HSE

Health & Safety

Executive

Promoting health and safety as a key goal of

the Corporate Social Responsibility agenda

Prepared by Technopolis Ltd and

Emerging Markets Economics Ltd
for the Health and Safety Executive 2005

RESEARCH REPORT 339

HSE

Health & Safety

Executive

Promoting health and safety as a key goal of

the Corporate Social Responsibility agenda

Philip Sowden
Technopolis Ltd
3 Pavillion Buildings
Brighton
BN1 1EE
Sunil Sinha
Emerging Markets Economics Ltd
Mill Harbour
London
E14 9XP

The Health and Safety Commission/Executive (HSC/E) is looking to business to move beyond
compliance with health and safety regulations to continuously improve all aspects of the working
environment that result in a workforce that is happy, healthy and here. It recognises that, as a result of
progress in improving occupational safety, the major challenge for the UK in improving Occupational
Health and Safety (OHS) lies in improving occupational health. Issues of occupational health are less
amenable to regulation than occupational safety. CSR is therefore a potential valuable trend for the
HSC/E to promote OHS.
This study was commissioned in order to consider the current thinking within CSR with respect to OHS,
the views of the key CSR players on OHS in the CSR agenda and the actions that the HSC/E could
take to raise the profile of OHS in the CSR agenda.
This report and the work it describes were funded by the Health and Safety Executive (HSE). Its
contents, including any opinions and/or conclusions expressed, are those of the authors alone and do
not necessarily reflect HSE policy.

HSE BOOKS

 Crown copyright 2005

First published 2005
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or by e-mail to [email protected]

ii

PROMOTING HEALTH AND SAFETY AS A KEY GOAL OF THE

CORPORATE SOCIAL RESPONSIBILITY AGENDA

CONTENTS
1

Objectives & Methodology

1.1
1.2

The Relevance of CSR for Promoting OHS

2.1
2.2
2.3
2.4
2.5

Study Objectives
Methodology

The OHS Challenge

CSR: Beyond Regulation
Ways in which CSR can help promote OHS
Forces for Change
Key Trends and their Relevance

10

12

17

Attitudes Towards CSR and OHS

18

3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8

18

19

23

24

26

27

28

29

The HSC/Es Knowledge Base

The Attitudes of Businesses
CSR Organisations
SRI Organisations
Business Organisations
OHS Organisations
The Trade Unions
The Major Sources of Influence

The Proposed Strategy

30

4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9
4.10
4.11

30

30

32

34

35

35

37

37

38

39

39

The HSC/Es Role

The Proposed Strategy
Highlighting Reputational Issues
Making OHS material for business performance
Stakeholder Engagement
A possible framework for Evaluating OHS in relation to CSR
Measurement & Reporting
Benchmarking
Guidance
Recognising Innovation
Implications for HSC/E

List of References and bibliography

iii

40

iv

PROMOTING HEALTH AND SAFETY AS A KEY GOAL OF THE

CORPORATE SOCIAL RESPONSIBILITY AGENDA

EXECUTIVE SUMMARY
Corporate Social Responsibility (CSR) has many definitions but, in essence, it is
based on the integration of economic, social, ethical and environmental concerns in
business operations. The major social concerns include the welfare of the key
stakeholders in the business, especially employees. Thus, occupational safety and
health (OHS) forms an integral part of CSR and this is confirmed by its inclusion in all
the major measurement and reporting guidelines and tools developed for CSR. An
important aspect of CSR is that it requires business, alongside its profit maximising
function, to maximise its positive impact on society. It therefore requires that
business goes beyond compliance.
The Health and Safety Commission/Executive (HSC/E) is looking to business to
move beyond compliance with health and safety regulations to continuously improve
all aspects of the working environment that result in a workforce that is happy,
healthy and here. It recognises that, as a result of progress in improving
occupational safety, the major challenge for the UK in improving OHS lies in
improving occupational health. Issues of occupational health are less amenable to
regulation than occupational safety. CSR is therefore a potential valuable trend for
the HSC/E to promote OHS.
This study was commissioned in order to consider the current thinking within CSR
with respect to OHS, the views of the key CSR players on OHS in the CSR agenda
and the actions that the HSC/E could take to raise the profile of OHS in the CSR
agenda.
Study Findings
The study established that CSR is gaining in influence and, as the CSR movement
comes of age, it is becoming mainstreamed in the measurement and reporting of
business performance on which the financial services industry bases its investment
decisions. This places a burden on organisations such as HSC/E to demonstrate why
and how OHS is a material issue for the reputation of companies and for their
business performance.
O

O

Surveys carried out by the Association of British Insurers (ABI) and Business in
the Community (BITC) confirm that there is strong awareness of CSR issues,
especially environmental concerns, amongst large businesses and widespread
disclosure of performance on CSR issues, including OHS. However, disclosure
tails off rapidly as the size of business decreases. Disclosure is greatest amongst
businesses operating in industries where occupational safety is an issue,
particularly those whose activities affect the safety of the public. This reflects the
potential effect of OHS on the reputation of these businesses.
Amongst large businesses, disclosure is lowest amongst industries such as IT,
financial services and distribution where occupational safety is less of an issue
than occupational health. Occupational health is yet to become a significant issue

for the reputation of these businesses. It is these industries in which employment

is growing in the UK. The case for establishing OHS a material factor in business
performance is yet to be established for most types of large business, even for
industries that rely on human resources to drive performance and claim that their
employees are their biggest asset.
The Institute of Directors (IoD) has carried out an authoritative survey of the attitudes
of SMEs to CSR. Unlike their larger counterparts, it is social rather than
environmental concerns to which they give the greatest attention focussing on their
impacts on local communities. The biggest influence on these businesses is their
employees and customers. These businesses are influenced far less by CSR
organisations and the Socially Responsible Investment (SRI) movement as they are
less exposed to reputational risk and are less likely to be quoted companies. These
businesses are driven to adopt good practices for CSR by the material impact on
business performance. It is easier to see the material impact of the welfare of
employees on business performance in the extended family culture of these
businesses
O

In promoting OHS in the CSR agenda, the organisations with which the HSC/E
needs to work most closely are CSR organisations such as BITC, organisations
concerned with SRI such as the ABI, National Association of Pension Funds
(NAPF) and the UK Social Investment Forum (UKSIF), the safety organisations
such as the Royal Society for the Prevention of Accidents (RoSPA) and
Institution of Occupational Safety and Health (IOHS) and the business
organisations such as the Confederation of British Industry, the Federation of
Small Businesses and the IoD. The latter two are particularly important for
influencing small businesses. The trade unions, who not only represent the
interests of one of the main stakeholders in the business but also influence the
SRI industry as trustees of pension funds, are especially important partners for
HSC/E.

The Proposed Strategy

In support of HSCs Strategy for workplace health and safety in Great Britain to 2010
and beyond (published in 2004) HSE has developed a coherent and cohesive
programme of work comprising six strands. This study forms part of one of those
strands. What this study shows that CSR should not be regarded by HSC/E as a
separate vehicle for promoting OHS but as integral to its overall strategy. CSR is one
of many external and internal influences on a business and in providing the business
case for OHS it must show how it affects the range of factors. It must work also with
other influencers of business including the Department of Trade and Industry (DTI),
Department for Works and Pensions (DWP) and the London Stock Exchange.
For the CSR movement to give OHS greater prominence it must be viewed as a
material issue of reputational risk and business performance and/or an important
element in the interaction of the business with employees. Ideally three conditions
need to be fulfilled to enable this to happen:
O

HSC/E must demonstrate that OHS is a reputational risk issue for all types of
business. For the reputational risk to be material, it needs to be shown that
companies that fail to adequately address occupational safety and health are in
danger of losing public trust with a consequent loss of profit and shareholder
value. Public awareness is key to making OHS a material issue for reputational
risk. The focus here should be that whilst HSC/E raises public awareness,

especially of occupational health issues, HSEs Business Involvement Unit

translates the message into CSR language to engage with the CSR movement.
O

O

HSC/E must demonstrate to the CSR movement that the business case for OHS
is sufficient to be material to business performance overall. This is likely to
include the influence it has on customers as well as on costs. The aim should be
to bring together the diverse impacts that OHS has on business performance as
a whole so that OHS is seen to have a material impact on profits. Currently,
OHSs diverse impacts are considered individually and so the issue is not
considered material.
OHS must be given greater prominence by employees - and those who represent
them - in their interaction with employers. The trade union movement must be
persuaded to broaden its vision for OHS beyond compliance to embrace the
potential that engagement with employers on the CSR agenda holds for
promoting OHS. As trustees of pension funds the trades unions also have an
important and influential role to play in making SRI fund managers pay greater
attention to OHS as a criteria for their investment decisions. The unions
representing employees in industries where occupational health is the main
threat to OHS have a special role to play in this respect.

Once these conditions are in place, then the HSC/E can assist the CSR movement in
its role of influencing business effectively by extending the tools that it provides, such
as a framework for evaluating OHS in relation to CSR, tools to measure performance
and benchmark management practices, providing guidance on key risks and what
constitutes good practice and recognising innovation. HSEs Business Involvement
Unit needs to engage more closely with the rest of HSE to extend existing tools so
that they are better suited to influencing the CSR agenda.

1.
1.1

OBJECTIVES & METHODOLOGY

STUDY OBJECTIVES
In its strategy document Revitalising Health & Safety, the Health & Safety
Commission (HSC) set out action points aimed at promoting greater corporate
responsibility and accountability for health and safety. In 2001, in support of its
strategy, the HSC issued guidance on company directors responsibility for health
and safety. Since then, the Health and Safety Executive (HSE) has undertaken a
programme of work to develop the business case for occupational safety and health
(OHS) and to permit investors to measure the OHS practices and performance of
businesses. This approach has been strengthened with the HSC/E Strategy for
Workplace Health and Safety in Great Britain to 2010 and beyond1 published in
2004.
HSC/E have undertaken a number of measures and initiatives in support of
Revitalising Health and Safety, particularly action point 2 which deals with public
reporting of OHS performance and action point 11 on directors responsibilities. The
main focus of these measures and initiatives is to raise recognition among CEOs and
directors on the role that health and safety has to play in enhancing the reputation of
their business and in achieving a high performance team.2
In recognition of the potential offered by the trend towards greater corporate social
responsibility (CSR) for promoting greater responsibility at corporate level for OHS,
the Health and Safety Commission/Executive (HSC/E) also established contact with
the main organisations promoting CSR. The organisations cover socially responsible
investors (SRI), leading business representative organisations and trade unions that
were also CSR, aware. This document refers to these organisations collectively as
the CSR movement. Whilst dialogue with these organisations has helped ensure
that the CSR movement did not neglect OHS in its overall coverage, the HSC/E took
the view that more could be done to help move OHS up the CSR agenda within
companies.
HSE commissioned this study in order to strengthen the organisations knowledge of
how to engage with the CSR movement to promote health and safety as a key goal
of the CSR agenda. Specific objectives are:
Identify 10 key CSR players in the United Kingdom (UK) and explain their
position and influence;
Assess the receptiveness of these players to working with the HSC/E in
achieving its goal of greater corporate responsibility and accountability for OHS;
Identify the evidence that the HSC/E needs to provide to raise the profile of OHS
in the CSR agenda, drawing also on experience in other countries;
Develop the evidence and arguments into a coherent strategy for further
engagement with the CSR movement, and;
Assist in the development of guidance and publicity to take forward the proposed
strategy

O

O

O

O

O

www.hse.gov.uk/aboutus/hsc/strategy.htm
The aims of the block of work and the details of measures and activities are summarized in Corporate
Responsibility and Accountability for Occupational Health and Safety: A Progress Report on Initiatives and Measures
see HSC paper 03/105 - www.hse.gov.uk/aboutus/hsc/meetings/2003/141003/c105.pdf.

To address these objectives, the report on this study is organised as follows:

Section 2 examines the relevance of CSR in promoting responsibility and
accountability for OHS.
Section 3 - examines current attitudes amongst businesses and the CSR movement
towards CSR and OHS.
Section 4 - sets out the key channels of influence and the evidence that will be most
compelling in engaging with them to raise the profile of OHS. A proposed strategy for
HSC/E to raise the profile of OHS in the CSR agenda is then developed.
1.2

METHODOLOGY
This report is based on a combination of literature reviews, interviews with the staff of
HSE, interviews with organisations engaged in the CSR movement and with a small
number of businesses. We are grateful for the helpful support we have received from
the HSC/E and everyone we interviewed from the CSR movement. Whilst we hope
that the views expressed us are reflected in this report, particularly in Section 3, the
conclusion and recommendations reached are those of the team alone and may not
reflect those of the HSC/E.

2.

THE RELEVANCE OF CSR FOR PROMOTING OHS

This section addresses the further contribution that CSR could make to promoting
responsibility and accountability for OHS. It considers the nature of CSR and the
trends that are driving it, the extent to which CSR is making a difference to the way
businesses behave and considers the trends in CSR that could be harnessed by
HSC/E to promote OHS. It starts with considering the challenges facing HSC/E in
improving OHS before considering the relevance of CSR to promoting OHS.
2.1

THE OHS CHALLENGE

The UK is recognised internationally as a leader in the field of OHS. It has in place a
set of comprehensive laws encompassed in the Health and Safety at Work etc Act
19743, an effective regulatory regime enforced by the HSC/E and local authorities
and a generally supportive workforce and employers. The HSC/E recognises that
further progress in improving OHS, to ensure the desired outcome of a work force
that is happy, healthy and here,4 requires focusing beyond regulation for two
reasons:

In line with Government policy and a wish to minimise the regulatory burden upon
businesses, it wishes to use further legislation and regulation only if a voluntary
approach is found inadequate.
The challenges faced in further improving the UKs OHS performance are less
amenable to regulation.

