INSTITUTIONAL DYNAMICS OF CORPORATE SOCIAL RESPONSIBILITY STANDARDIZATION: A MULTILEVEL PERSPECTIVE ON THE ESG RATING FIELD Emma Avetisyan* SKEMA Business School Campus Sophia – Antipolis 60, Rue Dostoïevski – BP 085 06902 Sophia- Antipolis Cedex, France Tel.:+33 (0)4 93 95 46 29 Jean-Pascal Gond HEC Montréal Édifice Côte-Sainte-Catherine 3000, chemin de la Côte-Sainte-Catherine Montréal (Québec), Canada H3T 2A7 Tel.: 514 340-7029 Fax: + 1 514 340-5635 jean-pascal.gond@hec.ca EGOS 2012 Sub-theme 15: Multiplicity and Plurality in the World of Standards – Convenors: Frank den Hond, Marie-Laure Djelic, Kristina Tamm Hallström Keywords: Corporate Social Responsibility, ESG rating agencies, Standardization Dynamics, Institutional Change, Multilevel Analysis * Corresponding author 1 INSTITUTIONAL DYNAMICS OF CORPORATE SOCIAL RESPONSIBILITY STANDARDIZATION: A MULTILEVEL PERSPECTIVE ON THE ESG RATING FIELD Corporate Social Responsibility (CSR) has recently emerged as an organizational field aiming at regulating corporate behavior across variety of institutional arenas (Aguilera et al., 2007; Campbell, 2007; Gond, Kang, and Moon, 2011; Matten and Moon, 2008). Central to this process is the development of CSR standards that make the ambiguous notion of CSR calculable and manageable, laying the ground of a global “CSR infrastructure” (Gilbert, Rasche, and Waddock, 2011; Waddock, 2008). CSR standards support the institutionalization of CSR practice within corporations through the pressure they exercise via financial markets (Déjean, Gond & Leca, 2004; Slager, Gond, and Moon, 2010, 2012). CSR standardization enhances the development of the so-called “markets for virtue” (Vogel, 2005) such as responsible investment, by providing quantified tools that meet investors’ expectations and professional standards (Acquier and Aggeri, 2007; Déjean, Gond, and Leca, 2004). Although organizational standardization is exercised through a variety of processes (Brunsson and Jacobsson, 2000)—such as the development of an “audit society” (Power, 1997) or the emergence of new rankings or ratings that discipline organizational actors (Sauder and Espeland, 2009)—little is known about how modes of standardization taking place at a variety of levels of analysis interplay to shape organizational behavior and push it toward CSR or sustainability (Aguilera et al., 2007). As a result, the dynamics stimulated by the potential contradictions of attempts at normalizing CSR behaviors engaged by a variety of agencies with different expectations at the organizational field, national, regional, and transinternational field levels has been overlooked (Gilbert et al, 2011; Gilbert & Rasche, 2007). This neglect is especially problematic in the CSR domain which is characterized by a plurality of meaning and definitions (Carroll, 1999, 2008; Gond & Moon, 2011), that have been shown to depend heavily from the institutional contexts within which actors operate (Matten and Moon, 2008), and given that numerous institutions—such as national governments or the 2 European union—seek to “govern” CSR self-regulation (Gond et al., 2011). In addition, the lack of knowledge about the interplay across standardizations levels prevents the theoretical consolidation of a much needed “multilevel” that could contribute the micro / macro divide in CSR theory (Aguinis and Glavas, 2012; Aguilera et al., 2007). This paper starts addressing these gaps by focusing on the institutional dynamics of standardization within and around the field of CSR or Environmental, Social and Governance (ESG) rating.i ESG ratings and indexes can be regarded for at least two reasons. First, some of them have been accepted by scholars as a standard for CSP measurement (Gond & Crane, 2000). As such, the KLD data set became de facto research standard for measuring CSP in scholarly research (Sharfman, 1996; Waddock, 2003; Wood, 2000). Second, ESG ratings and CSR index based on these rating such as the FTSE4GOOD (launched by FTSE) were seen as a de facto standard within the responsible investment field and was mobilized by corporations for good CSR practices (Déjean, 2006; Slager et al., 2012). Since the late 1980s, a plethora of ESG rating agencies have sprung up, developing new rating methodologies to meet the (new) needs of concerned investors (Avetisyan and Hockerts, 2012; Déjean et al., 2004; Gond, 2006). Because ESG rating agencies operate on the financial markets, they are more likely to alter corporate behavior than other CSR standards (Slager et al., 2012; Vogel, 2005) and they may reflect current economic transformations such the broader process of global CSR standardization (Gilbert et al., 2011). In addition, due to their position in the CSR field at the interface of corporations, investors, media organizations, and civil society organizations (e.g., NGOs or labor unions), these agencies offer a unique window to uncover the current standardization dynamics at play in the (meso) ESG rating field and the process whereby social and environmental are progressively translated from global (macro) institutional spheres of standardization to (micro) intra-organizational corporate practice. Finally, because these agencies provide competing modes of CSR evaluation, the study of their interplay can 3 advance our understanding of organizational standardization competitive dynamics. Therefore, we relied on this specific organizational field to shed light on the CSR standardization dynamics within and across levels of analysis. Our analysis relies on a set of interviews with experts from several of the main players in the ESG rating field and their key stakeholders as well as on secondary data. Together these data allow reconstructing the historical emergence and dynamics of this fieldand clarifying its organization. Our findings capture the ESG rating field functions as a process translating a set of social, ethical, environmental and governance issues across levels to the corporations. Specifically, our analysis points to three core tensions that structure the dynamics of ESG rating standardization: a tension between global and national processes of CSR standardization at the macro level; a tension between differentiation and homogenization of CSR standards within the meso field of ESG rating (inter-organizational); and finally a tension between tailoring and industrialization of CSR standards that underlie the search for a sustainable business model at the micro level (organizational). Through a second stage of analysis, we build on our data to highlight the interplay between these three levels and describe how each dynamics of CSR standardization contribute to shape the two others. This allows theorizing how standardizing organizations (ESG rating agencies) balance the tensions across multiple levels of analysis in their struggle to impose their approach to CSR standards. In approaching ESG ratings standardization as a multilevel process structured by the management of a variety of tensions, our paper makes three theoretical contributions to the study of organizational standardization and CSR. First, we theorize the functioning and dynamics of an important group of actors in the “CSR calculative infrastructure” (Slager et al., 2012; Waddock, 2008) in showing how they collectively contribute to shape managerial attention to specific issues by translating and materializing these issues. In so doing, we uncover an important aspect of the broader process whereby social, environmental, ethical or 4 governance issues are progressively incorporated within market functioning (Shamir, 2008) and advance the understanding of CSR standardization (Gilbert et al., 2011). Specifically, we clarify how standardizing agencies extend and transform their domain of relevancy over time (Durand and McGuire, 2005). Second, our findings also highlight the tensions that structure the dynamics of CSR standardization within a variety of levels of analysis. These tensions explains how and why ESG issues resist to some extent commensuration and homogenization and point to the paradoxical need for agencies to maintain their differences for marketing and intraorganizational purpose even though they collectively need to reduce differences in their stakeholders’ perceptions of their methods and ratings. This conceptualization allows considering how standardizing organizations balance multiple tensions within and across levels of analysis. Third and finally, we provide a framework that clarifies the relationships between CSR standardization processes across levels of analysis and that can be applied to other field than ESG rating. This framework brings together various streams of research on intraorganizational, organizational and international standardization dynamics (Brunsson & Jacobsson, 2000; Djelic & Quack, 2003; Djelic & Sahlin-Andersson, 2006; Tamm Hallström, 2000) and contributes to build a consolidated multilevel CSR theory (Aguinis and Glavas, 2012; Aguilera et al., 2007). CORPORATE SOCIAL RESPONSIBILITY STANDARDIZATION: TOWARDS A MULTILEVEL PERSPECTIVE Organizational Standardization Standardization has been defined as a growing form of organizational regulation that involves the construction of rules that define what adopters should (or should not) do (Brunsson and Jacobson, 2000: 1). Organizational definitions of standards point to standard design activities—such as calculative or rule-making activities (Ahrne et al., 2007; Déjean et 5 al., 2004; Timmermans and Epstein, 2010), legitimacy-building activities (Durand and McGuire, 2005; Kerwer, 2005) as well as monitoring activities (Gilbert et al., 2011; Power, 1997) as core elements within standardization dynamics (Slager et al., 2012: 4). Thus far, organizational studies of standard have been dominated either by a focus on standard diffusion or considerations related to the process of standard adoption by organizations (Gilbert et al., 2011: 38). On the one hand, the diffusion perspective on standards has clarified the factors driving the diffusion of standards at the industry, national or international levels of analysis (Delmas, 2002; Delmas and Montiel, 2008; Delmas and Monte-Sancho, 2011). On the other hand, the adoption perspective on standards suggests that diffusion processes may be superficial as it is subjected to organizational “decoupling” (Boxenbaum and Jonsson, 2008; Meyer and Rowan, 1977), that is a ceremonial and superficial adoption. Studies of CSR standards diffusion such as ethical code of conducts or environmental standards tend to confirm the plausibility of decoupling as an outcome of standard diffusion (Aravind and Christmann, 2011; Behnam and MacLean, 2011; Boiral, 2003; Weaver, Treviño and Cochran, 1999). However, organizational capacity to decouple their activities has been shown to depend heavily on the nature of standard at hand (Fiss and Zajac, 2006), and recent studies of the influence of rankings on organizational behavior suggest that some standards may have a lasting influence on organizational practices (Sauder and Espeland, 2009; Slager et al., 2010, 2012). Accordingly, the understanding of the process of standard’s organizational influence remains to a large extent bounded by our knowledge of the organizational activities that underlie the production, maintenance and regulative power of standards. Recent research addresses this shortcoming by focusing on how organizations produce standards rather than on the impact or outcome of standardization processes. These studies have clarified the relational nature of standards-making by focusing on