FINAL REPORT OF THECONSERVATIVE PARTY WORKING GROUPON RESPONSIBLE BUSINESS

A light but effective touch

MARCH 2008

CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSCONTENTS

3 Foreword by David Cameron MP

4 Preface by the Working Group

5 Executive summary

6 The value of the market• Reassessing the role of government• Using what we have: reinforce and resource• The need for a long-term vision• The role of government in promoting responsible business

9 Recommendations• Responsibility Deals• Investors and responsible business practice• A corporate-responsibility-based review of the Combined Code• “Apply or explain” responsible business reporting• Revitalising the Corporate Health and Safety Performance Index• Amending the Pensions Act 1999

15 Small and medium-sized businesses and responsibility

16 Oversight of responsible business practice overseas• Human rights• Bribery and corruption• Encouraging business participation in private voluntary initiatives

18 Business and better community engagement

19 Climate change and the role of business• Encouragement and engagement• Carbon labelling

21 About the Working Group on Responsible Business

AuthorsPeter Davis, Jonathan Djanogly, David Grayson, Richard Hamilton, Tom Rotherham and Tobias Webb

Editing assistanceGareth Overton, Christian Braun and Ian Welsh

DesignAlex Chilton Design Ltd

Contents

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The Conservative Party has always been the party ofbusiness: we instinctively understand and appre-

ciate the vital role that businesses play in creating thejobs, wealth and opportunity on which all elsedepends. The products, services and innovationswhich improve people’s quality of life are created bythe talent and energy of men and women working incompanies of all types and all sizes, and we mustnever take their enterprise for granted.

Precisely because we have such a high regard forbusiness and the contribution it makes to our society,I want the modern Conservative Party to be not justthe party of business but of responsible business. Thisreport sets out what that means, and shows howresponsible business is not only in the public interestbut the commercial interest too. It also describes adistinctively Conservative approach to responsiblebusiness – one which is part of our overall vision ofsocial responsibility, moving to a post-bureaucraticage in which the state does less, but does it better.

We have seen over the past decade howill-thought-out regulation adds unnecessary costs andburdens to business. That’s why I’m delighted to backthe central argument in this report: that by workingtogether constructively with business we can achievefar more than through top-down, over prescriptivemicro-management.

I’m enormously grateful to the authors of thisreport for their work, and to the many businesspeople who have kindly participated in the consulta-tions that have helped to shape this document.

FOREWORDCONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

Foreword by David Cameron MP

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CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSPREFACE

In March 2006 the Conservative Party commis-sioned the Ethical Corporation Institute to form a

Working Group on responsible business as part of theparty’s policy review process. The aim was to convenea small panel of active and experienced experts in thefield, produce an initial scoping report and thenengage business and other actors to explore a modernresponsible business policy for the Conservative Party.

The interim report was published in January 2007.Thereaer, more than 150 group and individualmeetings each took place with at least one WorkingGroup member present. Peter Davis and Tobias Webbof the Ethical Corporation Institute co-ordinated theWorking Group’s activities and led the writing ofboth reports.

Jonathan Djanogly’s oce provided support,writing to every FTSE 100 company and other keygroup asking for its input, as well as helping co-ordinate consultations. Jonathan Djanogly himselfcommitted considerable personal time to consulta-tions with business.

Following on om the interim report in January2007, the Working Group has produced this, a secondreport, for the party. Given the exploratory nature ofthe first report, this second report contains morepractical detail and discusses the Working Group’sfindings. Many ideas having been tested in thebusiness community and beyond during the consul-tation process. �

Preface by theWorking Group

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This report seeks to answer a question: What can afuture Conservative government do to encourage

business to play a central role in securing a betterfuture for British society?

Despite a proliferation of regulations, initiatives andother interventions by the current government, thenegative effects of issues like obesity and drinking areincreasing, and are of evermore concern to the public.

We advocate a shi in emphasis for government,om seeking always to ‘do’ things, to acting rather as

a facilitator to stimulate and co-ordinate action bythose groups that make up modern society.

In our view, the most effective tool for a futureConservative government to achieve this in concertwith the corporate sector is by using the market,which we believe can be shaped to provide not justproducts and services, but social and environmentalgoods as well. Government’s central undertaking

should be to help all relevant market actors have agreater influence in bringing about positive socialoutcomes where this is consistent with public policyobjectives.

Our proposal to achieve this is the introduction ofthe Responsibility Deal – a mechanism that enablescompanies to collaborate more effectively with othergroups in society to address issues of commonconcern in a coherent and focussed way.

This is not to say that regulation and legislationare irrelevant. Far om it: Legislation and regulationare key tools that government can use for balancingthe market. However, we believe that encouragingmore responsible business practice does not requiresignificant new legislation. We argue that much ofthe legislation and regulation needed is already inplace. It simply needs to be used more effectively.

Where new regulations are needed, they must betargeted and specific. We make recommendations inthe areas of disclosure requirements and corporategovernance. There are also a number of recommen-dations focussed on the specific needs of the smalland medium-sized business sector.

We recognise that the behaviour of Britishbusinesses overseas is a matter of considerable impor-tance, and one for which oversight is much morecomplicated. Nonetheless, we recommend that, as isthe case in domestic policy, there is no need to passnew laws, but rather to reinforce and properlyresource structures that are already in place. �

EXECUTIVE SUMMARYCONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

Executive summary

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Much of the legislation and regulationneeded is already in place. It simplyneeds to be used more effectively

Many business leaders believe that responding towider social and environmental challenges is

simply the right thing to do

CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSTHE VALUE OF THE MARKET

The Working Group believes that markets are themost effective mechanism for producing goods

and services, creating both financial and social valueand stimulating innovation. We also believe that themarket, steered where necessary, is capable of gener-ating environmental and social goods, and that themarket is the most expedient vehicle for generatingmore responsible business practice.

Companies oen find themselves chastised in thepress for misdemeanours, and equently the criti-cism is justified. Conservatives should entirelysupport public criticism of companies that repeatedlyact against the common good. However, criticism ofparticular companies on specific issues is sometimestaken to imply that somehow companies in general,with profit their sole motive, are “a bad thing” andthat they are incapable of providing any social benefitbeyond their economic success.

We reject this. Any schema that sees companies asnecessarily in conflict with society is wrong. Compa-nies are a fundamental part of society. The problem isthat markets must be better aligned with society’sneeds.