As a result of progress in improving occupational safety, the focus for improving OHS
has shifted from occupational safety to occupational health5. Currently, of the
approximately 42 million working days lost through injury and ill health in the UK, 9
million are due to injury and 33 million through ill health. The issues involved in
improving occupational health are less amenable to regulation than those aimed at
improving safety at work. Of the 33 million days lost to ill health, 13 million are
estimated to be due to stress. The generation of stress, and the ability to cope with it,
are influenced not only by conditions at work but also the personal circumstances of
individuals. Given that personal stress is largely beyond the control of employers,
stress due to work should however be controlled in order to minimise any additional
stress burden on the employee.
Employers are already required to carry out risk assessments to identify and address
the potential causes of ill health and injury in the work place. This includes all
aspects of a businesss operational and management practices which may lead to
unnecessary stress. Any additional regulation may turn out to be difficult to enforce
given the fact that almost all occupations generate some level of competitive stress
and individuals are varied in their abilities to cope with it.
Other issues for further consideration in the future include musculo-skeletal
disorders, prolonged sickness absence after injury or ill health, binge drinking and
general absenteeism. The HSC/E has, therefore, been promoting awareness of

3
4
5

The Health and Safety at Work etc Act, 1974. www.hmso.gov.uk

Revitalising Health & Safety, HSC, 2000. www.hse.gov.uk
Supra at 1.

these health issues, providing guidance on best practice for prevention and
mitigation6and support for the return to work.
HSC/Es agenda of promoting responsibility and accountability for OHS, beyond
regulation, has much in common with the CSR movement. As discussed in the
following section, CSR focuses on the social and environmental impacts of business
beyond regulation.
2.2

CSR: BEYOND REGULATION

The essence of the term Corporate Social Responsibility is the integration of
economic, social, ethical and environmental concerns in business operations,
including dealings with stakeholders7. CSR is based on the understanding that the
impact of business on society is far wider than the established, more limited view that
it is simply about the creation of wealth for shareholders. The definition also
encompasses impacts on a wider group of stakeholders in the business - especially
employees and local communities - as well as economic, social and environmental
outcomes in society as a whole. Dealing with the concerns and interests of all
stakeholders is therefore a cornerstone of CSR.
Perhaps because of its wide-ranging coverage, there is no universally accepted
definition of CSR. For some, the term is essentially about sustainable development
with respect to the environment - the careful use of resources by the current
generation so as not to prejudice the rights and quality of life of future generations.
For others, the term has become synonymous with attempts to reduce the
exploitation by major multinationals of the poor in the developing countries through
globalisation. In the United States of America (USA), the term used is Corporate
Responsibility and, after recent major corporate collapses such as Enron, the focus
is turning to Corporate Governance.
The CSR movement recognises that, in modern polities, it is the tri-partite
relationship between government, business and civil society that is responsible for
economic, social and environmental outcomes. In this relationship, business has
become more powerful with respect to its command over resources8 and equally,
more responsible and accountable for societal outcomes. Because it is responsible
and accountable for societal outcomes, business is vulnerable to a loss of trust
amongst its wider stakeholders. A loss of trust may result in consumer boycotts, as
happened with Shell in Germany over the Brent Spar, in a loss of shareholder value
as happened with Railtrack or the ultimate sanction - the end of the business - as
happened with Union Carbide after the Bhopal disaster.
The underpinning of the CSR concept is however that the interests of business and
those of society are not irreconcilable and can be pursued together. As the UK
Chancellor of the Exchequer recently said Corporate responsibility is a belief that
the economic, social and environmental objectives can be pursued together and in
harmony, and in particular that corporate self interest and corporate responsibility are
not irreconcilable opposites but can move forward in unison. It is a recognition that
when business loses trust it is at its most vulnerable 9.

6
7

8
9

Securing Health Together, HSC. www.hse.gov.uk/press/2003/e03232.htm

For a discussion of the definition of CSR see, for instance, Corporate Social Responsibility, IoD Member
Opinion Survey, Ruth Lea, especially Annex 3. IoD 2003.
As frequently pointed out, the 50 most powerful economic entities in the world include ten corporations.
Counting on Responsibility, Louise Armitstead, Sunday Times, March 14, 2004.

For responsible businesses and the CSR movement, CSR starts beyond regulation:
adherence to the law and regulatory regime is considered mandatory for all
businesses, irrespective of whether they have embraced the principles of CSR. This
is why the leading CSR organisation in the UK, Business in the Community (BITC),
defines CSR as a companys positive impact on society and the environment,
through its operations, products or services and through its interaction with key
stakeholders such as employees, customers, investors, suppliers and
communities.10
The CSR movement is not without its critics. Reputable Non Governmental
Organisations (NGOs)11 have recently argued that much of the CSR activities of the
business community are no more than the interests of those business and their
periodic philanthropy, dressed up by their public affairs advisors in glossy CSR
reports as new concepts. As Richard Breeden observed in his report on corporate
governance failures at WorldCom It is worth noting that persons engaged in
wrongdoing may indulge in frequent prayer and expressions of dedication to integrity,
all without meaning.12 Trust in business has fallen as a result of corporate major
collapses such as Enron and Ahold. Almost two thirds of British adults do not trust
business leaders13 and 80% do not trust directors of large companies to tell the truth.
Over 60% of the British public believe that big business does not care about its social
and environmental impacts.
In recognition of these developments and the growing sophistication of the
movement itself, the following trends have emerged in CSR:
O

O

10

11
12

13
14

15
16

Led by initiatives such as the United Nations (UN)-backed Global Reporting

Initiative (GRI), new guidelines are being developed on measuring and reporting
wider societal impacts of business. A recent book14 describes over 30 new
international codes of conduct that form the basis of initiatives on measuring and
reporting CSR impacts. BITC and other national organisations have also
introduced measurement and reporting guidelines. By better specifying what
should be measured and reported, it is hoped that the selective nature of what
business chooses to report may be replaced by comparable indicators that reflect
their actual impact on society and the environment;
An emphasis on integrating CSR within the operations of a business rather than
as a stand alone add-on. As George Cox, then Director General of the Institute
of Directors (IoD), stated in 2003 CSR is something that needs to permeate
every decision, whether this concerns the workforce, products, markets, quality or
operations. It is a way of thinking and behaving, not a separate programme or
campaign Good business is good business .15 More recently in 2003, the
Government Minister with responsibility at that time for CSR, Stephen Timms
said16 What we are talking about is beyond philanthropy. CSR is not an addon. It must be the way we do business at home and overseas. CSR evaluation is
therefore concerned with the extent that CSR is integrated into business policies
and management systems;
See, The What, Why, How of CSR: A beginner's guide to corporate social responsibility
http://www.bitc.org.uk/resources/toolkit/index.html www.bitc.org.uk
See for instance Action Aid www.actionaid.org.uk
Restoring Trust, Richard Breeden Available on:
http://news.findlaw.com/hdocs/docs/worldcom/corpgov82603rpt.pdf
MORI Trust Monitor 2003. www.mori.com
The Corporate Responsibility Code Book, Deborah Leipziger, 2003.
http://www.duurzaam-ondernemen.nl/greenleaf/codebook.htm
Foreword to IoD Member Opinion Survey, IoD 2003.
Speech at Commonwealth Business Council Conference, 2 July 2003.

O

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New tools for measuring the CSR performance of businesses such as BITCs
Corporate Responsibility Index17 that aim to address all aspects of the impact of
business on society and allow comparison of performance across sectors. There
are also numerous sector specific indices of performance. These tools focus on
measuring policies, practices and performance and allow comparisons over time.
They are concerned with policy and processes as well as actual performance;
In SRI, a trend away from the practice of excluding businesses on the basis of
the sector in which they operate (defence, alcohol, tobacco) and grading them
through dark green or light green environmental filters, towards their policies and
impacts. This has been accompanied by a move away from reliance on indices
such as Financial Times Stock Exchange series for socially responsible
investment (FTSE 4 Good)18 or the Dow Jones Sustainability Index (DJSI)19
towards engagement between analysts and companies, with the analyst relying
for information on the business and independent sources of information such as
the Ethical Investment Research and Information Service (EIRIS)20. The indices
are still referred to, but as a source of information and evaluation rather than the
principal basis for the investment decision, and;
SRI is being mainstreamed. As a result of an amendment to the Pensions Act
that came into force in 2000, trustees of pension funds are required, in their
Annual Statement of Investment Principles, to state the extent to which social,
ethical and environmental (SEE) issues are taken account of in investment
decisions. Research shows that over 90 billion - representing a quarter of the
sectors holding - is now subject to some form of socially responsible investment
policy21. Whilst the sum held in dedicated ethical funds remains small, the main
SRI houses are incorporating engagement on governance and SEE issues into
their mainstream funds. It is estimated that some 200 billion worth of assets is
subject to such engagement22.

The net result of all these trends is that the CSR movement increasingly considers
responsible businesses to be those who strive to improve practices and performance
on economic, social, ethical and environmental issues on a continuous basis. This
they do by integrating their approach to these concerns with their quest for creating
value for shareholders. In fact, the effective management of these issues is
considered an essential part of the process of creating shareholder value. If a
business loses societys trust - irrespective of whether the result directly impacts the
bottom line - the result will be lower shareholder value in the longer term. This
stance is given concrete expression in the Combined Code that specifies that it is a
duty of care on boards of directors to identify and manage sources of reputational
risk.
The spotlighting of reputational risk by the Turnbull Committee that produced the
Combined Code has helped to mainstream CSR. The UK Government is introducing
a mandatory requirement for an expanded operating and financial review (OFR) in
the annual reports of the UKs 1000 largest companies. In the words of the Secretary
of State for Trade and Industry, Patricia Hewitt, the intention of the expanded review
17
18
19
20
21
22

www.bitc.org.uk
www.ftse.com
www.sustainability-indexes.com
www.eiris.org
Socially Responsible Investment Amongst European Institutional Investors, EuroSif, 2003.
SRI: A Global Revolution, Russell Sparkes, 2002.

is so our largest businesses report fairly and transparently on the factors which
affect them, including their impact on the environment and society where relevant.
The OFR is intended to allow readers of company reports to assess the companys
strategy and performance prospects on conventional financial measures as well as
on CSR issues.
It is left to directors of businesses to judge which issues are sufficiently material to be
included in the OFR. The White Paper advises that directors consider whether to
include anything that might affect the companys reputation, as well as policies and
performance on issues such as employment, the environment, social and community
issues. Guidance on what is material is provided by the Working Group on
Materiality23 which states, The key question in deciding whether or not an item is
material should be: Does this item matter to the members (shareholders) either
directly or indirectly as a result of its significance to other stakeholders, and thus to
the company? . From this, it may be concluded that any issue that may have a
significant direct impact on a companys financial performance, on its reputation and
its interaction with other stakeholders should be considered material.
What the above review of CSR shows is that it is concerned with issues beyond
regulation. CSR is being driven by the public increasingly holding business
responsible and accountable for societal outcomes. This is manifested in new tools
to measure and rank CSR performance and the growing importance given to social,
ethical and environmental issues by the financial sector, SRI and mainstream. A loss
of public trust in a company may have dire consequences. Furthermore, as the
movement matures and becomes more of a mainstream issue, it will increasingly
focus on objective measurement and reporting of CSR issues, focusing on material
risks to its reputation and its relationship with a wider group of stakeholders.
2.3

WAYS IN WHICH CSR CAN HELP PROMOTE OHS

In considering the impact of business on wider stakeholders, employees are amongst
the first stakeholders considered by the CSR movement. This is the main reason why
all of the major reporting guidelines and declarations of CSR principles include
employee relations. International codes of conduct such as the UN Global Compact
and the Organisation for Economic Co-operation and Development (OECD)
Guidelines for Multinationals include the treatment of employees, and the GRI has a
section covering the treatment of employees under social impacts. The major UK
CSR organisations such as BITC include aspects such as treating employees fairly,
equitably and with respect as a leading principle of CSR.
OHS is mentioned explicitly by most codes of conduct, statements of principles and
associated measurement and reporting guidelines. The UN Global Compact, OECD
Guidelines and the GRI mention OHS explicitly. In the UK, the BITC Corporate
Responsibility Index and the Forge Guidelines developed by the financial sector to
help companies report on their industry specific environmental and social issues
include OHS under the workplace - one of four key impact areas. Increasing
recognition is also being given to the work - life balance, an issue linked closely to
stress. The place of OHS in the BITCs Corporate Responsibility Index - the most
widely recognised tool for measuring a companys CSR performance - is shown in
figure 1 below. Under the Workplace management area, the two major sub categories are working environment, including OHS and employee rights which
covers issues of workplace diversity and equality.

