Opportunities and obstacles for corporate responsibility reporting in developing countries

Full text

OPPORTUNITIES AND OBSTACLES
FOR CORPORATE SOCIAL
RESPONSIBILITY REPORTING IN
DEVELOPING COUNTRIES
Dara O’Rourke
University of California, Berkeley
for the Corporate Social Responsibility Practice of the World Bank Group
March 2004

This report is a product of the staff of the World Bank Group. The findings,
interpretations and conclusions expressed herein do not necessarily reflect the
views of the Board of Executive Directors of the World Bank or the governments
they represent. The World Bank does not guarantee the accuracy of the data
included in this work.

Abbreviations and Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii
Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 Background to the Study. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.2 Structure of the Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1.3 The Emerging Field of CSR Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
1.4 Potential Futures for CSR Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2. Drivers of CSR Reporting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.1 Theories of Information Disclosure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.2 Government Uses of Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.3 Consumer Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.4 Investor Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.5 Corporate Interests in Reporting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2.6 Other Stakeholder Interests. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3. Trends in CSR Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.1. Government Mandated Reporting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.1.1 Financial Disclosure Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.1.2 Environmental Disclosure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.1.3 Social Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.2 “Voluntary” Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
3.2.1 Leading Firms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
3.2.2 Geographic and Sectoral Variation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.2.3 Characteristics of Firms Most Likely to Report . . . . . . . . . . . . . . . . . . . 15
3.2.4 NGO and Multi-Stakeholder Reporting Initiatives. . . . . . . . . . . . . . . . . 16
3.2.5 International Initiatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Table of Contents
i

4. Impacts of CSR Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
4.1 Investor Responses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
4.2 Consumer Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
4.3 Other Stakeholder Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
5. Key Metrics of Corporate Social Responsibility. . . . . . . . . . . . . . . . . . . . . . 25
6. Challenges of Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
6.1 Metrics and Materiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
6.2 Incentives to Disclose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
6.3 Supply Chains . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
6.4 Costs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
6.5 Analyzing Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
6.6 Consumers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
7. Strategies for Improving Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
7.1 Standardized Metrics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
7.2 Incentives for Continuous Improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
8. Government Roles in CSR Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
8.1 Mandating . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
8.2 Facilitating . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
8.3 Partnering. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
8.4 Endorsing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
8.5 Demonstrating . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
9. A Draft Pilot Program for CSR Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
9.1 Step-by-Step Actions for a Pilot Program on CSR Reporting . . . . . . . . . . . . . . . 35
9.2 Possible “Core Indicators”. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
9.3 Possible Sector-Specific Indicators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
9.4 Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
10. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
Table of Contents
ii

AA1000 AccountAbility 1000 Assurance Standard
BSR Business for Social Responsibility
CalPERS California Public Employees’ Retirement System
CSR Corporate Social Responsibility
EPA Environmental Protection Agency
EITI Extractive Industries Transparency Initiative
ETI Ethical Trading Initiative
EU European Union
FLA Fair Labor Association
FWF Fair Wear Foundation
GFT250 Top 250 Firms in the Global Fortune 500
GRI Global Reporting Initiative
MNC Multinational Corporation
NGO Non-Governmental Organization
NPRI National Pollutant Release Inventory
NRE Nouvelles Regulations Economiques
OECD Organisation for Economic Cooperation and Development
PDA Personal Digital Assistant
PR Public Relations
PRTR Pollutant Release and Transfer Registers
PWYP Publish What You Pay
SAI Social Accountability International
SBS Social Balance Sheets
SEC Securities and Exchange Commission
SME Small and Medium-sized Enterprise
SRI Socially Responsible Investment
TRI Toxic Release Inventory
WBCSD World Business Council for Sustainable Development
WRAP Worldwide Responsible Apparel Production
WRC Worker Rights Consortium
Acronyms and Abbreviations
iii

v
G
overnments seeking to advance sustainable
development are increasingly turning to poli-
cies and strategies that encourage, support, man-
date, or directly demonstrate more socially and
environmentally sound business practices. A cen-
tral component of these policies involves promot-
ing increased transparency of economic activities.
This disclosure is designed to support market-
based incentives (such as product differentiation),
public awareness and pressures, and government
enforcement. Transparency mechanisms can be
advanced on at least two different levels: disclo-
sure of government inspection and factory audit
reports, or disclosure of Corporate Social Respon-
sibility (CSR) practices, including both the posi-
tive and negative impacts of business operations
on labor standards, the environment, economic
development, human rights, and governance
issues. This report focuses on CSR reporting.
Encouraging Corporate Social Responsibility
reporting, or more specifically public disclosure of
the social and environmental impacts of firm
practices is becoming an increasingly important
governmental and non-governmental policy
strategy. CSR reporting is seen as a linchpin of
efforts to evaluate the impacts of corporate
activities, to identify best practices, and to promote
continuous improvements in firm performance.
CSR reporting has been taken up by governments
to support efforts to regulate the adverse impacts
of economic activities, to promote more socially
responsible business practices, and to support
development goals.
BACKGROUND TO THIS REPORT
Because of the potential societal benefits associ-
ated with CSR reporting, the World Bank is now
evaluating whether encouraging CSR reporting
might be of interest and benefit to developing
country governments. If sufficient data were avail-
able, it is possible that developing countries could
leverage the CSR achievements of local firms to
attract investment and export opportunities, and
also use CSR reporting of multinational corpora-
tions to support local economic development
efforts. The extent to which a market exists for this
information, and how investors and manufacturers
respond to this information requires further study.
Similarly, attempts to aggregate firm level data on
CSR performance for use at a national or interna-
tional level are still quite new.
However, in order to begin to evaluate these issues,
the World Bank commissioned this study of trans-
parency and CSR reporting. This paper analyzes:
• Current CSR reporting activities in developed
and developing countries;
• Characteristics of companies most likely to
report;
• Existing and potential uses of data generated by
CSR reporting;
• Criteria for evaluating CSR reporting systems;
•Impacts of CSR reporting on stakeholder deci-
sion-making in developing countries;
• Impacts of CSR reporting for development
objectives;
• Challenges and obstacles to effective CSR
reporting;
• Conditions necessary to support the imple-
mentation of CSR reporting; and,
Executive Summary

•Potential public sector roles to strengthen and
support implementation of CSR reporting in
developing countries.
The focus of this study is on CSR reporting in sup-
ply chain industries with high social or environ-
mental impacts. The study considers cases from a
wide range of industries and issue areas: environ-
ment, health, labor rights, governance, and social
impacts. The paper evaluates current reporting ini-
tiatives, challenges and problems with these ini-
tiatives, and strategies for improving reporting
systems. The report also discusses how CSR activ-
ities and reporting might better address local
development priorities.
The paper concludes with a preliminary propos-
al—designed largely to begin a discussion—for a
pilot program to advance CSR reporting in devel-
oping countries. The pilot program is pro-
posed in part to develop a reporting system that
explicitly focuses on developing country issues and
concerns and that produces information that is
“material” to local stakeholders such as workers,
community members, and local firms. The pilot
may also seek to test the hypothesis that CSR
reporting can substantively support development
goals. The proposed pilot program focuses on the
apparel and mining sectors as examples of chal-
lenging industries which are experiencing increas-
ing demands for corporate disclosure, and seeks to
advance new roles for developing country govern-
ments in promoting local socially responsi-
ble development.
Above all, this report seeks to begin a dialogue
regarding CSR reporting and to advance efforts to
promote transparency and social accountability in
the global economy.
CURRENT TRENDS IN CSR REPORTING
Corporate reporting—whether mandated or vol-
untary—on environmental, social, labor, and
human rights issues is a relatively new phe-
nomenon. While a small number of firms have
irregularly published information on their non-
financial performance, more systematic and stan-
dardized systems of social and environmental
reporting only emerged in the late-1980s and
early-1990s.
Since the 1980s, governments, firms, and NGOs
around the world have developed a wide range of
reporting systems with goals as diverse as reduc-
ing pollution, mitigating health and safety risks,
spotlighting (and thus rooting out) corruption,
improving public service delivery, and protecting
civil rights. With each new initiative in public
reporting, public demands for fuller information
and a deeper “right-to-know” appear to solidify.
These initiatives have been driven by a range of
pressures and demands from: consumers, NGOs,
unions, investors, governments, community mem-
bers, and firms themselves.
GOVERNMENT MANDATED REPORTING
There are a large number of governments cur-
rently experimenting with or implementing new
reporting requirements for corporations. These
programs often simply require reporting of factual
information in a standardized format on a regular
basis. Information is then presented in a manner to
allow the public (and government officials) to
compare the performance of firms and make deci-
sions based on that information. Financial and
environmental reporting are the most advanced of
these systems, with some governments requiring
or facilitating the public release of factory-level
audit information. However, social, human rights,
and governance reporting are all emerging very
rapidly around the world.
A number of countries are now strengthening and
expanding financial reporting requirements to
include more stringent disclosures on environ-
mental, labor, and human rights “liabilities” and
“risks” that might have a material impact on cur-
rent or future profits (and thus stock prices) of
publicly traded firms. Governments are also
strengthening environmental disclosure laws, now
generally referred to as Pollutant Release and
Transfer Registers (PRTRs). While much newer,
there are also now a range of government facili-
tated social reporting initiatives.
VOLUNTARY REPORTING
Surveys of global firms regarding their public
reporting have found that 45 percent of the world’s
largest firms now produce some form of non-
financial report, compared to 35 percent of these
firms in 1999. As one study found, in 1993, only
Opportunities and Obstacles in CSR Reporting in Developing Countriesvi

Executive Summary
vii
13 percent of the top 100 firms in the countries
studied produced a health, safety, or environmen-
tal report. By 1996, that number had risen to 17
percent, in 1999, 24 percent of firms produced
reports, and by 2002, 28 percent of top 100 firms
produced reports.
Firms are also increasingly employing independent
auditors to verify or assure the data presented in
their reports. Third party verification increased
gradually during this period from approximately 15
percent of reporters in 1996 to 27 percent in 2002.
There are however, clear geographical and sectoral
variations in reporting. A survey conducted by
KPMG found that 72 percent of Japanese firms
published environmental or social reports, 49 per-
cent of UK firms, and only 36 percent of US
firms. The electronics and auto industries had very
high reporting rates (90 percent of the firms in one
survey) compared to financial services (only 27
percent reporting).
Not surprisingly, large, branded manufacturing
firms are currently the most likely to voluntarily
report on CSR issues. These firms are most “repu-
tation sensitive” and thus most at risk of critical
information or “bad news” about poor practices.
NGOs are also advancing a range of multi-stake-
holder initiatives regarding CSR reporting, and
raising questions about the issues firms should
report on, and how they should report.
IMPACTS OF CSR REPORTING
A critical question of course is whether current
reporting initiatives are having any impact. Do they
make a difference in consumer preferences and
purchases? Do they influence investors away from
poor performers and towards good performers? Do
they influence firm decision-making at any point
along a supply chain? Is the information used by
government agencies to more effectively regulate
firms or to provide technical assistance? Is infor-
mation used to support local development decision-
making? Essentially, does reporting have any
impact on consumers, firms, governments, or other
key stakeholders in advanced industrialized coun-
tries, and more importantly, does reporting support
development goals in developing countries? And if
reporting does make a difference, when and under
what conditions is it most effective?
Recent research indicates that investors and con-
sumers do respond to information on corporate
social responsibility. Investors don’t like to be sur-
prised with bad news, or with news that is diver-
gent from existing information on a company.
Consumers appear to use bad news to avoid or
punish companies, and less often use good news to
select products and firms to reward. However, both
groups would benefit from more systematic and
comparable sources of information.
METRICS OF CSR
With hundreds of corporations now producing
reports, a wide range of laws being implemented
around the world, and dozens of non-governmen-
tal initiatives on transparency and reporting
emerging, there is staggering variation in what is
reported, in what forms, and for which audiences.
Current CSR reporting initiatives disclose infor-
mation on:
•Environmental Performance;
• Labor Rights;
• Health and Safety Practices;
• Human Rights;
• Community Economic Development and Social
Impacts;
• Corporate Governance;
• Corporate Payments to Governments;
•Stakeholder Engagement;
• Supply Chain Management; and,
• Corporate Planning and Policies.
KEY CHALLENGES
There are a number of major challenges to making
CSR reporting effective. Questions remain in dif-
ferent sectors and countries on what to report, in
what form, to what level of detail, to what audi-
ences, and for what uses. There are also weak-
nesses and problems with current systems of CSR
reporting, and important barriers to expanding
public disclosure systems around the world. These
include problems of:
• Metrics and Materiality;
•Timeliness and Usefulness of Information;

•Incentives to Disclose;
• Supply Chain Monitoring;
• Costs to Information Producers and Users;
• Analyzing and Translating Information for End
Users.
MOVING FORWARD
There is no single reporting system or model of
corporate transparency that fits all social or envi-
ronmental problems. However, there are some
basic principles which can support efforts at
advancing and improving CSR reporting. First,
reporting initiatives should seek to increase the
quality of information disclosed. Second, they
should work to increase the uses of the informa-
tion and the benefits to users of the information.
Third, they should create mechanisms for learning
and continuously improving disclosure systems.
These goals can be supported through explicit
efforts to target information to specific stakehold-
ers and decision-making processes. Information
should be reported in formats useful to specific
users. And efforts should be made to verify that
information is used by stakeholders to inform their
decisions.
GOVERNMENT ROLES IN CSR REPORTING
To date, CSR reporting has largely been driven
from the north, often by large multinational firms,
private investors, or non-governmental organiza-
tions. Nonetheless, there are important roles for
governments, and particularly developing country
governments, to play in further advancing report-
ing systems.
The World Bank has previously grouped govern-
ment roles in supporting corporate social respon-
sibility into five categories of action: mandating,
facilitating, partnering, endorsing, and demon-
strating. Each of these strategies of action can
support improvements in CSR reporting. Govern-
ments, and their citizens, however, must decide
how they can most effectively support an environ-
ment for socially responsible business, and specif-
ically advance CSR reporting.
A PROPOSED PILOT PROJECT
There is clear potential for government action,
particularly in developing countries, to advance
and strengthen CSR reporting. However, in think-
ing about designing an appropriate and effective
disclosure system in a developing country, it is
also critical to recognize that there are no perfect
systems, no easily replicable programs, and no
one-size-fits-all standards for reporting.
By starting with a small set of core indicators, ver-
ifying that they are material to stakeholders, eval-
uating uses of the information, and soliciting
feedback on the quality of the data, it would be
possible to gradually expand and deepen CSR
indicators to include sector specific issues. By
having reporting be driven by local concerns and
capacities, it would also be possible to gradually
connect to and compare against global reporting
schemes.
Government agencies and NGOs could play a key
role in verifying CSR reporting information, and
gradually working to improve the credibility and
accountability of reporting.
Finally, a government agency could work to aggre-
gate data, and to produce a national CSR report.
This information would support future compar-
isons of country-level performance on CSR
issues. The program could also help local firms
establish and demonstrate their social and envi-
ronmental performance, and facilitate socially and
environmentally responsible firms connecting into
high value supply chains.
Opportunities and Obstacles in CSR Reporting in Developing Countriesviii

