Japan Forum of Business and Society Annals, No.10, pp. 41-55, 2021

41

Chinese CSR Report Rating――Symbolic or Substantial?

Xinwu HePhD Candidate in Accounting, Durham University Business School
Key words：Chinese CSR Report Rating, CSR reporting, CSR assurance, China, Case study【Abstract】
This case study examines the nature of the Chinese Corporate Social Responsibility (CSR) Report
Rating, a local CSR-related practice recently developed and provided by a government-affiliatedresearch institution. The past decade has witnessed the rapid growth of CSR reporting in China andthe development of the CSR Report Rating. However, the extant literature remains inconclusive
regarding (1) whether the Rating can effectively enhance the credibility of CSR reports and (2) why
Chinese companies, particularly State-owned Enterprises (SOEs), prefer the Rating. This paper fills
the research gaps through an engagement-based case study. Evidence collected for the case study
includes interview data and documents. A key finding is the symbolic nature of the Chinese CSR
Report Rating. It is more like an extension or a “variant” of CSR consulting, a mechanism forcompanies’ CSR strategy, and a business image enhancement tool, rather than an alternative to CSR
assurance.

porting on CSR has increased dramatically1.

Introduction

during the past decade. According to Yin etal. (2019), 739 Chinese companies reported CSR

The past decade has witnessed an increasing

in 2009, and the number increased to 2,089 indemand for corporate non-financial disclosures

2019. This increase has been primarily driven

from investors, shareholders, customers, andby governmental CSR reporting guidelines

other stakeholders (Shabana, Buchholtz, andsince 2008. For example, the State-owned As-

Carroll, 2017). The increasing demand has led

sets Supervision and Administration Commis-

to the proliferation of corporate social respon-sion of the State Council (SASAC)（1） publishedsibility (CSR)/sustainability reporting covering

Recommendations for Central Enterprises（2）an organisation’s economic, environmental,

on Fulfilling Social Responsibility (SASAC,

and social impacts and positive or negative

2008). The Recommendations encouraged Cen-

contributions to sustainable development (GRI,

tral Enterprises to establish CSR reporting2016). The number of Chinese companies re-systems. In 2009, the SASAC required all

Reviewed Article (Received February 13th 2021 / Accepted May 16th 2021)42

投稿（事例紹介・解説）/Reviewed Article (Case Study・General Review)

Central Enterprises to publish CSR reports

investigate the Chinese CSR Report Rating

within three years (Zhu, Liu, and Lai, 2016).

practice overlooked by the extant literature.

With the proliferation of CSR reporting in

It provides evidence through a fieldwork-

China, a local CSR-related practice has been

based qualitative study, responding to the calldeveloped: the Chinese CSR Report Rating

for more engagement research within CSR/

provided by the Chinese Expert Committee

sustainability accounting and accountability

on CSR Report Rating. This practice is broad-area (Adams and Larrinaga, 2019). Second, thisly regarded as a mechanism to enhance thestudy contributes to a comprehensive and nu-

credibility of CSR reporting. Many Chinese

anced understanding of the Chinese CSR Re-

CSR reporting companies, particularly state-

port Rating. It clears up the ambiguity about

owned enterprises (SOEs), adopt the Rating

the purpose and nature of the Rating by sug-annually. However, it remains unclear (1)gesting that it is more like an extension or awhether the Rating can effectively enhance“variant” of CSR consulting service rather

the credibility of CSR reporting and (2) why

than an alternative to CSR assurance. Third,

the Chinese companies prefer the Rating.

this study has important practical implica-

There is a lack of research exploring the na-

tions. The symbolic nature of the Rating im-ture, process, and effectiveness of the Chinese

plies that the credibility of Chinese CSR re-

CSR Report Rating within the extant litera-ports is doubtful. There is an urgent demandture.

for credibility-enhancing mechanisms (for ex-

This research examines the nature of theChinese CSR Report Rating and its effective-

ample, mandatory CSR assurance) for Chinese

CSR reporting.

ness in enhancing the credibility of CSR re-

The Reminder of the paper is organised as

porting. An engagement-based qualitative

follows. Chapter 2 provides a literature re-case study approach was adopted. The evi-view on the development of CSR reporting indence collected for the case study included in-China and the origin, purpose, and process ofterview data (primary data) and documentary

the Chinese CSR Report Rating. Chapter 3 de-data (secondary data). A thematic analysis ofscribes the research methods. Chapter 4 dis-the evidence was conducted. The findings re-cusses the findings from the case study analy-

veal that the CSR Report Rating is more likesis and highlights the Rating’s symbolic nature.

an extension or a “variant” of CSR consulting

The last chapter concludes this case study

service, a mechanism for companies’ CSR

with research contributions, limitations, andstrategy, and a corporate image tool, rather

avenues for further research.