23

The Operating and Financial Review Working Group on Materiality, DTI consultation document

10

Figure 1:

Business in the Community Corporate Responsibility Index

Corporate
Strategy

Integration

Management

Performance &
impact

Community

Environment

Marketplace

Workplace

The fact that companies are being guided to measure and report on OHS issues
provides an obvious and important entry point for the HSC/E to use the CSR
movement to promote OHS. This move is further strengthened by the HSEs actions
to improve the public reporting of OHS records and recording systems by all
businesses. Evidence suggests that if companies start to measure and report on an
issue it becomes easier to hold them to account for performance, provided that
measurement and reporting are accurate and transparent. In addition, measurement
and reporting tend to lead to a process whereby companies strive to improve
performance as part of the normal process of setting stretch targets for operational
and financial performance indicators.
Of course, what matters for the HSC/E is that companies measure and report against
the right indicators. This is explored in the next section as part of Attitudes Towards
CSR and OHS. What is important to note at this point is that the guidance available
on what should be measured and reported against is currently not specific to sectors.
For instance, the GRI is only now considering providing sector specific guidelines.
Moreover, it is not based on a sound understanding of what matters for OHS. In the
UK for example, only a few businesses and CSR organisations are aware that the
major cause of time off work is occupational health and not safety. The HSC/E can
do much to improve the understanding of OHS issues health issues in particular and thus promote measurement and reporting that will lead to improved OHS.
For companies to have an incentive to measure, report and ultimately improve
performance, what counts most is that this issue is considered important (material)
enough to affect a companys reputation, interaction with wider stakeholders and
financial performance. In turn, this means that OHS issues should receive
prominence in codes of conduct and a stronger presence in tools that are designed
to assess CSR performance.
There is however evidence to suggest that OHS may not receive the importance it
deserves in codes of conduct and sufficient weight in CSR assessments. For
companies in higher risk industries, particularly those that are likely to threaten public
safety or cause large - scale loss of life amongst employees, such as the chemical
processing sector, the CSR organisations and SRI industry do pay particular
attention to OHS issues. But for some other companies, OHS is considered a

11

relatively unimportant attribute for a socially responsible business necessary, but

not an indicator of commitment. Furthermore, there is a lack of appreciation that
issues such as stress may blight lives just as much as physical injury and that
employers may be as culpable in failing to address stress in the working environment
as they would be in failing to address injury.
There is an opportunity for the HSC/E to raise the status of OHS in what is measured
and reported as CSR impacts. This will entail raising awareness of occupational
health issues, showing how they apply to particular sectors. It will also involve
demonstrating that a failure to address such issues is likely to have a material impact
on the companys reputation, interaction with stakeholders and financial
performance.
2.4

FORCES FOR CHANGE

The review of CSR trends shows that CSR issues such as OHS cannot be viewed in
isolation. They are affected by - and in turn affect - other forces for change that drive
business attitudes and behaviour. For businesses to take such issues more seriously
they must be seen to be material either to their financial performance, reputation or
interaction with wider stakeholders. The issues are more likely to be seen as material
if they reinforce other forces for change. It is important therefore to set OHS in the
context of the other factors that may affect a companys behaviour with respect to
working conditions and the management of its workforce. Figure 2 shows the main
external and internal forces that need to be considered alongside OHS.

12

EXTERNAL
EXTERNAL INVESTORS
Materiality
Reputation
CSR
Beyond regulation
Reporting trends
Engagement

LABOUR MARKETS
Skill Gaps
Attitudes
BUSINESS
ORGANISATIONS
Business performance
Reputational risk
CSR

PUBLIC OPINION
Awareness
Accountability

HEALTH & SAFETY

ORGANISATIONS
Awareness
Promotion

REGULATION
Statutes
Guidance

BUSINESS
COST OF IMPROVED
OSH
Treatment
Effort

CORPORATE VALUES
Ways of doing business

REPUTATION & BRAND

IMAGE
Intangibles
Positioning

INSURANCE COST
ELCI
Medical

PRODUCTIVITY
QUALITY
Qualitative
Quantitative

INTERNAL
SHAREHOLDERS
Business valuation

EMPLOYEES
Working conditions

EMPLOYMENT COSTS
Recruitment
Retention

INTERNAL

Figure 2:

2.4.1

Occupational Safety & Health The Forces for Change

External Factors
Regulatory pressures that help improve OHS need not come entirely from the
HSC/E. An amendment of the Pensions Act that required trustees to disclose the
extent to which SEE issues influence investment decisions is an example of how
other regulations influence CSR, including OHS. It is therefore important for the
HSC/E to influence the institutions that are responsible for formulating such
regulations. The OFR is an obvious candidate. The clearer the guidance that the
Department of Trade and Industry (DTI) provides in terms of what the OFR should
contain with respect to OHS issues, the greater will be its impact in promoting OHS.
The Department of Work and Pensions (DWP) and the DTI are clearly important
institutions for the HSC/E to engage with. Other candidates include the Stock
Exchange that issues guidance to directors - such as the Combined Code - and sets
disclosure requirements.
Pressure to improve CSR and OHS performance may arise also from the market
place, through consumers and their representative groups demanding better
performance and competitors setting higher standards. It may be useful, therefore,
for the HSC/E to ensure that there is sufficient consumer awareness of OHS. This

13

will ensure that the proportion of consumers for whom OHS is an important issue and who are sufficiently motivated to use their purchasing power in support of it - are
informed of the issue and know what to look for in good and bad performers.
Greater consumer awareness could also promote greater dissemination of good
practice so that companies become aware of what the leaders in the field are doing
and so respond more quickly to competition. As discussed further in Section 4, the
HSC/E need not name or shame. But it should continue to inform and educate. Any
suggestion that a company may be disadvantaged in the market place as a result of
its OHS performance will serve to make it a material issue24.
The external forces arising from the CSR movement and SRI concerns of investors
are the subject of the next section. At this point, what is important to note is the
distinctions between the various organisations that comprise the CSR movement on
the ways in which they exert influence on businesses. CSR organisations, whether
concerned with measurement and reporting or assessing performance, essentially
target the corporate values of businesses, backing the business case for CSR with
the implied threat to their reputations. The role of CSR organisations is primarily
advocacy, though most also provide direct advice to their members. If convinced
further of the importance of OHS, they are likely to have more freedom than the
HSC/E in advocating that addressing the issue should be incorporated in codes of
conduct and regulations - and to name and shame the worst offenders. They can
therefore supplement the HSC/Es own capability which is restricted by its regulatory
functions and by its own policy of resorting to regulation as a final resort.
The CSR units of business organisations such as the Confederation of British
Industry (CBI), IoD, Engineering Employers Federation (EEF), Federation of Small
Businesses (FSB) etc. play a different role. Although they are concerned with CSR
issues and performance their primary role is to assist their members. They focus on
providing the business case for CSR, guidance on CSR issues, in minimising red
tape and in ensuring that the CSR movement remains pro business. They are
therefore good channels for raising awareness of issues and conveying guidance to
businesses. In many cases these organisations cover components of CSR (such as
employee relations, legal issues, etc.) separately and have yet to fully engage with
the combination of these factors that are represented in CSR.
The SRI industry essentially influences business through engagement. As noted
earlier, despite their strong growth, the sums invested in socially responsible funds
do not represent a sufficiently high proportion of total portfolio investment to affect
share prices. The bigger impact is through the integration of CSR concerns in the
investment decisions of mainstream pension funds and the portfolios of the SRI
houses. Even so, it is difficult to attribute movements in share price to CSR
performance or SRI ratings as the main determinants of share price movements
remains the ability to create shareholder value. Further, the trend in SRI is to move
away from negative screening on the basis of sectors of activity towards an
assessment of how far businesses have identified the main reputational risks and
taken steps to mange them. This requires access to information, especially direct
engagement with the business by an SRI analyst. This finding is confirmed by
discussions with the UK Social Investment Forum (UKSIF), the main member
organisation of the SRI industry. It is important to place on record that the help and
advice that UKSIF has given HSC/E to open a dialogue and engage effectively with
those active in SRI has been invaluable.

24

In their analysis of ethical purchasing the New Economics Foundation and the Co-operative

Bank found that 52% of consumers had boycotted a product or service for ethical reasons.

14

The HSC/E can help the SRI industry to ask pertinent questions during their
engagement process with businesses and thus affect their behaviour. It is the case
that the SRI industrys reach in theory extends only as far as companies quoted on
the Stock Exchange. In practice the industry focuses only on the Financial Times
Stock Exchange index of the top 100 companies the FTSE100. However, as these
businesses are the largest traders, the influence of the large on the medium and
smaller companies through their supply chains means that the influence of the SRI
industry spreads well beyond their target group and the Stock Exchange.
Labour markets also influence companies behaviour towards their employees. In a
recent survey25, approximately 20% of employees were reported to find employers
with a positive, socially responsible image more attractive. Whilst remuneration
always plays a major role in the choice of an employer, the study found a good fit
between the preferred choice of company to work for and the employees view on
whether the business took social responsibility seriously. With the numbers of young
people (25-35) in the UKs workforce likely to decrease by 1.3 million by 2010, trends
in the labour market are likely to favour companies with a good CSR reputation.
HSC/E can help to ensure that the image of companies as both employers and the
extent to which they take CSR seriously takes account of OHS performance.
Targeting entrants to the workforce and making them aware of what to look for in an
employer would help to increase pressure on companies to perform well on OHS
indicators.
The labour movement primarily through trades unions - is a major influence on
CSR and OHS. As trustees of pension funds it influences a major flow of investment
to companies. The movement also directly influences the labour market and brings
pressure to bear externally on employers to improve working conditions and
employee rights and benefits. It is also an internal source of pressure for change. As
a result, the labour movement must be viewed by HSC/E as an important partner in
moving OHS further up the CSR agenda in businesses.
The focus of the press and communications media on public opinion means that they
affect the views of consumers as well as the whole CSR movement. Engagement
with the press and other communications media is therefore an important tool for
moving OHS up the CSR and business agendas. It is particularly important for the
HSC/E to raise awareness of OHS issues amongst civil society organisations. There
is a strong possibility that civil society organisations such as health charities and
religious groups often themselves major investors - would identify with the need for
greater control of social and health issues such as binge drinking after work and
violence in the family. It is likely that they would strongly support campaigns for a
better work - life balance and reducing stress in the work place.
2.4.2

Internal Factors
Internal factors tend to focus on costs and benefits but there is sufficient evidence to
suggest that for many businesses, corporate values take precedence over bottom
line impacts. Evidence for this was provided26, along with other studies, by the 19
case studies that were recently prepared for the HSC/E to provide the business case
for OHS. When the consultants preparing the case studies asked for information to
carry out cost/benefit analyses, many companies responded by asking why it was
necessary to demonstrate in financial terms something they considered to be so
25
26

The Ethical Employee. Work Foundation and Future Foundation, www.theworkfoundation.com

HSE, The business benefits of health and safety (2004), www.hse.gov.uk/businessbenefits/casestudy.htm

15

obviously worthwhile. Appealing beyond financial returns to the corporate values of

companies should therefore not be ignored. After all, it is corporate values that the
CSR movement most strongly aims to influence.
There have been some notable attempts to measure the benefit of improved health
and safety on the operational and financial performance of businesses. For example,
the HSC/E case studies concentrated on returns to the investment in improving OHS.
The European Agency for Safety and Health at Work carried out a more extensive
study of ways in which improved OHS practices impact the cost of employment and
productivity. Whilst some impacts such as the benefits of reduced time off work are
relatively easy to quantify, there are problems of attribution and quantification of
other impacts such as employee quality and success rates for employee recruitment
and retention,27 higher productivity and quality of outputs.
The study did however show a positive relationship between OHS and reduced costs
of employment, higher productivity and quality. From first principles it should be easy
to argue that a safe and healthy work place should lead to easier recruitment and
retention of employees, lower absenteeism, and a more productive work force
committed to higher quality. What is difficult to prove is that the sole cause of
differences in performance are due to OHS and not wider employment policies and
practices carried out under a CSR exercise. This should not however detract from
the strong argument that OHS has a material impact on business performance. In
fact, the case should be made that good employment practices, including OHS, lead
to better overall business performance.
Difficult though the area is, there is mounting evidence in support of this argument.
The study People to Profits28 showed that at the United States (US) retailing group
Sears, the attitude of line management and company culture (values), translated into
employee commitment, led to lower staff absence and higher customer satisfaction
and sales. That study also found that retaining customers is less expensive than
finding new ones, making employee commitment the most cost-effective way of
generating sales. Additional evidence is provided by the Work Foundation which, on
the basis of interviews with 1000 Chief Executive Officers (CEOs), developed a high
performance index to explain differences in productivity. It found that the main
determinants of high performance were five overlapping areas:
Customers and markets
Shareholders and governance
Stakeholders
Human Resources (HR) Practices
Creativity and innovation

O
O
O
O
O

OHS issues are covered by HR practices and stakeholders. British Telecom (BT)
found recently that reputation and image - 25% of which is derived from CSR
activities - influences customer satisfaction alongside conventional attributes such as
29
the experience and value for money derived from products and services .
Lastly, there is evidence to suggest that companies which embrace CSR and make it
part of their business strategy outperform those that do not. The study Does