T
here is a growing global trend towards both
government mandated and voluntary corpo-
rate disclosure of information on the environmen-
tal, labor, human rights, and social impacts of
business practices. The goal of this reporting,
grouped here under the rubric of Corporate Social
Responsibility (CSR) reporting, is to generate new
and better information on the performance of
firms, to support more informed decision-making
by key stakeholders, and ultimately to create new
incentives for firms to reduce adverse impacts of
their activities. Public access to this information is
hypothesized to support market incentives, reputa-
tional pressures, and new forms of regulation moti-
vating firms to improve practices.
Governments seeking to advance more sustainable
development are increasingly turning to policies
and strategies that encourage, support, mandate, or
demonstrate more socially and environmentally
sound business practices. A central component of
these policies involves promoting increased trans-
parency of firm activities. Transparency mecha-
nisms can be advanced on at least two different
levels: disclosure of government inspection and
factory audit information, or disclosure of broader
Corporate Social Responsibility (CSR) practices,
including both the positive and negative impacts of
business operations on labor standards, the envi-
ronment, economic development, human rights,
and governance issues.
Public disclosure programs represent a relatively
new strategy of corporate governance and have
been employed only recently in developing nations.
This paper reviews both government-mandated,
and voluntary disclosure programs in developed
and developing nations, describing a number of
leading programs, and assessing what is reported, in
what forms, and to what audiences. The paper also
reviews challenges and weaknesses of existing
reporting programs, and barriers to expanding and
strengthening the scope and breadth of disclosure
efforts. The paper then lays out a range of roles and
functions governments can play in strengthening
CSR reporting. The paper concludes with a prelim-
inary proposal—designed largely to begin a discus-
sion—for a pilot program to advance CSR reporting
in developing countries.
1.1 BACKGROUND TO THE STUDY
In April 2002, the World Bank Group’s Corporate
Social Responsibility Practice initiated a program
of technical assistance to developing country gov-
ernments on the policies and instruments they can
usefully deploy to strengthen Corporate Social
Responsibility (CSR). Examples of roles the pub-
lic sector has played to strengthen CSR are few,
particularly in developing countries. However, to
gain a better understanding of existing practices,
the World Bank commissioned a baseline study of
public sector roles in strengthening CSR. From this
study emerged a framework for analyzing five pri-
mary categories of public sector roles: mandating,
facilitating, endorsing, partnering, and demonstrat-
ing. From June 2002 to November 2003, the World
Bank provided technical assistance to countries
whose national governments sought to explore
these potential roles in supporting CSR, including
Vietnam, the Philippines, Angola, and El Salvador.
One key aspect of this work involves reporting the
social and environmental performance of corpora-
tions. CSR reporting is seen as a linchpin of efforts
to evaluate the impacts of corporate practices, to
identify best practices, to promote continuous
1. Introduction
1

improvements in firm performance, and to enable
local stakeholders to make more informed deci-
sions about development options.
CSR reporting involves corporate disclosure of
both the positive and negative impacts of business
operations on labor standards, the environment,
economic development, and human rights. CSR
reporting has come a long way since the 1980s
when reporting focused almost entirely on occupa-
tional health and safety and environmental issues.
In addition to a general increase in the overall num-
ber of companies producing CSR reports, the past
five years have seen rapid growth and expansion of
CSR reporting to include a broad focus on social,
economic, and governance issues.
Because of the potential societal benefits associ-
ated with CSR reporting, the World Bank is now
evaluating whether encouraging CSR reporting
might be of interest and benefit to developing
country governments. If sufficient data were avail-
able, it is possible that developing countries could
leverage the CSR achievements of local firms and
attract investment and export opportunities. The
extent to which a market exists for this informa-
tion, and how investors and manufacturers respond
to this information requires further study. Simi-
larly, how firm level data on CSR performance
might be aggregated for use at a national level is
still unclear.
In order to begin to evaluate these issues, the World
Bank commissioned this study of transparency and
CSR reporting to evaluate:
• Current CSR reporting activities in developed
and developing countries and other relevant
domestic disclosure initiatives underway;
• Characteristics of companies most likely to
report;
• Potential market demand for data generated by
CSR reporting among firms, investors, con-
sumers, and local stakeholders;
• Whether CSR reporting could be an effective
mechanism for strengthening CSR in develop-
ing countries;
•Whether CSR reporting can support develop-
ment goals;
• Criteria for evaluating CSR reporting systems in
a given country;
• Challenges and obstacles to effective CSR
reporting among diverse stakeholders (e.g., con-
cerns about transparency, reliability, protection-
ism, etc.);
• Conditions necessary to support the implemen-
tation of CSR reporting among domestic com-
panies in a developing country context;
• Potential public sector roles to strengthen and
support implementation of CSR reporting in
developing countries.
The focus of this study is on CSR reporting in sup-
ply chain industries with high social or environ-
mental impacts. The study considers cases from a
wide range of industries and issue areas: environ-
ment, health, labor rights, governance, and social
impacts. In the proposed pilot program we discuss
the apparel and mining sectors as examples of chal-
lenging industries which are experiencing increas-
ing demands for corporate disclosure.
Above all, this report seeks to begin a dialogue
regarding CSR reporting and specifically on how
best to make reporting work. The paper begins this
discussion by presenting a framework for examin-
ing the issues, assumptions, and feasibility of CSR
reporting in developing countries.
1.2 STRUCTURE OF THE REPORT
This report follows a straightforward stucture. We
begin with background on the emerging field of
CSR reporting, and growing public concerns about
corporate practices that have led to increased
demands for corporate disclosure of information.
We then discuss different stakeholder groups
“driving” specific forms of CSR reporting, and the
resulting programs, laws, and voluntary initiatives
emerging around the world to meet these demands
for fuller public information on firm practices and
impacts.
The paper then examines recent research evaluat-
ing the impacts of corporate reporting of environ-
mental and social practices. In particular we look
at stock market and investor responses to corporate
disclosures, and broader community and consumer
responses to public information on corporate per-
formance.
The paper then discusses existing metrics for eval-
uating Corporate Social Responsibility, challenges
to current CSR measurement and reporting, and
strategies for improving measurement and report-
ing.
Opportunities and Obstacles in CSR Reporting in Developing Countries
2

Introduction
3
We then turn to a discussion of government roles
in CSR reporting—from mandating, to facilitating,
to partnering, to endorsing, to demonstrating—and
how developing country governments might
advance these strategies in their own contexts.
Finally, the paper presents a proposal for a pilot
program for CSR reporting in a developing coun-
try. This includes a step-by-step plan for establish-
ing requirements for reporting, including what to
report—possible “Core Indicators”—and strate-
gies for collating, publishing, and using this infor-
mation to allow key stakeholders to benchmark
firms, identify leaders and laggards, and use the
information to motivate improved practices.
1.3 THE EMERGING FIELD OF CSR REPORTING
With the globalization of information flows, and
the ability of organizations to transmit information
literally at the speed of the Internet, companies and
countries are increasingly being tracked not only
for their economic performance, but also for their
social, environmental, labor, and human rights
policies and impacts. Socially responsible firms are
now listed in sustainability indexes, screened
investment funds, and ethical consumer web sites.
And socially irresponsible firms are being labeled
as “sweatshop” producers, environmental pol-
luters, corrupt actors, or worse in the media and on
NGO web sites.
Entire countries are now even sometimes labeled
as socially irresponsible locations of production:
Burma is widely regarded as a pariah country for
its internal political repression and human rights
abuses; China is critiqued as a site of “sweatshop”
production; Pakistan is viewed by some as a haven
for exploiters of child labor; Angola for corrupt
mining and oil extraction practices.
And it is not only advocacy groups which are now
critically evaluating the performance of compa-
nies and countries. In 2002 for instance, the Cali-
fornia Public Employees’ Retirement System
(CalPERS), which manages more than $151 bil-
lion in assets, revised its procedures for evaluating
developing countries for equity investments. New
guidelines analyzed both traditional “market fac-
tors” and new “country factors,” such as trans-
parency, labor practices, and political stability.
Based on these social and political factors,
CalPERS recently ended its investments in several
countries in Southeast Asia.
1
Corporations themselves are also increasingly
making investment and location decisions based on
evaluations of social and environmental risks and
country conditions. A recent survey of multina-
tional firms reported that many firms now have
lists of countries that are off-limits to sourcing,
with over half of the firms surveyed employing
country selection criteria that include social indi-
cators.
2
18 of 19 firms surveyed had policies
against sourcing from Burma, which may not be
surprising. However, thirty other countries also
showed up on company “no sourcing” lists.
A recent World Bank survey of 107 multinational
corporations in the extractive, agribusiness and
manufacturing sectors found that over 45 percent
of firms surveyed chose countries for investment or
operation based at least in part on CSR issues, and
36 percent of respondents had actually withdrawn
from a country because of CSR concerns. Over 80
percent of companies reported analyzing the CSR
performance of potential partner firms in develop-
ing countries, and over 50 percent had chosen cer-
tain partners over others because of CSR concerns.
Fully 88 percent of firms reported that CSR issues
are “more influential” or “much more influential”
now than five years ago.
3
Companies are responding to pressures to prove
they are responsible actors by not only avoiding
“bad” countries, but also by positively affirming
their commitments to socially responsible prac-
tices, implementing a broad range of CSR activi-
ties, developing codes of conduct and monitoring
systems, and publishing information to demon-
strate this commitment.
British Petroleum (BP), for example, recently reaf-
firmed its policies against corrupt business prac-
tices in developing countries, but went further by
actually backing up this policy with a pledge to
publish exactly what it was paying developing
country governments for oil concessions. John
Browne, the CEO of BP, asserted that he was inter-
ested in advancing “radical openness” for his com-
pany’s operations. Nike recently disclosed the
average monthly wages of workers in its supply
chain factories around the world, and made public
the names and locations of garment factories pro-
ducing goods for US universities—data that was all

previously considered confidential business infor-
mation.
A number of developing country governments
have also taken steps towards greater transparency
by providing public information on their revenues,
budgets, and expenditures. Participatory budgeting
initiatives in Brazil and India, diamond revenue
disclosure in Botswana, and oil revenue disclosure
programs advanced through the new Extraction
Industries Transparency Initiative are all examples
of new trends towards disclosure of information
seldom before made public.
These surprising cases of public reporting might
seem to go against current trends in the global
economy. The general public’s view of multina-
tional corporations (MNCs) in this post-Enron
world is increasingly skeptical and cynical about
unaccountable, non-transparent, and often decep-
tive firms. However, many firms are now respond-
ing to exactly these concerns, and to a growing
number of stakeholders demanding that global
businesses be socially responsible, publicly
accountable, and transparent. Companies are
increasingly being asked to publicly report on
their environmental, social, and ethical risks, how
they are working to manage and reduce these
risks, and how these risks might affect their short-
and long-term value. In areas as diverse as food
safety, drinking water quality, medical practices,
toxic releases from industrial facilities, Sport Util-
ity Vehicle rollover risks, and health hazards faced
by workers, disclosure is growing as a strategy to
inform the public about risks they might face, and
to incentivize firms to reduce these risks.
4
It should be noted that disclosure has been
advanced as a strategy not just to identify risks or
“bad actors,” but also to support a positive agenda
for socially responsible business, ethical consump-
tion, sustainable community development, and
more democratic political processes. Countries are
increasingly viewing disclosure of corporate prac-
tices as a strategy of both regulation and incentiviz-
ing improved environmental, social, and human
rights performance.
1.4 POTENTIAL FUTURES FOR CSR
REPORTING
It is not hard to imagine a future level of disclosure
and public access to corporate data that would truly
empower a new kind of economy, new forms of
public accountability, and new levels of corporate
social responsibility.
Imagine walking into your local mall, pointing
your cell phone or personal digital assistant (PDA)
at the tag on a pair of shoes or jeans, pulling up data
on the environmental, labor, and human rights
impacts of the product, and then making a
purchasing decision. Or using your PDA or the
Internet to compare two similar toys for their con-
nections to child labor, two computers for their
environmental recyclability, or two brands of cof-
fee for their impacts on farm workers’ health, and
then choosing the one that satisfies your personal
ethical commitments. Or more simply, identifying
countries that inspire confidence that a product is
made in humane and sustainable conditions.
This vision of fuller public access to information
on the ethical impacts and performance of different
products and firms is not science fiction. It is tech-
nically feasible today.
5
Electronic and radio fre-
quency tags, advanced supply chain management
and tracking systems, and increased monitoring of
global supply chains for environmental, labor, and
human rights issues has brought us to the edge of a
revolution in disclosure of the “stories” of prod-
ucts’ lives and a fuller accounting of the real costs
of production in the global economy.
However, there remain critical barriers to this fuller
public reporting of product impacts and costs.
Despite important advances over the last several
years in voluntary reporting systems, public access
to systematic information on business practices
remains limited. Very little information is available
on non-financial performance that is standardized,
comprehensive, or comparable across factories,
brands, or countries.
Standardized reporting is critical to the future of
corporate social responsibility, as it will allow
Opportunities and Obstacles in CSR Reporting in Developing Countries
4

Introduction
5
stakeholders to document CSR practices, compare
and differentiate firms, support market responses,
and institutionalize mechanisms for continuous
improvement. And ultimately, more systematic
CSR reporting may also be central to developing
country strategies for advancing sustainable eco-
nomic development. For increasingly, firms and
countries will be judged not only by the price of
their products, but also on their social and envi-
ronmental performance. For more and more con-
sumers, sales will be based at least in part on CSR
concerns. Documenting performance to meet
these concerns will be critical to accessing these
markets.