the active co- 6 construction of standards by “standardizing” and “standardized” organizations (Seidl, 2007) or by analyzing the multi-stakeholder processes driving their construction and dynamics (Tamm Hallström, 2000; Fransen and Kolk, 2007). For instance, Etzion and Ferraro (2010) show how groups involved in the establishment of Global Reporting Initiative (GRI) standard have purposefully built analogies to enhance the legitimacy of their standards through successive transformations. Slager et al. (2012) completed this investigation of the activities underlying the building of a standard in analyzing the construction of the FTSE4Good index as a form of “institutional work” involving continuous activities. These authors show how the combination of these micro-level activities progressively enhances the regulative power of the standards over the regulated organizations. Their contributions to the dynamics of standardization nothwistanding, prior studies of the organizational production of standards are restricted by their focus on a single process of standard construction (e.g. GRI, ISO 26 0000, or FTSE4Good) that generates several concerns. First, such an approach tends to restrain the focus of analysis on a focal organization and its key stakeholders neglecting the interplay of the process of standard production with concurrent process taking place at other level of analysis. In particular the competitive dynamics underlying the organizational production of standards tend to be tuned down in these studies. Second, this approach neglects the potential interdependencies between standards that may play a crucial role in the broader process of CSR commodification by enhancing standards’ interoperability (Acquier and Aggieri, 2007; Henderson and Clark, 1990). Third and finally, such a research design prevents the theorization of processes that cut across standardization processes levels of analysis, preventing the development of a multilevel process of standardization. However, several scholars have pointed to the need for a consolidated understanding of CSR across levels of analysis (Aguilera et al., 2007; Aguinis and Glavas, 2012; Gond et al., 2010). 7 In this study, our aim is to shed light on the standard competitive dynamics and interplay by providing a multilevel understanding of how a variety of standardization dynamics interplay in the CSR domain. We specify some of the core dimensions of such a multilevel perspective. A Multilevel Perspective on Corporate Social Responsibility Standardization Although it is nowadays admitted organizations evolve in a “world of standards” (Brunsson and Jacobsson, 2000), nowhere is this affirmation clearer that in the domains of social, ethical, governance and environmental issues (Waddock, 2008). Over the last twenty years, trends such as globalization and deregulation have created governance gaps (Ruggie, 2003; Scherer and Palazzo, 2011) that have been partially addressed by the development at the international level of a “soft law” that took the form of “international accountability standards” (Gilbert et al., 2011). These standards create a new mode of governance that has been described as “transnational regulation” (Djelic and Sahlin-Andersson, 2006: 3-4). They not only encompass CSR reporting guidelines (aforementioned GRI), ethical principles (United Nations Global Compact) but also environmental issues (ISO 14 001), when they do not take “organizations” as a whole as their focus of standardization for CSR (ISO 26 000) (Tamm-Hallström, 2008). However, CSR and governance standardization processes are not bounded to global or transnational processes, they also emerge at the industrial level through the production of dedicated codes of conducts and standards (King and Lenox, 2000), and at the national level— with initiatives from government to regulate the sphere of CSR—as for instance the French law on New Economic Regulation from 2001 (Berthoin-Antal and Sobczak, 2007). Similarly to pressures leading to social changes through CSR (Aguilera et al., 2007), processes of CSR standardization have multiple origins and are deployed across the 8 transnational / global levels, inter-organizational / industrial levels and organizational or intraorganizational levels. The proliferation of CSR standards across levels of analysis creates issues and threats that correspond to gaps in our knowledge of CSR standardization dynamics. A first concern relies to the multiplicity of potential contradictory demands from a wide range of CSR standards and how organizations cope with potentially contradictory demands as expressed through CSR standards (Gilbert et al., 2011). This issue is of a special importance for standardizing organizations that have to catch-up with the standardizing efforts deployed across levels in order to maintain both their legitimacy and technical relevancy. A second issue relates to the competitive dynamics that surrounds the production of CSR standards from a certain type. Prior studies have mainly focused on successful standards (e.g., Déjean et al., 2004; Etzion and Ferraro, 2010) neglecting the competitive dynamics inherent to fields within which multiple CSR standards co-exist. As a result the field-level dynamics of CSR standard production remained under-studied. A third concern relates to the cross-levels relationship across standards and the problem of standards inter-operability. Although Acquier and Aggeri (2007) suggest that these dimensions may be central to the success of standardizing processes in the CSR domain in allowing the co-construction of standards’ legitimacy and technical feasibility, the relationship between distinct processes of CSR standardization has been so far overlooked. In this paper, we start focus on these three blind spots of the CSR standardization dynamics by focusing on the following research questions: Research Question 1: How are CSR standardization dynamics structured within macro (transnational), meso (inter-organizational) and micro (intraorganizational) levels? Research Question 2: How do CSR standardization dynamics interplay across the macro (transnational), meso (inter-organizational) and micro (intraorganizational) levels? 9 To address these questions, we focus on the case of ESG rating agencies that have emerged over the last 20 years as an important category of players in the growing field of CSR and have structured the development of the responsible industry in several countries. METHOD AND DATA Research Design Although quantitative analyses are commonly used to conduct multilevel analysis, qualitative studies may also be appropriate to uncover overlooked bridges across levels of analysis (Chan, 1998; Hitt et al., 2007). In the context of this research, our main level of analysis is the organizational field of ESG rating agencies. This field encompasses the agencies themselves as well as all their stakeholders such as their customers (investors who buy their ratings or analysis), corporations that provide them with data, experts who help them defining their methods (Igalens and Gond, 2005). Because of the nature of their activities, these agencies are directly or indirectly affected related to broader macro and transnational field of CSR standardization that produce new CSR standards such as reporting standards (e.g., GRI) or standards for managing CSR processes. Analyzing the functioning of these agencies also allows uncovering the micro-dynamics that structure their internal processes of standard production in relation to their stakeholders that will constitute the micro level of analysis in the context of this empirical research. Because our main research interest lies in the functioning of ESG rating as a field, we adopted a multi-case study research design (Eisenhardt, 1989; Yin, 2003). Relying on evidence from multiple cases allows for triangulating data, a process that enhances qualitative analyses validity and robustness (Yin, 2003). The cases have been sampled theoretically based on two main criteria. The first criterion is the historical significance of these agencies in the ESG field and in their institutional context. Several cases pioneered the activity of ESG 10 rating in their country context—KLD in the US, Eiris in the UK, Arese/Vigeo in France—and has a significant influence on the development of the RI field. These second criterion consisted in maximizing the diversity of ESG agencies functioning (Eisenhardt and Graebner, 2007), so that we can evaluate differences in how they react and are influenced by the macro and micro levels dynamics. We focused on six ESG rating agencies that are representative of the diversity of approaches to ESG rating in the USA and Europe (KLD, Eiris, Vigeo, BMJ-Ratings, SAM, Innovest). These agencies have distinctive features in terms of universe of companies rated, information collection methods, methodologies for data analysis and processing, criteria of evaluation. The importance which agencies give to different services within their offer indicates differently their activity: rating agency (Vigeo, BMJ Ratings), research organization (KLD, Innovest, Eiris), asset management company (SAM). Their juridical status varies from the non-profit association to the limited company passing by research institute and fund manager. Also, the research undertaken by these agencies is addressed to several clients such as investors, companies, associations, communities, regions, governments etc. We hold that the variety of stakeholders to whom the research is addressed as well as the origins of these agencies give birth to different strategic positions and often explain the criteria used in the analyses. Table 1 provides a brief description of each agency along a set of criteria. ---------------------------------------------INSERT TABLE 1 ABOUT HERE ---------------------------------------------The case studies can provide intricate details and understanding when “how” and “why” questions are being posed and are suitable to explore uncovered empirical relationships (Yin, 2003). Also Lee (1999: 43) argues that qualitative research is appropriate when contextualization, vivid description under study is important. Contextualization is central tour inquiry as we aim at clarifying the “embeddedness” (Granovetter, 1985) of individual ESG 11 agencies micro-level dynamics within the ESG rating field, as well as the embeddedness of this field within the broader macro context of CSR standardization. Data collection Interviews. To capture the view point of a variety of stakeholders in the ESG rating field that constitutes our main unit of analysis, we adopted a multi-perspective approach by interviewing three categories of informants: key individuals of ESG rating agencies, SRI experts, and CSR managers of international companies rated agencies. Our interview grid includes questions that covered topics related to the micro-dynamics (methodological changes and factors driving the analysis of new ESG issues) as well as macro-dynamics (influence and role of macro CSR standards on their practice). In so doing, we could explore the interplay across levels of analysis, even though our core empirical lens was the ESG rating field. Given the purpose of our study, we focused on informants who could provide us with evidence in regard to the methodological developments and the strategy and history of the organization. We therefore interviewees members of CSR rating agencies who occupied high level positions, such as (co-)founders of rating agencies and Responsible Investment indexes, CEOs and