a

GAO

United States Government Accountability Office

Report to Congressional Requesters

August 2005 GLOBALIZATION

Numerous Federal 

Activities Complement 

U.S. Business’s Global 

Corporate Social 

Responsibility Efforts

GAO-05-744
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-744.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Loren Yager at 

(202) 512-4347 or yagerl@gao.gov. 

Highlights of GAO-05-744, a report to 

congressional requesters 

August 2005

GLOBALIZATION

Numerous Federal Activities Complement 

U.S. Business’s Global Corporate Social 

Responsibility Efforts 

Although there is no broad federal CSR mandate, we identified 12 U.S. 

agencies with over 50 federal programs, policies, and activities that generally 

fall into four roles of endorsing, facilitating, partnering, or mandating CSR 

activities. Many of these programs have small budgets and staff and aim to 

accomplish broader agency mission goals, rather than being specifically 

designed to facilitate or promote companies’ global CSR activities. The U.S. 

government endorses CSR by providing awards to companies, such as the 

Department of State’s Award for Corporate Excellence. Federal programs 

facilitate CSR by such activities as providing information or providing 

funding to engage in CSR. For example, a Department of Commerce 

program facilitates CSR by providing training on corporate stewardship. 

Some agencies partner with corporations on specific projects related to their 

core mission. For example, the U.S. Agency for International Development 

(USAID) partnered with one U.S. corporation operating in post-war Angola 

to build up the country’s business sector and workforce. Other agencies, 

such as the Overseas Private Investment Corporation, mandate CSR by 

requiring companies to meet CSR-related criteria to obtain their services. 

While perspectives on the government’s role are tied to perspectives on CSR 

and its connection to profit, many we spoke with who are actively involved 

in global CSR desired a government role supporting business’s voluntary 

CSR efforts. Those with a free-market economic perspective believe 

corporations should be primarily concerned with earning a profit and 

government should not promote CSR as it reduces profits. Those with a 

“business case” perspective often welcome government assistance with their 

voluntary efforts because they view their CSR efforts as increasing profits 

and business value. Finally, those with a social issues perspective believe 

that business should contribute to broader social goals but split on whether 

business action should be voluntary or mandatory. Most groups we spoke 

with at U.S. companies and others actively engaged in CSR were generally 

supportive of U.S. federal agency efforts to endorse and facilitate CSR and 

partner with companies voluntarily pursuing CSR actions. For example, 

several groups supported a government role in providing CSR-related 

information and convening stakeholders to address CSR-related issues. 

Range of U.S. Government Activities Related to Global CSR 

Endorsing Partnering Mandating Facilitating

Source: GAO illustration based on World Bank report.

Provide awards for 

CSR activities

Discuss CSR in 

public speeches

Provide CSR 

information

Provide grants to 

address CSR issues

Facilitate publicprivate partnerships

Convene 

stakeholders

Mandate CSR for 

participating 

companies

Regulate CSRrelated issues

The trend toward globalization has 

intensified the debate about the 

proper role of business and 

government in global “corporate 

social responsibility” (CSR),which 

involves business efforts to address 

the social and environmental 

concerns associated with business 

operations. The growth in global 

trade and the dramatic increase in 

foreign direct investment in 

developing countries raise 

questions regarding CSR-related 

issues such as labor, environment, 

and human rights. U.S. firms with 

operations in many countries 

employ millions of foreign workers 

and conduct a range of CSR 

activities to address these issues. 

However, there is controversy as to 

the proper government role. GAO 

describes (1) federal agency 

policies and programs relating to 

global CSR and (2) different 

perspectives regarding the 

appropriate U.S. government role 

and views on the impact of current 

federal activities on corporate 

global CSR efforts. 
Page i GAO-05-744 Global CSR

Contents

Letter 1

Results in Brief 2

Background 3

Global Corporate Social Responsibility Is an Umbrella Concept 

Covering Many Business Actions and Involving Many Players 5

Although No Broad Federal CSR Mandate Exists, Federal Agencies 

Conduct Many Activities Related to Global CSR 16

Perspectives on the Appropriate Government Role in CSR Vary, but 

Many Support Federal Assistance for Voluntary Efforts 26

Concluding Observations 34

Agency Comments and Our Evaluation 35

Appendixes

Appendix I: Objectives, Scope, and Methodology 37

Appendix II: Federal Agency CSR-Related Programs and Activities 41

Appendix III: GAO Contact and Staff Acknowledgements 69

Tables Table 1: Sample Definitions of Corporate Social Responsibility 6

Table 2: Definitions of Terms Related to Corporate Social 

Responsibility 7

Table 3: Responses from Department of Commerce 41

Table 4: Responses from Department of Energy 44

Table 5: Responses from U.S. Environmental Protection Agency 46

Table 6: Responses from Export-Import Bank of the United 

States 50

Table 7: Responses from Inter-American Foundation 52

Table 8: Responses from Department of Labor 54

Table 9: Responses from Overseas Private Investment 

Corporation 56

Table 10: Responses from U.S. Securities and Exchange 

Commission 57

Table 11: Responses from the Department of State 59

Table 12: Responses from the Department of Treasury 66

Table 13: Responses from U.S. Agency for International 

Development 67

Table 14: Responses from Office of the U.S. Trade 

Representative 68
Contents

Page ii GAO-05-744 Global CSR

Figures Figure 1: Some Federal Programs and Activities Complement U.S. 

Corporate CSR Practices 19

Figure 2: Illustrative U.S. Government Activities Related to CSR 

Range from Endorsing CSR to Mandating CSR 22

Abbreviations

CSR Corporate Social Responsibility

DFI Digital Freedom Initiative

EPA U.S. Environmental Protection Agency

Ex-Im Bank Export-Import Bank of the U.S.

HIV/AIDS human immunodeficiency virus/acquired immune deficiency 

syndrome

IAF Inter-American Foundation

GRI Global Reporting Initiative

NGO nongovernmental organization

OECD Organization for Economic Cooperation and Development

OPIC Overseas Private Investment Corporation

SEC U.S. Securities and Exchange Commission

USAID U.S. Agency for International Development

USTR Office of the U.S. Trade Representative

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Page 1 GAO-05-744 Global CSR

United States Government Accountability Office

Washington, D.C. 20548

A

August 8, 2005 Leter

The Honorable David E. Price

House of Representatives

The Honorable Sander M. Levin

House of Representatives

The trend toward globalization—as evidenced by the growth in global trade 

and the dramatic increase in foreign direct investment in developing 

countries, from $22 billion in 1990 to $154 billion in 2002—has intensified 

the debate about the role of business and the U.S. government in 

addressing “corporate social responsibility” (CSR) related issues. 

Presently, for example, some opponents of the U.S.-Central American Free 

Trade Agreement (CAFTA) have complained that the agreement does not 

do enough to ensure that workers in these countries have adequate labor 

protections. The term CSR is often used to refer to business efforts to 

address the impact of business operations on such concerns as labor, 

environment, and human rights. U.S. multinational corporations, which 

conduct operations in many countries and employ millions of foreign 

workers, have sometimes responded to the varying pressures they face by 

adopting CSR efforts to address social and environmental concerns. Some 

advocates argue that the U.S. government should embrace CSR more 

actively and use policies such as trade agreements to encourage or require 

its adoption by U.S. multinational corporations. Others state that CSR 

should be a voluntary corporate activity, and the federal government 

should neither regulate nor promote CSR.

Given the role of U.S. corporations in the growth of trade and investment in 

developing nations and your interest in issues related to globalization, this 

report describes (1) global corporate social responsibility, (2) federal 

agency policies and programs relating to global CSR, and (3) different 

perspectives regarding the appropriate U.S. government role and views on 

the impact of current federal activities on corporate global CSR efforts.

To describe global corporate social responsibility, we reviewed business 

and ethics literature and interviewed selected corporations and other 

groups interested in CSR. To determine what policies and programs federal 

agencies have adopted that relate to global CSR, we surveyed federal 

legislation and spoke with agency officials and experts in CSR. We obtained 

information on specific agency programs and policies related to CSR using 

a two-step process. First, we provided a general description of global CSR 
Page 2 GAO-05-744 Global CSR

to agency officials and asked them to identify relevant programs, policies, 

and efforts within their agency. We then sent a questionnaire to officials 

responsible for each identified program and interviewed officials to obtain 

further information. To identify different perspectives regarding the role

of the U.S. government related to corporate global CSR efforts, we 

reviewed CSR-related trade and business literature and interviewed, on a 

nonattribution basis, representatives from 14 selected U.S. multinational 

corporations; 4 business interest groups; 4 investor groups; 6 

nongovernmental organizations; and 4 academic institutions that are 

leaders in the CSR field. We conducted our work from May 2004 through 

May 2005 in accordance with generally accepted government auditing 

standards. (Appendix I provides detailed information on our objectives, 

scope, and methodology.)

Results in Brief Global CSR is an umbrella concept that can best be described through the 

definitions used for the term, the actions companies take to practice CSR, 

and the roles of key players. CSR can be broadly defined as addressing the 

interests of all company stakeholders, which include not only shareholders 

but also customers, employees, suppliers, and the surrounding community 

on issues such as environmental protection, worker safety, and ethical 

conduct. Global CSR addresses these issues within international markets, 

particularly in developing countries. U.S. businesses take a variety of 

actions related to CSR that range from voluntary, such as philanthropic 

donations, to government mandated, such as disclosure of significant 

environmental conditions. Businesses play a central role in determining if 

and how to address social and environmental issues they face in their 

operations. Civil society, investor groups, multilateral organizations, and 

governments play key roles in identifying issues of concern and in 

encouraging businesses to adopt CSR efforts to address these issues. 

Although the United States has no broad federal CSR mandate, we 

identified 12 U.S. agencies with over 50 programs, policies, and activities 

that generally fall into four key government roles of endorsing, facilitating, 

partnering, and mandating company CSR activities. However, many of 

these programs have small budgets and staff and aim to accomplish 

broader agency mission goals, rather than being specifically designed to 

facilitate or promote companies’ global CSR activities. The U.S. 

government endorses CSR by providing awards to companies, such as the 

Department of State’s Award for Corporate Excellence and discussing CSR 

in public speeches. Federal programs facilitate CSR primarily by providing 

information or providing funding and incentives to key players to engage in 
Page 3 GAO-05-744 Global CSR

CSR. For example, the Department of Commerce facilitates CSR by 

training its commercial service officers specifically on corporate 

stewardship. The U.S. Agency for International Development’s (USAID) 

Global Development Alliance provides an example of a federal program 

that partners with corporations to leverage additional resources. Finally, 

some agencies, such as the Overseas Private Investment Corporation 

(OPIC), mandate CSR by requiring companies to meet criteria consistent 

with CSR to obtain their services. 

While varying perspectives of the government’s role are tied to perspectives 

on CSR and its connection to profit, many we spoke with from groups that 

are actively involved in global CSR reported that a government role 

supporting companies’ CSR efforts would be useful. Those with a freemarket economic perspective state that corporations should be primarily 

concerned with earning profits and that government should not promote 

CSR because it reduces profit. Those with a “business case” perspective 

contend that CSR efforts can increase business long-term profits and value, 

and welcome government assistance with voluntary business efforts. 

Finally, those with a social issues perspective believe that business should 

contribute to broader social goals but have mixed opinions of whether this 

should be accomplished through voluntary CSR actions or more extensive 

regulation. Most representatives we spoke with at U.S. companies and 

other groups who were actively engaged in CSR were generally supportive 

of U.S. federal agency efforts to endorse and facilitate CSR and partner 

with companies voluntarily pursuing CSR actions. For example, several 

groups supported a government role in providing CSR-related information 

and convening stakeholders to address CSR-related issues. 

Background The expansion of world trade and investment has led to the increasing 

integration of the world economy in recent decades—a process often 

referred to as “globalization.” Total trade in developing countries, exports 

and imports, rose from less than $1.5 trillion in 1990 to $3.8 trillion in 2002, 

while foreign direct investment in developing counties grew even faster 

during this period, from $22 billion to $154 billion. Some view globalization 

as fostering economic growth, increasing employment, and improving 

living standards in both developed and developing nations. At the same 

time, others view globalization as resulting in negative social impacts and 

raise concerns about the expanding activities of multinational 

corporations, particularly in developing countries. U.S. multinational 

corporations are now faced with difficult issues, such as the treatment and 

conditions of foreign workers in corporate supply chains, environmental 
Page 4 GAO-05-744 Global CSR

and health issues associated with production in diverse local communities, 

and human rights issues associated with authoritarian governments in 

countries where multinationals operate. In addition, some negative 

incidents involving U.S.-based companies have been widely publicized, 

hurting their own and the United States’ image, such as the use of 

sweatshops in the manufacture of clothing and other products. In another 

example, a U.S.-based company recently came under allegations that its 

overseas mining operations produced toxic waste that have caused 

illnesses.

U.S. corporations are increasingly building operations or buying products 

from sources in developing countries. However, the legal, regulatory and 

ethical environments in which U.S. businesses and their suppliers operate 

vary across countries. For example, some have asserted that developing 

countries have inadequate or poorly enforced environmental and labor 

laws. Given the limited capacity of some developing countries, CSR 

advocates argue that corporations themselves must establish and maintain 

codes of conduct regarding operating standards in these environments. 

Companies face increasing pressure from nongovernmental organizations 

(NGO), the media, “socially responsible” investor groups, and other 

stakeholders to adhere to high standards globally in their own operations 

and throughout their supply chains. In addition, some members of 

Congress have shown support for CSR-related policies, similar to those 

advocated by working groups convened by the Kenan Institute.1

In response to these business challenges and outside pressures, companies 

are increasingly adopting “corporate social responsibility” programs. For 

example, recently U.S. electronics companies signed a joint code of 

conduct to protect working conditions, workers’ rights, and the 

environment in the electronics industry supply chain. A number of U.S. 

companies have instituted programs to address HIV/AIDS and other 

diseases in their operations in developing countries, for example, by raising 

awareness or providing access to treatment. Most recently, U.S. companies 

provided nearly $453 million to relief efforts in the wake of the tsunami that 

hit South and Southeast Asia and East Africa in December 2004.2

 Despite 

these efforts, some CSR advocates call for more government action to 

1

The Frank Hawkins Kenan Institute of Private Enterprise – Washington Center,

www.kenaninstitute.unc.edu.

2

U.S. Chamber of Commerce Web site, www.uschamber.com, April 28, 2005.
Page 5 GAO-05-744 Global CSR

promote CSR, with some noting that several national governments in 

Europe have put in place mechanisms to encourage or require the adoption 

of CSR practices.

Global Corporate 

Social Responsibility Is 

an Umbrella Concept 

Covering Many 

Business Actions and 

Involving Many Players 

Global CSR is an umbrella concept that can best be understood by 

describing the different definitions used for the term, the actions 

businesses take to practice CSR, and the roles of key players involved in 

CSR. Although groups use different definitions and terms, CSR generally 

involves business efforts to address a broad range of issues, including the 

environment, labor, and human rights. Businesses perform many different 

actions to address CSR concerns. The extent and type of these actions are 

influenced by key players in CSR that include not only businesses, but also 

the civil society, investor groups, multilateral organizations and 

governments that seek to influence them.

The term “global CSR” is sometimes used to refer to business efforts to 

address the social impacts of business in the global economy. Discussions 

of global CSR in the context of developing countries focuses on the need 

for business to address the gaps from inadequate or poorly enforced laws 

to protect the environment, labor, human rights, and other social resources.

CSR Is Generally Defined as 

Business Efforts to Address 

the Interests of Its Many 

Stakeholders 

The term “CSR” is an umbrella concept with many different definitions. 

However, most definitions suggest that, in addition to addressing the 

interests of its shareholders, business should address the interests of its 

other stakeholders, including customers, employees, suppliers, and the 

local community. CSR definitions cover a broad range of potential social 

concerns, including business ethics, community development, labor, 

environment, and human rights. Table 1 presents sample CSR definitions.
Page 6 GAO-05-744 Global CSR

Table 1: Sample Definitions of Corporate Social Responsibility

Source: GAO compilation from sources listed.

a

Business for Social Responsibility, BSR Issue Briefs, Overview of Corporate Social Responsibility.

b

European Commission, Directorate-General for Employment and Social Affairs, Promoting a 

European framework for Corporate Social Responsibility, Green Paper, July 2001, p. 8.

c

Institute of Business Ethics, Web site, http://www.ibe.org.uk.

d

The World Bank, Corporate Social Responsibility Practice, Public Sector Roles in Strengthening 

Corporate Social Responsibility: Taking Stock, January 2004, p. 3.

CSR definitions vary on whether CSR is considered exclusively voluntary 

or whether it includes mandatory requirements for business regarding 

social and environmental issues. Some definitions of CSR limit it to 

voluntary business decisions and actions, above and beyond what is 

required by law. Others organizations have reasoned that CSR should 

include mandatory efforts, especially because in developing countries it 

can be a tool to encourage compliance with laws and regulations.3

 This 

voluntary compliance with laws and regulations assumes a greater role in 

developing countries, because even where developing countries have 

adequate laws and regulations concerning social and environmental 

concerns, they often have limited enforcement resources. 

Some groups prefer other terms to address all or some of the ethical, social, 

and environmental issues addressed by CSR. For example, one business 

Name of group Definition of CSR

Business for Social 

Responsibility (BSR)

“Achieving commercial success in ways that honor ethical 

values, and respect people, communities, and the natural 

environment.”a

European Commission “A concept whereby companies integrate social and 

environmental concerns in their business operations and in their 

interactions with their stakeholders on a voluntary basis.”b

Institute of Business 

Ethics

“The voluntary actions taken by a company to address the 

ethical, social, and environmental impacts of its business 

operations and the concerns of its principle stakeholders.”c

World Bank “The commitment of business to contribute to sustainable 

economic development—working with employees, their families, 

the local community and society at large to improve the quality 

of life in ways that are both good for business and good for 

development.”d

3

The World Bank, Public Sector Roles in Strengthening Corporate Social Responsibility: A 

Baseline Study, October 2002, p. 1.
Page 7 GAO-05-744 Global CSR

group preferred the term “corporate citizenship” because business social 

and environmental efforts are indicative of business’s effort to be good 

citizens, while they believe the term “CSR” implies that those efforts are a 

responsibility rather than voluntary. Others prefer the terms “sustainable 

development” or “triple bottom line,” reasoning that business decisions and 

performance should be evaluated in terms of their economic, social, and 

environmental impacts. Other terms such as “business ethics” deal with 

one of the many concerns of CSR. Table 2 presents definitions of some 

terms related to CSR. 

