QCEA: Corporate Social Responsibility The European Multi-Stakeholder Forum on Corporate Social Responsibility

We are writing to you as the non-governmental organisations active in the Multi-Stakeholder Forum. We would like to confirm our support for the agreed objective of “Exploring the appropriateness of establishing common guiding principles for CSR practices and instruments, taking into account existing EU initiatives and legislation and internationally agreed standards”. We believe that a multi-stakeholder process at the European level has the potential to make significant progress towards this objective.

However, having reviewed the first wave of Round Tables, we have little confidence that the process as it stands will lead to any substantive developments. We therefore wish to articulate a number of major concerns in relation to the process so far, and to propose constructive solutions to these problems. These are issues, which have already been highlighted, but we must reiterate the need for these concerns to be adequately addressed.

We ask that the following points are given full consideration and that they are put to the Forum for action in future meetings.

1) For the Round Tables to take existing EU initiatives and legislation into account, the European Commission and other European Institutions need to play a much greater and more active role. We have a short time to move to clear policy recommendations and this can only be done with full co-operation of all the DGs involved in this process.

Recommendation: that for each Round Table the Commission prepares a written input on existing EU initiatives and legislation for discussion by the stakeholders.

2) The Commission must commit its full support to the rapporteurs and lead them towards the identification of concrete proposals for EU action. This commitment must also be marked by feeding information, gathered from the discussions held in the inter-service meetings on CSR back to the Round Tables.

Recommendation: that the Commission and rapporteur take full responsibility for channelling discussions towards the objectives of the Forum, while providing the participants of the Round Tables with the relevant information to guide the discussions.

3) It is also important to ensure that we involve the real stakeholders in the discussions, if we are to bring about change. Delegations must be transparent and the business delegations, though they may be led by a business group, should consist of representatives from the companies themselves. Dialogue with these representatives is key to the added value of the Forum, and they should therefore be open, accessible and fully engaged with the debate.

Recommendation: that all participants have place identifiers with their name and organisation/company, and also wear name badges with this information. Lists of participants are circulated at the beginning of the meeting.

We also deplore the limited scope for active participation, particularly in the development round table, by representatives from developing countries. In order to achieve a balanced picture of corporate impact in developing countries we must ensure greater participation, especially of the least-developed countries, vis-à-vis the middle income countries. We insist that the Commission makes all possible efforts to improve this situation in future meetings.

Recommendation: that the Development Round Table be given the resources to invite at least two representatives from developing countries, including at least one from the least developed countries, to actively participate in the Round Table.

4) In the delegations we would also welcome participation from representatives of the investment sector, a contribution that we feel until now has been largely overlooked.

Recommendation: that the MSF discuss the issue of investor representation at the meeting on 20th May and decide how it can be best dealt with in the second wave of the Round Tables.

5) On the issue of the participation of NGOs, we have experienced great difficulty concerning the limited travel budgets available. In order to offer the most comprehensive and relevant contribution, the delegations have often consisted of up to eight participants from outside Brussels. They have given valued input into the debate and will only be able to continue to contribute if more funding is made available.

Recommendation: to review the three-person limit per sector for the persons attending from outside Brussels, or to make an exception for the NGO participants who do not have the financial resources available to cover this travel.

6) In moving towards our main objectives it is important that the case studies presented at the Round Tables are selected carefully. We feel that the aims of the Forum have not been adequately addressed, owing to the insistence that all cases discussed should be business-led or focussed on a particular business. We agree that cases need to be from two or more of the stakeholders involved, and should seek to reveal wider lessons, through the examination of successes and failures. The definition of stakeholders should also include governments, and secretariats of multi-stakeholder initiatives, where there is the agreement of the multi-stakeholders in the initiative.

Recommendation: to have confirmation that cases can be presented from any combination of the groups involved, and that cases in the second wave need not focus on particular businesses, but could address sectoral themes, stakeholder-led initiatives, analytical research or survey findings.