（3）

than an alternative to CSR assurance . Therefore, its effectiveness in enhancing the credi-

2.

Literature Review

bility of CSR reporting is questionable.
This case study makes several contribu-

CSR reporting has recently become nearlytions. First, it represents an early attempt touniversally adopted and is considered theChinese CSR Report Rating

43

global norm (KPMG, 2020). China has achieved

CSR assurance worldwide has increased steadi-a CSR reporting rate of 78% in 2020, slightly

ly since 2005 (KPMG, 2020). Notably, few Chi-higher than the global average (77%) (KPMG,

nese companies currently invest in CSR as-2020). This higher-than-average rate marks asurance (KPMG, 2020). According to Yin et al.

significant growth of CSR reporting in China(2019), only 5.19% of the Chinese CSR reports

over the past decade, compared to the CSR

published in 2019 were assured. This low per-reporting rate (nearly 60%) in 2011 (KPMG,

centage reveals that most Chinese CSR re-2011). The development of CSR reporting in

porting companies are reluctant to invest in

China features considerable governmental in-

CSR assurance. It further implies that the

fluence, which is reflected in three aspects (Licredibility of Chinese CSR reports is question-

and Belal, 2018; Shen, Wu, and Chand, 2017; Zhao,

able.

2012; Zhu, Liu, and Lai, 2016; Zhu and Zhang,

The Chinese context has recently witnessed2015): (1) the Chinese government’s leading

the development of a CSR-related practicerole in driving CSR reporting; (2) SOEs’ pio-

perceived as another credibility-enhancing

neering role in implementing CSR reporting;mechanism: the Chinese CSR Report Rating.

and (3) the domination of experts with gov-

It is a service provided by the Chinese Ex-

ernmental or quasi-governmental backgrounds

pert Committee on CSR Report Rating found-in the CSR consulting and assurance market.

ed by the Corporate Social Responsibility Re-

With the rapid growth of CSR reporting,search Centre, Chinese Academy of Social

there is an increasing concern about the cred-

Sciences（4）(CASS-CSRRC).

ibility of CSR disclosures, as companies may

Founded in 2008, CASS-CSRRC is a govern-

use CSR reporting as a marketing/green-

ment-affiliated research institution focusing on

washing/image tool (Laufer, 2003; Mahoney et

CSR in China. It runs research projects onal., 2013; Uyar, Karaman, and Kilic, 2020). Previ-

CSR-related topics and publishes researchous literature indicates mechanisms that canwork. Also, CASS-CSRRC is a standards or-enhance the credibility of CSR reporting, in-ganisation. It has developed The Chinese Cor-cluding CSR assurance, robust internal control

porate Social Responsibility Reporting Guide

and reporting systems, stakeholder engage-(CASS-CSR 4.0) (Zhong et al., 2018). Moreover,ment, and internal audit (Simnett, Zhou, and

CASS-CSRRC runs a CSR-related business,

Hoang, 2016). Particularly, CSR assurance is anproviding CSR consulting, report writing, andessential credibility-enhancing mechanism

report rating services. Therefore, CASS-CSR-

where independent assurance providers are

RC plays multiple roles in the CSR area.

involved and verifying CSR reports. It helps

In the CSR Report Rating service, CASS-

reduce information asymmetry and increase

CSRRC works with the Chinese Expert Com-

stakeholder confidence in the reliability of

mittee on CSR Report Rating, evaluates the

CSR disclosures (Boiral and Heras-Saizarbitoria,

quality of a company’s CSR report, and issues2020). The number of companies investing ina Rating Report with comments and sugges-44

