Showing posts with label ethics. Show all posts
Showing posts with label ethics. Show all posts

Saturday, September 26, 2015

5 truths about Volkswagen and CSR

It's just incredible how everyone is jumping down the throat of sustainability and sustainability reporting as a result of the Volkswagen crimes against emissions. Is the sustainability movement so fragile that the deliberate fraudulent behavior of one corporation can disrupt the credibility of thousands of corporations that are making genuine efforts to act ethically, responsibly and ... wow, even legally? The first thing many people are saying now that Volkswagen is down the tubes is: "Aha, vindicated at last, that's the end of CSR. Just look at Volkswagen's last Sustainability Report. What a waste of paper. This just proves that CSR is all a big waste of time. It's about time we started refocusing on business and leaving out the sustainability PR stuff.

A few examples from the flurry of writings over the past couple of days:

"Volkswagen takes down corporate social responsibility in its plunge to the bottom of the sea"
Linda Greer's blog on the NRDC likens Volkswagen's statements in its sustainability report to something out of a Hollywood script. She finds it incredible that environmental professionals actually believe anything that's written in self-reported glossy brochures and infographics. Now that Volkswagen is exposed, she says we have to reevaluate what other companies are up to.

"Volkswagen and the dark side of corporate sustainability"
Lauren Helper's post focuses on ratings and rankings, noting that the DJSI is now developing a new picture of public perception that will be factored in to DJSI rankings. The conclusion is foregone. DJSI will want to drop Volkswagen even faster than shareholders are dumping Volkswagen's stock. And then of course, the entire voluntary thing is now on the chopping table. If it's a voluntary disclosure, it must be rubbish. Henk Campher, a well-known PR player in sustainability circles actually says "I'm not surprised this happened!". Lack of regulation and paying too much attention to ratings and rankings are apparently among the root causes according to Henk.

"VW Scandal a Jolt to 'CSR' That Reaches Far Beyond the Auto Industry"
Leon Kaye's take on the Volkswagen impact, published on Sustainable Brands also makes the point that Volkswagen cheated = CSR is rubbish: "For too long now, CSR has focused far more on theatrics and less on tangible results.....CSR lens tends to focus on accolades and congratulate each other for stories well told ..Volkwagen’s struggles send a signal to the CSR and sustainability crowd that it must start changing its tone and set its sights on what it does best - helping organizations operate more sustainably.... " According to Leon, the sustainability movement risks "irrelevance" because one corporation has managed to get away with cheating the system for a few years.

"VW Scandal Exposes What Has Gone Awry with ‘CSR’"
Another article from Leon Kaye, this time on Triple Pundit, offers a similar take: "Unfortunately, while the ideals behind corporate social responsibility certainly have merit, the overall execution has been deeply flawed. The trend in CSR has been to focus more on goals and aspirations, and less on concrete and tangible results."

"The Volkswagen diesel deception - 5 key questions "
Rather than delivering their own diatribe denouncing CSR and Sustainability movement, Crane and Matten ask five questions about the "nature of corporate responsibility" that arise as a result of Volkswagengate. Top of the list - you guessed it. " How is it possible that a company committed to some of the core values of corporate responsibility could so blatantly cross the line into not only unethical but clearly illegal practice in a key area of its responsibilities? Is this just another greenwash case to fuel further cynicism about the CSR commitment of corporations?"

"Here's The Joke Of A Sustainability Report That VW Put Out Last Year"
Emily Peck at Huffington Post takes the well-traveled path, pulling holes Volkswagen's statements about values, commitment and ethics. She even counts the number of times the word "environment" appears in Volkswagen's last report. She calls it an absurd document.

Well, folks, let me set a few things straight. It's easy enough to get settled in on the CSR-bashing bandwagon. Instead, I offer five truths about the current discourse on Volkswagen and CSR.

ONE: The fact that a company is highly placed in rankings and ratings means not all that much.

In my view, rankings and ratings are designed in the best interests of the rankers and the raters. I believe they are rarely rigorous enough or balanced enough to be a reliable guide for investors or for any other stakeholder. Comparability among companies, even within sectors, remains nebulous. Ratings are designed to give the rankers and the raters a claim to fame and often, a revenue stream. Just look at how the same company can rank top in one system and bottom in another and pretty much everywhere on the spectrum in several others. Rankings and ratings are not necessarily a bad things (as long as we don't believe them). They play a role in framing a debate and generating some competitive interest. They can be a CEO hook. That can encourage companies to do better. On the other hand, rankings may encourage companies to appear to do better. Possibly the strive to be a supersector superpower partially fuelled the creative criminality at Volkswagen, who knows? The point is, just the fact that Volkswagen was a DJSI superstar is not directly connected to the set of actions that caused the current issue. And the fact that one company screwed up does not make the rankings and ratings any better or any worse than they already are.

I think my respected colleague Antonio Vives comes to the same conclusion. More or less. My Spanish is not that good. In his article about Volkswagengate, he concludes: "Esto también nos demuestra que las calificaciones, rankings y premiso de responsabilidad deben tomarse con mucha suspicacia." which Google translated for me as "This also shows that the ratings, rankings and permission of responsibility should be taken with great suspicion."


TWO: The fact that a company produces great sustainability reports does not mean it is perfect.

Oh dear!! Did I disappoint you? Did you think that Sustainability Reporting comes with a squeaky clean bill-of-health in the sustainable-company department? Well, it does come with a guarantee. But not the one you think. Sustainability Reporting comes with a guarantee that the information that is NOT reported is the information that is MOST relevant to stakeholders. Hah. Work that one out. The upside is that sustainability reporting adds value in so many ways and the information that IS reported often has value as well. But the fact that there was dirty dealing at Volkswagen does not means that every single word in its Sustainability Report was untrue, or that other sustainability reports of other companies are suddenly irrelevant. Sustainability reporting as a process adds value, it empowers people, it catalyzes performance and it enables dialogue. One dirty player doesn't change that. But it does remind us that, as stakeholders, we are the vigilantes. When was the last time you asked a company about something they published in their Sustainability Report? It's easy to sit on the sidelines and say the system doesn't work when you are doing nothing to make it work.

THREE: The fact that people break the law is a fact. It's not always preventable. That's not about sustainability. Sometimes it's just breaking the law. 

