Csr In The Development Industry: A Preliminary Study

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Corporate Social Responsibility in the Development Industry: A preliminary study By Linda Carroli (CC) August 2009 This paper is released under a Creative Commons Licence – attribution, noncommercial use and no derivatives.

Introduction

In addressing Corporate Social Responsibility (CSR) in urban development, the specific qualities and impacts of the development industry and the industry-specific application of CSR are considered. While the principles of CSR that apply to industry generally equally apply to the development industry, there are specificities in the development industry’s impact that warrant attention. The development industry is characterised by Coiacetto as an increasingly concentrated yet diverse sector which is both “dominated by large powerful players (sometimes trampling the rights of local communities and overriding the plans of local authorities) ... [and] comprising many [competitive] small players”.1 He states that “evidence suggests that industry concentration is rising: developers are getting bigger and fewer and more powerful as opposed to merely having some local spatial monopoly or submarket power.”2 In this context, noting Coiacetto’s parenthetical point about reputation issues experienced by developers, companies are adopting or considering CSR. Given that the development industry, together with government (through statutory planning), markets and financial services, profoundly shapes human settlements, there is an underlying expectation that industry agents are attentive to the social and environmental outcomes and impacts of development.3 For example, the provision of community benefit, a requirement in planning provisions, can be negotiated between the developer and local authority during the development approval process.4 Another planning/property principle is that of ‘highest and best use’, a concept that ordinarily expresses property value or investment return. 5 This notion of value may increasingly be considered within frameworks of social, cultural and environmental sustainability such as smart growth, biobanking and incentive zoning.6 1

E Coiacetto, ‘Development Industry structure into the global era: The challenge for planning, cities and sustainability’. Australian Planner. vol 44, no 3, 2007, 50 2 Coiacetto, 2007, 50 3 P Fewings, Ethics for the Built Environment, Taylor & Francis, Oxon, UK, 2009. 171 ff 4 Fewings, 2009, 176. In the UK, ‘community benefit’ is referred to as ‘public gain’. 5 MG Dotzour, TV Grissom, CH Liu & T Pearson, ‘Highest and Best Use: The Evolving Paradigm’, Journal of Real Estate Research, vol 5, no 1, passim 6 B Roberts, ‘Planning and the Economics of Development’, Australian Planner, vol 45, no 1, 2008, 27

1

CSR and related ideas (such as corporate citizenship, triple bottom line etc) emerge from and sometimes as critiques of late capitalism and liberal economics7 as well as of the corporate ontologies they spawned in areas such as management and organisational behaviour.8 Birch proposes that “CSR is not only about the survival of capitalism, it is about the creation of Sustainable Capitalism” necessitating a cultural change in business.9 CSR involves “building systems of corporate ethics and values in the enterprise, tackling questions of compliance and governance, meeting the needs of the economically and socially disadvantaged and satisfying responsibilities to the environment”.10 Garriga and Mele identify four primary motivations for CSR11:



producing profits



using business power in a reasonable way



integrating social demands



contributing to a good society through ethical behaviour.

CSR fundamentally means that “business is being asked to assume broader responsibilities to society than ever before and to serve a wider range of human values. They are asked to contribute more to the quality of human life, it will depend on the quality of management as well as how they response to the changing expectations of the public”.12 [sic] Importantly, when expressed in the language of capitalism as a capitalist imperative, CSR can also point to ways of transforming organisations, industries, markets and capitalism itself.13

7

D Birch, “Corporate Social Responsibility: Some key theoretical issues and concepts for new ways of doing business”, Journal of New Business Ideas and Trends, vol 1, no 1, 2003, passim 8 Particularly cultures of command and control (linear) which were challenged in the late 20th century by disorganised capital, decentralisation and internationalisation. 9 Birch, 2003, 2 10 Birch, 2003, 10 11 E Garriga and D Mele, ‘Corporate Social Responsibility Theories: Mapping the Territory’, Journal of Business Ethics, Vol 53, 2004 12 S Yam, M Ismail & T Yin, “Corporate Social Responsibility in Housing Development – The Developers’ Perspective.” Conference Paper. Fourteenth Pacific Rim Real Estate Society Conference, 2008, retrieved 1 August 2009 http://www.prres.net/Papers/Yam_Corporate_Social_Responsibility_In_Housing_Development.pdf 13 See Birch, 2003; Barrett, 1998; Senge, 1998; Kaptein & Wempe, 2002