It is evident om our consultation and experiencethat a great deal of work is being done by companiesto address directly a wide range of social and environ-

mental issues. In most cases, these activities areundertaken not because there is a legal requirementto do so but because the company in question believesthere is a commercial rationale. Alongside this, manybusiness leaders believe that responding to widersocial and environmental challenges is simply theright thing to do. The market for organic agriculture,

for example, emerged om the coincidental interestsand actions of, among others, retailers, farmers,investors, consumers and civil society – all of whichhave shaped the market into what it is today.

None of this is to say, of course, that the market isperfect. We recognise that, individually and collec-tively, companies do have negative impacts. However,in our view, this does not negate the relevance of themarket. It simply means the market needs to betailored better to produce the benefits that modernsociety requires. It is the responsibility of governmentto step in carefully where ee markets produceundesirable social and environmental outcomes.

Reassessing the role of governmentIt is the view of the Working Group that the role ofgovernment in British society has expanded too far. Inthe past few years the country has reached a positionwhere the government believes it is expected to solveall social ills. Regulation and legislation are seen bysome as the sole tools with which to address issues ofconcern. When existing rules fail to solve a problem,there are calls for these rules to be tightened.

This is wrong. Historically, the standard responseto the issue, for example, of problem drinking, is totighten regulations – to raise the drinking age andincrease the age at which alcohol can be bought. Webelieve that the exclusively regulatory approach isbased on a fundamentally flawed view of the world,and actually stifles more collaborative and moreeffective ways of addressing issues of concern tosociety.

We believe that issues such as problem drinking,which are complex and multifaceted, cannot beresolved by government action alone: They need toinclude all relevant groups in society. We thereforepropose a fundamental change to the role of govern-ment in the regulation of business, away om“government as doer” to “government as facilitator”.

In our view, it is unsurprising that governmentsroutinely fail, when elected, to do what they promisein their manifestos. Many of the things they proposeare just not deliverable by government acting on itsown simply through legislation. There is a strongneed for collaborative problem-solving, and this

The value of the marketUsing the market and existing legislation, government can promote better business practices

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THE VALUE OF THE MARKETCONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

report recommends a specific process – the Respon-sibility Deal – to help make this happen.

Using what we have: reinforce and resourceA number of the submissions the Working Groupreceived called for the introduction of legislation torequire responsible business practice. This was aconsistent theme in meetings with many non-governmental organisations, though by no means all.We have not been persuaded to alter the view weexpressed in our interim report that such legislationis generally not the best way forward. This is not tosay that legislation is irrelevant, merely that it shouldbe, when used, carefully targeted at specific behav-iour. In fact, in our view, much of the legislation thatcould encourage more responsible business practiceis already in place. It simply is not being used orenforced properly. For example, no major prosecu-tion has yet been brought under those parts of theAnti-terrorism, Crime and Security Act 2001 that aredesigned to tackle corruption.

It is our recommendation, therefore, that a futureConservative government, rather than introduce rasof new legislation, should reinforce and properlyresource existing regulations and other ameworksthat could be used to encourage more responsiblebusiness. Government exists to take action in the collec-tive public interest. It has to respond to the wishes andaspirations of the majority of the population, whileprotecting the interests of minorities.

A central part of government’s role, therefore, is toexamine competing interests and values, and come upwith a definition of the “public interest”. Governmentalso has to set priorities – it is impossible to address allissues of concern in one go. Furthermore, governmentis responsible for creating national and internationalinstitutions capable of addressing the priority issues –the National Health Service, for example. Governmentcan also introduce legislation and regulation to seek tomake happen those things that are decided to be in thepublic interest. Government can:

• regulate access to resources, for example throughplanning consents;

• stipulate required performance, for example onvehicle emissions or the minimum wage; and

• ensure openness and disclosure, for examplethrough product labelling and advertisingstandards.

In our opinion, the expectation of what govern-ment can achieve directly by acting on its own has

become greatly exaggerated. We have reached a situa-tion where we expect government to do too much.The usual response to a newly identified societalproblem or intractable old one is: “The governmentmust act.” In our view, this position is untenable forthe simple reason that change cannot be broughtabout by government alone.

On the question of business responsibility, it is timeto move to the modern Conservative view of a smaller,smarter state. In a post-bureaucratic age, governmentintervention in a problem should be at a level and to adegree that is appropriate to the issue at hand, and therole of government should be more creative thansimply that of legislator. We advocate that governmentshould develop its role as a catalyst to instigate intel-ligent debate about key issues of concern, and then actas facilitator for solutions, bringing together all those

different groups that can help to bring about change.This approach will bring back in and empower not justcompanies but also other key groups in our society, bethey charities, faith groups, cultural groups orconsumers. What we are seeking to do is, to paraphraseDavid Cameron, find ways of rolling forward society,not just rolling back government.

The need for a long-term visionAll but the most dogmatic stances on responsiblebusiness now recognise that the primary motivatingforce behind a company’s actions is, and can only be,enlightened self-interest. Just as a company would beunlikely to invest in research and development unlessthere was an expected return, neither should we hopethat companies would invest in sustainability withoutan expected return.

But self-interest is not the same as selfishness.Particularly over longer time scales, it is clear thatcorporate interests overlap significantly with publicinterests. While a deteriorating educational system isunlikely to hurt a company’s revenue in the shortterm, a reduction in skilled labour may well limit its

On the question of business responsibility, it istime to move to the modern Conservative view

of a smaller, smarter state

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CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSTHE VALUE OF THE MARKET

long-term prospects. Similarly, investments in energyeciency may increase costs over this quarter, butlower energy costs can save money in the longer term.

The most enlightened self-interest can be mistakenfor altruism, but efforts to promote altruism incompanies will fail. The objective must be to extendthe time scale over which companies can pursue theirself-interest and, in so doing, to increase the consis-tency between corporate interests and publicinterests. Government’s propensity constantly tomove the goalposts on important issues makes it di-cult for companies to plan and invest. A Conservativegovernment should put greater long-termpredictability at the heart of market-based policies toenable responsible business.

The role of government in promoting responsiblebusinessWe propose a new role for government in promotingresponsible business: acting as the convening bodyto identi common interests; negotiating co-opera-tive and mutually beneficial strategies; anddeveloping and, in some cases, overseeing the insti-tutions needed for those strategies to succeed.The following pages detail recommendations onwhat a future Conservative government can doto harness the market so that all actors in societycan play a full role, and ensure that the marketdelivers responsible business practice. We alsomake recommendations appropriate to particularmarket actors. �

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RECOMMENDATIONSCONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

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The Working Group’s central recommendation,which reflects our post-bureaucratic view of the

state, is the development and use of what we callResponsibility Deals. Such deals represent a funda-mental shi in the model of government in the UK,om the current top-down, bureaucratic approach, toone that stresses collaboration and collective action.