T
he primary drivers for CSR reporting have
come from a range of social actors and inter-
ests: public demands for a “right-to-know” about
the impacts of corporate activities, consumer con-
cerns about environmental and social impacts of
specific products, government attempts to use dis-
closure as a strategy of regulation, and financial
institution demands for fuller disclosure of non-
financial risks. Reporting is in some cases man-
dated by government agencies (such as for toxic
release inventories), required of firms who partici-
pate voluntarily in trade associations (such as the
World Business Council for Sustainable Develop-
ment (WBCSD)) or multi-stakeholder initiatives
(such as the Fair Labor Association (FLA)),
requested by financial institutions (such as socially
responsible investment funds), or simply a response
to consumer, worker, or community requests for
information. Disclosure has become a strategy for
both creating and responding to market incentives
for improved performance, and a means for miti-
gating risks of market sanction.
2.1 THEORIES OF INFORMATION DISCLOSURE
CSR reporting supports basic market dynamics.
One of the central assumptions of market eco-
nomics is that full information is required for the
efficient functioning of markets. Information dis-
closure strategies attempt to deal with the “market
failures” of information asymmetry and externali-
ties. Faulty or incomplete information, it is hypoth-
esized, may lead stakeholders to make economic or
social decisions which are actually not in their best
interest (and thus fail to maximize their utility).
6
The basic premise of information disclosure pro-
grams is thus to provide interested parties with
more and better information upon which to base
their decisions. As the WBCSD asserts, “If busi-
ness believes in a free market where people have
choices, companies must accept responsibility for
informing consumers about the social and environ-
mental effects of those choices.”
7
In slightly more theoretical terms, there is also a
Coasian efficiency argument for increased trans-
parency.
8
Disclosure of information on externali-
ties will increase information available to impacted
parties, which can support negotiations over the
fair distribution of those impacts. The more infor-
mation available, the greater chance of an efficient
allocation of the costs and benefits of an economic
activity. Furthermore, public disclosure of exter-
nalities is hypothesized to support the more rapid
identification of solutions to externalities, either by
stimulating preventive corporate actions (to avoid
2. Drivers of CSR Reporting
7
“Publicity is justly commended as a remedy for social and industrial diseases. Sunlight is said to be the
best of disinfectants.”
—Louis Brandeis, 1932.

costly disclosures), or by motivating citizen actions
to pressure for solutions to environmental and
social problems. Providing fuller information to
key stakeholders is also likely to lead to different
choices by consumers, investors, employees, exter-
nal stakeholders, and even competitors, thus poten-
tially shifting market incentives and firm actions.
9
A critical aspect of information asymmetry prob-
lems is that individuals (and particularly poor peo-
ple) are less likely to have the resources to gather
information on firm practices and impacts than
firms themselves. There is thus a central role for
governments to play in facilitating or mandating
disclosure that provides equal information to all
stakeholders.
2.2 GOVERNMENT USES OF INFORMATION
There is also a regulatory aspect to information dis-
closure systems. Governments around the world
have turned recently to public reporting systems as
a complement to traditional command-and-control
regulatory mechanisms. This has been motivated in
part by continuing critiques of current systems of
labor and environmental regulation.
10
These cri-
tiques have grown louder in the face of new chal-
lenges of regulating global firms and mobile
supply chains. Traditional regulations and the gov-
ernment-implemented monitoring and enforce-
ment systems upon which they depend, are
arguably being outpaced by changes in the global
economy.
Governments are thus looking for new strategies to
more effectively regulate the environmental, labor,
and social impacts of industry. Governments
appear to be particularly interested in disclosure
systems that may also be more cost-effective, flex-
ible, and decentralized, and that build on market
mechanisms and public participation.
2.3 CONSUMER CONCERNS
Growing concerns among the public about the
environmental and social impacts of the products
they buy, the places they work, and the communi-
ties they live in, have also led to new demands for
corporate disclosure. The on-going globalization
of information flows has allowed labor, environ-
mental, and human rights groups to raise public
awareness about the negative impacts of produc-
tion and to target individual company practices.
Globalization of branding, and the interconnec-
tions between high-value supply chains and low-
cost sites of production, have given rise to a
mushrooming field of labels, certifications, and
disclosure schemes.
11
On-going media accounts of corporate scandals,
pollution incidents, health problems, and stories of
sweatshops have created new reputational pressures
on multinational corporations. Brands, which repre-
sent a critical currency in the global economy, are
under attack from activists around the world. Advo-
cacy groups have become increasingly sophisticated
and effective in their corporate research and infor-
mation dissemination campaigns to create market
pressures on MNCs to change their practices.
However, it remains extremely difficult (if not
impossible) for consumers and investors to distin-
guish the performance of similar firms based on
existing information. Consumers for instance, can-
not systematically compare the performance of
Nike versus adidas, BP versus Shell, or Interna-
tional Paper versus Boise Cascade. Firms are thus
taking steps to develop systems of reporting that
can effectively communicate their commitments,
policies, actions, and performance.
2.4 INVESTOR CONCERNS
Firms must also increasingly demonstrate their
social and environmental performance to investors
– both traditional mainstream investors, and grow-
ing numbers of socially responsible investors. The
financial sector today demands much fuller infor-
mation on risks and liabilities, including non-finan-
cial risks. In fact, a number of countries now
require this disclosure to reduce risks and liabilities
for retirement and pension funds. Research has
shown important correlations between environ-
mental performance and financial results.
12
Non-
financial risks are increasingly crucial to firm
performance. Investors thus demand better mea-
sures of management practices and systems for
handling current and future liabilities.
13
This fuller
reporting of CSR issues provides information for
investors to select superior environmental or social
performers, and to avoid poor performers.
Financial markets have increased their interest in
CSR reporting due to the growth in demand for
Opportunities and Obstacles in CSR Reporting in Developing Countries
8

Drivers of CSR Reporting
9
socially responsible investments (SRI) by institu-
tional and individual investors. Several prominent
SRI indices have been established over the last few
years, including the FTS4Good index in London
and the Dow Jones Sustainability Index in New
York. Questionnaires, interviews, and surveys con-
ducted for these indexes, as well as for SRI rating
firms, SRI research firms, and screened mutual
funds, have forced corporations to be more trans-
parent about their social and environmental perfor-
mance. Investor requests for CSR information have
gained motivational force as the socially responsi-
ble investment community has expanded to now
manage some $3 trillion in assets in the US alone.
These investors are increasingly working together
to motivate standardized reporting. As just one
example, in 2000, a group of financial investors
controlling over $140 billion in assets sent a letter
to the CEOs of the 500 largest firms in the US urg-
ing them to report their performance on sustain-
ability measures proposed by the Global Reporting
Initiative.
14
2.5 CORPORATE INTERESTS IN REPORTING
There are actually a number of benefits of these
demands on firms to report information that they
had previously either not tracked, or at least not
made public. First, the process of developing
reporting systems, measuring performance, and
tracking changes over time can support the devel-
opment of information systems that improve inter-
nal management of risks, stakeholder concerns,
and bottom-line issues. If done right, reporting can
lead to significant internal learning within a firm.
Companies can also learn about best practices in
their industries, new ways of operation, and better
systems of management. Reporting can also sup-
port self-regulation to prevent future liabilities and
risks.
15
By measuring, managing, and reporting on
problems in their supply chains, firms can work to
minimize actual risks to profitability, maintain or
create market access, and manage problems as they
emerge.
16
Fuller public disclosure of CSR practices can also
help to improve a company’s reputation and brand
value. A positive public image, backed up by trans-
parent operations, can help to recruit and retain top
quality employees (who are increasingly con-
cerned about social, environmental, and ethical
issues), get a company listed in socially or envi-
ronmentally screened funds, and improve relations
with stakeholders such as host communities. Pub-
lic transparency may be the single most effective
way to win back trust and respond to the current
credibility crisis for MNCs operating around the
world.
Public disclosure may also improve firm-NGO
relations, and the quality of public participation in
corporate issues. With better information, the pub-
lic can play a more effective role in addressing
environmental and social problems, and better
understand the opportunities and constraints on
businesses.
2.6 OTHER STAKEHOLDER INTERESTS
There are numerous other stakeholders who can
benefit from improved corporate reporting. In
developing countries, local community members
often lack information on the potential environ-
mental and health impacts of the industries operat-
ing in their neighborhoods. Workers rarely have
access to information on the real risks they face in
accepting employment in industrial facilities. And
local governments almost never publicly calculate
the costs and benefits of specific economic activi-
ties and their impacts on broader development
goals. Providing fuller (or in most cases any) infor-
mation on the environmental, social, and economic
impacts of business activities would allow devel-
oping country stakeholders to make more informed
decisions about individual and collective develop-
ment alternatives. Clearly not all investments or
jobs are equal. Developing country stakeholders
should have information available on which to
make informed decisions about development alter-
natives.

3. Trends in CSR Reporting
C
orporate reporting—whether mandated or vol-
untary—on environmental, social, labor, and
human rights issues is a relatively new phe-
nomenon. While a small number of firms have
irregularly published information on their non-
financial performance, more systematic and stan-
dardized systems of social and environmental
reporting only really emerged in the late-1980s and
early-1990s.
Public reporting initiatives received increased
attention after the catastrophes in Bhopal, India,
and Valdez, Alaska in the 1980s. The Bhopal
chemical disaster, and a similar accident at a Union
Carbide facility in West Virginia, led the US
Congress to pass the Emergency Planning and
Community Right-to-Know Act of 1986 which
mandated corporate disclosure of emissions of
toxic chemicals through the Toxic Release Inven-
tory (TRI). The Exxon Valdez oil spill prompted a
group of socially responsible investment firms,
public pension funds, and environmentalists to
establish the Valdez Principles, later renamed the
CERES Principles, which called for voluntary
reporting of key environmental information.
Since the passage of the TRI and the development
of the CERES principles, governments, firms, and
NGOs around the world have developed a wide
range of reporting systems with goals as diverse as
reducing pollution, mitigating health and safety
risks, spotlighting corruption, improving public
service delivery, and protecting civil rights.
17
With
each new initiative in public reporting, public
demands for fuller information and a deeper “right-
to-know” appear to solidify.
3.1. GOVERNMENT MANDATED REPORTING
There are a large number of governments currently
experimenting with or implementing new reporting
requirements for corporations. These programs
often simply require reporting of factual informa-
tion in a standardized format on a regular basis.
Information is then presented in a manner to allow
the public (and government officials) to compare
the performance of firms and make decisions based
on that information. Financial and environmental
reporting are the most advanced of these systems.
However, social, human rights, and governance
reporting are all emerging rapidly around the world.
3.1.1 Financial Disclosure Requirements
The earliest CSR-related reporting requirements
originated in financial disclosure laws designed to
provide information to investors, such as U.S.
Securities and Exchange Commission (SEC) filing
requirements. Under the U.S. Securities Act of
1934 (regulation S-K, Items 101, 103, and 303)
publicly traded firms are required to disclose
“material information”—whether financial or non-
financial—such as environmental liabilities, costs
11
“Pressures for transparency will undoubtedly intensify moving forward.”
—Business for Social Responsibility, 2002

of complying with environmental and other laws,
costs of not complying with these laws, pending
legal proceedings on environmental or other issues,
and any known trends or uncertainties that might
affect the company profits such as environmental
risks, changes in laws, revocation of permits, etc.
18
Despite these statutory requirements, there is cur-
rently a low level of compliance among publicly
traded firms in the US with non-financial disclo-
sure requirements. A 1998 EPA study on disclo-
sure of environmental legal proceedings in 10-K
statements found a non-reporting rate of over 74
percent, and only 16 percent of the firms engaged
in civil or administrative legal proceedings prop-
erly disclosed those proceedings.
19
A number of countries are now strengthening and
expanding financial reporting requirements to
include more stringent disclosures on environmen-
tal, labor, and human rights “liabilities” and “risks”
that might have a material impact on current or
future profits (and thus stock prices) of publicly
traded firms. The French government for instance,
promulgated the Nouvelles Regulations Economi-
ques (NRE) in 2001 which requires mandatory dis-
closure of social and environmental issues in
annual financial reports for all firms listed on the
“premier marche” stock exchange. The NRE estab-
lished indicators against which firms must report
on labor, health and safety, environmental, social,
human rights, and community engagement issues.
2002 was the first year publicly traded companies
were required to report on these indicators, leading
to a notable rise in “voluntary” CSR reporting in
France.
Another example is the 2001 revision of British
pension fund regulations, which require pension
funds to disclose the extent to which CSR issues
are considered in their investment decisions. This
requirement seems to have motivated an increase
in requests for CSR information from financial
analysts and a subsequent increase in CSR report-
ing among UK firms. The proposed “CORE Bill”
on corporate responsibility in the UK would build
on these efforts to require mandatory social and
environmental reporting for UK listed firms.
20
A
current review of Company Law in the UK is also
examining these issues, and assessing the types of
information that should be considered “material”
for social and environmental disclosure.
In 2002, the Johannesburg Stock Exchange (JSE)
became the first exchange to require all listed com-
panies to comply with a code of conduct that stip-
ulates disclosure of non-financial information in
the form of “Integrated Sustainability Reporting.”
This involves mandatory “disclosure of non-finan-
cial information” that is “governed by the princi-
ples of reliability, relevance, clarity, comparability,
timeliness and verifiability with reference to the
Global Reporting Initiative Sustainability Report-
ing Guidelines...” This decision by the JSE marks
the first time a major stock exchange has recog-
nized sustainability reporting according to the GRI
Guidelines.
3.1.2 Environmental Disclosure
Other early reporting initiatives originated in envi-
ronmental disclosure laws, now generally referred
to as Pollutant Release and Transfer Registers
(PRTRs). PRTRs such as the US Toxic Release
Inventory (TRI) created in 1986, the Canadian
National Pollutant Release Inventory (NPRI) cre-
ated in 1993, and the Mexican Registro de Emi-
siones y Transferencia de Contaminantes (RETC)
created in 1996, require public reporting of detailed
information on the types, locations, and amounts of
specific chemicals released or transferred by indus-
trial facilities into the environment.
21
Both the US TRI and the Canadian NPRI systems
require public disclosure of on-site and off-site
pollutant releases and transfers from firms operat-
ing within their borders. The Mexican RETC cur-
rently involves only voluntary reporting, although
the government is taking steps towards mandated
reporting.
22
At their base, programs such as the
TRI are simply pollution accounting systems
which require manufacturing firms of a certain
size to report their annual emissions of toxic
chemicals to the Environmental Protection
Agency (EPA).
23
Emissions are self-reported and
then compiled by the EPA and stored in a database
that is publicly available through the Internet.
24
The EPA does little to check the accuracy of emis-
sions reports, inspecting only approximately three
percent of firms in a given year. Reported data do
not claim to represent actual measures of emis-
sions, but are based on industry estimates of
releases and transfers.
25
Opportunities and Obstacles in CSR Reporting in Developing Countries
12

