This year, the Ministry of Corporate Affairs, Government of India, instituted National Corporate Social Responsibility (CSR) Awards to recognise companies that have made a positive impact on society through their innovative and sustainable CSR initiatives.

The corporate world, being the foremost stakeholders of these awards, is looking at them as being at par with National Film Awards, Sahitya Akademi Awards, Khel Protsahan Purasakar and all such awards that have been constituted by the central governments or their affiliated departments.

Considering that the last few years have seen the CSR space getting populated with pay-and-get-decorated type of awards, the move by the ministry has created a needed buzz as well as some hope that finally some benchmarks will be created as far as the felicitation and recognition of impactful CSR programmes is concerned.

Looking at the excitement among companies, the editorial team of CauseBecause planned a feature on the same. In the last month, the team spoke to several decision makers – CEOs and CSR heads at corporate groups, corporate foundations and large NGOs that are implementing CSR programmes in India. During these interactions, all of them appreciated the move and at the same time shared ideas and suggestions as well as some concerns about the application and selection process and the evaluation mechanism. They all wished that these would be conveyed to the honourable ministry and Indian Institute of Corporate Affairs (IICA).

Being a responsible medium in this domain, CauseBecause shouldered the responsibility of consolidating all relevant points and created a formal report to be shared with the nodal officer, National CSR Awards, Indian Institute of Corporate Affairs, keeping all relevant officials and stakeholders in the loop. The purpose and the progress of the exercise had already been communicated to DG & CEO at IICA as well as the nodal officer.

Following are the common and most relevant suggestions that leaders (only from the limited/private limited companies, not PSUs) have put forth:

1.Nomination categories
Nomination categories were an area of concern for nearly all leaders who conversed with CauseBecause. They pointed out that all companies investing above Rs 5 crore were put in the same category. This was a major gap as companies sending Rs 5 crore could be competing with companies spending over Rs 500 crore in the same category, making the competition a bit unfair as far as the scale of the programmes was concerned.

For example, X Company nominates its children-focused project wherein it is investing Rs 5 core, and Y Company nominates a project in the same category but has made Rs 50 crore investments, and both projects have similar objectives and implementation mechanism, the one making a higher investment certainly gets an edge in making a larger measureable impact.

To address this concern, following are some ideas that came up during discussions with CSR decision makers.

1.1 Categories may be according to project budget, not whole CSR budget 

This approach will primarily be focusing on programmes and their impact vis-à-vis the investment made. For example, all companies investing between Rs 1 crore to Rs 10 crore in Human Development projects may nominate in one category. Likewise, another category could be made for companies investing above Rs 10 crore and up to Rs 25 crore for same cause, and so on.

1.2 Categorisation by turnover/CSR budget break-up

In case the jury and IICA wish to retain turnover/CSR budget-wise categories, it may look at further bifurcation of that in order to avoid small companies competing with large corporate groups. For example, all companies with CSR budget of Rs 10 crore to Rs 20 crore may nominate in one category, the ones spending above Rs 20 crore but less than Rs 40 crore may get a separate category, and so on.

2. Sub-sectors in nomination categories
Most companies have multiple ongoing projects in most of the sub-sectors mentioned under larger categories. For example, there are many companies running two or three projects under education, gender equality or sports sub-sector, and would want to nominate all three. However, the awards rules/guidelines state that one company can nominate only one project for one sub-sector, thereby limiting its ability to present/showcase the holistic impact that the CSR programme could be making through multiple complementary projects targeting the same set of beneficiaries.

Another area of concern with sub-sectors is that there is a clutter of sub-sectors under human development category. Thus, projects focused at education, sports, health & nutrition, women and child empowerment, old-age-care projects, gender equality, malnutrition… all fall within the same category.

In the current application format, despite their different thematic approaches, measurement indices and expected outcomes, all programmes will compete in the same category. This means a programme focused at gender parity may be competing with a programme focused at old age or a programme focused at development of sports.

Therefore, it is suggested that multiple nominations under one category or multiple sub-sectors in each category be allowed.

At present, there are companies that run 5-6 programmes under 4 sub-sectors of human development category and none for other sectors in other categories. Such companies, as per the current nomination rules, can apply for one category only.

3. Impact measurement techniques/parameters/mechanism
The nomination forms have asked for almost every detail related to each element of the CSR programme, including the impact evaluation done by the company as well as a third party. Corporate groups here wish to understand the common assessment parameters that have been chalked out for each sub-sector.

3.1 Clarity on the basis of merit of the programme is needed. Is there going to be a weightage points system (X points for innovation, Y points for scale, Z points for impact, etc.)? Is there any other mechanism that has been decided by the IICA or the jury?

3.2 Ideally, the entire cycle from short-listing to awarding should be transparent, and the companies that do not get the award should know the reason for their not making it and work upon betterment of the project.

3.3 Contradiction to CauseBecause RTI on impact measurement?
In September 2015, replying to CauseBecause’s queries filed under RTI (Registration No. MOCAF/R/2015/60791), Ministry of Corporate Affairs had stated: No mechanism exists in the Ministry to evaluate the real impact of Corporate Social activities of every company that falls in the ambit of Section 135. Under the provisions of Section 135 of the Act, the Board and the CSR Committee is to formulate and recommend a CSR Policy, including the activities to be undertaken by the company with allocation of funds across activities. The Committee is also responsible for monitoring implementation of CSR policy from time to time.