7) The brief of the rapporteur appears to have become confused during the first wave. As agreed by the Forum, the role of the rapporteur is essential if there are to be concrete outcomes and recommendations from the Round Table meetings. We therefore regret that all rapporteurs have not yet been appointed.
Recommendation: we call on the Commission to fix in place all four rapporteurs as soon as possible.
Secondly we would like clarification on the reports, which will be produced. A clear distinction must be made between the minutes (including analytical summary, points of agreement and disagreement and issues for future discussion) and the final summary report on the work of the Round Table (recommendations to the EU). Sufficient time must be set aside to discuss this final report in the second and third wave of the Round Tables, so that it can be built up progressively during the meetings.

Recommendation: that discussion time on the content must be set aside in the second wave of the Round Tables and a draft of such a report needs to made available to the participants prior to the final wave of the Round Tables.

8) Time for discussion has been another difficult element for the first wave of Round Tables. The amount of case studies presented has made it difficult to build on the points that have been made, and has led to some superficial discussions, with little in the way of content for future EU policy. For this reason we recommend that, with the input of the Commission and the Rapporteur as specified above, more time needs to be given to discussing the more complex issues being raised and to focus on some of the areas of dispute among the stakeholders. A more analytical debate is needed, including analysis of existing instruments, and also concentrating on sectoral and thematic issues and comparative studies.

Recommendation: that the agendas take into account the need for increased discussion time and analytical debate, assisted by the rapporteur, Commission and experts.

9) When looking at the CSR issue three major ‘types’ of companies can be identified.

a. Those who believe that CSR can benefit their business and make it part of their corporate culture. It is key to the way they do business or the way they want to do business.
b. Those who want to ‘greenwash’ and see CSR as a Public Relations exercise that must be done to limit reputation risk and harm.
c. Those who simply don’t care. No matter what business model you show they will continue to be driven by profits without any reference to CSR.

Our discussions and case studies so far have dealt with the first group, and to some extent the second. However, if we are going to bring about real change, we must recognise that many companies are in the third category. To ignore this aspect, is to keep CSR to the few progressive companies at the tip of the iceberg. This is failing to meet the real challenge of the Forum. In addition, recognising that a multi-stakeholder approach is key to achieving sustainable results, we also need to consider the role of each of the stakeholder groups achieving social and environmental responsibility.

Recommendation: that future discussions are directed by the Commission and rapporteur to consider all of these groups: that we look not only at the business case, but also at how to bring up the bottom line and force the laggard businesses into greater social and environmental responsibility. That the role of stakeholders in this is also considered.

10) We believe that there should be no taboo topics in this Forum. For example, even though the Commission defines CSR as ‘voluntary’ actions, other stakeholders use different definitions of CSR and many agree that the legislative environment is also an important consideration. We encourage an open and strategic discussion on this, and other debates, in order to effect real change.

Recommendation: In particular, we seek confirmation that the Commission will not seek to restrain debate involving non-European cases, or ongoing European legislative activities.

CSR is a process that will not be concluded overnight. We do not expect that June 2004 will be the end of the EU debate; instead it should provide a clear outline for development in the next phase. We are launching a process that will gain in momentum and fuel the debate for clear policy recommendations and successful implementation.

However in order to successfully move the debate forward, which we are sure is the intention of the Commission and the other stakeholders, we ask you to consider the points we have raised and to make the appropriate alterations for the next round of debate.

We would be happy to meet with you to discuss any of the points we have raised.

Yours sincerely,

Anne-Sophie Parent, President, Social Platform

Tony Long, Director, WWF European Policy Office, On behalf of the G8

Dick Oosting, Director, Amnesty International

Michael Gidney, Director of Policy, Traidcraft Exchange

Jim Murray, Director, BEUC, the European Consumers' Organisation

Antoine Bernard, Executive Director, FIDH, Fédération internationale des ligues des droits de l'Homme

Together with:

Solidar

Caritas

Quaker Council for European Affairs