How many companies have Codes of Ethics these days? All of them? How many companies have people who work for them that break the law? All of them? How many companies say they value women in management? All of them? How many companies have less than 50% women in management? Nearly all of them? How many companies have teams of lawyers fighting legal breaches or misdemeanors? Most of them? The point is that there will always be differences between saying and doing and there will always be people who break the law. They may be your family, your friends, your neighbors, your colleagues, your employees or your bosses. If they want to break the law, there's probably nothing you can do to stop them. Unless you speak out. Why did no-one at Volkswagen speak out? That's the most interesting question of all. How many people were complicit in this crazy scheme and how many thought they were acting in their own best interests? I guess we will hear the sensational details sooner or later, but if I were in a CEO seat right now, I would start making whistle-blowing one of the top corporate values alongside reinforcing the values of trust, honesty, legal and ethical behavior. As we say in the Middle East, "Trust in Allah, but tie your camel."  But does the fact that people want to break the law and the corporate culture is not strong enough to prevent them doing so equate to CSR being an ineffective waste of time? Don't think so. That math doesn't add up. 

FOUR: More regulation will not prevent companies circumventing regulation. Voluntary does have value. 

Yeah, yeah, yeah, all this voluntary stuff is not what it's cracked up to be, the naysayers are naysaying. Time to change the laws, make more laws, don't let companies do just what they want. Well, truth be told, it's much of the voluntary work that is done by corporations in the field of CSR that has influenced and continues to influence greater lawmaking. Would Europe have passed a directive on mandatory sustainability reporting had not the largest companies in the world led the charge and undertaken to do so voluntarily? No way. And I could give a thousand more examples. Voluntary CSR has a way of raising the bar, paving the way for regulation to touch it up around the edges and level the playing field. What's the alternative? Sit around and wait for lawmakers to wake up? Look where that got us RIO+20. A corporate reality without voluntary CSR and sustainability strategies would be a far grimmer reality than the one we share today. And finally for the pro-regulators, this would not have prevented Volkswagengate. Regulation was in place. Volkswagen broke the law, systematically and deliberately. (See truth three above). Maybe we should pass a law saying that people in companies should not break the law. Now, there's a thought.

FIVE: The fact that Volkswagen is history does not mean that sustainability is too.

The sustainability movement will be around long after Volkswagen has been buried under the 11 million vehicles it may need to recall or pay compensation for. Thousands of companies around the world have been saying that sustainability in one form or another is one of the most important aspects of the way they do business for many years now. Some of them are winging it, PR-blurbing and greenwashing ... but many are genuinely genuine. Look at the CEO surveys over the last couple of years. Sustainability is the talk and many are walking the talk. No company has reached perfection. Everyone is still walking. Might be good if we picked up the walking pace to a light jog sometime soon, but what's been achieved so far is not cancelled by Winterkorn and team. That would be far overstating the power that Volkswagen can leverage both in the motor vehicle sector and in general. Watch this space. Sustainability will outlive Volkswagen.


Anyway, at least I don't drive a Volkswagen. I just hope Hyundai doesn't screw up some time soon.


elaine cohen, CSR consultant, Sustainability Reporter, HR Professional, Ice Cream Addict. Author of Understanding G4: the Concise Guide to Next Generation Sustainability Reporting  AND  Sustainability Reporting for SMEs: Competitive Advantage Through Transparency AND CSR for HR: A necessary partnership for advancing responsible business practices . Contact me via Twitter (@elainecohen)  or via my business website www.b-yond.biz   (Beyond Business Ltd, an inspired CSR consulting and Sustainability Reporting firm).  Need help writing your first / next Sustainability Report? Contact elaine: info@b-yond.biz  

Thursday, June 12, 2014

Using sex to sell ice cream at Nestlé

By now, anyone that reads the CSR Reporting Blog knows how much I love ice cream. So perhaps it's not by chance that a Facebook post about ice cream caught my eye. Yesterday, I noticed a such a post by Eyal Carmi who criticized an advertisement for Joya ice cream in Israel by Osem, which is 63.7% owned by Nestlé. His Facebook comment drew attention to the soft-porno nature of the ad, apparently aired on prime time TV.

I don't wish to promote Nestlé ice cream or lend any sort of support to this marketing campaign, but, before I offer my thoughts, I have to let you judge for yourself. A screen shot and the ad itself on Youtube - proclaiming Joya ice cream the hottest ice cream around.





I have to wonder how this kind of marketing passes the ethics test at Nestlé.

Beyond the fact that I personally find this ad rather nauseating, serving only to make me resolved NOT to try Joya ice cream,  I wonder why it is even necessary to create such a campaign that borders on pornography. Why does Nestlé need sex to sell ice cream? Does fabricated sensuality really make people buy ice cream? What does this ad say about the way Osem-Nestlé thinks about women, when corporate marketeers are prepared to air a voluptuous woman lustfully sucking on a phallus-shaped ice cream bar, vigorously licking her fingers, in what appears to be the way advertisers think women scheme to attract a man's attention? Is this the kind of ad that should be seen by kids on prime time TV?  Or on YouTube alongside fun ads for kids' snacks on the company's YouTube channel?



I sought another opinion from a respected colleague who is an expert in corporate and business communications. This is what he said:

I recall putting the issue of responsible marketing to the director of sustainability who was speaking at a conference one day while his company was running an ad featuring almost voyeuristic images of a woman’s body that bore no relation to the product being sold. His reply - the the effect of “it wouldn’t happen if I was in charge of marketing” - spoke volumes about the lack of integration of sustainability into day-to-day practices, which is so often claimed by corporations. How companies approach marketing is emblematic of the way they understand consumers but so often merely seeks to plug into stereotypical, out-dated attitudes in order to grab (men’s) attention for the brand name."
James Osborne, Senior Partner, Lundquist  

Nestlé's Consumer Communication Principles is a four page document that prescribes the way Nestlé companies should develop and air marketing content. It states: "The Nestlé Communication Principles have been defined as the highest standard on which all marketing and communication to consumers must be based." Here are some of the principles:

  • The content of consumer communications must reflect good taste and social responsibility in accordance with each country’s laws and regulations and voluntary codes and standards. Although standards will vary from country to country, it must not display vulgarity, bad manners and offensive behavior and there must never be an intention to shock or offend. 
  • Advertising content must not depict attitudes that are discriminatory or offensive to religious, ethnic, political, cultural or social groups. 
  • Advertising should avoid exploiting media events that could be in bad taste.
Nestlé is no stranger to ethical problems. In fact, it's one of the corporations that exemplifies the most extreme levels of emotion, as, one the one hand, the most boycotted company in the UK, and on the other hand, the most admired for its' work in "creating shared value" and advancing global food science and technology for the benefit of everyone. A quick internet search brings up a host of ethical issues over the years related to different parts of the Nestlé business, including a recent $680,000 fine for anti-competitive marketing tactics in the coffee business. In fairness, Nestlé claims to be addressing many of the concerns of stakeholders around the world with several supply chain assessments, and a host of other initiatives under the CSV banner, as you can read in the 2013 Nestle Shared Value Report. The company even made a bold commitment to no deforestation traceable palm oil, after the Greenpeace campaign disaster that had everyone associating Kit-Kats with bloody orang-utan fingers.