Responsibility Deals are a mechanism to tackle overtand clear problems in British society in a collaborativeway. Issues that they might address include businesscontributions to tackling obesity, problem drinking,climate change, and reducing and recycling waste.

Existing models of government consultation onsuch issues with business and civil society groups arefundamentally flawed. Firstly, there is the question ofwhether such consultations actually have any effecton proposed legislation. However, secondly and farmore importantly, existing models are based on theassumption that action taken will consist only ofregulation or legislation by government, to whichbusiness will respond.

Responsibility Deals represent a shi away omthis approach. They are not designed to get industryand civil society “input” or “consent” into plannedgovernment activity, but rather about creating theright kinds of ameworks for constructive andprogressive activity om all sides, with a bias againstnew government activity, except as a last resort.Responsibility Deals would be based on genuinecollaboration throughout the process om beginningto end. Using this mechanism, government, businessand civil society would jointly define the issueneeding attention; agree which party is best placed todo what; and move forward with defined responsi-bilities and agreed goals and targets.

Participants in Responsibility Deals would be drawnom businesses and business-representative bodies,NGOs and the voluntary sector, academic institutions,regulators, government bodies and investors. Theywould tackle important societal issues by agreeing ona shared understanding of what the issue is, whatneeds to be done and who will do what, and by when.

The Working Group advocates that part of aredefined government role in business should be toconvene and manage such partnerships as an objec-tive broker and arbiter. Relevant governmentdepartments and agencies would also be participantsin Responsibility Deals.

Responsibility Deals would provide a forum inwhich different types of organisations could discusshow to create a market environment that financiallyrewards companies that produce non-financial

benefits to the others. Their aim would not bepunishment for anti-social behaviour but reward forpositive environmental and social behaviour. Repre-sentatives of British communities as a whole wouldbe taking responsibility for ensuring that the rightconditions are present to drive change.

Why have them?It is evident om our research and consultations thatbusiness, government, labour and civil society groupsdesire mechanisms for tackling issues more collabo-ratively, as a shared responsibility. Carefully chaired

and managed Responsibility Deals would bringtogether all relevant parties. These would define thekey aspects of a problem. Government would thenbroker a way forward for the parties involved thataimed to be predominantly non-regulatory. TheWorking Group’s many consultations revealed a highlevel of support for this concept om businesses andothers who attended the sessions we held during thecourse of 2007.

How would our proposed model work?First the relevant Secretary of State would be chargedwith developing a process of sharing responsibilitiesin order to address a particular issue where businesscan make an appropriate progressive contribution. Itis important that Responsibility Deals be driven atSecretary of State level, to encourage and incentiviseproper participation om business and other partsof society.

For example, a Responsibility Deal concerned withobesity could be led by the Secretary of State forHealth. On a day-to-day basis, a Responsibility Dealcould be overseen by a relevant Minister of State,supported by a team of ocials, in the same way as adepartment’s work is currently apportioned andmanaged.

That Secretary of State and the Responsibility Dealmanagement team would be responsible for

RecommendationsResponsibility Deals are a new way to tackle social and environmental challenges and encourage innovation

CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSRECOMMENDATIONS

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identiing all the key relevant organisations – civil,governmental and corporate. Given the number andrange of different potential participants in a Respon-sibility Deal on an issue such as obesity, there wouldbe a balance to be struck in having a suciently-broad participation to ensure a wide range of inputand, on the other hand, a suciently-focused partic-ipation to enable the process to be manageable.

For the sake of manageability, it would probablybe best to begin initial Responsibility Deals with arelatively small number of representative groups. TheSecretary of State would then invite the groups to aseries of outcome-focused meetings. The aim of thesewould be to develop a shared understanding of theissue, and to define a shared and realistic approachto dealing with it.

For example, a Responsibility Deal in obesitywould have to tease out how different factors such asthe role of regular exercise, the composition ofvarious food products, and education in healthyeating might combine to address the problem. TheResponsibility Deal process would then have tonegotiate who would do what in each area so that a“joined-up” approach would result.

Securing participationWhile participation would not be mandatory, itwould reflect poorly on any party – corporate orotherwise – that did not participate when invited todo so. The aim of each group would be to develop aResponsibility Deal, defining, in the case of compa-nies and other actors, what reasonable expectationsthe rest of society had of them and what reasonableactions can be expected of business and other parties,bearing in mind the constraints under which eachgroup operates.

The process would be discursive and companieswould therefore have the opportunity to argue theircase for why certain expectations were realistic orotherwise. The process will also be designed to bringpressure on other parties to play their respective rolesand focus on outcomes over ideology. It would fall tothe relevant Secretary of State to exert pressure toensure that commitments made as part of theseforums were delivered. That would become a keyfunction of the relevant government department.However, regular meetings of the forum would alsohelp to ensure that there was a shared sense, amongall participants, of the need to deliver on their part ofthe contract.

The finding of our review is that many companieswould welcome Responsibility Deals. Wise compa-

nies have seen the many ways in which responsiblebusiness behaviour makes them more competitive,although we accept there are laggards. A key advan-tage of Responsibility Deals is that they wouldprovide a context for collective action, therebyreducing (even eliminating) the commercial risk forcompanies of being put at a competitive disadvantageby taking some action that has short-term cost forlonger-term gain. Responsibility Deals create spacefor all companies in a sector to move forwardtogether voluntarily, whilst retaining the eedom forsome to go further and show real leadership if theyconsider it to make business sense and to meet publicexpectations.

In our experience, one ustration many compa-nies express is the diculty of “joining up” theirefforts to address the social and environmental

aspects of their operations with the work of others.The proposed Responsibility Deals would place co-operation between companies and others – whetherNGOs, government agencies or voluntary groups – atthe centre of the process of government. Theapproach would ensure that companies’ activitiescohere and interlock properly with those of others.

How would Deals be created and their scopeassessed?It is an obvious risk that Responsibility Deals could bejust another quango-like talking-shop. It is crucialthat they be focused on real, practical actions and thatthe relevant government department is held account-able by the cabinet on this basis.

A Responsibility Deal on obesity might see compa-nies changing the ingredients of the goods they sell,and amending their advertising practices; schoolsproviding better education on healthy eating; and agovernment campaign – similar perhaps to otherbehaviour-change campaigns such as that regardingdrink-driving – to encourage people to eat healthily.