Trends in CSR Reporting
13
Despite seemingly lax regulation and enforcement,
parties on all sides of the toxics debate—from
chemical manufacturers to regulators to environ-
mentalists—have acknowledged the success of the
TRI. Dow Chemical environmental manager Mil-
lard Etling asserts that the TRI’s “mandatory dis-
closure has done more than all other legislation put
together in getting companies to voluntarily reduce
emissions.”
26
Former Vice-President Al Gore pro-
claimed that “Putting information about local pol-
lution into the hands of the public is the single most
effective, common-sense tool available for pro-
tecting human health and the environment.” Carol
Browner, former head of the EPA, argued that the
TRI “is quite simply one of the most effective
means we have in this country for protecting the
health of our people, the health of our environ-
ment.” Environmentalists go further, calling the
TRI “one of the most successful environmental
laws in US history,”
27
noted for having done “more
to reduce toxic emissions than all of our regulations
taken together.”
28
Intermediary groups have been critical to the func-
tioning and effectiveness of programs like the TRI.
NGOs that analyze PRTR data play a pivotal role in
magnifying pressures from public reporting. The
“Scorecard” project sponsored by Environmental
Defense,
29
the Right-to-Know Network
30
, and the
Pollution Watch Scorecard in Canada
31
, all make
PRTR data more comparable and understandable,
and provide simple tools for the public to compare
firms within an area, generate lists of the worst pol-
luters in a region, and even generate automated faxes
to factory managers inquiring about emissions.
The success of PRTRs in North America has led to
their spread around the world. In 2001, the United
Nations Economic Commission for Europe pro-
mulgated a “Convention on Access to Information,
Public Participation in Decision Making, and
Access to Justice in Environmental Matters,”
known as the Aarhus Convention. An international
protocol on PRTRs was adopted by parties to the
Aarhus Convention in May 2003 which seeks “to
enhance public access to information through the
establishment of coherent, nationwide pollutant
release and transfer registers (PRTRs).” The proto-
col recommends that national PRTR’s be manda-
tory, with annual reporting of multimedia (air,
water, land) emissions, from specific facilities, and
for specific pollutant releases and transfers.
A number of developing countries have also exper-
imented with environmental disclosure systems.
Recognizing the many barriers and limitations to
enforcing their own environmental laws, the
Indonesian Environmental Agency (BAPEDEL)
decided in 1995 to create a simple pollution dis-
closure system called PROPER. The idea of
PROPER was to “create incentives for compliance
through honor and shame”
32
by publicly rating the
environmental performance of factories. PROPER
assigned a color-coded rating—black, red, blue,
green, and gold (in order from worst to best)—to
factories based on their compliance with environ-
mental standards. Ratings were based on monthly
emissions reports filed by firms and corroborated
through spot checks by the environmental agency.
This simple, fairly inexpensive program resulted in
significant reductions in pollution. All of the
“black” rated firms improved to red or blue
between 1995 and 1997, 46 percent of the red firms
improved to blue, and 11 percent of the blue
improved to green.
33
Factory managers reported
that bad PROPER ratings increased pressure from
communities, NGOs and the media, a major moti-
vation for improving environmental performance.
Information from PROPER ratings also helped
managers make better decisions about pollution
reduction as the ratings served as an environmen-
tal audit of the factory. The PROPER rating system
also helped to strengthen BAPEDEL, as the agency
had to improve the technical capacity and public
accountability of its monitoring.
Similar programs supporting public reporting of
environmental information have been, or are cur-
rently being developed in the Philippines, China,
Mexico, India, Colombia, Bangladesh, Australia,
Mexico, Canada, Denmark, Czech Republic, Thai-
land, the Netherlands, Norway, and Sweden. The
European Union has recently promulgated
a related “Integrated Pollution Prevention and Con-
trol Directive” which requires firms to report pollu-
tant emission data to the European Commission.
3.1.3 Social Reporting
The Belgian government recently adopted the
world’s first social reporting and labeling law. In
order the win the right to display this social label,
firms must certify that factories in their production
networks meet ILO core labor standards, and then

allow government accredited auditors to inspect
these factories.
While much newer, there have also been a range of
government social reporting initiatives emerging in
developing countries. For example, new systems of
“participatory budgeting” in Brazil and India have
sought to provide information to average citizens
on where and how government funds are
expended. In Rajasthan, India, campaigns by a
local NGO to combat local corruption and to
include citizens in auditing government officials
have led to experiments in providing citizens with
detailed information on government contracts and
expenditures.
34
Representatives of the Workers
Party in Porto Alegre, Brazil have developed sim-
ilar institutional reforms to make budgeting pro-
cesses more transparent and participatory.
35
Botswana also stands out for its efforts to be more
transparent about economic activities, government
revenues, and expenditures. In a region renowned
for corruption and conflict, Botswana has been
listed by Transparency International as the most
transparent and least corrupt country in Africa. To
avoid being branded as a producer of “conflict dia-
monds,” Botswana has established systems for reg-
ulating the diamond trade through increased public
reporting of both revenues from diamond produc-
tion and state expenditures of these revenues.
Botswana currently boasts spending almost 27 per-
cent of its budget on education expenses (among the
highest per capita education spending in the world).
3.2 “VOLUNTARY” REPORTING
“Some may argue that reporting makes the com-
pany more transparent, and therefore exposed to
more criticism…we believe that today it is the lack
of transparency that is more risky, particularly in
the wake of recent corporate scandals.”—WBCSD,
2002
There has been a rapid growth in “voluntary” cor-
porate codes of conduct and reporting initiatives
over the last 10 years. Almost half of the world’s
largest firms now regularly report on CSR issues.
3.2.1 Leading Firms
KPMG has surveyed global firms—both the top
250 companies in the Global Fortune 500 (referred
to as the GFT250) and the top 100 companies in
each of 19 countries—regarding their public
reporting every three years since 1993. This survey
recently found that 45 percent of the GFT250 now
produce some form of non-financial report, com-
pared to 35 percent of these firms in 1999. As
KPMG notes, social and environmental reporting
“is becoming mainstream business.”
36
In 1993,
only 13 percent of the top 100 firms in the countries
studied produced a health, safety, or environmen-
tal report. That number had risen to 17 percent by
1996, 24 percent by 1999, and 28 percent of top
100 firms produced reports by 2002.
Firms are also increasingly employing independent
auditors to verify or assure the data presented in
their reports. Third party verification increased
gradually during this period from approximately
15 percent of reporters in 1996, to 18 percent in
1999, to 27 percent in 2002. The UK and Japan led
all countries in the rates at which their firms
employed third party verification of CSR reports.
The 2003 Benchmark Survey produced by the
European “csr network”
37
found similar trends in
corporate reporting. 48 percent of the top 100 firms
in the world produced public reports on social or
environmental issues in 2002. The csr network
evaluated this reporting according to 32 categories
and found that:
• 25 percent of companies surveyed produced
integrated social and environmental reports;
• 23 percent of companies produced only envi-
ronmental reports;
Opportunities and Obstacles in CSR Reporting in Developing Countries
14
Table 1—Global Firms Voluntarily Reporting
1993 1996 1999 2002
Non-Financial Reporting by the Global Fortune Top 250 35% 45%
Non-Financial Reporting by the Top 100 Companies in 19 Countries 13% 17% 24% 28%
Independent Verification of Reports 15% 18% 27%
Source: KPMG International Survey 2002

Trends in CSR Reporting
15
• 26 percent of reporting companies published
their position with respect to human rights;
• 48 percent of reporting companies disclosed
health and safety information;
• 40 percent of reporting companies included
independent assurance of their findings (up from
18 percent in 2000);
• 32 percent of firms now have stakeholder
engagement processes;
• 75 percent of reporting companies now report
their greenhouse gas emissions; and,
• 37 percent of reporting companies made refer-
ence to the Global Reporting Initiative (GRI).
3.2.2 Geographic and Sectoral Variation
In both the KPMG and csr network surveys, there
were clear geographical and sectoral variations in
reporting. KPMG noted that 72 percent of Japanese
firms published environmental or social reports, 49
percent of UK firms, and only 36 percent of US
firms. The csr network found 70 percent of
Japanese firms, 69 percent of European firms, and
only 18 percent of US firms reporting.
The high rate of reporting among Japanese firms is
likely due to government guidelines on environ-
mental reporting. Growth in reporting in France
(from 4 percent in 1999 to 21 percent in 2002) and
the United Kingdom (from 32 percent in 1999 to 49
percent in 2002) is likely due to new regulations
(being developed or already implemented) requir-
ing reporting by publicly listed firms. This rapid
growth in reporting clearly shows the potential of
governments to motivate (or mandate) reporting.
Reporting is increasing in most countries, with the
notable exception of the United States, where cor-
porate reporting has oscillated from a rate of 44
percent in 1996, to only 30 percent in 1999, back
up to 36 percent in 2002. The csr network noted
that 62 percent of non-reporting companies in their
survey were based in the US.
These surveys also found variations in reporting
by industrial sector. The electronics and auto
industries had very high reporting rates (90 per-
cent of the firms in the csr network survey) com-
pared to financial services (only 27 percent
reporting). Interestingly, the KPMG survey also
found very high reporting rates in the mining sec-
tor. 100 percent of GFT250 mining firms pro-
duced CSR reports in 2002, while 33 percent of
top 100 mining firms produced reports. As is con-
sistent with other research, larger multinational
firms report more frequently than smaller domes-
tic firms.
38
There is also variation in participation in reporting
schemes across countries. Some developing coun-
tries are taking a lead in supporting voluntary CSR
reporting. Brazil for instance, has developed a
national system of “Social Balance Sheets,” that
although still voluntary, are now quite common
among large publicly traded firms.
39
The Social
Balance Sheets (SBS) report direct and indirect
social and environmental impacts of a company’s
operations, including employee benefits and labor
conditions, ethical codes, product life-cycle
impacts, philanthropic investments, etc. More than
500 companies now produce SBS’s annually in
Brazil, and leading Brazilian NGOs give an award
to the company with the best SBS each year.
3.2.3 Characteristics of Firms Most Likely to
Report
Based on recent evaluations of firm reporting
practices such as the KPMG and csr network sur-
veys, and consumer polling data on firms under
pressure to report, it is not surprising that large,
branded manufacturing firms are currently the
most likely to voluntarily report on CSR issues.
These firms are most “reputation sensitive” and
thus most at risk of information or bad news about
poor practices. Furthermore, according to polls
conducted by Marymount University, consumers
believe that manufacturers, and not retailers, are
responsible for the social and environmental
impacts of products.
40
That said, it is interesting to note from the KPMG
surveys that national firms in developing countries
are also increasingly reporting. Here again though,
we see higher reporting rates within industries that
have been targeted by advocacy groups around
controversial issues such as human rights and envi-
ronmental impacts of mining.
These trends would seem to indicate that in the
future even small firms that connect into the sup-
ply chains of high-profile brands and retailers will
be under pressure to report their CSR practices.

3.2.4 NGO and Multi-Stakeholder Reporting
Initiatives
Despite the overall growth in rates of disclosure,
some NGOs remain critical of both the breadth and
depth of corporate reporting. In a survey of mem-
ber companies, Business for Social Responsibility
found that while firms are under increasing pres-
sure to publish social and environmental informa-
tion, only a few share information on conditions in
supplier factories, and none of their respondents
provided comprehensive data on the effectiveness
of their CSR programs or included external stake-
holders in the development of their reporting pro-
grams.
41
NGOs have thus sought to expand the
universe of firms reporting, the issues they report
on, and how they report, through a range of multi-
stakeholder initiatives.
The Global Reporting Initiative
A new NGO, the Global Reporting Initiative
(GRI), has emerged as one attempt to respond to
these reporting debates and problems of standard-
ization. Founded in 1997 in the US, and now based
in Amsterdam, the GRI seeks to advance globally
applicable guidelines for voluntary self-reporting
of economic, environmental and social perfor-
mance of firms. The GRI is working to establish a
global standard for corporate reporting, creating a
system analogous to financial reporting proce-
dures for environmental and social issues. GRI has
both general “core guidelines” for sustainability
reporting that are meant to be applicable to all
firms, and is now developing “sector supple-
ments” that provide guidelines for specific indus-
tries. These guidelines aim to support and guide a
globally accepted CSR reporting framework.
As Allen White, the former Executive Director
explains, the goal of the GRI is “to make sustain-
ability reporting as routine as financial report-
ing.”
42
While still quite young, over 300
companies from 26 countries have referenced the
GRI guidelines in their reporting.
A number of firms however, have complained that
the GRI standards for reporting are “setting the bar
unrealistically high…[with] a unique blend of mea-
sures that were onerous to collect whilst being unin-
formative.”
43
Some firms complain of too many
indicators (50 core indicators) that are too difficult
to measure and report. While some NGOs and trade
groups have complained conversely that the GRI is
in essence too weak as it focuses primarily on pol-
icy indicators (i.e., whether a company has a policy
on a topic or not), rather than actual measures of per-
formance.
44
Nonetheless, the GRI continues to lead
efforts to develop a global standard for reporting.
Verification and Assurance
An increasingly important adjunct to reporting
involves efforts to “verify” or “assure” the infor-
mation presented in CSR reports. A new “assur-
ance” industry has emerged over the last several
years to audit corporate reports and attest to their
content. The British NGO AccountAbility has
developed an assurance standard call AA1000
45
which seeks to improve the quality, consistency,
and comparability of reporting information by
advancing a standard for assessing, attesting to,
and improving the credibility of CSR report-
ing. This standard is based around the basic prin-
ciples of: materiality, completeness, and respon-
siveness.
Labor Practices Reporting
Other multi-stakeholder initiatives are also emerg-
ing to advance CSR evaluation and reporting.
Growing public awareness and activist pressures
around “sweatshop” issues have led to a recent pro-
fusion of programs in the US and Europe to estab-
lish standardized codes of conduct, systems of
monitoring, and public reporting. Six major initia-
tives of this type have emerged: the Fair Labor
Association (FLA), Social Accountability Interna-
tional (SAI), the Worldwide Responsible Apparel
Production (WRAP) certification program, the
Workers Rights Consortium (WRC), the Ethical
Trading Initiative (ETI), and the Fair Wear Foun-
dation (FWF). Each of these programs has a code
of conduct informed largely by ILO core standards,
and a system in place for monitoring compliance
with their codes. A small army of monitors includ-
ing accounting firms, professional service firms,
and small non-profit organizations are emerging to
provide third party monitoring and verification ser-
vices. These non-governmental regulatory systems
collect, analyze, and make public different types of
information. Some are completely confidential,
providing information only to corporate managers.
Others are fully transparent, with all investigation
reports made public.
The WRAP certification program, for instance,
currently provides virtually no information to the
Opportunities and Obstacles in CSR Reporting in Developing Countries
16

