EURHONET – CSR TG – EURHO-GR® Handbook – Version: June 5th, 2013
EURHO-GR®:
a European
framework for CSR
in social housing
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Ljubitza Kouris – Charlotte Limousin
EURHONET – CSR TG – EURHO-GR® Handbook – Version: June 5th, 2013
FOREWORD
TO BE DONE
WHAT CAN BE FOUND IN THIS DOCUMENT:
An introduction to our vision of CSR in Social housing in Europe
 Chapter 1
The reasons why EURHO-GR® was developed and the benefits it can bring to social
housing organizations
 Chapter 2
A presentation of EURHO-GR®, its structure and indicators, and linkages with other
international CSR frameworks
 Chapter 3
Purposes and benefits of CSR reporting and reports
 Chapter 4
EURHO-GR® reporting principles and guidance to CSR reporting
 Chapter 5
EURHO-GR® narrative CSR reports rules and content, and guidance to CSR reports
writing and dissemination
 Chapter 6
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SOME KEYS TO UNDERSTAND CSR AND THE PRESENT DOCUMENT
 Social housing organizations
There is no single definition and no unique model for “Social housing” across Europe. The “Social
housing umbrella” actually gathers very different structures, ranging from small local non-profit charities to
large corporations. In the present document, “social housing organizations” are understood as all kinds
of public, private or cooperative landlords, recognized as providers of a service of general
interest, whose mission is to provide decent affordable housing to households experiencing
greater difficulties to access housing under the local market conditions. In some countries, social
housing organizations may also, in addition to “social housing”, provide standard “market housing”.
 Corporate Social Responsibility (CSR) or Social Responsibility (SR)?
CSR stands for Corporate Social Responsibility, which focuses on private companies exclusively. Indeed,
the concept was initially developed in the private business sector. However, in recent years, Social
Responsibility was broadened to all types of organizations -public companies, public authorities as well as
non-profit organizations-, recognizing that all actors, all structures impact on society, and should therefore
take on their own “Social Responsibility”. This is why the ISO 26 000 standard (see p. XX) is entitled
“Guidance on Social Responsibility”, and is clearly aimed at all kinds of organizations, regardless of their
core mission, activity or legal status.
In the present guidelines, “CSR” refers to this larger meaning, encompassing both private companies and
public or non-profit actors.
For more details on CSR definition, see chapter 1.
 Stakeholders
Stakeholders can be defined as all actors which are concerned by an organization’s activities and
impacts, either because they can be directly or indirectly affected by them, or because can contribute
and/or influence decisions and activities.
For more details on stakeholders, see chapter 1.
 Sustainable development
The most popular definition of sustainable development stems from the Brundtland report Our common
future (1987): a way of “development that meets the needs of the present without compromising the
ability of future generations to meet their own needs”. Contrary to what is commonly thought, sustainable
development does not only relate to environmental matters but also implies addressing social needs and
economic constraints.
For more details on sustainable development, see chapter 1.
 Sustainability reports vs CSR reports
“Sustainability reports” and “CSR reports” both refer to organizations’ reports on their strategy, actions
and performance with regards to their “Social Responsibility” (and thus their impact on and contribution to
society and the environment). In all EURHO-GR® documents, we use the term “CSR reports” (or
“Responsible activity report” when it is combined with the usual activity report).
For more details on CSR reports, see chapter 6.
 ISO 26 000 Standard
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CONTENT:
FOREWORD ................................................................................................................................................ 2
SOME KEYS TO UNDERSTAND CSR AND THE PRESENT DOCUMENT .............................................. 3
1
2
3
CSR AS A RENEWED VISION OF SOCIAL HOUSING .................................................................... 5
1.1
Defining CSR in the context of European public and social housing ........................................... 5
1.2
CSR as a way to revisit organisations’ relation to their Stakeholders .......................................... 9
1.3
Why engage in CSR? ................................................................................................................. 12
1.4
CSR: a continuous improvement approach ................................................................................ 15
WHY A EUROPEAN CSR FRAMEWORK FOR THE SOCIAL HOUSING SECTOR? .................... 17
2.1
Why a common framework? ....................................................................................................... 17
2.2
Why a European framework? ..................................................................................................... 20
2.3
Why a sector specific framework? .............................................................................................. 21
WHAT IS EURHO-GR®? .................................................................................................................. 23
3.1
General presentation .................................................................................................................. 23
3.2
4
5
6
EURHO-GR® sections ............................................................................................................... 25
CSR REPORTING AND REPORTS: WHAT FOR? .......................................................................... 33
4.1
Putting key CSR principles into practice .................................................................................... 33
4.2
Beyond CSR principles: supporting CSR implementation and visibility ..................................... 34
4.3
Reporting within CSR implementation ........................................................................................ 36
CSR REPORTING WITH EURHO-GR®: .......................................................................................... 39
5.1
EURHO-GR® fundamental principles ........................................................................................ 39
5.2
Setting up a reporting system ..................................................................................................... 41
5.3
CSR reporting steps ................................................................................................................... 44
CSR NARRATIVE REPORTS WITH EURHO-GR® ......................................................................... 45
6.1
Reports’ scope: ........................................................................................................................... 45
6.2
The “Golden rules” ...................................................................................................................... 45
6.3
EURHO-GR® Reports’ main content ......................................................................................... 46
6.4
CSR reports or “combined reports”? .......................................................................................... 47
6.5
Reports’ dissemination ............................................................................................................... 47
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1
CSR AS A RENEWED VISION OF SOCIAL HOUSING
1.1
DEFINING CSR IN THE CONTEXT OF EUROPEAN PUBLIC AND SOCIAL HOUSING
The concept of Corporate Social Responsibility (CSR) was defined by the European Commission in 2011
as « The responsibility of enterprises for their impacts on society » 1.
In the same landmark document on CSR, the European Commission further specifies how companies are
expected to assume this responsibility:
“Respect for applicable legislation, and for collective agreements between social partners, is a
prerequisite for meeting that responsibility. To fully meet their corporate social responsibility,
enterprises should have in place a process to integrate social, environmental, ethical, human
rights and consumer concerns into their business operations and core strategy in close
collaboration with their stakeholders, with the aim of:
– maximising the creation of shared value for their owners/shareholders and for their other
stakeholders and society at large;
– identifying, preventing and mitigating their possible adverse impacts.”
Based on this definition, CSR can be approached through three main perspectives:
- Sustainable development: whereas sustainable development refers to a global model, CSR can be
seen as companies’ and organisations’ contribution to this system, through the implementation of its
principles into their own business model and strategy;
- Transparency and accountability: answering for its decisions and actions, and their impacts. This is to
be connected with the very first meaning and origin of the term “Responsibility” (from the Latin verb
“respondere”);
- Ethics: CSR also implies, for an organization, adopting a respectful behaviour towards its stakeholders,
and considering, in all circumstances, its actions’ consequences on others (be they employees, clients,
partners, suppliers, etc.).
Being
responsible
is
The first approach refers to core issues companies should consider
and seek to address through their strategies and activities.
recognising the impacts of
The other two relate to key principles of action and conduct that they
an organisation on society
should adopt and follow throughout all processes and interactions.
The European definition of CSR, focusing on impacts, highlights that all
activities engender effects on society, positive and negative.
“Responsible companies” are those which voluntarily choose to
acknowledge them and are willing to react and implement solutions to
maximize the positive impacts and reduce as much as possible the
negative ones.
and reacting in order to
limit negative impacts and
contribute to a better
society.
ISO 26000 CSR definition:
The CSR definition given by the European Commission has clearly been inspired by the definition
found in the ISO 26000 standard:
«Responsibility of an organization for the impacts of its decisions and activities on society and the
environment, through transparent and ethical behaviour that:
 contributes to sustainable development, including health and the welfare of society;
 takes into account the expectations of stakeholders;
 is in compliance with applicable law and consistent with international norms of behaviour;
 is integrated throughout the organization and practiced in its relationships. »
1
European Commission, A renewed EU strategy 2011-14 for Corporate Social Responsibility (COM(2011) 681).
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1.1.1
Social housing at the heart of sustainable development’s issues
The concept of sustainable development entered the global political landscape in 1987, through the
Brundltand report, officially entitled “Our common future”. This report has coined the most widespread
definition of sustainable development: sustainable development “meets the needs of the present without
compromising the ability of future generations to meet their own needs.” This definition stresses the longterm perspective embedded in the concept, which is consequently very often exclusively associated with
environmental issues. Yet, as stated a few lines further in the report, sustainable development is also
about ensuring people’s well-being: it “requires meeting the basic needs of all and extending to all the
opportunity to fulfil their aspirations for a better life”.
The concept was born from the conclusion that the socio-economic model which prevailed in the last
decades is impossible to maintain and needs to be completely reconsidered: its impacts on the
environment and society are indeed rapidly destroying the very resources and equilibrium it relies on.
Sustainable development means thus changing our production and consumption patterns, to adopt a
long-term perspective and enable a form of balanced economic growth, which contributes to social
objectives and preserves environmental resources.
Social housing clearly stands at the heart of sustainable development challenges.