Table 2: Definitions of Terms Related to Corporate Social Responsibility

Source: GAO compilation from sources listed.

a

Institute of Business Ethics, Web site, http://www.ibe.org.uk.

b

Logan David, Roy Delwin, and Regelbrugge Laurie, Global Corporate Citizenship – Rationale and 

Strategies, The Hitachi Foundation, Washington D.C.: 1997, p. 7.

c

Report of the World Commission on Environment and Development, (the Brundtland Commission) 

Our Common Future, United Nations, August 1987, p. 24.

d

The Sustainable Business Network and Ministry for the Environment, New Zealand, Enterprise3 Your 

Business and the Triple Bottom Line, Economic, Environmental and Social Performance, June 2003, 

p. 2.

Many U.S. Businesses’ 

Actions Address CSR 

Concerns 

U.S. businesses conduct many different types of actions that address CSR 

concerns that range from voluntary, such as philanthropic donations, to 

government mandated, such as disclosure of significant environmental 

conditions. These actions may or may not be part of a formal CSR effort. 

Although groups categorize business actions addressing CSR concerns 

differently, they can broadly be grouped as relating to (1) business ethics, 

(2) community development, (3) environment, (4) governance, (5) human 

Term Definition 

Business Ethics “The application of ethical values to business behavior.”a

Corporate Citizenship “The conduct of business in ways that reflect proactive, 

responsible behavior in business and in dealings with all 

constituents and with respect to communities, society, and the 

natural environment more generally.”b

Sustainable 

Development

“[development that] meets the needs of the present without 

compromising the ability of future generations to meet their own 

needs.”c

Triple Bottom Line “A method that allows companies to assess their performance 

against three bottom lines: environmental, social, and 

economic.”d
Page 8 GAO-05-744 Global CSR

rights, (6) marketplace, and (7) workplace.4 In our discussions with 

representatives of U.S. corporations, which are noted as leaders in CSR, we 

identified illustrative examples of U.S. companies’ actions that address 

these categories of CSR concerns. 

Business Ethics Business actions addressing the CSR concern of business ethics involve 

values such as fairness, honesty, trust and compliance, internal rules, and 

legal requirements. Among the actions taken to address business ethics are 

incorporating ethics into corporate value and mission statements, 

developing ethics codes, conducting ethics training, and monitoring ethical 

performance. In one example from the companies we interviewed, the 

company had recently trained its workforce—including all levels of 

management—on its standards of business conduct and now publishes 

these standards in 20 languages.

Community Development Business actions addressing the CSR concern of community development 

involve business policies and practices intended to benefit the business and 

the community economically, particularly for low-income and underserved 

communities. Community development activities include employing and 

training disadvantaged workers, partnering with minority- and womenowned businesses, and locating facilities in underserved communities. One 

business we interviewed with a factory in South Africa works with its 

employees to develop the physical structures of schools for youth and 

adults in that community.

Environment Business actions addressing the CSR concern of the environment involve 

company policies and procedures to ensure the environmental soundness 

of its operations, products, and facilities. Examples include pollution 

prevention, energy efficiency, and supply-chain environmental 

management. One company we interviewed stated that it strives to exceed 

minimum U.S. government standards for toxic emissions, even in foreign 

countries. The company stated that it had sent a team of specialists to 

Mexico to bring a Mexican facility to the U.S. standard.

Corporate Governance Business actions addressing the CSR concern of corporate governance 

involve the broad range of policies and practices that boards of directors 

use to manage themselves and fulfill their responsibilities to investors and 

4

Business for Social Responsibility Education Fund, Corporate Social Responsibility: A 

Guide to Better Business Practices, 2000. 
Page 9 GAO-05-744 Global CSR

other stakeholders. Examples include developing processes for 

communication with stakeholders, adopting formal board guidelines, and 

implementing board and Chief Executive Officer (CEO) performance 

evaluations. 

Human Rights Business actions addressing the CSR concern of human rights involve 

assuring basic standards of treatment to all people, regardless of 

nationality, gender, race, economic status, or religion. Among the concerns 

in developing human rights policies are to avoid child labor in 

manufacturing, government action depriving citizens of basic civil liberties, 

and forced or prison labor. For example, a company we interviewed said it 

had signed the United Nations Global Compact, which requires businesses 

to comply with human rights requirements as one of its 10 principles.

Marketplace Business actions addressing CSR marketplace concerns involve business 

relationships with its customers and such issues as product manufacturing 

and integrity; product disclosures and labeling; and marketing, advertising, 

and distribution practices. Marketplace-related actions include establishing 

ethical marketing and advertising policies, ensuring safety and efficacy of 

products, and employing ethical sales tactics. One company we 

interviewed that views water, health, and hygiene as their business stated it 

had developed low-cost water purifying systems and products to save 

water in hand washing and improve the lives of consumers in developing 

countries.

Workplace Business actions addressing CSR workplace concerns generally involve 

human resource policies that directly impact employees, such as 

compensation and benefits, career development, and health and wellness 

issues. Examples of workplace CSR actions include adoption of global 

workplace standards, involvement of employees in business decisions, and 

establishment of employee grievance policies and procedures. 

Business, Civil Society, 

Investor Groups, 

Multilateral Organizations 

and Government Play 

Important Roles in Shaping 

CSR

Businesses play the central role in determining their efforts to address CSR 

concerns, but these efforts can also be influenced by the actions of civil 

society, investor groups, multilateral organizations, and government. 
Page 10 GAO-05-744 Global CSR

Businesses’ Role in CSR Businesses play a central role in CSR by determining which social and 

environmental issues are addressed and how they are addressed. CSR 

literature notes that there is a growing recognition by businesses that CSR 

includes the way the company runs its core business, not just its 

philanthropic activities. Businesses can further influence CSR in their 

relationships with other firms through business networks, intermediaries, 

and supply chains. For example, a business may require or promote CSR 

among its business partners.

Available but not necessarily representative data on U.S. business efforts to 

address CSR concerns suggests that many firms conduct some CSR efforts 

and that a small number of firms hold themselves to more rigorous non 

financial reporting standards on social, economic and environmental 

information. A 2002 survey of U.S. firm involvement in sustainability (a 

closely related term to CSR) included responses from 140 U.S.-based firms 

that were likely among the most active U.S. companies in CSR.5

 Threequarters of responding firms reported practicing some form of 

sustainability. Large firms, defined as those having revenues over $25 

billion annually, were more likely than smaller firms to issue sustainability 

reports, according to that same survey. Over half of the firms issuing a 

sustainability report indicated that they were following Global Reporting 

Initiative (GRI) guidelines. The GRI is an independent institution that 

disseminates globally applicable sustainable reporting guidelines for 

companies use in reporting on economic, environmental and social 

dimensions of their activities, products, and services. As of March 2005, 69 

U.S. firms had registered to use the GRI guidelines for reporting CSR 

Issues. Similarly, 71 U.S. firms have signed onto the United Nations 

Global Compact. Signatories to the Global Compact voluntarily agree to 

support its 10 principles in areas of human rights, labor, environment, and 

anticorruption policies. 

Available information from some surveys suggest that business leaders 

address social issues for business as well as for other reasons, including 

consistency with their core operating values. Two recent surveys of 

business executives reported that businesses practiced corporate 

citizenship or sustainable business practices for a variety of reasons. The 

voluntary nature of these surveys makes it impossible to project to the 

universe of all firms. In the first survey, the majority of business 

respondents concurred with the statement that “good corporate citizenship 

5

2002 Sustainability Survey Report, August 2002, PricewaterhouseCoopers, LLP.
Page 11 GAO-05-744 Global CSR

helps the bottom line.” 6 Similarly, the majority of the respondents to the 

second survey indicated “cost savings” as a reason for adopting sustainable 

business practices.7

 The majority of firms responding to the first survey 

also indicated that their founding traditions and core organizational values 

of their companies dictate their commitment to corporate citizenship. 

Similarly, the second survey reported that the majority of responding firms 

indicated the CEO/Board commitment as a contributing reason for their 

sustainable business practices. Further, this survey reported that a number 

of respondents stated that one reason for adopting sustainable practices 

was because it was “the right thing to do.” 

Despite over 30 years of research, no consensus has been reached on the 

relationship between business social and financial performance. Numerous 

empirical research studies have attempted to determine whether those 

firms that engage in socially responsible practices also do well in terms of 

financial performance. A 1997 study that surveyed 25 years of research 

observes that, many studies find a negative relationship between these 

practices and financial performance, although the largest number of 

studies find a positive relationship.8

 More recent studies also reach a range 

of conclusions with some finding a positive association,9

 some finding at 

least a neutral association, and others finding no significant or a mildly 

negative relationship.10 A recent paper on the business justification for CSR 

6

The State of Corporate Citizenship in the U.S.: A View from inside 2003-2004, The 

Center for Corporate Citizenship at Boston College and the U.S. Chamber of Commerce 

Center for Corporate Citizenship, 2004.

7

2002 Sustainability Survey Report, August 2002, PricewaterhouseCoopers, LLP.

8

They further caution, “Even though there is hope in the large number of studies that have 

shown a positive relationship, academics and practitioners alike should be concerned with 

the variability and inconsistency in these results. Some of the reasons for these 

contradictory results stem from conceptual, operationalization, and methodological 

differences in the definitions of social and financial performance.” Griffin, Jennifer J., and 

John F. Mahon, “The Corporate Social Performance and Corporate Financial Performance 

Debate: Twenty-Five Years of Incomparable Research,” Business and Society, Mar. 1997, pp. 

5-31.

9

Association of Chartered Certified Accountants, Corporate Social Responsibility: Making 

the Business Case, London, 2002; Orlitzky, Marc, Frank L. Schmidt and Sara L. Rynes, 

“Corporate Social and Financial Performance: A MetaAnalysis,” Organization Studies, Vol. 

24, no. 3 (May-June 2003).

10Laffer, Arthur B., Andrew Coors and Wayne Winegarden, “Does Corporate Social 

Responsibility Enhance Business Profitability?” Laffer Associates, 2004 available via

www.csrwatch.com. 
Page 12 GAO-05-744 Global CSR

concludes, “It has not yet been possible to make a strong, causal, 

quantitative link between CSR actions and financial indicators such as 

share price, stock-market value, return on assets and economic value 

added.”11

The difficulty in accurately measuring CSR benefits to business 

complicates any assessment of CSR. CSR literature, as well as discussions 

with CSR experts, indicates that it can be very difficult to assess the 

profitability of CSR actions because benefits may occur far into the future 

and involve intangibles such as enhanced brand and company image or 

other goodwill. Furthermore, the authors of a recent study suggest that the 

provision of CSR will vary across industries, products, and firms. For 

example, they argue that larger, more diversified firms, and those that 

produce more highly differentiated products, may be more likely to engage 

in CSR practices than smaller firms or those that produce in less 

differentiated markets. The authors further suggest that if a firm is 

successful in implementing a CSR action, competitors may adopt similar 

measures, and this may have the effect of eroding any profit advantage. As 

a result, they argue that there should be a neutral relationship between CSR 

activity and firm performance.12

Civil Society’s Role in CSR CSR literature recognizes the impact of civil society on raising awareness 

of social issues among businesses. The World Bank defines civil society as 

the wide array of nongovernmental and not-for-profit organizations that 

express the interests and values of their members or others based on 

ethical, cultural, political, scientific, religious, or philanthropic 

considerations. Civil society organizations include community groups, 

nongovernmental organizations (NGO), labor unions, indigenous groups, 

charitable organizations, faith-based organizations, professional 

associations, and foundations. A recent report by the Kennedy School of 

Government notes that the growth in civil society is one of the drivers 

making CSR more mainstream. 

Civil society groups can serve to strengthen the links between CSR 

activities and business profits by increasing the transparency of corporate 

11Association of Chartered Certified Accountants, Corporate Social Responsibility: Making 

the Business Case, London, 2002.

12McWilliams, Abigail and Donald Siegel, “Corporate Social Responsibility: A Theory of the 

Firm Perspective,” Academy of Management Review, 2001, Vol. 26: No. 1, pp. 117-127.
Page 13 GAO-05-744 Global CSR

operations. For example, civil society activities exposing sweatshops or 

other questionable corporate activities can provide an incentive for firms to 

act in ways that would not damage their reputation. Further, civil society 

sometimes establish standards that business can use to signal compliance 

or to enhance their reputation with their customers and other stakeholders, 

potentially increasing profits and firm value. In 1997, the Council on 

Economic Priorities Accreditation Agency13 released its Social 

Accountability (SA) 8000, a voluntary standard to help companies monitor 

a variety of workplace concerns. The SA 8000 provides verification of 

corporate performance. The Coalition for Environmentally Responsible 

Economies (CERES) partnered with the United Nations Environmental 

Program (UNEP) to oversee the development of the GRI14 reporting 

guidelines in the late 1990’s. The Interfaith Center for Corporate 

Responsibility15 (ICCR), composed of over 275 religious institutions, 

published a guide to be used as a reference tool by companies to monitor 

policies in such areas as community development, environment, ethics, 

human rights and workplace issues. 

Investor Groups’ Role in CSR Investor groups such as mutual funds and pension plans are responsible for 

a growing proportion of U.S. investments and therefore, are a potentially 

increasing influence over business’s CSR actions. According to a report by 

the Social Investment Forum,16 a national membership organization of 

social investment practitioners and institutions, firms using some type of 

socially responsible investment strategy manage over 11 percent of all U.S. 

investment assets under professional management. The report further 

indicated that between 1995 and 2003 social-invested assets grew faster 

than all other types of professionally managed investment assets in the 

United States. CSR literature notes the increased activism of some 

institutional investors and their calls for increased corporate accountability 

and transparency. 

13www.cepaa.org.

14www.globalreporting.org.

15www.iccr.org.

16www.socialinvest.org.
Page 14 GAO-05-744 Global CSR

The Role of Multilateral 

Organizations in CSR

Multilateral organizations have played an active role in developing 

standards relating to CSR and in promoting the concept of CSR. The 

Organization for Economic Cooperation and Development17 (OECD) first 

published its guidelines for multinational enterprises in 1976. These 

guidelines include recommendations by OECD-member governments to 

multinational enterprises on appropriate business conduct in such areas as 

business ethics, labor relations, environmental practices, and information 

disclosure. The OECD revised the guidelines in 2000 to include a call for 

companies to respect human rights, abolish forced and child labor, and 

take a more active role in promoting environmental sustainability. The 

United Nations launched its Global Compact18 in 1999, and it now consists 

of 10 principles covering concerns with human rights, labor, environment, 

and anticorruption. The World Bank also has a number of program goals 

related to CSR, including supporting the development of environmental 

and social practices in individual businesses in emerging markets, working 

with national governments to help countries better understand and address 

CSR, and cosponsoring (with the OECD) the Global Corporate Governance 

Forum,19 which helps countries improve standards of governance for their 

corporations. 

The Role of Governments in CSR A 2002 World Bank study identified four major CSR roles for government: 

endorsing, facilitating, partnering, and mandating. Government 

endorsement of CSR can take a variety of forms, including direct 

recognition of businesses with awards. In their facilitating role, 

governments enable or provide incentives to companies to engage in CSR 

to obtain social and environmental improvements. Government partners 

with the private sector and civil society in tackling complex social and 

environmental problems. In the mandating role, governments require 

minimum CSR-related actions in laws and regulations. 

Some industrialized countries have established programs to foster CSR. 

For example, in 2001, the European Commission published a green paper 

to launch debate on how the European Union could promote CSR. 

Subsequently, the commission held a forum to foster dialogue among the 

business community, trade unions, civil society organizations, and other 

17www.oecd.org.

18www.unglobalcompact.org.

19www.gcgf.org.
Page 15 GAO-05-744 Global CSR

stakeholders on CSR.20 In May 2001, France became the first country to 

require all publicly listed companies to report on the social and 

environmental consequences of their activities. In 2000, the United 

Kingdom appointed a Minister for Corporate Social Responsibility, who 

maintains a central Web site that highlights government departments with 

CSR responsibilities. 

Although the social and economic priorities vary among developing 

countries, the high incidence of poverty and weak civil society means there 

are often fewer conventional drivers for CSR. Most developing country 

governments seek foreign investment to help them grow and develop and 

must attempt to balance development with other social and environmental 

goals. A 2002 World Bank report notes that developing country 

governments do not often participate in the development of CSR policies 

and standards.21 Another report on public sector support for CSR among 

global supply chains states that the lack of resources for developing 

country governments, which do not view export sector workplaces as the 

highest priority for social and environmental intervention, hinders progress 

in addressing CSR-related issues in global supply chains.22

The effectiveness of government programs supporting CSR in achieving 

public policy goals has not been established, in part because of the 

difficulties inherent in such assessments. CSR literature notes that it is 

difficult to assess the impact of CSR-related partnerships on public policy 

goals because it is difficult to measure or compare their intangible inputs 

and outputs. Representatives from the four academic institutions we 

interviewed agreed that it was difficult to assess the impact of CSR on 

social goals. Several of these academicians also noted that they had not 

seen good work measuring the benefit of CSR to society. One noted that 

CSR is incremental and that it is hard to measure incremental 

improvements.

20http://europa.eu.int/comm/employment_social/soc-dial/csr/.

21Public Sector Roles in Strengthening Corporate Social Responsibility: A Baseline Study, 

the World Bank, October 2002.

22Public Sector Support For The Implementation of Corporate Social Responsibility (CSR) 

in Global Supply Chains: Conclusions from Practical Experience, the World Bank, 

December 2004.
Page 16 GAO-05-744 Global CSR

Although No Broad 

Federal CSR Mandate 

Exists, Federal 

Agencies Conduct 

Many Activities 

Related to Global CSR

While the federal government does not have a formal role in global 

corporate social responsibility, we identified over 50 programs, policies, 

and activities at 12 agencies that are related to global CSR using a data 

collection instrument completed by agency officials. We narrowed down 

the programs to those that were ongoing in fiscal year 2003 or afterwards, 

those that may affect U.S. corporations’ CSR efforts overseas, including 

their supply chains, and those that touch on key components of CSR, such 

as labor, environment, human rights, community development and 

corporate governance. As illustrated in the text below, most of these 

activities can be loosely categorized into the four key roles of governments 

in global CSR identified by the World Bank: endorsing, facilitating, 

partnering and mandating.23 Appendix II catalogs all the programs we 

identified by agency.