However, it is vital that these actions be based on a

Responsibility Deals will bring together allrelevant parties to define key aspects of a problem.

Government would then broker a way forward

RECOMMENDATIONSCONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

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shared and comprehensive understanding of the issueat hand. Responsibility Deals would be created to makethings happen. The chair of each Deal must be of su-cient seniority and authority to achieve generallyagreed goals under the terms of reference created: Webelieve that this means that Deals need to be chairedunder the direct supervision of a Secretary of State.

There is great potential for Responsibility Deals tohave a distinct relationship with the CHaSPI indexidea mechanism, which appears later in this chapter(see p13). The Conservative Party should explore thisfurther. For example, on a particular issue a regulatorcan design a credible voluntary index for measuringspecific business performance in conjunction with arange of stakeholders. The regulator can then rewardcorporate take-up of the index and good performancewithin it (and hence improved corporate self-regula-tion) with a lighter regulatory touch whereappropriate. The Working Group feels this notion iswell worth exploring with regard to ResponsibilityDeals to help create credibility and improve businessperformance.

Business involvement should not be over-compli-cated, since this would increase costs and thelikelihood of non-participation. An effective chairwould be directly appointed by, and report to, thelead Secretary of State to steer discussions and avoidany stalling of the process.

Representative NGOs must feel their contributionis valued and that they would have proportionateinfluence within Responsibility Deals. Equally,business and trade associations could play a key role,provided they can demonstrate over time that theirefforts make a difference to their members. Partici-pants in Responsibility Deals should set the standardsby which their progress should be judged. MPs couldplay a key role in deciding what sector or issues areappropriate for Responsibility Deals and offer publiccomment on their performance.

How would progress be measured?TheWorking Group feels that other collaborative initia-tives where government has been involved inresponsible business have focused on both dialogue andprocess over even-handed outcomes. Shiing the focusto outcomes while maintaining the open dialogue andtransparent process is vital, and is something Respon-sibility Deals can do, if government plays its full role asconvenor, catalyst and ultimate arbiter.

Central to the concept of the Responsibility Deal isthe idea that actions to address a given issue aredivided amongst different participants, each doing

what it is best placed to do. All participants wouldtherefore have to report back to the partners in theirDeal on progress against the actions they commit tomake.

It is necessary also to consider public reporting ofprogress on Responsibility Deals. The Working Groupproposes that each Deal would have an annual reviewprocess, to include transparent reporting and assess-

ment by an independent group of experts offeringcommentary on what has worked, and what has not.Random audits of the performance of any of theparticipants – corporate, governmental or civilsocietal – could be carried out by an appropriateregulator to veri performance. Companies would beencouraged to report on their participation inResponsibility Deals in their corporate responsibilityreporting. NGO and government participants maydecide to report in a similar way.

How would laggards be encouraged to take part?Regulation on the specific topic under considerationcould be discussed as a last resort should anindividual Responsibility Deal not be able to makesuitable progress. A senior level cabinet ministerwould ultimately be responsible for each Deal, and mayuse his or her influence to make sure progress is made.

Participation, or lack thereof, in Responsibility Dealswould be governed by the principle of “engage orexplain” for companies, giving them the opportunityto clari or explain their position should they notwish to contribute. Investors and NGOs involved inResponsibility Deals would be encouraged to highlightto the public the good work they see being done bycompanies. Equally, they would be encouraged tocreate pressure on laggard businesses as they see fit,including those that choose not to participate. Giventhe high public profile of issues likely to be coveredby Responsibility Deals, we believe it is likelymost major business players will want to participatein them.

Actions to address a given issue are dividedamongst different participants, each doing

what it is best placed to do

CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSRECOMMENDATIONS

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Challenges that need further studyClearly, Responsibility Deals have their limits. Notevery issue or every industry can be automaticallyincluded. A future Conservative government willneed to carefully consider where and when to makeuse of them, and who takes part.

For example, small and medium-sized businessesare unlikely to have much time or many resources toapply to some of the issues where ResponsibilityDeals could be applied. Careful assessment of whotakes part and a focus on encouraging participation bysmaller companies would be vital.

Another question that requires further study iswhether Responsibility Deals can work on extremelysensitive issues such as UK business corruptionoverseas. Measures of Responsibility Deals would also

be important, and the Working Group suggests theConservative party would need to work with otherbodies, notably NGO specialists and academics, indeveloping measurement criteria.

Responsibility Deals would also need to avoidduplication of existing efforts and initiatives. They arenot appropriate all of the time, but are one of manytools the Working Group believes government canuse to help steer the responsible business agenda.

Other recommendations

Investors and responsible business practiceSome investors are currently using their votes atannual general meetings as an indicator of their viewsof the firm’s attitude to environmental, social andgovernance factors. The Working Group welcomesthis innovation, but believes that it would be furtherimproved with the inclusion of an advisory vote oncorporate responsibility reporting at company AGMs.Fully-listed companies should ask investors to voteon the corporate responsibility report. This would beknown as an “advisory vote” whereby the companycould engage investors who have voted against the

report. The Working Group recommends that theFinancial Services Authority amend the CombinedCode on Corporate Governance to encourage this.

This formalises the debate and provides informa-tion to civil society groups and pension fund trusteeson how engaged investor groups are in responsiblebusiness issues. Currently, responsible businessperformance discussion takes place in small pocketswith specific investors or small groups of investors.However, the Working Group feels this topic is ofsucient importance to shareholder value for it tobe something that all listed companies talk toinvestors about.

Equally, all investors should consider environmental,social and governance risks in the companies they haveinvestments in. This mechanism encourages both. Thisrecommendation is not about regulation; it is aboutbetter information, shareholder democracy andharnessing the influence of the market.

A corporate-responsibility-based review of theCombined CodeClearly it is one of the roles of company boards tohelp define the standards and values of the company.The Combined Code on Corporate Governance doescontain a reference to the board’s role in setting thecompany’s values and standards (Code A.1 The Board).However, we suggest that this is insuciently clearand requires further serious thought. Further, thetick-box mentality of some companies and investorshas led to this clause being overlooked in practice.While the Turnbull Inquiry, a forerunner of theCombined Code, does mention corporate responsi-bility as a concept, the Combined Code does not makesucient mention of this. The Working Groupbelieves the Combined Code should make recom-mendations about incentives, training and corporateresponsibility strategy.