Trends in CSR Reporting
17
public, even on factories audited or certified. SAI
currently lists certified factories on its web site and
is in discussions about making public information
on the resolution of complaints at SA8000 certified
factories. The ETI employs a kind of “club trans-
parency” for its audits. Members of the ETI—
including NGOs and union representatives—can
review audit reports and aggregate data. However,
this information is not available to the general pub-
lic. The WRC has committed to full public disclo-
sure of monitoring results. Currently, all inspection
reports are made public through its web site and
media releases. These reports provide detailed
analyses of individual factories, and insights into
problems common in apparel suppliers. The WRC
has also developed a database of factory locations
for member universities.
46
The FLA recently
unveiled a new transparency initiative that pro-
vides “tracking charts” of individual factories
(without names or locations), detailing noncompli-
ance findings by FLA-accredited monitors and
tracking progress of participating brands in reme-
diating these problems.
47
Clearly, these initiatives are at the very early
stages of development, are trying to recruit new
participants, and are thus often reluctant to be
fully transparent about their processes or audit
results. Companies remain concerned about dis-
closing information on factory locations or con-
ditions that might be used by their competitors or
critics. Disclosure is thus still quite limited in
these programs.
One critical piece of information that has been
made public by several of these initiatives is the
names and locations of factories sourcing for
multinational brands and retailers. The student
anti-sweatshop movement in the US has made this
a central demand of their campaigns, and has been
successful in winning fuller disclosure of factory
locations from university licensees. It is now pos-
sible to identify factories producing for leading
colleges. Several brands have also voluntarily dis-
closed this information, although the vast majority
still do not.
Firm Reporting
A small number of firms are also beginning to
make public summaries of their external audit
reports. Nike has published summaries of external
audits (under a program dubbed Transparency
101), aggregate data on factories producing uni-
versity-logo goods, and factory locations.
48
Nike
also published a “corporate responsibility report”
in 2002 in line with GRI reporting guidelines. Adi-
das recently published a report disclosing the
country locations of supplier factories, the number
that have been audited, and the number of con-
tracts terminated due to failures to comply with the
company’s code. Adidas has also developed a
“supplier scoring system” and releases summary
data on scores for factories in Asia, the Americas,
and Europe. Otto Versand similarly collects audit
results (based on the SAI system) of its suppliers
and analyzes compliance patterns across coun-
tries. These firms and others are gathering very
rich data on factory practices and labor and envi-
ronmental compliance around the world. How-
ever, to date, very little of this information has
been made public.
3.2.5 International Initiatives
At the international level, the OECD guidelines for
multinational enterprises were significantly revised
in 2001
49
and now require much greater trans-
parency. The Guidelines remain the only compre-
hensive, multilaterally endorsed code of conduct for
MNCs, and establish a range of non-binding stan-
dards and principles for corporate practice includ-
ing recommendations for advancing corporate
social accountability through disclosing environ-
mental and social performance information.
50
The United Nations is also advancing voluntary
codes and reporting procedures through the Global
Compact initiative, created by the UN General
Secretary in 2000. The Global Compact is in the
words of the UN “not a regulatory instrument or
code of conduct, but a value-based platform
designed to promote institutional learning. It uti-
lizes the power of transparency and dialogue to
identify and disseminate good practices based on
universal principles.”
51
Towards this end, the
Global Compact asks companies to commit to
respecting nine principles, including respect for
human rights, labor rights (basically the ILO core
standards), and the environment, and to report
annually on their progress on advancing these prin-
ciples. The Global Compact and GRI now work
together, with GRI reports qualifying for Global
Compact annual reporting.

Another interesting initiative seeking to advance
transparency and reporting is the Publish What
You Pay (PWYP) campaign.
52
PWYP is a coalition
of over 130 NGOs from 35 countries advocating
for multinational corporations to publicly report on
payments (such as royalties, signature bonuses,
and tax payments) to developing country govern-
ments for oil, gas, and mineral concessions. The
goal of this campaign is to mandate reporting that
supports citizen efforts to hold developing country
governments accountable for the uses of revenues
from natural resource extraction. The coalition has
argued that reporting should be mandatory for all
firms as companies that unilaterally report finan-
cial payments to governments may have their
licenses revoked and awarded to less transparent or
less scrupulous companies.
PWYP seeks to create better information for both
investors in developed countries and for citizens
of developing countries to know how much rev-
enue is being generated from the exploitation of
their national resources. PWYP seeks explicitly to
put pressure on reputationally sensitive oil, gas,
and mining firms to prove that they are not brib-
ing corrupt officials or diverting funds that should
be used for local development purposes. The
PWYP coalition is also now advancing demands
for governments to “publish what they earn” from
resource extraction. The coalition recently drafted
an amendment to a proposed EU “Transparency
Obligations Directive” that would require the dis-
closure of payments by companies listed in the
EU to any government, public body, or public
official.
Opportunities and Obstacles in CSR Reporting in Developing Countries
18
Table 2—Labor Monitoring and Reporting Initiatives
Social
Fair Labor Accountability Worldwide Worker Rights
Association International Responsible Apparel Consortium Ethical Trading Fair Wear
(FLA) (SA8000) Production (WRAP) (WRC) Initiative (ETI) Foundation
www.fairlabor.org www.sa8000.org www.wrapapparel.org www.workersrights.org www.ethicaltrade.org www.fairwear.nl
Scope Apparel and Factories Apparel industry. University Licensed Wide range Apparel
footwear producing Goods. of industries: industry
companies. a wide range agriculture, wine, (initially only
Licensees of of products. apparel, firms sourc-
affiliated electronics, etc. ing to Dutch
universities. retailers).
Reporting All internal and Audit reports go Audit reports are Firms do not directly Firms report the Companies
external monitor- to the companies provided to factories report to the WRC. results of auditing submit audit
ing reports be and to SAI. and the WRAP board. The WRC sends and pilot studies to reports and
provided to the FLA Other parties investigation teams the ETI board and corrective
staff. The FLA eval- can only receive to areas of member organiza- action plans to
uate audits, jointly them after hav- controversy and tions. the FWF
develop remediation ing signed a conducts its own office.
plans, and then pub- confidentiality evaluations.
lish summary reports agreement with
of audit remediation the company
results. and the audit
company.
Public Annual reports on Public disclosure No public reporting. Full public reporting Disclosure of Disclosure of
Disclosure each company based of factories No mention of sites of investigation aggregate results brands partici-
on internal and extern- granted certifi- that receive, fail, or findings. to the public. pating in FWF,
al monitoring. Partici- cation. lose certification. Detailed reporting the countries
pating companies are only available to of operation,
publicly listed on web- members of the ETI. and the number
site. No disclosure of of suppliers in
locations of certified each country.
factories. Business data
and worker
interviews are
kept confidential.
Source: Organizational web sites.

Trends in CSR Reporting
19
The UK government has responded in part to the
demands of the PWYP coalition by developing a
pilot program called the Extractive Industries
Transparency Initiative (EITI). The EITI will in-
volve 5 to 8 voluntary country-level pilot systems
of transparency and reporting on payments to gov-
ernments and revenues from extraction of natural
resources. Anglo American, British Petroleum,
Newmont, Rio Tinto, Shell, and Statoil are all par-
ticipating in the project, as are the governments of
Azerbaijan, East Timor, Ghana, Indonesia, Nigeria,
Sierra Leone, and Trinidad & Tabago.

21
A
critical question of course is whether current
reporting initiatives are having any impact.
Do they make a difference in consumer prefer-
ences and purchases? Do they influence investors
to avoid poor performers (and higher risks), and to
invest in good performers? Do they influence firm
decision-making at any point along a supply
chain? Is the information used by government
agencies to more effectively regulate or provide
technical assistance? Does the information benefit
local development goals? Essentially, does report-
ing have any impact on consumers, firms, govern-
ments, workers, or other key stakeholders? And if
reporting does make a difference, when and under
what conditions is it most effective?
As a number of researchers have discovered, it is
extremely difficult to evaluate the effectiveness of
CSR reporting initiatives on their own. First, these
initiatives are still quite young, so there is limited
data to evaluate their impacts over time. Second,
transparency initiatives are often tied up in larger
packages of reforms. Socially responsible, “high-
road” management practices may include CSR
reporting, but it is often difficult to isolate and
evaluate these impacts.
There are of course clear examples of ineffective
CSR reporting. Many corporations still produce
reports that are flawed, unreliable, unsystematic,
unverifiable, immaterial to key stakeholders, and
largely designed as public relations. This reporting
can actually have negative value—serving to con-
fuse or deceive stakeholders, and costing firms
time and money that could be spent actually
improving practices. This has led at least one
researcher to conclude that, “little evidence to date
exists of social and sustainability reporting pro-
viding an effective tool in making a real difference
to corporate decisions, practices and outcomes.”
53
While accepting that there is ineffective (and even
deceptive) reporting. There also appears to be
some reporting that is quite serious and that can
have positive impacts. A number of anecdotal
accounts claim that reporting can help companies
better measure, manage, and communicate their
performance.
54
Researchers thus continue to look
for data to systematically evaluate the impacts of
reporting, and to make the “business case” for
reporting. Early research that has been conducted
points to interesting, albeit tentative findings on
the impacts of reporting on investors, consumers,
and local stakeholders such as workers and com-
munity members.
4.1 INVESTOR RESPONSES
The public face of corporate performance is often
a simple measure: a company’s stock price. This
single number often contains public (or really Wall
Street) expectations about current profitability,
management practices, worker productivity, mar-
ket prospects, and future risks and liabilities. It is
thus important to look at how investors—and stock
prices—respond to the release of information on
corporate environmental and social practices.
Through an “event study” of corporate environ-
mental disclosures (in the form of annual Toxic
Release Inventory releases), media coverage, and
stock market responses, research has found that
“firms reporting TRI pollution figures experienced
negative, statistically significant abnormal returns
upon the first release of the information.”
55
Researchers have found that the market does not
4. Impacts of CSR Reporting

just punish polluting firms, but rather punishes
firms with the greatest discrepancies between
existing information and reported results. As the
EPA has explained, “firms were not solely pun-
ished or rewarded based on levels of emissions, but
on level of disclosure and magnitude.”
56
In-
vestors it seems don’t like to be surprised with bad
news, or with news that is divergent from existing
information on a company.
Researchers have found similar dynamics in stock
market responses to public disclosures of labor
practices. One event study of public reports of
“sweatshop” practices found that public reports of
poor practices “cause firms’ stock prices to fall,
sometimes substantially.”
57
Interestingly, this study
also found that stock prices reacted positively to
actions and reports of positive actions on labor
practices. Negative sweatshop news resulted in sub-
stantial losses in stock prices. Positive reports
resulted in statistically significant positive returns.
Other researchers have shown that capital markets
in developing countries similarly react rapidly to
good and bad environmental information.
58
A recent survey conducted for the World Bank also
has shown that multinational enterprises do track
the performance of their partners in developing
countries, and the climate and conditions of coun-
tries. An increasing number of these multinational
firms are choosing to not invest in or partner with
“bad” companies, and to avoid countries altogether
that don’t enforce CSR-related regulations.
59
There are of course limitations to investor
responses to information on labor and environ-
mental practices. The lack of systematic, standard-
ized information on firm practices (except for
mandatory pollutant release information in some
countries) make investor responses often some-
what random and based on sporadic news reports.
Simplified, standardized metrics of performance
and reporting would support investor decision-
making. This information would also help con-
sumers make more informed decisions about the
companies they want to support or avoid.
4.2 CONSUMER RESPONSES
Over three quarters of consumers polled in the US
assert that they would avoid purchasing products if
they knew they were made under poor working
conditions. Eighty six percent of these respondents
claim they would pay an extra dollar on a $20 gar-
ment if it was guaranteed to be made in a legiti-
mate, sweat-free factory.
60
Surveys conducted by
other researchers report even higher “willingness
to pay” for “sweat-free” garments among con-
sumers, with 76 percent of respondents in one sur-
vey asserting they would pay 25 percent more for
a $20 garment if it were certified to not be made in
a sweatshop, and respondents in another survey
claiming they would pay 28 percent more on a $10
item, and 15 percent more on a $100 item.
61
Researchers assert that these findings indicate that
“consumers are prepared to alter their shopping
behavior in order to help deter the practice of
sweatshop labor.”
62
However, despite these very high numbers who
claim they would avoid bad products and pay more
for good products, the actual data on “ethical con-
sumption” shows that only a small percentage of
consumers actually implement these concerns in
the marketplace. A recent study in the UK showed
that ethical consumption currently represents only
about two percent of market transactions, with
“ethical boycotts”—avoiding bad firms—a leading
aspect of ethical consumption.
63
Other research has
shown that approximately five percent of the pub-
lic strictly follows ethical concerns in their pur-
chasing.
64
One might ask whether the failure of consumers to
actually buy socially responsible products is due to
an unwillingness to pay more when they pull out
their wallets. That is, though no one wants to admit
in a survey that they would buy products made in a
sweatshop, in the privacy of their own purchases
they buy the best deal.
Or perhaps, as some have argued, consumers lack
credible information on the environmental and
social impacts of the products they buy, which
inhibits their ability to purchase their desired level
of social responsibility. Do consumers simply
need credible labels and standard performance cri-
teria to support their “willingness to pay more”
and their desire to “buy different”? Would addi-
tional, and better information lead to more con-
sumers avoiding bad products and purchasing
good products? Or would this information just
confuse consumers further with claims and
counter-claims?
Opportunities and Obstacles in CSR Reporting in Developing Countries
22

Impacts of CSR Reporting
23
Unfortunately there is limited empirical research
on these questions. Evidence from approximately
20 years of “green consumer” campaigns indicates
that people do think and care about ethical, social,
environmental, and health concerns. Again,
roughly three quarters of people polled in OECD
countries call themselves environmentalists and
report that they would purchase a green product
over an environmentally problematic product.
However, again only 10-12 percent of consumers
actually go out of their way to purchase environ-
mentally sound products.
65
Debates continue on
explaining this divide between stated preferences
and actions.
On many of the central issues of corporate respon-
sibility, it also appears that “bad news” is more
influential than good news. That is, consumers use
the disclosure of bad news to help them screen out
and avoid socially irresponsible companies. So it is
quite common now for consumers to report that
they regularly boycott a company. In the UK, over
50 percent of respondents in a recent poll claimed
they had punished a firm by boycotting it in the last
year.
66
Positive information about a company’s
practices appears to have a less clear influence on
purchasing patterns.
67
Consumers thus remain something of a contradic-
tion. They report significant concern for CSR
issues. But only a small percentage proactively
seek out good firms or products. They do however
punish firms for bad practices. This threat of bad
news, and the growing likelihood for bad news to
surface from far-flung, global supply chains may
be leading some firms to be proactive, to evaluate
their supply chains, and to communicate perfor-
mance clearly, rather than waiting for information
to emerge on its own.
4.3 OTHER STAKEHOLDER RESPONSES
Other stakeholders, such as workers—both
employees of MNCs and of local firms—and com-
munity members impacted by corporate activities,
also respond to CSR reporting and other public
information on corporate activities and impacts.
In one recent international survey of MNCs, top
CEOs reported that employee retention was the
most important impact of a positive corporate rep-
utation, and that transparency was a key factor in
determining this reputation. 71 percent of CEOs
cited recruiting and retaining employees as the top
business benefit of CSR activities and communi-
cations.
68
Local community members are also often very
interested in information that helps them evaluate
the environmental and social impacts of firms. The
Indonesian “PROPER” program (discussed above
in section 3.1.2) and similar programs around the
world have shown high demand among community
members for even the most basic information on
corporate practices and impacts. Disclosure of this
information can support community awareness of
the benefits and costs of economic development
activities, and can facilitate community mobiliza-
tions and demands for solutions to environmental
and social problems caused by firm activities. The
“Publish What You Pay” campaign has also high-
lighted strong demand among community members
for information on what MNCs are paying their
governments for oil, mining, and other concessions.
With all of these different stakeholders and differ-
ent uses of CSR information, questions remain
regarding what information firms should be report-
ing? In what forms? For which stakeholders? And
whether this information could be made systematic
and comparable across firms and countries?