There Is No Comprehensive 

Mandated Federal Role, 

Definition, or Agency 

Coordination in Global CSR 

There is no comprehensive legislation mandating a federal role in global 

corporate social responsibility, and few agencies actually define CSR. Many 

agencies work with the private sector on issues that are generally covered 

by the concept “corporate social responsibility,” such as labor, 

environment, human rights and corporate governance, but few agencies 

define corporate social responsibility or label their activities CSR. Some 

agencies noted that they use other terms, such as corporate stewardship or 

corporate citizenship, to refer to similar issues. 

While there is no law designating a lead agency to coordinate federal 

government activities related to global corporate social responsibility, 

United States agencies are currently in the initial stages of creating a Web 

site to catalogue federal CSR initiatives. This informal interagency 

initiative, led by staff at the Inter-American Foundation (IAF), initially 

involved the Department of State, USAID, the Department of Commerce, 

the Environmental Protection Agency (EPA), and the Overseas Private 

Investment Corporation (OPIC). The purpose of the initiative is to publicize 

the U.S. government programs and resources that promote good corporate 

practices or CSR to businesses and NGOs. The IAF expects to make the 

Web site publicly available sometime in 2005. 

23In trying to categorize programs into these roles, we identified 9 programs that did not 

clearly fit into these categories. We also identified 13 programs that appear to have elements 

of more than one category. 
Page 17 GAO-05-744 Global CSR

Some agencies also reported that while they do not have a formal program 

focused on global corporate social responsibility, they have a number of 

initiatives that relate to global CSR. For example, officials at the 

Department of State, which had the greatest number of initiatives related to 

global CSR, told us that they house their CSR-related activities in several 

bureaus linked through informal coordination. Likewise, at the EPA, which 

also had a large number of related initiatives, an official told us that the 

agency does not have a specific CSR program, but acknowledged there 

were many links between EPA programs on the environment and the goals 

of CSR. Further, EPA recently completed an internal inventory of its 

voluntary initiatives that partner with corporations to improve 

coordination and policy consistency. 

While Agency Perspectives 

on CSR Vary, Many Federal 

Programs in Pursuit of 

Broader Mission Goals Are 

Related to Global CSR 

Agency perspectives on global corporate social responsibility vary from 

active endorsement to reluctance to labeling their programs CSR. For 

example, several bureaus in the Department of State foster corporate CSR 

practices as a means to enhance their own efforts aimed at public 

diplomacy, protecting human rights, and other areas. Similarly, the 

Department of Commerce has officially endorsed corporate social 

responsibility, stating that American companies must follow the highest 

standards of conduct anywhere they do business and that American 

companies contribute to the communities in which they do business. 

Through good corporate governance and global corporate social 

responsibility, the Department of Commerce maintains that American 

companies are helping to spread democratic values and prosperity around 

the globe, which leads to greater economic freedom, higher standards of 

living, and greater social and political freedoms. However, other agencies 

do not want their programs to be labeled CSR because they do not see it as 

part of their mission or believe they lack authority to engage in CSR 

activities. For example, while officials from the Office of the U.S. Trade 

Representative acknowledged that the agency undertakes some activities 

that might complement CSR, they stated that the agency’s mission is to 

negotiate trade agreements, not to engage in CSR efforts. Similarly, a senior 

official at the Department of Labor said that, while the department has 

many activities that could conceivably be seen as supporting global CSR, 

the department is not doing them for that reason. He believes the 

department lacks specific authority to do work on CSR. 

Some agencies without a formal position on CSR actively take advantage of 

mutual interests between their missions and company CSR practices to 

achieve their broader mission goals. For example, USAID and the IAF 
Page 18 GAO-05-744 Global CSR

leverage resources from corporations for development missions, and EPA 

intends to control pollution through voluntary programs with corporations. 

Specifically, USAID’s Global Development Alliance aims to achieve the 

agency’s development goals by leveraging resources from the private sector 

and other partners. USAID’s alliances address a range of issues, such as 

encouraging economic growth, developing businesses and workforces, 

addressing health and environmental problems, and expanding access to 

education and technology. To illustrate, USAID partnered with one U.S. 

corporation operating in post-war Angola to build up the country’s business 

sector and equip Angola’s workforce with necessary business skills. The 

company and USAID each agreed in 2002 to provide $10 million over 5 

years for a series of projects to strengthen small and medium-sized 

businesses, including helping refugees and former soldiers to return to 

agriculture, developing an enterprise development bank, and supporting 

the creation of an agricultural training center. From fiscal years 2002 to 

2004, USAID reported funding approximately 290 public-private alliances 

with over $1.1 billion in federal money and over $3.7 billion in partner 

contributions.24 Figure 1 illustrates how federal agency programs 

sometimes complement company CSR practices.

24Funding reported by USAID includes moneys obligated in the planning stage as well as 

actual expenditures. The partner contributions include committed contributions that are 

projected for future years as well as contributions already expended by partners. 
Page 19 GAO-05-744 Global CSR

Figure 1: Some Federal Programs and Activities Complement U.S. Corporate CSR 

Practices

Other agencies, such as OPIC, the Export-Import Bank of the United States 

(Ex-Im Bank), and the U.S. Securities and Exchange Commission (SEC) 

engage in activities that are related to CSR, generally in response to 

statutory or congressional requirements rather than based on a formal 

agency decision on CSR. 

Many Federal CSR-Related 

Programs Are Recent, Focus 

on a Range of Countries and 

Sectors, and Have Small 

Budgets and Staffs

Many of the programs we identified started in the last 5 years. For example, 

the Department of State’s Partnership to Eliminate Sweatshops Program 

started in 2000 to provide grants to address unacceptable working 

conditions in manufacturing facilities overseas that produce goods for the 

U.S. market. In fiscal year 2003, the program funded the development of a 

confidential database of factory monitoring reports that would be 

accessible by companies seeking compliance information on factories in 

their supply chains. The effort was in response to U.S. companies that have 

cited lack of information about factory compliance as an obstacle to 

improving their own compliance efforts and responsible behavior. 

Since 2001, several presidential initiatives aimed at foreign assistance have 

partnered with companies to achieve the initiative goals, which also 

complement corporate CSR practices. For example, one interagency

Federal programs and

activities relating to

global environmental

and social goals

U.S. companies’ 

global CSR practices

Mutual

interests

Source: GAO.
Page 20 GAO-05-744 Global CSR

presidential initiative led by the Department of Commerce,25 the Digital 

Freedom Initiative, was announced in 2003 to partner with U.S. businesses 

to transfer the benefits of information and communication technology to 

businesses in the developing world.26 The program has over 90 U.S. 

corporate and nonprofit organization partners that provide volunteers and 

other resources to support its activities. As part of the initiative, in Senegal, 

a U.S. information technology company is developing 12 academies to train 

Senegalese to install, manage, and maintain modern computer networks.27

Federal agency activities related to CSR focus on a range of countries and 

sectors. For example, the International Child Labor Program at the 

Department of Labor funds projects in Bangladesh, Pakistan, Central 

America, and West Africa that work with various industry associations to 

address the use of child labor. The Department of State funds a number of 

projects in China and other countries in various sectors, including the 

apparel industry and the extractives sector. Federal programs and activities 

assist U.S. companies with their philanthropic efforts, as well as with their 

efforts to be socially responsible in their core business operations, 

including their supply chains. None of the programs we identified were 

specifically designed to monitor company CSR activities.

Most federal programs, policies, and activities related to CSR have small 

budgets and staffs. Many programs do not specifically track budget and 

staffing information for their CSR-related activities. Of the programs 

reporting budget and staffing information, most are relatively small. The 

Departments of Commerce and State and EPA, which identified the largest 

numbers of discrete initiatives related to CSR, reported relatively modest 

budgets and staffing for their initiatives. In total, only four programs 

reported budgets at or over $2 million in fiscal year 2003 for CSR-related 

activities. The two programs that reported the largest annual budgets of 

25Members of the Digital Freedom Initiative Interagency Working Group include the 

Department of Commerce, USAID, the Department of State, the Peace Corps, the Small 

Business Administration, and the Federal Communications Commission.

26The Digital Freedom Initiative is part of the Volunteers for Prosperity Initiative. Managed 

by USAID’s Office of Volunteers for Prosperity, this is also an interagency Presidential 

initiative that promotes international voluntary service by highly skilled American 

professionals in support of the nation’s global health and prosperity agenda.

27According to a Commerce official, the Digital Freedom Act (DFI) has no specific funding. 

The program uses some USAID money already assigned to projects that complement the 

DFI program. For example, these training efforts are a component of an ongoing alliance the 

company has through the USAID Global Development Alliance.
Page 21 GAO-05-744 Global CSR

around $20 million and $30 million are at the Department of Labor28 and 

USAID, respectively. Similarly, many federal CSR efforts are staffed by 

agency officials with multiple responsibilities, working part time on the 

effort. 

Federal Agencies Conduct a 

Range of Activities that 

Endorse, Facilitate, Partner 

and Mandate Company CSR 

Activities

Most U.S. government programs, policies, and activities related to global 

CSR can be loosely categorized into the World Bank’s four public sector 

roles: endorsing, facilitating, partnering, and mandating.29 These roles 

range from the least government involvement—endorsing companies’ 

voluntary efforts above and beyond compliance with laws and 

regulations—to the most government involvement through mandating 

behavior consistent with CSR. Although some federal efforts related to 

CSR can be classified as serving more than one role, roughly two-thirds of 

the U.S. government programs, policies, and activities, that we identified 

fell in the middle of the spectrum by either facilitating and/or partnering 

with companies on their voluntary CSR efforts. The remainder either fell 

into the mandating and endorsing roles, or outside the World Bank’s roles. 

Figure 2 illustrates the range of U.S. government activities in the World 

Bank framework. See appendix II for a complete listing and brief 

description of the 54 CSR-related programs and activities that we identified 

at 12 U.S. agencies.

28However, an official from the Protecting the Basic Rights of Workers program at the 

Department of Labor, which reported a $20 million budget in fiscal year 2003, said the 

program received no funding from the fiscal year 2005 appropriations. 

29See Fox, Tom; Ward, Halina; and Howard, Bruce. Public Sector Roles in Strengthening 

Corporate Social Responsibility: A Baseline Study. The World Bank, 2002. The report 

describes four principle public sector roles as follows (The report acknowledges overlaps 

across the four categories):

Endorsing: Political support and public sector endorsement of the concept of CSR and in 

particular, CSR-related initiatives. 

Facilitating: Enabling or incentivizing companies to engage with the CSR agenda or to drive 

social and environmental improvements.

Partnering: Bringing the complementary skills and inputs of the public sector, the private 

sector, and civil society in tackling complex social and environmental problems.

Mandating: Defining minimum standards for business performance embedded within the 

legal framework.
Page 22 GAO-05-744 Global CSR

Figure 2: Illustrative U.S. Government Activities Related to CSR Range from 

Endorsing CSR to Mandating CSR

Endorsing The U.S. government has a number of awards programs that endorse CSR 

by recognizing companies for socially responsible activities. U.S. officials 

also endorse the concept to audiences through public speeches on an ad 

hoc basis. Some examples of endorsing include:

• The Department of State’s annual Award for Corporate Excellence, 

which emphasizes the role U.S. businesses play to advance good 

corporate governance, best practices, and democratic values overseas. 

Since 1999, 12 businesses have received the Award for Corporate 

Excellence,30 following nominations submitted by Chiefs of Missions at 

U.S. Embassies and Consulates abroad. In fiscal year 2004, the 

Department of State received 50 award nominations from Chiefs of 

Missions. 

• The EPA’s Climate Protection and Stratospheric Ozone Protection 

Awards, which encourage and recognize outstanding corporate 

environmental efforts in climate protection. For example, a 2002 

corporate recipient of EPA’s Climate Protection Award reduced its 

energy use by over 30 percent internationally and offset all the 

remaining greenhouse gas emissions both in the United States and 

overseas.

Endorsing Partnering Mandating Facilitating

Source: GAO illustration based on World Bank report.

Provide awards for 

CSR activities

Discuss CSR in 

public speeches

Provide CSR 

information

Provide grants to 

address CSR issues

Facilitate publicprivate partnerships

Convene 

stakeholders

Mandate CSR for 

participating 

companies

Regulate CSRrelated issues

30Typically, one award is given to a multinational enterprise and one award is given to a 

small and medium-sized enterprise each year, but that is flexible and up to the selection 

committee to decide.
Page 23 GAO-05-744 Global CSR

Facilitating The U.S. government facilitates CSR by providing information, funding or 

incentives to companies and other players to engage in CSR-related issues. 

Some examples include: 

• The Department of Commerce’s training on rule of law, human rights, 

and corporate stewardship for commercial service employees. The 

training helps these officers provide information on corporate 

stewardship issues to companies involved in the export promotion 

process. Additionally, commercial service officers can use this 

information in their work with overseas chambers of commerce. As of 

March 2005, 260 commercial service employees had received the 

training since the program’s inception in 2003.31

• The Ex-Im Bank’s Environmental Exports Program, which began in 

1993. The program enhances the Ex-Im Bank’s financing package for 

such U.S. goods and services, thereby encouraging foreign buyers to 

purchase U.S. exports that are beneficial to the environment. 

Specifically, the program extends loan repayment terms, finances the 

interest accrued during the disbursement period, and finances local 

costs to an amount equal to 15 percent of the contract price. Exports 

eligible for the program include renewable energy projects, water 

treatment projects, air quality monitoring instruments, equipment for 

waste collection and clean up, services for environmental assessments 

and ecological studies, and other projects that meet specified emission 

thresholds. During fiscal year 2003, Ex-Im Bank supported over $173 

million of environmentally beneficial goods and services, including $13 

million in products and technologies related to renewable energy.

Partnering Several U.S. government programs partner with corporations or convene 

partnerships with key stakeholders, which can help companies accomplish 

their CSR initiatives. In addition to USAID’s Global Development Alliance 

discussed earlier, representative examples include: 

• EPA’s Climate Leaders Program, which partners with companies to 

achieve EPA’s goal of protecting the environment. The Climate Leaders 

Program is a voluntary government partnership that enlists major U.S. 

companies to set an aggressive greenhouse gas reduction target. EPA 

established inventory protocols to assist the companies in tracking their 

31This figure includes 183 commercial officers, 56 foreign service national commercial 

specialists, and 21 domestic trade specialists.
Page 24 GAO-05-744 Global CSR

success toward their greenhouse gas target. Partners receive training 

and technical assistance in completing the greenhouse gas inventories, 

and EPA works with each partner to develop standard Inventory 

Management Plans. EPA plans to provide recognition in later years after 

partners have met or exceeded their targets, which are publicly 

available on the EPA Web site. 

• The Voluntary Principles on Security and Human Rights, which provide 

guidance to oil and mining companies on how to ensure respect for 

human rights in their security procedures. In 1999, together with the 

government of the United Kingdom, the Department of State convened 

international NGOs with U.S. and United Kingdom oil and mining 

companies concerning human rights abuses by hired security forces. A 

set of voluntary principles was developed through collaboration with 

the relevant stakeholders. According to a State Department official, 

nearly every major oil and mining company is now a participant in the 

Voluntary Principles process. 

Mandating While there is debate over whether complying with laws and regulations 

constitute CSR, a number of federal requirements and regulatory 

mechanisms that mandate social and environmental issues could fall under 

the CSR umbrella. Examples of regulations and agencies that require 

participating companies to comply with CSR-related requirements 

include:32

• An SEC rule,33 which provides anyone who owns more than $2,000 in a 

company’s stock for more than 1 year with the opportunity to propose 

issues for shareholders to vote on. SEC ensures that companies do not 

exclude shareholder proposals for vote at annual company meetings, 

unless they meet the legal criteria for exclusion outlined in the rule. 

According to an investor group that tracks shareholder proposals, out of 

1,052 shareholder proposals that were filed at U.S. companies for 2005 

meetings, approximately 350 proposals focused on issues related to 

32In addition to the regulations listed here, various respondents also mentioned the Foreign 

Corrupt Practices Act; the Sarbanes-Oxley Act of 2002; the Alien Tort Claims Act; and import 

controls, such as those prohibiting the importation into the United States of merchandise 

produced by forced or indentured child labor as laws or regulations that impact companies’ 

CSR activities.

33Rule 14a-8 of the Securities Exchange Act of 1934.
Page 25 GAO-05-744 Global CSR

corporate social responsibility, such as global warming and global labor 

standards. 

• The Overseas Private Investment Corporation (OPIC), which provides 

long-term financing and/or political risk insurance to U.S. companies 

investing in over 150 emerging markets and developing countries, 

requires that all beneficiary companies comply with certain CSR 

criteria. These requirements cover issues that include host country 

development impact, environmental protection, international labor 

rights, and human rights. The requirements are written into contracts, 

and OPIC specifies that they must be carried down to the subcontract 

level. 

Strengthening Enforcement and 

Compliance with CSR-Related 

Regulations in Other Countries 

In addition to the four roles discussed above, a number of U.S. programs 

foster a business environment conducive to CSR by working with other 

national governments to strengthen compliance and enforcement of social 

and environmental regulations in countries where U.S. companies operate. 

These efforts serve to protect U.S. businesses from competing with 

companies that are not complying with weakly enforced laws and 

regulations. Some examples include:

• The Department of Labor’s program on Protecting the Basic Rights of 

Workers, which works with host country ministries of labor to improve 

adherence to international core labor standards and acceptable 

conditions of work in developing countries. In accordance with a 

congressional appropriation, in fiscal year 2003 the office allocated $20 

million for these efforts worldwide, including in a number of countries 

in Africa, the Americas, Asia, and in Ukraine. However, according to an 

agency official, the budget decreased significantly in subsequent years 

to $2.5 million in fiscal year 2004 and no funding in fiscal year 2005.