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CSR Commitments of Development Companies

There are a range of sustainability initiatives in the development and construction industry that advocate or aspire to higher standards. Peak bodies in the development industry, such as the Urban Development Institute of Australia (UDIA)14 and Australian Green Development Forum (AGDF), are forming policy on and other responses to social inclusion and environmental responsibility. The UDIA has developed a sustainability certification protocol titled EnviroDevelopment.15 The Property Council of Australia has released a draft discussion paper and guidelines on CSR in the property sector.16 Professional bodies, such as the Planning Institute of Australia,17 are also considering such matters as they apply to their organisation and the industry more broadly. As a diverse profession, urban planning can be underpinned by ethical drives including stakeholder engagement, social equity, public interest and environmental stewardship. In order to consider the development industry’s engagement of CSR in a more granular way, a scan of eight corporate websites was undertaken. It is acknowledged that only information made publicly available via this media is accessed. Publication of CSR information is considered as an ‘expression’ of that company18 and a means of contributing to a public discourse or community of interest about CSR. It may be an indication that CSR and company values are integral to the company’s public interface and corporate culture, and considered sufficiently significant to warrant communication (for reasons such as transparency or accountability). The study scanned the websites of GPT, Lend Lease, GHD, Watpac, Laing O'Rourke, Devine, Conics and Stockland Development.19 The core business and geographic reach of each company are tabulated below: Company Lend Lease

GHD

Core Business Integrated property solutions providers. With capabilities that span the property value chain, from the origination of opportunities through to the delivery of property outcomes. Professional and technical consultants in water, energy &

Geographic Global

Global

14

Urban Development Institute of Australia, National Policy Statement. UDIA, Sydney, retrieved 29 July 2009, http://www.udia.com.au/resource/UDIA-National%20Policy.pdf 15 Urban Development Institute of Australia, EnviroDevelopment, retrieved 4 August 2009, http://www.envirodevelopment.com.au/ 16 Property Council of Australia, A Guide to Corporate Responsibility in the Property Sector: Draft Discussion Paper, Property Council of Australia, Sydney, 2009, retrieved 29 July 2009, http://www.propertyoz.com.au/library/A%20Guide%20to%20Corporate%20Responsibility%20Reporting%20in%20the%20Prop erty%20Sector%20V1.0.pdf 17 Planning Institute of Australia, retrieved 1 August 2009, http://www.planning.org.au 18 M Kaptein & J Wempe, ‘The Corporation as Moral Entity’, The Balanced Company: a theory of Corporate Integrity, Oxford University. 2002. 146 19 These companies are all large companies, as per Coiacetto’s description of the industry structure, and were selected from various lists of state and national top company. There is a further question about how small to medium companies are adopting CSR and whether this presents challenges in supply chain, competition and marketplace. Smaller companies may, for example, be less inclined to offer generous community dividends or ‘do more’.

3

Laing O'Rourke

Watpac

Stockland Development Devine Conics GPT

resources, environment, property & buildings, and transportation. Construction of both buildings and infrastructure projects as well as capability in investing equity into property and infrastructure developments and specialist manufacturing, plant and trades businesses. Construction, property development, specialty services (refurbishments), civil landscaping, civil infrastructure, civil engineering, and mining. Diversified property group - developing and managing a portfolio of residential community, apartment, retirement living, retail, office and industrial assets. Residential property, masterplanned communities, some commercial property Urban planning, growth and infrastructure: planning, environment, design and survey Diversified property trust with quality property across various real estate sectors. The ownership, management and development of Australian retail, office and industrial property.

Global

National, plus Vietnam National, plus UK National National National

The study identifies indications of each company’s commitment to CSR by referring to the seven main areas of activity identified through the 2005 Ashridge Business School study.20 While the classes of activity associated with these areas of CSR are not exhaustive, 31 activities are noted. CSR commitments of these companies, as expressed on company websites, are summarised in the tables in Appendix 1.