It seems that as soon as one ethical problem dies down, another one crops up. This ice cream advertisement is, in my view, poor judgment and poor ethics. If the marketing is in bad taste, I wonder if the ice cream comes with a bad taste too.

Perhaps it's time to refresh that set of consumer communication principles and get the folks that market ice cream at Osem-Nestlé up to date with today's values.  


elaine cohen, CSR consultant, winning (CRRA'12) Sustainability Reporter, HR Professional, Ice Cream Addict. Author of Understanding G4: the Concise guide to Next Generation Sustainability Reporting  AND  Sustainability Reporting for SMEs: Competitive Advantage Through Transparency AND CSR for HR: A necessary partnership for advancing responsible business practices . Contact me via www.twitter.com/elainecohen   or via my business website www.b-yond.biz   (Beyond Business Ltd, an inspired CSR consulting and Sustainability Reporting firm

Sunday, September 2, 2012

The G4 Anti-Corruption proposals - explained

Ready for more Thematics ? As promised in my last post on the Thematic Draft of the GHG Reporting Guidelines for the new G4 Framework, I will now discuss the Anti Corruption Thematic Draft. And don't worry, its only 24 pages. Surely there won't be too much to say about that! Think again.

(For clarity (and brevity!) (OK, forget brevity, that's not me), I will focus in this post only on the specific disclosures related to Anti-Corruption - not to changes made to the Ethics profile disclosures or the indicators relating to Public Policy and Political Contributions)

The proposed revisions include:
  • Disclosure on Management Approach: New disclosures and guidance (Anti-Corruption Aspect, Society Category)
  • Indicators
  • Specific edits to Indicators SO2, SO3, and SO4 (Anti-corruption Aspect, Society Category)
You can provide your feedback until 12 November 2012, using the G4 Consultation Platform.


Currently, G3 has three disclosures on anti-corruption (excluding public policy and lobbying):

CORE SO2: Percentage and total number of business units analyzed for risks related to corruption.
CORE SO3: Percentage of employees trained in organization's anti-corruption policies and procedures.
CORE SO4: Actions taken in response to incidents of corruption.
 
The new proposed Thematic has the same three, with slightly different wording and a lot more guidance on what to report against each one. The new indicators are: 

CORE SO2: Percentage and total number of operations assessed for risks related to corruption
CORE SO3: Information and training on anti-corruption policy and procedures
CORE SO5: Confirmed incidents of corruption and actions taken

Anti-Corruption may hide below the Radar
Remember, that in the new G4 draft, companies will not be required to report on anti-corruption if they have not selected this as a material issue. See my post on the G4 Exposure Draft for an explanation of this. So, unlike today, where every A-level reporter must respond to the Anti-Corruption indicators, in future, any company who does not consider this to be material will happily leave it out. In the Mother of Materiality Matrices Analysis by Fronesys, Bribery and Corruption was found to be only number 33 out of a total of 50 top issues identified as material by 31 leading companies. Given that the average number of material issues listed  per company is 27, Anti-Corruption may just conveniently drop off the radar! (This, I believe, is the single biggest weakness of the G4 proposal - there must be a threshold of basic indicators which all companies should report - and this should include at least some reference to anti-corruption practices.) 
 
 
Don't Forget the Juicy Bits
The Thematic Draft includes detailed explanations and specific details which should be reported against each disclosure, ensuring that reporting companies are not tempted to leave out the juicy bits. In fact, the level of detail required is quite daunting - for example, the disclosure on Management Approach for Anti-Corruption contains no less than 11 separate data elements, ranging from whether the organization has a publicly stated commitment to zero tolerance of corruption (that's an easy one, right? If the company doesn't have one, it sure will by the time  it publishes its report!), to processes to prevent, detect, investigate, respond to and remediate forms of corruption to whether and how the effectiveness of the anti-corruption training for governance body members, employees, and business partners is evaluated (errrr... we evaluate our anti-corruption program as effective if no-one has got caught). There is also another interesting disclosure which I haven't seen many companies refer to: "Report policy and procedures in place to ensure that charitable donations and sponsorships (financial and in-kind) that are made to other organizations are not used as a disguised form of bribery. "


Anyway, back to the juicy bits, let's face it, anti-corruption reporting is not the most fun part of any Sustainability Report. Along with reporting on Governance, the Anti-Corruption disclosures are pretty boring and unimaginative. It's not all that easy to make anti-corruption sound sexy and exciting. In G4, it's going to be much more not sexy and not exciting.

The State of Disclosure on Anti-Corruption in G3
This is a random selection of current disclosures  on anti-corruption:


State Street's reporting wouldn't measure up to G4. In fact the company reports partially against the current SO2 and SO4 indicators in this GRI Application Level B+ report.

State Street reports on the existence of an Ethics Office and a Standard of Conduct together with a specific email address for employees to send questions. State Street reports that the Ethics Office is currently updating ethics-related policies, especially Anti-Corruption and that risk requirements were implemented in the UK to respond to the new Bribery Act.

The report contains  a description of a Controls Testing Program in place to analyz risk, and the process for filing of a Suspicious Activity Report in the case of suspected incidents of unlawful activities. All employees must provide annual certification of their compliance with the Standard of Conduct, with 99.9% of employees did in 2011.

All in all, a light-weight disclosure on anti-corruption. State Street is going to have to work hard to be In Accordance with G4, if Anti-Corruption is selected as a material issue. It's could be a lot not more fun at State Street. Except that, Anti-Corruption is not listed as a key material issue for State Street, so it's possible they will not choose to go with the full disclosure anyway. That's a relief for their Sustainability Reporting team, I am sure.
 

This GRI Application Level A report, the company's 17th CSR Report, is 116 pages long. AMD confirms to reporting fully against the current SO indicators on Anti-Corruption
 
SO2: "AMD’s Internal Audit Department performs comprehensive risk analyses (including regarding corruption) of all AMD sites/departments." It is not clear if this is every year, and the description of internal audit procedures does not really address this. In G4, a much fuller response to this indicator will be required, including the criteria used for risk assessment for corruption, whether risks related to external stakeholders, and the operations identified as having high risk and what the risks are.