• EPA’s International Compliance Assurance Division, which works with 

governments to ensure compliance of companies with environmental 

standards. Since 2001, approximately 20 trainings have been held for 

officials from a wide range of countries, including South Africa, Nigeria, 

Indonesia, Vietnam, Brazil, Guatemala, and Egypt, among others. 
Page 26 GAO-05-744 Global CSR

Perspectives on the 

Appropriate 

Government Role in 

CSR Vary, but Many 

Support Federal 

Assistance for 

Voluntary Efforts

Our review of CSR literature revealed support for government involvement 

in CSR varied with views of CSR’s connection to business profit. Opinions 

of those we interviewed on the impact of existing federal agency efforts 

and the appropriate government role related to CSR generally revealed a 

desire for government involvement and the widest support for federal 

agency activities that assist businesses in their voluntary efforts.

Perspectives on the 

Appropriate Government 

Role in CSR Vary with Views 

of CSR’s Connection to 

Business Profits

Based on our review of CSR literature, perspectives on the appropriate role 

of government in CSR vary, but generally correlate with three major 

perspectives on the connection of CSR to business profits: (1) free-market 

economic, (2) “business case,” and (3) social issues. 

Free-Market Economic 

Perspective

Those with a free-market economic perspective generally view businesses 

engaging in CSR as a potential taking of profits from the business owners 

that will ultimately diminish the effectiveness of the business and a freemarket economy. The well known economist, Milton Friedman refers to the 

doctrine of “social responsibility” as fundamentally subversive in a free 

society, stating, “there is one and only one social responsibility of 

business—to use it[s] resources and engage in activities designed to 

increase its profits so long as it stays within the rules of the game, which is 

to say, engages in open and free competition without deception or fraud.”34

According to this free-market economic perspective, business managers 

have a primary duty to maximize value for shareholders and in doing this 

businesses serve the general welfare by directing resources to produce 

goods and services society wants. In this view, engaging in CSR actions that 

are not based on profitability can affect not only business performance but 

also potentially reduce the general welfare of society. David Henderson, an 

economist who has written extensively questioning the value of CSR, 

recently wrote “The general adoption of CSR, in response to social 

pressures, would undermine the market economy and make businesses 

34Friedman, Milton, “The Social Responsibility of Business is to Increase Profits.” New York 

Times Magazine, September 13, 1970.
Page 27 GAO-05-744 Global CSR

less effective in performance of their primary role.”35 While this free-market 

economic perspective recognizes that government has a role in structuring 

the legal framework of a market economy, those with this view do not 

support government involvement in the general adoption of the concept of 

CSR. 

Business-Case Perspective Many CSR proponents cite a “business-case” perspective, in which 

business CSR efforts are supported based on their contribution to business 

profit and value. Those with the business-case perspective reason that 

businesses can undertake CSR actions that will increase businesses’ value 

or return on investment in terms of increased revenue, increased asset 

value, or reduced cost. Business leaders often indicate that their CSR 

practices help their bottom line. Supporters of the business-case 

perspective assert that addressing important social issues in the business 

environment can contribute to the long-term value of the firm. Supporters 

of this perspective have developed many different lists of potential benefits 

to a business in adopting CSR. For example, one discussion of the business 

case identified the following six potential business benefits:36

• Operational cost savings—Investment in environmental efficiency 

measures such as waste reduction and energy efficiency can save 

money as well.

• Enhanced reputation—Good company performance in relation to 

sustainability issues can build reputation, while poor performance, 

when exposed, can damage brand value.

• Increased ability to recruit, develop, and retain staff—These can 

be direct results of introducing ‘family friendly’ policies. Also, 

volunteering programs may improve employee morale and loyalty to the 

company.

35Henderson, David, “The Role of Business in the Modern World: Progress, Pressures and 

Prospects for the Market Economy.” (Landover Maryland, Competitive Enterprise Institute) 

2004, p. 20.

36Raynard, Peter and Forstater, Maya, Corporate Social Responsibility: Implications for 

Small and Medium Enterprises in Developing Countries, The United Nations Industrial 

Development Organization, Vienna, 2002, pp. 8 and 9, with reference to: Raynard, P & 

Forstater, M (2001) The Business Case for Sustainability. London, SIGMA.
Page 28 GAO-05-744 Global CSR

• Better relations with government—More favorable government 

relations and regulatory rulings are key for many companies looking to 

extend their business in politically unstable conditions. 

• Anticipation and management of risk—Managing risk is increasingly 

complex in a global market environment. Greater oversight and 

stakeholder scrutiny of corporate activities makes managing risk key to 

company success. 

• Learning and innovation—The interaction required with a wide range 

of individuals and organizations outside the traditional business 

relationships can encourage creativity, which can lead to increases in 

profitability.

The benefits of CSR can also be viewed in a global context, with the 

interaction between multinational businesses and foreign host-country 

governments concerning issues of foreign direct investment and business 

operations in host countries, generally. Engaging in CSR practices may help 

the multinational business manage certain political and reputation risks in 

their operations, particularly with regard to host countries in the 

developing world.37

Negative publicity can seriously undermine the reputation of multinational 

business internationally, and it can create a political climate that may lead a 

host government to take actions, such as regulation or other restrictions, 

that can undermine the firm’s efficiency and profitability. In addition, some 

developing countries may not have adequate laws to address concerns 

about workers rights or the local environment, and even where they do, 

these countries may not have the resources, technical expertise, or the 

willingness to adequately enforce their laws and regulations. By 

demonstrating a commitment to good business practices, such as through 

CSR, multinational businesses may send a signal that they are committed to 

helping mitigate problems or issues that may arise regarding their 

operations, thus creating a more positive climate in which to pursue 

business opportunities.

Those with a “business case” perspective view a major role of government 

as supporting business’s voluntary CSR-related efforts. Surveys of business 

37Haufler, Virgina, A Public Role for the Private Sector: Industry Self-Regulation in a 

Global Economy (Washington, D.C.: Carnegie Endowment for International Peace) 2001.
Page 29 GAO-05-744 Global CSR

leaders indicate that they believe that CSR should be completely voluntary. 

This perspective stresses business involvement in the development of CSR 

efforts because the business knows its resources and constraints and can 

best identify potential benefit to the business. Supporters of this 

perspective look for business to work with civil society and government to 

develop CSR approaches that address relevant social issues. Subscribers to 

this view see advantages of government working with business. For 

example, in a recent book Walking the Talk the Business Case for 

Sustainable Development, the authors state, “Governments too, have a 

vested interest in collaborating with companies. Governments are spending 

less time on command-and-control regulations and more on forms of 

cooperation with industry to produce workable, incentive based solutions. 

They are finding that historically intractable social and environmental 

problems, such as poverty, disease, and threats to biodiversity, can only be 

solved through partnership.”38

Social Issues Perspective Those with a social issues perspective focus on the extent to which 

business addresses social issues, but opinions within this group are mixed 

on whether to rely on voluntary or mandatory CSR approaches. A 1999 

survey of 25,000 consumers worldwide found that two-thirds of the 

population in countries surveyed indicated that “they want companies to go 

beyond their historical role of making a profit, paying taxes, employing 

people and obeying all laws; they want companies to contribute to broader 

societal goals as well.”39 Some supporters of the social issues perspective 

cite successes of some business voluntary CSR efforts in contributing to 

social issues. Some also call on business to voluntarily adopt CSR practices 

to address social issues beyond what might be justified by business profit. 

Such organizations see a role for government in fostering voluntary 

corporate CSR actions. 

Others with a social issues perspective take a very different view. They 

believe that business is primarily concerned with profit and thus should not 

be trusted to develop solutions for important social issues on their own. 

According to those with this view, business involvement in CSR efforts can 

become merely a branch of public relations instead of effectively 

38Holiday, Charles O. Jr.; Schmidheiny, Stephan; and Watts, Phillip, Walking the Talk: The 

Business Case for Sustainable Development, Greenleaf, Sheffield; 2002, p. 156. 

39The Millennium Poll on Corporate Social Responsibility, Conducted by Environics 

International Ltd. In cooperation with the Prince of Wales Business Leaders Forum and the 

Conference Board. Consumers in 23 countries were surveyed.
Page 30 GAO-05-744 Global CSR

addressing social problems.40 As a result, they feel that governments should 

move to mandate CSR. Several groups have argued for increased 

government engagement in CSR initiatives aimed at ensuring that business 

adhere to international norms. For example, one consumer group’s position 

paper on CSR calls on governments and international agencies to introduce 

legislation to set standards that transnational corporations must observe 

and also a framework for monitoring corporate behavior.41 Similarly, 

another group noted that there is a need for increased government 

engagement in CSR initiatives aimed at ensuring that businesses adhere to 

international norms because governments are the only actors with 

jurisdiction over the private sector.42 Another human rights NGO states that 

voluntary initiatives will often be ineffective and insufficient. This 

organization further states that more attention should be given to the role 

international law can play in anchoring these responsibilities in a legal 

framework that crosses national boundaries.43

Views of Groups Actively 

Engaged in CSR Vary on the 

Appropriate Role of the U.S. 

Government and the Impact 

of Current Federal Activities 

Related to CSR

In addition to reviewing the available literature, we also interviewed 32 

individuals representing groups actively engaged in CSR to obtain their 

views on the appropriate role for the federal government and the impact of 

current federal activities on their CSR efforts. Specifically, we interviewed 

14 companies, 4 business groups, 6 NGOs focused on environmental, 

human rights and labor issues, 4 investor groups, and 4 academic 

institutions (See app. I for a complete list of the respondents).44 A majority 

of respondents supported a government role in global CSR, yet views 

varied regarding the appropriate federal role and the impact of current 

activities. Most respondents generally supported government assistance 

40Behind the Mask: The Real Face of Corporate Social Responsibility, Christian Aid, p. 2.

41Consumers International and Corporate Social Responsibility, Consumers International.

42Calder, Fanny and Culverwell, Malaika, Following Up the World Summit on Sustainable 

Development Commitments on Corporate Social Responsibility, Options for Action by 

Governments, Royal Institute of International Affairs, February, Chatham House, 2005, p. 36.

43International Council on Human Rights Policy, “Beyond Voluntarism, Human Rights and 

the Developing International Obligations of Companies,” Versoix, Switzerland, 2002, p. 2.

44We selected these groups and organizations to help us obtain a broad range of 

knowledgeable and informed views on global CSR and the federal government's role in 

global CSR; our selection was not intended to be representative in any statistical sense. 

Groups that are not active in global CSR may have different views and opinions, especially 

in terms of the federal government's role. 
Page 31 GAO-05-744 Global CSR

with voluntary CSR efforts such as endorsing, facilitating, and partnering, 

while some also expressed an interest in government-mandated CSR, 

especially to increase disclosure of CSR-related information. Most 

respondents saw a need for the U.S. government to encourage foreign 

governments to enforce CSR standards to help level the playing field for 

U.S. companies adhering to high CSR standards.45 Some respondents based 

their discussion of the government role on their knowledge of current U.S. 

government activities related to global CSR, yet we found that several were 

unaware of these efforts. Also, some said they were aware of U.S. 

government efforts, but primarily cited domestic CSR efforts or initiatives 

that are not led by the U.S. government. Several respondents called for a 

greater U.S. government role in CSR, as in some other countries, and 

greater coordination of existing U.S. efforts.

Mixed Reactions Regarding the 

Impact of U.S. Government 

Efforts to Endorse CSR through 

Awards

A number of respondents were aware of U.S. government award programs 

that endorse CSR, but had mixed reactions regarding their effectiveness. 

Whereas a majority of companies we interviewed who commented on 

awards46 said they have a positive impact, for example, by motivating 

employees and validating the company’s efforts, some were not motivated 

by awards. One company in favor of government endorsing CSR through 

awards said that, although there are a lot of awards given to companies for 

corporate social responsibility, an award from the U.S. government or 

another government is credible and valuable. However, another company 

said it receives so many awards that receiving one more is not very useful, 

unless it is accompanied by significant media attention. Most of the 

business groups reacted positively to federal government awards, stating 

that awards call attention to success stories and provide a signal of the type 

of behavior the government likes, help to motivate companies, and provide 

a positive counterbalance to regulations and compliance by rewarding 

voluntary efforts. Most of the NGOs that were aware of federal government 

awards for global CSR activities were skeptical of the impact of the awards, 

questioning the nominations and selection processes and whether the 

awards are a good indicator for companies’ CSR performance. The two 

investor groups that were aware of federal government awards programs 

45For example, see The Frank Hawkins Kenan Institute of Private Enterprise, Washington 

Center, Statement of Findings: Promoting CSR in China, Sept. 2004 and Promoting Global 

Corporate Social Responsibility: The Kenan Institute Study Group Consensus, Sept. 2003.

46Respondents tended to speak generally of U.S. government and non-U.S. government 

awards, as they were not always clear whether or not a particular award was given by the 

U.S. government.
Page 32 GAO-05-744 Global CSR

thought they were a positive influence. In addition to awards, a few 

respondents also suggested the government should more actively endorse 

CSR in its own procurement processes and in government pension 

investments. 

Respondents Viewed 

Government Efforts to Facilitate 

CSR Favorably 

Many respondents from the various groups expressed support for federal 

government efforts to facilitate CSR, especially through providing 

information. Representatives from companies and other groups suggested 

that the government could play a more active role in providing information 

on setting benchmarks in areas such as the environment and human rights, 

providing information on best practices and how to start CSR activities in 

other countries, or establishing a clearinghouse with CSR-related 

information. A few respondents suggested that providing information or 

assistance would be particularly helpful for small and medium-sized 

companies and companies just getting started with CSR. 

Respondents Generally Viewed 

Partnerships with Government 

on CSR Favorably 

Many respondents viewed government partnerships with companies and 

efforts to convene stakeholders to accomplish CSR goals favorably and 

thought it was an appropriate role for the U.S. government. One company 

that has worked with USAID and the Centers for Disease Control on a 

health-related issue in Haiti said that the government is well placed to help 

companies focus on the needs of those living in poverty and that companies 

have a lot to contribute by helping to provide safe drinking water, fight 

HIV/AIDS, and improve education and economic welfare. Two NGOs that 

are aware of partnership programs had mixed reactions. For example, 

while one NGO said partnerships are helpful in bringing parties together 

and leveraging private sector resources, another NGO was concerned 

about potential conflicts of interest. Respondents from business groups, 

investor groups, and academic institutions who commented on federal 

efforts to partner with companies on CSR issues were generally positive 

about these partnerships. Many organizations supported a federal role in 

partnering by convening stakeholders to address specific CSR issues or to 

share information. For example, the Department of State’s involvement in 

developing the Voluntary Principles on Security and Human Rights was 

cited as an example of a positive effort by the U.S. government to convene 

stakeholders to address a CSR-related issue. 

Mixed Views on Government 

Mandating CSR through Laws 

and Regulations

Companies and business groups generally held mixed views regarding the 

impact of laws and regulations on company global CSR efforts, whereas 

NGOs and investor groups largely believed that laws have a positive impact 

on CSR. In general, these latter groups desired a government role in 
Page 33 GAO-05-744 Global CSR

mandating CSR, especially to increase disclosure and transparency of 

company CSR activities. A few respondents cited the lack of U.S. 

legislation or involvement in CSR as an impediment to companies’ CSR 

efforts. 

While some companies were concerned about burdensome mandates, 

several said that certain existing regulations and government efforts create 

minimum standards and level the playing field internationally, which is 

helpful to companies with active CSR programs.47 According to one 

director of CSR, the company’s initial reaction to CSR requirements, such 

as import controls, is negative because they are costly and burdensome. 

However, the company recognizes that new rules can help level the playing 

field, as not all companies voluntarily adopt high standards. Another 

company said the Foreign Corrupt Practices Act has had a positive impact 

on the company’s CSR activities by enhancing the visibility of CSR and 

helping to raise standards of transparency and governance. Similarly, 

customs legislation that set minimum criteria allows the company to 

discuss CSR standards with its suppliers and ensures that it is not the only 

company focusing on these issues, which could create a competitive 

disadvantage. A business group expressed concern that codes can also lead 

to two moral principles conflicting with each other, such as policies to 

prevent harm to animals or the environment may inhibit the ability of 

companies from discovering life-saving treatments or technologies. One 

multinational company said it upholds homogenous standards globally, so 

in that sense, U.S. programs could affect its global standards in reporting, 

building design standards, and worker health and safety. However, the 

company also noted that its own standards often exceed legal standards.

Many respondents agreed that government should play a role in promoting 

transparency and disclosure of companies’ CSR efforts. Some companies 

strongly supported a federal role in promoting transparency, yet others 

warned against regulation and adverse consequences, for example, if U.S. 

companies face regulatory burdens and are forced to disclose more than 

their foreign competitors. For example, the Sarbanes-Oxley Act of 2002 

was cited by companies as a costly and burdensome mandate. However, 

some NGOs and investor groups supported government mandating that 

companies should disclose information on CSR-related issues. Three 

47Some companies held both views: that some regulations are burdensome, while other 

regulations are useful in setting minimum standards and leveling the playing field. 
Page 34 GAO-05-744 Global CSR

academic institutions cited recent European regulations on disclosure of 

CSR issues as a model for the U.S. government.

A majority of respondents from the various groups supported a government 

role in encouraging other governments to enforce their own laws and 

standards related to common CSR issues. A few suggested that trade 

agreements offer an opportunity to encourage other governments to 

enforce CSR standards. According to one business group, 

“The single most useful activity of the U.S. government to promote corporate responsibility 

would be to promote the implementation and enforcement of existing national laws in other 

countries and to assist national governments in this regard. The majority of countries 

around the world have adequate laws, but such laws are not implemented or enforced. 

Commercial activity and private enterprise depend on national governments to set a level 

playing field so that competitive markets can flourish for the benefit of consumer and 

society. This requires . . . appropriate legal frameworks in areas such as corporate 

governance, financial disclosure, bribery and corruption, environmental protection and 

labor rights.”

Some Respondents Want More 

Coordination among U.S. CSR 

Activities and Greater Role in 

Global Leadership on CSR

Some respondents expressed a desire for more coordination among U.S. 

activities related to global CSR and pointed out that other countries are 

more involved in CSR than the U.S. government. Some noted that federal 

efforts are not well coordinated, which can make it difficult for companies 

to participate in U.S. government activities, and called for increased 

coordination among U.S. government agencies for CSR activities. Several 

respondents also expressed a desire for a greater U.S. government role in 

CSR, stating that the United States is absent from world leadership, 

especially the European Union, on this issue. According to one company, 

many European countries are involved in CSR activities; and if the U.S. 

government does not play a role regarding U.S. companies’ international 

CSR activities, leadership will go elsewhere. Similarly, another company 

wanted the U.S. government to participate in the global debate on CSR and 

to continue its efforts to represent U.S. interests in the face of the 

European Union’s more regulatory approach to CSR. 