27
28
29

Workers Safety and Health, Productivity and Quality. European Agency for Safety and Health at Work.
People to Profits, Institute of Employment Studies, 1999.
Enlightened Values, BT 2002. www.btplc.com

16

Business Ethics Pay30 found a correlation between shareholder value and adopting
a code of ethics. The forthcoming Workplace Trends Survey 2004, carried out by the
Work Foundation, is going to report strong correlation between CSR activity and
stronger growth in sales and market share, particularly in business services and the
service sector as a whole31. The HSC/E can add to this evidence, by using the
argument that no business can be seriously considered as engaging in CSR
activities if it has not seriously addressed OHS.
Evidence which shows that good employment practices and CSR activities lead to
better bottom line performance may be useful for raising awareness of the potential
impacts of OHS amongst businesses. It helps to show the materiality of the issue
and to create a drive for higher performance amongst business through the
promotion and adoption of better OHS practices.
2.5

KEY TRENDS AND THEIR RELEVANCE

The review of the relevance of CSR to the promotion of OHS shows that in many
ways CSR is potentially a very useful vehicle for the promotion of OHS. Its focus on
social outcomes - particularly impacts on employees who form an important category
of stakeholder - should place OHS at the centre of CSR. This is reflected in the fact
that most reporting guidelines, codes of conduct and tools for measuring CSR
performance take note of OHS issues. The fact that CSR is essentially concerned
with performance beyond regulation makes it particularly appropriate for delivering
improved OHS in line with HSC/Es policy of using regulation only when voluntary
measures do not succeed.
The CSR movement is coming of age and increasingly CSR is being mainstreamed
to form part of business performance measurement and reporting. More crucially for
the financial success of businesses, it is becoming an important basis on which
investment decisions are being taken by the financial services industry. The
mainstreaming of CSR, however, means that there is a need to show the materiality
of issues if they are to be taken seriously by businesses and their investors.
There is some evidence to suggest that, except in some industries that threaten large
loss of life or public safety, OHS and in particular health - may not be given the
prominence it deserves. To raise the profile of OHS in the CSR agenda it will
therefore be important to demonstrate links with other forces of change that drive
businesses to improve working conditions and employment practices. This will help
make OHS material to business and set out the case for integrating the issue in
pursuit of higher business performance. There is a growing body of evidence that the
HSC/E may utilise to show how CSR and OHS impact on business performance. It
should be possible for the HSC/E to argue strongly that good OHS performance and
practices are at the heart of any corporate CSR agenda.

30

31

Does Business Ethics Pay Ethics and Financial Performance. Institute of Business Ethics, 2003.
www.ibe.org.uk
Reported in Achieving Higher Performance- CSR at the heart of business, the Virtuous Circle and the Work
Foundation, March 2004. Stephen Bevan, Nick Isles, Peter Emery & Tony Hoskins,
www.theworkfoundation.com

17

3.

ATTITUDES TOWARDS CSR AND OHS

The previous section concluded that CSR has the potential to serve as a useful
vehicle for promoting OHS. This section considers the attitudes towards CSR and
OHS on the part of business, the CSR movement and other stakeholders, notably
the trades unions. Its aim is to identify the importance that these players place on
OHS as an element of CSR and as material to business performance. The section
analyses the types of evidence that would persuade the organisations to give greater
attention to OHS within the CSR agenda and their willingness to engage with the
HSC/E in promoting OHS.
3.1

THE HSC/ES KNOWLEDGE BASE

The HSC/E has carried out research on the extent to which its Guidance on
Directors Responsibilities for Health and Safety32 has been implemented, comparing
the situation in 2001 and 2003. The research report33 showed a marked
improvement, with 66% of those surveyed reporting that health and safety had board
level direction - up from 58% in 2001. Among the top 350 companies, 70% had such
arrangements with 90% having a board level person responsible for health and
safety. The figures were lower for public bodies and the voluntary sector.
The HSC/E has also carried out research on the extent to which its Guidance on
Health and Safety in Annual Reports has been taken up. HSE research report 134
shows that over 78% of those surveyed (companies and public bodies) now report on
health and safety, up substantially from 47% in 200034. However, the incidence of
reporting varied considerably between sectors. In sectors such as chemicals,
petroleum, construction, pharmaceuticals and utilities - where safety is a major
concern - reporting incidence is high and the quality of reporting is good. In others,
where safety is not a major concern - notably finance and Information Technology
(IT) - both incidence and quality of reporting is low. These service industries, where
safety is not a major concern, dominate employment and employment growth in the
UK. According to the Office for National Statistics, the financial and business service
industries, for instance, employed 20% of the male and 19% of the female work force
of the UK in 2003.35
The HSC/E has an on-going dialogue on health and safety issues with directors of
the UKs top companies. A general willingness of the companies to engage in an
extended dialogue and their receptivity to increasing the importance given to OHS
issues has been noted from the feedback from meetings.

32

33

34

35

Directors responsibilities for health and safety. HSC guidance (INDG343) published in 2001. See
www.hse.gov.uk/pubns/indg343faq.htm
Health and safety responsibilities of company directors and management board members. HSE Research
Report 135 published in 2003. See www.hse.gov.uk/research/rrhtm/rr135.htm
The provision of health and safety information in the annual reports, websites and other publicly available
documents produced by the UK's top companies and a sample of government departments, agencies, local
authorities and NHS trusts. HSE Research Report 134 published in 2003.
See www.http//hse.gov.uk/research/rrpdf/rr134.pdf
Social Trends: Short term Turnover and Employment Survey, ONS, 2003.

18

3.2

THE ATTITUDES OF BUSINESSES

3.2.1

Attitudes to CSR
HSC/Es findings with respect to reporting on health and safety issues reflect trends
in reporting on CSR issues as a whole. The Association of British Insurers (ABI)
recently surveyed the extent to which companies listed on the stock exchange were
reporting on SEE risks, following the release of its disclosure guidelines in 2001. The
results were as follows:
SEE Disclosure for Year-Ends During 2003
% of companies
FTSE 100
FTSE 250
FTSE All-share
Full Disclosure
23
2
6
Moderate Disclosure
57
46
35
Limited Disclosure
20
41
41
No Disclosure
0
11
18
Source: ABI, Risks, Returns and Responsibility, Feb 2004
Among the largest companies, disclosure is universal and - based on the ABI
guidelines - 80% achieved moderate or full disclosure. But the extent of reporting
tails off rapidly after that. More than half the FTSE 250 did not achieve moderate
disclosure and amongst the All-share one in six failed to disclose any information on
SEE issues.
The ABI also noted sectoral variances in disclosure with the extractive industries and
the utilities achieving the highest levels. Only 8% and 9% of distributors and IT
companies respectively made modest levels of disclosure. Failure to achieve even
moderate levels of disclosure stem primarily from a view that SEE risks are not
considered material for the business. Businesses do not sufficiently believe that the
reputation of the company depends upon its wider social and environmental impacts.
Some may also fail to recognise that issues such as working conditions and
employee management are in fact CSR issues, part of the process of the interaction
with stakeholders and, as such, convey information of value to investors. The main
cause of failure to report adequately is the considered lack of relevance rather than
lack of knowledge.
According to the ABI the overall level of disclosure is increasing. This reflects the
growing acceptance amongst CEOs that such disclosure is part of the process of
restoring or maintaining trust in business. Apart from the largest, there is still
however some way to go for even quoted companies let alone the vast majority
businesses in the UK. It must be borne in mind that 95% of UK businesses are micro
enterprises employing less than 10 employees, although companies employing over
250 employees account for over 40% of employment in the UK. Progress amongst
the FTSE All-share is therefore likely to mean increased sensitivity to CSR issues
amongst the employers of the majority of the UKs workforce.
The majority of IoD members are directors of smaller businesses. The Institute
carried out a survey of its members in 2002 to assess the extent to which their
companies discuss and report on CSR issues, which CSR issues are highest on their
corporate agenda and which bodies influence them most on CSR issues.36
The results follow a pattern that large and medium sized companies are more likely
to discuss within the board and report on CSR issues than small and micro firms do.
36

Corporate Social Responsibility: IoD Member Opinion Survey, Ruth Lea, IoD, 2002.

19

Interestingly, the survey also showed that over 40% of companies employing up to
20 discussed social issues occasionally or regularly within their board. This figure
shows that CSR is on the agenda, perhaps in a component form, of a significant
proportion of SMEs. The survey also confirms the pattern that industrial companies
are more likely to be concerned with CSR than service sector ones. It also provides
evidence to support the view held by many in the CSR movement that environmental
concerns tend to be discussed and reported amongst a higher proportion of
businesses than are social issues.
The IoD survey is also noteworthy in that it directly asked directors whether they
were concerned with the CSR performance of companies that were either their
suppliers or customers. The results show that CSR performance of suppliers and
customers were of concern, with the treatment of employees and environmental
impacts the most important aspects. This is of relevance to the HSC/E, as providing
guidance on how to evaluate the OHS performance of other companies could form a
useful way of raising the profile of OHS in the CSR agenda.
3.2.2

Attitudes towards OHS

Whilst separate surveys exist on company attitudes towards CSR and OHS, few link
the two together. It is therefore interesting to note that the results of a survey
undertaken by BITC for the Sunday Times published in March 200437 showed some
useful data on the subject. The survey covers the top 100 highest scoring companies
that have voluntarily used the BITC self-assessment index, from 139 respondents.
The assessment invites respondents to detail the impact areas that they have
selected to improve their CSR; these range from community investment to human
rights in the supply chain and reducing water consumption. Of the 100 companies
detailed, 70 show occupational safety and health as one of their (on average) 4 key
areas. It is interesting to note such a high level of recognition given to OHS among
the more social and community based priorities.
For larger businesses, the overriding driver of what is considered material in CSR
activities are issues that are a threat to reputational risk. These are therefore given
the highest priority. OHS is usually only considered an important CSR issue in
industries where injury to employees may be sufficiently serious to threaten the
reputation of the business as an employer or product/service provider. Reporting
focuses on reporting under the Reporting of Injuries, Diseases and Dangerous
Occurrences Regulations 1985 (RIDDOR). BITC and the SRI industry confirm that
reporting is focused on safety returns.
Almost all CSR reports and the majority of annual reports that address CSR issues
contain a statement to the effect that employees are the companys biggest asset.
The issues surrounding these statements, such as what motivates and enables
employees to raise productivity and follow better OHS practices are in general not
discussed further in order to substantiate these claims. In service businesses where
customer interface is crucial there is little analysis of occupational health issues,
rates of absenteeism or appropriate work - life balance of employees. Only a few
service companies have given employee welfare the importance it deserves as a
CSR and business performance issue.
This is not to say that larger businesses, including those in the service sector, do not
in general undertake activities that improve employee welfare. As the business
37

Companies that Count BITC/DTI/Sunday Times survey, published 14 March 2004,

www.bitc.org.uk/programme/keyinitiatives/corporateresponsibility-index

20

benefit case studies produced on behalf of HSC/E prove, there are numerous
examples of companies that invest in OHS. What appears to be missing is a
recognition that such investment is a material issue that contributes to business
performance and lessens reputational risk and needs to be seen as a strategic,
rather than an operational issue. This is a challenge to which the HSC/E needs to
respond.
The evidence that offers the greatest potential to do so is:
O

O

O

O

Identifying further the types of work conditions and employment practices that
lead to poor OHS adoption and recognition. This should help to raise awareness
that businesses may, wittingly or unwittingly, contribute to poor health and safety
of their employees with the potential of it becoming a reputational risk issue.
Study material would also enable larger businesses to better evaluate the OHS
practices of their SME suppliers and customers and so bring to bear pressure on
smaller companies to improve their OHS performance;
Publishing industry specific benchmarks for time off work caused through stress
and muscular-skeletal disorders and related causes so that businesses and their
stakeholders can assess how far they vary from the average and the leaders.
This information should allow stakeholders and potential investors to assess in
material terms how poor or how good the business performance is by quantifying
variations in recruitment and retention costs, comparative productivity and quality
performance and the effect of being a less preferred employer;
Providing industry specific examples that identify major OHS issues and good
practice in dealing with them, and;
Communicating to businesses the growing body of case law that shows that the
courts are increasingly holding employers to account for causing unnecessary
stress to their employees by failing to assess OHS risks. This will help to ensure
that businesses are aware of the risks to their reputation posed by such litigation
and that the cost of such litigation, including possible fines and lost market share,
may become material even to larger businesses.

