Corporate Social Responsibility - Research Paper Example

 Table of Contents 1.0 Introduction 4 2.0 Historical Developments 5 2.1 CSR during 60s 5 2.2 CSR during 70s 6 2.3 CSR during 80s 7 2.4 CSR during 90s 7 2.5 CSR during 2000s 9 3.0 Interpretation (and Understanding), Disclosure and Theoretical Debate 10 3.1 Interpretation and Understanding of CSR 10 3.2 Disclosure of CSR 15 3.3 Key Theoretical Issues of CSR 17 4.0 CSR Model Design 18 5.0 Challenges towards CSR 22 5.1 Code of Conduct 22 5.2 Guidance 23 5.3 CSR Accountability 25 6.0 Evidences of Corporate Governance and Ethics Embedment 26 26 7.0 CSR in Action 28 8.0 Conclusion 29 References 30 Bibliography 35 1.0 Introduction Corporate Social Responsibility (CSR) has evolved as a significant activity for businesses, both nationally as well as internationally. As globalisation accelerates and all big corporations act as global providers, several benefits have been recognised by these corporations for conducting CSR programmes in their different locations. The rationale for CSR has been about building sustainable businesses that require healthy economies, communities and markets (Asian-Occasion Computing Industry Organization, 2004). CSR has been recognised as that responsibility of business houses that are relevant for acting in socially responsible way. The concept of CSR is linked to the process of business decision making related to ethical values, respect for people, legal compliance, environment and community. CSR is that aspect of business which induces a company for going further than it is demanded by law. The following dimensions are significant in requirements for success of CSR: Treatment of employees with respect and fairness Operate in an ethical manner and with integrity in its business deals with suppliers, customers, lenders and others Respect the rights of human beings Sustaining environment for generations to come Become a responsible neighbour within society along with evolving as a fair ‘corporate citizen’ (The Economist Intelligence Unit, 2005) CSR has evolved as the latest buzz word to which companies are getting attentive. Governments are also keen on the aspect that companies follow CSR since social welfare has become the responsibility of both private and public sector. CSR should be viewed by the corporate as being guided by social conscience and not by force of any external sources. Considering the level of importance of CSR, this research study has been undertaken that will deal with the entire perspective of the concept in today’s corporate world. 2.0 Historical Developments The concept of CSR is not new to the world as it has evolved since the concept of business has started. CSR is such a principle that reviews that corporate have responsibility towards society apart from the objective of profit maximisation. CSR has emerged throughout the years and has evolved as an important part of corporate. The historical development of CSR will be presented with respect to its perspectives of growth and development from the period during 1960s till the present time. 2.1 CSR during 60s An organisation for economic cooperation and development was created when OECD Convention was signed in Paris on 14/12/60 and came into effect on 30/9/61. The convention was created for promoting policies that were designed on achieving three important objectives. The first objective was to achieve the highest level of sustaining economic growth along with employment and an enhanced standard of living in the member countries. It was also aimed to maintain stability in financial perspectives and as a result contribute towards the overall development of the international economy. The second objective was to contribute towards expansion in economic sector in both the member and non-member countries in the development process. The third objective of the convention was to contribute towards world trade expansion on the basis of multilateral and non-discrimination according to international obligation (Katsoulakos & Et. Al., 2004). 2.2 CSR during 70s The first ‘Earth Day’ was held in the year 1970 as an environmental awareness campaign on national basis. It was a successful campaign in which around twenty million people participated from all over the USA. During the same year, the first major NGO ‘Greenpeace’ was set up that shifted the emphasis on the concept of CSR more towards corporate sector compared to the governments. During late 70s, a book “Quest for a Sustainable Society” was published that initiated that there is another dimension of growth apart from business growth. The book emphasised social responsibility as an alternative of growth (Katsoulakos & Et. Al., 2004). 2.3 CSR during 80s During the year 1980, IUCN (World Conservation Union) released the “World Conservation Strategy” as a modified version of biosphere and implementation of human, living and non-living and financial resources for satisfying the needs of human beings and develop human life quality. During the year 1982, “business in the community” was founded by business organisations based in the UK that completely focused on CSR. The Brundtland Commission introduced the new definition of sustainable development that explained the term as that development which meets the present needs not at the price of future generation’s ability to satisfy their own needs. During the end of this period, the concept of “natural capital” was introduced along with defining sustainable development as “non-declining per capita human well-being over time” (Katsoulakos & Et. Al., 2004). 