Adherence to the Combined Code on a “comply orexplain” basis is a requirement of primary listingson the London Stock Exchange. Past reviews ofcorporate governance have considered differentaspects of corporate governance, including executiveincentives on shareholder value. Putting a require-ment for boards to seriously consider their corporatevalues and ethical standards – in other words, realcorporate responsibility – into the Combined Codewould have a beneficial effect on encouragingenlightened self-interest om business.

The Working Group recommends that the Conser-vative Party consider the sections on internal controlsand strategic oversight of corporate responsibility by

All investors should consider environmental,social and governance risks in thecompanies they have investment in

RECOMMENDATIONSCONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

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boards in the “Rewarding Virtue” report by InsightInvestment. Guidelines issued by the Association ofBritish Insurers note that corporate remunerationcommittees should consider corporate responsibilityperformance when they look at overall executivereward. This suggestion should be included withinthe Combined Code, which aer all is designed to berevised over time.

The Working Group believes it would be possibleto mandate an additional remuneration report torequire the remuneration committee to set outwhether and, if so, how corporate responsibility andsustainability are considered by the senior manage-ment of companies when setting annual bonuses andlong-term incentive plans.

‘Apply or explain’ responsible business reportingThe Higgs Review of Corporate Governance isgenerally seen as a success among governanceexperts, large companies and investors. It encourages,in a non-regulatory way, better practices in corporategovernance.

Non-financial risk reporting, a wider but arguablymore important issue, could be encouraged in theways that Higgs has worked. This means encouragingthe use of the “comply or explain” principle thatHiggs has embedded in corporate disclosures ongovernance practices. Higgs himself believes thisshould now be seen an “apply or explain” toemphasise the element of opportunity, rather thanthe compliance approach.

The recent revisions to the Companies Act wouldnot require further reworking on this basis, butinstead government should encourage investor andregulatory groups to take an interest in non-financialrisk reporting by companies on an “apply or explain”basis. Fully-listed companies (which would notinclude, for example, AIM companies) could beencouraged by influential groups and government (viacontract awarding as well as other methods) to adhereto an “apply or explain” principle on non-financialreporting. Encouragement could involve governmentstimulating peer pressure and giving awards to thebest disclosers on an annual basis.

We welcome the publishing of the WalkerWorking Group’s recent report and the fact that theprivate equity industry has decided to come togetherto address the wider concerns implicit in corporateresponsibility through a voluntary code and on acomply or explain basis. The Working Group believesthat there should be a review of how the proposalswork aer an appropriate period.

Revitalising the Corporate Health and SafetyPerformance IndexThe Corporate Health and Safety Performance Index(CHaSPI) could be used as a model for reportingon other areas of corporate responsibility for UKcompanies.

CHaSPI is aimed at organisations with more than250 employees. It is designed to help them manageoccupational health and safety better. The index, some18 months old, currently has about 60 companiesparticipating by inputting performance data onaspects related to health and safety in the workplace.One of the aims is to provide investors with compa-rable information on corporate health and safetyperformance; another to allow companies to comparethemselves to each other. CHaSPI uses both qualita-tive and quantitative data. Key performance indicatorsand information about board oversight are included.

CHaSPI does not have enoughmembers yet. An effec-tive index would greatly help in the self-policing ofcorporate performance on health and safety. A majorfailure has been the lack of a concerted marketingcampaign to get companies to sign up. Companies havealso lacked an incentive to do so. Many of the companiesthat have so far signed up to use CHaSPI are among thebest, meaning its impact is limited in affecting thosecompanies in need of improvement. Without broaderand deeper participation om other companies, CHaSPIwill not be a useful tool.

Government can use its influence with companiesto encourage participation and offer incentives. Forexample, good performance can be rewarded with alighter-touch health and safety inspection regime.A reward for taking part in CHaSPI could be morelenient requirements on reporting to the Health andSafety Executive. Subject to audits om the HSE, ifcompanies do well in CHaSPI they can be offeredfewer site inspections as an incentive, saving timeand money.

Despite the problems with a number of members,there is already significant interest om investors,including Morley Fund Management and InsightInvestment, in CHaSPI. More than 20 investmenthouses contributed to the index’s development, and asimilar number have used it when engaging withFTSE 350 companies. These include Schroders, JupiterAsset Management and Henderson Global Investors.

In CHaSPI, the Health and Safety Executive hascreated an innovative, modern tool, but there is a lackof organisational understanding of how to promoteparticipation. When several years worth of perform-ance data is available om a substantial number of

Fully-listed companies could be encouraged byinfluential groups and government to adhere to an

“apply or explain” principle on non-financial reporting

CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSRECOMMENDATIONS

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companies using CHaSPI, investors will be able to useit to measure quality of management and perhapsidenti links between good health and safetyperformance and financial returns.

Using the CHaSPI concept for responsible businessIf CHaSPI can be made to work, the concept can beexplored in other areas relating to responsible business.Clearly there is a greater opportunity for regulators tomodernise and use the corporate social responsibilityand socially responsible investment agendas toencourage better corporate self-regulation. This wouldneed to be done carefully, with the primary accounta-bility for regulating corporate performance restingwith the relevant government authority.

However, most regulators have overlooked theopportunity to use the influence of other marketparticipants. An example of how this might work isthe Environment Agency’s useful “Spotlight onBusiness” initiative. This highlights good and under-performing UK companies depending onenvironmental performance. This work could beexpanded. The Environment Agency could develop aperformance index based on corporate environmentalgovernance and publish its results. Equally, the Finan-cial Services Authority could publish a performanceindex on treating customers fairly.

Additionally, the data generated om a revitalisedCHaSPI and a future environmental governance orperformance index would have the authority of theocial regulator. Investors would be interested in arevitalised CHaSPI because it would provide themwith consistent and comparable data using standard-ised performance indicators. CHaSPI offers thepotential to reduce the burden of data that compa-nies are mandated to disclose. An environmentalversion of the index would enable investors to judgebusiness progress, adjust their investments andsupport progressive practices while expressingconcerns about poor performance.

This notion of performance indexes presents anopportunity for companies to gain useful bench-marking information. Companies would be able todemonstrate that they have made progress in acredible way. With regular audits of the data cominginto the indexes, with CHaSPI as the initial trialproject, this method can be made extremely ecient.

Specific performance indexes reduce questionnaire

fatigue, are a quality of management indicator,and are proof of progress for investors concernedabout risk. Data om such indexes can also beused in corporate communications and corporateresponsibility reports, and to motivate staff viainternal communications of how their company isprogressing.