The IoD Member Opinion survey of 200238 is one of the most informative sources on
which CSR issues matter to SMEs. Some of the results are encouraging for the
HSC/E in their task:
O

O

O

38

In the IoD survey, social issues - including charitable giving - were addressed in
corporate policies by a greater proportion of businesses surveyed than were
environmental issues;
Environmental concerns were greater among manufacturing and other industrial
businesses than in the service sector. It appears however that the environment is
much less of a concern for SMEs than it is for larger businesses, presumably
because the small size of the business makes their perceived impact smaller,
and;
A high proportion of respondents (46%) kept records of employee satisfaction
with the work - life balance, had policies on this issue (48%) and agreed with the
IoD Survey, www.iod.com

21

statement that implementing policies on this issue brought business benefits

(96%). In fact, a higher proportion of businesses agreed with the statement that
improving the work - life balance of employees would deliver business benefit
than any other CSR measure listed, including increasing the qualifications of
employees.
SMEs appear to pay particular attention to their employees. In the IoD survey, a high
proportion of businesses (over 75%) believed that following equal opportunity and
ethnic diversity, improving the work life - balance, and employee training policies
would bring business benefits. These findings suggest that although SMEs may be
further behind than their larger counterparts in measuring, reporting and adopting
policies for OHS, they are more sensitive to employee concerns. If the issue is of
importance to employees in an SME, it is likely to be addressed by the board of
directors. Respondents from SMEs appear to view addressing issues that matter to
employees as likely to deliver business benefits. In these smaller businesses,
employees do seem to be regarded more as the biggest asset. The possible causes
for this difference with larger firms include the business case being far easier to
identify in a smaller organisation or simply better communication between
management and employees more of an extended family approach.
In our interviews, the FSB highlighted the business case as being an important, if not
the most important determinant of SME behaviour when making policy decisions. For
OHS, the issue to which SMEs were most likely to respond was reported to be the
cost of insurance which in many cases is compulsory in order for them to trade.
The cost of insurance has recently increased rapidly and has become a much more
important material issue for small businesses. HSC/E is already working with the
ABI and the Department of Work and Pensions (DWP) to provide incentives for
businesses to improve OHS through Employers Liability Compulsory Insurance
(ELCI). Based on the IoD survey, this activity could be best reinforced through
further informing employees in SMEs about good practice on OHS issues and
demonstrating the business case for improving OHS to directors.
It should be noted that the pioneers in the development of new OHS policies and
practices include a very high proportion of SMEs. The European Agency for Health
and Safety (EAHS) has documented39 a number of case studies of companies that
have introduced innovative approaches to OHS in their industrial sectors. These
case studies show that for some SMEs the occupational safety and health of
employees is an integral part of the corporate values of the company, expressed in
the market positioning of products and services. For example, the UK company
Happy Computers sells its services on the basis that customers should be assured
their employees are well motivated because they as an employer have built the
welfare of workers into the way they conduct their business40. This contrasts with the
many large IT businesses that do not measure and report OHS issues because
these aspects are not considered to pose reputational risks.
This example shows that in addition to informing employees on good practice and
providing a business case for employers, there is a need also to publicise - through
awards and case studies - companies that may provide inspiration to others. The
award or case study should ideally contain evidence of a business case for OHS. In
the case of Happy Computers it was possible to demonstrate that its innovative

39

40

Issue 210, Social Responsibility and Safety and Health at Work. European Agency for Health and Safety at
Work. See http://agency.OHSa.eu.int/publications
See. www.happy.co.uk

22

policies did result in lower employee turnover, leading to lower recruitment and
training costs and lower levels of absenteeism than the industry norm.
3.2.3

Influences on Businesses
The IoD member survey also provides a useful insight into the main influences on
business with respect to CSR. The largest influences in making businesses think
about their social and environmental impacts were found to be employees, with 82%
stating they were important. The next groups identified in descending order were
customers at 81%, business organisations - such as the IoD - (68%),
shareholders (65%) and government (63%). The lowest groupings were other
investors, suppliers and the media, all scoring over 50%. Perhaps surprisingly,
NGOs and interest groups (39%) were not considered to be major influences.
Government and business organisations were considered the most appropriate for
monitoring impacts.
BITC was reported to be the CSR organisation that businesses were most aware of
(73%). The European Union (EU) Green Paper on CSR41, the Association of
Chartered Certified Accountants (ACCA) awards on social and environmental
reporting42, the Department for Food and Rural Affairs (DEFRA) and DTI guidelines
on environmental reporting and the Minister for CSR followed with awareness levels
of over 30%. In terms of standards and guidelines, the highest awareness and
participation levels were reported to be Investors in People, International Standards
Organisation (ISO) 14001 and the ABI Guidelines. International CSR standards and
guidelines such as the GRI scored poorly. It should be noted though that these CSR
organisations, standards and guidelines were considered to exert limited influence
when compared with employees and customers a view expressed more by Small
and Medium Enterprises (SMEs) than larger businesses.

3.3

CSR ORGANISATIONS
As noted in Section 2, the major organisation in the UK promoting CSR is the BITC.
It has 400 employees working from 10 regional offices. The organisation serves 700
members, the majority of which are businesses. Though the majority of the members
are large businesses, a significant proportion of regional members are SMEs. Other
noteworthy CSR organisations include Forum for the Future, Accountability, the
Centre for Corporate Accountability, the International Business Leaders Forum and
the Institute of Business Ethics. There is considerable duplication of membership
amongst these organisations. Most cover the full range of CSR issues, combining
campaigning and lobbying, publishing research on CSR impacts and providing
guidance and advice to their members.
The BITC confirmed the findings set out earlier on the attitudes of businesses. In
summary, they felt that most of them are concerned with safety rather than health,
that OHS is considered to be material chiefly by industrial businesses and that issues
such as stress and musculo-skeletal disorders, return to work and the work - life
balance are not regarded as major OHS issues. In general, the fact that the major
challenge facing the UK was to improve occupational health was not widely known
amongst their members.
As an organisation, BITC recognises the importance of OHS to CSR. In developing
its corporate responsibility index, it had considered making OHS a separate
41
42

The European Union (EU) Green Paper on CSR, see. www.bsdglobal.com/issues/eugreenpaper.asp

The Association of Chartered Certified Accountants (ACCA) awards on social and environmental reporting,
see. www.accaglobal.com

23

management area alongside community, environment, marketplace and workplace

but chose eventually to include it under workplace. The focus of the management
section of the index is on processes for managing interaction with stakeholders and it
recognises the importance of OHS as part of a business interaction with employees.
BITC is potentially willing to work with HSC/E in a number of ways:
O

O

O

3.4

It is revising and improving its Corporate Responsibility Index (CRI) and would
welcome suggestions from the HSC/E on how the current evaluation criteria
could be improved. It should however be noted that the index is already long and
that the focus of the management section is process rather than benchmarking
performance. It would not therefore be possible for the BITC to use the HSC/Es
index as it stands;
Revise/develop its reporting guidelines on OHS,and;
BITC would be willing to run campaigns and/or award schemes jointly with the
HSC/E. Campaigns could take the form of highlighting practices that contribute to
poor OHS, coverage of key OHS issues by industrial sector, benchmarking OHS
performance by sector and providing industry specific guidance.

SRI ORGANISATIONS
Three types of organisation are influential for socially responsible investment:

1 Organisations such as the ABI and the National Association of Pension Funds
(NAPF) that represent the interests of mainstream investors and fund managers.
Insurance companies and the pension funds are the major institutional investors
in the stock market and the fund management industry is their means to invest in
it. These organisations provide advice and guidance on the types of reputational
risk that their members should be concerned with and on mainstreaming
CSR/OHS concerns in the investment industry.

2 Membership organisations of the SRI industry, such as the UK Social Investment

Forum (UKSIF) and networks of SRI analysts that work for SRI fund managers
help to raise awareness of issues and provide guidance and advice on issues
that matter for reputational risk.

3 Organisations providing information and evaluation services on CSR issues for

the SRI industry. It is the information that they provide that is used by the SRI
analysts and fund managers to evaluate the reputational risk that possible
investee companies are exposed to and the extent to which they have taken
measures to mitigate these risks. This is crucial for determining whether an SRI
fund manage will invest in a company. Notable examples are the Ethical
Investment Research Service (EIRIS), FTSE4 Good and DJSI/SAM (SAM
Indexes GmbH).
The ABI is probably the more influential of the mainstream investment organisations.
Not only has it influenced the thinking of its members - who comprise a sizeable part
of the fund management industry - its disclosure guidelines have been adopted by
large and medium businesses as the basis of reporting43. The ABI provides a
monitoring service that reports on compliance with the Combined Code and progress
43

This section refers only to the ABIs role as a member organization for fund managers. The organization plays
an important role in promoting OHS through ELCI and other insurance products.

24

on non-financial risks and opportunities generally. In practice, the focus is on risk

rather than opportunity because risk may destroy the value of the business. It also
advises companies on reporting.
The ABIs disclosure guidelines leave it to companies to determine what is material
for reputational risk. This means that for an issue to be given prominence in
measurement and reporting it must be perceived as being material. The ABI would
not wish to impose a view upon businesses. In discussions it was noted that for
many businesses OHS was not considered as material to their reputations.
Moreover, there was a view that there were doubts in the minds of some fund
managers as to whether OHS should be considered an SRI issue or simply a
component cost of doing business. As with issues such as cost savings on energy,
OHS was considered material for business performance but its effect on profits was
considered too diffuse for the issue to be seen as a priority.
The challenge for HCS/E is to work with the ABI to ensure that fund managers
recognise that OHS is a potential contributor to reputational risk for all industries,
rather than a select group of industrial companies for whom safety is a major factor.
Apart from ensuring that the OHS issue is raised in the public domain and by
stakeholders such as employees and their representatives, this may involve HSC/E
in greater dialogue with the investment industry. This is because of the need to show
why OHS is a CSR, and hence an SRI issue, not simply an on - cost of doing
business. Investment organisations will need to be shown ways in which
occupational health can be impaired and the improvements that may be achieved.
The investment sector is in itself prone to stress and other abuses of occupational
health. They may need to be shown that, even in industries such as their own, the
difference between good and bad practices can mean the difference between an
appropriate work - life balance and considerable human resource problems that
reflect badly on them as employers.
Fund managers will need to be shown persuasive evidence that OHS policy and its
implementation does reflect on the profitability of a business. As well as providing
aggregate costs to the economy of poor OHS and case studies that focus on the
returns on investment in OHS, the evidence needs to show bottom line impacts of
good and bad practices of businesses in similar industrial sectors. This will help fund
management to look to businesses to report meaningful indicators of OHS
performance and ask appropriate questions of the processes they use to manage
OHS through engagement. It may even empower them to ask pertinent questions of
their own employers and help them to become good examples themselves. This is
recognised in Revitalising Health and Strategy which provides under Action 1 the
provision of a Ready Reckoner to help management understand the business case
for OHS.44
As already discussed, the ABI is willing to cooperate with the HSC/E in raising the
profile of OHS in the SRI agenda. ABI organises seminars and workshops on
important issues and would be willing to facilitate dialogue between the fund
management industry and the HSC/E.
UKSIF is a member organisation made up of investors, fund managers and CSR
organisations. It runs programmes such as Just Pensions that help to ensure SRI
practices are mainstreamed and provides information, guidance and campaigns on
specific issues. The organisation has a close working relationship with the HSC/E,
passing on advice and guidance to its members. UKSIF believes that OHS in terms
44

Revitalising Health and Safety. www.hse.gov.uk

25

of occupational safety - is regarded as a top level issue and that much of the SRI
industry therefore regard it as a relatively easy issue to engage. The difficulty arises
when trying to engage the SRI industry more on occupational health issues.
Despite the importance already attached to OHS, UKSIF believes that it should be
possible to further raise the profile of OHS in the SRI - range of possibilities for doing
so were discussed. The organisation is preparing sector profiles that set out risks
and opportunities relating to social, ethical and environment impacts of industries.
The HSC/E may contribute to the preparation of these profiles using their
understanding of OHS risks, benchmarking for assessing performance and providing
guidance on good practice. Good practice examples - well thought through and
preferably endorsed by industry leaders and stakeholders such as trade unions would be welcome. Further, the organisation would also be willing to help arrange a
dialogue between the HSC/E and their own members on important OHS issues.
One of the most influential sources of information in the UK on the social, ethical and
environmental performance of companies is EIRIS. Whilst fund managers do pay
attention to evaluations carried out by FTSE 4 Good, the DJSI and rankings prepared
by BITC, they are increasingly inclined to undertake assessments of companies
themselves. To complete these assessments they need to have access to all the
information available on a companys processes and systems, impacts and the views
of the various key stakeholders. EIRIS is the most widely used source accessed by
the UK SRI industry.
EIRIS would welcome closer co-operation with HSC/E. Benchmarks of performance
by industry, evaluations of key OHS risks by sector and guidance on best practice
would be valuable. HSC/E could also perhaps commission EIRIS to run its Corporate
Health and Safety Performance Index (CHaSPI)45 - the organisation has been
approached by other UK Government agencies to run official measurement tools.
EIRIS is a not for profit body and therefore has no revenue income other than from
charges for its services. This factor should be borne in mind if any working
arrangements are considered.
3.5

BUSINESS ORGANISATIONS
Business organisations typically cover a wide range of subject areas, with widely
differing viewpoints. For example, they may promote a subject such as trading with
the new European Member States, run seminars on new labour laws and lobby the
Government on taxation. In each case there can therefore be a disconnection in both
time and actions between related subjects and this appears to be the case with OHS
and CSR. Modern thinking on OHS has been a part of business organisation activity
for over 30 years, many going much further back on safety issues. CSR is a much
more recent subject that impinges on different aspects of their activities investment,
social awareness, employment, etc. In this sense, OHS has to take its place as just
one of these components and does not rank high on the agenda. Neither does CSR
when compared to the overall coverage of the organisations concerned.
Although not prominent in their activities, CSR was certainly recognised as important
by the organisations concerned and most had some coverage of the subject, albeit
broad in nature and not OHS specific.
45

The development of a health and safety management index for use by business, investors, employees, the
regulator and other stakeholdersHealth and Safety Management Performance Index. HSE Research Report 217
published 2004. See www.hse.gov.uk/research/rrpdf/rr217.pdf and see Reeve, Paul. Committed for good, The
Safety and Health Practioner, August 2004.