vice-presidents, directors of methodology, directors of research, heads of SRI development and senior RI Analysts. In addition, we also interviewed former staff of these agencies to capture the dynamics of field changes when the agencies were being created. Further, the interviews with RI experts and CSR managers of companies helped us to clarify some aspects of the interplay between the ESG rating field (meso level), CSR standardization (macro level). In addition, this second category of interviewees could help identify and/or validate field-level perceptions of key differences among individual rating agencies (micro level). Table 2 presents the profile of the interviewees who were chosen following this sampling process. All the interviews were taped and transcribed. ---------------------------------------------INSERT TABLE 2 ABOUT HERE 12 ---------------------------------------------Secondary data. The factuality of the first-hand information obtained from the interviews was verified and complemented with secondary data from a variety of sources. First, we collected press articles, the data provided in official websites of these ESG rating agencies, as well as prior reports on this field, such as the “Rate the Raters report”, the report produced by Novethic reports, or the Guide to Sustainability Analysis Organizations, published by ORSE/ADEME in 2007. Second, we consulted prior academic studies of the ESG or Responsible Investment fields in the different national or institutional contexts under study (e.g., Arjaliès, 2010; Déjean et al., 2004, 2012; Giamporcaro, 2006; Gond, 2006; Pénalva, 2010; Igalens and Gond, 2005; Vogel, 2005). These two sources of secondary data helped to illuminate the dynamics of multilevel standardization over time, opening the room for analyzing respective reasons of that dynamics and the interplay across the levels. Data analysis Our analysis combined several techniques to make sense of the process data we collected and to build an understanding of the ESG field dynamics in relation to CSR standardization and intra-organizational micro-dynamics (Miles and Huberman, 1994; Langley, 1999). In a first stage of data analysis we focused the key tensions that structured the process of standard construction by each agency (micro level), within the ESG field (meso level) and at the broader level of CSR standardization (macro level). Building on these findings, we could identify a core tension that explained of the process of standard development and competition. The description of each tension provides the basis of our firstorder findings. A second stage of data analysis consisted in re-analyzing our data by considering explicitly the interactions between the three tensions we identified. This stage allowed us to uncover how technical and legitimacy dimensions were intertwined in the interplay of the 13 three levels of standardization. The outcome of this second, higher order level of coding constitutes our second-order findings. For both stages of data analysis, we used the qualitative analysis software QSR NVivo® as a tool to assist with the coding process and to identify the structuring tensions in the ESG rating field. Codes and sub-codes were created with some later refinements as the new important issues emerged. This software is useful particularly as it allows retrieving the properties of each coding category (nodes) in the process of comparing the a-priori construct definition with the empirical data. Secondly it gives immediate access from the coded text to the full interview transcript allowing the researcher to go back and forth, to ensure the data is always kept in context (Miles and Huberman, 1994). FIRST-ORDER FINDINGS: STRUCTURING TENSIONS ACROSS STANDARDIZATION PROCESSES IN THE ESG FIELD Macro level dynamics: The Global-Local Tension in CSR Standardization Governments and intergovernmental organisations are fostering CSR and ensuring corporate accountability by launching several standards, laws and regulations on this topic at both national and international levels (Gilbert et al., 2011; Waddock, 2008). Since then they are actively fulfilling different functions in the dynamics of CSR standardization. First, the macro-level, standards act as macro contracts and provide repertoires of norms that define what organizations are responsible Gilbert and Rasche (2007). Standardized ethics initiatives such as the UN Global Compact, SA 8000, GRI and the ISO 26000 are regarded as promising approaches that complement efforts by legislation to better address social and environmental issues. Second, they help to standardize the information disclosed by corporations. Third, standards refine the methodology of ratings agencies and the way they assess the CSR. Scalet and Kelly (2009) suggest that either market will decide which of these agencies becomes the standard or calls a need to press for more uniformity through global standards. However, by creating homogeneity in the field standards make the competition more severe at 14 CSR rating field level as now the agencies need to find sources of differentiation in their marketing strategy, discourse and other aspects in order to convince clients in their uniqueness. At macro level we identified the tension of global vs national standardization processes. Global standards more commonly refer to UN declaration and conventions, EU Council directives and decisions, OECD guidelines, ISO26000, ILO convention and other recognized texts published mainly by intergovernmental organisations. In terms of reporting, the GRI remains the breakthrough standard that agencies would refer to when replying to consultations on reporting in international integrated reporting communities and platform. The standards come from different areas, but constitute altogether a global infrastructure. Although globalization have massively shaped the field of CSR these global regulations have never been a major driver for CSR rating agencies having more international scale, because they are dealing with multinational companies operating in many countries. This in its turn makes impossible to keep an overview on the regulative state of all those countries. As none of the international standards, codes and guidelines are mandatory (Cuesta Gonzalez and Valor Martinez, 2004), none of them include enforcement mechanisms, which allow CSR rating agencies a room for flexibility in adapting their business strategy to these standards. The initiatives carried out under the Global Compact reflect that the UN has opted for a facilitative rather than an enforcement role (Whitehouse, 2003) and it faces great difficulties in convincing some developing countries that the standard is not ‘‘meddling or paternalistic’’ and that it may help to attract foreign direct investment (Aaronson and Reeves, 2002). Likewise, OECD guidelines apply only to OECD countries and it is not clear how nonOECD Members could apply this standard, which is seen as an important limitation (Aaronson and Reeves, 2002). It has also been argued that codes may not respond to actual 15 societal demands (Leighton et al., 2002). Thus, the research and ranking methodology of agencies have also to reflect emergent CSR topics embedded in local laws and regulations. “We certainly integrated the main principles of OECD, ILO norms and some ISO9001 and ISO14001 principles in our model. It doesn’t mean that we wanted to have a global product, but we needed to cover all the big international CSR principles. Given that we operate only in France and the high application of ISO norms we had to integrate that as well. In line with labels, council, laws of Grenelle and all the events which take place in France we adapt our methodology” (Responsible of Finance, banks, high educational institutions and insurance sectors, assocation and foundations) Meanwhile if the CSR rating agency focuses too much on local regulations, there is a risk that the method will become idiosyncratic and it can’t meet clients’ increasing expectations. When investors asked Arèse (Vigeo nowadays) to provide them with the same environmental data for European universe as for France, this caused a big problem. In France Arèse was getting unique environmental data from Ministry of Environment which was not available in other European countries. Thus they were not able to deliver identical data for other countries and had to find another way to assess that information. Both local and global standards provide support in terms of technical aspects and legitimacy. Technical dimension of standards help CSR ratings agencies to assess what should be assessed. It refers to the measurability and calculability of issues which are suggested in national and international standards. Partnerships between CSR rating agencies and established institutions and standard setters such as OECD, UNEP, ISO is a sign of legitimacy, which give agencies an international exposure and add credibility to their ranking. Partnerships between CSR rating agencies and established institutions and standard setters such as OECD, UNEP, ISO are another sign of legitimacy, which give agencies an international exposure and add credibility to their ranking. One strategy to balance the tensions is to have a minimum level standard. However, this can compromise the legitimacy of the applied criteria as it will be perceived as too week by some stakeholders of the field. Another strategy is to integrate and apply all the best norms 16 with the risk that companies might not be able to understand it and respond the questionnaires. When rating a company CSR rating agencies first make sure to comply with national government reporting requirements and industry specific texts. The advanced integration of sustainable development in EU regulatory approach to environment and society resulted the initiation of several national legislations making sustainability reporting compulsory for some companies in certain cases (Delbard, 2008). In Denmark, the parliament has adopted Green Accounts Act (1995) which calls companies to be more active and sensible for the environment protection by obliging them to publish environmental report. This report should cover information about company emissions, the link between different policies and environmental objectives, concrete achieved results, consumption of natural resources etc. Two years after the parliament of Netherlands revised the law on environmental management by introducing a new article on environmental reporting. Finally in 2001, the French government generated the law relative to the New Economic Regulations (NER). The article 116 of the law compels listed companies to disclose social and environmental data in their annual reports. Similar initiatives were seen in Belgium (Social Statement, 1996), Sweden (1991 Code of the Environment.), Germany (Bilanzrechtsreformgesetz, 2004) for certain categories of companies, depending on size or sector of activity. Mandatory reporting presents several advantages such as the creation of standardized and comparable measures that enable benchmarking and best practices (Hess, 2007; Hess and Dunfee, 2007). Figure 1 reflects the main cross reference list of national and international regulations and guidelines used by CSR rating agencies. ---------------------------------------------INSERT FIGURE 1 ABOUT HERE ---------------------------------------------- 17 Meso level Dynamics: The Homogenization-Differentiation Tension in the ESG Rating Agencies Competition In this part we are looking at the inter-organizational dynamics and the processes whereby