SO3: AMD's response is: "All employees worldwide receive copies of and training on AMD’s Worldwide Standards of Business Conduct, which includes strict anti-corruption provisions. Training typically takes about one hour per employee and must be completed during the employee’s first 90 days of service." In G4, this wouldn't cut it. The disclosure would have to include all forms of training and information on anti-corruption, including the number of business partners informed and the percentage of business or purchasing volume that these partners account for as well as the Board and Management members which are identified as high risk and the type of training they received, for example, web-based, in person or general or specialized training. I think the GRI Working Group forgot to add that the company should report whether lunch was served during the training and what brand of coffee was provided.

SO4: AMD has got this covered in G3: "The response is AMD is not aware of any incidents during or related to 2011." G4 contains several more points in this indicator, but of course, if there were no incidents, there's nothing more to say. It's probably worth avoiding corruption in your business just to avoid the endless details you would have to include in the Sustainability Report to be In Accordance with G4 on Anti-Corruption.

AMD reports only four material issues, and none of them are Anti-Corruption. Looks like this Thematic Revision may not be too useful, in that case.
 
 

This is Ford's 13th Annual Sustainability Report at Application Level A of the GRI Framework. The report is online with a downloadable summary, and Ford claims to respond to the SO Anti-Corruption indicators in full. The Disclosure on Management Approach is also noted as being reported in the Sustainability Governance section, though a search on this page reveals no mention of the word Anti-Corruption, as well as on the page on  Ethical Business Practices, which is noted as containing responses to SO2,3 and 4. This page also contains no specific reference to Anti-Corruption.

Reference is made to the Ford Code of Conduct Handbook, which is available in 14 languages and all employees must certify they conform every year. Ford assesses compliance with the Code of Conduct through internal audits. This level of disclosure barely meets the requirements for the current G3 framework, let alone G4. In fact, this report, which is self-declared at Application Level A, in the area of Anti-Corruption at least, would not make the grade. Ford will have more work to do on its 2014 report to be In Accordance with the new G4 guidelines on Anti-Corruption.

Ford's Materiality Analysis, which always has one of the longest list of material issues you can find in any Sustainability Report, also does not specifically include Anti-Corruption as a material issue. Sorry, Thematic Revision.

When is Anti-Corruption Material?
Actually, I found it hard to find a good example of where Anti-Corruption is stated as a top material issue.That's probably not so surprising. Identifying this as a top material issue could be interpreted as the company being plagued with corruption. Not the kind of impression most companies want to leave with their stakeholders. It's much easier to go with climate change and diversity.

Symantec's 2011 Sustainability Report includes Anti-Corruption so far down the bottom of the long list of material issues that it almost falls off the edge of the matrix and actually does fall off the edge of the report.

Wipro India's 2010 Sustainability Report, on the other hand, has two Materiality Matrices and one of them contains Anti-Corruption.


Wipro has a Code of Business Conduct and Ethics (COBCE) which is "is socialized at multiple points of an employee's lifecycle – it is first covered as part of the induction program of new hires and subsequently every employee has to take an online test annually to assert his familiarity with the tenets of the COBCE". Wipro states "We have a zero-tolerance policy for noncompliance with the COBCE,especially on non-negotiable factors – e.g., child labor, anti-corruption,etc." Wipro also discloses a case of financial embezzlement that was committed by a junior level employee during the period from November 2006 to December 2009. After investigation, it was decided that the amounts embezzled were not material, but changes such as enhancing segregation of duties and implementing stronger password controls to access financial systems were implemented. This particular case has an unfortunate consequence: "The employee directly involved died after the embezzlement was discovered."

Wipro also reports the number of complaints received through their Ombudsman process, and in 2010, 451 complaints were received of which 3% related to fraud or financial impropriety.

Would Wipro's reporting stand up to the rigor of G4? I could not locate a response to indicator SO2 - number of operations assessed for risk of corruption, and the disclosures on training would not pass the SO3 sub-clauses. SO4 is covered with the case of embezzlement, but the new cases arising in 2010 are not explained in detail. In other words, Wipro's reporting of this material issue is not significantly more extensive than companies who do not state Anti-Corruption to be material, and disclosures do not meet the requirements of the current G3, let alone G4.

One more point: the Difference between Ethics and Anti-Corruption
Generally speaking, if companies have a Code of Ethics, and this includes prohibition of corruption, and companies make sure that employees sign off on the Code of Ethics (after some training, perhaps), is this an adequate response to the question of corruption? Is ethics training enough to cover off anti-corruption? The answer is probably generally not.
 
The revised G4  Definition of Corruption is as follows:
"Corruption is ‘the abuse of entrusted power for private gain’ and can be instigated by individuals or organizations. In GRI’s Framework, corruption includes practices such as bribery, facilitation payments, fraud, extortion, collusion, and money laundering. It also includes an offer or receipt of any gift, loan, fee, reward, or other advantage to or from any person as an inducement to do  something that is dishonest, illegal, or a breach of trust in the conduct of the enterprise’s business. This  may include cash or in-kind benefits, such as free goods, gifts, and holidays, or special personal services provided for the purpose of an improper advantage or that may result in moral pressure to receive such an advantage."
  
There is a very good paper written on Corruption, published by FSG Social Impact Advisors - it's well worth reading.  Some highlights from this paper:

  • Corruption is estimated to cost $2.6 trillion annually, an amount equal to more than 5 percent of global GDP. Each year, over $1 trillion is paid in bribes; not only do these payments undermine fair competition and affect the profitability of businesses operating globally, but they also divert crucial public resources away from their legitimate uses, denying citizens essential public services such as education, clean water, and health care.
  • Emerging markets have higher corruption.
  • Almost two-thirds of executives have experienced some form of corruption.
  • Corporations today largely treat corruption as a legal and risk-management problem requiring a compliance-driven approach. Ethics and compliance officers typically do not view external anti-corruption efforts as part of their jobs, nor do CSR executives often seek to address this social problem.
  • Global or industry-wide anti-corruption initiatives are frequently toothless, inadequate in size, or nonexistent. Compared with other social issues that affect business, corruption has not received a proportionate level of attention.