投稿（事例紹介・解説）/Reviewed Article (Case Study・General Review)

Figure 1

The structure of the Chinese Expert Committee on CSR Report Rating
Chinese Expert Committee on CSR Report
RatingChairman

The expert pool

Experts

Secretariat

Associate
ChairmanContact
persons

The rating panel
Source: translated and adapted from Chinese Expert Committee on CSR Report Rating (2020, p.6).

tions. The Committee consists of experts fromp. 271) view the CASS-CSRRC as one of thethe government, universities, research institu-“government-affiliated industry expert assur-

tions, and industry associations. For each rat-ers” (a type of CSR assurance providers（5）). The

ing project, the Committee sets up a rating

Rating is considered a mechanism that adds

panel. Figure 1 shows the structure of thecredibility to CSR reports by “improving their

Committee.

actual and perceived quality” (Shen, Wu, and

The CSR Report Rating evaluates the quali-

Chand, 2017, p. 275) . In this case, the Ratingty and management of CSR reporting, aiming

represents a practice performed by “an expert

at (1) providing CSR reporting entities withthird party” (Shen, Wu, and Chand, 2017, p. 275).

professional advice to improve the quality of

Similarly, Noronha et al. (2013, p. 39) view

CSR disclosures and support the implementa-

CASS-CSRRC’s Report Rating as “assurance

tion of CSR activities; (2) enhancing CSR man-services” for Chinese companies.

agement through better CSR reporting which

Figure 2 shows the process of the Rating.

facilitates stakeholder dialogue and CSR per-Once a company sets an agreement with theformance improvement; and (3) facilitating theCommittee Secretariat, the rating process be-

development of CSR in China (Chinese Expert

gins. The Committee randomly selects ex-

Committee on CSR Report Rating, 2020). There-

perts from the expert pool and establishes afore, the Rating provides reporting companies

rating panel. The panel consists of one leader

with professional advice regarding CSR re-(an expert), one member (an expert), and sever-porting and management. It is essentially an

al contact persons from the Secretariat.

extension or a “variant” of CSR consulting service.

The Secretariat is responsible for the evaluation of the company’s CSR reporting proce-

Previous literature indicates a different un-dures. If this is the first time the company

derstanding of the Chinese CSR Report Rat-

purchases the Rating, a contact person willing. For example, Shen, Wu, and Chand (2017,

conduct an online interview with its CSR re-Chinese CSR Report Rating

Figure 2

Set anagreement

Establish arating panel

45

The process of CSR report rating

Evaluate
CSR reporting
procedures

Rate the CSR
reportIssue a rating
reportCommunicate

Ten working days
Source: translated and adapted from Chinese Expert Committee on CSR Report Rating (2020, pp.7-8).

porting manager, collect relevant documenta（6）ry evidence

overall rating, respectively. The overall rating, and fill a Procedural Assess-is determined by the weighted sum of the（7）seven scores, with possible results categorised

ment Data Information Confirmation Form.

The Form is confirmed and signed by the

into seven levels (see Table 1).

company. If the company has been continu-

Finally, the rating panel leader produces aously involved in the Rating for two or more

Rating Report based on the rating scores andyears, no interview will be conducted. Instead,the panel members’ opinions. The Associate

the contact person will send the Form to the

Chairman of the Committee then signs thecompany directly. The company will then fill

Rating Report before issuing it. The Secretari-

the form, sign it, and send it with relevant

at subsequently sends the Rating Report anddocumentary evidence back to the contact

communicates with the reporting company.

person.

The company is expected to include the Rat-

After evaluating the reporting procedures,ing Report in its CSR report.

the Secretariat sends the company’s CSR re-

The past decade has witnessed the increas-

port and the Confirmation Form to the ratinging popularity of the CSR Report Rating ser-panel. The rating panel evaluates the CSR re-vice. A total number of 597 rating reports haveport based on CASS-CSR 4.0 (Zhong et al., 2018)

been issued by the end of 2019 (Chinese Expert

and the Chinese Corporate Social Responsibili-

Committee on CSR Report Rating, 2020). Manyty Report Rating Standards (Chinese Expert