Concluding 

Observations 

The globalization of recent decades has increased the breadth and extent of 

U.S. corporations’ operations in foreign markets, through both increased 

investment and trade. These globalization trends have led to increased 

pressure on U.S. multinational corporations to adopt more CSR-related 

activities in their global operations, particularly for developing countries. 

Nevertheless, the extent that U.S. multinationals adopt CSR practices 

continues to vary by industry, location, and by individual firm priorities. At 
Page 35 GAO-05-744 Global CSR

the same time, if the recent CAFTA debate in Congress is any guide, the 

U.S. government also faces calls to strengthen labor, environmental, and 

social conditions abroad. Thus, the debate over the right balance between 

private sector and government roles in achieving these CSR-related goals 

will likely continue.

Important public policy questions have been raised by the trends in 

globalization and global corporate social responsibility such as whether the 

U.S. government should adopt an official position regarding global CSR. 

However, the dichotomy of views regarding the benefits of CSR to business 

and society complicates any consensus on the appropriate government 

role. Our research shows that U.S. federal agencies already conduct a 

number of programs and activities that overlap and/or interact with 

corporate global CSR efforts. In addition, our interviews with agency 

officials indicate many view CSR as a useful complementary tool for 

attaining their broader policy missions. Key private sector players in CSR, 

meanwhile, indicate that they generally found current U.S. government 

activities helpful in their voluntary CSR efforts. More generally, it appears 

that CSR—even if not a substitute for regulation—has resulted in the 

commitment of U.S. multinational resources, and focus on issues of 

importance to the U.S. and to host countries. The challenge for the U.S. 

government is to determine how global CSR fits within the broader range of 

policy tools directed at achieving sustainable improvements in the quality 

of life for both U.S. and foreign citizens.

Agency Comments and 

Our Evaluation

We provided a draft of this report to the Administrator, Agency for 

International Development; the Administrator, Environmental Protection 

Agency; the President, Export-Import Bank; the President, Inter-American 

Foundation; the President, Overseas Private Investment Corporation; the 

Executive Director, Securities and Exchange Commission; the U.S. Trade 

Representative; and the Secretaries of the Departments of Commerce, 

Energy, Labor, State, and the Treasury. We received technical comments 

from the Agency for International Development; the Environmental 

Protection Agency; the Export-Import Bank; the Inter-American 

Foundation; the U.S. Trade Representative; and the Departments of 

Commerce, Labor, and State. We revised the text based on these comments, 

where appropriate.
Page 36 GAO-05-744 Global CSR

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

date of this letter. At that time, we will send copies of this report to 

interested Congressional Committees and to the Agency for International 

Development; Environmental Protection Agency; the Export-Import Bank; 

the Inter-American Foundation; the Overseas Private Investment 

Corporation; the Securities and Exchange Commission; the U.S. Trade 

Representative; and the Departments of Commerce, Energy, Labor, State, 

and Treasury. We will also make copies available to others upon request. In 

addition, this report will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-4347 or at yagerl@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this report. GAO staff who made major contributions to this 

report are listed in appendix III.

Loren Yager, Director, 

International Affairs and Trade
Page 37 GAO-05-744 Global CSR

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

Members of the House of Representatives asked us to provide information 

on the federal involvement in global corporate social responsibility. This 

report describes (1) global corporate social responsibility (CSR), (2) 

federal agency policies and programs relating to global CSR, and (3) 

different perspectives regarding the appropriate U.S. government role and 

views on the impact of current federal activities on corporate global CSR 

efforts.

To describe global corporate social responsibility, we reviewed business 

and ethics literature and interviewed corporations and other groups 

interested in CSR. Specifically, we reviewed documentation from academic 

institutions, business associations, and multilateral organizations, 

including the European Commission and the World Bank CSR Practice. 

However, the information on foreign law in this report does not reflect our 

independent legal analysis, but is based on interviews and secondary 

sources. We collected major definitions and descriptions of CSR and global 

CSR and related terms and obtained information on different perspectives 

that have led to different definitions for CSR and CSR-related terms. 

To determine what policies and programs U.S. federal agencies have 

adopted that relate to global CSR, we surveyed federal legislation, reviewed 

literature, and spoke with agency officials and experts in CSR. To select the 

federal agencies to involve in our review, we first considered which 

agencies’ missions suggest possible involvement with promoting, 

facilitating, or monitoring global corporate social responsibility efforts, 

which yielded seven agencies. We then added two additional agencies to 

include all of the agencies that participate in the interagency working group 

developing a Web portal to publicize the U.S. government programs and 

resources that promote good corporate practices or CSR. We added the 

remaining three agencies, following referrals by agency officials or CSR 

experts, and had discussions with some agency officials to determine if 

their agencies had relevant programs for this review. The agencies we 

identified with CSR-related programs were: 

• Department of Commerce,

• Department of Energy (DOE),

• U.S. Environmental Protection Agency (EPA),

• Export-Import Bank of the U.S. (Ex-Im Bank),
Appendix I

Objectives, Scope, and Methodology

Page 38 GAO-05-744 Global CSR

• Inter-American Foundation (IAF),

• Department of Labor,

• Overseas Private Investment Corporation (OPIC),

• U.S. Securities and Exchange Commission (SEC),

• Department of State,

• Department of the Treasury,

• U.S. Agency for International Development (USAID), and

• Office of the U.S. Trade Representative (USTR). 

We identified specific agency programs and policies related to CSR using a 

two-step process. First, we provided a standard Data Collection Instrument 

(DCI) with a general description of global CSR to agency officials and 

asked them to identify current programs, policies, and efforts within their 

agencies that directly or indirectly promote, facilitate, or monitor global 

CSR efforts. The description discussed the general elements that a global 

CSR program can involve, including labor, human rights, environmental 

and corporate governance efforts. In addition, we also asked agencies 

about programs that we identified through interviews or literature review. 

We then sent a more detailed DCI to officials responsible for each identified 

program to obtain further information, such as the program’s objective, 

start year, legal basis, targeted groups, and activities. Most of the programs 

have other goals and objectives, and some only relate to CSR in particular 

aspects of their activities. We collected budget information and staffing 

levels, where available, to estimate the level of effort dedicated to the CSR 

activities by the agency.

After we received the responses from the agencies, we followed up with 

many of the identified federal programs to obtain additional information, 

which helped us determine whether we should include the program in our 

review. We also obtained additional documentation from a subset of the 

programs to verify the information and conducted a thorough review of all 

of the responses identifying the legal basis for the program/activity. We 

narrowed down the programs to those that met the following criteria: (1) 

were ongoing in fiscal year 2003 or afterwards; (2) may affect U.S. 

corporations’ CSR efforts overseas, including their supply chains (e.g., 
Appendix I

Objectives, Scope, and Methodology

Page 39 GAO-05-744 Global CSR

government to government efforts); and (3) touch on key components of 

CSR, such as labor, environment, human rights, community development 

and corporate governance. We also obtained agency concurrence that the 

program is related to CSR.

We excluded programs or activities that are primarily aimed at U.S. 

corporations’ CSR efforts within the United States, although they may 

influence a company’s CSR efforts overseas, and efforts that are primarily 

targeted at the federal government, such as government procurement 

policies. Due to the lack of federal legislation on, and a generally accepted 

definition of, corporate social responsibility, there are likely additional 

programs, policies, and efforts related to global CSR within the federal 

government that we did not identify. 

To obtain different perspectives regarding the role of the U.S. government 

in corporate global CSR efforts, we reviewed CSR literature. In addition, 

we conducted and synthesized information from a structured interview 

with 32 individuals representing a diverse variety of groups actively 

engaged in CSR. We initially identified 25 U.S. companies that were (1) 

leaders in CSR, based on companies that appeared on the Business Ethics 

Magazines’s Top 100 to Corporate Citizens list each year from 1999 to 2004 

and (2) had international operations. Fourteen of these companies agreed 

to participate in interviews with us. However, their views may not 

represent those of all 25 leaders we identified, or those of all U.S. 

companies. We identified representatives from other groups actively 

engaged in CSR through a review of CSR literature and referrals from 

experts and agency officials. We selected these groups and organizations to 

help us obtain a broad range of knowledgeable and informed views on 

global CSR and the federal government's role in global CSR; our selection 

was not intended to be representative in any statistical sense. Groups that 

are not active in global CSR may have different views and opinions, 

especially in terms of the federal government's role. Specifically, we 

interviewed:

• Fourteen U.S. multinational corporations that appeared on the Business 

Ethics Magazine’s Top 100 Corporate Citizens list for each year from 

1999 to 2004—Brady Corporation; Coors Brewing Company; Cummins, 

Inc.; Deere & Company; Herman Miller, Inc.; Hewlett-Packard 

Development Company, L.P.; International Business Machines 

Corporation; Intel Corporation; Merck & Co., Inc.; Modine 

Manufacturing Company; Motorola, Inc.; Procter & Gamble; The 

Timberland Company; and Whirlpool Corporation; 
Appendix I

Objectives, Scope, and Methodology

Page 40 GAO-05-744 Global CSR

• Four business interest groups that have been active in CSR—Business 

for Social Responsibility; the Conference Board; the U.S. Chamber of 

Commerce Center for Corporate Citizenship; and the U.S. Council for 

International Business;

• Four investor groups—Calvert Group, Ltd.; Domini Social Investments, 

LLC ; Dow Jones Sustainability Index; and the Interfaith Center on 

Corporate Responsibility; 

• Six nongovernmental organizations—Coalition for Environmentally 

Responsible Economies; Fair Labor Association; Human Rights Watch; 

Social Accountability International; World Resources Institute; and 

Worldwide Responsible Apparel Production; and

• Four academic institutions—Center for Corporate Citizenship, Boston 

College; Center for Responsible Business, the Haas School of Business, 

University of California at Berkeley; the Corporate Social Responsibility 

Initiative, John F. Kennedy School of Government, Harvard University; 

the Frank Hawkins Kenan Institute of Private Enterprise, University of 

North Carolina’s Kenan-Flagler Business School. 

The structured interview instrument included questions designed to obtain 

information from these organizations on their definition of CSR and similar 

terms; efforts related to evaluating the effectiveness of CSR activities; the 

impact of current U.S. government programs, policies and practices; and 

opinions regarding the appropriate U.S. government actions or role 

regarding U.S. companies’ global CSR activities. However, in this report, we 

do not evaluate the concept of CSR nor the justification or efficacy of any 

government role with regard to CSR activities.

We conducted our work from May 2004 through May 2005 in accordance 

with generally accepted government auditing standards. 
Page 41 GAO-05-744 Global CSR

Appendix II

Federal Agency CSR-Related Programs and 

Activities ApendxiI

This appendix provides a listing and brief description of the 54 programs 

and activities we identified at 12 U.S. agencies that relate to global CSR. 

Currently, an inventory of U.S. government efforts related to global 

corporate social responsibility is unavailable. To develop this list, we 

provided a standard DCI to 12 agencies with a general description of global 

CSR to obtain information on current programs, policies, and efforts within 

their agency that directly or indirectly promote, facilitate, or monitor global 

CSR efforts. For programs or activities that are interagency in nature, we 

list the program or activity with the lead agency and indicate other agencies 

involved with a footnote. Due to the lack of federal legislation on, and a 

generally accepted definition of, corporate social responsibility, we do not 

consider this list exhaustive. See appendix I for a more detailed description 

of our data-collection process.

Table 3: Responses from Department of Commerce

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa Staff levelb

Training on Human 

Rights, Rule of 

Law and 

Corporate 

Stewardship

Sarah.Murphy@m

ail.doc.gov, 

Foreign 

Commercial 

Service

To train 

commercial 

service officers 

and foreign 

service 

nationals on rule 

of law, human 

rights and 

corporate 

stewardship.

2003 15 U.S.C. 

4051 et seq.c

Commercial 

officers, 

foreign service 

nationals, 

domestic 

trade 

specialists.

Trainings. Since 

inception, 260 

commercial employees 

have been trained. The 

office is planning both 

a certificate and an 

award program to 

recognize companies 

and commercial 

officers, respectively, 

for corporate 

stewardship activities.

$500,000 One fulltime 

equivalent 

(FTE) 

divided 

among 

three 

people plus 

contractor 

support.

The President's 

Export Council's 

Report on 

Corporate 

Stewardship

http://www.ita.doc.

gov/td/pec/

To disseminate 

information on 

good citizenship 

activities of U.S. 

corporations.

2003d Executive 

Order 11753.

U.S. and 

foreign 

companies, 

U.S. missions, 

foreign 

governments.

Report production and 

public awareness 

through the report's 

launch. The Council 

maintains 

subcommittees to 

pursue its own 

interests and, in 2003, 

created a 

subcommittee on 

corporate stewardship 

to produce this report.

$18,311 for 

publication 

expenses.

One staff 

works full 

time, and 

four staff 

work part 

time on all 

of the 

Council’s 

activities, 

which are 

ongoing.
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 42 GAO-05-744 Global CSR

Digital Freedom 

Initiativee

www.dfi.gov

To promote 

economic 

growth by 

providing 

information and 

communications 

technology to 

businesses in 

the developing 

world through 

partnership with 

U.S. business 

volunteers.

2003 Executive 

Order 13317.

U.S. business 

community, 

government 

agencies and 

business 

community in 

four partner 

countries.

Placing business and 

NGO volunteers in 

small businesses in 

partner countries. For 

example, in Senegal, 

an E-market training 

program was 

implemented in 

partnership with two 

large U.S. information 

technology companies.

No specific 

funding.f

One person 

works 50 

percent on 

this 

program.f

Good Governance 

Program

www.ita.doc.gov/g

oodgovernance

To increase 

market access 

and ensure a 

level playing 

field for U.S. 

companies in 

emerging 

markets by 

training foreign 

companies on 

business ethics, 

corporate 

governance and 

rule of law 

issues.

2000 15 U.S.C. 

1512.

Foreign 

companies 

and individual 

entrepreneurs, 

business 

associations, 

civil society 

groups, and 

foreign federal 

and regional 

governments.

Training, providing 

tools and resources, 

capacity building, 

awareness building, 

and outreach. In FY 

2003, over 1,000 

companies/individuals 

were trained directly 

through the program or 

indirectly through train 

the trainer programs.g

$1,065,585 for 

FY 2002-2003h

Three full 

time,i one 

part time 

staff.j

HIV/AIDS Initiative

shalizeh.nadjmi@

mail.doc.gov

To further 

private sector 

engagement on 

HIV/AIDS by 

fostering publicprivate 

partnerships 

with other key 

stakeholders 

focused on 

HIV/AIDS.

2003 U.S. 

Leadership 

Against 

HIV/AIDS, 

Tuberculosis 

and Malaria 

Act of 2003, 

See P. L. 

108-25.

U.S. 

companies 

and trade 

associations, 

and chambers 

of commerce.

Information publication 

and dissemination, 

liaison between 

businesses and other 

U.S. government 

organizations, 

multilateral 

organizations, NGOs 

and academia. Hosted 

2004 forum on 

business involvement 

in HIV/AIDS for more 

than 200 companies 

and other entities.

No specific 

funding. 

However, 

$15,000 from 

the $500,000 

appropriation 

listed above for 

training 

commercial 

service officers 

was spent on 

the Forum.

Five people 

work on 

this 

initiative 

ranging 

from 15 

percent to 

80 percent 

of their 

timek

[Estimate].

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa Staff levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 43 GAO-05-744 Global CSR

Source: GAO based on information provided by agency officials.

a

Budget information is for fiscal year 2003 unless otherwise noted.

b

Staff located in the Russia and Independent States Division.

c

The conference committee for H.J. Res. 2, the Consolidated Appropriations Resolution, 2003, 

instructed the department to establish this program. See p. 684 of H. Rept. 108-10.

d

This is the year when the Subcommittee on Corporate Stewardship was created to work on this 

report. The report was released in September 2004.

e

In addition to the Department of Commerce, members of the Digital Freedom Initiative Interagency 

Working Group include USAID, the Department of State, the Peace Corps, the Small Business 

Administration, and the Federal Communications Commission.

f

Other agencies, such as USAID, contribute resources to this initiative, which are not reflected here. 

For example, there are local Digital Freedom Initiative coordinators in Senegal and Peru that are 

funded through USAID funds.

g

Since 2003, the Program has expanded to additional countries in Eastern Europe and Latin America, 

published manuals on Corporate Governance and on Business Ethics, and is facilitating institutional 

capacity building through partnerships with private sectors, government and nongovernmental 

organizations, and international institutions. In fiscal years 2005 to 2006, the Business Ethics manual 

will be translated and published in five other languages.

h

The 2003 program initiatives were fully funded through Freedom Support Act Funds through the 

Department of State.

i

Staff located in the Russia and Independent States Division.

j

Staff located in the Latin America Division. In FY 2004, the program had three full time and two part 

time employees. 

Implementation of 

the Labor 

Standards 

Provision of the 

Bilateral Textile 

Agreement with 

Cambodia

Ross_Arnold@ita.

doc.gov

To provide 

incentives to the 

Government of 

Cambodia to 

improve working 

conditions in the 

Cambodian 

textile and 

apparel industry 

through effective 

enforcement of 

local labor laws 

and 

internationally 

recognized core 

labor standards.

1999 U.S.-

Cambodia 

Bilateral 

Textile 

Agreement, 

paragraph 

10, as 

notified 

under Article 

2.17 of the 

World Trade 

Agreement 

on Textiles 

and Clothing.

Government 

of Cambodia

Two consultations 

every year between the 

governments of the 

United States and 

Cambodia to discuss 

labor standards, 

specific benchmarks, 

and the 

implementation of the 

program. Based on 

those consultations, 

the U.S. Government 

made a determination 

as to whether working 

conditions in the 

Cambodia textile and 

apparel sector 

substantially comply 

with such labor law and 

standards, and apply 

quota increases 

commensurate with 

progress on labor 

issues.l

$7,500

[Estimate].

One staff 

for 2 

weeks. Five 

staff for 1 

day apiece.

[Estimate].

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa Staff levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 44 GAO-05-744 Global CSR

k

The one staff person who worked 80 percent of her time on the HIV/AIDS Initiative in fiscal year 2003 

noted that her time dedicated to the initiative decreased in fiscal years 2004 and 2005 to 33 percent of 

her time.

l

The International Labor Organization and the Departments of State and Labor provided input into this 

process.