26

The Confederation of British Industry (CBI) as the principal employers organisation

recognises the importance both of CSR and, to a much greater degree, OHS. The
organisation has undertaken several policy studies on the constituent elements of
CSR, for example absenteeism and profitability, but has yet to link OHS to CSR in
any major way. The organisation is very willing to work with HSC/E on the subject but
of course, as with any member-based organisation, must act broadly in the interests
of its members.
The Federation of Small Businesses (FSB) represents 185,000 members across all
sectors, 75% of whom are in businesses with 5 employees or less. Their general
view was that small businesses have difficulty in grasping the concept of CSR and in
general feel that they are already practising many of these aspects that it contains
responsibility to their employees, social awareness, activities in local communities,
etc. The CSR focus seemed to be mainly on factors that are external rather than
internal to businesses and therefore missed the opportunity of formally using CSR to
improve labour retention, profitability and performance improvement although as
small businesses this may already be part of their informal family culture.
The FSB is already working with BITC to set up a small business consortium to help
smaller firms appreciate the importance of CSR in the wider context. The contact
interviewed felt that a wide range of publicity on the subject covering different
aspects and case studies would be better than a single CSR strand.
On OHS, the FSB offer a Health and Safety hotline that provides limited legal and
technical advice and they are currently considering how this could be linked to CSR.
Again, the organisation is very willing to work with HSC/E in this respect and
suggested that the subject could be linked to insurance premium savings a cost
area that is currently causing concern to their members. The FSB were not keen to
see regulation used as a means of achieving CSR compliance and would prefer to
use small business champions to promote the subject in a more positive way.
The Institute of Directors (IoD) again represents a substantial number of members
with SME backgrounds. The organisations works closely with the HSC/E on OHS
issues and has been involved in several publications notably the pamphlet
Directors Responsibilities for Health and Safety (HSE, February 2002). Again, the
focus of the Institute has been largely focused on OHS and CSR, although covered
in their range of courses and publications, is somewhat marginal. The IoD has good
working relations with the HSC/E and would be happy to continue on CSR.
3.6

OHS ORGANISATIONS
The UKs foremost OHS organisations for the promotion of occupational safety and
health are the Royal Society for the Prevention of Accidents (RoSPA) and the
Institution of Occupational Safety and Health (IOHS).
RoSPA is a member organisation with a current membership of 5000, consisting
mainly of larger businesses. Its prime objectives are the promotion of safety at all
levels - at work, in the home, on the road, water and leisure safety - and occupational
safety and health education. Advice, training and consultancy services for the private
sector generate approximately 90% of RoSPAs revenue revenue that helps to
subsidise the policy work of the organisation. RoSPA employs 100 staff across five
area offices.

27

RoSPAs policy activities focus on learning how to prevent accidents/poor

occupational health, raising awareness of health and safety issues, providing
guidance and - where appropriate - campaigning for regulatory change. Currently the
organisation has a keen interest in issues associated with managing occupational
road risk. On average in the UK 20 people die each week as road casualties, 7 of
whom are driving for work.
RoSPA believes that the main challenge for the HSC/E in using CSR to promote
OHS is to overcome the fact that most CSR practitioners regard OHS as a
compliance issue. Health and safety should be included in the curricula of HR
courses and as an elective in MBA degrees and considered a key part of everyday
business management, not a separate CSR issue. In RoSPAs opinion, if HSC/E is to
succeed in its objective it must be able to demonstrate ways in which OHS goes
beyond compliance. In RoSPAs view, HSC/E has to extend the typology of business
attitudes towards OHS beyond the compliance perspective.
RoSPA already has a close working relationship with HSC/E. The Society is keen to
work with HSC/E on raising the profile of OHS in CSR.
The Institution of Occupational Safety and Health (IOHS) is one of the foremost
professional training and accreditation organisations in the field. The organisation
obviously has a long track record on OHS and latterly has begun to focus on CSR as
a means of achieving improvements in OHS. Whilst not referring directly to CSR, the
Institution provides a number of courses and publications that refer to the
corporateness of OHS in terms of better working relationships, workplace
improvement and team building. IOHS worked with BITC in developing their CSR
index and would be very happy to work with HSC/E on the subject.
3.7

THE TRADE UNIONS

As noted in Section 2, the trade unions have a pivotally important role to play in using
CSR to promote OHS. In the role of employee representatives they facilitate the
interaction between a business and one of their main stakeholders. They can
therefore help raise the profile of OHS in this interaction. Trade unions may also
stand to verify the processes and quality of the interaction and to educate their
members on what constitutes good practice. Trade unions have a vital role in making
OHS a reputational risk issue. Any suggestion that a business is losing the trust of its
employees because it does not pay sufficient attention to their welfare would be
regarded by the CSR movement as a matter of reputational risk.
Many trade unions are trustees of major pension funds and hence can influence the
way that fund managers regard OHS. For example, they can ask fund managers to
declare the extent to which they take account of OHS and select managers who give
importance to, and are knowledgeable about OHS, issues. The trade union
movement has supported research on CSR issues and the way they influence SRI.
The HSC/E and the trade union movement have a long-standing mutual interest in
improving safety in the workplace. The critical issue for HSC/E in working with the
trade unions to jointly improve the profile of OHS in CSR is that, up to now, the trade
union movement has focused on regulation rather than voluntary measures such as
CSR to improve OHS. This is understandable given the importance that they place
on the welfare of their members.
HSC/E needs to convince the movement that whilst it does not rule out additional
regulation, it is concerned to move the practice of OHS up the scale of competence,

28

well beyond basic compliance. In support of this, the trade unions will need to see
that HSC/E has a strategy for doing so that is coherent and credible. If that strategy
fails, then HSC/E may need to review again the need for additional regulation.
Whilst the Trades Union Congress (TUC) is an obvious partner for such an
approach, it may be additionally useful to work through them with the unions of
sectors where businesses give a low priority to OHS, such as finance and IT. In fact,
as and when the HSC/E is able to provide industry specific benchmarks and
guidance, it should engage with the relevant trade unions to ensure that their
members are enabled to use the information as part of their interaction with
employers.
3.8

THE MAJOR SOURCES OF INFLUENCE

As may be seen from the text activities on both OHS and CSR are undertaken by
several organisations, but rarely do they overlap. This is not helped by the fact that
OHS is a multi faceted, long - established business issue and CSR, whilst also
multi faceted, is comparatively recent. One of the major issues in furthering the
cause of OHS through CSR will therefore be to raise the level of OHS as a business
issue within the CSR agenda. To do this, the various organisations concerned must
be able to interpret their varying member and corporate agendas in ways that will
further the cause of OHS and simultaneously raise their perception of CSR as a
business improvement tool. Figure 3 shows the three main groupings of the
suggested top group organisations that are likely to be the major sources of influence
in achieving this goal. It may be seen that the organisations fit three main groupings
OHS, Business and CSR.

Figure 3:

OHS, Business and CSR organisations

Health & Safety

IoSH, RoSPA
HSC/E, TUC

OSH
through
CSR
CSR
BITC, ABI, EIRIS,
NAPF, UKSIF

Business
IoD, CBI, FSB

29

4.

THE PROPOSED STRATEGY

This section presents a strategy to raise the profile of OHS in CSR. It considers the
role of HSC/E in raising the profile of OHS and a suggested strategy to pursue, the
key levers for making occupational health a reputational risk issue and material to
business performance, the ways that it can influence measurement and reporting,
enable businesses and investors to benchmark performance and practices, and the
types of guidance it needs to provide.
4.1

THE HSC/ES ROLE

Before discussing the strategy that HSC/E may pursue to raise the profile of OHS in
CSR, it is important to consider the types of initiative that are compatible with the
HSC/Es statutory responsibilities. As the regulator of OHS, the HSC/E is the most
influential OHS organisation in the country but as such the organisation cannot
undertake activities that could prejudice its regulatory function.
In fulfilling its statutory responsibility for health and safety the HSC/E takes a view
beyond regulation. As set out in the document, Revitalising Health and Safety, the
organisations broader aim is to motivate and encourage employers to take greater
responsibility for OHS outcomes than simply complying with the law. This approach
has been taken in order to ensure at the UK builds on its considerable achievements
on health and safety. In fulfilment of this aim, the HSC/E has for some time been
raising awareness of OHS issues, providing guidance and running programmes that
support employers in dealing with OHS issues. This activity is being extended by the
introduction of programmes to raise awareness on and mitigate stress and musculoskeletal problems.
Activities that are more problematic for the HSC/E to undertake are those that
publicly name and shame or alternatively endorse the OHS practices of individual
companies. Such public criticism or endorsement may be judged to impair the
objectivity of the HSE in discharging its regulatory functions.
These limitations do not present major hurdles in being able to use CSR as a tool for
improving OHS or on raising the profile of OHS in CSR. In reality CSR focuses on
interaction with stakeholders. Organisations promoting CSR therefore tend to utilise
major influences on customers, employees, investors and local communities to put
pressure on businesses to improve social and environmental impacts. The HSC/E
may also motivate and enable these stakeholders using a bottom up approach to
engage with businesses in order to raise the profile of OHS in CSR.

4.2

THE PROPOSED STRATEGY

In the Government and HSC/Es Revitalising Health and Safety Strategy document
action point 2 deals with public reporting of OHS performance and action point 11
with directors responsibilities. HSE have undertaken a number of measures and
initiatives in support of these action points. The aim is to raise recognition among
CEOs and directors on the role that health and safety has to play in enhancing the
reputation of their business and in achieving a high performance team46.
46

Corporate Responsibility and Accountability for Occupational safety and health: A Progress Report on
Initiatives and Measures - see HSC paper 03/105 www.hse.gov.uk/aboutus/hsc/meetings/2003/141003/c105.pdf.

30

This work includes the following six strands:

O

O

O

O

O

O

Strand 1: Facilitate meetings for Chair/Director General/Deputy Directors

Generals with top people in top companies to promote corporate responsibility
and accountability and active support for the HSC/Es Strategy for workplace
health and safety in Great Britain to 2010 and beyond;
Strand 2: Engage more effectively with large organisations;
Strand 3: Identify, develop and review influencing tools. This includes publishing
the results of research on reporting and directors responsibilities, evaluating the
effectiveness of guidance and supplementing where necessary with persuasive
evidence of the benefits of top level leadership and direction and good practice
case studies. This strand also covers the provision of influencing tools such as
case studies and the health and safety management index;
Strand 4: identify and exploit opportunities through the complementary work of
others to further CR&A goals. This is effectively what the Business Involvement
Unit has been doing through the relationships it has built with the CSR
movement. This study is intended to further that engagement;
Strand 5: Encourage others to use their influence to improve health and safety.
The two key instruments noted are the use of CHaSPI by investors in large
companies and the use of the SME Health and Safety Performance indicator by
Employer Liability insurers, and;
Strand 6: Assist large companies to benchmark their OHS performance through
using CHaSPI

The six strands represent a coherent and comprehensive set of measures and
initiatives. What our study shows is that CSR should not be viewed by the HSC/E as
a separate vehicle for promoting OHS. Strand 4 will only succeed if the HSC/E is
successful in other elements of its strategy to Revitalise Health and Strategy. To be
effective, CSR must become a core aspect of the HSC/Es overall strategy for raising
public awareness of OHS issues, persuading employers of the business case for
OHS and providing guidance to them on how to measure performance and manage
OHS.
As shown in figure 2, CSR is one of a number of forces that influence business. The
HSC/E should use the wider range of forces to influence businesses, including other
sources of regulation. These include the OFR and the disclosure requirements of the
stock exchange, other external factors such as conditions in the labour market and
the full range of internal factors that provide the business case for OHS.
CSR is a valuable trend that provides a new set of arguments for improving OHS. In
support of this, the CSR movement provides a useful channel of influence on
business. In order to raise the profile of OHS in CSR however, the CSR movement
needs the HSC/E and other OHS organisations to raise the public profile of OHS and
engagement with employees to make it an interactive issue with their employers. The
CSR movement, though recognising the importance of OHS and including it in
measurement and reporting guidelines and evaluation tools, will not raise its profile in
CSR unless societal impacts and influence on business performance have been

31

demonstrated. As the movement matures and becomes more of a mainstream issue

it is increasingly subject to the discipline of materiality and is less prone to arguments
of societal impacts alone.
For the CSR movement to give OHS greater prominence it must be viewed as a
material issue of reputational risk and business performance and/or an important
element in the interaction of the business with employees. One or more of three
conditions need to be fulfilled to enable this to happen:
O

O

O

HSC/E must demonstrate that OHS is a reputational risk issue for all types of
business. For the reputational risk to be material, it needs to be shown that
companies that fail to adequately address occupational safety and health are in
danger of losing public trust with a consequent loss of profit;
HSC/E must demonstrate to the CSR movement that the business case for OHS
is sufficient to be material to business performance overall. This is likely to
include the influence it has on customers as well as on costs. The aim should be
to bring together the diverse impacts so that OHS is seen to have a material
impact on profits, and;
OHS must be given greater prominence by employees - and those who represent
them - in their interaction with employers. The trade union movement must
broaden its focus on improving regulation to include the potential that
engagement with CSR holds. As trustees of pension funds the trades unions also
have an important and influential role to play. The unions representing employees
in industries where occupational health is the main threat to OHS have a special
role to play in this respect.