Discussion

The website scan documented in Appendix 1 reveals that these companies are variously engaging in and aware of CSR and that this is impacting on the way they conduct business and their workplaces. As a scan, the findings are not conclusive and there is some value in further exploring each company’s use of CSR. For example, it is worth nothing that GPT, one of the companies appearing to have one of the highest commitments to CSR, is a participant in the Corporate Responsibility Index. In a 2008 report of the Sixth Corporate Responsibility Index, the company’s scores measuring performance using that index were 74-% in five areas with two higher ratings in corporate strategy and assurance and disclosure.21 Of these eight companies:



Three maintain offices globally

20

Ashridge Centre for Business and Society, A Catalogue of CSR Activities, Ashridge Centre for Business and Society, Berkhamsted, 2005, passim Corporate Responsibility Index, Sixth Corporate Responsibility Index: 2008 Index Results, Corporate Responsibility Index, published May 2009, retrieved 5 August 2009, http://www.corporate-responsibility.com.au/sites/default/files/2009-cri-results.pdf 21

4



Two maintain at least one international office



Three have offices only in Australia (and two are known to service international markets).

This is indicative of the trend in internationalisation and decentralisation of markets and capital,22 and also highlights how global companies can respond to local community needs (e.g. RPI, global profit/local value). Fewings asks whether voluntary or self-regulated CSR “is a complementary or fairer system than the current dependence on the planning system to guide compliance to a more sustainable built environment”.23 That is, is it sufficient in terms of CSR or corporate citizenship for companies to just comply with statutes and regulations rather than create additional opportunities for sustainable, innovative, integrated and responsible corporate activity? If companies are expected to ‘do more’ then should that be voluntary or legislated?24 ‘Doing more’ is a repeated refrain in discussions and definitions of CSR, for example, [CSR means] private firms doing more than they are required to do under applicable laws and regulations governing the environment, worker safety and health, and investments in the communities in which they operate.25 (my italics) As companies are expected to ‘do more’ than is legally required, they are also moved to be more innovative in their CSR programs and capability, particularly as planning reforms increasingly respond to sustainability considerations. Longstaff argues that: No matter how much they [developers] might argue that they are just responding to “market forces”, the economic realities of their industry or the planning requirements of local government, they cannot escape ultimate responsibility for the way in which they shape the world in which most of us live. As such, developers have a particular

22

S Lash & J Urry, The end of organised capitalism, Polity, Cambridge, 1987, passim Fewings, 2009, 300 24 For example, Kelly, 2003, proposes that “voluntary change is not enough”, while Campbell, 2006, as Chen & Bouvain report, “argues that corporations are more likely to behave in a socially responsible way, the more they encounter strong state regulation, collective industrial self regulation, NGOs, and other independent organizations that monitor them and a normative institutional environment that encourages socially responsible behavior.” M Kelly, The divine right of capital: dethroning the corporate aristocracy, Barrett-Koehler Publishers, San Francisco, 2003, 148; S Chen & P Bouvain, “Is Corporate Responsibility Converging? A Comparison of Corporate Responsibility Reporting in the USA, UK, Australia, and Germany”, Journal of Business Ethics, vol 87, 2009, 303 25 PR Portney, “Corporate social responsibility: an economic and public policy perspective”, in B.L. Hay, RN Stavins and RHK Vietor (eds), Environmental Protection and the Social Responsibility of Firms: Perspectives from Law, Economics, and Business, Resources for the Future, Washington DC, 2005, 108 23

5

responsibility to be clear about the values that they bring to the development process.26 In other words, the company should be “held responsible for the effects of its actions”27 if it seeks a license to operate. Devinney’s warnings about the need for domain specification in CSR - in terms of identifying societies and responsibilities determined by the needs and demands of those societies - are especially relevant for the development industry given its role in shaping human settlements.28 Several companies – Lend Lease, GHD, Stockland and GPT – include more detailed information about CSR on their websites, such as strategies and plans, and CSR appears internalised by the company’s culture. An assumption is that these companies also dedicate more resources to their CSR or there are internal CSR champions. Devine, a residential property developer, and Watpac, a major infrastructure developer, do not provide significant detail about their CSR commitments. This indicates that these companies are at different stages of CSR development and this is akin to Zadek’s formulation of first, second and third generation corporate citizenship.29 All websites provide indications that the companies have set their compasses30 and are leaning towards CSR-like initiatives and values, with several couched in sustainability terms rather than CSR.31 Environmental commitments across these companies are prioritised with several companies demonstrating their commitments in publicly available actions plans and performance reports. Other CSR indications include: •

Possible collaboration with suppliers, clients and markets about the social and environmental sustainability of products, projects and activities



Supporting the community through their development activities



Establishing grant giving programs or foundations.