The institution of awards this year, however, suggests that the ministry—probably through Indian Institute of Corporate Affairs—has conceptualised a mechanism to minutely evaluate each CSR programme that will be nominated for the awards. A little clarity on this will be good as it will help companies and their impact assessment partners to devise a strategy as well as identify measurement indices for various projects under various sectors and sub-sectors.

4. Commendation/consolation/appreciating certificate
Considering that this is the first year of the awards and that these come at a time when hundreds of companies are yet to start reporting on their CSR, it will be great to encourage companies by adding a commendation certificate as part of the awards. These may be given to companies who nominated good projects with appreciable concepts but could not win the award.

The commendation will surely help the jury as well. For instance, when jury will be comparing a sports project and an old-age-focused project for the same award category, they may choose one for the award and the other for a commendation certificate.

5. Felicitations for CSR professionals
Many CSR professionals have been selflessly engaged in the domain and have been instrumental in making a great impact at the grassroots. Since the awards have been conceptualised for the programmes, it would be great value addition to have a few professionals felicitated for exceptional work.

5.1 Felicitation for exceptional work by CSR heads/decision makers
Encourage young professionals, many of whom are being trained to be social leaders of the future by IICA itself through its various courses.

5.2 Lifetime achievement award
There is a suggestion from a section of the corporate groups to institute/include a category for lifetime achievement award for retiring professionals or for those who have been serving the space several years.

5.3 Felicitations for founders/business owners/managing directors
CSR decisions are now being made at the highest office in the company, with the managing director being the chairman of the CSR committee. Hence, a few awards/recognitions focused only at the founders/business owners/managing directors may add great value. This, too, can be decided based on the size of the company, so as to encourage SMEs and other small organisations to apply for the same.

6. Composition of jury
Most corporate leaders understood and appreciated the fact that the jury’s names are not out in the public domain (some said they feared lobbying by dominating companies). At the same time, many of them observed that knowing the strength, as in number of jury members, their areas of expertise and experience, could lend more credibility to the awards-evaluation process.

Inclusion of an unbiased individual from a neutral non-profit organisation and unbiased domain media has also been recommended.

7. Include weightage for pro bono/volunteerism/ISR initiatives
Almost all companies have started to encourage employees to be socially responsible – to be conscious of their individual social responsibility. Of late, collective volunteering efforts of employees of large corporate houses (where number of employees varies from about 2,000 to 200,000) are making an appreciable contribution towards various social programmes. Therefore, while evaluating a particular CSR programme of the company, engagement of its employees in the same may also be measured.

8. Enquiries cell for nominating companies
The idea of having an active cell to guide a company through the nomination process was also brought forth by several leaders. It was noted that no direct number had been given for awards-specific queries. A couple of companies stated that the staff often did not connect the caller to the nodal officer or his staff.

9. Website: Language and navigation errors
Some individuals pointed out some simple language errors on the FAQs section – this needs editing. It was also noted that the site did not allow saving of the nomination process in the middle unless one section was fully filled and completed.

NOTE: CauseBecause is only playing its role as a domain medium and does not intend to influence, disturb, interfere in or hamper the work and efforts of MoCA and IICA. The intent of this report is only to share the suggestions with the concerned authorities.  Incorporation of one, all or none of the suggestions in the awards parameters is the prerogative of the authorities.

CauseBecause is not representing any one corporate or business entity. The suggestions as stated in the report are unbiased and a consolidation of common responses by the majority of respondents.

The names and designations of some of the respondents are given below. Eight decision makers at different companies requested anonymity, hence while their names have not been shared, their suggestions are incorporated.

  • Dr Pragnya Ram
    Group Executive President, Aditya Birla Group
  • Brigadier Rajiv Williams
    Head CSR, Jindal Stainless
  • Mr Vijay Sethi
    CIO & Head CSR, Hero MotoCorp
  • Ms Nidhi Pundir
    Director CSR, Head, HCL Foundation
  • Ms Sushama Oza
    CEO, Adani Foundation
  • Mr Deepak Arora
    CEO, Essar Foundation
  • Ms Mohini Daljit Singh
    CEO, Max India Foundation
  • Ms Vikas Goswami
    Head, Green and Good, Godrej Industries and associate companies
  • Mr Rishi Phatania
    Head CSR, UPL Limited
  • Ms Urja Shah
    Managing Director, Setco Group of Companies
  • Mr Vishwas Dhumal
    CEO, Industrial Infrastructure and logistics, K Raheja Corp
  • Mr Debangshu Ganguly
    Head Partnerships, REACH India
  • Mr Ranjan Rayna
    Director & chief strategist, CauseBecause

[CauseBecause is doing a story on evaluation mechanism of about half a dozen CSR awards that started in the last few years. The team will only present the facts and leave it to you to make sense of their credibility.]

Images are symbolic and are not related to any CSR awards