2.4 CSR during 90s In the year 1991, “Earth Summit” addressed ways for halting the devastation of natural resources and planet pollution. Agreement was laid by the summit on the Rio Declaration on Environment and Development that provided 27 principles in support to the concept of sustainable development. Agenda 21, a plan of action was also agreed by the summit along with a recommendation that every country of the world would produce strategies for sustainable development in national perspective. The establishment of the UN Commission on Sustainable Development was also taken up by the summit. During the end of 90s, Global Sullivan Principles were launched. On 31st January, 1999, United Nation Secretary, General Kofi Annan challenged the leaders of business in an address to The World Economic Forum that instigated the leaders to join an initiative in international level that aims towards bringing the UN agencies together. The civil and labour society was initiated to support certain principles in the areas of environment, human rights and labour (Katsoulakos & Et. Al., 2004). 2.5 CSR during 2000s During the year 2000, the UK Pension Act was amended that necessitated the schemes on occupational pension to disclose their policies on investment in socially responsible variables in their Investment Principles Statement. Till the year 2004, there were above 60 initiatives of the government relevant to CSR. The Parliament of the UK had two groups on all-party on corporate citizenship: the All-Party Parliamentary Group on CSR and the All-Party Parliamentary Group on Social Responsible Investment (Katsoulakos & Et. Al., 2004). With respect to the historical developments of CSR discussed above, the period from the year 1960 to 1990 is termed as “CSR Initiation Phase”; the period from the year 1990 to 2000 as “CSR Momentum Building Phase” and the period form the year 2000 onwards is termed as “Mainstream Initiation Phase”. Source: (Katsoulakos & Et. Al., 2004). 3.0 Interpretation (and Understanding), Disclosure and Theoretical Debate CSR is indulged in disclosing facts to huge range of stakeholders apart from investors and shareholders. Concerned with the concept of CSR, important areas are well-being of employees and protection of environment along with well-being of society and community. CSR concept is underpinned by the visualisation that corporate cannot act as a separate entity of economies. Thus, the corporate cannot operate in isolation from the broader society. In this section of the research paper, comprehensive understanding of the concept of CSR will be presented along with reference to several theoretical perspectives from present literatures. 3.1 Interpretation and Understanding of CSR Preliminary understanding of the concept of CSR can be undertaken with respect to certain contemporary issues in social aspects which are associated with CSR. The issues are environmental, global and technological issues. Although corporate are faced with various issues and problems, these issues will be discussed as they are found to be directly related to corporate operations. Environmental Issues There has been long criticism on the corporate action which mentions that the corporations have negative impact on the natural environment. The negative impact is in terms of contribution towards various environmental problems such as that of global warming and pollution and also in terms of wasting natural resources. The operation that normally contributes to global warming is the use of fossil fuels. In view to all these, there are both societal and governmental pressure on corporations inducing them to adhere to stricter standards of environment and production processes of voluntary changes aimed towards doing less harm to the environmental factors. Other environmental issues that gave rise to CSR standards include deforestation, land degradation, waste disposal and acid rain. It is possible that responsibilities of the corporate towards this area will increase in the future days (The National Academy Press, 2011). Global Issues In the recent business world, corporations operate increasingly in a global environment. Business globalisation has evolved as an irreversible trend, but there are several opponents to it. According to the perception of critics, globalisation exploits workers and developing nations, increases abuses of human rights and destructs environment. They have also put forward that globalisation leads to benefits of wealthy people and increases the gap between the poor and the rich. On the other hand, proponents of globalisation argue that it leads to enhanced standard of living of the people along with workers’ higher wages and economic development. However, the supportive and opposing issues towards globalisation do not reduce the fact that corporations that operate globally are faced with several societal issues. Among those issues, the most important is that of labour standards across various countries of the world. The problem related to this issue is complex because social standards and anticipations of working conditions along with children employment vary up to a massive standard across the world. Corporations frequently face the problem of deciding which standards to select. Another important issue in the global business is that of marketing goods and services. These concerns related to the globalisation have also contributed largely to the evolution of CSR (Taking IT Global, 2011). Technological Issues Another important contemporary issue in CSR is that of technology and its impact on society. For example, with the opening up of internet, several new avenues were opened up for marketing goods and services but at the same time, it has also led to the chances of mistreatment by corporations. Issues in this respect that needs to be addressed are that of privacy and security of information which are confidential in nature for the corporations. With the advancement of technological capabilities, it is expected that responsibilities of the corporations in this area will dramatically increase in the future. Corporations are even faced with their internal operations. For example, biotechnology firms are faced with questions related to use of genetic engineering, embryonic stem cells and cloning (Arora & Dharwadkar, 2011). 