Although mainstream research on leadership, organizations and management generally continues to ignore gender relations, over recent years there has been major expansion of international research on gender relations in organizations. This article examines a key aspect of gender leadership (and indeed non-leadership), namely that on gender policy development in large transnational businesses. Three levels of analysis of gendered leaderships and non-leaderships are addressed: the national (Finnish) context, corporate structures, and chief Human Resources managers. These three levels are reviewed using secondary material; a questionnaire survey of the largest 100 Finnish companies on their gender organization and gender policy development; and interviews with chief HR managers, respectively. The interviews were conducted in seven corporations that are ‘relatively active’, ‘moderately active’ and ‘largely inactive’ in relation to gender equality policy. Chief HR managers’ accounts are focused upon in terms of the extent of positive leadership or non-leadership on gender policy, how this interlinks with other levels, and how they make sense of relations and tensions between levels.