the ESG rating agencies field has been structured. Over the past decades ESG rating field moved from niche or side market into mainstream market of traditional asset managers, given their increase interest in SRI and the predominance of CSR concept in all domains. While credit rating is built on algorithms which is more or less the same, extra-financial notation is based on questionings which are heterogeneous. Unlike financial ratings extrafinancial notation is a field where new subjects emerge continuously. It also quantifies more subjective elements than financial notation and needs more time to be accepted in the market. ESG evaluation also takes into account the expectations which may appear under the form of weak signals that a good agency should be able to capture quickly. Those signals develop and become mainstream within the time. According to the study of Avetisyan and Ferrary (2012) the emergence and evolution of CSR rating agencies as new institutions result from the convergence of interest of different stakeholders of the CSR field. On one hand the appearance of CSR rating agencies and their further development is often seen as a part of the SRI movement, as initially those organizations mostly worked for socially responsible investors who were gradually cutting investment in companies engaged in sectors or practices considered irresponsible, and privileging the investments in companies respecting social and environmental issues as they saw that the economy based solely on speculation is not sustainable. In the context of their limited capacity for handling viable information on companies’ CSP, the ranking of the firm by a specialized agency that lies at the center of an issue based field can help investors to select the most ethical or responsible companies for their portfolio. On the other hand multinational companies were often being accused of having conflicts concerning human 18 rights and environmental issues with their operations in developing countries. They needed a special tool to assess their social and environmental performance, with the objective of improving their actions in CSR and enhancing the reputation in the eyes of investors and the public at large (Avetisyan and Ferrary, 2012). Obviously rating agencies contributed to make companies more aware of their responsibilities, and influenced the way companies were reporting on the sustainability. The influence was more visible on the medium level CSR engaged companies as well on the laggard companies that could benefit from a structured approach to sustainability. Since the beginning of the millennium companies have started to valorize this notation as they saw the advantage of providing ESG information. Given the evolution of CSR regulation which obliged companies in certain countries to report about their environmental and social impacts, they transformed the constraint of being rated into an opportunity to communicate their results to different stakeholders. Avetisyan and Hockerts (2012) state that CSR rating agencies provide ranking services, corporate research, compliance and consulting services analogous to those provided by financial research service firms with a focus on ESG criteria based on the analysis of public documents; company’s financial, environmental, social, sustainability reports; specific questionnaires; meetings with the heads of companies and other information sources (e.g. governmental databases, press releases). Thus, in terms of functionality they transfer and translate global social and environmental concerns into a language which is understandable by investors, corporation and other interested stakeholders. This is a form of standardization as they make those concerns measurable, calculable/quantifiable. They can fill standardization functions of process management and contribute, to insure management companies the acquisition of a cognitive legitimacy (Scott, 1991, Meyer and Scott, 1977). Many rating agencies started as a background as an NGO or foundation with a clear social mission to review the companies on ethical and social criteria and also norms. The 19 majority of the research undertaken tended in the UK, North America and even in some European agencies was focused on people often with faith based views or who had other values on labour, environment, human rights… wishing to see ‘sin’ companies excluded from their funds. Those were individuals investing mainly in very first retail mutual funds in the UK and Pax World in the US. There were people who were working for religious institutions, certain NGOs, charity companies for whom investing in such companies seems to be going against their values. So it was a quite normative and contractualist approach in the beginning with a vision of social responsibility, which was based on exclusion related to certain products or services. With regards to the negative screening they started more from an ethical point of view and went more to global normative view which was summarized for companies in UN Global Compact. This was a clear tendency on alcohol, tobacco, and all the sin sectors to the international agreed values and norms. Agencies worked together with asset managers that were committed to social and ethical screening. An example of a player that remains in that tradition is Eiris, which is still a foundation and still has clear ethical roots. Very soon, following market demand which changed from ethical screening, negative screening to positive screening these early funds began to also look for more positive responding to the challenges of the day. This positioning is illustrated by SAM which is selling the research with a “best in class” approach. Vigeo in France and Oekom in Germany also took this approach. The majority of agencies decided to add more industry specific approach and was looking more on the materiality of the criteria. With this respect they would privilege site visits from sending the questionnaires. “When we started our approach was ‘with SRI information we have additional information which allow us to take better involved investment decision compared to others’. In the beginning it was efficient to check whether they had environmental reporting or SRI reporting or responsible people, whether a company was just monitoring performance by mental issues according to environmental criteria. However, it all changed. The focus was more on the criteria that had a strategic impact and on certain issues like ‘what does climate change mean for the automotive industry, or what does transparence mean for evaluation 20 service industry, or what is a good corporate governance. This was the case with SAM”. (Cofounder of DJSI, SAM) The initial funds were also soon concerned about broader issues and were engaged to see change about pollution, corporate involvement, environment etc. The pension funds and other asset owners recognized that there were elements of risk management in strategy. More advanced CSR rating agencies began to focus efforts on understanding how they can respond to risk that their clients faced- climate change, water, biodiversity, bribery, labour etc. Another clear trend of this period was the move from broad based ESG rating agencies covering all potential issues to rating agencies with more specific topics. As such TruCost is fully focused on environmental data, and RepRisk on reputational risk. Meanwhile the focus was more on the strategic impact and on certain issues such as ‘what does climate change mean for the automotive industry’ or ‘what good corporate governance is’. The governance domain also came to be a separate angle for ESG assessment after Enron scandal. “Before the year 2000 the questions were more focused on environment and social dimensions. Over the last ten years there are a lot of questions on governance and on the application of Global Compact principle.” (Chief Sustainability Officer, Essilor International) Meanwhile, the environmental criteria became more quantified over time, which drove materiality with regard to environmental issues. In the beginning of the years 2000, KLD was very environmentally oriented as it was trying to conform to Stockholm conference constraints: economy and environment against economy or environment. Within time ESG ratings became more data oriented and standardized in terms of provided information to asset managers. That’s partly because data got better, more companies produced data, but also Asset Managers require information in such forms that can be easily digestible. It can be in a form of scores or some kind of quantitative figure, where they can adjust portfolios and framework with regard to sustainable information. Some agencies provide more sophisticated 21 research and try to dig deeper and have more interactions with companies, rather than relying solely on publicly available data. “We were designing our very own KPIs that were based on highly intuitive research that was coming out of the people who had a deep semi-conducting industry background. I was pulling this people and guiding them to understand where we were doing critical thinking. We call that sustainability because we were saying we were going to predict stock drops. We were doing short pictures and we have designed very esoteric model using Forensic accounting technology, using screens to identify issues. It was very sophisticated. You have to remember that BP looked great on paper according to the SRI industry experts. Most of the SRI industry except for the Innovest had rated BP at the AAA at that the time of the accident. We did not. We were putting out notes to our clients warning them of the dangers associated with this company”. The core tension that contributes to shape standardization dynamics at meso level is a tension between imitation and differentiation. This tension is well theorized by Deephouse (1999) who developed an integrative theory of strategic balance that syntheses the contradictory insights from the resource based view and institutional theory by considering both the need for differentiation and the need for conformity. How do CSR rating agencies find a position in a field? How does each agency face trade-offs between imitation and differentiation and strike the strategic balance between these two tensions? Hereunder, we address these tensions deriving from our data from firm-level findings. An abiding question that stands in organization research is what makes organizations similar to each other. Organizations need a societal mandate or legitimacy, to operate and this is gained by conforming to societal expectations, because to violate them would make the organization illegitimate (Meyer and Rowan, 1977). As a result, organizations often act in ways that are not necessarily ‘rational’ but are consistent with the ‘rules, norms and ideologies of the wider society’ (Meyer and Rowan, 1983:84), preferring not to suffer penalty for noncompliance. Moreover, the more organizations conform to these myths the more deeply institutionalized they become. By being the same, a firm benefits, because it is recognized as legitimate, ceteris paribus (DiMaggio and Powell, 1983; Meyer and Rowan, 1977; Pfeffer and Salanchik 1977). Thus a certain level of homogenization of evaluation methodology of CSR 22 rating agencies is a sign of the seriousness, properness and robustness of the conducted research. A CSR rating agency which is similar to other CSR rating agencies avoids legitimacy challenge that hinders resource acquisitions, ceteris paribus (Deephouse, 1990). At the meso level, copying/imitating