For laggards, it offers easily identifiable targetsfor future years – to get to the level of competitors, forexample. The Working Group feels this conceptdeserves further serious exploration by the Conserva-tive Party. CHaSPI should be used as a trial model.

Amending the Pensions Act 1999In 1999, The Pensions Act was amended to place arequirement on trustees to declare via a Statement ofInvestment Principles (SIP) “the extent (if at all)to which social, environmental or ethical (SEE)considerations are taken into account in theselection, retention and realisation of investments; andthe policy (if any) directing the exercise of the rights(including voting rights) attaching to investments”(HMSO, 1999, Section 35(3)(f )). At the time, thisreceived cross-party support and was considered by abroad range of stakeholders to be an innovative policychange. Since then, a number of other countries haveduplicated this reform within their own pensions law.

However, there are a number of serious questions.For example, are pension schemes in compliance? Dotheir advisors regard this as a suciently importantissue? What has been the effect on fund managers? Hasthis ultimately helped to improve the corporate respon-sibility practices of the companies in which they invest?

A central theme of this Working Group report isthat there is significant potential in harnessing themarket to promote corporate responsibility andenhance corporate self-regulation. It is therefore criti-cally important to ensure the effectiveness of thismarket-based, customer information disclosure reformto the Pensions Act and to learn lessons om its imple-mentation. As a result, the Working Group suggests afull review of whether pensions schemes and theirfund managers are implementing both the spirit andthe letter of the law. This review would be conductedwith a view to further strengthening the reform byincorporating an annual reporting requirement forPension Schemes detailing what action has been takenin support of the SIP.�

SMESCONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

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Small and medium-sized enterprises do manythings that could be called responsible business,

although they tend to do so informally. The singlemost important area of responsible-business-relatedactivity for most SMEs is how they treat theiremployees, although this is by no means an exclusivefocus and they oen address other issues too. Manysurveys suggest that the smaller the enterprise, thegreater the importance of personal and ethical valuesas a driver for responsible business. There is, however,a significant proportion of SMEs for which the real orperceived business benefits are an important driverfor corporate responsibility.

In reality, responsible practice in SMEs is oendriven by a combination of personal values andpotential business benefits. Few SMEs can quantithe actual business benefits of their responsiblebusiness work, but the following are equently citedas perceived benefits:

• recruiting and retaining staff;• customer loyalty;• more secure supplier relationships; and• energy savings.

The links between corporate social responsibilityand innovation, and between responsibility and thedevelopment of social capital, are two interestingemerging areas of research on the “business case”for responsible practice for SMEs.

ConstraintsThe most commonly cited constraints on the furtherdevelopment of corporate social responsibility inSMEs are:

• the perceived cost, combined with having otherpressing business priorities;

• uncertainty about the business case;• a lack of know-how; and• time.

Furthermore, the term “corporate social responsi-bility” is unattractive and off-putting for many SMEs.One alternative to be promoted should be “sustain-able business”.

Help for SMEs to embed responsible or ethicalbusiness practices needs to be customised fordifferent types of company and should be availablethrough existing business development organisationssuch as Business Link, chambers of commerce andtrade associations. Membership organisations shouldlead wherever possible in raising standards. Largecompanies need to consider the ability of smallcompanies to comply with new expectations –offering assistance and the phasing in of any changesand not immediately requiring revised practices.Large companies need to consider the ability of smallcompanies to comply by letting SMEs develop theirown way forward, and not seek to over-prescribe.

We also recommend that existing governmentgrants for “Knowledge Transfer Partnerships”between universities and business be utilised tosupport facilitated action-learning by groups ofowner-managers of small businesses.

Big companies should also be encouraged totransfer knowledge om small companies totheir own operations and vice versa. This couldbe undertaken via bilateral engagement or in regionalforums. The Conservative Party should encourage thispublicly. The first part of the process should be toresearch what practical hurdles exist to prevent orrestrain SMEs om adopting good business practiceand how these hurdles can be lowered or removed.Equally the minority of illegal rogues, who undercutthe good SMEs, need to be tackled by targeted andeffective legal enforcement. Larger companies shouldbe encouraged to consider innovative ways ofengaging with the smaller firms with which theydo business. �

Small and medium-sized businessesand responsibilityPersonal qualities of directors drive the ethics of smaller companies. Business associations and largercompanies should help establish an ethos of responsibility in their members and supply chains

Help for SMEs to embed responsible orethical business practices needs to be

customised to different types of company

CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSBUSINESS PRACTICES OVERSEAS

Most of the recommendations in this report dealwith encouraging responsible business practices

of companies operating in the UK. We recognise,however, that the behaviour of British companiesoverseas is also a matter requiring consideration.

Dealing with such issues is complicated by the factthat extra-judicial oversight by the UK legal system ishard to enforce, except where international agree-ments exist or reciprocal arrangements are in placewith other countries. However, in the view of theWorking Group, there are a number of steps that afuture Conservative government could take to protecthuman rights and fight corruption. This does notinvolve passing new laws, but rather reinforcing andresourcing structures that are already in place.

Human rightsThe human rights impacts of the corporate sectorhave been a cause célèbre in the past decade. Fromoil extraction in Aica to garment manufacturing inIndia, the impacts of companies’ activities on thehuman rights of workers and communities inemerging markets have been the subject of large-scalecampaigns and much public debate. Understandably,there have been strong calls for legislation to controlthe behaviour of British companies working overseas,to ensure that their activities do not have adversehuman rights impacts, and to call companies toaccount where necessary.

While we are sympathetic to the sentiment that liesbehind these calls, the Working Group does not believethat such legislation would be practical. We also believethat new legislation is unnecessary since mechanismsalready exist that, if properly used and resourced, couldhave a significant impact on corporate behaviour.

It is our view that there is a need to “reinforce andresource” existing legislation and guidance, ratherthan introduce anything new. The UK has acceded tothe OECD Guidelines for Multinational Enterprises,and a National Contact Point has long been estab-lished at the Department for Business Enterprise andRegulatory Reform.

However, despite recent changes, this NCP appearsto be under-resourced, with the result that it is

unable to deal with the cases brought before it. Thecurrent system allows campaigners, unions and othercivil society groups to raise issues of concern, andprovides a dispute-resolution process. It is our strongrecommendation, therefore, that a future Conserva-tive government provide sucient resources to theNCP so that it is capable of dealing with any substan-

tive issues referred to it. Further, the work of the NCPshould be publicised better.