Its very core mission, providing access to affordable housing, relates to one of the major concerns
of today’s society. Housing can definitely not be considered like other ordinary goods; it is
recognized as a right in a number of international human rights instruments (Universal Declaration of
Human Rights; the International Covenant on Economic, Social and Cultural Rights…) and in the EU
Charter of fundamentals rights, made legally binding by treaty of Lisbon2. Housing is besides a
determining factor on people’s lives, health, social and economic development… By targeting in
priority those who face greater difficulty to access decent housing conditions, social housing
contributes to social equity and diversity.
Social and public housing providers are besides more and more expected, or even requested, to
address other social and community needs, through investment in equipment or infrastructures, or
involvement in specific actions, aimed at, for example, supporting employment and social integration
or reducing antisocial behaviours…

Construction and housing have significant and long-lasting impacts on the environment, locally and
globally. In 2010, the residential sector accounted for over 26% of the total final energy consumption in
the EU. It is seen as one of the greatest potential for increased energy efficiency in the EU. Closely
related to energy consumption is the amount of Greenhouse Gas (GHG) emissions released every
year, contributing to climate change. Although the current regulation focuses on these aspects, other
environmental impacts are to be considered, including water consumption, land use and impact on the
ecosystem…
Through their regular contact with a number of actors, and, in particular with inhabitants, social
housing providers can also play a role in awareness-raising and accompanying change towards more
sustainable practices.

As highlighted in a number of recent studies in various EU countries, social housing providers also
have a significant economic impact, through their investments and maintenance expenditures,
which often largely benefit to local companies. Through the billions of euros injected each year, they
can be important drivers of local economies. This increases their potential influence, and therefore
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their responsibility with regard to how they spend and how they behave on markets and with their
suppliers.
This has to be conciliated with a particular duty in terms of
sound financial management in order to ensure limited
housing costs for their tenants, and because in many
countries social housing providers receive public support.

A long-term perspective is also inherent to the very
nature of the activity: not only does it rely on long-term
lending (and long business cycles), but it also involves
managing a housing stock for years after its construction.
The choices made in the conception phase will impact
durably on the buildings’ use and maintenance, but also on
the area where it is located. The relation to customers is
also more durable: unlike many other businesses, it is not
based on brief, intermittent transactions but on multi-year
contracts.
“The
current
global
economic crisis arose from
fundamental errors with
respect to transparency,
accountability, responsibility
and from short-termism, and
the EU has a duty to ensure
that these lessons are learnt
by all” (European Parliament resolution of
6 February 2013)
Socio-demographic changes, new society aspirations as well as rising social issues represent some of
the major challenges faced by social housing providers today. These are further exacerbated by the
current crisis, which led to impoverishment and intensified social disintegration, and subsequent dramatic
consequences at individual, household and community levels. Housing providers cannot either ignore
anymore the growing environmental concerns, which also affect households’ housing costs and living
conditions.
Adding to this evolving context, retreating States and ever more constrained public budgets put
considerable pressure on social housing providers, forced to re-invent their business models,
management systems and day-to-day practices.
Social housing providers’ mission is intrinsically committed to the general interest. They are
today already confronted to a number of social, environmental and economic issues.
As such, can they really, in the current context, turn their back to sustainable development?
Shall they wait for new, stricter regulation, or be pro-active and endorse voluntarily these new
responsibilities?
Aren’t the major changes the sector is going through an opportunity to redesign their strategies
and integrate sustainable development concerns into their operations?
1.1.2 CSR key principles and expectations towards Social housing
Beyond addressing sustainable development issues, being a “responsible organization” also implies
operating according to a number of fundamental principles; some of them find a peculiar resonance in the
social housing sector.
The ISO 26 000 standard has defined 7 principles: accountability, transparency, ethical behaviour,
respect for stakeholders’ interest, respect for the rule of law, respect for international norms of
behaviour, respects for human rights.
These principles have to guide organizations’ actions and decisions, and shall be applied by all members
of the organization, in their daily activities.
Because it addresses major social issues and benefits from a special status, as well as public
funding/support, the sector draws particular attention from national and local authorities and, more
generally, from citizens. Shrinking public resources intensify authorities’ and citizens’ demand for greater
accountability and transparency on the use of funds. In parallel, as actors invested with a mission of
general interest, social housing providers are expected to act as examples, as models for other sectors.
The crisis and scandals in recent years have aggravated distrust from civil society actors and citizens
towards private enterprises and public bodies. Citizens are particularly watchful of the conduct of public
actors and their partners, and will judge extremely severely any breach to what is considered as ethical
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and responsible. As such, accountability, transparency and respect of stakeholders’ interests are
particularly relevant for social housing.
PRINCIPLES OF SOCIAL RESPONSIBILITY AS
PER THE ISO 26 000 STANDARD
ACCOUNTABILITY
State of being answerable for decisions and activities to
the organization's governing bodies, legal authorities
and, more broadly, its stakeholders
TRANSPARENCY
Openness about decisions and activities that affect
society, the economy and the environment, and
willingness to communicate these in a clear, accurate,
timely, honest and complete manner
ETHICAL BEHAVIOUR
The organization’s behaviour should be based on the
values of honesty, loyalty and integrity.
RESPECT FOR
STAKEHOLDERS INTERESTS
An organization should respect, consider and respond to
the interests of its stakeholders
RESPECT FOR THE RULE OF
LAW
An organization should accept that respect for the rule of
law is mandatory
RESPECT FOR
INTERNATIONAL NORMS OF
BEHAVIOR
An organization should respect international norms of
behavior, while adhering to the principle of respect for
the rule of law
RESPECT FOR HUMAN
RIGHTS
An organization should respect human rights and
recognize both their importance and their universality
Transparency and accountability are fundamental imperatives of CSR, and stand very close one to the
other. Accountability means assuming responsibility and answering for decisions, actions and their
consequences towards stakeholders. It implies accepting that stakeholders have a right to be examine
how business is conducted and question the organization on its actions. Transparency means providing
access to complete, clear, correct and up-to-date information pertaining decisions, actions and impacts.
Organisations should be transparent and accountable on all dimensions (economic, environmental,
social), and on positive as well as negative impacts. They should be transparent on impacts, preventive
or corrective actions and decision making processes.
The EU and companies’ transparency on social and environmental matters
Companies’ obligations in terms of transparency on social and environmental matters were first
mentioned in the 2003/51/CE Directive on the annual and consolidated accounts of certain types of
companies, banks and other financial institutions and insurance undertakings.
This first step at European level was enhanced in the EU 2011-2014 strategy for CSR, which includes a
clear focus on accountability and transparency. The EU Parliament non-binding EU Parliament resolution
issued in February 2013 (“Corporate social responsibility: accountable, transparent and responsible
business behaviour and sustainable growth”) supported this view and called for a European framework on
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companies’ disclosure requirements on CSR-related issues. The European Commission subsequently
submitted a Directive proposal in April 2013; should this proposal be endorsed by the Parliament and the
Council, companies over 500 staff and either a balance sheet total of EUR 20 million or a net turnover of
EUR 40 million would be required to include in their annual report information pertaining to, at least:
environmental, social and employee matters, respect for human rights, anti-corruption and bribery
matters.
At the very heart of a CSR approach stands the principle of “respect for stakeholders’ interests”. As
such, CSR requires to not just consider the interests and expectations of owners and shareholders, but
also of all actors directly or indirectly concerned by the organization’s activity and impact. Social housing
is by nature exposed to a number of actors, in particular at local level, and has thus to deal with diverging
or even contradictory objectives, while always keeping in mind the collective interest. The first imperative
is then to explain and justify the choices made towards stakeholders.
Accountability and transparency are necessary to build trust with stakeholders. It should be supported by
an ethical behaviour. Integrity, loyalty and equity shall be spread and observed throughout the
company, along with concern and respect for others.
Respect for the rule of law is obviously a first necessary condition to Corporate Social Responsibility,
while respect for international norms of behaviour and human rights refers mainly to UN Conventions
and International Labour Organizations Standards. These principles target in priority multinational firms
operating in developing countries where regulation and standards are not as strict as in Europe. However,
considering the sensitive nature of their work, growing and changing regulation, and rising concerns
relating to working conditions (work-life balance, non-discrimination, stress and harassment…), social
housing providers in Europe should not overlook these key CSR rules.
Social housing organizations are major partners of local authorities. They provide an essential –
and highly-demanded- service. They operate according to a special status and, in most countries,
benefit from different types of public support.
As such, don’t they have a particular responsibility towards citizens, taxpayers and society at
large in terms of accountability and transparency?
Shouldn’t they lead the way in terms of ethical behaviour, respect for stakeholders’ interests and
human rights?
While the sector often suffers from a negative image, largely conveyed by the media, isn’t it time
to (re)affirm and demonstrate high engagement and human values?
1.2
CSR AS A WAY TO REVISIT ORGANISATIONS’ RELATION TO THEIR STAKEHOLDERS
The ISO 26 000 standard defines a stakeholders as “an individual or group that has an interest in any
decision or activity of an organisation”.
In other words, «stakeholders» are actors:
 On which the organization has an impact or could have an impact (positive or negative)
 And/or which could impact (directly or indirectly) on the organization’s activity, decisions and
functioning (and/or contribute to its action).
CSR is about building a longterm and solid relationship, to the
benefit of both the organisation
and its stakeholders.
Stakeholders are the heart of the CSR approach: responsible
organizations should identify, understand and respond to the
expectations of their stakeholders, and develop with them a
relationship based on mutual respect.
Social housing stakeholders
Social housing stakeholders can be classified into 5 main categories, according to the actors’ nature:
 Institutions and public authorities: public actors elaborating and implementing policies at a
European, national and local level.
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