Table 4: Responses from Department of Energy

CSR-Related 

program/activity Objective Start year

Legal 

basis Groups targeted Activities

Budget 

information Staff levela

Office of Energy 

Efficiency and 

Renewable Energy 

- Select Activities 

within the Office of 

Technology 

Development

michael.mills@ee.

doe.gov

To strengthen 

America’s 

energy security, 

environmental 

quality, and 

economic vitality 

in public-private 

partnerships that 

enhance energy 

efficiency.

Not 

available.

Various 

acts.b

Private sector, 

academia, states, 

local governments, 

trade 

organizations, 

research 

organizations, 

other federal 

agencies and the 

U.S. Congress, 

foreign 

governments and 

multilateral 

agencies.c

Select programs 

work with the U.S. 

private sector on 

global energy 

issues, such as the 

Clean Cities 

Program and 

Freedom 

Cooperative Auto 

Research (CAR).d

No discrete 

budget.

Not 

available.e

Carbon 

Sequestration 

Leadership Forum 

cslfsecretariat@hq

.doe.gov

To develop and 

make available 

internationally 

improved costeffective 

technologies for 

the separation 

and capture of 

carbon dioxide, 

a greenhouse 

gas, for its 

transport and 

long-term safe 

storage.

2003 Presidential 

initiative.

Foreign 

governments, 

intergovernmental 

organizations, U.S. 

and foreign-owned 

companies that 

produce and/or 

utilize energy, 

environmental 

organizations, and 

international 

experts on energy 

and environment.

Under 

development. Ten 

projects that were 

proposed by 

Carbon 

Sequestration 

Leadership Forum 

members have 

been endorsed. 

Stakeholder 

registry is 

forthcoming. U.S. 

companies have 

participated in 

discussions as 

observers, but a 

formal role for 

companies is yet to 

be developed.

Not available. Six people 

work part 

time on this 

effort

[Estimate].
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 45 GAO-05-744 Global CSR

Source: GAO based on information provided by agency officials.

a

Staff levels are for fiscal year 2003 unless otherwise noted.

b

See Department of Energy Organization Act of 1977 (See P.L. 95-91), The Energy Policy Act of 1992 

(P.L. 102-486), Energy Security Act of 1980 (P.L. 96-294), Hydrogen Research, Development and 

Demonstration Act of 1990 (P.L. 101-566) and the Hydrogen Future Act of 1996 (P.L. 104-271).

c

The office’s efforts with foreign governments and multilateral agencies are indirect via relationships 

established and maintained by the U.S. Department of State and USAID.

d

The Clean Cities program promotes public-private partnerships to increase the use of alternative fuel 

vehicles. Freedom Cooperative Auto Research (CAR) partners with automobile companies to research 

cleaner, more efficient transportation systems.

e

According to an agency official, it would be difficult for anyone to identify how much time they spend 

on CSR activities. The office takes on a broad portfolio of activities, and with the problem of defining 

what constitutes CSR, it is not possible to identify budget and staffing for the office’s CSR activities. 

f

Hydrogen is considered an alternative, cleaner energy source.

Secretariat for the 

International 

Partnership for 

Hydrogen 

Economy

michael.mills@ee.

doe.gov

To organize and 

coordinate 

multinational 

research and 

projects among 

16 member 

nations to 

advance the 

transition to a 

global hydrogen 

economy.f

2003 Presidential 

initiative.

Governments, 

international 

organizations, civil 

society, 

companies.

Under 

development. 

However, seven 

companies 

sponsored the 

inaugural meeting 

of the member 

nations, and the 

Department of 

Energy engages in 

ongoing discussion 

with U.S. 

companies to 

obtain their input. 

No discrete 

budget.

Two to three 

FTE plus two 

full-time 

contractors 

[Estimate].

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year

Legal 

basis Groups targeted Activities

Budget 

information Staff levela
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 46 GAO-05-744 Global CSR

Table 5: Responses from U.S. Environmental Protection Agency

CSR-Related 

program/activity Objective Start year Legal basis Groups targeted Activities

Budget 

informationa Staff levelb

Climate Leaders 

Program

www.epa.gov/clim

ateleaders/

To enlist major 

U.S. companies 

to voluntarily 

set and track 

their success 

toward meeting 

an aggressive 

greenhouse 

gas reduction 

target. 

2002 Clean Air Act, 

section 103. 

Large U.S. 

companies.

Training and 

technical assistance 

to help partners 

complete 

greenhouse gas 

inventories. By the 

end of fiscal year 

2003, close to 50 

partners had signed 

up. EPA plans to 

provide recognition 

in later years for 

partners who meet 

or exceed their 

targets.

15 percent of 

the total 

budget of 

$900,000 was 

used for 

international 

efforts

[Estimate].

15 percent 

of three full 

time staff 

members’ 

time was 

spent on 

international 

efforts

[Estimate].

Climate 

Protection Awards

http://www.epa.go

v/cppd/awards/cli

mproawards.htm

To recognize 

and provide 

incentive to 

businesses, 

organizations 

and individuals 

who voluntarily 

make 

significant 

achievements 

in climate 

protection.

1998 Section 

13103(b)(13) 

of the Pollution 

Prevention Act 

of 1990, Pub. 

L. 101-508.

U.S. and foreign 

companies, 

foreign 

governments, 

institutions, 

nonprofit 

organizations, 

individuals.

To date, over 100 

individuals, 

companies, and 

organizations from 

all over the globe 

have received 

awards. Award 

winners are 

recognized at a 

special dinner, 

along with the 

Stratospheric 

Ozone Protection 

Award winners.

$25,000

[Estimate].

One staff 

person 

works 2 

months per 

year on this 

program

[Estimate].

Stratospheric 

Ozone Protection 

Awards 

http://www.epa.go

v/docs/ozone/awa

rds/

To recognize 

and provide 

incentive to 

businesses, 

organizations, 

and individuals 

who voluntarily 

make 

significant 

achievements 

in protecting 

the ozone layer.

1990 Section 

13103(b)(13) 

of the Pollution 

Prevention Act 

of 1990.

U.S. and foreign 

companies, 

foreign 

governments, 

institutions, 

nonprofit 

organizations, 

and individuals.

To date, 477 

individuals, 

companies, 

organizations, and 

teams from over 40 

countries have 

earned the award. 

$25,000

[Estimate].

One staff 

person 

spends 

about 150-

200 hours 

per year on 

this 

program, 

plus some 

additional 

support

[Estimate].
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 47 GAO-05-744 Global CSR

Energy Star 

Program - 

International 

Efforts

schmeltz.rachel@

epa.gov

To promote 

international 

consistency in 

specifications 

for energy 

efficient 

products in 

voluntary 

programs.c

1995d Various acts.e U.S. 

manufacturing 

companies, 

retailers, energy 

efficiency 

program 

sponsors/

utilities, foreign 

governments.

The program has 

signed international 

agreements with the 

European 

Commission, 

Japan, Canada, 

Australia, New 

Zealand and Taiwan 

and is starting to 

harmonize product 

specifications with 

China. The program 

is working with 

international 

partners on a 

common database 

of Energy Star 

qualified products. 

$30,000 was 

spent on 

international 

effortsf 

[Estimate].

One staff 

member 

spends 25 

percent of 

her time on 

the 

international 

efforts 

[Estimate].

Bilateral and 

Regional 

Trainings on 

Environmental 

Compliance, 

Inspections and 

Enforcement

jones.davis@epa.

gov

To increase the 

capacity of 

governments to 

ensure 

compliance 

with 

environmental 

standards.

1990 Various acts.g Government 

officials. 

In fiscal year 2003, 

EPA trained officials 

from several 

countries including 

Panama, 

Nicaragua, 

Honduras, Costa 

Rica, El Salvador, 

Belize, Guatemala, 

Mexico, India and 

Brazil. 

Not available. One fulltimeh

 staff 

plus 

additional 

support.

Co chair of the 

International 

Network for 

Environmental 

Compliance and 

Enforcement 

(INECE)

www.inece.org

INECE is a 

network of 

government 

and nongovernment 

enforcement 

and compliance 

practitioners 

from over 100 

countries. It 

aims to 

increase the 

capacity of 

governments to 

monitor and 

detect 

violations of 

domestic 

environmental 

laws by 

corporations.

1989 1985 

Memorandum 

of 

Understanding 

between EPA 

and Dutch 

Ministry of 

Housing, 

Spatial 

Planning and 

the 

Environment 

led to creation 

of INECE.i

Governmental 

environmental 

enforcement 

authorities, 

including 

prosecutors, 

investigators, 

environmental 

ministries, and 

nongovernmental 

organizations 

working to 

increase 

environmental 

compliance.

INECE connects 

developed and 

developing 

governments’ 

environmental 

compliance and 

enforcement 

authorities. 

Specifically, INECE 

provides training, 

holds conferences, 

and issues 

publications.

EPA and the 

Dutch 

government 

each provide 

about half of 

the expenses 

totaling 

$200,000-

250,000 a 

yearj 

[Estimate].

One FTE 

spread 

among 

several 

people 

working on 

INECE.

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis Groups targeted Activities

Budget 

informationa Staff levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 48 GAO-05-744 Global CSR

China-U.S. 

Cooperation in 

Industrial 

Pollution 

Prevention and 

Energy Efficiency 

Cooperative 

Agreement

gianninispohn.suzanne@

epa.gov

To assist China 

to develop 

voluntary 

governmentindustry 

partnership 

programs in 

industrial 

pollution 

prevention and 

energy 

efficiency. 

2001 Clean Air Act, 

Section 103 

and National 

Environmental 

Policy Act, 

Sec. 102(2)(f).

Companies in 

China, including 

U.S. companies, 

and the Chinese 

government.

Training, awards,k

and information 

provision.

$300,000 

total 

approved 

costs for the 

project.l

One staff 

person 

works 25-50 

percent of 

her time 

[Estimate].

Chair of the 

American 

National 

Standards 

Institute (ANSI)'s 

Ad Hoc Group on 

CSR

www.ansi.org

To track the 

strategic and 

policy 

implications of 

CSR work in 

the 

International 

Organization 

for 

Standardization 

(ISO).

2004 The National 

Technology 

Transfer and 

Advancement 

Act (NTTAA) 

of 1995 and 

OMB Circular 

A-119.

ANSI members, 

including 

consumer groups, 

industry, 

government, and 

NGOs.

As a member of the 

Interagency 

Committee on 

Standards Policy 

composed of the 

Standards 

Executives from all 

federal agencies, 

the EPA member 

coordinates input 

from federal 

agencies regarding 

the development 

and utility of an 

international 

standard in CSR.

No discrete 

budget.

One staff 

person 

works part 

time on this 

effort.

Party to 

Commission for 

Environmental 

Cooperation, 

FinanciallyRelevant 

Environmental 

Information 

Project

correa.sylvia@ep

a.gov

To improve 

voluntary 

corporate 

disclosure of 

environmental 

information that 

is financially 

relevant.

2003 A side 

agreement to 

the North 

American 

Agreement on 

Environmental 

Cooperation 

(NAFTA) 

established 

the 

Commission 

for 

Environmental 

Cooperation, 

See P. L. 103-

182, title V.

Corporations in 

the U.S., Canada, 

and Mexico, as 

well as 

institutional and 

other investors 

who are users of 

financially 

relevant 

information.

The commission 

held a workshop of 

experts in early 

2003 and published 

background papers 

for the workshop, as 

well as a report. 

No specific 

budget.

Two staff 

work part 

time on this 

effort.

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis Groups targeted Activities

Budget 

informationa Staff levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 49 GAO-05-744 Global CSR

Source: GAO based on information provided by agency officials.

a

Budget information is for fiscal year 2003 unless otherwise noted.

b

Staff levels are for fiscal year 2003 unless otherwise noted.

c

The objective of the Energy Star product labeling program is to reduce greenhouse gas emissions in 

the United States by encouraging consumers and businesses to purchase and use more efficient 

products. 

d

The Energy Star program was introduced in 1992. The first agreement with another country to 

recognize the Energy Star label internationally was in 1995 with Japan.

e

Statutory Authorities for EPA’s Climate Programs: Clean Air Act, 42 U.S.C. 7401 ct sew. - section 

103(a), (b), (g); National Environmental Policy Act, 42 U.S.C. 4321 ct seq. - section 102(2)(F); · Global 

Climate Protection Act of 1987, 15 U.S.C. 2901 - section 1103.

f

The total budget for the Energy Star program was approximately $50.3 million in FY 2003.

g

Clean Air Act § 103; Clean Water Act § 104; Solid Waste Disposal Act § 8001; Federal Insecticide, 

Fungicide, and Rodenticide Act § 20; Toxic Substances Control Act § 10; National Environmental 

Policy Act § 102(2)(f).

h

This staff person works full time on these efforts as well as efforts related to the International Network 

for Environmental Compliance and Enforcement (INECE), although more of the time is spent on this 

effort.

U.S.-Chile Free 

Trade Agreement 

(FTA) - CSR 

Project

Hill-Macon.Cam 

@epa.gov

The objective is 

to facilitate 

exchange of 

information and 

expertise on 

best practices 

that have been 

used by 

companies to 

promote 

sustainable 

development.

The U.S.-

Chile FTA 

went into 

effect in 

January 

2004. This 

project is 

likely to 

start in 

spring/

summer 

2005.

Annex 19.3, 

Section 1(d) of 

the U.S.-Chile 

Free Trade 

Agreement. 

Companies, in 

particular 

business councils 

for sustainable 

development, 

Chilean National 

Environmental 

Council 

(CONAMA).

The project will try 

to build and 

promote networking 

and exchange of 

information between 

business councils. 

EPA, USTR, the 

Department of State 

and CONAMA held 

a workshop on 

corporate 

responsibility in 

Chile in 2004 as 

part of the FTA. 

$25,000 

through FY 

2005.

Three staff 

work part 

time on this 

effort.

Partnership for 

Clean Fuels and 

Vehicles

metcalfe.jane@ep

a.gov

To address 

vehicular air 

pollution 

worldwide by 

eliminating lead 

in gasoline and 

phasing down 

sulfur in diesel 

and gasoline, 

and adopting 

cleaner vehicle 

technologies.

2002 Clean Air Act, 

Section 103; 

National 

Environmental 

Policy Act, 

Section 102.

Governments, 

private sector, 

NGOs, 

international 

organizations.

Clearinghouse of 

information, 

publications, 

technical assistance 

to African countries 

to phase out lead in 

Africa, and related 

projects in other 

countries. U.S. 

companies 

participate on the 

Advisory Board, 

which steers the 

partnership.

$700,000 Two FTEs.

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis Groups targeted Activities

Budget 

informationa Staff levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 50 GAO-05-744 Global CSR

i

See also Clean Air Act § 103; Clean Water Act § 104; Solid Waste Disposal Act § 8001; Federal 

Insecticide, Fungicide, and Rodenticide Act § 20; Toxic Substances Control Act § 10; National 

Environmental Policy Act § 102(2)(f).

j

This figure does not include resources for staffing or additional funding that came from the State 

Department.

k

The awards are incentives offered by China’s State Environmental Protection Administration to 

companies operating in China (including U.S. companies) named “China Environmentally Friendly 

Enterprises.” The local environmental protection bureau reduces the frequency of routine inspections 

and gives a higher priority to loans for capital environmental improvements to these companies. 

l

A total of $200,00 had been funded as of March 2005.

Table 6: Responses from Export-Import Bank of the United States

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa Staff levelb

Environmental 

Procedures and 

Guidelines

http://www.exim.gov/

products/policies/

environment/ 

environment.html

To take

into account 

the potential 

beneficial and 

adverse 

environmental 

effects of

goods and 

services for 

which support 

is requested 

under its direct 

lending

and guarantee 

programs.

1995c Export-Import 

Bank Act of 

1945, as 

amended,

codified at 

12 U.S.C. 

635.

Foreign buyers 

and U.S. 

exporters 

participating in 

foreign projects. 

During FY 2003, 

Ex-Im Bank 

screened 

approximately 70 

applications for 

their potential 

environmental 

effects. The 

Bank’s 

Engineering and 

Environment 

Division 

undertook formal 

environmental 

evaluations of the 

projects related 

to 21 separate 

applications for 

financing.

$531,000 

[Estimate].

Three FTEs 

[Estimate].
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 51 GAO-05-744 Global CSR

Source: GAO based on information provided by agency officials.

a

Budget information is for fiscal year 2003 unless otherwise noted.

b

Staff levels are for fiscal year 2003 unless otherwise noted.

c

Interim guidelines were established in 1993.

d

Participants refer to both U.S. suppliers and/or foreign buyers.

Environmental 

Exports Program

http://www.exim.gov

products/policies/

environment/ 

environment.html

To

encourage the 

use of its 

programs to 

support the 

export of 

goods and

services that 

have beneficial 

effects on the 

environment or 

mitigate

potential 

adverse 

environmental 

effects.

1993 Export-Import 

Bank Act of 

1945, as 

amended,

codified at 12 

U.S.C. 635.

U.S. suppliers of 

environmentally 

beneficial 

products, and 

participantsd

undertaking 

projects that are 

beneficial to the 

environment.

The 

Environmental 

Exports Program 

was instrumental 

in enabling

Ex-Im Bank to 

support over 

$173 million of 

environmentally 

beneficial goods 

and services in 

FY 2003, 

including $13 

million in 

products and 

technologies 

related to 

renewable 

energy.

$148,000 

[Estimate].

0.80 of an 

FTE 

[Estimate].

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa Staff levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 52 GAO-05-744 Global CSR

Table 7: Responses from Inter-American Foundation

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget

Information Staff levela

U.S. Government 

CSR Web Portalb

ajones@iaf.gov

To provide 

public access to 

U.S. 

government 

CSR programs, 

case studies, 

events, and 

contacts.

2003 Authorizing 

legislation, 

See 22 

U.S.C. 290f.

U.S. 

companies 

and other 

organizations 

operating in 

the U.S. and 

abroad.

A web portal will be 

launched in 2005 

housing each agency’s 

activities related to CSR 

or corporate 

stewardship.

$37,000 was 

obligated in 

FY 2003, but 

activities were 

carried out in 

FY 2004. 