Chinese companies, particularly SOEs, invest

Committee on CSR Report Rating, 2020). Notably,in the Rating annually. However, the under-

the evaluation is based on the text of the CSR

standing of the Rating is in a muddle. Previ-

report only. The CSR report is then given scores

ous literature (Noronha et al., 2013; Shen, Wu,

based on seven indicators: Procedure, Sub-

and Chand, 2017) views the Rating as an alter-

stantiality, Integrity, Balance, Comparability,

native (or an equivalent) to CSR assurance,

Readability, and Innovation, which account for

which aims to enhance CSR reports’ credibili-

20%, 25%, 20%, 10%, 10%, 10%, and 5% of thety. However, Chinese Expert Committee on46

投稿（事例紹介・解説）/Reviewed Article (Case Study・General Review)

Table 1

Levels of Rating

Overall rating

Shown asThe level of CSR reporting

Five-star Plus★★★★★ (+)

Model

Five-star★★★★★

Outstanding

Four-star and half★★★★☆

Leading

Four-star★★★★

ExcellentThree-star

★★★

Good

Two-star★★

Developing

One-star★

Beginning

Source: translated and adapted from Chinese Expert Committee on CSR Report Rating (2020, p.15).

CSR Report Rating (2020) indicates that the
Rating aims to provide Chinese reporting

3.

Methods

companies with professional advice and enhance CSR management through better CSRThis research examines the nature of the Chi-

reporting. It implies that the Rating is morenese CSR Report Rating and its effectivenesslike an extension of CSR consulting.

in enhancing the credibility of CSR reporting.

Therefore, the nature and purpose of the

An engagement-based qualitative case study

Chinese CSR Report Rating are unclear. More-was designed and conducted. The evidence

over, the extant literature remains inconclu-

collected for the case study included inter-sive regarding (1) whether the Rating can ef-

view data and documentary evidence.

fectively enhance the credibility of CSR reports

The approach to interviewee selection in-and (2) why the Chinese companies, particu-

volved purposive and self-selection sampling

larly SOEs, prefer the Rating. There is a

(Saunders, Lewis, and Thornhill, 2019). It wasdearth of qualitative research illuminating the

purposive in seeking opinions from CSR re-nature, process, and effectiveness of the Rat-porting managers of the very largest Chinese

ing. Furthermore, there is a lack of engage-companies (particularly SOEs), CSR experts

ment-based case studies which provide in-from major Chinese CSR consulting firms, anddepth insights into the Chinese CSR reporting

Chinese CSR assurance providers. The sample

practice (Adams and Larrinaga, 2019; Li andof ten interviewees included CSR managers/

Belal, 2018; Yang, Craig, and Farley, 2015). This

Heads of five large Chinese companies whichstudy aims to fill these research gaps. The fol-

have adopted the Chinese CSR Report Rating

lowing chapter summarises the research meth-service for years. The sample also includedods.

CSR experts from three CSR consulting firms
and two CSR assurance providers. Appendix
1 shows the details of the interviewees, with
key identity information anonymised.

Chinese CSR Report Rating

Table 247

The design of initial interview questions

Interviewee category

Initial interview questions

CSR manager/HeadWhen did your company start to purchase the CSR Report Rating service?
Why did your company purchase the CSR Report Rating service?
What value has the CSR Report Rating service provided?
How do you perceive the role of CASS-CSRRC in the Chinese CSR field?
Is the CSR Report Rating service an alternative to CSR assurance?
Could you please compare the CSR Report Rating service and the CSR assurance?
Will your company continue purchasing the CSR Report Rating service?

CSR expert

How do you perceive the value the CSR Report Rating service provides?
How do you perceive the role of CASS-CSRRC in the Chinese CSR field?
Is the CSR Report Rating service an alternative to CSR assurance?
Could you please compare the CSR Report Rating service and the CSR assurance?
In your opinion, why many companies prefer the CSR Report Rating service?
When providing CSR consulting service, will you recommend any mechanism
enhancing the credibility of CSR reporting to your clients?
What mechanism(s) will you recommend?