Residents: populations living in the territories of the organism’s implantation area and affected by
their stock of dwellings, among which: clients, social housing applicants and other local residents.
Human resources and related actors: organisation’s direction and employees; peripheral external
actors, influencing or contributing on human resources management
Economic actors: actors directly involved in the management and funding of the organisation;
economic partners; organisations representing economic interests or contributing to the economic
fabric; other private and public actors of the housing sector.
Society and environment: actors which form the ecosystem in which the organism operates, and
which contribute to defend interests or society or environmental concerns.
Given the number of stakeholders, this classification needs to be completed by a ranking, according to
stakeholders’ strategic importance. A prioritisation on three levels is proposed:
- Fundamental stakeholders: direct involvement into the organisation’s functioning.
- Major stakeholders: meaningful contribution to the organism’s core activity; regular and very often
contractual relation with the organization.
- Secondary stakeholders: contribution or influence on certain actions, certain aspects of the
organization’s activity, but not essential for its primary mission. They can represent either a support for
the organism or, on the contrary a protesting force or pressure.
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“Stakeholder mapping” is an efficient way to get an overall picture of all different stakeholders and monitor
on a regular basis:
 The relationship between the company and a stakeholder, including the degree of interaction
 Stakeholders’ interests and their expectations from the organisation
 Organisation’s expectations from stakeholders
 The means of dialogue adopted to interact with stakeholders
Annex n°X shows an exhaustive list of social housing stakeholders that may help you design your own
proper map.
Organizations have impacts on their stakeholders, but are also very often dependant on them. Social
housing providers rely heavily on a variety of actors to deliver their mission, ranging from local authorities
to service suppliers and community actors. Ensuring their support and adherence to the organization’s
vision and strategy is therefore essential, not only to help fulfil the organisation’s work, but also to
establish and reinforce its legitimacy (or “licence to operate”).
Dialogue is essential for companies to engage in this mutually beneficial relationship. In the social
housing sector, specific regulation imposes in many countries governance structures and systems which
encourage close dialogue –and cooperation- with local authorities and tenant representatives. However,
even when they comply with the national regulation, these mechanisms do not always enable sincere and
effective collaboration: indeed, a true relationship cannot be imposed by rules and laws, and depends
much more on actors’ intentions and motivations, and their willingness to co-operate.
Building a sound and lasting relationship with stakeholders can be
compared with the construction of a house. The construction of a house
starts from building its foundations. Foundations have to be solid to
support the house on the long term and resist to potential hazards. Only
once the foundations are laid, can walls and the rest of the house be
raised.
Similarly, the relationship with stakeholders starts from building trust,
though, in particular, accountability and transparency. This is crucial to
initiate a constructive, long-lasting dialogue and create the necessary
conditions for the ultimate step: cooperation.
Taking into account its
stakeholders’ interests
starts with accounting
for its own actions and
impacts.
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Social housing providers deal with a great diversity of stakeholders, who are becoming more and
more sensitive to sustainable development and Social responsibility principles.
Instead of a relationship based on suspicion, or even conflict, wouldn’t a stable and fruitful
collaboration with stakeholders increase efficiency of joint actions?
Wouldn’t it help ensure products’ appropriateness and stakeholders’ final satisfaction, thus
reducing the risks for potential opposition?
Wouldn’t it is thus reinforce the organization’s reputation and “social acceptance”?
1.3
WHY ENGAGE IN CSR?
Engaging in CSR still stands on a voluntary basis, despite tightening regulation on several aspects
(environment, transparency, governance…). It has therefore for a long time been considered as
secondary to a company’s activities, and is still very often seen as a luxury.
So what makes organizations freely endorse Social Responsibility, in particular in social housing? There
are several answers to this question.
It is first and foremost a question of values and vision. Organisations engage in CSR because they
adhere to its underlying principles, and they believe that everyone, every actor has a role to play towards
sustainable development.
But CEOs also adopt CSR because they see the benefits it can
CSR engagement is most
bring to the organisation:
often the result of both
- as a tool to respond to the sector’s current challenges and
changes;
internal motivations and
- as a way to reaffirm the organisation’s identity and positioning;
external drivers. It is about
- as a means to reinforce internal cohesion and unity, at a time
principles but also sound
where uncertainty, a changing context and intensified financial
constraints generate great mutations in social housing providers’
business strategy.
management.
Lastly, external incentives and pressure can act as powerful leverages on general managers’ decision to
engage in a structured and formalized Social Responsibility strategy.
In all cases, whatever the main reason for adopting CSR, organisations shall do it sincerely and
only if they do believe in its primary principles. As a social housing general manager once put it,
“humility is a key condition. Don’t do it if you are not ready to question and, ultimately, change
your practices, the way you do business”.
1.3.1
Expected gains from CSR
One of the main positive gains recognised by most companies throughout different sectors is the
beneficial impact on the company’s image and reputation that is driven by the implementation of CSR.
More specifically in social housing, reputation is anchored to the providers’ territory and strongly
interconnected with social acceptability. The opinions of residents, voters and the media are fundamental
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to local authorities, more inclined at selecting firms with a good reputation as long lasting partners in their
territory.
Linked to reputation is the differentiating virtue of CSR, which can represent a significant advantage on
some markets. Moreover, where social housing providers’ investment relies on financial markets’ funding,
CSR, highlighting providers’ societal impacts and specificities, could help them secure alternative funds
(e.g. social/responsible investment), in a context of acute tension in a housing sector facing severe
funding shortages.
Beyond reputation and differentiation, CSR helps restore or strengthen the confidence of stakeholders, in
particular investors and local authorities, increasingly more sensitive to sustainability matters and in
demand for more accountability and ethical practices.
CSR also supports global performance and continuous improvement. Quality management systems,
which have blossomed in the last decade in the social housing sector, aim at ensuring final customers’
satisfaction and processes’ efficiency, thus improving the organisation’s performance. CSR follows a
similar approach, expanded to all stakeholders and all activities.
CSR can be seen as a “360 mapping” of the organisations’ activities and associated impacts, along with
correlated risks and opportunities. It provides a global vision, ensuring that no aspect is omitted or left
aside. It fosters regular monitoring of the organisations’ environment to identify changes and trends,
which could represent chances or threats for the organisation.
As such, CSR is an amazing tool for risk management and to anticipate regulation. It is also a strong
driver for innovation as it raises new issues, new questions, which call for collective creativity to invent the
solutions to address them. CSR also promotes openness and dialogue with external actors, which
provides a window on different ways of thinking and doing.
The positive effects of CSR on the internal dimension of companies are very often neglected compared to
the external valuation, though the results can be highly
Fundamentally, CSR raises
impressive and meaningful. Particularly in the latter years, as
social housing providers are experiencing a global crisis and
three major questions to
drastic changes (including dramatic budget costs, merging,
organisations:
etc..), it is fundamental for them to pay great attention to the
inside of their organisations.
1. What do you want to be?
Social housing providers are increasingly adopting typical
2. What do you want to be
business-like strategies and management systems. They are
seen and defined as?
requested to fill in harder tasks, to address increasingly more
complex issues, and cover a wider spectrum, while being more
3. Where do you want to
efficient and competitive, reactive and innovating. In such a
stand in five years’, ten years’
context, Internal cohesion and a strong sense of belonging
among staff are also essential. As evidenced in a number of
time?
studies, inspiring vision and values are strong driving forces to
develop and maintain employee engagement. CSR can therefore assist in change management, through
a rallying vision and strategy based on high societal goals and values, ensuring that reinforced economic
objectives, environmental considerations and social purposes are adequately balanced.
CSR can help also attract and retain new skills and highly-qualified workers, contributing to maintain and
increase the organisation’s performance, while actions aimed at safety and well-being at work, as well as
employees’ engagement, contribute to limit absenteeism and turnover.
Lastly, sharing a common project, implemented collectively, helps create strong bonds, and overcome
potential barriers between the organisations’ departments, thus increasing efficiency and reactivity.
1.3.2
CSR: complementary, compelling or compulsory?
External drivers also largely contribute to CSR uptake and tend to gradually “impose” Social responsibility
in the social housing landscape.
Civil society (citizens, consumer associations, trade unions, the media…) are increasingly exhorting
companies to take responsibility for their impacts and adopt more ethical, responsible, sustainable
practices. As mentioned in the previous section, social housing providers, are also more and more under
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such pressure from their stakeholders –in particular local and national authorities, which request greater
involvement and demonstration of housing providers’ contribution to society.
While trade unions were at first quite reluctant to CSR, they are now more and more using it to support
and advocate for their demands. Tenant associations are also much more familiar to the concept, and
see in CSR a way to strengthen their relationship to landlords and voice their expectations.
Civil society organisations are also prompter to challenge companies which claim their social
responsibility, by confronting their declarations to their actual deeds and practices.
External pressure also comes from “peers”, creating a virtuous “snowball effect”: pioneers which engaged
in CSR in the mid-2000s have now been followed by dozens of others, in particular when encouraged by
national federations, like in France or Germany for example. Furthermore, as private companies in the
real estate sector are increasingly engaging in, and communicating on CSR, social housing providers do
not want to be outdone.
As well as in other sectors, social responsibility in social housing is steadily increasing. Actors,
stakeholders and citizens are realising that CSR will soon not be considered as a nice “extra” anymore, or
a simple marketing tool, but as an inevitable approach that has to be introduced into the everyday life of
business operations, as an integral part –or even the basis- of their strategy. Social housing providers are
increasingly looking at CSR as the added value to their activities necessary for their progress and
compelling to their needs. They will all soon have no choice but to take it into account in order to deal with
today’s challenges and maintain their activity on the long run.
“CSR should be placed
in a broader setting
which, while ensuring
that CSR remains
primarily a voluntary
policy, also leaves room
for dialogue on
regulatory measures,
wherever appropriate.”
Adding up to this, law reinforcement on environment and social
matters, governance, transparency at European and national levels
have come along to underline that companies and organisations could
not ignore their impacts and responsibility towards society anymore.
Some of CSR issues or principles are already quite strictly regulated,
in particular in the environmental field. Very recently, new legislation on
companies’ transparency on their actions and impacts relating to
human resources, the environment and society has emerged in several
European countries. France has gone the furthest: information on over
40 topics is now requested from larger companies. Inspired by this
breakthrough regulation, the European Commission proposed in April
2013 a new directive for a European framework on companies’
transparency.
(European Parliament resolution of 6
February 2013)
As such, whereas, in its previous definition of CSR, the European
Commission insisted on the “voluntary dimension” of CSR2, it has
removed this aspect in the latest definition, and now
clearly states that ensuring that some elements of
“[The European Parliament] endorses the
Social responsibility may also require mandatory
regulation: “Public authorities should play a
new definition of CSR put forward by the
supporting role through a smart mix of voluntary
Commission, which does away with the
policy
measures
and,
where
necessary,
dichotomy between voluntary and
complementary regulation, for example to promote
transparency, create market incentives for
compulsory approaches.” (European Parliament
responsible business conduct, and ensure corporate
resolution of 6 February 2013)
accountability.”
The opposition between “voluntary” and “mandatory” CSR should be seen as over. Organisations
must accept that, sooner or later, they will have to face and assume their Social Responsibility.
The question is: do you want to be proactive, to contribute to shape it and make it an opportunity,
or will you wait until it is imposed on you?
“a concept whereby companies integrate social and environmental concerns in their business operations and in their
interaction with their stakeholders on a voluntary basis”
2
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CSR aims at sustainability for the society and environment, but also for the organisation!
1.4
CSR: A CONTINUOUS IMPROVEMENT APPROACH
Like Quality management systems, Social Responsibility is based on a “continuous improvement”
principle. It is a step-by-step approach, which should be implemented cautiously and progressively.
Like Quality management systems, it is based on a “Plan-Do-Check-Act” method: in order to firmly anchor
social responsibility into the organisation and ensure its durability, it has to be structured, based on
strategic planning, and regularly monitored and evaluated, in order to identify ways of progress.
An organisation never starts from “a blank sheet”: there are always some good practices, some internal
policies or actions to build on. The CSR strategy should rely on them, but needs to go further. Existing
actions should be first identified and analysed: from this baseline analysis, a mid-term action plan, with
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specific and quantified objectives, must then be defined, and regularly reviewed. Without such planning,
to set and coordinate objectives and actions, social responsibility may remain either a set of “good
intentions” or a collection of disconnected, and often short-lived, “good practices”. It can thus not lead to
genuine and lasting changes, and may create confusion, internally and with external partners; worse, it
can lead to discrepancies between the organisation’s discourse and its actual day-to-day practices. This
can have a terrible impact on the organisation’s reputation, but also in terms of employees’ loyalty and
engagement.
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2
WHY A EUROPEAN CSR FRAMEWORK FOR THE SOCIAL HOUSING SECTOR?
As described above, Corporate Social Responsibility covers an extremely wide scope, ranging from
employees’ training to biodiversity protection and “good governance”. The concept is still relatively new,
and thus sometimes perceived as vague, not to say hazy. So, how to put it into practice? How to translate
it into concrete actions?
The EURHO-GR® (EURopean Housing – Global Reporting) framework was precisely developed to
address this question. It is a structured, European, sector-specific framework, aimed at helping social
housing providers implement CSR, and account for their strategy, actions and global performance.
2.1