In other words, a Code of Ethics has a very broad brief and contains many clauses ranging from privacy of information to equal opportunity to protection of company assets and more. Ethics training may not cover anti-corruption comprehensively enough. Ethics training is often broadscale and minimum (completion of an online module), and may not specifically go deep enough for those who are at highest risk of corruption. An example of training in the area of money-laundering, one of the defined forms of corruption,  can be found in the 2011 Sustainability Report of the Landesbank Baden Wurttemburg:



" ...all of our employees who conduct transactions or whose jobs involve initiating and establishing business relationships (such as opening bank accounts and securities accounts, assigning safety deposit boxes) are trained through an educational program at their workplace. In addition, compliance officers are assigned to the various divisions and sales departments to personally support our staff in their money laundering prevention activities directly on site."

A Thematic Conclusion
The GRI G4 proposed disclosures on Anti-Corruption are comprehensive and rigorous in detail - perhaps overly so. The Disclosure on Management Approach clauses and the detailed responses to SO2, SO3 and SO4 are probably more than most of us want to know and it's questionable whether they add to our assessment of an organization's true capabilities in managing corruption risk. If perfect is the enemy of good, then these Anti-Corruption disclosures might just be in enemy territory. 

The best way for most companies to handle this will be to establish a separate multi-year Anti-Corruption Policy, covering all the Management Approach Disclosures and part of SO2 on the way risk assessments are conducted, downloadable from the corporate website  This leaves the actual annual Sustainability Report to refer to this policy and report only those specific instances, percentages and numbers occuring in the reporting period. Assuming, of course, that Anti-Corruption is material for the organization. Who determines materiality? Well, that's another story. I have talked a little about this in my previous G4 post, but I will surely come back to it as a core determinant of effective sustainability reporting.


In the meantime, go and treat yourself to you an ice-cream. (I am glad the GRI doesn't issue guidelines about ice-cream consumption. My report would be 937 pages long!)

Yes, it was as delicious as it looks!



elaine cohen, CSR consultant, winning (CRRA'12) Sustainability Reporter, HR Professional, Ice Cream Addict. Author of CSR for HR: A necessary partnership for advancing responsible business practices  Contact me via www.twitter.com/elainecohen   on Twitter or via my business website www.b-yond.biz  (Beyond Business Ltd, an inspired CSR consulting and Sustainability Reporting firm)

Friday, February 4, 2011

David fights Goliath Thales on bad ethics

Should I be flattered or concerned ? I came accross an interesting (unintended?) use for the the Expert CSR Report Reviews that I regularly publish on CorporateRegister.com. This was a review I wrote about the Thales aerospace and defense company Sustainability Report of 2008 (read it here). My review was critical of the Thales report, referencing the lack of transparency and highlighting  the greenwashy language used in the report. As with all my report reviews, which I write on a voluntary and unpaid basis, of companies with whom I have no personal or commercial relationship. I base my assessment on what I find in the report itself, plus additional review of material in the public domain - company website, previous reports, online news. My reviews are my own independent professional assessment, as a general stakeholder of all companies, and include my impressions of the reports and the way they deliver on content, communication and credibility. Whilst I know my reviews are used in academic curricula, it was quite a surprise to find one being quoted in private disputes between companies and their suppliers. However, this has happened in the case of "DataSonic versus Thales".

A company, DataSonic Ltd UK, which was established with the support of Thales to supply proprietary specialist training systems, was allegedly forced to cease trading as a result of a personal vendetta by a Thales Purchasing Manager who cancelled partially-fulfilled orders, reneged on agreements worth quite a lot of money to a small supplier and claimed rights to designs owned by the supplier. Allegedly, complaints to Thales did not yield any reasonable conclusion of this issue and Thales continued doing their stuff whilst this small supplier went out of business and the owners suffered significant personal financial hardship. The former directors of DataSonic, David Giles and Matthew Pitt, have published a website called EthicalThales which describes the story in all its gruesome details and personal profiles of all the Thales people involved, accusing the company of stealing, lying and cheating.

Hmm. My thoughts on this:

The ethical behaviour of corporations almost always comes down to the individual behaviour of a single person in the organisation. Any unethical process or practice can always be traced back to one person. One person, therefore, has the power to make or break the ethical reputation of any company. In this story, one person is cited as being responible for a series of unethical practices which have now become public. Whether this will make a big hole in Thales' reputation or not remains to be seen, but it's certainly something that investors, managers, employees and other suppliers will not relish reading. The value of embedding ethical behaviour right down to the last employee, and ensuring that ethical practices are positively unpeld in the business by all employees, is  critical, as this sad story shows. 

The ethical behaviour of big businesses can often be measured by the way it treats small suppliers. Small suppliers have few options to ensure they are treated ethically by big customers if the big customers themselves do not behave ethically. Payment terms, timeliness of payments , ordering procedures, complaints handling, dialogue, behaviour around price tenders, confidentiality of information, rights to intellectual property and more are issues which can make or break small suppliers, who do not have the bandwith to fight court battles on each of these issues. As a small supplier myself, I know only too well how cashflow management can be nightmarish if large customers so not pay on time, or how price-squeezing by multi-million $ companies can force us into agonizing decisions about whether or not to offer suicide prices just to get the business, or how non-negotiable payment terms means we are funding our large customers with our own (expensive) credit  (one large client, who I now do not do business with, unilaterally advised me of payment terms "current month plus 94 days", after accepting our offer based on regular current plus 30 days terms, and after the work had been done - meaing work that we did in Month 1 was actually paid in Month 5!), or how we are given the runaround, attending several meetings and discussions in the course of providing offers for our services, only to find that subsequent decisions are made based on non-commercial factors, such as personal relationships. As a small business, when this happens, we learn and move on, refusing to do business with suppliers who are unethical, and trying to ensure our exposure is never such that one big company can bankrupt us. However, this is a lesson some learn the hard way. DataSonic was apparently very dependent on the Thales business  and was not able to recover from a major change in policy and alleged defaults on commitments. In this case, I can understand a small supplier who has been burned resorting to the internet to publicise an ethical issue which apparently no-one else takes any interest in, and the accused company refuses to engage. Purchasing process is a key element of CSR and ethical purchasing practices are a very telling aspect of corporate behaviour. All companies must ensure Purchasing Managers behave in accordance with ethical standards. The boomerang is never too far from returning home.   

No issue is a small issue in CSR terms. Everything counts. A small issue can be symptomatic of bigger issues. Or a small issue can grow into a big issue. Therefore CSR-minded companies cannot afford to leave small issues to fester. Things need to be resolved to adequate solutions. As a qualified mediator, I have often found that mediation can be a very positive tool in disputes such as these. Refusing to engage, without closing out issues in a respectful way, can only place strain on an organisation in ways it might not fully anticipate.  