We also believe that a Conservative governmentshould encourage business to focus on the practicaldelivery of human rights policies through activitieson the ground. This can be done by, for example,providing government support and financialresources to such initiatives as the Business LeadersInitiative on Human Rights and Business Action forAica. Encouragement should also be given byrequiring companies to report on how human rightspolicies and principles are incorporated into theiroverall strategy, as part of their compliance with arevised Combined Code on Corporate Governance.

Bribery and corruptionThe UK has a significant body of legislation designedto tackle corruption, dating as far back as the PublicBodies Corruption Act 1889 and the Prevention ofCorruption Act 1916. More recently, the 1997 OECDConvention on Combating Bribery of Foreign PublicOcials in International Business Transactions wasincorporated into UK law as Part 12 of the Anti-Terrorism, Crime and Security Act 2001. The currentgovernment has been heavily criticised in the past

Oversight of responsible businesspractice overseasUK companies operating overseas must be encouraged to continue to develop best practice regarding humanrights and corruption issues. Private voluntary initiatives are a useful tool in this respect

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We believe that a Conservative government shouldencourage business to focus on the practical delivery ofhuman rights policies through activities on the ground

BUSINESS PRACTICES OVERSEASCONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

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year, not least by the OECD, for dropping the SeriousFraud Oce investigation into the al-Yamamah armsdeal with Saudi Arabia.

This report is not the place to debate this series ofevents, but we believe it is important that the Conser-vative Party take a stand against corruption. TheWorking Group recommends that a future Conserva-tive government demonstrate its commitment toensuring that British companies are not engaged incorruption by rigorously enforcing those elements ofthe 2001 Act that embody the OECD anti-corruptionconvention, if necessary through the introduction ofnew legislation.

Encouraging participation in private voluntaryinitiativesThe current government has made some headway infunding and encouraging private voluntary initiatives(PVIs) that tackle major issues in business supplychains and in worldwide responsible business.

The Ethical Trading Initiative, the ExtractiveIndustries Transparency Initiative and the KimberleyProcess have flourished with government support,and are examples of successful PVIs in recent years.More than 30 are in existence, and a biannual reviewof their progress should be commissioned to discoverthe lessons learned.

But the Conservative Party could go further.

We suggest:

• The party should promote independent researchon labour violations and emerging progressivepractice in the global supply chains of specificindustries. It should financially support researchon the impact of improved voluntary standardson company competitiveness, for example byacademic institutions.

• It should be an active supporter of those PVIs thattackle serious labour violations. Government canhelp by promoting standards for openness andtransparency on PVI operations and achievements.

• It should help build new PVIs by assistingBritish firms to build bridges in both sourcingand customer markets. Government’s relation-ships with other administrations couldbe useful for the private sector in developingrelations for PVIs in the markets om whichcompanies source.

• It should develop new mechanisms to provideincentives for companies to join PVIs. This couldbe done by using state procurement contracts,providing favoured access on trade missions toPVI participants and by putting pressure oninternational financial institutions to addPVI-like requirements as a condition of financeprovision. �

A future Conservative government should demonstrateits commitment to ensuring that British companies are

not engaged in corruption

CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSCOMMUNITY ENGAGEMENT

Employee volunteering has become an establishedfeature of working life for the UK’s largest compa-

nies. With employee participation running atanything up to a third of employees in some compa-nies, many organisations invest considerably inencouraging their staff to get involved in the localcommunity. In some cases, employee volunteeringschemes have been established for a decade or more,and are bolstered by volunteering taking place on thecompany’s time.

However, for all but the largest companiesemployee volunteering is dicult. Smaller businessesneed their staff to be working during work hours, andthe idea that a company can tell its employees whatthey should do in their own time is repellent to many.

Yet it is critical that business be engaged in the localcommunity. On one level, companies are engagedthrough the economic contribution they make tosociety and to communities. But we believe that

business has a role to encourage staff to be involved incommunity issues, and those issues need to becomemuch more aligned with companies’ core strengths.

Whether a business operates globally withhundreds of thousands of people, or is a smallbusiness operating in one town with half a dozenpeople, there are issues in those communities thatcannot be solved without the positive, active andenergetic engagement of business and the people whowork in them.

At the global level, the United Nations – throughthe Millennium Development Goals – laid downeight key challenges. The world has no hope oftackling them without the active engagement ofbusiness.

Given the need to rebuild society here in Britain,the encouragement of civic and social engagement bybusiness, and those who work in it, is not just impor-tant, it is a prerequisite. There are no solutions tofixing our society that do not involve business insome form or another.

Community activityOne of the six ways Business in the Communityidentifies for business to be involved in the commu-nity is engaging employees in community activity.BiTC believes that companies should aim to supportat least a quarter of staff in volunteering.

We believe that corporate schemes to encouragevolunteering should not be about setting a target, norshould they be simply about employees “volun-teering” for worthy causes. If business has a role inemployee volunteering it must include focusing onissues that matter to the company’s core business, andleading change by encouraging their people to takeup local community issues as leaders, volunteersand supporters.

We recommend that businesses think aboutemployee engagement in a strategic sense, so thatthey align such activity with their core strengths.At present, the government is looking to businesses tohelp solve a ra of different problems. Large compa-nies, in particular, are increasingly expected toaddress specific social challenges identified bygovernment, not all of which relate to every business.

A Conservative government should encouragebusinesses to be engaged with community or publicpolicy issues that relate to their business activities,and look at how they can incentivise their employeesto use their business skills and expertise in a broadercapacity. �

Business and better community engagementCompanies should be encouraged to integrate more closely with the wider community throughemployee volunteering schemes

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There are no solutions to fixing our society that do notinvolve business in some form or another

CLIMATE CHANGECONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

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According to a poll conducted by the EnergySaving Trust in April 2007, 80 per cent of the

public believe that climate change is having a seriousfinancial, environmental and social impact on the UK.70 per cent want to help tackle it. But just 38 per centof those surveyed said they had changed their lives totackle climate change and only 4 per cent hadchanged their lives dramatically.

The people questioned by the Energy Saving Trustare likely to be representative of the employees of thesmall and medium-sized businesses that make up 90per cent of the UK economy. The clear message is thatmore practical advice is needed about how people cantackle climate change in small steps, starting, forexample, with insulation and energy eciency inhomes and oces.