3.1.1 Driving Issues for Corporate towards CSR Research suggests various issues that are considered as drivers inducing business towards corporate social responsibility and those issues include the following: Government’s Shrinking Role During the past years, there was heavy reliance of governments on regulations and legislations for delivering environmental and social objectives in the business sector. Over the years, resources of the governments had shrunk along with growing distrust on regulations. The consequences of all these aspects have led to the discovery of voluntary and non-regulatory initiatives. For handling the situations prevailing at this stage in the world, concept of CSR has evolved throughout the years. Greater Disclosure Demand CSR has resulted from growing demands from stakeholders including suppliers, communities, employees, investors, customers and activist organisations for corporate disclosure. This growing demand from the stakeholders has resulted in formation of CSR accountability. Increased Interest of Customers There is evidence that purchasing decision of consumers is greatly influenced by companies’ ethical conduct. Surveys related to this perspective suggested that consumers increasingly reward or punish companies on the basis of their perception regarding the companies’ social performance. As consumers are perhaps the most important entity in companies’ success, for satisfying them, CSR has been initiated. Growing Pressure of Investor In recent times, there has been a shift of investors’ assessment of the companies’ performance. They now make decision on ethical criteria. According to the report of Social Investment Forum, in the year 1999 in the US, there were above $2 trillion of assets that were invested in portfolios using screens linked to social responsibility and environment. Competitive Labour Market Employees at present looks beyond benefits and pay checks and seek out employers whose operational practices and philosophies match with their own perceived principles. For recruiting and retaining skilled employees, companies are inducted to use improved working conditions. Relations with Suppliers With the suppliers becoming more and more interested in business affairs, several companies are aiming towards ensuring that their partners’ operations are conducted in a manner which is socially responsible. Several companies, for their suppliers, have introduced codes of conduct for ensuring that policies and practices of their companies do not harm their reputation (International Institute for Sustainable Development, 2010). 3.2 Disclosure of CSR Undertaking of responsibilities towards society and environment is not just enough for corporate, the responsibilities require proper disclosure as well. Corporations indicate their reputations and enhance their image through disclosure of CSR. Research indicates that many publicly held listed companies use the annual report for the purpose of disclosing activities related to CSR. The annual report of corporations has evolved more than just a compulsory financial report depicting financial performance of the companies. Several companies also use the financial reports as an effective tool of marketing communication. Companies disclose their CSR activities through annual reports because it has become an important issue in the world of business. However, research on the disclosure of CSR activities of companies show that the level of CSR disclosures for different organisations are different. This is because while certain companies engage themselves in disclosing activities, others do not bother to do so. CSR is broadly defined as that aspect of corporations which include concern for impact of corporations’ activities on the society’s total welfare. This perspective of CSR suggests that companies are influenced by its own activities and has greater influence upon the society in which it operates. CSR disclosure is that process of information provision that is designed to publish social accountability. Typically, the act of disclosure is undertaken by a responsible organisation and hence may be inclusive of information in the annual report, socially oriented advertising or even special publication. CSR disclosure is reviewed as that method through which management gets a chance of interacting with the broader society for influencing perceptions of their companies on the part of outsiders or stakeholders. While it solely depends on companies to voluntarily disclose their activities of CSR, there might be social benefits associated in communication of these activities to various publics such as employees, suppliers, media, shareholders and government. Companies that have section of CSR in their annual report communicate their CSR strategy in one form or other such as a vision statement, set of guidelines and/or information on a CSR committee. A vision statement can be an effective tool for communicating CSR objectives both internally as well as externally. For example, Havas discloses a statement that represents company’s importance towards “civic and corporate social responsibility”. The most important CSR issues that companies disclose are related to work output, activities of HR, commitment of social or community and initiatives towards the environment (Walker & Lanis, 2007). Various researches on the CSR disclosure of public listed companies showed that there prevails extreme diversity in information provided and format depicted during disclosure. However, one common trait can be observable among companies that they mostly disclose information about employees, consumers, products and community involvement. It was even observed that disclosures of CSR involve certain quantifiable data. Various natures of companies’ disclosure suggest certain preliminary evidences that through CSR disclosures, companies might attempt to improve their corporate image and represent themselves as responsible corporate citizen of the nation (Ahmad & Et. Al., 2003). 