26

S Longstaff, ‘Urban development matters’. St James Ethics Centre, Sydney, 1997, retrieved 26 July 2009. http://www.ethics.org.au/about-ethics/ethics-centre-articles/ethics-subjects/architecture-and-urban-development/article0037.html. Echoing arguments for CSR, Longstaff foregrounds issues such as stakeholder engagement and disclosure (transparency) as pivotal for the development industry. 27 Kaptein & Wempe, 2002, 124 28 TM Devinney, “Is the Socially Responsible Corporation a myth? The Good, the Bad and the Ugly of Corporate Social Responsibility”, Academy of Management Perspectives. May, 2009, 54 29 S Zadek, The Civil Corporation: the new economy of corporate citizenship, Earthscan, London, 2001, 73ff 30 Kelly, 2003, 146 31 This stands in contrast to Birch’s 2002 study about corporate citizenship in Australia in which he concluded that environmental issues played a marginal role in a company’s understanding of corporate citizenship. This indicates a corporate cultural shift, possibly due to escalating concerns about sustainability since 2002. D Birch, “Corporate Citizenship in Australia: Some ups, some downs”, Journal of Corporate Citizenship, Issue 5, Spring, 2002

6

Workforce activities generally focus on health and safety with indications that companies provide support and training for their employees and, in at least two, volunteering opportunities. The values statements and codes of conduct of the companies also indicate commitments to diversity, integrity and the like as integral to company culture. This can be interpreted as awareness of values-based leadership32. The inclusion of these statements indicates the companies are promoting ethical organisational cultures and communicating how they ‘do culture’.33 While diversity can be acknowledged in company values and supported in the workplace, there is only one specific acknowledgement of Indigenous people as traditional owners or as beneficiaries of CSR initiatives. GPT has allocated resources for improving the health and wellbeing of Indigenous communities. Other development companies have not considered cultural protocols, community partnerships and Reconciliation (e.g. Reconciliation Action Plans34) in their CSR. However, the Planning Institute of Australia is currently drafting a Reconciliation Action Plan. Two companies have also indicated their involvement with or otherwise refer to the Global Reporting Initiative,35 a widely used sustainability reporting framework, while others appear unstructured in their approach to and communication of CSR initiatives. The Global Reporting Initiative provides a sector supplement for the construction and real estate industry, highlighting key priorities for developers.36 Other involvements include the UNEP’s Sustainable Buildings and Construction Initiative (SBCI)37 and Principles for Responsible Investment (PRI).38 Pivo describes Responsible Property Investment as CSR for the property sector39 which has particular significance in orienting development and/or investment activity to responsible development.40

32

R Barrett, Liberating the Corporate Soul: Building a Visionary Organisation, Butterworth-Heinemann, Boston, Mass., 1998, 2 D Birch & M Glazebrook, ‘Doing business – doing culture: corporate citizenship and community’ in S Rees & S Wright (eds), Human Rights, Corporate Responsibility: a dialogue, Pluto Press, Sydney, NSW, 50 34 Reconciliation Australia, Reconciliation Action Plans, Reconciliation Australia, retrieved 29 July 2009, http://www.reconciliation.org.au/home/reconciliation-action-plans 35 Global Reporting Initiative, Netherlands, retrieved 4 August 2009, http://www.globalreporting.org 36 Global Reporting Initiative, Supplement for Construction and Real Estate, Global Reporting Initiative, Netherlands, retrieved 4 August 2009, http://www.globalreporting.org/ReportingFramework/SectorSupplements/ConstructionandRealEstate 37 Sustainable Buildings and Construction Initiative, retrieved 4 August 2009, http://www.unepsbci.org 38 Principles for Responsible Investment, retrieved 4 August 2009, http://www.unpri.org 39 RPI is defined by Pivo as “making and managing property investments in ways that go beyond compliance with minimum legal requirements in order to better manage social and environmental issues. The goal is to help solve societal and ecological problems while also managing their associated business risks and opportunities.” G Pivo, “Responsible property investment criteria developed using the Delphi Method”, Building Research and Information, vol 36, no 1, 2008, 21. 40 For example, see L Carroli, “Community Benefits Agreements: Grounding Equitable Development in Negotiation”, 2009, http://flytrapper.yolasite.com/community_benefits.php 33

