CSR and the art of reporting

Amongst fierce take-over battles and constant scrutiny from the media, Marks & Spencer have still found the time to produce their first CSR report. Along with what the company learnt from this process, Rowland Hill tells us about the past, present and future of sustainability reporting.

June 2004 was a significant point in Marks & Spencer’s history. Whilst the changes and challenges taking place in the boardroom have been amply reported in the media, a less well-publicised event was our first Corporate Social Responsibility Report.

Whilst there is a clear case for greater cross-company consistency going forward I suspect that initially most companies will have to find an approach that is right for them.


Small thing, big issue. To those readers ‘in the know’, there is a world of difference between, for example, CSR and HSE. Whilst there are no hard and fast rules here, your title, like your internal function, ought to reflect how your business approaches the issues. However, be aware that the words you eventually choose will create an external label for your company and its impacts. Key points include:

  • Health, safety and environment: ‘Nuts and bolts’ compliance data usually produced by high-risk/high-environmental impact companies for government and regulators.

  • Environment: Predominantly operational environmental impacts. A more modern approach used by a wider range of companies who feel that their environmental impacts are important enough to communicate to government, regulators, business customers and NGOs.

  • Social: Predominantly operational social impacts. Used by companies either attempting to demonstrate compliance on challenging social issues such as global clothing brands, to human right stakeholders or commerce-based businesses illustrating their community programmes to employees.

  • Corporate Social Responsibility: One of the business buzz-words of the early 2000’s but now going out of fashion. Builds on the notion of voluntary actions to build trust based on stakeholder engagement but is increasingly seen as lacking in conviction and carries too many welfare connotations. Most likely to be replaced by the more governance-centred ‘Corporate Responsibility’. Used by medium- and low-impact industries with stronger social credentials. Can be aimed at many different audiences.

  • Sustainable development: Conviction-led reporting that features a high degree of stakeholder feedback. Includes a balance of environmental, social and economic elements and is likely to come from sectoral leaders. Sustainable development reports are leading edge but can be seen as indulgent and removed form core business activities by mainstream business. Aimed at a wide range of audiences but, some might argue, mainly judges of awards.

Marks & Spencer chose the use of a CSR report as an accurate reflection of our current positioning on these issues.


The transition from leaflet to review to report is not one you’ll find covered in many academic publications but I’ll give you my observations. Leaflets and brochures are the start of the genealogy covering a particular issue or summaries of a number. Their key characteristic is that they contain unremitting good news and are essentially a PR tool.

A review is the next evolution. This is a much more serious attempt to address a particular set of stakeholders on a particular set of issues. Examples from other companies that spring to mind include lobbying positions directed at Government or community programmes aimed at employees. However, don’t expect much in the way of defining materiality (what is genuinely important to a business’s future success), balance, stakeholder comment or performance from a review. This means again that only the good news makes it into the pages.

We produced a CSR review in 2003 as a means of defining our goals and to act as a focus for further consultation. Since these were aspirations, there seemed little point in adopting a full ‘reporting’ format. However, we ran a number of events including a lunch with members of our board for stakeholders to provide feedback.
To build our understanding and confidence in using measurements of performance we participated in Business in the Community’s (BitC) Impact on Society initiative which allowed us to experiment with reporting on BitC’s website alongside twenty other companies. One lesson I learned from this was the difference between descriptive measurements and actual performance indicators. There is often a tendency to muddle the two.

A report, to my mind should provide all the elements that a review doesn’t. That is definitions of materiality, scope, systems, stakeholder comment and balance. Exact content will still be influenced strongly by its intended audience, so expect lots of health, safety and environmental data for regulators and detailed supply chain audits for human rights groups etc. Either way I would expect to see a balance of ‘achievements’ and ‘work to do’.

After much debate, we framed our intended audience as ‘individuals or organisations with an interest in Marks & Spencer’s performance on CSR’. Whilst this assumes that the readership has a certain level of knowledge, we took the view that we would try to explain issues as clearly as possible. This improves accessibility but might seem a little basic to some specialists. I believe that our 2004 CSR report has a strong selection criterion for content (issues that are important to our customers) and a good balance of achievements and challenges. For instance, we’ve been brave enough to cover sensitive issues like the Office of Fair Trading criticism of how we launched our &more credit card. We also include stakeholder feedback from our 2003 review.


I’ve read many papers on virtues of assurance and all the different forms it can take. Interestingly, only around half of Association of Certified and Chartered Accountant’s sustainable development, environment and social reporting shortlist in 2003 had any form of assurance.

On the up side, assurance provides confidence in the information for some stakeholders (particularly regulators), but on the downside counts for little with many more. You can choose an established big accountancy name or go for a specialist stakeholder assurance-based approach. Either way it’ll work for some readers but will be a turn-off for others, so it really depends on who you’re trying to influence.

I won’t go into the differences between assurance, audit and verification, partly because I’ve heard so many different definitions myself. However, in summary you could choose to assure the scope, the accuracy of any claims, systems, data or stakeholder views. Again, it depends what you’re trying to achieve.

Our non-executive chaired audit committee asked for assurance. We chose a large accountancy auditor and covered scope, systems and claims that included any quoted stakeholder views. I have to say that the process of assurance has been extremely valuable internally in helping our people to appreciate issues from different perspectives, and what was published is substantially different from what we would have had without assurance.


The case in favour of reporting is clear. Transparency of performance builds trust and draws management focus. It also provides insight into the running of an organisation for a wide range of stakeholders. What is less clearly defined is the most appropriate content and intended audience for such a report. For example, what issues should a company with predominantly social impacts include? And if such a company’s report ended up as a very long document could they be accused of hiding the important issues within a fog of data?

In the UK, reform of company law is proposing the introduction of a more formal operating and financial review (OFR), which will require a robust and auditable system for identifying important issues, referred to in the draft legislation as material or relevant. But where does that leave CSR or sustainability reporting? Providing additional levels of information on what has been identified as material to the future success of the business or addressing less important issues for stakeholders who still require information?

CSR or sustainability reporting is here to stay, but in what form, covering which issues and to whom will clearly continue to develop.

Rowland Hill, Corporate Social Responsibility and Sustainable Development, Marks and Spencer. For more information please visit: http://www2.marksandspencer.com/thecompany/ourcommitmenttosociety/index.shtml

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