WHY A COMMON FRAMEWORK?
It develops a common language and reinforces credibility and legitimacy
Transforming the ideal of “Social responsibility” into action requires to define precisely what is meant, and
what is expected, in particular from civil society.
The concept of CSR, which remains quite new to many, has been interpreted in many different ways
throughout the last decades and is still subject to debate. Companies have adopted different ways to
address subjects and issues related to CSR, and have sometimes voluntarily excluded some aspects,
though considered as important by civil society organisations or authorities. The great diversity of CSR
approaches has created confusion, and even sometimes mistrust, as it seemed that any organisation
could claim to be “socially responsible” without specifying what it really entailed. This is further
exacerbated by the absence of CSR certification.
Furthermore, a company implementing such a complex approach through its own vision and
understanding may often lack a wider and more global overview on the issues that are considered
important to its environment and stakeholders.
Against this background, international CSR frameworks have progressively emerged, the latest being the
ISO 26 000 standard. These common frameworks enable to set a shared and agreed language, both for
organisations and their stakeholders.
Moreover, using a common framework to build your own CSR strategy gives more weight to it, reinforces
its legitimacy. In particular, CSR reporting frameworks, which provide collectively accepted rules and
indicators, contribute to the credibility of organisations’ CSR reports and communication.
To ensure its significance and acceptability by all, EURHO-GR® was developed together with
social housing organisations and their stakeholders. Through the set of indicators, it helps
ensuring exhaustive and credible CSR reports. It is now used by 35 organisations across France,
Germany, Italy and Sweden.