Should my report review be "evidence" supporting the case of the small supplier against the big customer? At one level, I am flattered to see that my reviews are being read and quoted. At another level, I am a little concerned that my review is quoted in this context. The anti-Thales website states:

We are not alone in questioning the validity of Thales 'ethical credentials'.  Written in 2010 and without our first hand experience, an article by Elaine Cohen of BeyondBusiness Ltd suggests "there is little evidence, beyond rhetoric, of embedded processes and practices".  This reflects our direct experience precisely; read the full text here. 
  
I must point out that I did not question the validity of Thales "ethical credentials". I  criticized the quality of their Sustainability Report. This is not the same thing. I am not sure I am happy with my reviews being used in this way which I feel is a touch misleading.

Things are not always what they seem. There are two (or more)  sides to every story . The anti-Thales website tells one side of this painful issue (though a letter from a former Purchasing Manager at Thales appears to give DataSonic's claim some legitimacy). Whilst the alleged facts and figures are presented from the point of view of DataSonic, in rather emotional style, what actually went on may be a combination of other factors as well. I do have sympathy with a small supplier who is obviously suffering significant pain and can undertand how such situations come about. It will certainly be interesting to know if the EthicalThales website generates any response from the company and what action ensues.    

I will continue, of course, to write my report reviews. I just hope I don't get hit with a subpoena one of these days :)

elaine cohen, CSR consultant, Sustainabilty Reporter, HR Professional, Ice Cream Addict. Author of CSR for HR: A necessary partnership for advancing responsible business practices   Contact me via www.twitter.com/elainecohen on Twitter or via my business website www.b-yond.biz/en (BeyondBusiness, an inspired CSR consulting and Sustainability Reporting firm)

Friday, September 17, 2010

The Big CSR Debate : Elvis rules!!

So, the BIG CSR debate has come and gone. Did we learn anything new? Well, frankly, the only thing that was new to me was the total extent of the disconnect between the views of Dr Aneel Karnani and Chrystia Freeland and today's external reality. At some point, the only way both could feel comfortable about CSR was by calling it simply "good management" or even better "acting in self-interest to make a profit by observing the law". If that is what CSR is all about, then, as Aron Cramer put it, there is a problem. Karnani let himself neatly off the hook by saying that there is no definition for CSR. In fact, this debate might have been called a "dialogue de sourds", where 5 out of 7 people were talking coherently, and two were throwing out a whole series of "wobblies" (a great term used by a former boss of mine), not many of which were accurate, relevant or even interesting. I missed the first part of the debate, so I don't know if it actually started out with an agreement of a definition of what people were going to talk about. In fact, 5 people were talking about one thing, and two people were talking about something else. And there was no middle ground.

At the point at which I hooked in, Chrystia Freeland of Thomson Reuters was referring to "CSR rhetoric", "milk and motherhood and apple pie", and "feel-good win-win Kumbaya language". This might have been relevant about 10 years, ago, but her needle has clearly stuck in that groove. Today, CSR is about strategy, shared value, business opportunity and addressing global challenges. Karnani lives in a world where governments everywhere are icons, where they regulate for every possible impact of business, and enforce every regulation with such perfect finesse that no corporate anywhere is ever able to do any harm to society or environment in any capacity whatsoever. Aron Cramer says this exists only in North Korea, a model which he does not recommend for the entire developed and developing world. Guess we can understand why.

Ultimately, the CSR anti's were putting up smoke screens – the very smoke screens they accuse responsible business of wielding to mask their irresponsible practices and the "deceptive dangers" of CSR. Chrystia Freeland kept harping on about the fallen-halo of " Beyond Petroleum" when in reality, everyone stopped believing that slogan many moons ago, and no educated business person would consider that as part of the current CSR Kumbaya. Another needle, another goove. Chrystia then turned her sights to Microsoft who has just been accused of collaboration with the Russian Government to crack down on outspoken advocacy groups and opposition newspapers. Yep, not a nice story. But Microsoft have issued a full and frank explanation and confirm that "to prevent non-government organizations from falling victim to nefarious actions taken in the guise of anti-piracy enforcement, Microsoft will create a new unilateral software license for NGOs that will ensure they have free, legal copies of our products." Such is the world of CSR. No corporate is perfect. Georg Kell of the Global Compact made this point well. He said "we have to recognize that most big dilemmas are not so easy to solve - climate, poverty and other global issues do not follow a clean simple path, commitment to a non-financial issues is uneven progress, it is very hard to be on top performance in all domains all the time. We have to accept the dynamics of regulatory changes and what business can contribute. Private solutions spill over to the regulatory machine. Where there is a conflict you have to tackle the conflict and work out where you stand." This rings true. The multiple touch-points of any large corporation which impact on so many aspects of our lives are continually being discovered and addressed. The fact that companies haven’t yet buttoned everything down in a nice neat package for every aspect of their business everywhere cannot be an argument for the failure of CSR. Real CSR is that they are willing to try.

Dave Stangis, who told Campbells Soup's Board when they hired him, that he is not a treehugger, but a capitalist who believes in helping them make more money (but in a way which creates positive social impact), says that this state of EITHER – OR makes him crazy. I identify with that, though Karnani and Freeland seem to have problems with the concept of co (co as in shared, together, participative, partnership, working together, interconnectedness, leveraging joint strengths, engaging). The possibility that there is an overlap between the contribution of business and the role of governments in contributing to global sustainability is off their radar. Bob Corcoran gave an example of how GE supported Transparency International in establishing a framework for anti-corruption. But this was dismissed by Chrystia as self interest on behalf of GE, because, she said, apparently GE is apparently not so good at corruption and their competitors are better, so leveling the playing field had to be about regaining competitive leverage for GE. Come on. Is this drivel or is this drivel?

Matthew Bishop, of the Economist, was an eloquent contributor to this debate and got to the crux of things quite effectively. He made the point, which I also subscribe to, that the problem with stock market capitalism is that it overly focuses on short term measures of performance. He says that visionary business leaders are on the side of preparing themselves to be doing things which move the business forward in a sustainable way. Karnani had an answer to this, of course. He says " Shareholders should demand that business be long term. It's a governance problem" . Perhaps Dr Karnani would like governments to regulate that shareholders may only invest in businesses whose governance allows only for a long term shareholder return? Yup. That would work. Not. Bishop again: "How effective regulation can actually be? There is a huge problem of corporate money in America, lack of transparency in corporate lobbying, a lot of our institutions are not being held to account properly" Nail on the head.