methodologies partially or entirely can be seen as a sign of a standardization of CSR evaluation. Although agencies have several partnerships between each other all the agencies of our study were seeing others copying their methodology. By accepting that copying evaluation methodology from one agency to another destroys completely copyright instant, Eiris considers copying elements of their methodology also as sign of their credibility within the field. Likewise, Vigeo considers this issue not as a threat but as a consecration of their choices and recognition of the relevance of their methodology as a standard for ESG assessment. “Of course we have seen others copying our methodology. Meanwhile, we are glad as our ambition since the beginning was to promote a standard. Our approach of CSR definition and our topics of evaluation are largely diffused. It’s very important and we need to lead to a standard”. (Director of Methodology and Institutional Relations, Vigeo) “Everybody was copying us. Everybody is still copying us. Now when I read ratings products from other rating agencies - it’s all the same thing just in different ways. What makes me mad is that they try to be the same but it’s very poorly done, not analytical, not sophisticated”. (Former Director of Research, Innovest) DiMaggio and Powell (1983:150-154) proposed that organizations become increasingly similar, because institutionalized ideas pressure them to adopt similar structures and forms. They explained processes of homogenization and institutionalization by three mechanisms of isomorphic institutional change: coercive, mimetic and normative pressures. Coercive occurs when a powerful organization such as state imposes rules and practices on organization, mimetic arises from uncertainty and normative occurs from a moral duty. Thus, the institutions of each country or region are the forces that put pressure on firms to adopt similar CSR constructions to those adopted by other societies in the same context (Boxenbaum, 2006). When this concept is extended into the field of CSR ratings, the national and 23 international regulations as well as stakeholders’ expectations can push agencies to adopt similar ranking methodologies. Besides, the degree of the overall homogeneity of the method and the compliance to certain CSR norms help rating agencies to be perceived as legitimate actors of emerging field where the widespread of new practices may be problematic. However, Scott (2008: 160) states that although all organizations within a given institutional field or sector are subjected to the effects of institutional processes within the context, all do not experience them in the same way or respond in the same manner. Differences in methodologies do exist because of the function that CSR has within different societies. This variety of indices and rating agencies also responds to national specificities, social and statutory practices (for each country or region having adapted socially responsible investment). Independently from cultural influences, the importance and weightings of criteria reflect the conception of social responsibility of each ranking organism, the way they represent “good” social and environmental performance of a domain. It is possible that differences in ratings are due to raters’ strategic choices to satisfy the demands of their different stakeholders. For example, when social raters use screens against tobacco or other categories of firms, that screen is useful to investors who wish to avoid profits from these sectors. “All the rating agencies started from the same background. They are using international standards such as GC, ILO, universal declaration of human rights, other conventions of EC of OECD etc. to develop rating models. Then of course models are different, because some rating agencies are interested in environment, others in corporate governance. Even if the rating models are similar the outputs are quite different on the base of what you want to produce”. (SRI Analyst, Vigeo) Meanwhile, CSR rating agencies need to be distinctive to be attractive and able to sell their products. While conforming to the strategies of others limits the performance of the firm and increases failure rates (Baum and Singh, 1994; Hannan et al., 1990), rational differentiation reduces competition and increases performance (Deephouse, 1999). The social rating varies significantly from one agency to another, according to universe of analyses 24 (which is formed in five ways: traditional stock index, geographical area, business sector, innovative companies in a very precise domain, products or brands of regular consumption in a particular geographical zone), information collect methods (positive and negative screening) and sources (company, stakeholders and third part observers), methodologies of analysis, the criteria of evaluation which characterize the processes of companies’ ranking. According to the Guide of Sustainability Organizations although all rating agencies try to measure the CSP the importance which agencies give to this or that service within their offer indicate differently its activity: rating agency (Vigeo), Research institute (EIRIS, ODE), Consulting agency (PIRC), Asset Manager (SAM). Thus the juridical status of sustainability rating agencies varies from the non-profit association to the limited company passing by research institute and fund manager. It can impact the activity of the agency, which can change its status during the history. The guide of Sustainability Analysis Organizations suggests three “cultures of origin” while leaving this list open: associative environment, religious foundation, financial environment. Here it is important to retain that these various origins give birth to different positions and they often explain the criteria used in the analyses. Innovest was expressing data with financial denominators making them the most relevant possible. They were helping portfolio managers even to understand how they contributed to alpha. Once Innovest started using this language and doing ratings that almost sounded as regular financial analysis they started having big contracts covering all Blue Chip clients. “We didn’t care whether a company had a policy on anything. In fact I never looked at CSR reports, ever. We ignored them. That is a giant difference. Companies can go crazy making their beautiful CSR reports, we never used them. None of our analyses was based on any reporting.. Dow is an A+ complaint GRI company. That tells you everything”. (Former director of Research, Innovest) The financial pressure which is applied on a limited company entails very different conditions of action as compared to non-profit association. “Eiris is owned by the Eiris foundation. So it’s wholly owned by not for profit charitable organization. We operate there as a social enterprise. That gives a big degree of 25 independence, objectivity which is important and we do not provide ratings directly to companies. We think it is inappropriate”. (Head of SRI Development; Eiris) While other agencies were opening offices in different countries Eiris had a distinguishing strategy of setting a network of local partners. Those partners of Eiris Global Platform were providing them with data, expertise and insights on the local area. Another distinguishing factor is their recent partnerships with groups in developing countries. SAM is looking on sustainability from business perspective, trying to see how sustainability adds value to companies having an investor perspective. SAM has the entire value chain of sustainability investing, while most of the competitors are just focused on one or two aspect of this value chain. Besides they get data directly from companies. They are able to ask questions and get insights that are a bit beyond what can be found in public sources. “In the last 10 years SAM has seen actions to develop ESG criteria more connected to the financial performance, where there is a link between extra-financial criteria and more traditional business performance metrics. So we developed in the past 5 years several new criteria such as innovation management in order to understand how well companies are managing innovation processes within their companies. SAM tries to move behind the standard metrics that you find in sustainability reports. Our approach is not ethical. We are not choosing companies because they are better or worse from a moral perspective. We are trying to choose companies that are better or worse in terms of management practices and the ability to succeed in a long term”. (Head of Sustainability Application and Operations, SAM) Applying integrated and managerial approach of social responsibility which consists in questioning the degree of integration in the strategy and in the system of company management, Vigeo broke the traditional approach of ranking with exclusion criteria. Vigeo has evaluated the degree of integration of a number of subjects for a new referential which included other domains-human rights. They were the first agency to evaluate the degree of corporate commitment toward the integration of the respect of human rights in their strategy and activities. 26 The main distinctive feature of BMJRatings is that this agency is the only one purely focused only on solicitated notation, which also assumes suggestions and recommendations behind the rating. It is also the only CSR rating company to have a matrix model, which is stable since the beginning. What has changed is the interior of the palette: the themes have enriched and shaped and enriched by current national, European and international trends and the weightings have been adapted accordingly. The philosophy of main research themes is close to Vigeo. “Globally we have the same domain of evaluation as Vigeo. The difference lies in the approach. We have decided to have exclusive positioning in solicitated notation requested by companies and organizations. This is the main difference. Then we are also different in our philosophy and way of information treatment. We are more business oriented, less moralistic, les militant than Vigeo. Thus the criteria, the question lines are the same, but the angle of attack is different”. (Responsible of Construction Sector; BMJ ratings) “It uses managerial model and not that of compliance, as used by most of the agencies. This ex-ante managerial analysis model puts the human intelligence at the center of the company and not in compliance. They analyze the conditions of CSR policy realizations and not the results. The huge advantage of the matrix model lies in its ability to be split as Russian dolls. Each column can be split infinite and consolidated. Inside the box, the color (major, medium and low) is a conceptual equation which is the level stakeholder expectation on the issue raised multiplied by the room of manoeuvre (marge de manoeuvre) of the company. The matrix enables to take into account all the specificities”. (Founder and former CEO, BMJ Ratings) Micro level Dynamics: The Tailoring-Industrialization Tension in the Search for a Sustainable Business Model Tensions at micro-level are tailoring vs. industrialization. The more agency practices tailoring by applying customized method for each client (or group of clients) the more costly it is in terms of Human Resource. This technical business model constraint obliges CSR rating agencies to recruit knowledgeable analysts of high level. Because of the high level competition (which contributed to structure the field) CSR rating agencies conducted more