It’s easier and time saving
Implementing CSR and integrating it into the organisation’s strategy is no easy process. Existing CSR
definitions target all different kinds of organisations
Sharing a common framework
(activity, size and structure) worldwide. As a result, they
remain generic, and more conceptual than practical. CSR
means developing a common
has also led to the development of a highly technical
language and saving resources
lexicon, made of a wide spectrum of terms, not always very
clear and well defined, making it very difficult for
by avoiding reinventing the
organisations willing to engage in CSR to understand how
wheel.
exactly to do so. One does not always know “where to
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start” and how to proceed; defining its CSR strategy can thus be extremely arduous and time-consuming.
CSR frameworks, as the Global Compact, the GRI or the ISO 26000 standard, have been designed as
helpful guides to organisations. They describe and explain what is included within the whole concept and
definition of CSR. They list a number of core issues, of main stakeholders and society expectations, and
organize them into main categories, in order to help organisations navigate through the maze of Social
responsibility.
Through this preliminary “spadework”, common CSR frameworks are thus valuable skeletons for
organisations to build on. Yet, they sometimes still remain too broad, hence the need for sector-specific
frameworks.
EURHO-GR® was designed to facilitate social housing organisations’ engagement in CSR. It
provides a global structure to help them identify their main challenges, define their strategy and
set their objectives.

Be part of a community / network (especially for SMEs )
The literature underlines the major –and growing- role of business networks for SMEs, in particular for
their adoption of innovation and new practices, and CSR in particular.
Membership to local and/or sector-based groups, and exchanges with other organizations, constitute for
them a source of inspiration, of stimulation, and give them opportunities to learn from others’ experiences.
These networks compensate for the limited internal resources, especially for R&D, innovation and inhouse tool development. As evidenced by a number of research works, business networks strongly
contribute to spread “models” of “good practices”, and are thus essential vectors of CSR among SMEs,
through a “peer influence” and imitation process.
A same framework used by a number of organisations help forge a sense of identity, of “community”, as it
formalizes a joint commitment and language. It thus enables to create links between organisations of
various sizes, cultures, countries…
Beyond a CSR framework, EURHO-GR® is also a network of social housing organisations sharing
a same vision, and building on each other’s’ experience to innovate and continuously improve
theirs action and practices.
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INTERNATIONAL CSR FRAMEWORKS:

ISO 26 000 : 2010 : Social Responsibility Guidelines
A reference document published in 2010 from the International Standard Organisation (ISO), and
approved by 93% of the ISO member states, the ISO 26000 Standard provides guidelines (definitions,
principles and recommendations) to promote a common understanding of social responsibility, and help
organisations implement CSR. This standard targets any kind of organisation, without difference in size,
status, activity’s sector, localisation…This standard does not include any requirement, and thus cannot
be subject to certification. The ISO 26000 standard was developed with the participation of experts and
stakeholder representatives from more than 90 countries and 40 international organisations, divided into
6 groups: consumers, public authorities, industries, workers, NGOs and the services, consultancy,
research, education and others. (Source: Norm ISO 26000(2010): « Guidance to social responsibility »).

Global reporting initiative
NGO founded in 1997, the Global Reporting Initiative has as a mission to promote an economic, social
and environmental sustainable development. It is at the origins of reporting extra-financial information
with regard to all organisations; independently form their size, status and sector’s activity. GRI
guidelines act as a worldwide reference today and in particular among multinational firms. They include
recommendations not only in terms of indicators but also on the CSR reports’ content. The first version
of the GRI Guidelines was published in 2000. It evolved progressively ever since, based on users’
feedback and new CSR issues. The 4th version has just been published (June 2013).

Global compact
The United Nations Global Compact is a United Nations initiative leading businesses worldwide to
implement a sustainable and socially responsible policy, and to report on their impacts and results. The
Global Compact is a principle-based framework for businesses following ten principles of 4 different
areas: human rights, labour, environment and anti-corruption.
The Global Compact was announced in 1999 by the UN Secretary-General Kofi Annan and officially
launched at UN Headquarters in New York in the year 2000.
INTERNATIONAL
CSR INITIATIVES
ISO 26 000 :
2010
GLOBAL
COMPACT
(2000)
FOCUS
Management
Engagement
PRINCIPLES
SECTIONS OR ISSUES
7 principles:
7 core subjects:
Accountability, Transparency,
Ethical behaviour, Respect for
stakeholders’ interest,
Respect for the rule of law,
Respect for international norms
of behaviour,
Respects for human rights
Organisational governance,
Human rights issues,
Labour practices issues,
Fair operating practices,
Environmental issues,
Consumers issues,
Community involvement and
development issues
10 principles organised into 4 sections :
Human rights, Labour, Environment, Anti-corruption
- General standard
disclosures (7 parts)
10 principles:
Global
Reporting
Initiative (1997)
Transparency
and
accountability
Transparency; Inclusiveness;
Auditability; Completeness;
Relevance; Sustainability;
Context; Accuracy; Neutrality;
Comparability; Clarity;
Timeliness
- Specific standard
disclosures organised
into 3 categories :
Environmental,
Economic
Social (Society, Product
responsibility, Human
rights, Labor practices and
decent work)
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2.2
WHY A EUROPEAN FRAMEWORK?
European countries share a common history and, despite some differences, a common cultural
background. Above all, they share supranational institutions, which set an overall regulatory framework.
As such, organisations’ activity is increasingly dependent on, and affected by decisions from the
European Union. The European Union has also been quite active in promoting a European model and
framework for CSR. Adopting a European approach thus appears rather natural; in addition, it broadens
organisations’ perspectives, and brings added value to their CSR initiatives.

To develop a common language between different countries
As a number of smaller companies with no or limited international outreach, social housing organizations
are keen on exchanging with and learning from their European peers: experiences in other countries are
an important stimulus and “innovation booster”.
The social housing sector in Europe has developed differently in each country, depending on the
country’s organisation, politics, institution, culture and needs. Social housing models vary greatly, in
particular in terms of: tenure (right to sell, shared ownership, etc…), status of the provider (local
authorities, public companies, non-profit private companies, investors…), beneficiaries (accessible to all,
or under resources conditions, or to the most deprived households….) and funding arrangements (public
money only, subsidies, credit raised on the financial markets…)3. The position and role of tenant
representatives are also different from one country to another.
Yet, despite these differences, social housing providers in all European countries carry out a mission of
general interest, which aims at supporting and increasing access to decent housing conditions for all. And
they face today a number of similar issues across the different countries.
Similarly, CSR embraces different “shades” across countries, reflecting different contexts, priorities,
cultures: environmental challenges, social issues, dialogue with stakeholders… are diversely
apprehended, and so are the solutions developed. Legislation in some
Adopting a European countries has encouraged or triggered actions on some issues, which are still
framework
means only scarcely addressed in others. Nonetheless, expectations towards CSR
issues are converging.
looking
at
your
activity through a
European perspective.
Rather than obstacles or frontiers, these differences should be seen as
opportunities for learning and improvement through experience-sharing. A
common language is however necessary to enable an efficient exchange of
practices across countries, which is source of innovation and of useful
initiatives. A European framework for CSR helps establish this common language.
As a shared “analysis matrix” developed with social housing providers in France, Italy, Germany
and Sweden, EURHO-GR® sets the foundations for exchanges between organizations from
various European countries. Concurrently, it acknowledges national specificities: the framework’s
indicators may vary according to regulation or rules in use in the country, and some may be
added to the European basis to emphasize national priorities.