3.3 Key Theoretical Issues of CSR Important theoretical perspectives of CSR will be presented in this following section. These will not be presented in the form of an objective theory but through integrated thinking in the area of corporate social responsibility. Capitalism There are certain important issues in the capitalism approach of CSR. The issues comprise of more involvement of strategic community along with their engagement and involvement. Second important capitalism issue is that of long term partnership of community and business. Thirdly, it consists of greater engagement and dialogue of stakeholders and finally compliance with increasing regulation and legislation in CSR, corporate governance and related issues. Throughout history, several companies have always kept themselves engaged with some or all of these capitalism issues. The concern is that, if capitalism has remained to be the only feasible economic system in the developed world of today then there should be strong emphasis towards sustaining that capitalism through more environmental and social responsibility. Sustainable capitalism requires change in cultural activities of companies and CSR has evolved as an effective means of bringing a change in generic activities of companies (Mele, 2011). Business is a Social Enterprise A corporate business is termed as a “visionary company” and depends on a set of timeless values and a continuous purpose of operations that is beyond just making money. This has evolved as a key principle of CSR discussion and a key principle for companies that seek to build sustainability as that “continuous purpose”. The essence of this theory is that companies are required to change in a dynamic way for responding to external dynamic environment but at the same time needs to preserve its purposes and core values. According to the believers of this perspective, businesses need mechanism of progressing forward, entrepreneurship and experimentation or continuous improvement of their own activities. Businesses need to develop consistent alignment for maintaining its purpose and core values and at the same time enhance progress. However, above all these aspects, businesses need to perceive resilience and capability of bouncing back from adverse situations. These issues are at the heart of corporate citizenship, CSR debates and sustainability at present times (Birch, 2003). 4.0 CSR Model Design CSR model should represent operational capabilities of a business that develops and continuously engages all stakeholders. The CSR model designed is applicable for SMEs because this model represents businesses that have commitments to social and environmental goals along with achievement of tangible financial results. Achievement of social and environmental goals has been presumed to be perceived by companies with equal eagerness towards profit. In developing this model, it has been assumed that executives in companies’ senior ranks, who decide on CSR, feel good when they perceive a chance of giving back to their communities. In fact, the executives perceive this aspect to be a part of their responsibility as professionals. It is uncommon but still true that there are certain companies which view their business form in terms of its environmental and social contributions (Redman, 1995). Source: (Geva, 2008). The above figure shows the level of perception that those companies hold about certain perspectives of their economy. The companies provide philanthropists the topmost priority and these are those companies where CEOs are bonded with deep personal fervour. They love human beings, hold sincere value for them and keep themselves aware of the fact that organisations cannot work without personnel. The next priority provided by these companies is ethical perspective of society. Ethics demand complete transparency on the part of CSR issues of the companies. The ethical perspective demanded from the companies is initiated by the stakeholders or the persons related to and interested in companies’ activities. The legal and economic perspectives are then primarily maintained for arriving at success in the above two respects. With respect to the demands initiated by the stakeholders, proper identification of goals should be undertaken that would achieve not only the social and environmental responsibilities but at the same time will satisfy the financial demands of the stakeholders. Thus, a new concept can be instigated through this perception of the companies: the model of multi-firm goals. Identification of goals would result in forming CSR strategies for fulfilling the goals. The strategies in turn should provide accountability to the entire legal standards and proceedings so that no opponents can ever interfere in smooth organisation of CSR operations. After comprehensive strategies are formulated by taking multi-firm goals into consideration, proper disclosure is essential. Disclosure can be easily undertaken in the financial reports published every quarter. Financial reports are effectively utilised by companies perceiving CSR activities for informing their stakeholders, which is evident from the findings in the above sections about disclosure. Disclosures should be presented in such a manner