Chrystia, continuing in the self-interest groove, raised the issue of Pepsi who on the one hand, sells a product which has "no redeeming value to society" whilst engaging in all sorts of great CSR activities. She calls soft drinks the next "tobacco", pointing out that Pepsi lobbied hard against a soft drinks tax. Hmm. Matthew Bishop wasn’t having any of that. He says that when companies make a claim such as the Pepsico "Performance with Purpose", they are held to account. He says that Indra Nooyi's performance in this respect should be judged by the media and all stakeholders on those promises "Where's the beef, Indra? everyone should ask. He says that this is going to be the defining issue of her career.

Rounding off on this short summary of this long debate, the likelihood is that the camp you started out rooting for is the camp you remained in. And that camp won. If you believe that CSR is a smoke-screen to mask corporate self-interest which is in conflict with the public good, and that the only bodies that corporations should be held accountable to are governments, then you can shake hands with the Karnani-Freeland double act. If you believe that CSR has a valid role to play in improving society and planet whilst enabling businesses to deliver long term shareholder and stakeholder value, in a way which is core to business strategy, then you have many more hands to shake.

If you are undecided, as Aron Cramer says, 50,000,000 Elvis Fans can't be wrong. Go with the majority!

Kudos to Susan McPherson and Fenton for organizing this session and to Christine Arena for skillfully navigating the lion's den. And as it is the start of Yom Kippur, haha, I ask forgiveness for having no patience for arguments that hold back progress.

elaine cohen, CSR consultant, Sustainabilty Reporter, HR Professional, Ice Cream Addict. Contact me via www.twitter.com/elainecohen  on Twitter or via my business website www.b-yond.biz/en  (BeyondBusiness, an inspired CSR consulting and Sustainability Reporting firm)

Wednesday, January 13, 2010

The Ghetto Fighters and CSR

What do the Ghetto Fighters  have to do with CSR? Stay tuned. I will explain.

Who were the Ghetto Fighters ?
These were the group of people who led the resistance to the final liquidation of the  Warsaw Ghetto which was established by the Governor of the Warsaw district in Poland in 1940. A fighting organization was declared in 1942, led by Jewish leadership in the Ghetto, to stage the Warsaw Ghetto Uprising , the "first urban uprising in German-occupied Europe", which succeeded in holding out for over a month until it was finally defeated in May 1943. All those who were left were deported to extermination camps, though a certain number survived. Of those who did, some made their way to Israel and founded Kibbutz Lohamei Ghetaot (Ghetto Fighters) Museum in 1949, on the sixth anniversary of the uprising. In addition to building a cowshed, a kindergarten and living quarters, one of the founders' very first acts was to lay the foundation for a memorial museum, which would be not only a way of remembering those who had lost their lives, but also serve as a tribute to the survivors' spirit and the renewal of life. Warsaw had been home to over 350,000 Jews before the occupation. By 1943, only 11,500 remained.

So, what has this to do with CSR?
The Warsaw Ghetto Uprising was a triumph of vision and leadership under the most impossible circumstances one could ever imagine. Instead of waiting till the "storm had passed", or committing mass suicide (a very real option at the time cf: Massada), the choice was to use every possible option to survive and leave a legacy. Some incredible leaders emerged from within the Ghetto population to pioneer what would be a miraculous fight against inhumanity and abuse of everything we know about human rights,  respect for and acceptance of othersequality and tolerance. The community drew  itself together, gathered its collective spirit and capabilities, developed a network based on trust and mutual support, to fight the good fight. But these were not the only people who made choices. There were many righteous people who assisted the oppressed Jews during the occupation and during the uprising. Those people had chosen not to be complicit in the evil of the Holocaust, but risked their lives to help where they could. The entire story of the Warsaw Ghetto and its Fighters is a tragic but wonderful manifestation of  values and how we adhere to values when under extreme stress.Ultimately, the Warsaw uprising is the optimistic a story of the spirit and victory of humanity. The survivors, few though they may have been, went on to recreate life, share and teach their experiences, and promote humanism and democratic values for generations to come.Ultimately, the Warsaw Ghetto is a lesson in sustainability.

So, you are STILL wondering what this has to do with CSR. Here is the final piece in the puzzle.
In my meetings with a long-standing friend and fellow professional in the field of advancing social justice, who is today the Marketing Manager of the Ghetto Fighters Museum, we discussed how this unique and inspiring place could serve as a platform to teach sustainability. The Warsaw Uprising may be over, but globalization of business has contributed to the continued oppression of many different  peoples in the world, there is discrimination in business organizations, abuse of human rights, complicity in supply chain irregularities, erosion of values, particularly in times of crisis,  a lack of collaborative spirit and a reluctance to combine and share resources to ensure the best collective chances of survival on our shared planet. Competitive forces work against the best outcome for all. These are issues of CSR and sustainability, which we can see in every aspect of the Warsaw history. By using this platform, we can create a learning experience which is powerful and associative in a way which no other learning framework I know can achieve.

And we have a little time for Q&As:

Q: Wouldn't it be totally depressing to attend a workshop surrounded by a memorial to the tragedy of the Holocaust?
A: No. The Museum celebrates the survival, the bravery, the risk-taking, the astounding capabilities of those driven by values, humanism and a better future life. The Museum celebrates the human spirit and what it can achieve. It's an optimistic message.  

Q: But did those people really have a choice? They were attacked, they defended themselves. What choice is that ?
A:
Of course they had a choice. Anyone who has read
Viktor Frankl's book, Man's Search for Meaning, will know that life is a conscious choice, survival is a choice, sustainability is a choice. They could have chosen to do nothing. The righteous ones amongst the Polish people could have chosen to be complicit, like so many others. This is the parallel with business today. Business, or the people who run businesses, have choices. Choices which are not so easy to make. But they are choices. The Warsaw Ghetto may seem like an irregular backdrop, but those who have attended workshops there to date have proven  that this format can be a catalyst for deep paradigm change.

Back to CSR
We are now developing a series of workshops in partnership with the Ghetto Fighters Museum  team (the Museum has been running workshops, courses and learning programs, including management training, for a long while)  The CSR workshops will cover: sustainability principles, ethics and assimilation of ethical values in business (especially in times of extreme pressure) , diversity and inclusion, collective and personal accountability and more. These workshops will blend with existing CSR processes in businesses to support new generations of CSR leadership at all levels. 

Oh, and we might even serve Chunky Monkey in the afternoon break.

elaine cohen is the joint CEO of BeyondBusiness, a leading reporting and social-environmental consulting firm based in Israel. Visit our website at: www.b-yond.biz/en  

Friday, November 27, 2009

Does size really matter ?