To strengthen organizations’ voice at European level
Social housing providers, anchored to their territories and closely connected to local authorities, do not
have a direct way to interact with European institutions, although these are an important stakeholder for
the sector, considering how they can impact on organizations’ decisions. Beside the European Union,
For more information on the current state and differences in Social housing in Europe, see: “Social Housing in the
European Union”, European Parliament, 2013.
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other sector’s stakeholders are organized at European level to voice their concerns, expectations,
priorities: tenants (the International Union of Tenants), local authorities (Eurocities, UDiTE…), workers
(European Trade Union Confederation), construction sector companies (FIEC, ACE…).
The sector’s funding is also partly dependent on European actors, be it public, and therefore subject to
EU’s rules and flexibilities on state aid, or private, thus dependent on international investors’ interests and
organizations’ capacity to access funding in a context of tightened competition with the private housing
sector. With regard to the latter, in order to increase housing providers’ chances to attract investment,
alternative or innovative funding is increasingly explored, such as “Socially Responsible Investment”
(which targets companies which demonstrate higher “social and environmental performance”) or “Impact
investing” (which targets “social business” actors).
For all these reasons, it is important for social housing actors to uphold and make visible, at European
level, a common vision of their Social Responsibility and contribution to sustainable development; it is
important for them to be able to present to the sector’s main European stakeholders a clear picture of
their challenges, impacts and performance on social and environmental matters. A European sector
specific framework used by a large number of providers can thus work as an effective tool to display the
major issues facing the sector, as well as its activities and impacts, and how providers tackle these
issues. It also contributes to fully underline the sector’s increasing transparency, a further argument to
bring in front of international institutions.
EURHO-GR® provides common lenses to look at CSR in social housing. It highlights the main
responsibilities of social housing providers towards their stakeholders and society as a whole.
Through common indicators, it helps not only identify issues but also demonstrate individual and
collective performance.
2.3
WHY A SECTOR SPECIFIC FRAMEWORK?
Common frameworks at international or European levels help clarify the concept of CSR to facilitate its
implementation. However, to increase their relevance and utility, it seems necessary to adopt a sectorspecific perspective. In fact, such sector-based approaches are strongly encouraged by European
institutions and national authorities, but also by the various actors promoting CSR at international level
(such as the GRI, ISO 26 000, etc.). Indeed, it appears quite obviously that the retail sector, for instance,
will not face the same issues and expectations as, for example, the banking or extractive sectors.
A sector-specific framework emphasizes the most important issues; it enables faster and better
understanding of CSR issues and results, by organisations and their stakeholders. As for CSR reports, it
ensures that the information disclosed in the reports is not superfluous, as a great amount of information,
not strictly needed, may create confusion and be overwhelming for readers. In addition, a common
reporting framework makes constructive comparison and benchmarking possible, in order to foster
excellence and constant progress.

To focus on what is important and translate CSR into very concrete terms
Not all CSR issues are equally significant for all sectors and this should be very well kept in mind by
organisations: they need to focus on what is most important and significant for them and their
stakeholders. This “materiality” principle is at the basis of CSR.
Identifying the sector’s key issues is therefore a first, fundamental step towards a CSR strategy. It would
be not only useless but also hazardous to embrace indiscriminately all issues covered by CSR. If an
organisation misses a significant concern for its stakeholders, or, conversely, if it focuses or dedicates too
much resources on issues considered as minor, its CSR strategy may seriously lose credibility.
In addition, the organisation’s employees need to be mobilized on CSR. To that aim, they need to be
“reassured”. This implies to clearly state what really concerns the organisation; it also requires to make
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sure that they understand the issues and objectives properly, and are able to correlate them to their daily
activities.
A sector-based framework addressing the sector specific issues is therefore
more relevant than a generic one, as it makes more sense to the company’s
activity. Besides, the procedure to identify the “material” issues is complex
as it takes into account several factors and expectations that weight on
opposite plates of the balance. When designed by the sector’s actors in
cooperation with the sector’s stakeholders, a sector-based framework
presents greater and justified credibility, leading not only companies but
also stakeholders to better accept it. A framework constructed on these
criteria is a helpful “ready to use” tool, which at the same time reassures
organisations and their stakeholders.
A
sector-specific
framework is useful to
identify and prioritize
which are the core
issues to be addressed
when
implementing
CSR.
Inspired by the GRI guidelines, EURHO-GR® is the result of a collective work between social
housing providers and their stakeholders, which aimed at determining together the core CSR
issues for the sector. Through tangible indicators, it “decodes” what is CSR for social housing
organisations, their staff, their stakeholders.

Benchmarking
One of the objectives of reporting on indicators is to allow comparison and benchmarking. These are two
important principles in terms of CSR for several reasons. First, to enable stakeholders to assess the
global performance of organisations, they must have adequate points of reference. Secondly,
benchmarking, when done on a relevant and reliable basis, can be of great support to organisations
themselves, to help them progress.
An article written by professors Roca and Searchy, Ryerson University4, based on a study on 94 CSR
reports, highlights how «…wide variation in the indicators disclosed hinders benchmarking efforts». The
causes are the multiple interpretations that firms have on CSR, the diverse priorities that are specific to
each sector and the necessity to adjust reporting to local context. The article also explains the risks
associated by disclosing an excessively small or big amount of indicators: ignoring some of the key
issues in the first case and rendering reports hard to read in the second one. Among other suggestions to
overcome these issues, the authors propose «..developing more prescriptive guidelines for sustainability
reporting ». They conclude that «There is a clear need to improve comparability of the indicators
disclosed in CSR reports, particularly among corporations in the same sector».
In social housing, competition mostly rises from the providers’ territory action field. Nonetheless being
comparable to organisations of other countries may be a way to look at the company through a larger
perspective and, as such, may be a lever of innovation. The comparison should however be done
intelligently, taking into account the specific contexts, constraints and opportunities: more than the figures
themselves, trends and analyses can be useful information for organisations willing to keep moving
forward.
EURHO-GR®’s common indicators facilitate benchmarking between social housing organisations
engaged in CSR, within and across countries.
4
Posted in the Harvard Law School Forum on Corporate Governance and Financial Regulation.
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3
3.1
WHAT IS EURHO-GR®?
GENERAL PRESENTATION
EURHO-GR® is a European CSR framework specific to the social housing sector. As a basis for
organizations’ CSR reporting, it is composed of key indicators reflecting the main CSR topics in social
housing.
EURHO-GR® was designed as a valuable tool to help organizations in their “materiality
assessment”, namely the identification of their priority CSR issues. The process of identification of
“material” CSR issues is absolutely fundamental as it determines the whole CSR strategy, its
effectiveness and relevance. It is nonetheless highly complex, especially for smaller organizations.
EURHO-GR® aims to help them carry out this assessment, while ensuring certain homogeneity between
organizations from the same sector. Yet, EURHO-GR® only provides a common basis for this
assessment: organizations must identify, among all topics included in the framework, the ones on which
they will concentrate their effort, according to their own strengths and weaknesses, and local needs and
stakeholders’ interests.
EURHO-GR® is
As such, EURHO-GR® is a tool conceived not just to plainly report data
but also to structure a CSR approach in line with the material issues of the
a first step in the
sector. It helps providers not only write their CSR report, but most
identification of
importantly, define, monitor and improve their CSR strategy. EURHO-GR®
material issues for
indicators enable organizations to follow progress towards their specific
objectives, while at the same time monitoring other key aspects to ensure
social
housing
that they are not neglected and deteriorating.
organizations.
EURHO-GR® indicators are categorized into five main themes, directly
related to the concept of sustainable development and its three dimensions: Social, Environmental and
Economic.
The “Social” dimension is divided into two themes: one refers to the organization’s impact and
contribution to society at large; the other relates to the workplace and the organization’s responsibility
towards its employees. The fifth theme concerns the organization’s governance, defined by the ISO
26000 standard as “system by which an organization makes and implements decisions in pursuit of its
objectives”. This theme highlights the critical importance of decision-making processes and management
in CSR implementation, and includes the key principle of dialogue with stakeholders. In order to help
analyse and compare data, a complementary section incudes key “contextual” indicators, which do not
reflect performance, but the organizations’ main characteristics.
In addition to quantitative indicators, qualitative information is also required, on issues or policies which
cannot be properly reflected through simple figures.
This structure around five sections provides organizations with a clear overall view of their global
performance, necessary to establish objectives and develop a continuous improvement approach. It
makes it also easier for stakeholders to search and find specific information within the organizations’
reports.
EURHO-GR® Structure:
PROMOTING LOCAL SOCIAL SUSTAINABILITY (SOC)
PROTECTING THE ENVIRONMENT (ENV)
ASSUMING ITS ECONOMIC RESPONSIBILITY (ECO)
PROMOTING DIALOGUE AND GOOD GOVERNANCE (GOV)
DEVELOPING HUMAN RESOURCES (HR)
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HOW WAS EURHO-GR® DESIGNED?
Defining the “material” issues on which CSR strategies will be built is naturally highly critical. The
process must ensure that key impacts and stakeholders’ concerns are taken into account.
The EURHO-GR® framework was defined in 2006-2007, through a process led by a French network
of social housing companies, DELPHIS, with the support of an external consulting firm specialized in
sustainable development and stakeholder dialogue, for an inclusive, neutral and professional
approach. The key topics and indicators were identified through workshops with social housing
companies and representatives of their main stakeholders: tenants, local authorities, employees,
architects and construction enterprises, funding partners, etc. This participative method was essential
to highlight stakeholders’ interests; it also aimed to ensure the framework’s acceptance and
legitimacy. EURHO-GR® was afterwards discussed within the CSR Topic Group of the European
network EURHONET. Social housing organizations from Sweden, Germany and Italy selected the
issues relevant to them, considering their national context and their stakeholders’ concerns. This led to
a common European basis, and some country-specific indicators.
The framework was then progressively enriched and improved by EURHONET’s CSR Topic Group.
On the one side, indicators were modified to facilitate data collection and calculation, and increase
their reliability. On the other side, indicators were added to reflect emerging issues in the social
housing sector or the CSR field (in particular with the publication of the ISO 26000 standard in 2010).
In 2012-2013, a major revision process was carried out to simplify EURHO-GR® and reduce the
number of indicators, to focus on the most significant aspects. A first pre-selection was done by social
housing organizations from the four countries. It was based on their experience and their stakeholders’
feedback, but also on other CSR frameworks (ISO 26000 and GRI in particular) and discussions within
a working group of the European federation of social housing (CECODHAS) on the sector’s Key
Performance Indicators. This selection resulted in a common European basis of XX key indicators, to
which can be added qualitative information and up to XX country-specific indicators (to reflect national
issues and ensure coherence with national CSR frameworks).
In short, EURHO-GR® indicators’ were determined according to the following criteria:
 voluntary and regulatory frameworks linked to CSR issues;
 stakeholders’ interests and concerns;
 social housing’s impacts;
 organizations’ latitude and capacity to address these impacts and concerns.
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3.2
EURHO-GR® SECTIONS
PROMOTING LOCAL SOCIAL SUSTAINABILITY
Main stakeholders
concerned:
Linkages with other
frameworks:
Local authorities
Tenants and housing applicants
ISO 26000 Core subjects: “Consumers’ issues”; “Community development”
GRI categories: Social (Society; Product Responsibility)
The first section of the framework reflects primarily the organisation’s performance with regard to its core
mission and ambition: providing affordable quality housing to all. This is sub-divided into two subsections, one relating to the contribution of organizations to local communities’ housing supply
(responsibility as a housing producer); the other relating to their responsibility towards their clients
(responsibility as a landlord).
Lastly, a third section reflects organizations’ involvement in communities’ quality of life and cohesion
(engagement as a local actor).

