Draftsman de Roo would have the following main points to add to Mr. Bushill-Matthews’ draft report:

CSR must be placed firmly in the context of sustainable development;
CSR can never be seen as an alternative to, or substitute for, adequate governance, sound and effective public policy and legislation;
the term “corporate social responsibility” emphasises the social frame only, and therefore, it should be changed to “corporate responsibility” to cover the environmental aspect as well;
CSR has been defined as a voluntary approach, yet companies should be required to contribute to a cleaner environment by law and not only on a voluntary basis;
a common framework and harmonised standards are important and, in this context, the Commission should develop mechanisms for the registration, verification and enforcement of internationally agreed codes of conduct, which could be best done via a specialised agency;
the Commission should propose a legislative framework for mandatory reporting, requiring transnational companies to publish an independently verified annual report, taking the “triple bottom line” approach (integrating social, environmental and economic criteria);
integration of CSR into other policies should be enhanced.