20-25 

percent of 

one staff 

person’s time 

[Estimate].c

Program Office - 

Corporate 

Outreach

ajones@iaf.gov

To meet IAF's 

mandate of 

providing grants 

to support 

grassroots 

initiatives by 

cofunding 

projects with 

corporations 

interested in 

developing or 

enhancing their 

CSR efforts in 

the region.

1991 Authorizing 

legislation, 

See 22 

U.S.C. 290f.

U.S., Latin 

American and 

Caribbean 

corporations 

and business 

associations, 

local 

governments 

and NGOs.

Supports innovative 

projects in Latin America 

and the Caribbean in 

partnership with 

companies that want to 

invest in grassroots 

development; Facilitates 

tax-deductible 

contributions by U.S. 

corporations to support 

grassroots development 

programs in Latin 

America and the 

Caribbean; Provides 

technical assistance to 

corporate partners to 

create more sustainable, 

participatory CSR 

programs.

$1,039,500.d 0.75 of an 

FTE divided 

among 

several staff 

persons

[Estimate]. 

RedEAmérica 

Initiativee

wprice@iaf.gov

To encourage 

companies and 

corporate 

foundations to 

take leadership 

in grassroots 

development in 

the Americas. 

2002 Authorizing 

legislation, 

See 22 

U.S.C. 290f.

U.S. and 

foreign 

companies 

and corporate 

foundations.

Learning exchanges 

among members, 

strategy formulation, 

development of trainings 

in all countries, 

mobilizing corporate and 

other resources; At the 

end of FY 2004, 52 

companies were in the 

network, several of 

which represented 

multiple companies.

$1,848,560 

for FY 2004

Two full time 

staff starting 

in FY 2004.
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 53 GAO-05-744 Global CSR

Source: GAO based on information provided by agency officials.

a

Staff levels are for fiscal year 2003 unless otherwise noted.

b

The Inter-American Foundation is leading this interagency effort. Additional participating agencies 

include the Departments of Commerce and State, USAID, and EPA.

c

This estimate includes only IAF staff time.

d

This figure represents grants from IAF for which corporations are cofunding part of the activities with 

cash or in-kind contributions. These figures are not exhaustive as not all foundation representatives 

had submitted their figures. 

e

The full name of the RedEAmérica Initiative is the Inter-American Network of Corporate Foundations 

and Companies for Grassroots Development. 

f

The Inter-American Development Bank is the lead organizer for the conference. The U.S. Department 

of State has also played a role coordinating U.S. government involvement in the conference.

g

This figure does not include resources dedicated to the conference from the Department of State.

h

This estimate does not include staff time dedicated to the conference from the Department of State.

Cosponsor for 

CSR Americas 

Conferencef

ajones@iaf.gov

To bring 

together 

government, 

civil society, 

business, the 

academic world

and other 

institutions to 

develop 

effective and 

sustainable

CSR principles 

for the Western 

hemisphere.

2002 Authorizing 

legislation, 

See 22 

U.S.C. 290f.

Private, public 

and 

nongovernme

ntal sectors. 

Provides funding, 

participated on steering 

and operating 

committee. 

$35,800 for 

FY 2004.g

10-15 

percent of 

one staff 

person’s time 

[Estimate].h

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget

Information Staff levela
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 54 GAO-05-744 Global CSR

Table 8: Responses from Department of Labor

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa

Staff 

levelb

Bureau of 

International Labor 

Affairs (ILAB) – 

Protecting the Basic 

Rights of Workers 

program

www.dol.gov/ilab

To improve the 

capacity of 

developing 

country 

governments 

to achieve 

compliance 

with national 

labor laws and 

internationally 

–recognized 

workers rights.

2000 Annual 

appropriations 

legislation. 

Current 

authority is P. L. 

108-447, Div. F, 

Title 1 

(Department of 

Labor 

Appropriations 

Act, 2005).

Foreign 

Governments, 

workers and 

employers. 

Training, 

equipment 

provision,c

drafting of 

training 

materials and 

promotional 

activities. The 

program works 

in a range of 

sectors and 

countries in 

Africa, the 

Americas, Asia, 

and in Ukraine. 

One project in 

Cambodia is 

establishing an 

independent 

monitoring 

system to 

generate 

reliable 

information on 

the 

implementation 

of core labor 

standards in the 

garment sector.

$20 milliond Nine staff 

work part 

time on 

this 

program.
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 55 GAO-05-744 Global CSR

Source: GAO based on information provided by agency officials.

a

Budget information is for fiscal year 2003 unless otherwise noted.

b

Staff levels are for fiscal year 2003 unless otherwise noted.

c

Examples of equipment include computers or vehicles to access workplaces.

d

The budget for this program decreased significantly in fiscal years 2004 and 2005 to $2.5 million and 

no funding, respectively.

e

The International Child Labor Program generally provides technical assistance and funds 

international projects designed to eliminate the most hazardous and exploitive forms of child labor; 

researches and reports information to inform U.S. foreign policy, trade policy, and development 

projects; and raises awareness of the U.S. public to increase their understanding of the issues relating 

to international child labor and recent efforts to combat the problem. For example, the program works 

with foreign governments to improve their capacity to handle the issue of child labor and has provided 

funds to the International Labor Organization to address trafficking of children for labor exploitation. 

However, the program informed us that they consider their work with industry associations to be most 

relevant to global corporate social responsibility.

ILAB - International 

Child Labor Program 

– activities working 

with industry 

associationse

www.dol.gov/ilab

To support 

efforts to 

eradicate 

exploitive child 

labor 

worldwide.

1993 Annual 

appropriations 

legislation. 

Current 

authority is P. L. 

108-447, Div. F, 

Title 1 

(Department of 

Labor 

Appropriations 

Act, 2005).

Children, 

parents, 

community 

leaders, 

government 

officials, and 

industry 

associations.

The program 

has funded 

several projects 

for various 

lengths of time 

in Bangladesh, 

Pakistan, 

Central 

America, and 

West Africa that 

involve industry 

associations to 

combat child 

labor. For 

example, the 

program 

provided a $6 

million grant to 

the International 

Labor 

Organization to 

prevent child 

labor in the 

coffee industry 

in Central 

America and the 

Dominican 

Republic, which 

included the 

creation of a 

child labor 

monitoring 

system, among 

other activities.

About $35 million 

between fiscal 

years 1999-2004 

for all projects 

working with 

industry 

associations.

Not 

available.

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa

Staff 

levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 56 GAO-05-744 Global CSR

Table 9: Responses from Overseas Private Investment Corporation

Source: GAO based on information provided by agency officials.

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

information Staff level

Corporate social 

responsibility 

requirements

www.opic.gov

To develop and 

implement 

policies and 

procedures to 

comply with 

OPIC statutory 

mandates and 

management 

policies with 

respect to host 

country 

development 

impact, 

environmental 

protection, 

international 

labor rights, 

human rights 

and related risk 

management 

responsibilities. 

1971a Various actsb

 Companies 

receiving OPIC 

support in the 

form of direct 

loans, loan 

guaranties, 

political risk 

insurance and 

“subprojects” 

obtaining funds 

from OPICsupported 

financial 

intermediaries. 

Evaluates 

each project’s 

expected 

impact on 

development, 

the 

environment, 

and requires 

projects to 

meet all 

applicable host 

country labor 

laws or 

international 

conventions on 

labor rights.

Not available. Not 

available.

Corporate 

governance 

requirements

www.opic.gov

To ensure that 

OPIC users' 

corporate 

governance 

policies and 

practices follow 

and implement 

OPIC policies 

and procedures 

in compliance 

with OPIC’s 

statutory 

responsibilities 

and risk 

management 

requirements. 

1971c Overseas 

Private 

Investment 

Corporation 

Amendments 

Act of 1977, 

See P. L. 95-

268, Sec. 

237(1).

U.S. investors 

that receive 

OPIC support 

and the 

companies in 

which they 

invest.

All major 

sponsors of an 

OPIC financed 

project must 

answer 

questions 

relating to the 

Foreign 

Corrupt 

Practices Act 

and OPIC 

ensures that 

support does 

not go to 

persons and 

practices 

restricted by 

Treasury’s 

Office of 

Foreign Assets 

Control. OPIC 

monitors loan 

projects on an 

ongoing basis. 

Not available. Not 

available.
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 57 GAO-05-744 Global CSR

a

Certain policies and procedures have been in effect since OPIC began operations in 1971 with 

periodic updates in response to evolving statutory requirements, U.S. executive branch requirements 

and international best practices

b

Foreign Assistance Act of 1969, OPIC Amendments Act of 1985, Export Enhancement Act of 1999, 

Jobs through Exports Act of 1992, and annual appropriations since 1992.

c

Certain policies and procedures have been in effect since OPIC began operations in 1971 with 

periodic updates in response to subsequent statutory requirements.

Table 10: Responses from U.S. Securities and Exchange Commission

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

information Staff level

Implementation of Rule 

14a-8 on Shareholder 

Proposalsa

lynnd@sec.gov

To ensure that 

companies do 

not exclude 

shareholder 

proposals for 

vote at annual 

company 

meetings, 

including those 

related to 

global CSR, 

unless they 

meet the legal 

criteria for 

exclusion 

outlined in Rule 

14a-8.

Late 1960s

[Estimate]

Rule 14a-8 

of the 

Securities 

Exchange 

Act of 1934, 

See 17 

C.F.R. 

240.14a-8.

SEC reporting 

companies.

The 

Shareholder 

Proposal 

Taskforce 

corresponds 

with companies 

regarding 

requests to 

exclude 

shareholder 

proposals that 

do not meet the 

criteria 

according to 

Rule 14a-8.

Not available. Not 

available.

Full Disclosure 

Program - Office of 

Global Security Risk

blyec@sec.gov

To ensure that 

companies 

disclose all 

material 

information 

regarding their 

operations in, 

or contacts 

with, countries 

identified as 

supporting 

terrorism or 

associated with 

the production 

or proliferation 

of weapons of 

mass 

destruction or 

human rights 

abuses.

2004b Securities 

Act of 1933 

and the 

Securities 

Exchange 

Act of 1934c

Foreign 

companies and 

U.S. 

companies 

with foreign 

subsidiaries 

that have 

contacts with 

countries of 

concern.

Review 

company 

documents to 

ensure that 

companies are 

aware of the 

disclosure 

standard 

applicable to 

their operations 

or contacts.

Not available. Three full 

time staff in 

FY 2004.
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 58 GAO-05-744 Global CSR

Source: GAO based on information provided by agency officials.

a

Rule 14a-8 provides shareholders owning more than $2,000 of company stock for more than 1 year 

with the opportunity to place a proposal in the company’s proxy materials for presentation to a vote at 

an annual or special meeting of shareholders. The rule generally requires the company to include the 

proposal unless the shareholder has not complied with the rule’s procedural requirements or the 

proposal falls within 1 of the 13 substantive bases for exclusion contained in the rule. For some or most 

of the proposals, the company accepts the proposal or negotiates with the shareholder and the issue 

never reaches the SEC. However, if a company intends to exclude a proposal from its proxy materials, 

the company must submit its basis for excluding the proposal to the SEC. The Shareholder Proposal 

Taskforce reviews these requests for exclusion. Accordingly, the task force considers proposals that 

address a range of issues, including global CSR issues. 

b

The Office of Global Security Risk was established in 2004. However, the Division of Corporate 

Finance began focusing on this type of disclosure in 2001.

c

See conference report at H. Rept. 108-221. The conference committee considering the Commerce 

Justice State Appropriations Act, 2004 (enacted in Div. B of P. L. 108-299) requested the establishment 

of this initiative.

Full Disclosure 

Program

ParrattS@sec.gov

To ensure that 

companies 

whose 

securities trade 

in the U.S. 

capital markets 

or that sell 

securities 

through public 

offerings 

provide 

appropriate 

narrative and 

financial 

disclosure 

regarding their 

operations, 

their financial 

condition, and 

the terms of 

their securities 

offerings. 

1933 Securities 

Act of 1933 

and the 

Securities 

Exchange 

Act of 1934.

SEC reporting 

companies.

Review 

company 

disclosure and 

provide 

comments to 

companies.

Not available. Not 

available.

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

information Staff level
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 59 GAO-05-744 Global CSR

Table 11: Responses from the Department of State

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa

Staff 

levelb

Bureau for 

Democracy, Human 

Rights and Labor 

(DRL) - Partnership 

to Eliminate 

Sweatshops 

Program

camponovocn@

state.gov

To address 

unacceptable 

working 

conditions in 

manufacturing 

facilities 

overseas that 

produce goods 

for the U.S. 

market. 

2000 State 

Department 

Basic Authorities 

Act of 1956, as 

amended, See 

22 U.S.C. 

2651a(c)(2) and 

22 U.S.C. 

2151n(d)(3).

NGOs, 

governments, 

U.S. and 

foreign 

companies.

The Partnership has 

provided several 

million dollars to 

support public and 

private sector 

initiatives to establish 

codes of conduct, 

encourage effective 

workplace monitoring 

and auditing systems, 

and conduct 

research, training and 

education initiatives. 

The program has 

funded projects in a 

number of countries, 

including China and 

other Asian countries, 

Central America, the 

Middle East and 

Africa.

$1,994,554c One staff 

person 

works 60 

percent of 

his time 

and one 

staff 

person 

works 25 

percent of 

her time 

on this 

effort 

[Estimate].

DRL - Voluntary 

Principles on 

Security and Human 

Rights

camponovocn@

state.gov

To provide 

guidance to 

extractives 

companies on 

how to ensure 

respect for 

human rights in 

the creation and 

implementation 

of security 

procedures. 

1999 State 

Department 

Basic Authorities 

Act of 1956, as 

amended, See 

22 U.S.C. 

2651a(c)(2).

NGOs, U.S. 

and U.K. oil 

and mining 

companies, 

and corporate 

responsibility 

organizations.

The bureau convenes 

companies, NGOs, 

and local 

governments to 

implement the 

principles, and is 

working to include 

additional 

governments. Nearly 

every major oil and 

mining company is a 

participant in the 

Voluntary Principles 

process. 

$10,000 in 

FY 2004

One staff 

person 

works15-

20 percent 

of his time 

on this 

effort 

[Estimate].

DRL - Bilateral 

efforts

camponovocn@

state.gov

To utilize private 

investment to 

strengthen 

human rights 

and the rule of 

law in select 

countries.

2001 State 

Department 

Basic Authorities 

Act of 1956, as 

amended, See 

22 U.S.C. 

2651a(c)(2).

U.S. 

companies, 

NGOs, 

foreign 

governments.

Ongoing or planned 

projects in Equatorial 

Guinea, Oman and 

China.

Equatorial 

Guinea - 

$225,000; 

Oman - N/A; 

China - 

$400,000 in 

FY 2004.

One staff 

person 

works 20 

percent of 

his time on 

this effort 

[Estimate].
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 60 GAO-05-744 Global CSR

DRL – Work Within 

Multilateral 

Institutions

camponovocn@

state.gov

To promote and 

protect U.S. 

government 

interests in the 

area of CSR and 

human rights 

within 

multilateral 

institutions.

Not 

available.

State 

Department 

Basic Authorities 

Act of 1956, as 

amended, See 

22 U.S.C. 

2651a(c)(2).

Multilateral 

organizations 

and their 

member 

states.

Prepares guidance 

for U.S. delegations 

and responds to 

requests for 

information from 

United Nations 

organizations when 

issues arise related to 

corporate 

responsibility. DRL 

also represents the 

State Department 

and the U.S. 

Government at a 

variety of 

conferences and 

meetings related to 

corporate 

responsibility, where 

human rights issues 

are directly relevant. 

No specific 

budget.

One staff 

person 

works 5 

percent of 

his time on 

this effort 

[Estimate].

Bureau of 

Economics and 

Business Affairs 

(EB) – Secretary of 

State’s Award for 

Corporate 

Excellence

smith-nissleyn@ 

state.gov

To promote best 

business 

practices, good 

corporate 

governance, and 

democratic 

values overseas.

1999 Mission of the 

Bureau of 

Economics and 

Business Affairs.

U.S. small 

and mediumsized 

companies 

and 

multinational 

corporations.

Award nominations, 

public ceremony. In 

FY 2004, the 

Department received 

a record number of 

50 nominations from 

U.S. Chiefs of 

Mission worldwide.

$6,000d One staff 

person 

works 30-

40 percent 

of her time 

on this 

efforte 

Estimate].

EB - US-Mexico 

Good Partner Award

smith-nissleyn

@state.gov

To recognize the 

role that U.S. 

and Mexican 

enterprises, 

business 

associations, 

and academic 

institutions play 

in advancing the 

goals of the 

Partnership for 

Prosperityf to 

boost the social 

and economic 

well-being of 

Mexican 

citizens.

2003 Presidential 

initiative.

U.S. and 

Mexican 

businesses, 

associations 

and academic 

institutions.

Award nominations, 

public ceremony. 

Seventy nominations 

were received in FY 

2003. More than 900 

people attended the 

Award Ceremony and 

Gala, which received 

extensive media 

coverage, especially 

in Mexico.

Not 

available.g

One staff 

person 

works 100 

percent on 

the award 

program 

from April 

– June and 

30 percent 

for the 

remainder 

of the year

[Estimate].

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa

Staff 

levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 61 GAO-05-744 Global CSR

EB - OECD National 

Contact Pointh

usncp@state.gov

To raise 

awareness 

among U.S. 

companies of 

the OECD 

Guidelines for 

Multinational 

Enterprisesi

 and 

to facilitate 

resolution when 

parties raise 

issues 

concerning U.S. 

companies’ 

treatment of the 

guidelines. 

1976 Requirement as 

signatory to the 

OECD 

Declaration and 

Decisions on 

International 

Investment and 

Multilateral 

Enterprises.

Companies, 

labor unions 

and NGOs.

Promotes 

understanding of the 

OECD Guidelines 

and helps companies, 

labor unions and 

NGOs in their efforts 

to resolve issues that 

may arise with 

respect to the 

Guidelines; From 

2000-2004, 16 

specific instances 

were brought to the 

attention of the 

National Contact 

Point.

No discrete 

budget.

One staff 

person 

spends 33 

percent of 

his time on 

this effort 

and one 

office 

director 

spends 10-

15 percent 

of his time 

on this 

effort 

[Estimate].