Once one or more of these conditions is in place, then the HSC/E can assist the CSR
movement in its role of influencing business effectively by providing the movement
with tools such as a framework for evaluating OHS in relation to CSR, tools to
measure performance and benchmark management practices, provide guidance on
key risks and what constitutes good practice and recognise innovation. We consider
below the types of evidence that HSC/E may provide to address the three conditions
before considering the tools that will enable the CSR movement to influence
business behaviour more effectively.

4.3

HIGHLIGHTING REPUTATIONAL ISSUES

For large industrial businesses, occupational safety is already recognised as a
material reputational risk issue. The key challenge for HSC/E will be how to make
occupational health a material reputational risk issue for a wider range of business
sizes and sectors, particularly larger service sector businesses such as those
engaged in financial services, IT and distribution.
The critical test of whether an issue is material for corporate reputations is loss of
public trust. The starting point for making these issues material for corporate
reputations must therefore be public awareness. As yet, public awareness of the
damage caused by stress and an inappropriate work - life balance generally,
musculo-skeletal disorders and occupation related road safety is not as high as
safety in the workplace.

32

The HSC/E is actively campaigning to raise awareness of occupational health issues.

The evidence used in promoting the importance of this issue should include the loss
of time from work and the human suffering caused. There is growing evidence that
this latter aspect is being cited more in cases brought before the courts. This could
be used to raise awareness among employers and employees of the common
causes and consequences. Employers that do not take action to identify and mitigate
these risks are failing in their statutory obligations and so are in danger of breaking
their trust with society.
HSE needs to undertake a public awareness campaign, the Business Involvement
Unit could help to translate its key messages into the language of CSR in order to
engage with the CSR movement. The CSR movement has already accepted that
OHS is part of CSR, though there are some doubters who view OHS purely as a
compliance issue. The key levers that the IEU can use in engaging the CSR
movement are:
O

O

O

O

Promoting the 5 -10 key OHS risks for a broader range of industrial sectors,
demonstrating the impact of poor practice on the lives of employees. This should
help to raise the profile of OHS within the CSR movement;
Evidence to show the difference between sector leaders and the average to
demonstrate that businesses claiming to be socially responsible need to go
beyond compliance if they are to improve their impact on society;
Businesses claiming that their employees are their biggest asset need to
substantiate their claims. The HSC/E can point to what is good practice and
challenge the CSR movement to ensure businesses are following it, and;
Point to the public awareness campaign and suggest that as the public learns
more of the issues it is bound to question whether businesses are taking the
issue seriously enough to justify their trust. Businesses failing to do so run the
danger of losing public trust.

The two main sources of influence on the CSR practices of businesses, as

demonstrated by the IoD survey, are customers and employees. Both groups need to
be enabled in order to evaluate how businesses are performing and to hold them to
account if they are not following good practice. The CSR movement is more likely to
regard OHS as a material issue for reputational risk if customers and employees do
so as well.
The ultimate customer for all products and services is the consumer - this is why
public opinion is so important. For many businesses - especially SMEs - the
customer is frequently another business, often large. The CSR movement has
already accepted the principle that businesses can be held to account for the
negative social and environmental impacts of businesses that they trade with. It is
therefore important to point out that poor OHS practices of suppliers may also impact
on larger corporate reputations. Socially responsible businesses need to build OHS
practices into supplier vetting. BT and other leaders in the field of CSR already do
so. This should help to ensure that good practices on OHS are followed not only by
large companies but also by SMEs. The enabling of employees is discussed later
under Stakeholder Engagement.
Initially, the key channels of influence for highlighting reputational risk will be the
CSR organisations and the SRI industry. They will help to bring pressure to bear on

33

large businesses and this should help to increase the demand for guidance on how
to improve OHS practices and performance. The HSEs Business Involvement Unit
should mobilise the help of the OHS organisations in the dialogue with the CSR
organisations and the SRI industry. As guidance becomes available the Business
Involvement Unit can then work with the CSR functions of business organisations to
provide simple and easily to implement recommendations for their members.
4.4

MAKING OHS MATERIAL FOR BUSINESS PERFORMANCE

O

O

O

O

O

47

As observed by the ABI, currently, the business case for OHS remains too diffuse
to be considered material to business performance. There is a need to bring
together all the impacts that affect profits and performance for example,
customers, recruitment costs, employee retention, higher employee satisfaction
leading to better customer retention/product service quality and lower
absenteeism/higher productivity. This will require the development of a robust
methodology that separates out the effect of other factors such as pay and
management methods from purely OHS effects. With the methodology in place, it
should be possible to quantify the variance between the best and worst
performers in an industry to demonstrate how material OHS is for business
performance;
The case studies47 that the HSC/E has recently prepared are useful in
demonstrating the business case for OHS. They are designed, however, to
demonstrate the cost-benefit case for investing in OHS rather than the material
impact that OHS practices may have on overall business performance. They
need to be supplemented by additional research and case studies;
Amongst larger businesses, the additional research and case studies should
focus on industries where OHS is not perceived as a reputational risk such as IT,
financial services and distribution. Providing a business case for OHS is
particularly relevant for smaller businesses as they are less exposed to external
pressure from investors. It is therefore important to include SMEs in the case
studies to provide practical examples of how businesses can improve their
performance through better OHS;
The case studies can then be publicised to raise awareness. To influence
behaviour, the HSC/E may also provide guidance on better OHS practices that
lead to improved business performance. Guidance on how to achieve better
performance should be simple and easy to implement. This is discussed further
below, and;
In using business performance as a tool for making OHS a material issue for
CSR, the key channels of influence are the CSR units of business organisations.
The IoD and the FSB will prove particularly useful in reaching smaller firms but
the CBI and EEF will also have an important role. Where industry specific
guidance is available the HSC/E could also work with the respective trade
associations. In addition, it will be important to keep the CSR movement informed
of developments and issues so that they realise OHS is material for the bottom
line.

Supra at 26.

34

4.5

STAKEHOLDER ENGAGEMENT
O

O

O

O

4.6

Close interaction between businesses and their employees is fundamental to the

success of a sound CSR strategy. Most businesses that have adopted CSR as
integral to their way of doing business therefore have in place mechanisms to
engage with their biggest asset, either through employee representatives (trade
unions) and/or directly through the line management function. Those who have
adopted better OHS practices to improve business performance will also have in
place mechanisms to engage with their employees;
Of course, what matters in practice is not just that engagement takes place but
the quality of that engagement. HSC/E may help to improve the quality of
stakeholder engagement amongst those committed to CSR or who have decided
to adopt better OHS practices to improve business performance. Even if
engagement is taking place, if employees are not aware of what constitutes good
practice in OHS, then they cannot engage in meaningful dialogue;
The key to success in improving the quality of engagement is to demonstrate
good practice and why it makes sense for employers to follow it. Evidence may
be based on the same case studies as above and the guidance derived from it,
but to ensure buy-in, the orientation should be on employees. They should be
able to see how better OHS practices can lead to improvements in their working
conditions and their performance and why adopting these practices is in the
interests of their employer, and;
To reach employees, apart from the use of the media, the main channel of
influence is the trade unions. They need to be convinced that a voluntary
approach is worth trying and that such an approach will help to empower/benefit
their members. It is especially important to work with unions in industries where
occupational health issues go unrecognised, such as IT and financial services.

A POSSIBLE FRAMEWORK FOR EVALUATING OHS IN RELATION TO CSR

The first of the tools that the HSC/E may wish to provide to the CSR movement to
influence business behaviour is a possible framework for evaluation OHS in relation
to SCR. If the emphasis within OHS is to switch more toward longer - term health
issues, it is important that businesses regard OHS as a continuous process that does
not end with compliance. Current evaluation tools often focus on whether risks have
been assessed or appropriate management systems are in place. These need to be
improved in line with other aspects of CSR that are now moving away from
compliance and managing risks to maximising the positive impact on society. To do
so, a framework for evaluating impacts is needed.
The outline of a possible simple framework is shown in figure 4 below. The vertical
axis indicates degree of awareness of effective OHS management; the horizontal
indicates extent to which good practice is integrated into business strategy and
operations. Companies may be graded into five categories by degree of engagement
as follows. The categories could of course be further subdivided in order to provide a
finer degree of comparison.
O

O

The first, least engaged, group are Dont know, Dont Care businesses;
The next stage covers businesses that have taken the trouble and effort to meet
their statutory OHS obligations;

35

O

O

O

At the third stage are businesses that manage their reputational risk - those that
are concerned with corporate reputations but have not embraced OHS as a
business tool;
Businesses that have embraced the business case for OHS are at the fourth
stage, and;
The fifth and final stage covers OHS Leaders, those that have integrated OHS
into their corporate values and the way do business

Figure 4:

Framework for evaluating OHS in relation to CSR

Full

Business
AWARENESS
OF
EFFECT IVE
OSH

MANAGEMENT

case

Reput ational

St at utor y
Dont
dont

integ ration

for

risk

of

OSH

int o

CSR

OSH is emb raced

managed

compliance

know,

care

EXTE NT

OF INT EGRAT ION

OSH/ CSR

Awareness and integration clearly go hand in hand but greater awareness does not
always result in greater integration in the strategy and operations of a business.
Almost always, adopting better OHS will entail some cost, be it expenditure on goods
or services or, at the least, management time in changing practices and procedures.
The perceived difficulty of bringing about change, in terms of cost or effort, may
prevent awareness becoming the basis of actual change in practice . What the
framework above does is allow the CSR movement to evaluate both the extent to
which businesses are aware of reputational risk/and or business benefits posed by
OHS issues and the extent to which they have implemented change to integrate
better OHS practices in the way they do business.
We have discussed this framework with stakeholders and found their support in
principle. No doubt it will need further discussion within HSC/E and with other OHS
organisations, including agreeing criteria for each stage. A framework of this type is
useful for getting the CSR movement to think beyond compliance and even
reputational risk. If CSR is about a companys positive impact on society and OHS is
part of CSR, then companies must be aware that managing reputational risk may not
maximise their impact. It should help to place the idea that for companies seeking to
maximise their contribution to society, improving OHS performance is a continuous
process.

36

4.7

MEASUREMENT & REPORTING

O

O

O

O

4.8

At present, company reporting follows ABI and other guidelines that leave it to
businesses to identify the key reputational issues and measure and report their
performance against them. There is a need to work with ABI and BITC toward
providing more detailed guidance on what should be measured and reported on
OHS issues, particularly for industries such as IT and financial services where
occupational health is an important issue. It would be useful also to open a
dialogue with the GRI to ensure that international reporting guidelines follow suit;
These organisations must be motivated to issue a supplement or an annex to
their guidance that sets out details and incorporate the key indicators in the main
body of their guidelines. The HSC/E should issue guidance on the key OHS risks
of each sector linked to CSR, so that the CSR organisations and SRI industry
start to engage more with businesses on OHS issues and so put pressure on
them to disclose performance;
SMEs do not need to respond to external investors. Measurement and reporting
guidance should focus on the OHS information that they should monitor to be of
value in demonstrating their performance to customers and employees, rather
than framing it as disclosure requirements. The CSR units of business
organisations are the best channel for developing this aspect, and;
The overall aim should be to develop a range of sector specific guidance on
measurement and disclosure requirements for larger firms and for SMEs a
simpler - sector specific - tool on how to monitor and record OHS performance.

BENCHMARKING
O

O

O

48

To reinforce the effect of measurement and reporting on providing an incentive to

businesses to improve OHS performance and to enable the CSR movement to
evaluate the performance of individual businesses, improved measurement and
reporting needs to be accompanied by the provision of comparators to enable
benchmarking of performance. In this respect, HSC/E has made a good start by
developing the Corporate Health and Safety Performance Index48 (CHaSPI). The
key issue now is ensuring it is adopted and widely used.
There are two possibilities to achieve this, the development of CHaSPI as a self assessment tool for benchmarking and the uses of CHaSPI as a ratings tool. If it
is decided to develop CHaSPI as a ratings tool, the key issues that will need to
be addressed are:
 The need for independent verification
 How analysts may use the resulting rankings alongside other indicators of
CSR performance
 The current trend amongst analysts to move away from indices towards
engagement may make it difficult to promote the use of the Index. as a
ratings tool.
Perhaps a better prospect would be to promote the Index as a self - assessment
tool thereby avoiding the need for independent CHaSPI verification. As
businesses can be assured of confidentiality, they will have less incentive to feed
biased information into CHaSPI. Further, including processes that involve
Supra at 45.