that it influences investors and satisfies stakeholders. The final and perhaps the ultimate step developed in the model is that of the achievement of multi-firm goal or the intermingled financial goals with that of social and environmental goals. However, the model does not provide assurance of achieving the multi-firm goals as the success of socially oriented firms is not clear. The problem with follow up of this model is that for achieving both financial benefits along with social and environmental benefits, policymakers should consider the present indices. However, this model demands educating business owners and managers about the responsibility as corporate citizen apart from taking the present indices into account. Along with this knowledge, it is also required that companies understand value creation and thus boosts success definition to triumph over social and environmental perspective. CSR Model Design 5.0 Challenges towards CSR The challenges accountable for companies with respect to their CSR activities revolve around their ability to comply with the codes of conduct and guidance of CSR. There are certain requirements that companies must adhere to beyond just voluntary disclosure initiated by stakeholders’ pressures. Those requirements will be presented with reference to code of conduct such as AA1000 and guidance such as GRI G3. 5.1 Code of Conduct Accountability 1000 (AA1000), a work of ISEA (Institute for Social and Ethical Accountability) is promoted as a standard for reporting and measurement of ethical practices across businesses. A framework is provided by AA1000 which organisations can use for understanding and as a result improve their level of ethical performances. The framework also provides a means for all to judge the legitimacy of the claims in order to be ethical. The code of conduct depicted in this framework for companies assists in defining goals and targets, controlling progress, reporting and auditing performances and establishing mechanisms of feedback. In each of the processes, stakeholders’ involvement is crucial. AA1000 is used for underpinning the standard quality of specialised accountability and can be also used as a system of stand-alone. The standard or the code of conduct is formulated for both internal as well as external procedures of auditing and at certain times act as challenge for companies. The entire procedure can be used by any organisation, no matter big or small, private, public or non-profit organisation. It is believed that organisations which mostly adhere to these standards are expected to earn more profit than those which does not adhere to (Mallen Baker, 2011). 5.2 Guidance The guidance for companies related to CSR activities will be presented with respect to “document CSR performance with GRI G3 Guidelines”. GRI G3 guidelines are a framework treatment of sustainability initiatives for stakeholders. The guidelines provide means to companies for determining measure and progress report towards goals of sustainability and include evaluation of economic impact, environmental impact and impact of human rights. The framework in GRI G3 guidelines determines content of report, qualities and boundaries. For undertaking a review of sustainability and completing the report, the companies are required to determine the content along with quality and boundaries. The report should represent fields of societal, economical and environmental impact that the company has on the community. Issues addressed in the report should have the stakeholders’ considerations and must answer logical questions from the stakeholders about the effect of operations. Companies that utilise the guidelines are required to disclose the level of application of the guidelines used. The application level ranges from A to C and companies achieve the level based on their capabilities of compliance to all the requirements of guideline framework. Thus, it is a challenge for the companies to achieve higher level than their competitors for gaining competitive advantage (Lloyd, 2009). Source: (SEEP Network, 2009). The above table depicts the areas of critical challenges for companies in management of CSR and expectations of stakeholders. The dimension on the left hand side of the table represents the themes in CSR that needs to be adhered to and on the right hand side, issues have been represented that acts as challenges in handling the themes. 5.3 CSR Accountability Corporate accountability to CSR is initiated by greater involvement of stakeholders who are external to the organisational operations and it leads to an alternative form of company where superfluous resources are utilised by the companies for enhancing the communities’ social welfare. At individual firm’s level, the concept that received some degree of attention is that of ‘shareholder democracy’. Resolutions of shareholders during the past few years had led to certain questions about practices in corporate such as excess remuneration to the CEOs of companies or deficiency in providing transparency. Social movements constantly explore new arenas of accountability consisting of creating new institutes and developing alternatives to prevailing development dialogue. While NGOs play an important role towards deliberative democracy, a critical overview on CSR political economy does not suggest that NGOs bear the morality in regards to environmental and social issues. Civil society and NGOs though are not profit driven, their legitimacy and power need critical scrutiny along with their intentions and motives. The impacts of the governments and regulation aimed towards promotion of CSR could not achieve much attention since CSR activities are considered voluntary ones (Banerjee, 2008). 