sophisticated research and grouped set of mainstream clients who would need this information in order to construct other portfolios. As a consequence more and more rating agencies 27 showed tailoring ability by offering customized products and highly adapting their models into clients’ specific needs. “Maybe we didn’t have the best business model or maybe we had this dysfunctionality where we were constantly customizing what we were doing for different clients and it was a mess. It was a mess, but it was a good mess. We were really trying to think hard about what we were doing and whether we were really being predictive of something”. (Former director of Research, Innovest) “We have this B-Product that is very adapted to investors’ specific needs. We try to have something flexible that can fit each of our investors, but then we have also some standards to respect. It’s difficult to undertake analysis on special criteria, because it cost resources, time, analysts, and is very specific”. (Client Relationship Manager, Eiris) “SAM is different in that we are an Asset Manager and it allowed to both have more customized methodology because it’s the methodology we are developing, we are not buying data from the outside and we were able to move beyond generic Key Performance indicators and develop leading edge advanced and customized criteria. We are just using the information in the asset management process and in the assessment for the DJSI conducts. We don’t sell the information or the data itself, we don’t sell the KPIs. That’s pretty big difference between us and other rating agencies”. Christopher Greenwald (Head of Sustainability Application and Operations, SAM) Given the weakness of the business model, CSR rating agencies need to use the same methodologies for all clients to realize economies of scale. There is a need to have a sustainable model which can be achieved only if analysts work on the method which is stabilized. Another way of achieving a sustainable model and securing financial resources is the expansion of the scope of the activity. CSR rating agencies have actively expanded their activity by diversifying offered products and services and adapting existing products to new markets. They started to cover not only listed and non-listed companies but also public administrations (cities, districts, regions and states), financial institutions, higher education institutions, foundations, and associations. Although the main priority of agencies is to provide information to investors there has been an evolution in providing sectoral and thematic research, trainings, audit, contribution to sustainability reports and other services to companies. This massively helped rating agencies to secure the resources. The sectoral approach helps to reveal and to take into account specificities and challenges of each sector, which are different, at once because of the scope of activity of a company (subsidiaries and suppliers in foreign, emergent countries) and its nature. Finally in the last 6 years the industry of ESG ratings has witnessed an important number of both cross-border and within-border consolidations as ESG data providers were on the edge struggling to remain profitable and to 28 offer good quality research. As stated in the paper of Avetisyan and Hockerts (2012), the business model for ESG rating agencies is very weak and that makes very difficult generating revenues. They describe the main types of consolidations: Regional extension and ESG market entry strategy. The first type happens when two or more ESG rating agencies decide to joint their forces. When Vigeo bought Stock at Stake in Belgium and Avanzi in Italy the group has increased its coverage and made a stronger presence in European ESG market. The ESG Market entry strategy by bundling of services was when large index providers such as MSCI, Bloomberg, Thomson and Reuters acquired rating agencies or launched their own ESG indexes to meet client requirements who wanted complete information about companies’ financial and extra-financial performance. Economies of scale, support from acquiring firm, cost delocalization and financial stability were seen as the main drivers of consolidation. From client side motivations observed were the standardization of the field, building reputation of a global market leader and synergies with the acquiring parent. This consolidation has carried both positive and negative aspects (e.g. quality loss and price war, motivation decrease and price war etc.) for each side of industry players (Avetisyan and Hockerts, 2012). 2. SECOND ORDER FINDINGS: HOW INTERACTIONS ACROSS LEVELS OF CSR STANDARDIZATION SHAPE THE DYNAMICS OF ESG RATING AGENCIES STANDARDIZATION 2.1. How Macro level Dynamics Influence Meso and Micro level Dynamics The basics of Unites Nations (UN) Global Compact, OECD guidelines, ISO26000, European Union (EU) and industry specific initiatives, local laws and regulations appeared to be the inspiration for creating the methodologies of ESG rating agencies. Depending on the given research they would make reference to EMAS, PRI, Greenhouse Gas Protocol, ISO14000 and 9001 families, supply chain issues, the standard for Carbon Disclosure, ILO convention on labor issues, diversity conventions. “I think it’s important to ground the research in internationally recognized standards for investors as a benchmark of quality of issues which are measured, as being completely independent would be both unrealistic and unhelpful”. (Head of SRI Development; Eiris) “Yes we certainly look at them and refer to them, but it depends on the topic. It’s certainly important the certification questions and ILO for labour practice, other indications, the GRI to just keep track of what is going reported publically or what the companies are being asked to report publically. Those are important as inputs”. (Head of Sustainability Application and Operations, SAM) 29 Some clients of rating agencies would even ask rating agencies to provide them with full list of cross references before any engagement with them. Given the high recognition of some CSR related standards by field actors of meso level, new types of CSR rating agencies were created to measure companies’ compliance with those standards. They are specialized in norm-based screening which enables them to distinguish for investors the companies which violate international standards. In Norway Investment Services ESG rating agency ranks companies violation of international standards (e.g. The Global Compact, the universal declaration of human rights or ILO standards). Similarly, Ethix reveals company’s violation of human resources based on ILO standards. For the most of the rating agencies those standards are not considered being at the heart of their methodology but rather elements which help to enrich and refine it regularly. “Our Human Right evaluation domain was reviewed by adding some new criteria to fit Ruggie’s Guiding Principles on Business and Human Rights issued in 2011”. (Client Relationship Manager, Eiris) “We certainly referred to ISO26000 norms. There have been several evolutions in our frame of referential from the last year in line with ISO26000. We integrated a new criterion on promoting CSR in the sphere of influence, which is a concept of IS026000 concerning to all actors with whom company interacts and over whom it has an influence. We also referred to GRI as these initiatives are very concrete”. (SRI Analyst, Ethifinance) “We definitely look at regulations. In chemical sector when we saw that REACH regulations were starting out in Europe we assessed companies’ reaction to implementation of these regulations. We certainly use GRI research but if it didn’t exist we wouldn’t change what we were doing ourselves, because we do our research as well.” (Executive Director and Head of Product Development of ESG Research, MSCI; former president and co-founder of Innovest) However, in some domains of their research methodologies agencies claim to go beyond national and international regulations and to get deeper insights in specific themes. “Our frame of reference is more precise than ISO 26000, which has lighter insights in hundreds of themes as seen in our referential. You will find all the issues covered by ISO 26000 in our frame of reference. There is no single theme in IS0 26000 which we won’t treat. It is rather the opposite and it’s normal”. (Responsible of Collectivities and cooperations sectors; BMJ ratings) 30 Following the appearance of ISO26000, BMJ Ratings did not change its methodology to include Human Rights as a new domain (as it was presented in ISO26000), but made sure to fully cover this topic in other domains of its methodology. If in the beginning BMJ would look more on the challenges of the company and its stakeholders from management point of view, now the priority is to start with the synthesis of industry specific regulations and local government reporting requirements. Eiris uses several specific standards as it has in-house product- convention bunch which basically analyses the extent to which companies are being allegative in bridging international norms. This product is used by several Nordic-Canadian and other pension funds who draw on this recognized approach because of its link to international norms. All French rating agencies have reviewed their methodology to comply with NER norms as most of their clients are French, despite their international vocation. French CSR rating agencies pay more attention to diversity issues, due to two recent laws on diversity. The first decree obliges French listed companies to have agreements and commitments in terms of employment of seniors and disabled persons. The second law dated January 2011 includes obligations on more balanced gender representation on the boards of directors or supervisory boards. “Now companies in France are obliged to have agreements and commitments in terms of employment of seniors and disables people, diversity in terms of more balanced gender representation. We ask our (even international) companies to position towards these issues. We assess whether the companies have at least analyzed these issues and position themselves effectively (the way we assess French companies): with action plans and objectives”. (SRI Analyst, Ethifinance) 2.2. How Meso level Dynamics Influence the Micro and Macro level Dynamics Regular interactions between meso-micro levels have resulted in materializing several social and environmental issues by integrating them in ESG assessment criteria. Although the core of the methodologies never changed, several improvements were constantly done in all domains. CSR rating agencies are regularly revising the overall methodology to include 31 current social and environmental concerns but also to meet the expectations of various stakeholders at meso level. “The particular feature of Vigeo lies in its shareholders’ structure, which includes trade unions, NGOs, companies, investors, pension funds, asset managers. We needed to have a definition of Social Responsibility and a measurement method which integrates the interests of all stakeholders. That's why we opted for an analytical model that is primarily based on the opposability of objectives and managerial questioning with a view towards measurement of two elements. We measure the level of company’s engagement in relation to its objectives. But that's not enough. If our clients were only NGOs or civil society we could stop here. But our clients are also investors. Thus we interpret the level of commitment which we