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Some company websites include information about measuring and improving project performance. This means ensuring the social and environmental impacts/risks of projects are mitigated and well managed. In a development context, such concerns are also embedded in statutory planning, raising the issue of how companies negotiate their CSR beyond legal obligations. In this sense project delivery, supply chain, service provision and CSR are interleaved.41 The results indicate there is need for some of these companies – Devine and Watpac in particular - to consolidate their CSR commitments and/or communicate their CSR commitments. In so doing, CSR is understood as integral to the operations, policies and decision-making of the company.42 An assumption is that companies have inadvertently ‘fallen into’ CSR by adopting sound governance, risk management and HR practices to maintain competitiveness through staff retention and organisational development. If ‘doing more’ is expected of corporations, then those organisations must formalise their CSR commitments so that results can be demonstrated across operations, projects and products. Unless the activities and their impact are measured or monitored, they cannot be meaningfully improved or accounted for, particularly in terms of correlating CSR to market performance.

Conclusion

This essay has provided an introduction to the use of CSR in eight major development companies by scanning the CSR commitments of those companies, as expressed on company websites, and situating those within a broader discussion of CSR and the development industry. From this study, challenges of CSR for development companies and their workplaces may include:



Exerting influence in the marketplace and supply chain



Adopting responsible property investment



Formalising CSR within companies and across the industry



Use of the planning system to enhance CSR



Reporting, monitoring and improving CSR



Harnessing workforce creativity and innovation

41

This also represents a further research opportunity, perhaps to undertake a comparative study of several planning consultancies and identification of how company values can drive planning or project outcomes. With some companies endeavouring to generate CSR impact in the marketplace and supply chain, it could be valuable to chart their spheres of influence in the sector. 42 Birch, 2003, 13ff

8



Adaptation to new economics and organisational models



CSR blueprints and agendas for small to medium development companies



Continuing CSR development from philanthropic modes to integration and innovation43 (for example, how products are taken to market, such as innovative financing options for low income earners, and how products respond to social and environmental issues, such as the reinvention of suburbs for walkability and place management)



Developing and adopting industry-wide and industry-specific CSR guidelines, business case and/or accounting methods.

Through its interaction with the planning system, the CSR in the development industry, and individual companies therein, has a specific role to play in the urban environment and its governance which may, applying systems thinking, result in feedback or causal loops of change and adaptation.44 In a study of inner urban renewal, CSR is regarded as “vital ... to achieve sustainable, civic and accountable systems of urban governance through which urban regeneration can be realised”.45 The prevailing economic dynamics of the late 20th century (fin de siecle era) have been described by many urbanists as neo-liberal46 which marks the urban environment through gentrification, privatisation, diminished social capital, and intractable urban problems. In response, others call for a renewal of hope in the urban and suburban domains.47 While CSR in the development industry may be integral to the pursuit of sustainability both within and external to individual companies, it may also eventually be vital to the fitness of companies and human settlements as new social ecologies and complexities emerge and for corporate adaptation, resilience and survival into the future.

43

M Halme & J Laurila, “Philanthropy, Integration or Innovation? Exploring the Financial and Societal Outcomes of Different Types of Corporate Responsibility”, Journal of Business Ethics, vol 84, 2009, 329. Also, Innovations such as the Melbourne Model have also emerged which enables business, government and civil society groups to jointly tackle urban issues in a mutually beneficial and sustainable manner. Its approach of all-sector collaboration emerges from two observations: “first, that current corporate social responsibility (CSR) activities are generally ineffective in harnessing the true capacity inherent in the private sector to help resolve systemic issues; and, second, that there is a growing public frustration with existing forms of governance which seem unable to develop efficient and effective solutions to emerging and pressing urban problems.” See D Teller, “The Melbourne Model and its All Sector Taskforces: Theoretical Framework and Delivery Mechanism for the United Nations Global Compact Cities Programme (UNGCCP)”, Journal of Corporate Citizenship, vol 26, Summer, 2007, 47 44 P Senge, The Fifth Discipline: The Art & Practice of the Learning Organisation, Currency, USA, 2006, passim 45 J Gannon & G O’Brien, The Role of Corporate Social Responsibility in Urban Regeneration, unpaginated, retrieved 2 August 2009 http://www.thefuturesacademy.ie/sites/default/files/CSR-in-urban-regeneration.pdf 46 See, for example, J Hackworth, The Neoliberal City: Governance, Ideology, and Development in American Urbanism, Cornell University Press, New York, 2006; B Gleeson, and NP Low, N.P. Australian urban planning: New challenges, new agendas, Sydney, Allen and Unwin, 2000 47 See, for example, B Gleeson, Australian heartlands: Making space for hope in the suburbs, Sydney, Allen and Unwin, 2006; D Harvey, Spaces of Hope, Edinburgh University Press, Edinburgh, 2000