Is the CSR Report Rating service an alternative to CSR assurance?
Could you please compare the CSR Report Rating service and the CSR assurance?
How do you perceive the value the CSR Report Rating service provides?
CSR assurance provider
How do you perceive the role of CASS-CSRRC in the Chinese CSR field?
In your opinion, why many companies prefer the CSR Report Rating service?
In your opinion, why most Chinese companies are reluctant to adopt CSR assurance?

The interviews were semi-structured, where

involved four elements: (1) becoming familiar

the interviewees were free to speak theirwith the interview data, (2) coding the inter-minds. Initial interview questions were de-view data, (3) searching for themes and recog-

signed to stimulate reflection, which sought tonising relationships, (4) refining themes andcapture the interviewees’ views on (1) the

testing propositions (Saunders, Lewis, anddriving forces behind adopting the Rating;Thornhill, 2019). Notably, this procedure didand (2) the effectiveness of the Rating. Table 2

not occur in a simple linear progression but

shows the design of the initial interview ques-concurrently and recurrently. The analysis oftions.

a series of documents (see Appendix 2) supple-

Follow-up questions captured insights into

mented the thematic analysis of the interview

the relationships between the elements being

data. Five main themes were identified fromconsidered. The interviews were conducted

the data analysis, namely “drivers”, “purpose”,

during 2019, which yielded 10.9 hours of audio“process”, “nature”, and “effectiveness”.

recordings. The recordings were transcribedverbatim, with transcriptions being checked

4.

Findings

by the researcher.
A thematic analysis of the interview data

The analysis findings reveal the symbolic na-

was then conducted. The analytical procedure

ture of the Chinese CSR Report Rating, which48

投稿（事例紹介・解説）/Reviewed Article (Case Study・General Review)is reflected in three aspects. First, the Rating

standing”. Hence, the Rating is primarily a po-features heavy governmental influence. The

litical legitimacy tool used by the Chinese

evidence reveals that SOEs account for most

CSR reporting companies, especially SOEs.

of the client base in the Rating service andSecond, the purpose of the CSR Report Rat-

prefer the service because CASS-CSRRC is a

ing is ambiguous. The reporting companies

government-affiliated research institution:

tend to view the Rating as a credibility-en-“The CSR Report Rating is considered au-

hancing mechanism. MAN-1, MAN-2, MAN-

thoritative. Companies, including Central En-

3, MAN-4, and MAN-5 broadly agreed that

terprises, other SOEs, private companies, andthe Rating represented opinions from an au-

foreign companies, all recognise it. Therefore,

thoritative and independent research institu-

we also use it,” (MAN-1).

tion (CASS-CSRRC). A Rating Report issued byMAN-1 and MAN-5 further noted that by

CASS-CSRRC meant that the CSR report wascooperating with CASS-CSRRC, they could

endorsed by an authoritative and “neutral

maintain a good relationship with the central

third party” (MAN-2). MAN-2 further noted

government and gain access to critical resourc-that “in the absence of CSR assurance, thees controlled by the state. As MAN-5 put it:

Rating largely represents the credibility [of“[CASS-CSRRC] has an official and authori-

CSR reporting], just like [what] the assurance

tative background … It has a close relation-[can provide]”. However, other interviewees

ship with our superior regulatory authority,(EXP-1, EXP-2, EXP-3, AP-1, AP-2) noted that

SASAC. Through [cooperating with] CASS-

the Rating should not be considered equiva-

CSRRC, we can be tied up with our superior

lent to CSR assurance. The following quotes

in some projects,” (MAN-5).

elaborate:

The evidence indicates that the Rating serves“CSR assurance merely [focuses on data] re-the companies’ strategy to gain political legiti-

liability … The Rating does not assess the（8）(Marquis and Qian, 2014; Zhao, 2012) .

data reliability … It evaluates whether a com-

SOEs have significant political responsibilities

pany has fully disclosed the CSR information

and are required to work as political actors

as required” (EXP-1).

macy(Zhu and Zhang, 2015), and therefore have a“[CASS-CSRRC] can provide [the Ratingstrong desire to appear more legitimate. They

service] … but I think it is not assurance … ifcooperate with CASS-CSRRC and adopt the

the Rating could replace the assurance, theRating to meet the state’s social and environ-assurance would not exist … they are essen-

mental expectations, obtain and retain policy

tially incomparable” (AP-2).