W
ith hundreds of corporations now produc-
ing reports, a wide range of laws being
implemented around the world, and dozens of non-
governmental initiatives on transparency and
reporting emerging, there is staggering variation in
what is reported, in what forms, and for which
audiences. The Lawyers Committee for Human
Rights reports over 2000 different indicators of
labor standards used in corporate codes and moni-
toring systems.
69
This range and variation in report-
ing can cause information overload and actually
increase difficulties for comparing factories,
brands, or countries.
As Zadek argues, it is critical to determine what
matters most to stakeholders, and to report these
“material” facts in formats that are understandable,
useful, and comparable.
70
CSR reporting is in fact
in some danger now of reporting too much data that
is not meaningful to critical stakeholders. The
many audiences for CSR information are over-
whelmed with information, and simultaneously
over-stretched for time and resources to evaluate
this information. It is thus critical that information
is reported in the simplest, most direct, easy to
understand and comparable formats.
The first question for CSR reporting is simply
what to measure and report? Stakeholders are
increasingly concerned about not only current firm
performance, but also processes for managing
risks and remediating problems identified in a sup-
ply chain. A number of reporting schemes are
immersed in heated debates about exactly what
information should be considered “material.” The
US courts have held (in regards to financial dis-
closure) that a fact is material “if there is a sub-
stantial likelihood that a reasonable sharehold-
er would consider it important in deciding how
to vote”
71
or in making other critical decisions.
AccountAbility similarly defines material infor-
mation as information that allows a firm’s “stake-
holders to be able to make informed judgments,
decisions, and actions.”
72
These definitions unfortunately don’t help much in
narrowing the scope of information that might be
included in CSR reports. Information considered
“material” by different government agencies,
firms, and NGOs has included a wide range of indi-
cators of financial, environmental, social, and
human rights performance and policies. These
include, but are not limited to data on:
5. Key Metrics of Corporate
Social Responsibility
25
“For tomorrow’s corporate sustainability reporting to be effective, and so to survive, requires, in short, that
it communicates information that is ‘material’ to stakeholders in their efforts to make coherent decisions
and take planned and timely actions relevant to their interests.”
—Simon Zadek, 2003

Environmental Performance:
• Compliance with environmental laws (rates of
non-compliance, fines, legal proceedings, etc.);
• Emissions of toxic chemicals to air, water, and
land;
• Emissions of greenhouse gases;
• Material flows—energy, raw materials, water,
land, etc. ;
• Product life-cycle assessment;
• Environmental management systems (e.g., ISO
14000);
• Disclosure of environmental risks to local com-
munity members.
Respect for Labor Rights:
• Policies on freedom of association, collective
bargaining, non-discrimination, child labor, and
forced labor;
• Facilitation of freedom of association and rates
of unionization;
• Formal agreements with independent trade
unions;
• Wages (comparable to industry average, prevail-
ing wage, or “living wage”);
• Employee benefits provided;
•Working hours.
Health and Safety Practices:
• Rates of occupational injuries, diseases, and
fatalities;
• Lost time from injuries;
• Hazard communication programs;
• Training on health and safety;
• Joint employee-management health and safety
committees.
Respect for Human Rights:
• Countries of operation with problematic human
rights records;
• Role of government or military in factory opera-
tions;
• Political and economic rights guaranteed to
employees.
Community Economic Development and Social
Impacts:
• Percent of profits reinvested in community from
which profits earned;
• Percent of profits paid into a local community
development trust;
• Impacts on local development patterns of invest-
ments/suppliers.
Corporate Governance:
• Internal accountability procedures;
• Composition of the Board;
• Management compensation;
• Disclosure of potential conflicts of interest.
Corporate Payments to Governments:
• Payments for contracts or concessions;
• Corporate taxes and royalty payments;
• Donations to candidates for political office or
political parties.
Stakeholder Engagement:
• Policies and procedures for engagement;
• Frequency and forms of engagement;
• Information that is accessible and understandable
to stakeholders.
Supply Chain Management:
• Locations of factories/farms/mines in supply
chain;
• Number of workers in supply chain;
• Code implementation and monitoring program;
• Systems for measuring and monitoring perfor-
mance;
• Compliance staff numbers and budgets;
• Process for verification of reported data.
Forward-looking Information:
• Scenario planning to avoid specific problems;
• Plans for dealing with future risks.
Opportunities and Obstacles in CSR Reporting in Developing Countries
26

6. Challenges of Reporting
T
here are a number of major challenges to mak-
ing CSR reporting effective. Questions re-
main in different sectors and countries on what to
report, in what form, to what level of detail, to what
audiences, and for what uses. There are real chal-
lenges—even for those committed to reporting—
to design information systems that are accessible,
easy to understand, useful, and rigorous.
There are also weaknesses and problems with cur-
rent systems of CSR reporting, and important bar-
riers to expanding public disclosure systems
around the world. On the one hand is the problem
alluded to above, that corporations are disclosing
both too much data and not enough material infor-
mation that is useful to stakeholders. If CSR
reports are not perceived as useful, few firms will
bother to invest the time and resources to produce
them, and even fewer stakeholders will read them.
6.1 METRICS AND MATERIALITY
Primitive metrics for many CSR issues, and con-
tinuing disagreements on key measures of perfor-
mance, have led to reports using widely varying
indicators, some of which are vague, unclear, irrel-
evant to major impacts, misleading, or worse.
There is also the related problem of CSR reporting
being captured by marketing and PR departments
of companies.
73
Some CSR reporting has become
focused largely on “reputation assurance” and pub-
lic relations rather than material reporting that can
help improve management practices or stakeholder
decisions. Cases of firms gaming reporting or mis-
representing practices and conditions, all too com-
mon now in financial reporting as well, create the
danger of eroding public faith in all CSR reporting.
6.2 INCENTIVES TO DISCLOSE
At the same time, there are clear barriers to firms
openly reporting problems, mistakes, pollution,
etc., in their operations. Firms are inclined to focus
more on the “good news” of corporate philan-
thropy and voluntary initiatives, than bad news in
their supply chains. And the “business case” for
more material CSR reporting remains elusive, as
costs are concentrated on a few disclosers, and ben-
efits to investors, workers, community members,
etc., are diffuse and often limited.
74
Nonetheless,
there are increasing pressures on “brand” firms to
disclose key information to their stakeholders to
build trust and/or protect their reputations.
6.3 SUPPLY CHAINS
The nature of certain business models, particularly
global supply chain relations, create further barri-
ers to firms reporting key information on condi-
tions down their production networks (such as
wages, working conditions, hours of work, injuries,
etc.) The complex and shifting structure of global
supply chains makes it extremely difficult for out-
side organizations (and sometimes even buyers) to
track the locations of production for global prod-
ucts, let alone conditions in these facilities.
27

6.4 COSTS
Firms face costs of both gathering and disseminat-
ing information, and potential costs from public
responses to their reporting. Some early reporters
have faced increased criticism from frank disclo-
sure of their challenges.
75
Costs also appear to
increase as reporting gets more detailed and com-
prehensive. These costs create significant incen-
tives for firms either to avoid reporting altogether,
or to produce CSR reports that are simply PR.
There are also costs to users of CSR information.
The groups that often benefit most from disclosure
systems, such as neighbors of polluting factories,
workers in mines, or consumers of hazardous prod-
ucts, rarely have the time or resources to gather
information or to verify that information is accu-
rate and credible. This results in only a small num-
ber of stakeholders actually looking at publicly
reported information or demanding improved
reporting.
6.5 ANALYZING REPORTING
Stakeholder groups also sometimes need assistance
to analyze data presented in CSR reports. Techni-
cal (and financial) information sometimes needs to
be translated—such as from pounds of chemical X
released, or wages of workers in country Y—into
meaningful information, such as the risk posed by
the releases of the chemical or the implications for
livelihoods of workers. Translating complex infor-
mation into simple-to-understand indicators
requires resources, time, and technical capacities.
Third-party intermediary organizations are thus
critical for collecting, comparing, analyzing, inter-
preting, reformatting, explaining, and disseminat-
ing raw information from environmental, health
and safety, and social reports. These groups need
resources and staff to do this analysis and dissem-
ination.
6.6 CONSUMERS
Finally, many stakeholders are frustrated by the
continuing inability of citizens to simply compare
the social and environmental performance of spe-
cific firms. A lack of consistency and comparabil-
ity in reporting schemes, and a profusion of general
information that is not material, has limited the
ability of average citizens and consumers to use
information to inform their day-to-day decisions.
The goal of many groups to create mechanisms for
evaluating and labeling products and processes
remains a distant reality.
Opportunities and Obstacles in CSR Reporting in Developing Countries
28

29
T
here is no single reporting system or model of
corporate transparency that fits all social or
environmental problems. However, there are some
basic principles which can support efforts to
advance and improve CSR reporting. First, report-
ing initiatives should seek to increase the quality of
information disclosed. Second, they should work
to increase the uses of the information and the ben-
efits to users. Third, they should create mecha-
nisms for learning and continuously improving
disclosure systems.
These goals can be supported through explicit
efforts to target information to specific stakehold-
ers and decision-making processes. Information
should be reported in formats useful to specific
users. And efforts should be made to verify that
information is used by stakeholders to inform their
decisions.
7.1 STANDARDIZED METRICS
Continued work is needed on standardized metrics
and indicators for reporting. However, metrics in
general should be:
• Agreed upon by key stakeholders (representing
what matters to them);
• Factual, accurate, and verifiable;
• Reported at regular intervals in relatively simple
language or data;
• Comparable across locations, firms, and prod-
ucts;
• Flexible/dynamic, so that metrics can change
over time;
• Usable by key stakeholders;
• Easily accessible.
7. Strategies for Improving
Reporting
“Careful analysis of the character of the information problem as well as user and discloser costs and
benefits is needed to determine whether transparency is a promising regulatory approach. Substantial
benefits to users, the presence of third party organizations to press for system improvement, and
economic or political dynamics that lead some disclosers to promote improved transparency are all
factors that influence sustainability” of reporting.
—Archon Fung, Mary Graham, and David Weil, Harvard University.

Opportunities and Obstacles in CSR Reporting in Developing Countries
30
7.2 INCENTIVES FOR CONTINUOUS
IMPROVEMENT
Efforts are also needed to support continuous
improvements in reporting. As mentioned, inter-
mediary groups are critical to analyzing and
deploying information, and perhaps more impor-
tantly, to creating demands for improved reporting.
Stakeholder groups with built-in incentives for
using, analyzing, and monitoring the quality of the
information are central to the long-term sustain-
ability of reporting schemes.
76
In financial disclo-
sure, investors play this role of demanding high
quality, verifiable information upon which to base
their investments. In environmental disclosure
(such as the TRI), environmental groups use the
data, translate it for wider consumption, and keep
pressure on the government and firms to improve
reporting. No equivalent group currently exists for
CSR reporting in developing countries, or indeed
social reporting.
Disclosure systems can also be designed to create
incentives and benefits for leading disclosers. Gov-
ernments can foster certain kinds of disclosure
through a range of traditional economic incentives,
and through regulatory flexibility mechanisms.
Finally, in any system of disclosure it is critical to
establish mechanisms to track changes in reporting
practices over time, the impacts of this reporting,
and whether learning is occurring from reporting.
All of these strategies can be supported or directly
advanced through government actions.

T
o date, CSR reporting has largely been driven
from the north, often by large multinational
firms, private investors, or non-governmental orga-
nizations. Nonetheless, there are important roles
for governments, and particularly developing
country governments, to play in further advancing
reporting systems.
The World Bank has previously grouped govern-
ment roles in supporting corporate social responsi-
bility into five categories of action: mandating,
facilitating, partnering, endorsing, and demonstrat-
ing.
77
Each of these strategies of action can support
the kinds of improvements discussed above. Gov-
ernments, and their citizens, however, must decide
how they can most effectively support an environ-
ment for socially responsible business, and specif-
ically advance CSR reporting.
The following section lays out essentially a menu
of actions governments might take to advance CSR
reporting.
8.1 MANDATING
Governments can legally mandate reporting
requirements through company law, stock listing
regulations, pension fund regulations, or direct dis-
closure laws. These laws can set precise standards
for corporate reporting, including lists of metrics,
formats for reporting, and frequency of reporting.
Governments can also set other laws—such as tax
laws, labor standards, environmental regulations,
etc.—that establish measurement and reporting
requirements.
Governments can then monitor this reporting, both
by evaluating reporting data and comparing it to
physical inspections of facility performance. Gov-
ernment agencies can work to ensure the quality of
reported data by requiring external, third-party ver-
ification procedures, quality assurance standards,
and regulations for auditors of CSR reports. Gov-
ernment agencies can then oversee these verifica-
tion and assurance procedures and hold auditors
accountable.
Governments can also mandate sanctions for non-
disclosure or false disclosures of CSR data to cre-
ate incentives for full and accurate reporting.
8.2 FACILITATING
Governments can also work to facilitate CSR
reporting through the development of voluntary
guidelines for reporting. A government agency
8. Government Roles in
CSR Reporting
31
“The market does not provide sufficient incentives for companies to report on their social and environmental
impacts on a voluntary basis.”
—Deborah Doane, New Economics Foundation.

