MODEM HART

The term CSR can be said to be surrounded by the concept of guidelines from various organisations, states and groups. A guideline is characterised by being voluntary, as opposed to restrictions, laws and prohibitions. One could see guidelines as a first step in a desired direction as it lays down a visionary picture of a wanted situation (OECD, 2009; Autischer, 2009). In general, the purpose of guidelines are, “orientation, coordination, motivation and legitimation” (Autischer, 2009). Therefore which guidelines are adhered to might say something about the intentions and underlying values that an actor base the activity on.

We can set guidelines ourselves, we have to operationalise these things anyway. And it should always be a good debate internally on these things. And I think our board, the managing director and the organisation see the importance of this (Ersdal [interview], 26.06.09). Our reality is very complex and the guidelines from the IFC are very strict. We need some flexibility to adapt to different investments. To have clear instructions that dictates what we can do would limit what we can accomplish (Ersdal [interview] 26.06.2009).

Norfund is seen to take a passive and inward approach on this issue. An aspect of adopting guidelines is the fact that the guidelines are set by someone else, meaning that Norfund import some values and norms set in the political environment of the World Bank. Another aspect is the inactive attitude towards contributing in the dialogue on these guidelines. It is expected that a country like Norway, hailed for the transparency and the ethical guidelines set for the Governments Pension Fund -Global, would be highly considered in discussions on guidelines.

61 Influencing such guidelines can be argued to represent power in a global governance

perspective but Norfund does not take this role. One could argue that such activity is not in line with Norfund‟s mandate and that it would be more natural for the MFA to take on such tasks. But the fact that Norfund is invited to participate with other DFIs in the discussion and revision of the IFC standards, but refrain from participating, should raise the question on whether Norfund is using its international authority in accordance with what is stated:

We do not demand that all companies that we invest in shall be within the IFC standards or high international standards on HSE, but we shall contribute so that they move in the right direction. If we demanded the ideal standards before entering, there would have been no companies to invest in. These standards consider the more overarching politics and the principles are not that important to us. The important thing is to move in the right direction in every company by identifying what they can improve on. That is why we leave constructing standards to the IFC (Roland [interview] 26.06.09).

The on-ground approach taken can be argued to be in line with the mandate that Norfund has to work within. But looking at the Norwegian CSR regime, perhaps we should expect the political environment to take stronger measures to make sure that Norwegian policies, values and issue management were reflected in the CSR approach taken by Norfund? Within the Norwegian CSR regime voluntary codes and informal guidelines can be argued to have set the standards. Collective bargaining and communication has been a common feature (Gjølberg, 2009). In the White paper on CSR guidelines are presented as a central part of the official Norwegian CSR policy. Few regulations or restrictions are described, but the CSR strategy circles around expectations and encouragement in relation to international guidelines. The Scandinavian CSR regime and traditions cannot be said to be taken into account here as companies are encouraged to following international guidelines (St.meld. nr.10, 2009). This also leaves Norfund to the international guidelines and they specifically follow the World Bank, IFC standards.

We are a small DFI so we are using the IFC standards in everything we do; we are not moving the frontier on this area” (Ersdal [interview], 26.06.09).

The IFC organises a community of learning that is set up to share experiences between the different organisations that adhere to the IFC guidelines. This is also a forum for developing the guidelines further, where the participants can comment and suggest changes. The

community of learning are hosting events where the guidelines are discussed (IFC, 2009). Norfund has been invited to the learning community twice, but never participated (Vilsted [interview] 22.06.09)

62 We have decided to import guidelines. Others have more resources devoted to affect the guidelines. I have not seen this as a problem that these standards are not ambitious enough. We are on the receiving end and will follow the IFC guidelines (Roland [interview] 26.06.09). The UNDP has been in touch with Norfund on several occasions to make the organisation sign on to the Global Compact (GC) guidelines. This has triggered an internal discussion on whether Norfund should join:

The Global compact guidelines are loose principles that you sign on to and you decide yourself what kind of principles you want to adhere to. This reduces the value of GC for Norfund as the guidelines we are following [the IFC guidelines] are strictly defined and extends the voluntary nature of GC (Vilsted, 2009 [interview]).

Another way that Norfund could use the GC guidelines is to work with the companies that they invest in to get them to sign on to the GC. This reflects a view that CSR is something that the companies have to do:

If Norfund signed the GC guidelines it would be more as a communication strategy (Vilsted [interview] 22.06.2009).

For Norfund it is more important to get an overall understanding of our partner‟s strategies than judging them on the basis of their commitment to GC or not (Vilsted [interview] 22.06.2009).

It is positive if the companies that we invest in are adhering to the Global Compact principles, but we are not pushing for the Global Compact per se (Ersdal [interview] 26.06.09)

The internal debate on this reflects the dimension of how CSR is operationalised within the organisation. Some of the responsibility is here moved to the companies themselves and Norfund arguably acts as a facilitator of voluntary action rather than enforcing some strict principles towards the companies. This way of making sure that guidelines are acted on can be characterised as weak, with considerable uncertainty that guidelines are anything more than an act of window-dressing.