Atlantic credit the two countries with moving in similar directions regarding working women's rights. And many say that British women fare far better than their European counterparts. But dozens of interviews conducted with English and American professional women here in the City, London's financial district, show a consensus that Britain - largely because of less effective legislation and unique cultural mores - still lags behind the United States. In fact, a recent government study showed that many of the problems confronting high-ranking British women today - tokenism, lack of role models, indirect discrimination - are similar to those first encountered by their American counterparts a decade ago.
''After spending six months in the States for bank training, I would say that England is at least 10 years behind America in its attitudes towards women working,'' says the bank vice-president who, like many women interviewed, did not wish to be named.
''Britain now leads the whole of Western Europe in its numbers of women entering the work force: 65 percent of all women between the ages of 16 and 59, '' says Prof. Cary Cooper of the University of Manchester and director of the recent government study on female managers. ''And women are increasingly going into the traditional male preserves - management in particular. Unfortunately, while lots of British companies have the attitude that it is good to let women in at low levels, they are not as progressive about promoting them.'' Statistics indicate that the proportion of women managers in the United Kingdom still lagged at less than 20 percent in 1981. Comparable US figures show that nearly 30 percent of all working women were in managerial or ad-ministrative positions by 1982.
''In the States women command their institutions to support them,'' says Lisa Dickinson, an American bank vice-president based in London. ''But that doesn't happen here. Feminism has never caught on as a big topic here, and since there is no affirmative action, managers do not feel threatened if they don't hire and promote women.''
''America's equal-opportunity legislation has a lot more teeth than Britain's does,'' explains Eleanor MacDonald, a management consultant and founder of the London-based Women in Management organization. ''Because we have no quotas here , things are left in a very nebulous way. As a consequence, career paths are not clear, entry gates are not specified.''
Without such formal avenues, observers say, many British women lack not only the skills but the confidence needed to carve career patterns. ''There is sort of a negative syndrome here,'' Ms. MacDonald says. ''Women aren't used to saying , 'Yes, I can' and changing social patterns.''
Critics add that informal professional networks are nearly always male-dominated and hard to crack, having been forged early in Britain's sexually segregated school system. And career divisions into skilled and unskilled labor also happen at an unusually young age - and later advancement often appears to depend upon formal qualifications acquired early. In highly unionized fields - including such common entry-level positions for women as secretarial and ''personal assistant'' jobs - many changes are lateral rather than promotional. ''I was way overqualified for my job as a personal assistant,'' says a former advertising saleswoman for a large London daily newspaper, ''but I had to leave my job rather than move up, because the union would have lost that position if I had been promoted.''
In the professional fields, women have fared better, making the most gains in the international atmosphere of London's financial district. ''Women are succeeding best in stockbrokering, international banking, and law. But you definitely don't see high-ranking women in British industry,'' says one American businesswoman based in London. ''People like Laura Ashley (founder of the international clothing company that bears her name) are an exception.''
As for graduate degrees and on-the-job training programs, they are also perceived as more circuitous than direct routes to promotion. ''MBAs are much less common here,'' one high-ranking Englishwoman explains, adding that ''British business schools are oriented towards industry, not finance'' - an area where women have not gained much management clout. ''American banks are much better about training women on the job,'' adds an Englishwoman now working at an American bank. Another female executive said she had left a prestigious British bank for an American counterpart because there were ''no women in their international training program then.''
Yet as frustrating as the lack of formal career paths and significant legal recourse is - and many label the 1975 Sex Discrimination Act as an ''underused last resort'' - most observers say that a woman's professional progress is more apt to be challenged by entrenched cultural attitudes toward women and work.
Kati Marton, former ABC-TV Bonn bureau chief and wife of ABC anchor Peter Jennings, recently attacked British chauvinistic attitudes in The Times of London when she wrote that ''London is not a particularly congenial place to be a woman.'' Ms. Marton, an American, said that despite her professional credentials, ''to all too many Englishmen I was a 'Mum.' '' While she blames the British ''absence of curiosity'' and an ''air of complacency,'' other observers have criticized the country's socialistic practices and class system, which indirectly discourage worker initiative, as obstacles unique to British women.
''In the States women are used to being more assertive,'' says Evelyn Ebert, an American bank vice-president working in London. ''But Britain is a less open environment, and the word 'aggressive' carries negative connotations here.''
''Englishmen as a rule are threatened by strong, capable women - they don't know how to take them,'' adds Linda Kleinman, an American-educated Englishwoman now a practicing lawyer in London. ''Besides, the general English attitude is, 'Don't make waves.' ''
It's an attitude that acquires particular prominence in light of what many see as the British habit of translating professional relationships into personal ones. ''Part of doing business in the United Kingdom is being charming and building a personal relationship with your business contacts,'' says Ms. Dickinson. ''It's a bit more formal here. You don't call people by their first names. And women even have to dress more femininely here. You never see women wearing ties.''
Still, some observers see the English sense of propriety as an asset. ''British men can be nicer than American men,'' says Ms. MacDonald. ''If women can prove themselves upstanding and serious (in the workplace), they will get ahead faster than by table-thumping.''
Yet others insist that the absence of a strong work ethic is one of the biggest detriments to women's careers. ''The City has never been a particularly hardworking place,'' adds Susan Bluff, an officer in an American bank. ''The social aspects, the long lunches, the lingering over cigars, are very important here. Well, women aren't into those things. Americans openly seem to take their jobs much more seriously, and it's easier for women to fit in.''
''Basically there is very little work ethic here,'' says an American banker who has worked in London several years. ''Because Britain has a more highly developed welfare state, much of the emphasis is on job security, not worker initiative.''
In fact, some observers say that what many take for sexism is simply an indifference to the world of work. ''Americans are always defining themselves in terms of their jobs,'' says a female British journalist. ''They're always asking each other what they do for a living. We don't do that in this country. Here there are so many other ways of determining someone's status - who they know, where they went to school, what their accent is. One's job just diminishes in importance.''