Opportunities and Obstacles in CSR Reporting in Developing Countries
32
might work with trade associations, firms, or
multi-stakeholder organizations to design volun-
tary programs. The government could then play a
facilitating role in assisting in the collection, colla-
tion and dissemination of CSR information.
Government agencies could then work to support
users of CSR information both inside and outside
firms. One strategy for facilitating firm learning
would involve disseminating information from
reporting through a program of technical assis-
tance to firms to learn about “best practices” in
their industry. Government technical assistance
might also support improved participation of small
and medium-sized enterprises (SMEs) in reporting
systems. Governments can also support and moti-
vate increased dialogue with the business commu-
nity to ensure CSR reporting is in line with
government priorities and policies.
Governments might go even further to tie report-
ing and performance to tax incentives, export pro-
motion assistance, export quotas, buyer-supplier
matching, or direct production subsidies. Trade
and investment promotion could significantly
motivate and facilitate reporting.
Government efforts can also support citizens and
NGOs who seek to use CSR information to moti-
vate laggards to improve performance.
Perhaps the most important form of facilitation
would involve building a stable and transparent
environment for socially responsible business
within a country. This would involve basic efforts
to improve the openness and accountability of gov-
ernance structures and economic markets.
8.3 PARTNERING
Governments can also play a positive role through
partnering with specific groups to support report-
ing. By engaging multi-stakeholder initiatives or
individual firms, government agencies can act as
partners in the development of reporting initia-
tives. Government agencies can also establish and
support simple networks of reporting firms in order
to facilitate learning on environmental or social
problems and strategic responses.
Government agencies might also “partner” by pro-
viding government collected data (or links to
government databases) to non-governmental dis-
closure systems. Government data on enforcement
actions, compliance rates, numbers of inspections,
etc., could be very useful to civil society assess-
ments of firm performance.
Governments can also partner in convening stake-
holders, helping to open dialogues and decision-
making processes to stakeholders, and to facilitate
learning.
8.4 ENDORSING
Governments can focus more on endorsing disclo-
sure through positive efforts to increase awareness
of CSR issues by commending, supporting, and
honoring firms that are transparent. Government
agencies can support award programs, disseminate
information on “leading” firms, and otherwise lend
credibility and legitimacy to company efforts.
Governments can create a wide range of incentives
and rewards for firms that act responsibly and take
a leadership position on reporting.
Governments can also help to better inform the
public, and particularly consumers, about the per-
formance of firms. Government statements and
reports can help transparent firms distinguish them-
selves in the marketplace. Government agencies
can also work with financial and sustainability rat-
ing agencies to highlight superior performance of
firms within a country.
Over the long-term, governments might also use
endorsing strategies to market a region or country
that supports a positive climate for socially respon-
sible firms, that hosts firms that produce sustain-
able, fair trade, or socially responsible goods, and
that publicly reports on conditions and practices in
their country.
8.5 DEMONSTRATING
Finally, governments can directly demonstrate the
principles of increased transparency by publicly
disclosing material information on their own activ-
ities. Governments are in many countries either the
largest, or one of the largest: employers; con-
sumers of goods and services; owners of land, min-
eral rights, buildings, vehicles, etc.; and users of
energy and other resources. Over the last several
years, a number of governments have thus begun
initiatives to provide information to the public on

Government Roles in CSR Reporting
33
the impacts of this consumption, employment, and
resource management.
Some governments are now taking a leading role in
“walking the talk” to show private sector entities—
from whom they are demanding increased trans-
parency—that government agencies can be held to
similar standards. These initiatives range from sim-
ple disclosure of raw data on the environmental,
social, and economic impacts of government
agency operations, to structured reporting of per-
formance information, to reporting on the effec-
tiveness of government policies and programs, to
progress reports (with trend data over time) on gov-
ernment efforts to achieve sustainability goals.
In recognition of these varied initiatives, the Global
Reporting Initiative (GRI) has begun a project to
learn from and help standardize public agency sus-
tainability reporting.
78
A number of governments
are now sponsoring this work and experimenting
with GRI reports for their operations, in order to
demonstrate the benefits of reporting for other gov-
ernment agencies, private sector actors, and the
public.

T
here is clear potential for government action,
particularly in developing countries, to
advance and strengthen CSR reporting. However,
in thinking about designing an appropriate and
effective disclosure system in a developing coun-
try, it is also critical to recognize that there are no
perfect systems, no easily replicable programs, and
no one-size-fits-all standards for reporting.
Countries must begin by experimenting with pilot
programs in reporting that build on existing capac-
ities and concerns, and that are tailored to local
industries and development goals. A CSR report-
ing system is also more likely to succeed if it can
build on areas of mutual interest between stake-
holders in the developing and developed world.
Successful initiatives in environmental disclosure
(PRTRs, PROPER, etc.), anti-sweatshop monitor-
ing and disclosure (the FLA, WRC, etc.), and anti-
corruption disclosure (the Extractive Industries
Transparency Initiative, Publish What You Pay,
etc.) all seek to connect developed and developing
country firms, NGOs, workers, communities, and
government agencies interested in addressing a dif-
ficult problem.
These initiatives advance fairly simple programs
for systematic release of standardized information,
and then publicly compare the performance of fac-
tories, firms, or governments. Programs seek to
force out information about business practices into
the public sphere, foster public debate about
acceptable labor, environmental, and social stan-
dards, enlist a wide range of actors in evaluating
business practices, build the capacity of stakehold-
ers to participate in dialogues about solutions, and
use multiple mechanisms to incentivize firms to
improve their performance. All of these initiatives
however, hinge on the dynamic of producing rich
information that allows key stakeholders to com-
pare the performance of economic actors, and in
more refined systems to benchmark good perform-
ers, identify and target the worst performers, and
motivate improvements among all actors.
As noted above, governments can play widely
varying roles in these initiatives, from mandating
disclosure, to overseeing verification and assur-
ance, collating information, disseminating data,
convening stakeholders, facilitating dialogues,
supporting intermediary groups to use the data,
commending leaders, learning from disclosure, and
leading by example.
But how might a government actually take steps to
advance CSR reporting, or to experiment with
reporting as a strategy of governance and economic
development? Below, is a preliminary proposal for
advancing CSR reporting in a developing country,
with specific mention of two industrial sectors:
apparel and mining. This proposal is meant as a
starting point for thinking about actual steps
needed to pilot test CSR reporting in a developing
country.
9.1 STEP-BY-STEP ACTIONS FOR A PILOT
PROGRAM ON CSR REPORTING
Countries interested in CSR reporting might:
• Interview local stakeholders and investors about
the information they need to make critical deci-
sions;
9. A Draft Pilot Program for
CSR Reporting
35

Opportunities and Obstacles in CSR Reporting in Developing Countries
36
• Establish a central coordinating office to set
guidelines for reporting, then collect, collate,
quality check, and compare information on facil-
ity performance;
• Require firms to publicly disclose locations of
factories/mines;
• Require firms to annually report performance
criteria (described below) in a standardized for-
mat;
• Establish a central database accessible over the
Internet which would contain performance
information on factories/mines, and simple
means for comparing firms along selected crite-
ria, such as wages, health & safety, labor prac-
tices, environmental performance, etc.;
• Create mechanisms for public comparison of
firm performance (that could for example, lead
to the publication of lists of leading and laggard
firms in each sector);
• Publish lists of “best practices” and the firms
that employ them;
• Publish a CSR Sourcing book of leading local
firms and distribute this to multinational corpo-
rations, investors, and trade associations for
assistance in matching MNCs with local suppli-
ers that meet their CSR standards;
• Use publicity to motivate firms to improve per-
formance to match the best practices identified
in their industry. Spotlight, publicly commend,
and support leading firms;
• Support capacity building of non-governmental
groups to verify reporting;
• Establish a process for ground-truthing fac-
tory/mine performance information by workers
themselves;
• Aggregate firm level performance data to show
overall compliance rates, regional variations,
improvements over time, and best practices in
social and environmental performance within
the country. Include this information in invest-
ment marketing to foreign firms.
An effective pilot project should be designed as an
open system that invites key stakeholders to take
part in discussions about measures of performance
and systems of reporting. For the sake of providing
a starting point for this discussion, firms might dis-
close a number of standard “core indicators” of
facility performance, and indicators specific to sec-
toral issues and concerns.
9.2 POSSIBLE “CORE INDICATORS”
1. Name and location of factory/mine and number
of employees;
2. Incidence of violations of local laws, penalties,
legal proceedings, etc. in the last year;
3. Wages and benefits paid to workers (averages,
minimum, highest), and incidence of violations
of minimum wage laws;
4. Working hours and overtime worked. Inci-
dence of violations of maximum working hour
laws and overtime pay laws;
5. Policies for identification and elimination of
harassment and discrimination. Data on diver-
sity in management and work areas;
6. Policies for identification and elimination of
child, forced, and compulsory labor (including
system for determining accurate age of work-
ers);
7. Indicators of respect for workers rights to free-
dom of association (such as percent of workers
in a union, union-management relations, work
stoppages, lock-outs, strikes, etc.);
8. Health and safety performance (rates of acci-
dents, injuries, occupational diseases, and
deaths);
9. Environmental impacts: estimates of air and
water emissions of toxic chemicals, environ-
mental penalties, settlements, fines, and viola-
tions;
10. Policies for monitoring compliance with local
laws and codes of conduct.
9.3 POSSIBLE SECTOR-SPECIFIC INDICATORS
• In the apparel sector—including garments and
footwear—stakeholders are particularly con-
cerned about: wages (does the company pay a
“living wage”); hours of work; forced overtime;
freedom of association and the right to form
unions; sexual harassment; and health and safety
(exposures to glues, solvents, accidents, repeti-
tive stress injuries, etc.). The government could
convene a stakeholder group to determine
exactly which measures would be most appro-
priate for this sector.
• In the mining industry, stakeholders are particu-
larly concerned about: payments to local gov-
ernments for concessions; health and safety
(how many miners die per year); wages; free-

A Draft Pilot Program for CSR Reporting
37
dom of association; local community develop-
ment impacts (does the community benefit from
the extraction of local natural resources); and
local environmental impacts. The government
could convene a stakeholder group to determine
exactly which measures would be most appro-
priate for this sector.
In the pilot program it would make sense to begin
with simple indicators, hopefully including infor-
mation that is already being collected in supply
chain compliance programs or that is already
required by government regulations, and then to
gradually focus and improve this information over
time.
9.4 CONCLUSIONS
By starting with a small set of core indicators, ver-
ifying that they are material to stakeholders, eval-
uating uses of the information, and soliciting
feedback on the quality of the data, it would be pos-
sible to gradually expand and deepen CSR indica-
tors to include sector specific issues. By having the
reporting driven by local concerns and capacities,
it would also be possible to gradually connect to
and compare with global reporting schemes such as
the GRI.
Government agencies and NGOs might play a role
in verifying CSR reporting information, and grad-
ually working to improve the credibility and
accountability of reporting.
Finally, a government agency could work to aggre-
gate data, and to produce a national CSR report.
This information would support future compar-
isons of country-level performance on CSR issues.
The program could also help local firms establish
and demonstrate their social and environmental
performance, and facilitate socially and environ-
mentally responsible firms connecting into high
value supply chains.

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American Pollutant Releases and Transfers, Montreal: CECNA.
Conroy, Michael (2001), “Can Advocacy-Led Certification Systems Transform Global Corporate Practices? Evi-
dence and Some Theory,” Political Economy Research Institute, University of Massachusetts, Amherst, Working
Paper Series No. 21.
CSR Network (2003), “Material World: The 2003 Benchmark Survey of Global Reporting,” Bath, England: csr
network.
Doane, Deborah (2002), “Market Failures: The case for mandatory social and environmental reporting,” London:
New Economics Foundation.
Extractive Industries Transparency Initiative (2003), “Statement of Principles and Agreed Actions,” London Con-
ference, June 17, 2003.
Franco, Nicholas (2001), “Corporate Environmental Disclosure: Opportunities to Harness Market Forces to
Improve Corporate Environmental Performance,” paper presented at the American Bar Association conference on
Environmental Law, March 8-11, 2001, Keystone, CO.
Fung, Archon, Mary Graham, and David Weil (2002), “The Political Economy of Transparency: What Makes Dis-
closure Policies Sustainable?” OPS-02-03, Institute for Government Innovation, Harvard University.
10. References
39

Fung, Archon, Dara O’Rourke, and Charles Sabel (2001), Can We Put an End To Sweatshops?, Boston: Beacon
Press.
Fung, Archon and Dara O’Rourke (2000), “Reinventing Environmental Regulation from the Grassroots Up:
Explaining and Expanding the Success of the Toxics Release Inventory,” Environmental Management, vol. 25,
no. 2, pp.:115-127.
Global Reporting Initiative (2004), “Public Agency Sustainability Reporting—A GRI Resource Document in
Support of the Public Agency Sector Supplement Project,” Amsterdam, January, available at: http://www.glob-
alreporting.org/guidelines/resource/public.asp
Graham, Mary (2001), “Information as Risk Regulation: Lessons from Experience,” RPP-2001-04, Center for
Business and Government, Harvard University, Cambridge, MA.
Hearne, Shelley (1996), “Tracking Toxics: Chemical Use and the ‘Right-to-Know,’” Environment 38: 4-33.
Hill & Knowlton (2003), “2003 Corporate Reputation Watch Survey,” available at: www.corporatereputation-
watch.com
International Institute for Environment and Development (IIED) (2002), “Baseline Study of Public Sector Roles
in Strengthening Corporate Social Responsibility,” paper prepared for the Corporate Social Responsibility Pro-
gram, Washington, D.C.: World Bank.
Jenkins, Rob and Anne Marie Goetz (1999), “Accounts and accountability: theoretical implications of the right-
to-information movement in India,” Third World Quarterly, vol. 20, no. 3. pp.: 603-622.
Khagram, Sanjeev, Christin Mary Hokenstad, and Maria Cecilia Coutinho de Arruda, (forthcoming) “For a Clear
Picture: Focus on the Brazilian Social Balance Sheet,” Harvard Business Review - Latin America.
KPMG (2002), “International Survey of Corporate Social Responsibility Reporting,” Amsterdam: KPMG.
Lawrence, A.T. and Morell, D. (1995) “Leading-Edge Environmental Management: Motivation, Opportunity,
Resources, and Processes,” Research in Corporate Social Performance and Policy, Supplement 1: 99-126.
Nadvi, Khalid, and Frank Wältring (2003), “Making Sense of Global Standards,” in Hubert Schmitz (ed.), forth-
coming, Local Enterprises in the Global Economy: Issues of Governance and Upgrading, Edward Elgar, Chel-
tenham.
Oldenziel, Joris, (2000), “The 2000 Review of the OECD Guidelines for Multinational Enterprises: A New Code
of Conduct?” SOMO, Amsterdam.
Publish What You Pay (2003), “Frequently Asked Questions about the ‘Publish What You Pay’ Campaign,”
available at: http://www.publishwhatyoupay.org/faq.shtml
Rock, Michael (2001), “Public Disclosure of the Sweatshop Practices of American Multinational Garment/Shoe
Makers/Retailers: Impacts on Their Stock Prices,” Technical Paper No. 252, Washington, D.C.: Economic Pol-
icy Institute.
Roe, David (2000), “Starting Blocks for Environmental Information Policy,” draft paper available at:
www.edf.org/wip/starting_blocks.html
Seabrook, C. (1991), “Your Toxic Neighbors: Disclosures Spark Improvements; Pollution Law Brings A Clearer
Picture; But Industry Response Still Not Enough, EPA Says,” Atlanta Journal and Constitution (August 22):
Sec. G, p. 1.
Trade Union Advisory Committee (2001), “The OECD Guidelines on Multinational Enterprises: A User’s
Guide,” Paris.
Wade, Will (2003), “A Good Corporate Citizen? This Scanner Can Tell,” New York Times, August 28, 2003.
Opportunities and Obstacles in CSR Reporting in Developing Countries
40