measure by complementing with risk management level. So we have developed a method, which combines both measurement of engagement level and evaluation of risk control”. (Director of Methodology and Institutional Relations, Vigeo) For the majority of the agencies the ideas are often coming from internal research departments (in house data) complemented by insights from companies and other actors such as industry experts and leading think tanks, consulting groups and academia. “We changed our criteria constantly and that was important because otherwise we would still assess whether the company has the environmental reports or not. We needed to change very strongly the criteria from 1996 and that was the right thing. And how did we do it? We were talking with stakeholders; we were in discussions with experts. We integrated HR experts and I remember we closely cooperated with Boston consulting group on certain things. We also integrated corporate governance experts to improve corporate governance. We discussed with industry experts – what are the aspects of environmental issues within that industry. We also discussed with companies – how could we increase our criteria to make sure that we ask the right question. At the end of course we had the last vote, the last say, because we were responsible for everything. We had discussion with everyone”. (Co-founder of DJSI, SAM) “We have a fixed frame of referential for collectivities but we also have discussions with our clients. For example when assessing French Riviera region we knew we should discuss in details two issues: tourism and territory. How to take into consideration the issue of tourism in our referential? Should we include it in economic development and in relations with economic actors? Should we look at it in criteria where we assess the attractiveness of the territory? Or should we treat it as a separate criterion? Regarding the territory, on one hand the French Riviera region is very urbanized in coastal and Rhone sides with a pressure on natural resources. On the other hand a mountainous part is much less populated and sometimes needs public services etc. So can we integrate the specificity of the region either in existing criteria, or in formulating and defining criteria which will make visible the analyses that we do on these issue? I think we will have consensus that those are issues. They would probably suggest other issues and we would advance the discussions arguing which issues to take in the evaluation and which to neglect. Based on which issues we have kept we would make the offer and then we would discuss”. (Responsible of Collectivities and cooperations sectors; BMJ ratings) 32 Industry experts would judge how reasonable is the integration of the criterion, how realistic is it to measure and finally would advice whether a rating agency should rethink over it again. Also, when rating agencies are dealing with new topics they might be influenced by NGOs which are very knowledgeable on specific subjects. CSR rating agencies would sometimes validate the feedback given by Sustainable Development managers of companies on several topics such as responsible supply chain or supplier’s policy. Companies might also correct CSR rating agencies when they apply criteria non relevant for the activity of the company or put a company in a wrong industry. “X rating agency asked whether we have a policy on Nano technology, whereas we don’t use Nano particle. They also asked if we had a policy on follow up and respect of patients records, whereas ophthalmologists or opticians should take care of these records. For me the most exemplary agency is SAM, because they do satisfaction surveys on their information systems and the methodology itself. Moreover you are welcome to leave comments on certain number of issues. For me it’s really a good example of the agency which works with its stakeholders.” (Chief Sustainability Officer, Essilor International) As a result of the above mentioned systematic interactions with different stakeholders and their obvious influence, we found that from social perspectives the concepts of obesity, harassment, well-being at workplace, psychological risks have lately been treated as separate themes of assessment with higher weightings. About ten years ago these topics wouldn’t have any impact, but today they are seen as real social concerns. “Three years ago the topics such as psychological risk and well being at work were not a discussion subject. Now we treat these topics as priority both because this context became regulated and because of pressure from civil society due to stakeholder expectations”. (Responsible of Finance, banks, high educational institutions and insurance sectors, assocation and foundations; BMJ ratings) In the environmental dimension the topics such as water related risk, carbon gas and biodiversity were split up into much detailed parts and gained higher weightings. “The topic of biodiversity has slightly evolved. Although this theme exists since 2005, but the practices and good practices have evolved recently. Now, we would assess company’s efforts to adjust their independence towards biodiversity as a good practice (faire une comptabilisation d’indépendance à leur biodiversité comme bonne pratique qu’on va évaluer on peut le compter aujourd’hui)”. (Research and Development Responsible, BMJ Ratings) 33 “Today for listed companies the information on C02 emission indicators has become widespread. All companies provide this information. Likewise, the protection of biodiversity is as important from a normative point of view as reducing CO2 emissions. The same international texts have been adopted for two different subjects. However, as a result of current trends and economic interests companies and stakeholders are much interested in C02, rather than biodiversity issues. We, at Vigeo have reinforced the importance of biodiversity issues in our methodology” (Director of Methodology and Institutional Relations, Vigeo) Also, regarding the governance dimension one ESG rating agency started evaluating whether Board of Directors integrate the risk of Social Responsibility. The development of ESG criteria more connected to the financial performance, where there is a link between extra-financial criteria and more traditional business performance metrics has been seen within some rating agencies. Meanwhile, SAM introduced a couple of years ago new criteria on innovation. “We believe innovation is a key point for sustainability. It is a very difficult criterion to evaluate. We really tempted at the beginning with the methodology, we took it away because we thought we were not measuring the right issue. Then, few years ago, during our annual review we realized that it was time to put some effort and to focus on innovation again. The criteria have been improved in the last 2-3 years, because we needed to refine them better”. (Head of Sustainability Services, SAM) Finally the topic of lobbying which was neglected in early 2000s has become one of the main challenges of companies’ conflicts of interest evaluation at Vigeo. Similarly, Vigeo makes efforts to better interpret data on companies operation in tax heaven countries. “We are now studying the issue of tax haven countries and deciding how to evaluate this information which we collect anyway. For Vigeo putting money in tax haven countries is a way to take away resources from the country where the company operates, instead of creating and developing community value. This behavior should be assessed in a different way, where companies will report how they justify their presence. The grades will be given accordingly”. (SRI Analyst, Vigeo Milan) Although most of the agencies were including rather than excluding specific ESG criteria in their evaluation domains some issues on transparency in environmental communication, human rights in certain countries and sponsorship did not represent anymore key performance indicators. Once a specific social or environmental practice is applied by all the companies of the industry sector the criterion might lose it importance in weightings as it does not represent a reasonable risk anymore. 34 “There are different factors which affect the change of our methodology. On one side we look how companies answer our questions. If we see that we can’t discriminate them anymore because all the companies have reached what we are expecting then it’s time for us to change the criteria or to make the conditions tougher, stricter. On the other hand if no company has what we expect, it’s also may be a sign that we have to change something and that we have to decide whether it makes a sense to go a step back or how we can expect the company to go that far. The other reason is when we notice companies do not understand our question and we have too heterogeneous answers. Last but not least we have always tried to have a correlation between our criteria and financial performance. And if we see that our questions are not going into that direction than it’s also a reason for changes”. (Head of Sustainability Services, SAM) Instead of assessing whether a company does a sponsorship or not, a rating agency would rather be interested in evaluating its contribution to economic and social areas of implementation and commitment of controlling the social impacts of products and services. Innovest even had an internal materiality risk weighting system to determine how material new criterion would be. Meanwhile one agency is willing to provide overall default sustainability ratings, because of increasing demand from neutral ESG Responsible Investors to have an overall rating. Depending on client’s requirements CSR rating agencies can integrate specific criterion in their methodology as long as it represents a great value for the assessed entity. Moreover some criteria suggested by companies can permanently stay in the methodology. “A couple of years ago one of our clients asked to take in our methodology a specific criterion, which we didn’t find relevant at that moment. This year we have generalized this criterion for all the companies”. (SRI Analyst). 