legitimacy, and gain state resources (Marquis

Notably, AP-1 pointed out that CASS-CSR-

and Qian, 2014; Zhao, 2012). Moreover, AP-2 im-

RC should not be regarded as an assurance

plied that reporting companies would always

provider or external reviewer due to its lackget a satisfying result from the Rating, withof independence:

their CSR reports rated as “Leading” or “Out-“CASS-CSRRC helps companies write CSR

Chinese CSR Report Rating49

reports and then rates them. Consequently,

sue rating reports … [this rating process]the credibility [of the Rating] loses … That islacks stakeholder engagement as it is based

why CASS-CSRRC has been despised [by peers]

on the text only” (AP-1).

in this industry” (AP-1).

The evidence indicates that the rating pro-

MAN-1, MAN-2, and MAN-5 indicated thatcess is oversimplified, completely ignoring

CASS-CSRRC provided consulting, report

data accuracy and stakeholder engagement.

writing, and report rating services for them

Therefore, the evaluation of CSR reporting

simultaneously, with the Rating as part of thequality is superficial, further undermining the

CSR consulting service contract. As MAN-2

effectiveness of the CSR Report Rating in

put it:credibility-enhancing.

“[CASS-CSRRC] is both an authoritative rat-

The discussion above indicates that the na-

ing organisation and a consultant, or thinkture of the CSR Report Rating is symbolic,tank, that can provide advice regarding CSR

which is reflected in three aspects. First, thestrategy. Also, it cooperates with the govern-

CSR Report Rating is essentially a tool that

ment. Hence, for us, it has a comprehensive

the companies, especially SOEs, use as part ofrole,” (MAN-2).

their CSR strategy to gain political legitimacy

The evidence reveals that the Rating is inand access to state resources. With their CSR

fact an extension or a “variant” of CSR con-reports rated as “Outstanding” or “Leading”,

sulting but broadly considered equivalent tothe companies can show their achievement in

CSR assurance aiming at credibility-enhanc-

CSR performance and thus meet the state’s

ing. However, the fact that CASS-CSRRC ratessocial and environmental expectations. There-

its own work threatens its independence as

fore, the CSR Report Rating is more like “aan external reviewer. The lack of independence

promotional tool of business image” (Noronha

seriously undermines the commonly expected

et al., 2013, p. 39) rather than an unbiased evalu-

effectiveness of the Rating in credibility-en-

ation of CSR reporting quality.

hancing.

Second, the symbolic nature of the Rating is

Third, the process of the CSR Report Rat-

further revealed due to the ambiguity about

ing is also questionable. The report evaluation

its purpose. The main doubt is whether theis “based on the text only, without checking

Rating is an extension of CSR consulting or

the accuracy of CSR data disclosed” (EXP-1).

an alternative to CSR assurance. The CSR re-AP-1 further noted the lack of procedures such

porting managers interviewed (MAN-1, MAN-as site visit and staff enquiry, pointing to an

2, MAN-3, MAN-4, and MAN-5) were broadly

absence of stakeholder engagement during thein agreement that the Rating could function

rating process:as CSR assurance and enhance the credibility“[CASS-CSRRC] does not conduct a site visitof CSR reporting. However, CASS-CSRRC’s

but only asks the companies to send electron-lack of independence as an external reviewer/

ic CSR reports. Then the rating panel can is-assurance provider seriously undermines the

50

投稿（事例紹介・解説）/Reviewed Article (Case Study・General Review)

effectiveness of the Rating in credibility-en-

nature of the CSR Report Rating:hancing. The fact that CASS-CSRRC reviews
the reports prepared by itself reveals that the
CSR Report Rating is largely a self-review
practice with symbolic nature.
Third, the Rating process is superficial. The
Rating is based on the text of CSR reports
only, without checking data accuracy and en-(1) the CSR Report Rating is typically used
as a political legitimacy tool;(2) the CSR Report Rating is largely a selfreview practice; and(3) the rating process is oversimplified andsuperficial.

gaging key stakeholders. This finding meansthat a CSR report can still gain a high rate/

In summary, the CSR Report Rating’s effec-

score even if the data disclosed is incorrect or

tiveness in enhancing the credibility of CSR

manipulated. Therefore, the oversimplified rating

reports is questionable. It should not be re-process further points to the symbolic nature

garded as an alternative (or an equivalent) toof the CSR Report Rating practice.