37

stakeholder engagement may help improve the objectivity of the information used
for self-assessment. Independent verification does not necessarily mean
external audits in the accountancy auditing sense. Stakeholder engagement
involving groups of employees and unions can also be effective, more engaged
and constructive.
O

O

O

4.9

The collective results of self-assessment, aggregated by sector, location or size

of business may then be used to provide benchmarks against which businesses
may compare their self-assessments, setting up an agenda for improving
performance. An independent agency could be appointed to manage data
gathering and monitoring and to provide counselling on interpretation of the
results. This is in fact, the way the UK Benchmarking Index, established by the
DTI to help improve business performance functions.
When established, the aggregated results, on a sector or other basis, may be
used through the managing agency to brief analysts, business organisations and
HSC/E on the results, so raising the profile of OHS. In time, CHaSPI can then
start to take on role of ratings tool
A simultaneous action that could be taken by HSC/E whilst CHaSPI is building
data would be to compile and release data on industry (sectoral) averages of key
indicators such as time off work by major cause. This type of information is what
the CSR movement needs to identify and engage with poorly performing
businesses.

GUIDANCE
O

O

HSC/E is recognised as being the authoritative source of knowledge on health

and safety issues. It provides valuable guidance on how to improve occupational
safety and health. However, business organisations consider HSEs guidance to
be too general, not specific enough to be adopted by businesses and written in a
form that few businesses, especially SMEs, are likely to digest.
If action on OHS is to be leveraged by using CSR to improve performance a
number of additional actions should be taken on the form and content of
guidance issued. Guidance can take the form of identifying key risks for each
sector and advice on good practice in identifying and managing risk and better
OHS practices that may result in improve business performance. Guidance
material, as with any material targeted at businesses, needs to be as simple as
possible for example, the 5 key risks and how to manage them. For SMEs,
these should be written in a way that takes account of their realities less
emphasis on systems, more on what to look out for and what to do about it in
simple, achievable terms.

As noted earlier under Stakeholder Engagement, guidance should aim also to

improve the quality of engagement between employees and their employers. To do
so, it will need to be tailored to meet the needs of employees and their
representatives in articulating practices that will both improve their working
environment and benefit the business in terms of reputational risk and improved
business performance.
O

Whenever possible, guidance should be endorsed by the CSR movement and

industry leaders perhaps by working in partnership to issue joint material. Joint
working reinforces the authority of HSC/E and results in greater buy in from both

38

businesses and the partner organisation. Examples of such joint working are the
sector profiles that UKSIF are keen to produce and that SRI analysts need to
engage with businesses. With the BITC, HSC/E can help shape the questions on
OHS in CHaSPI and used by them for external verification.
4.10

RECOGNISING INNOVATION
O

O

4.11

It is important to inspire businesses, especially SMEs, to improve their way of

integrating OHS into their business strategy and operations. As noted earlier,
many of the leading companies in the field of OHS are SMEs that have chosen to
make the issue the basis of the way they do business. Awards such as the
RoSPA GOPOP (Going Public On Performance) have an important role to play
in recognising these innovators and inspiring others to follow their example. Such
awards should aim to acknowledge innovation in good practice on particular
issues of importance to OHS. It is critically important, however, that the award
process allows businesses to demonstrate their innovative ideas, not just reward
what HSC/E thinks is good practice.
To avoid direct endorsement of companies, the HSC/E need not give awards
directly. Instead, it may sponsor the award but leave it to other organisations to
administer the application, judging and actual award processes. Again, working in
partnership with business organisations will be useful. Joint publicity of the award
process may then be undertaken.

IMPLICATIONS FOR HSC/E

O

O

O

Whilst CSR is an important and relatively new tool to help influence businesses
on OHS issues, it is not an answer in itself. It must therefore be used in
conjunction with the many other ways that HSC/E can influence employers,
including ultimately, regulation
The link between public opinion and CSR is clear. If the public does not care
about CSR, then neither will businesses and investors. This means that coordinated action within BWED, other divisions and with the communications
function of HSE will be needed.
HSE recognises that it needs to engage regularly with the CSR movement to pick
up on trends and initiatives that they can use. The ten key CSR players that it
needs to work with have been identified in the body of this report.

39

LIST OF REFERENCES

1. HSC/E Strategy for Workplace Health and Safety in Great Britain to 2010 and
beyond, HSE, 2004. www.hse.gov.uk/aboutus/hsc/strategy.htm
2. The aims of this block of HSC/Es work and the details of measures and activities
are summarized in, Corporate Responsibility and Accountability for Occupational
Health and Safety: A Progress Report on Initiatives and Measures. HSC paper
03/105, September 2003.
www.hse.gov.uk/aboutus/hsc/meetings/2003/141003/c105.pdf
3. The Health and Safety at Work etc Act 1974. www.hmso.gov.uk.
4. Revitalising Health & Safety, HSC, 2000, www.hse.gov.uk.
5. Supra at 1.
6. Securing Health Together, HSC. www.hse.gov.uk/press/2003/e03232.htm.
7. For a discussion of the definition of CSR see, for instance, Corporate Social
Responsibility, IOD Member Opinion Survey, Ruth Lea, especially Annex 3. IOD
2003.
8. As frequently pointed out, the 50 most powerful economic entities in the world
include ten corporations.
9. Counting on Responsibility, Louise Armitstead, Sunday Times, March 14, 2004.
10. See, The What, Why, How of CSR: A beginner's guide to corporate social
responsibility, http://www.bitc.org.uk/resources/toolkit/index.html www.bitc.org.uk
11. See for instance Action Aid www.actionaid.org.uk.
12. Restoring Trust, Richard Breeden. Available on:
http://news.findlaw.com/hdocs/docs/worldcom/corpgov82603rpt.pdf.
13. MORI Trust Monitor 2003, www.mori.com.
14. The Corporate Responsibility Code Book, Deborah Leipziger, 2003,
http://www.duurzaam-ondernemen.nl/greenleaf/codebook.htm.
15. Foreword to IOD Member Opinion Survey, IOD 2003.
16. Stephen Timms, Speech at Commonwealth Business Council Conference, 2 July
2003.
17. See www.bitc.org.uk.
18. See www.ftse.com.
19. See www.sustainability-indexes.com.
20. See www.eiris.org.

40

21. Socially Responsible Investment Amongst European Institutional Investors,

EuroSif, 2003.
22. SRI: A Global Revolution, Russell Sparkes, 2002.
23. The Operating and Financial Review Working Group on Materiality, consultation
document.
24. In their analysis of ethical purchasing, the New Economics Foundation and the
Co-operative Bank found that 52% of consumers had boycotted a product or
service for ethical reasons.
25. The Ethical Employee. Work Foundation and Future Foundation,
www.theworkfoundation.com.
26. The business benefits of health and safety, HSE, 2004.
www.hse.gov.uk/businessbenefits/casestudy.htm
27. Workers Safety and Health, Productivity and Quality. European Agency for Safety
and Health at Work.
28. People to Profits, Institute of Employment Studies, 1999.
29. Enlightened Values, BT 2002, www.btplc.com.
30. Does Business Ethics Pay Ethics and Financial Performance. Institute of
Business Ethics, 2003, www.ibe.org.uk.
31. Reported in, Achieving Higher Performance - CSR at the heart of business, the
Virtuous Circle and the Work Foundation, March 2004, Stephen Bevan, Nick
Isles, Peter Emery & Tony Hoskins, www.theworkfoundation.com
32. Directors Responsibilities for Health and Safety, HSC guidance (INDG343),
2001. www.hse.gov.uk/pubns/indg343faq.htm
33. The health and safety responsibilities of company directors and management
board members, HSE Research Report 135, 2003.
www.hse.gov.uk/research/rrhtm/rr135.htm.
34. The provision of health and safety information in the annual reports, websites and
other publicly available documents produced by the UK's top companies and a
sample of government departments, agencies, local authorities and NHS trusts,
HSE Research Report 134, 2003. www.http//hse.gov.uk/research/rrpdf/rr134.pdf.
35. Social Trends: Short term Turnover and Employment Survey, ONS, 2003.
36. Corporate Social Responsibility: IoD Member Opinion Survey, Ruth Lea, IoD,
2002.
37. Companies that Count, BITC/DTI/Sunday Times survey, published 14 March
2004, www.bitc.org.uk/programme/keyinitiatives/corporateresponsibility-index.
38. IoD Survey, www.iod.com.

41

39. Issue 210, Social Responsibility and Safety and Health at Work, 2004,
http://agency.OHSa.eu.int/publications.
40. See www.happy.co.uk.
41. The European Union (EU) Green Paper on CSR. See
www.bsdglobal.com/issues/eu_green_paper.asp.
42. The Association of Chartered Certified Accountants (ACCA) awards on social
and environmental reporting. See www.accaglobal.com.
43. This section refers only to the ABIs role as a member organization for fund
managers. The organization plays an important role in promoting OHS through
ELCI and other insurance products.
44. Supra at 4.
45. The development of a health and safety management index for use by business,
investors, employees, the regulator and other stakeholdersHealth and Safety
Management Performance Index, HSE Research Report 217, 2004.
www.hse.gov.uk/research/rrpdf/rr217.pdf and see Reeve, Paul. Committed for
good, The Safety and Health Practioner, August 2004.
46. Supra at 2.
47. Supra at 26.
48. Supra at 45.

More information on the work of HSEs

Business Improvement Unit, including measures to
promote health and safety within the Corporate
Social Responsibility agenda, can be obtained from :
Steve Vinton, 9SW Rose Court, 2 Southwark Bridge,
London SE1 9HS
[email protected]

42

BIBLIOGRAPHY

1. Armitstead, Louise. Counting on Responsibility. Sunday Times, March 14, 2004.

2. The Association of Chartered Certified Accountants (ACCA) awards on social
and environmental reporting. www.accaglobal.com
3. Bevan, Isles, Emery & Hoskins. Reported in Achieving Higher PerformanceCSR at the heart of business, the Virtuous Circle and the Work Foundation.
March 2004, www.theworkfoundation.com
4. Breeden, Richard. Restoring Trust.
http://news.findlaw.com/hdocs/docs/worldcom/corpgov82603rpt.pdf
5. The business benefits of health and safety, HSE, 2004.
www.hse.gov.uk/businessbenefits/casestudy.htm
6. Companies that Count BITC/DTI/Sunday Times survey, published 14 March
2004, www.bitc.org.uk/programme/keyinitiatives/corporateresponsibility-index
7. Corporate Responsibility and Accountability for Occupational Health and Safety:
A Progress Report on Initiatives and Measures, HSC paper 03/105, September
2003. www.hse.gov.uk/aboutus/hsc/meetings/2003/141003/c105.pdf
8. The development of a health and safety management index for use by business,
investors, employees, the regulator and other stakeholdersHealth and Safety
Management Performance Index, HSE Research Report 217, 2004.
www.hse.gov.uk/research/rrpdf/rr217.pdf
9. Does Business Ethics Pay Ethics and Financial Performance. Institute of
Business Ethics, 2003, www.ibe.org.uk
10. Enlightened Values, BT 2002, www.btplc.com
11. The Ethical Employee. Work Foundation and Future Foundation,
www.theworkfoundation.com
12. The European Union (EU) Green Paper on CSR.
www.bsdglobal.com/issues/eugreenpaper.asp
13. The Health and Safety at Work etc Act 1974. www.hmso.gov.uk
14. The health and safety responsibilities of company directors and management
board members, HSE Research Report 135, 2003
www.hse.gov.uk/research/rrhtm/rr135.htm
15. HSC/E Strategy for Workplace Health and Safety in Great Britain to 2101 and
Beyond, HSE 2004, www.hse.gov.uk/aboutus/hsc/strategy.htm
16. IOD Member Opinion Survey, IOD 2003.
17. Issue 210, Social Responsibility and Safety and Health at Work 2004,
http://agency.OHSa.eu.int/publications

43

18. Lea, Ruth. Corporate Social Responsibility, IOD Member Opinion Survey. IOD
2003.
19. Leipziger, Deborah. The Corporate Responsibility Code Book. 2003,
http://www.duurzaam-ondernemen.nl/greenleaf/codebook.htm
20. MORI Trust Monitor 2003, www.mori.com
21. The Operating and Financial Review Working Group on Materiality, DTI.
22. People to Profits, Institute of Employment Studies, 1999.
23. The provision of health and safety information in the annual reports, websites and
other publicly available documents produced by the UK's top companies and a
sample of government departments, agencies, local authorities and NHS trusts,
HSE Research Report 134, 2003 www.http//hse.gov.uk/research/rrpdf/rr134.pdf
24. Reeve, Paul. Committed for good, The Safety and Health Practioner, August
2004.
25. Revitalising Health & Safety. HSC, 2000, www.hse.gov.uk
26. Securing Health Together. HSC. www.hse.gov.uk/press/2003/e03232.htm
27. Social Trends: Short term Turnover and Employment Survey, ONS, 2003
28. Socially Responsible Investment Amongst European Institutional Investors.
EuroSif, 2003.
29. Sparkes, Russell. Socially Responsible Investment: A Global Revolution. 2002.
30. Timms, Stephen. Speech at Commonwealth Business Council Conference, 2
July 2003.
31. The What, Why, How of CSR: A beginner's guide to corporate social
responsibility http://www.bitc.org.uk/resources/toolkit/index.html www.bitc.org.uk
32. Workers Safety and Health, Productivity and Quality. European Agency for
Safety and Health at Work.
33. www.actionaid.org.uk
34. www.bitc.org.uk
35. www.ftse.com
36. www.eiris.org
37. www.eurosif.org
38. www.happy.co.uk
39. www.sustainability-indexes.com

44

40. www.uksif.org

45

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