Should small Companies report ? Do you agree with the statement that "CR reporting is for companies with large footprints" ? Does the size of the Company, and its footprint dictate whether a Company should be transparent and accountable to its stakeholders? Is it true that "that large companies have many more resources than small firms" and therefore, large Companies can afford to report and small Companies cannot ? Should a small Company content itself with "more written policies and statements about our impacts"?

The quotes (in red) above are from Toby Webb, the founder and manager of Ethical Corporation.(The questions are mine!)  I have met Toby briefly a couple of times, when I have attended Ethical Corp's conferences, which are very good. I regularly follow his blog Reflections on Ethical Business which I genuinely find to be one of the best blogs around on CSR, full of sharp insight and commentary. Recently Toby posted "Twelve reasons why I won't read your corporate responsibility report", and my response, which was basically that the twelve reasons Toby mentions for not reading CSR reports, are precisely the reasons he should read reports (call me argumentative if you like, but check it out), led to a ping-pong of why reporting is for all organizations, irrespective of size (me) versus why a small business doesnt need, or have the resources, to report (Toby). This prompted me to bring  the ping-pong on to my territory, a blog about reporting, for all organizations (ALL organizations) and elaborate on why I believe this to be so.

What is reporting ? It's a process by which a business, after reasonable dialogue with stakeholders, considers the most material issues for them, the stakeholders, and for its business sustainability, and is transparent about how it performs on matters of stakeholder interest. Reporting is part of the loop of dialogue - we listen, we act, we respond, we listen again. The report is the periodical output of this cyclical process. The process itself builds relationships, trust, management discipline, identifies risk and oportunity, contributes to positive reputation and enhances investor interest, to name but a few benefits. The resources required to produce a report are do not need to be overwhelming - more often than not, the design, printing and dispatch of reports can cost more than the investment in wirting them, or the consultant fee. Most of these cost elements can be avoided by a producing a PDF download or an online report, with modest graphics. The content is what counts. In a small business, personnel resources may be more limited, but the issues are far less complex than in a big global business, and require less personnel.  So i think this  we-ain't-got-the-resources line is a cop-out for not applying rigorous thinking to sustainability, or accepting accountability. Oh, and let's face it, no-one reads reports, anyway, right ?

Let's take a look at some stuff relating to SME reporting:

In Spain, 822 SME's  now produce CSR reports. Why ? It enables them "to increase their competitiveness in a setting where transparency and distinguishing features play an important role. ...... the preparation of the reports initiates the enterprise in the main aspects of CSR while encouraging it to develop its skills of self-diagnosis." This is reported on the Instituto de Crédito Oficial website, an organziation which assists SMEs to report.

The Global Reporting Initiative website has a  section dedicated to support for SME's , and  lists a whole string of SME's who report. In an interview with  Scott McAusland on the GRI website, he says that SME's " account for about 90% of businesses worldwide and 50 - 60% of employment."  Often SME's are part of MNE (multinational enterprise) supply chains, and therefore may have a need to demonstrate ethical, accountable and transparent behaviour in order to stay competitive.

CorporateRegister.com's 2010 CR Reporting Awards has a special category for SME's , as in previous years. You can find many SME reports in the CorporateRegister.com database. The European Commission produced an excellent guide for SME's for communicating CSR.  Whilst the focus of this guide is communications, of which reporting is only one element, it lists many compelling reasons for SME's to communicate abobut their CSR activities, with a CSR report included in the different channels reletvant to different stakeholder groups.

In a post back in July 2009, called You don't have to be BIG to do CSR, I gave an example of an SME from Moldova who reported many positive impacts which almost certainly no-one would ever know about had they not reported themselves. Local competitiveness and reputation are just as crucial here as for bigger businesses.

Many of the reporting SME's confirm that both the process and the report deliver significant benefits as mentioned above. It is important to note that the process cannot succeed without the product of that process - the report itself - a periodical health-check of strategy and metrics, and renewed commitment. A report is the most appropriate vehicle for this - as part of a total csr and communications strategy. I dont see this as a privilege reserved  for only the big blockbuster corps.

What might a Company like Ethical Corporation have to gain by a reporting process and publication of a report? 
  • Stakeholder engagement and materiality analysis could throw up new insights about ways to serve stakeholders and do more, better, business. At worst, it will provide an external reality check of how the Company is percieved by those who can influence its sucess.
  • An environmental risk and impact assessment, followed by an Environmental Policy and Action Plan could deliver several benefits - cost savings through improved internal environmental practices, travel habits, printing and sustainability in events management.
  • A statement of mission, values and perhaps even a Code of Ethics could serve to align employees and all contributing writers to the Company's "what we stand for" and support the building of alignment, trust and reputation. Marketing practices for example are an important element of this too.
  • A review of Human Resources practices - even with a small team - could assist the business in improving employee engagement and beoming more attractive to potential employees.
  • A review of how the Company contributes to the public good through its business activities, and involves its employees in community activities or supporting social causes could contribute to positive reputation, improved egagement and skill development.
  • And more than anything else,  scoping of Ethical Corporation's indirect influence on its many readers and conference attendees could provide the business with a platform to measure and increase its influence and potential readership. Through a "Green Conference Facilities", for example, the Company could provide attendees with an opportunity to make their own contribution to environmental sustainability.
  • And finally, the compiling of all of this into a periodical, coherent report would provide a basis to maintain this cycle of planning and improvement, track performance and maintain a leading edge.  
Would this sell more mags or bring more people to summits ? Maybe not in the short term. But we all know that sustainability is a long haul and not a quick-buck thing. And it really doesn't matter how many people the Company employs or how many $ it earns. It's all about impacts. As Dolly Parton said, as far as i recall, "If you think you are too small to influence, you have never been in bed with a mosquito".

Note that i haven't even touched on the sense of duty we might assume of a Company whose core business is communicating about business ethics and "encouraging debate on responsible business" . The GRI produces a report, BSR produces a report, The Guardian produces a report.

Enough said.  I don't hope to convince Toby or Ethical Corporation, and i understand that every business must choose its own ways of doing things. My comments could apply to any small business, not just Ethical Corp. I just felt the need to share my perspective in good spirit on something i have, as you may have noticed, strong views about. And by way of disclosure, I am a CSR report-writing consultant so i am not totally objective.  Thanks to Toby for allowing this debate on his blog  - I expect i am getting on his nerves a bit. Oops!  Next time i see him at a conference I will buy him a Chunky Monkey!

elaine cohen is the joint CEO of BeyondBusiness, a leading reporting and social-environmental consulting firm . Visit our website at: www.b-yond.biz/en
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