Given the public profile of FTSE 100 companies,the Working Group has no doubt these organisationswill continue to lead the country, and the world, intackling climate change by reducing emissions. Thechallenge for the Conservative Party lies in encour-aging listed companies outside the top 100 andnon-listed companies to take similar action.

As we have argued, larger companies can be encour-aged to help and advise smaller ones, particularlysuppliers, to meet better standards. This is alreadyhappening. The key will be for the larger companies toget their incentives and time ames right, and forthem to offer support and encouragement, whilemandating continuous change in their supply chain.While encouraging this activity is a role for govern-ment, a bigger challenge, particularly given the likelyextension of carbon trading into the UK economy forlarger firms, is to persuade the small and medium-sized sector to do more to save both carbon and money.

Encouragement and engagementThe Working Group believes the Conservative Partyhas taken a strong position on climate change in UKpolitics. Incentives to act must be clearer for compa-nies, and many businesses have suggested that thegovernment needs to move faster to create a clearerincentives amework for business to tackle carbonemissions. The Working Group agrees with thisanalysis.

UK SMEs require encouragement and engagementon the basic steps they can take to tackle climatechange. As there is a dearth of evidence-based knowl-edge on how SMEs can be encouraged, theConservative Party should commission a suitablyfunded study.

We believe that larger businesses, and those soonto be affected by the dra climate change bill –“medium polluters” – will soon act further and asksmaller suppliers to join them in the transition to alower-carbon economy. It is therefore vital that astudy on SMEs and climate change consider how thistransition can be enabled with the lowest possibleimpact on SME competitiveness.

This is an area so far largely unexplored, butlessons can be learned om the experience of largerfirms assisting smaller ones, and social enterprise.The Working Group believes that many of theresources currently available to UK business onvarious climate-change-related websites are toofocused on awareness-raising rather than simple

Climate change and the role of businessThe next tranche of climate change policy initiatives should be aimed at SMEs

The challenge for the Conservative Party lies inencouraging listed companies outside the top 100

and non-listed companies to take action

Sustainability in government procurementOur remit in this report is not about what govern-ment can do for itself, but about corporateresponsibility. That said, how government behavesin terms of setting an example is important. Interms of procurement, the Working Group advocatesthat a future Conservative government should leadon sustainable procurement. Lessons should belearned from the private sector on this issue.

CONSERVATIVE PARTY WORKING GROUP ON RESPONSIBLE BUSINESSCLIMATE CHANGE

practical and immediate actions that businesses cantake. The Conservative Party should encourage

climate-change-related communications to be muchmore pragmatic for those businesses that wish to takesteps. A case-study approach in such literature, whichsmaller companies can relate to, with information onthe impacts of making climate-iendly changes oncompetitiveness, would also be more helpful thanmany of the current approaches.

Placing a value on carbon will significantly helpbusiness in the UK respond to climate change. UKbusinesses, large and small, can make some simpleimprovements on carbon emissions om UK oces,

facilities, power stations and transportation, andshould be encouraged to do so. But the complexity oftracking and reducing supply-chain carbon shouldnot be overlooked.

The Working Group advocates that business workwith pragmatic NGOs and academic institutions tounderstand properly and address the issues. TheConservative Party should explore ways of encour-aging this and make it a key part of their climatechange strategy.

Carbon labellingThe Working Group feels that carbon labelling shouldbe carefully considered. While companies will findbenchmarking helpful, we are not convinced thatputting carbon labels on tins of beans or bottles ofshampoo is the best approach. Consumers may beconfused and companies may simply contribute to labelproliferation without driving competitive advantage.

The Working Group recommends that the Conser-vative Party encourage businesses and public sectororganisations to begin labelling with caution. To beeffective, labelling should be limited to carbon-intense products or services. These might include, forexample, cars, flights, trains and large householdelectrical goods. �

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Social emissions tradingFor our interim report in January 2007 the WorkingGroup sought views on developing a process ofsocial emissions trading. This notion was basedon furthering the concept of carbon emissionstrading to specific social issues. After more than50 consultations with businesses and other actors,it became apparent that such a concept would notserve its purpose.

The Conservative Party should encourage climate-change-related communications to be much more pragmatic for

those businesses that wish to take steps

THEWORKING GROUPCONSERVATIVE PARTYWORKING GROUP ON RESPONSIBLE BUSINESS

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Peter DavisPeter Davis is co-director of the Ethical CorporationInstitute. As politics editor of Ethical Corporation, hewrites widely on the social and political issues under-lying the corporate responsibility agenda. He hasmore than 15 years of experience in the field ofresponsible business, and has worked all over theworld with organisations as varied as NATO, RoyalDutch Shell, BSkyB and Diageo.

Tobias WebbToby Webb is founding editor of Ethical Corporation,an independent media firm that publishes a magazineon corporate responsibility, produces conferences andresearch and publishes ClimateChangeCorp.com, anonline publication on climate change.

Jonathan Djanogly MPA partner in the corporate finance department of S JBerwin LLP solicitors, Jonathan Djanogly served as acouncillor on Westminster LBC, including aschairman of the contracts and environment commit-tees. He was elected to parliament, representingHuntingdon, in 2001 and recently served on thecompanies bill committee.

David Grayson CBEDavid Grayson is the Doughty chair of corporateresponsibility and director of the Doughty Centre forCorporate Responsibility at Cranfield School ofManagement. He is chairman of Housing 21 and adirector of Business in the Community. A visiting

senior fellow with the CSR Initiative at the KennedySchool of Government, Harvard, Grayson is a formerchairman of the National Disability Council and ofthe Business Link National Accreditation Board. He isa trustee of several national charities. Amongst hisbooks are “Everybody’s Business: Managing risks andopportunities in today’s global society” and “Corpo-rate Social Opportunity: Seven Steps to makeCorporate Social Responsibility work for yourbusiness” (both with Adrian Hodges). He is a serialsocial entrepreneur.

Richard HamiltonRichard Hamilton is a director at KPMG Internationalfocusing on issues of corporate responsibility andpolicy. He joined the firm in October 2006 followingten years at Barclays plc where his roles includedchief operating ocer, global investment advisory,and responsibility for the chairman’s oce. He hasbeen a non-executive director of an NHS Trust since2003.

Tom RotherhamTom Rotherham is head of corporate responsibilityat Radley Yeldar, a corporate communicationsconsultancy.

With the exception of Jonathan Djanogly, members of theWorking Group are not politically affiliated and have giventheir time and input as a way of advancing the debate onresponsible business practice.

About theWorking Groupon Responsible Business