2.3. How Micro level Dynamics Influence the Meso and Macro level Dynamics According to the study of Avetisyan and Ferrary (2012) rating agencies contributed to make companies more aware of their responsibilities, and influenced the way some companies were reporting on the sustainability. These Authors suggest that this influence (at meso level) was more visible on the medium level CSR engaged companies as well on the laggard companies that could benefit from a structured approach to sustainability. Since the beginning of the millennium companies have started to valorize this notation as they saw the 35 advantage of providing ESG information. Given the evolution of CSR regulation which obliged companies in certain countries to report about their environmental and social impacts, they transformed the constraint of being rated into an opportunity to communicate their results to different stakeholders. “The years 1999-2003 were characterized by increasing interest from the companies towards ratings. All the companies wanted to become a member of the index and I remember the day when we launched DJSI list, next day the companies would develop a logo ‘member of DJSI’ like a brand. Many companies put it on the first page on their website”. (Co-founder of DJSI, SAM) They created special departments of Sustainable Development, while understanding that a more holistic and integrated risk management approach can become for companies an element of their immaterial capital increase and thus could influence their performance. Moreover, some companies attributed every year special bonus policy for directors of SD department if they managed to keep the company in certain ESG index lists. At macro level, French rating agencies actively participated in the elaboration of NER law and together with international agencies contributed to developing ISO26000 guidelines and other CSR standards. They often claim to be one step ahead of a curve of standards as some of those norms came into the field very late. “We were the authors of the Carbon Disclosure Project for the first five reports. When they started they didn’t have money at all and we agreed to do it for very cheap. We were very involved in that. They didn’t have money at all and we agreed cheap. I am very proud of our help. We do our research for Access to Medicine Index for four-five years, which was modeled directly after CDP. And now we are doing a research for Access to Nutrition Index, which is not launched yet.” (Executive Director and Head of Product Development of ESG Research, MSCI; former president and co-founder of Innovest) DISCUSSION, IMPLICATIONS AND CONCLUSION This paper advances the theorization of the institutional dynamics of CSR standardization by focusing on the case of ESG rating agencies. In analyzing the processes whereby ESG rating agencies standardize CSR at the macro, meso and micro levels of analysis, our findings shed a new light on the dynamics explaining how ESG issues are materialized and translated to market actors, on the tensions that structure each level of 36 analysis, and the interrelationships between standardization processes across levels of analysis. This section discusses these three categories of insights with more details. Materialization and translation of ESG issues In this study we focused on materialization of social and environmental concerns by focusing on standardization processes across levels of analysis in the field of ESG rating. The understanding of emerging concerns and the translation of these concerns into measurable and calculable issues correspond to a form of CSR standardization. Their further integration into market functioning pushed the field of CSR ratings from being a niche market to a more mainstream market. When we focus on the standardization of an “unsettled” or “emerging” field it becomes clear that the participation of various groups of CSR rating field with complementary visions of CSR assessments is needed for the objectivity and relevance of measures. The collective contribution of industry experts, lead thinkers, government regulations and standards, companies and NGOs helped to shape reciprocally shared understanding of appropriate practice permitting ordered exchanges (Greenwood et al., 2002). Given that this field is characterized with continuous emergence of new issues and needs more time to be accepted in the market, the collaboration with recognized CSR entities and individuals will help to achieving the legitimation within the field. Hence our analysis provides a consolidated overview of the systemic process whereby the ESG rating field contribute to attract the attention of corporations and investors on social, ethical, governance, and environmental issues. This systemic mode of functioning of rating agencies can account for the rising importance over time agencies of issues such as obesity, harassment, well-being at workplace, psychological risks and treated those social issues as separate themes of assessment. Likewise the topics such as related risk, carbon gas and biodiversity gained higher weightings in environmental dimension. 37 More broadly, our paper extends the findings of Gilbert et al (2011) in showing that CSR rating agencies complement international accountability standards in consolidating a new institutional infrastructure for corporate responsibility (Waddock, 2008). We also showed the contribution of ‘hard laws’ and ‘market players’ in the standardization of CSR assessment. With this respect, we encourage other researchers in their efforts to explore separately the degree of influence of the above mentioned structures and their change over time. We suggest a comparative study of ‘hard’ and ‘soft’ laws and their influence on different CSR evaluation domains. Such cross-domain research will shed light on understanding the ‘nationalisation’ and the relevance of ‘cultural’ aspects in certain domains. Multilevel Analysis of CSR Ratings Standardization Our study pointed three core tensions which structure the dynamics of ESG rating standardization. At macro level we explored the tension between global and national processes of CSR standardization. While understanding the importance of both types of standards for the legitimacy of offered products and services we explained how companies managed this tension. Although the value of global CSR standards is nowadays well recognized (Gilbert et al, 2011; Gilbert and Rasche 2010, Etzion and Ferraro, 2010), these standards remain too general for being directly applied in the managerial context of specific countries. In providing assessment tools that conciliate national and transnational standards, agencies facilitate the translation of ESG issues to corporate actors by making them perceived as relevant and manageable both locally and globally. However, the development of idiosyncratic national standards creates a risk of making the ESG rating method too dependent from the local context, and the diversity of global standards creates some forms of ambiguity that ESG agencies have to manage. A second tension between differentiation and homogenization of CSR standards points to the management of the “strategic balance” (Deephouse, 1999) between differentiation and 38 conformity by ESG rating agencies. While a similarity of ESG ratings to other rating agencies avoids legitimacy challenge by demonstrating the consistency of judgment of these different experts who face the liability of newness in their organizational field, it may reduce competition and the possibility of marketing differentiation. On the other hand, the rational differentiation of each rating agency to capture more clients and attract the attention of more stakeholders may jeopardize the seriousness of each actor if for instance the ratings of a similar stock become too different. This tension shapes the competitive of the ESG rating field and has to be managed by each agency, either through consolidation strategy that mechanically reduce this tension by suppressing competition, or through specialization on specific ESG issues (e.g., environmental vs. social aspects that makes agencies perceived as complementary to each other). Finally, a tension between tailoring and industrialization of CSR standards at the micro organizational level showed the advantages of having “one fit” model for all clients versus customized approach toward each client of group of clients for marketing and technical and cost management purposes. Each agency struggles to establish a model of assessment that, one hand, is specific enough to accommodate the peculiarities of each sector and the expectations of each client (tailoring of ratings, focused rating studies for specific customers), and, on the other hand, enhances commensuration between stocks to cover the broader financial universe possible and allows savings work time by being as much standardized as possible. The building of a sustainable business model for an agency consists in striking this balance appropriately at its own level. The three above mentioned tensions helped understanding how standardizing organizations balance manage the expectations of their stakeholders within each level of analysis and contributed to compete the existing literature on dynamic of interplays between 39 micro-level activities (Slager and al, 2012) and the role of macro-level standards and their implication at micro level (Gilbert et al, 2010). Building a consolidated multilevel CSR theory An interesting contribution of the paper lies in its explanation of standardization processes across levels of analysis. Our findings suggest that the three dynamics described before interplay, each intra-level dynamics of standardization influencing the two other. The global-local tension that structures CSR standard building (macro level) shapes the (meso level) competitive dynamics whereas the each agency aims at influencing the transnational and national processes of CSR standard making with the aim of keeping the control and being up-to-date about the emerging standards. The (micro-level) struggle for building a sustainable business model at the directly frames the (meso level) competitive positioning of agencies as well as the agencies capacity to balance the differentiation-homogenizing tension. These cross-levels relationships can all be interpreted either through a technical or a legitimacy perspective, each level by mobilized by ESG rating either to enhance its legitimacy (or the legitimacy of the rated issues) or to support its method of assessment and of evaluation of CSR performance. To our knowledge, and despite recurrent calls for multilevel studies in CSR (e.g., Aguilera et al., 2007), there have been neither studies neither exploring the standardization of an emerging field through multilevel analysis nor highlighting the tensions across those different levels in the CSR domain (Aguinis and Glavas, 2012). The present extension of the study of CSR standardization processes through a multilevel perspective lays the ground for the building of a consolidated multilevel CSR theory. 40 REFERENCES Aaronson, S. A. & Reeves, J. 2002. The European response to public demands for global corporate responsibility. 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LEVEL 1: ESG RATING AGENCIES Interviewee Country Type BMJ Ratings Informant 1 (current staff) France Face to BMJ Ratings Informant 2 (current staff) France face/phone BMJ Ratings Informant 3 (current staff) France Face to face BMJ Ratings Informant 4 (current staff) France Face to face BMJ Ratings Informant 5 (current staff) France Face to face BMJ Ratings Informant 6 (former staff) France Face to face Vigeo Group Informant 1 (current staff) France Face to face Vigeo Group Informant 2(current staff) Italy Phone SAM Informant 1 (current staff) Switzerland Phone SAM Informant 2 (current staff) Switzerland Phone SAM Informant 3 (former staff) England Phone SAM Informant 4 (former staff) Switzerland Phone Eiris Informant 1 (current staff) England Phone Eiris Informant 2 (current staff) France Phone Eiris Informant 3 (former staff) England Face to face Innovest Informant 1 (former staff) USA Innovest Informant 2 (former staff) USA Phone TruCost Informant 1 (current staff) USA Phone MSCI Informant 1 USA Phone CSR/SRI Expert 1 Netherlands Phone CSR/SRI Expert 2 Netherlands Phone CSR/SRI Expert 3 France Phone CSR/SRI Expert 4 France Phone Company Sustainable Manager France Face to face Company Corporate Affairs & Sustainability VP USA Phone Company Environment and Sustainability Dir. USA Phone Length 60min. 60min. 42 min. 60min. 40 min 60min. 43 min. 54 min. 45 min. 40 min. 62 min. 35 min. 45 min. 67 min. 54 min. 33 min. 34 min. 50 min 45 min. 50 min. 50 min. 47 i The term ESG ratings agencies was introduced in the study of Avetisyan and Hockerts (2012) as an umbrella to refer to a number of similar terms such as Corporate Social Responsibility (CSR) rating agencies, SRI rating agencies, or sustainable asset management companies. 48