CSR assurance.

Overall, the symbolic nature of the CSR Re-

This case study makes several contribu-

port Rating indicates that its effectiveness intions to CSR accounting and reporting re-credibility- enhancing is questionable. The

search. Firstly, this study represents an early

Rating is more like an extension or a “variant”

attempt to investigate the Chinese CSR Re-

of CSR consulting, a mechanism for compa-

port Rating practice under-researched within

nies’ CSR strategy, and a business image en-

the extant literature. Further, as a response

hancement tool, rather than an alternative toto the call for more engagement research (Ad-

CSR assurance.

ams and Larrinaga, 2019), this study provides

qualitative evidence through fieldwork-based

5.

Conclusion

research on the development of CSR reporting practice in China, the world’s largest emerg-

The purpose of this paper is to examine anding economy.

explain the nature of the CSR Report Rating,

Secondly, this study contributes to a com-a CSR-related practice developed and provid-

prehensive and nuanced understanding of the

ed by CASS-CSRRC in China. An engage-

CSR Report Rating. In both practice and aca-

ment-based case study has been conducted indemia, the current understanding is in a mud-

response to the lack of qualitative evidencedle, with ambiguity about its purpose and na-

within the extant literature illuminating theture. This paper clears up the ambiguity bynature and effectiveness of the Rating. The

suggesting that the CSR Report Rating is moreevidence collected for the case study com-like an extension or a “variant” of CSR con-bined interview data and a series of relevant

sulting rather than an alternative to CSR as-

documents. The case study analysis reveals

surance. Therefore, the CSR Report Rating

three key findings pointing to the symbolic

should not be viewed as a credibility-enhanc-

Chinese CSR Report Rating

ing mechanism.

51

or local level), foreign companies, or private

Finally, this study has important practicalcompanies operating in China. Particularly,

implications. The symbolic nature of the CSR

the investigation of foreign and private com-

Report Rating implies that the nature of Chi-

panies would be interesting due to their loca-

nese CSR reports can also be symbolic. Chi-tion in a unique socioeconomic, political, andnese CSR reports are typically used as a legit-

cultural context (Li and Belal, 2018). Further-

imation or corporate image enhancement tool,

more, while this study has focused on the Chi-rather than a genuine accountability medium

nese CSR Report Rating, future research could

for stakeholders and the wider public (Lee,go further and explore other CSR-related

Walker, and Zeng, 2017; Marquis and Qian, 2014;

practices in China. For example, the CSR as-

Patten, Ren, and Zhao, 2015; Zhao and Pattern,surance practice in China is a topic currently

2016). This research further implies that theunder-researched. Research on this topic can

CSR reports’ credibility is doubtful. Hence,

provide empirical insights for policymakers

there is an urgent demand for credibility-en-

who can assist the development of regulations

hancing mechanisms for Chinese CSR report-

for CSR reporting and assurance.

ing. For example, regulators and policymakers
may consider requiring independent external（1）

assurance for CSR reporting to ensure thecompleteness and reliability of CSR disclosures.
This qualitative case study is inevitably subject to some limitations. While the interviews
allowed access to the managers involved in
the preparation of CSR reports, the practitioners in the CSR consulting and assurance
market, and some internal documents, the researcher was only given access to informationand organisational documents that were notconfidential. Therefore, the empirical analysis
is mainly based on the interviewee’ reflections. Moreover, the CSR reporting managers

The State-owned Assets Supervision and Ad-

ministration Commission of the State Council (SASAC) is a ministry directly under the management of the State Council (SASAC, 2021a).
（2）

Central Enterprises are also referred to as Central State-owned Enterprises. They are wholly or
partly owned and directed by the Central Government or government ministries such as the Ministry of Finance and SASAC (SASAC, 2021b).