White, Allen (2003), “The 2002 GRI Guidelines: Clearing Up the Misunderstandings,” Ethical Corporation,
May 21, 2003.
Wolf, S. M. (1996), “Fear and Loathing about the Public Right to Know: The Surprising Success of the Emer-
gency Planning and Community Right-to-Know Act.” Journal of Land Use & Environmental Law 11: 217-324.
World Bank (2003), “Race to the Top: Attracting and Enabling Global Sustainable Business,” report prepared
for the Corporate Social Responsibility Practice of the World Bank by Political and Economic Link Consulting
and Ethical Corporation Magazine, Washington: World Bank, October 2003.
World Business Council for Sustainable Development (WBCSD) (2002), “Sustainable Development Reporting:
Striking the Balance,” available at www.wbcsd.org
World Resources Institute (WRI) (2000), “Pure Profit: the Financial Implications of Environmental Perfor-
mance,” Washington, D.C.: World Resources Institute.
Zadek, Simon (2003), “Materiality in Reporting,” Ethical Corporation, August 7, 2003.
References
41

1. Baue, William (2002), “CalPERS Divests from Four Emerging Countries,” SocialFunds.com, available
at: http://www.socialfunds.com/news/article.cgi?sfArticleId=790
2. Business for Social Responsibility (BSR) (2002), “Social Compliance Benchmarking: Results of Survey
One,” San Francisco, Sept. 17, 2002.
3. World Bank (2003), “Race to the Top: Attracting and Enabling Global Sustainable Business,” report pre-
pared for the Corporate Social Responsibility Practice of the World Bank by Political and Economic Link
Consulting and Ethical Corporation Magazine, Washington: World Bank, October 2003.
4. Graham, Mary (2001), “Information as Risk Regulation: Lessons from Experience,” RPP-2001-04,
Center for Business and Government, Harvard University, Cambridge, MA.
5. Wade, Will (2003), “A Good Corporate Citizen? This Scanner Can Tell,” New York Times, August 28,
2003.
6. Franco, Nicholas (2001), “Corporate Environmental Disclosure: Opportunities to Harness Market Forces
to Improve Corporate Environmental Performance,” paper presented at the American Bar Association
conference on Environmental Law, March 8-11, 2001, Keystone, CO, p.4.
7. World Business Council for Sustainable Development (WBCSD) (2002), “Sustainable Development
Reporting: Striking the Balance,” p. 14, available at www.wbcsd.org
8. Roe, David (2000), “Starting Blocks for Environmental Information Policy,” draft paper available at:
www.edf.org/wip/starting_blocks.html
9. Graham, Mary (2001), “Information as Risk Regulation: Lessons from Experience,” RPP-2001-04,
Center for Business and Government, Harvard University, Cambridge, MA.
10. Nadvi, Khalid, and Frank Wältring (2003), “Making Sense of Global Standards” in Hubert Schmitz (ed.),
forthcoming, Local Enterprises in the Global Economy: Issues of Governance and Upgrading, Edward
Elgar, Cheltenham.
11. See for instance, Fung, Archon, Dara O’Rourke, and Charles Sabel (2001), Can We Put an End To
Sweatshops?, Boston: Beacon Press; and, Conroy, Michael (2001), “Can Advocacy-Led Certification
Systems Transform Global Corporate Practices? Evidence and Some Theory,” Political Economy
Research Institute, University of Massachusetts, Amherst, Working Paper Series No. 21.
12. Franco, Nicholas (2001), “Corporate Environmental Disclosure: Opportunities to Harness Market Forces
to Improve Corporate Environmental Performance,” paper presented at the American Bar Association
conference on Environmental Law, March 8-11, 2001, Keystone, CO.
13. World Resources Institute (WRI) (2000), “Pure Profit: the Financial Implications of Environmental
Performance,” Washington, D.C.: World Resources Institute.
14. Cited in Franco (2001).
Notes
43

15. Roe, David (2000), “Starting Blocks for Environmental Information Policy,” draft paper available at:
www.edf.org/wip/starting_blocks.html
16. World Business Council for Sustainable Development (WBCSD) (2002), “Sustainable Development
Reporting: Striking the Balance,” available at www.wbcsd.org
17. Fung, Archon, Mary Graham, and David Weil (2002), “The Political Economy of Transparency:
What Makes Disclosure Policies Sustainable?” OPS-02-03, Institute for Government Innovation, Harvard
University.
18. Ibid.
19. Franco, Nicholas (2001), “Corporate Environmental Disclosure: Opportunities to Harness Market Forces
to Improve Corporate Environmental Performance,” paper presented at the American Bar Association
conference on Environmental Law, March 8–11, 2001, Keystone, CO.
20. http://www.amnesty.org.uk/business/campaigns/core/bill.shtml
21. Commission for Environmental Cooperation of North America (CECNA) (2003), Taking Stock 2000:
North American Pollutant Releases and Transfers, Montreal: CECNA.
22. Currently 172 facilities in Mexico voluntarily report data on releases and transfers of listed chemicals to
the government.
23. Currently approximately 23,000 firms operating in SIC codes 20–39, which employ 10 or more full-time
workers, and which produce or use toxic chemicals above threshold levels report the release or transfer of
some 651 chemicals to the TRI.
24. The most recent TRI data can be accessed on the World Wide Web at http://www.epa.gov/tri/. From this
web site interested parties can download data on a specific factory, on emissions in a county, on national
trends in releases of a specific chemical, or can compare emissions between factories in the same sector.
25. Wolf, S. M. (1996), “Fear and Loathing about the Public Right to Know: The Surprising Success of the
Emergency Planning and Community Right-to-Know Act.” Journal of Land Use & Environmental Law
11: 217–324.
26. Seabrook, C. (1991), “Your Toxic Neighbors: Disclosures Spark Improvements; Pollution Law Brings A
Clearer Picture; But Industry Response Still Not Enough, EPA Says,” Atlanta Journal and Constitution
(August 22): Sec. G, p. 1.
27. Hearne, Shelley (1996), “Tracking Toxics: Chemical Use and the ‘Right-to-Know,’” Environment 38:
4–33.
28. Lawrence, A.T. and Morell, D. (1995) “Leading-Edge Environmental Management: Motivation,
Opportunity, Resources, and Processes,” Research in Corporate Social Performance and Policy, Supple-
ment 1: 99–126.
29. www.scorecard.org
30. www.rtk.net
31. www.pollutionwatch.org
32. Afsah, Shakeb and Damayanti Ratunanda (1999), “Environmental Performance Measurement and
Reporting in Developing Countries: The Case of Indonesia’s Program for Pollution Control Evaluation
and Rating (PROPER),” in M. Bennett and P.J. Sheffield (eds.) Sustainable Measures: Evaluation and
Reporting of Environmental and Social Performance, London: Greenleaf Publishing, pp:185-201.
33. Afsah, Shakeb, Allen Blackman, and Damayanti Ratunanda (2000), “How Do Public Disclosure Pollution
Control Programs Work? Evidence from Indonesia,” Resources for the Future, Discussion Paper No. 00–44.
Opportunities and Obstacles in CSR Reporting in Developing Countries
44

Notes
45
34. Jenkins, Rob and Anne Marie Goetz (1999), “Accounts and accountability: theoretical implications of the
right-to-information movement in India,” Third World Quarterly, vol. 20, no. 3. pp.: 603-622.
35. Baiocchi, Gianpaolo (2003), “Participation, Activism, and Politics: The Porto Alegre Experiment,” in
A. Fung and E.O. Wright (eds.) Deepening Democracy, New York: Verso.
36. KPMG (2002), “International Survey of Corporate Social Responsibility Reporting,” Amsterdam: KPMG,
p.5.
37. CSR Network (2003), “Material World: The 2003 Benchmark Survey of Global Reporting,” Bath,
England: csr network.
38. KPMG (2002), “International Survey of Corporate Social Responsibility Reporting,” Amsterdam: KPMG,
p. 13.
39. Khagram, Sanjeev, Christin Mary Hokenstad, and Maria Cecilia Coutinho de Arruda, (forthcoming) “For
a Clear Picture: Focus on the Brazilian Social Balance Sheet,” Harvard Business Review – Latin America.
40. http://www.marymount.edu/news/garmentstudy/findings.html
41. Business for Social Responsibility (BSR) (2002), “Social Compliance Benchmarking: Results of Survey
One,” San Francisco, Sept. 17, 2002.
42. White, Allen (2003), “The 2002 GRI Guidelines: Clearing Up the Misunderstandings,” Ethical
Corporation, May 21, 2003.
43. Baker, Mallen (2002), “The Global Reporting Initiative – Raising the Bar Too High?” Ethical
Corporation, Oct. 16th, 2002.
44. World Business Council for Sustainable Development (WBCSD) (2002), “Sustainable Development
Reporting: Striking the Balance,” p. 14, available at www.wbcsd.org
45. www.accountability.org.uk
46. http://www.workersrights.org/fdd.asp
47. http://www.fairlabor.org/all/transparency/index.html
48. http://www.nike.com/nikebiz/nikebiz.jhtml?page=25&cat=collegiate
49. See for commentary, Trade Union Advisory Committee (2001), “The OECD Guidelines on Multinational
Enterprises: A User’s Guide,” Paris. And Oldenziel, Joris, (2000), “The 2000 Review of the OECD Guide-
lines for Multinational Enterprises: A New Code of Conduct?” SOMO, Amsterdam.
50. It should be noted however, that key stakeholders to the Guidelines have complained of a continuing lack
of transparency on current cases, and a lack of clarity on National Contact Point (NCP) procedures and
case resolutions. Unions and NGOs have thus recommended the creation of a centralized on-line database
or clearinghouse on the status of cases before NCPs. This “registry of cases” could provide real-time infor-
mation on cases of concern to stakeholders around the world, including information on the status of the
NCP process to investigate and resolve the complaint, and the final outcome. Stakeholders have also
argued for greater transparency on the companies involved in specific instances, that is, “naming names”
of companies.
51. www.unglobalcompact.org
52. www.publishwhatyoupay.org
53. Monaghan, Philip (2003), “Impacts of Reporting: Uncovering the ‘Voluntary vs. Mandatory’ Myth,”
AccountAbility Quarterly, p. 4.
54. KPMG (2002), “International Survey of Corporate Social Responsibility Reporting,” Amsterdam: KPMG.

55. Hamilton, James (1995), “Pollution as News: Media and Stock Market Reactions to the Toxics Release
Inventory Data,” Journal of Economics and Environmental Management, vol. 28: 98–113.
56. EPA (1997), “Stock Performance of Environmentally Responsible Companies,” Environmental Damage
Valuation and Cost Benefit News, vol. IV, no. 6.
57. Rock, Michael (2001), “Public Disclosure of the Sweatshop Practices of American Multinational Gar-
ment/Shoe Makers/Retailers: Impacts on Their Stock Prices,” Technical Paper No. 252, Washington,
D.C.: Economic Policy Institute.
58. Dasgupta, S., B. Laplante, and N. Mamingi (1998), “Capital Market Responses to Environmental News in
Developing Countries,” World Bank, Washington, D.C., available at: www.worldbank.org/nipr/
59. World Bank (2003), “Race to the Top: Attracting and Enabling Global Sustainable Business,” report pre-
pared for the Corporate Social Responsibility Practice of the World Bank by Political and Economic Link
Consulting and Ethical Corporation Magazine, Washington: World Bank, October 2003.
60. http://www.marymount.edu/news/garmentstudy/findings.html
61. Elliott, Kim and Richard Freeman (2000), “White Hats or Don Quixotes? Human Rights Vigilantes in the
Global Economy,” Cambridge, MA: NBER.
62. http://www.marymount.edu/news/garmentstudy/findings.html
63. The Co-operative Bank (2003), The Ethical Consumer Report 2003, London.
64. Doane, Deborah (2002), “Market Failures: The case for mandatory social and environmental reporting,”
London: New Economics Foundation.
65. Makower, Joel (2000), “Whatever Happened to Green Consumers?” Organic Consumer Association,
July/August, available at: http://www.organicconsumers.org/Organic/greenism.cfm
66. The Co-operative Bank (2003), The Ethical Consumer Report 2003, London.
67. Elliott, Kim and Richard Freeman (2000), “White Hats or Don Quixotes? Human Rights Vigilantes in the
Global Economy,” Cambridge, MA: NBER.
68. Hill & Knowlton (2003), “2003 Corporate Reputation Watch Survey,” available at: www.corporatereputa-
tionwatch.com
69. http://workersrights.lchr.org/
70. Zadek, Simon (2003), “Materiality in Reporting,” Ethical Corporation, August 7, 2003.
71. Franco, Nicholas (2001), “Corporate Environmental Disclosure: Opportunities to Harness Market Forces
to Improve Corporate Environmental Performance,” paper presented at the American Bar Association
conference on Environmental Law, March 8-11, 2001, Keystone, CO.
72. www.accountability.org.uk
73. Doane, Deborah (2002), “Market Failures: The case for mandatory social and environmental reporting,”
London: New Economics Foundation.
74. Fung, Archon, Mary Graham, and David Weil (2002), “The Political Economy of Transparency: What
Makes Disclosure Policies Sustainable?” OPS-02-03, Institute for Government Innovation, Harvard Uni-
versity.
75. As one example, Reebok was criticized in the media for reporting problems in their factories in Indonesia,
despite the firm being forthcoming about these problems and investing funds to resolve them.
Opportunities and Obstacles in CSR Reporting in Developing Countries
46

Notes
47
76. Fung, Archon, Mary Graham, and David Weil (2002), “The Political Economy of Transparency:
What Makes Disclosure Policies Sustainable?” OPS-02-03, Institute for Government Innovation,
Harvard University.
77. International Institute for Environment and Development (IIED) (2002), “Baseline Study of Public
Sector Roles in Strengthening Corporate Social Responsibility,” paper prepared for the Corporate Social
Responsibility Program, Washington, D.C.: World Bank.
78. Global Reporting Initiative (2004), “Public Agency Sustainability Reporting – A GRI Resource
Document in Support of the Public Agency Sector Supplement Project,” Amsterdam, January,
available at: http://www.globalreporting.org/guidelines/resource/public.asp