6.0 Evidences of Corporate Governance and Ethics Embedment This section of the research paper is aimed at supporting the above findings on impacts of CSR on the performance of companies which follows CSR values. The supporting materials will be provided in the form of evidence on the relationship of corporate social performance and various dimension of business. A research on the evaluation of relationship between financial and social performance suggests that enhanced performance of companies towards social responsibilities leads to increased returns on stock either through improvements on productivity and cost reduction or through enhancement of the firm’s standing that initiates the analysts for recommending the stocks and thus making the investors more willing of holding stocks irrespective of reviewing firms revenues and costs. Another study was conducted for evaluating the relationship by employing data from the US survey by Fortune for the period 1983-1996 and it was found that stocks of the firms which are mostly admired yielded abnormal profits of 3.2% in the following year when CSR activities are undertaken and also yielded 8.3% over the next three years (Brammer & Et. Al., 2005). Evidence from the perspective of China shows investigation on perception of managers and executives about CSR. It was observed that though a large portion of respondents consisting of executives and managers had a favourable view about CSR, it was observed that the real nature of their affirmation was inclined towards gaining benefits from the economic point of view. However, it was also found from the research that the CSR orientation of the managers was positively related to performance of their firms. The ultimate result is that for gaining benefits in whatever form it is, be it financial or economical, the Chinese firms indulge themselves in CSR activities (Zu & Song, 2008). 7.0 CSR in Action The action perspective of CSR will be presented in this section with reference to reports published on the CSR perspectives. An article from BBC News reports that in the present world consisting of socially aware citizen, it is next to impossible to find a multinational company that is not involved in activities related to CSR commitments. Over the years, CSR has evolved as such a concept which is omnipresent in virtual terms. This report suggests that the companies have moved beyond the sole focus on profit maximisation and towards a wide commitment for helping in building a better society in the whole world. For example, Salesforce.com, a software service company undertakes a policy of giving 1 percent of its profit, 1 percent of the time of its employees and 1 percent of its equities to non-profit organisations and charities. Even the tobacco manufacturers indulge in CSR activities. For example, Gallaher, the fifth largest cigarette maker follows a CSR policy which depicts that it would not buy tobacco from those developing countries of the world where practice of child labour prevails (Smale, 2006). IPC Media follows agenda on corporate responsibility that focuses mainly on three major respects: environment, community, action from employees and collective input. The corporate responsibility at IPC takes attention towards interaction of the companies with the wider community, specifically the local area of Southwark. The attention is also concentrated on engaging with those issues of the environment that has an impact on the industry. The organisations highly value their involvement and input of their employees inclusive of volunteering, participating in activities of raising fund and contributing towards ideas related to environmental benefits (IPC Media, 2011). 8.0 Conclusion From the research, it is evident that the concern towards CSR activities does deal with not only what companies do for maximising profits but also the process through which they make those profits. CSR is more than following the approach of philanthropy as well as legal or regulatory compliance for addressing the process through companies takes on their social, environmental and economic impact on the community. The companies at preset times are faced with various demands for getting engaged in private-public partnership. Stakeholders inclusive of consumers, employees, suppliers, policymakers, local communities, environment and the society at large want companies to be both accountable and transparent in their social performance. The research also suggests that social expectation from businesses is increasing. Although there are critics who argue that ultimate ethical responsibility of corporate is to maximise profit, this view will diminish in the coming years with the growing interest of companies in performing social responsibility. The debate over the concept of CSR has shifted up to a considerable extent and will shift further in the coming years. The concern now is inclined more towards how to do CSR than whether to do CSR. It can be well mentioned that stakeholders’ role in CSR success is of immense importance and will eventually grow in the future too. References Ahmad, N. N. & Et. Al., 2003. Corporate Social Responsibility Disclosure in Malaysia: An Analysis of Annual Reports of KLSE Listed Companies. IIUM Journal of Economics and Management. [Online] Available at: http://staff.ui.ac.id/internal/060603523/publikasi/111art3.pdf [Accessed March 19, 2011]. Arora, P. & Dharwadkar, R., 2011. Corporate Governance and Corporate Social Responsibility (CSR): The Moderating Roles of Attainment Discrepancy and Organization Slack. Blackwell Publishing Ltd. [Online] Available at: http://www.isb.edu/faculty//upload/Doc9320111458.pdf [Accessed March 19, 2011]. Asian-Occasion Computing Industry Organization, 2004. Cororate Social Responsibility. Policy. 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