（3）

CSR/sustainability assurance is defined as as-

surance on CSR/sustainability reports (Canning,
O’Dwyer, and Georgakopoulos, 2019). Assurance isdefined as “an engagement in which a practitioner
aims to obtain sufficient appropriate evidence inorder to express a conclusion designed to enhancethe degree of confidence of the intended users
other than the responsible party about the subject matter information” (IAASB, 2013, p. 7). CSR
assurance is expected to enhance the credibilityof CSR reports and assist better decision making(Shen, Wu, and Chand, 2017).

interviewed were mainly from the very larg-（4） The Chinese Academy of Social Sciences (CASS)

est SOEs. Hence, the generalisation of the key

is an academic organisation and comprehensive

findings of this exploratory study might be
restricted.
Future research could explore the CSR reporting practice of SOEs (either at the central

research centre of the People’s Republic of China
in philosophy and social sciences (CASS, 2021).
（5）

CSR assurance providers are typically catego-

rised into accounting assurance providers andnon-accounting assurance providers (see, for ex-52

投稿（事例紹介・解説）/Reviewed Article (Case Study・General Review)

ample, Bepari and Mollik, 2016; Boiral and Heras-(2) staff training on CSR reporting, (3) stakehold-

Saizarbitoria, 2020; Channuntapipat, Samsonova-ers, the process of stakeholder engagement, andTaddei, and Turley, 2020; Farooq and De Villiers,

stakeholder feedback, (4) the process of materiali-

2017; 2019; Gürtürk and Hahn, 2016). Shen, Wu,
and Chand (2017) have added another categorise

ty assessment, (5) the process of report writing.
（7）

For details of the Procedural Assessment Dataof CSR assurance providers in the Chinese con-Information Confirmation Form, please see Chi-text, which is called “industry expert assurers”

nese Expert Committee on CSR Report Rating(p. 274).
（6）

According to Chinese Expert Committee on(2020, pp. 20-21).
（8）

Political legitimacy is defined as “the extent to

CSR Report Rating (2020, p. 9), the documentary

which the government views the firm’s actions asevidence includes, but is not limited to, the com-being in accordance with norms and laws” (Mar-pany’s internal written record of (1) CSR report-

quis and Qian, 2014, p. 127).

ing team members and respective responsibilities,

Chinese CSR Report Rating

53

Appendices

Appendix 1
Interview

Organisa-Codetion Code1

Details of Interview Data Collection
Sector

FIRM-1

SOE

EnergyMAN-1

2

FIRM-2

SOE

EnergyMAN-2

3

FIRM-3

SOE

4

FIRM-4

Non-SOE

Engineering andConstruction

Food Production

Interview

Interviewee

Organisation Type

Position

CodeManager of CSR reporting,Publicity Department
Manger of CSR reporting,
CSR OfficeDuration(In minute)90
96

Head of CSR reporting,MAN-3

Corporate Culture

52(Party Work) Department

MAN-4

Manager of CSR reporting,Group General Affair

85

Department
Head of Corporate Responsi-

5

FIRM-5SOE

Motor Vehicles
and Parts

MAN-5

bility, Brand Promotion Office,
Party Work Department

46

6

CON-1

CSR Consulting
firmProfessional
Service

EXP-1

Associate Head

38

7

CON-2

CSR Consulting
firmProfessional
Service

EXP-2

Director, Chief Executive
Officer (CEO) and Co-founder

72

8

CON-3

CSR Consulting
firmProfessional
Services

EXP-3

CSR Consulting Director

63

Professional
Services

SAP-1

Assurance Project Manager

41

Professional
Services

SAP-2

Senior Manager

72

9

AP-1

Technical Service
Provider(Non-accounting CSR
assurance provider)

Big Four10

AP-2

accounting firm
(Accounting CSR
assurance provider)

Total

655

Appendix 2Document TypeStandards
Rating reports
CSR reports
Company websites
Other relevant documents

Details of Documentary Evidence
Details

The Chinese Corporate Social Responsibility Report Rating Standards (Chinese
Expert Committee on CSR Report Rating, 2020)

Sample companies’ every rating report published from the earliest available tothe latest one (the year 2019)
Sample companies’ every CSR report from the earliest available to the latest one(the year 2019)

Accessed several times between 2019 and 2020. Details of the websites cannot
be provided due to confidentiality reasons.
Internal documents provided by some interviewees54

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