EB-U.S. Lead to 

OECD Working 

Group on Briberyj

brownpa@state.gov

To combat 

transnational 

bribery of 

foreign public 

officials and 

monitor 

enforcement of 

the OECD 

Convention on 

Combating 

Bribery of 

Foreign Public 

Officials in 

International 

Business 

Transactions 

(Antibribery 

Convention).

1999 See Pub. L. 100-

318, The 

Omnibus Trade 

and 

Competitiveness 

Act of 1988, 

asking the 

Executive 

Branch, led by 

State, to 

negotiate a 

convention on 

bribery at the 

OECD. See also 

Senate 

Resolution of 

Advice and 

Consent to the 

OECD 

Antibribery 

Convention, of 

July 31, 1998. 

Foreign 

governments, 

companies.

Leads U.S. 

delegationk

 to the 

OECD Working 

Group on Bribery to 

monitor 

implementation and 

enforcement of the 

OECD Antibribery 

Convention, and to 

assess areas where 

the Convention could 

be amended to 

decrease bribery and 

other corrupt activity. 

Meet with the private 

sector and civil 

society groups 

regarding 

implementation of the 

OECD Antibribery 

Convention. 

No separate 

funding.

One 

deputy 

office 

director 

spends 50 

percent of 

his time on 

this effort 

[Estimate].

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa

Staff 

levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 62 GAO-05-744 Global CSR

EB-U.S. Lead to G-8 

Anticorruption and 

Transparency Pilots 

brownpa@state.

gov

To reduce 

corruption and 

enhance 

transparency to 

ensure that 

development 

assistance 

resources and 

budget revenues 

achieve their 

intended 

purposes. 

2003 22 U.S.C. 2656. Georgia, 

Nicaragua, 

Nigeria, Peru, 

other G-8 

governments.

Provide assistance 

through the Bureau of 

International 

Narcotics and Law 

Enforcement Affairs 

to develop a series of 

projects with four 

countries that signed 

compacts with G-8 

countries in 2004 

committing to reduce 

corruption and 

enhance 

transparency in their 

budgets, government 

procurements and 

concession-letting 

procedures.l

$150,000 

(cost of 

contractor 

who serves 

as project 

coordinator).

1.25 FTEs.

EB – Coordinate 

U.S. input to the 

United Kingdom’s 

Extractive Industries 

Transparency 

Initiative (EITI)

brownpa@state.

gov

To increase 

transparency 

over payments 

and revenues in 

the extractives 

sector in 

countries heavily 

dependent on 

these resources.

2002 Presidential 

initiative.

Governments, 

companies, 

industry 

associations, 

international 

organizations, 

civil society, 

investors.

Liaise with USAID, 

Treasury, the private 

sector and civil 

society, coordinate 

U.S. policy toward the 

EITI, a United 

Kingdom-led 

initiative.

No separate 

funding.

0.25 of an 

FTE.

Bureau of Oceans 

and International 

Environmental and 

Scientific Affairs 

(OES) – CSRRelated Activities

lbrutten@state.

gov

To promote 

corporate 

responsibility 

through its 

efforts on 

sustainable 

development, 

particularly 

through 

voluntary publicprivate 

partnerships, 

and on making 

trade 

liberalization 

and natural 

resource 

protection 

mutually 

supportive of our 

Free Trade 

Agreement 

(FTA) objectives. 

2001 Foreign 

Assistance Act 

of 1961, as 

amended. 

U.S. 

companies 

and business 

groups, civil 

society, 

foreign 

governments, 

and 

international 

organizations.

Meets with 

representatives from 

the private sector and 

civil society on a 

regular but ad hoc 

basis, includes 

representatives from 

the private sector and 

civil society on official 

U.S. delegations 

relating to sustainable 

development, 

provides information 

about and 

encourages 

sustainable 

development 

partnership efforts. In 

addition, OES leads 

negotiations for 

environmental side 

agreements to trade 

agreements.

No specific 

budget.

Not 

available. 

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa

Staff 

levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 63 GAO-05-744 Global CSR

Office of Private 

Assistance, Iraq 

GramagliaTR@state

.gov

To coordinate 

U.S. private 

donations and 

private 

partnerships 

intended for the 

Iraqi people, 

including 

financial and inkind donations, 

and mentoring. 

2004 Coordinating 

function 

operating 

through the 

bureau.

U.S. 

commercial, 

academic or 

cultural 

contacts and 

civic groups.

Manages a Web site 

for donations, 

coordinates referrals 

from Congress, and 

with other agencies, 

presents to 

gatherings of 

individuals or 

organizations with an 

interest in supporting 

reconstruction and 

humanitarian needs 

in Iraq.

No specific 

budget.

One fulltime 

person.

Middle East 

Partnership Initiative 

– Business 

Internship Program

FranceskiS@state.

gov

To provide 

women from the 

Middle East with 

skills to promote 

successful 

businesses in 

the region while 

promoting 

mutual 

understanding 

and ongoing 

relationships 

between people 

in the United 

States and the 

Middle East.

2003 Emergency 

Wartime 

Supplemental 

Appropriations 

Act, 2003 (See 

P. L. 108-11) and 

chapter 4 of Part 

II of the Foreign 

Assistance Act 

of 1961, as 

amended.

U.S. 

companies.

U.S. companies host 

interns for three 

months at their own 

expense. In fiscal 

year 2003, more than 

35 companies hosted 

interns.

$2,000,000 One part 

time plus 

contractor 

support.

Middle East 

Partnership Initiative 

– Junior 

Achievement 

Program

FranceskiS@

state.gov

To help the 

Middle East 

region’s youth 

gain the skills 

required to build 

and succeed in 

their nations’ 

economies and 

to become 

productive and 

participative 

citizens.

2003 Emergency 

Wartime 

Supplemental 

Appropriations 

Act, 2003 (See 

Pub. L. 108-11) 

and chapter 4 of 

Part II of the 

Foreign 

Assistance Act 

of 1961, as 

amended. 

U.S. and 

foreign 

companies.

Through a 

cooperative 

agreement to the 

Junior Achievement 

program, MEPI is 

setting up chapters 

throughout the region 

to promote 

entrepreneurship, 

such as job training, 

among high schoolaged youth. U.S. and 

foreign companies 

serve as long-term 

sponsors and 

mentors for this 

program. 

$2,400,000m One part 

time plus 

contractor 

support.

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa

Staff 

levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 64 GAO-05-744 Global CSR

Source: GAO based on information provided by agency officials.

a

Budget information is for fiscal year 2003 unless otherwise noted.

b

Staff levels are for fiscal year 2003 unless otherwise noted.

c

This represents grants that were funded in fiscal year 2003. Grants funded in fiscal years 2001 and 

2002 were also ongoing in fiscal year 2003.

d

This figure represents expenses only, incurred by the Bureau of Economics and Business Affairs. This 

figure does not include staff salaries or the Secretary’s representation funds for ceremony hospitality 

and the design, manufacture and shipping of the awards.

e

More than 50 additional staff help to plan and organize the award ceremony.

f

The Partnership for Prosperity is a bilateral initiative between Mexico and the United States designed 

to leverage private sector resources and expertise to boost the social and economic well-being of 

Mexican citizens, particularly in regions where economic growth has lagged. 

g

The cost is the responsibility of the host country. The U.S. will host the ceremony in 2005, but the 

program had not yet established a budget for the costs.

Bureau of 

International 

Organization Affairs 

– select activities

DaleyPB@state.

gov

To ensure that 

initiatives related 

to CSR at the 

United Nations 

and its affiliated 

organizations 

remain 

consistent with 

the imperatives 

of the 

marketplace and 

compatible with 

United States 

interests.

Not 

available.n

United Nations 

Participation Act 

of 1945.

United 

Nations 

programs, 

funds, 

agencies and 

other 

organizations.

Negotiations over 

resolutions, work 

programs and 

budgets in United 

Nations 

organizations, and 

reviews of programs 

and activities.

No specific 

budget.

Several 

staff in this 

bureau 

devote 

time to 

CSR on an 

ad hoc 

basis.

Office of the U.S. 

Global AIDS 

Coordinator (OGAC) 

– Public-Private 

Partnershipso

Moloney-KittsMA@ 

state.gov

To combat 

HIV/AIDS, 

promoting 

integrated 

prevention, 

treatment and 

care 

interventions 

with an urgent 

focus on 15 

countries that 

are among the 

most afflicted 

nations in the 

world.

2004 The U.S. 

Leadership 

Against 

HIV/AIDS, 

Tuberculosis, 

and Malaria Act 

of 2003, See 

Section 101 of 

P.L. 108-25.

Private 

sector.

The private sector is 

a critical partner at 

the country level.p

These partnerships 

facilitate company 

workplace programs 

to create awareness 

about the spread of 

HIV/AIDS, decrease 

stigma among those 

who know their HIV 

status, and provide 

antiretroviral therapy 

to employees and 

their families. The 

office began keeping 

track of the number of 

partnerships in FY 

2005. 

No specific 

budget.

Not 

applicable.

(Continued From Previous Page)

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

informationa

Staff 

levelb
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 65 GAO-05-744 Global CSR

h

In addition to the Department of State, USTR, EPA and the Departments of Treasury, Commerce, and 

Labor help resolve complaints against companies.

i

The guidelines are a set of nonbinding recommendations that have been agreed upon by OECD 

member countries. Their aim is to provide guidance for companies on a range of business activities, 

including industrial relations, human rights, environment, information disclosure, competition, taxation, 

and science and technology.

j

The Department of State also coordinates with the Departments of Commerce and Justice to address, 

as appropriate, alleged incidents of bribery of foreign public officials (by foreign-based corporations) 

that adversely affect the opportunity for U.S. companies to compete on a transparent and level playing 

field for international tenders and contracts.

k

The Departments of Commerce and Justice are also members of the U.S. delegation.

l

These projects implement the Evian Declaration on Fighting Corruption and Improving Transparency 

that was signed by G-8 leaders in 2003, and proposes specific actions to reduce corruption and 

enhance transparency as part of a strategy to ensure that development assistance resources and 

budget revenues achieve their intended purpose. According to a State Department official, the 

Declaration proposed a partnership between donor and recipient countries to change the incentives to 

make corruption less attractive to public officials, expose the economic and political costs of corruption, 

and institutionalize effective checks and balances on corrupt regimes.

mFiscal year 2003 funds are also being spent in fiscal year 2004.

n

According to an agency official, this has been a continuing effort that has become more or less 

intense as CSR issues have become larger or smaller pieces of the work programs at these UN 

agencies.

o

OGAC is not an implementing office. Actual implementation of partnerships with the private sector 

and other workplace activities are put forth from its implementing agency partners, primarily USAID 

and The Department of Health and Human Services (HHS). 

p

At the local level, U.S. government offices work with pharmaceutical companies on an ad hoc basis to 

facilitate drug donations in specific countries.
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 66 GAO-05-744 Global CSR

Table 12: Responses from the Department of Treasury

Source: GAO based on information provided by agency officials.

a

Staff levels are for fiscal year 2003 unless otherwise noted.

b

OFAC administers the Rough Diamonds Control Regulations. In addition, pursuant to the Clean 

Diamond Trade Act (Act), OFAC (as the designee of the Secretary of the Treasury) and the 

Department of State cochair a Kimberley Process Implementation Coordinating Committee to 

coordinate implementation of the act and the Kimberley Process Certification Scheme for the United 

States. The Committee meets periodically to evaluate implementation issues, and, if necessary, take 

steps to improve performance. Other agencies, including the U.S. Census Bureau and Customs and 

Border Protection (CBP) are also involved with the implementation.

c

The Kimberley Process Certification Scheme as set forth in the regulations includes, among other 

requirements, trading rough diamonds only with other Kimberley Process participants having a 

validated Kimberley Process Certificate accompanying all exports and imports, and keeping 

accessible records about these transactions for at least 5 years. 

d

As part of the Kimberley Process, the diamond industry undertook to implement a voluntary system of 

self-regulation through a system of warranties that allows for the traceability of rough diamond 

transactions.

e

This does not capture the resources of additional agencies involved in the implementation of the 

Clean Diamond Trade Act.

f

According to an official at Treasury, most of the staff time is at the Department of State. This does not 

capture the resources of additional agencies involved in the implementation of the Clean Diamond 

Trade Act.

CSR-Related 

program/activity Objective Start year Legal basis

Groups 

targeted Activities

Budget 

information Staff levela

Implementation of 

the Clean Diamond 

Trade Act and 

Executive Order 

13312 by the 

Treasury 

Department’s 

Office of Foreign 

Assets Control 

(OFAC) - (with the 

Department of 

State)b

www.treas.gov/ofac

To implement the 

Kimberley 

Process 

Certification 

Scheme, pursuant 

to which 

participating 

countries, 

including the 

United States, 

seek to prevent 

rough diamonds 

used to fuel 

armed conflict 

aimed at 

undermining or 

overthrowing 

legitimate 

governments from 

entering the 

legitimate world 

diamond trade.

2003 Clean 

Diamond 

Trade Act (P.L. 

108-19), 

Executive 

Order 13312, 

and Rough 

Diamonds 

Control 

Regulations, 

31 C.F.R. part 

592

(Regulations).

Companies or 

individuals 

involved in the 

export from 

and/or import 

into the United 

States of 

rough 

diamonds.

The Regulations 

provide that trade 

in rough diamonds 

is prohibited unless 

the rough diamond 

is controlled 

through the 

Kimberley Process 

Certification 

Scheme as set 

forth in the 

Regulations.c

 The 

U.S. also 

participates in 

Kimberley Process 

multilateral working 

groups on 

Monitoring and 

Statistics.d

No specific 

budget.e

Three FTEs.f
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 67 GAO-05-744 Global CSR

Table 13: Responses from U.S. Agency for International Development

Source: GAO based on information provided by agency officials.

a

Budget information is for fiscal year 2003 unless otherwise noted.

b

Staff levels are for fiscal year 2003 unless otherwise noted.

c

In addition, according to officials, USAID overseas missions and USAID/Washington funded alliances 

to the total amount of $360 million. 

CSR-Related 

program/activity Objective Start year 

Legal 

basis

Groups 

targeted Activities

Budget 

informationa Staff levelb

Global Development 

Alliance

www.usaid.gov/gda

To encourage publicprivate partnerships 

for development 

projects.

2001 Foreign 

Assistance 

Act of 1961 

(P. L. 87-

195), as 

amended.

Foundations, 

for-profit firms, 

civil society 

organizations, 

foreign 

governments. 

Trains USAID 

staff on publicprivate 

alliances and 

conducts 

outreach to 

private sector 

and civil society 

partners. For 

fiscal years 

2002-2004, 

USAID 

leveraged over 

$3.7 billion in 

partner assets 

through $1.1 

billion in agency 

funding. 

$29.8 million.c Six full time 

staff plus 

contractors 

and field 

support.d

Volunteers for 

Prosperitye

www.volunteersforprosp

erity.gov

To deploy skilled 

volunteers in U.S. 

foreign assistance 

programs.f

2003 Executive 

Order 

13317.

U.S.-based 

organizations, 

including 

corporations. 

By the end of 

FY 2004, 

Volunteers for 

Prosperity 

recruited nearly 

200 for-profit 

and nonprofit 

organizations, 

representing a 

pool of at least 

34,000 skilled 

American 

professionals 

available to 

serve as 

volunteers. 

Participating 

organizations 

reported having 

deployed nearly 

7,000 

volunteers.

No specific 

budget.

Three full 

time staff.g
Appendix II

Federal Agency CSR-Related Programs and 

Activities

Page 68 GAO-05-744 Global CSR

d

Each USAID mission office and bureau has a Global Development Alliance point of contact, and each 

mission office manages at least one public-private alliance.

e

USAID serves as the interagency coordinator for this initiative. Per the executive order, USAID, the 

Departments of State, Commerce and Health and Human Services were required to set up Volunteers 

for Prosperity offices or operating units.

f

The volunteers serve to support efforts related to six presidential initiatives: The Emergency Plan for 

AIDS Relief, the Trade for African Development and Enterprise Initiative, the Water for the Poor 

Initiative, the Digital Freedom Initiative, the Middle East Partnership Initiative, and the Millennium 

Challenge Corporation. Organizations that become Volunteers for Prosperity participants and support 

the deployment of highly skilled American volunteers are given priority for federal funds for these 

initiatives.

g

As of March 2005, three full-time staff were approved, although two staff were in place.

Table 14: Responses from Office of the U.S. Trade Representativea

Source: GAO based on information provided by agency officials.

a

Officials from the USTR acknowledged that the agency undertakes some activities that might 

complement CSR, but emphasized that the agency’s mission is to negotiate trade agreements, and 

not to engage in CSR-related efforts.

b

Staff levels are for fiscal year 2003 unless otherwise noted.

CSR-Related 

program/activity Objective Start year 

Legal 

basis

Groups 

targeted Activities

Budget 

information Staff levelb

Negotiating Free 

Trade Agreements

www.ustr.gov

To ensure that 

negotiating 

objectives on labor 

and the 

environment laid 

out in the Trade 

Act of 2002 and 

issues of concern 

to trading partners 

are included in 

free trade 

agreements. 

2002. Trade Act of 

2002.

Foreign 

governments.

Negotiating terms of 

trade agreements with 

U.S. trading partners. 

USTR will consider 

including CSR issues 

and projects in trade 

agreements if the issue 

is raised by trading 

partners. For example, 

CSR language is 

included in the USChile and USSingapore free trade 

agreements. 

No discrete 

budget.

FTA 

negotiators 

address CSR 

as warranted 

during 

negotiations.

Outreach to 

Business 

Associations 

www.ustr.gov

To improve labor 

standards and 

business conduct 

in U.S. business 

overseas.

Not 

available.

Not 

available.

Business 

groups.

USTR meets with 

business groups on an 

ad hoc basis to discuss 

a range of issues. On 

occasion, this includes 

encouraging 

businesses to 

implement corporate 

codes of conduct.

No discrete 

budget.

One percent 

of one staff 

person’s 

time.
Page 69 GAO-05-744 Global CSR

Appendix III

GAO Contact and Staff Acknowledgements ApendxiI

GAO Contact Loren Yager (202) 512-4347 

Acknowledgements In addition, Kate Blumenreich, Kenneth Bombara, Martin De Alteriis, Mark 

Dowling, Tim Fairbanks, and Kim Frankena made key contributions to this 

report. Shirley Brothwell, Emilie Cassou, Jeanette Espinola and Richard 

Lindsey also provided assistance.

(320271)
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