Responsibility as a housing producer: providing a diversified housing supply to respond to
local needs
The first subtheme accounts for the organization’s contribution to the local housing supply, according to
the needs of the territory, both in terms of quantitatively and in terms of housing characteristics.
Indeed, building new dwellings can be of little or no use if they do not correspond to the real local
necessities. Communities with a large population of university students or young professionals, for
example, will require smaller dwellings, while in areas with large families or a high demographic growth,
the priority will instead be to provide larger, multi-room dwellings. In areas with no population growth,
providers will focus on the renovation and quality of the housing stock rather than on the construction of
new dwellings; conversely, where there is a major housing shortage, the growth of the housing stock is
obviously fundamental.
A particular focus has been placed on ageing households and people with disabilities. Indeed, ensuring
housing access to all also means addressing the particular barriers encountered by inhabitants with
physical mobility issues, who very often face greater difficulty to find suitable dwellings and decent
housing conditions.
Population ageing is a great challenge for all European countries, creating a growing demand for
dwellings adapted to their needs (considering mobility and autonomy constraints). Even when nursing
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homes exist, the great majority of the elderly aspire to stay at home at long as possible, where they have
lived for years, close to their families and within their social network. In addition, nursing homes are
expensive to build and manage. When public run, they represent a significant cost for communities, and
the final fare for residents is generally very high, often even higher than their incomes. In some countries,
residents receive social benefits to cover these costs (from the State or local authorities), which can
engender substantial public expenses.
Providing “adapted” dwellings, suited to the needs of elderly people, thus responds both to households’
and public bodies’ demands. It contributes to national and local “ageing at home” policies, and addresses
a priority of the European Union: tackling population ageing, one of the major socio-demographic
challenges of the 21st century.
 Responsibility as a landlord: responding to tenants’ needs and ensuring their quality of life
This subtheme relates to consumers’ issues, namely impacts organizations may have on tenants and on
their quality of life, and how they meet their expectations.
A first issue relates to housing cost, including both rents and running costs, which is a major issue in
all European countries. Housing costs represent a large share –if not the largest- of households’ budget,
reducing their available resources to address other essential needs (food, health, education…): in 2009,
Europeans spent on average over a fifth of their income on housing (22,9%) 5, and this has probably
increased since, as a consequence of the economic crisis and subsequent population’s impoverishment.
To address these issues and tenants’ needs, housing costs should not only be as limited as possible, but
should also not increase too much and too rapidly. Indeed, a sudden increase in housing costs can
severely disrupt households’ budget, potentially leading to difficult situations, such as debt.
Social housing providers’ latitude is however often limited. Housing providers need to carefully balance
tenants’ costs with their own financial constraints and needs to maintain the quality of the housing stock
and, where relevant, invest in the production of new dwellings. Besides, in some cases, they may not be
able to impact much on running costs, largely dependent on external factors (such as energy costs and
tenants’ consumption patterns); in some countries, the progression of rents is also very strictly regulated.
Yet, considering the importance of this issue and for transparency purposes, EURHO-GR® includes
indicators on both the progression of rents and of running costs (where data is available). This provides
valuable information both for tenants’ representatives and local authorities.
In relation to this, another important issue relates to the support provided by housing providers to
tenants when they face economic or social difficulties. Social housing providers’ clients tend to be
more vulnerable, more exposed to socio-economic hazards and psycho-social disorders, which can lead
to unpaid rents, improper use of their dwelling or nuisances affecting other tenants’ quality of life. Housing
providers need to address and prevent these situations, in order to limit financial loss but also to avoid
tenant evictions and their dramatic consequences on households. More generally, it reflects housing
providers’ engagement towards their tenants, often in cooperation with local public and social actors.
Tenants’ interests also concern their health and safety, in their dwelling and its surroundings. Social
housing is often associated with “difficult” urban areas. Indeed, many housing providers –though not all of
them- operate in neighbourhoods experiencing security issues. Tenants’ feeling of safety in their housing
environment is then an important matter in terms of their quality of life. It should be monitored and taken
into account by housing providers, within the limits of their responsibilities and without endorsing the
mission of public security forces.
Lastly, this sub-section includes the topic of tenants’ mobility within providers’ housing stock. This
reflects both providers’ ability to accompany and respond to tenants’ evolving needs (in terms of
dwellings’ size, location, rent, etc.), and to what extent providers are able to retain their clients. This
matter also refers to an issue often raised in the social housing sector: barriers to tenants’ mobility and
“housing pathways”.