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Appendix 1 Summary of CSR Commitments of Development Companies: Table A Note: Yes = affirmative commentary on website Blank = no commentary on website Indicative = commentary on website indicates a commitment; maybe Company

Marketplace activities

Workforce activities

Supply chain activities

Stakeholder engagement

Community activities

Lend Lease

Leadership, vision & values Yes

Yes

Yes

Yes

Yes

Yes

Environmental activities Yes

GHD

Yes

Yes

Yes

Indicative

Yes

Yes

Yes

Laing O'Rourke Watpac Stockland Development Devine Conics GPT

Yes Yes Yes

Yes Indicative Yes

Yes Yes Yes

Indicative Yes

Indicative Indicative Yes

Yes Indicative Yes

Yes Indicative Yes

Yes Yes Yes

Indicative Yes

Yes Yes Yes

Indicative Yes

Indicative Yes

Indicative Yes Yes

Indicative Yes Yes

Notes

Notes Global Reporting Initiative & other indices Extensive program of Sustainability aspirations and initiatives across economic, environment and social priorities Aims for compliance with UN Global Compact 10 Principles member of the World Business Council for Sustainable Development and Australian Green Infrastructure Council

Corporate Responsibility & Sustainability Strategy Sustainability Policy and Strategy Corporate Responsibility Strategy Participates in Global Reporting Initiative

10

Summary of CSR Commitments of Development Companies: Table B

Leadership, vision & values Purpose, values and vision Policies & procedures Putting into practice Ethical leadership & championing Marketplace activities Customer relations Product responsibility CR product labelling Ethical competition Making markets work Workforce activities Employee communication & representation Employability and skills development Diversity & equality Responsible / Fair remuneration Work-life balance Healthy, safety & wellbeing Responsible restructuring Supply chain activities Fair customer Social & environment standards in supply chain Stakeholder engagement Mapping key stakeholders Stakeholder consultation Responding to and managing stakeholders Transparent reporting & communication Community activities Financial donations Volunteering employee time

Lend Lease

GHD

Laing O'Rourke

Watpac

Stockland Development

Devine

Conics

GPT

Yes Yes Yes Yes

Yes Yes Yes Yes

Yes Yes Yes Yes

Yes

Yes Yes Yes Yes

Yes

Yes Yes Yes Yes

Yes Yes Yes Yes

Yes Yes Yes

Yes Yes Yes

Yes Yes

Indicative Indicative

Yes Yes

Indicative

Indicative Indicative Indicative

Yes Yes Yes

Indicative

Yes

Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes

Indicative Yes

Indicative

Yes

Yes Yes Indicative

Indicative Indicative Indicative

Yes Yes Yes

Indicative

Indicative

Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes

Yes

Indicative

Indicative

Yes

Yes

Indicative Indicative Indicative

Yes Yes Yes Yes Yes

Indicative Indicative

Yes Yes Yes

Yes Yes Yes Yes Yes

Yes

Indicative Yes Yes

Yes Yes

Indicative*

Yes Yes

Indicative Indicative*

Yes Yes

Yes Yes 11

Giving gifts in kind A good neighbour Environmental activities Resource and energy use Pollution & waste management Environmental product responsibility Transport planning

Indicative Indicative

Yes Yes

Yes Indicative Yes Indicative

Yes Yes Yes Indicative

Yes Yes Yes Yes

Indicative Indicative Indicative

Yes Yes Yes Indicative

Indicative Indicative Indicative

Indicative

Yes

Yes Yes Yes Indicative

Yes Yes Yes Indicative

*There are indications on the websites that there is some attention to community activities but it is unclear how this is undertaken. For example, Devine published a press release indicating that it presented a ‘community day’.

12

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