5
Engagement as a local actor: promoting communities’ diversity, cohesion and quality of life
Source : Eurostat
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The third sub-section reflects other forms of housing providers’ action to the benefit of the communities in
which they operate, which are closely connected to their primary mission.
This engagement concerns primarily two major aspects: investments, in particular in urban renewal and in
areas with specific needs; and social cohesion initiatives, to support social integration and social link.
It shows housing providers’ voluntary contribution to local policies and programs aimed at improving
quality of life in under-privileged areas, reducing inequalities and preventing exclusion.
PROTECTING THE ENVIRONMENT
Main stakeholders
concerned:
Linkages with other
frameworks:
Local authorities
Tenants and local residents
Environmental actors (associations, NGOs…)
Future generations
ISO 26000 Core subjects: “Environment”, “Consumers’ issues”
GRI category: Environmental (Energy, Water, Emissions, Waste)
Environmental regulation today covers many aspects of social housing activity; nonetheless, housing
providers’ impact and performance on environmental matters varies greatly, and while some simply
comply with the law, others make a significant effort to go further.
EURHO-GR® second section refers to providers’ effort and impact on the environment, at different levels:
their housing stock (climate change and energy consumption; residential sector’s environmental
impact); and their own practices (environmental responsibility as an organization).
 Limiting housing stock’s impact on climate change and energy consumption:
Climate change due to greenhouse gas emissions is a key environmental issue in today’s society, and
a priority of environmental policies at European and national levels. The environmental component of the
European Union’s strategy “Europe 2020” indeed focuses on climate change and energy sustainability. It
relies on three targets: reducing the level of greenhouse gas emissions in 1990 by 20%; 20% of
renewable energy within the overall gross final energy consumption; improving by 20% energy efficiency.
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Housing providers are particularly concerned, considering that buildings are responsible for 30% of GHG
emissions in Europe, and the housing sector has been identified as the most efficient leverage on overall
GHG emissions. Besides, energy consumption has a significant impact on tenants’ bills and represents a
growing share of their housing budget. Improving energy efficiency thus not only reduces providers’
environmental impact, but also contributes to their social objective of limiting tenant’s housing costs.
These issues are reflected through dwellings’ energy performance and GHG emissions, as well as the
share of dwellings relying totally or partially on renewable energy.
 Reducing the environmental impact of the residential sector
Although energy consumption and greenhouse gas emissions draw most attention, the housing sector
also impacts on a number of other environmental aspects, including water consumption and waste
management.
Providers’ power to significantly act on these impacts is however more limited than on the issue of energy
efficiency and emissions. Indeed, whereas providers can invest in buildings’ environmental quality, water
consumption and waste management are much more dependent on other actors: tenants, in priority,
through their habits and consumption patterns; but also local authorities, in particular on the question of
waste management.
These environmental issues should thus be addressed by providers directly (through specific equipment
for instance), but also indirectly through tenants’ awareness-raising, to provide further knowledge on
environmental issues, and on possible solutions and contributions that every single citizen can make.

Environmental responsibility as an organisation: promoting sustainable production and
behaviours
A social housing organisation should not only account for its impacts with regard to its housing stock, but
should as well report its action and environmental performance as an organization. Even though the
environmental impact related to the organization’s operation and functioning is more limited, taking action
at the organization-level is important to show full engagement and provide exemplarity.
This sub-section focuses in particular on the organizations’ awareness-raising action towards its sphere
of influence, beyond tenants, through campaigns and information targeting their employees and suppliers.
In addition to spreading “environmental-friendly” practices, it also helps ensure that the organization’s
essential partners also contribute to its environmental objectives.
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ASSUMING ITS ECONOMIC RESPONSIBILITY
Main stakeholders
concerned:
Linkages with other
frameworks:
Local authorities
Suppliers and service providers, and local economic actors
Shareholders and funding partners
ISO 26000 Core subjects: “Fair operating practices”; “Community
development”
GRI category: Economic
An organization’s economic responsibility relates to two main dimensions. Its first responsibility is to
ensure the continuation and development of its activity (responsible management). Secondly, it refers to
its impact on its economic environment and relations to economic actors (contribution to a sustainable
and responsible economic development). In a context of major economic recession, this second
aspect becomes particularly significant not only for the organizations’ providers’ financial health but for
the entire community’s sustainability as well.
 Responsible management to maintain and develop the activity
Social housing providers operate according to specific funding and financial rules, which differ between
countries. They are not driven by the same profitability objectives as ordinary market actors. As such,
traditional financial ratios and indicators are not relevant. However, a sound financial management is
critical, in order to be able to make the necessary expenses to provide quality services and maintain their
housing stock’s condition. This is partly reflected by the net cash-flow. Conversely, the vacancy rate gives
an indication on the organization’s financial loss due to sub-optimal occupation; it also mirrors the housing
stock’s attractiveness, and shows to what extent it corresponds to local needs and inhabitants’ aspirations
(although this data should be very carefully analysed, taking into account the local context).
Annual investments and expenditures dedicated to the housing stock development and quality are
therefore also reported in this topic. They show, on the one hand, how the organization spends its
revenues and re-invest them to the benefit of local communities and tenants; on the other hand, they
represent the organization’s effort to ensure its own sustainability, through a good stock management
aimed at maintaining its attractiveness and, therefore, its potential for revenue generation for the
organization.
 Contribution to a sustainable and responsible economic development
Among others, the above-mentioned investments also contribute to the global (and local) economic
dynamics. Beyond suppliers, the organization’s expenses represent revenues for other actors: employees
(salaries and social protection expenses), the State and local authorities (fiscal revenues), banks,
shareholders… This breakdown of expenses thus represents the organization’s “value redistribution” and
“shared value” creation; it reflects how the organization contributes to and supports the wider economic
growth.
The significant amount of organizations’ investments increases their responsibility towards their suppliers,
which can be highly dependent on their contracts with housing providers. Moreover, some of these
providers, in particular in the construction sector, are rather small companies. For these reasons, and
given the current economic context, the average settlement period has been identified as a key issue in
terms of housing providers’ economic responsibility.
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PROMOTING DIALOGUE AND GOOD GOVERNANCE
Main stakeholders
concerned:
Linkages with other
frameworks:
Governance bodies
External stakeholders, in particular tenants
ISO 26000 Core subject: “Governance”
GRI Standard Disclosure : Governance
As for the economic section, this theme concerns an internal dimension (responsible decision-making
and management structures and systems) as well as an external one (respect for stakeholders’
interests and relations to stakeholders). Organizational governance is critical in terms of Social
Responsibility. It is key to ensure respect for CSR principles throughout the organization and the
integration of sustainable development considerations into decision making processes.
However, this theme is particularly difficult to measure and monitor through quantitative indicators. The
number of indicators in this section is therefore very limited; the qualitative information provided in the
narrative sections of the report is thus an essential complement.
 Responsible decision-making and management structures and systems:
This sub-section includes two indicators.
The first relates to the organization’s management systems’ certifications, which give credibility to the
organization’s policies. It reflects the organization’s effort to structure, increase efficiency and to take into
account stakeholders and the environment in its overall management, according to recognised criteria
and third party evaluation.
The second indicators reflects actions taken in order to ensure gender balance in management boards.
Studies suggest that insufficient diversity among Board members and Executive Directors tends to impact
negatively on companies’ performance. Indeed, the lack of variety in perspectives and approaches may
lead to a narrower analysis, less debate and less challenge of management decisions, thus reducing
governance bodies’ effectiveness. Board diversity may also help better understand and integrate different
stakeholders’ interests. Gender is only one component of diversity, but has seen increasing attention from
society and public authorities. Thus, following examples of national regulation (in France and Norway in
particular), a 2012 Directive proposal submitted by the European Commission aims to promote a
minimum of 40/60 gender ratio among non-executive Directors of listed companies.
Other issues pertaining decision-making processes and structures include the overall composition of the
Board, Board information and evaluation processes, as well as awareness-raising, training and control on
ethics-related issues, to be described through narrative sections included in the reports.

Respect for stakeholders’ interests and relations to stakeholders:
Stakeholders’ interests are at the heart of a CSR approach and it is important to show how they are taken
into account in decision-making processes. This aspect is however extremely difficult to express through
quantitative measurement. Therefore, only one indicator is included in this sub-section, focusing on
tenants’ satisfaction measurement (employees’ interests are included in the next section dedicated to
human resources).
Tenants’ satisfaction surveys are an essential tool:
- to monitor to what extent the organization indeed meets its customers’ expectations;
- and to collect their concerns and views on improvement priorities.
Carrying out regular surveys and making effective use of results to define improvement action plans is
thus one way to identify and integrate tenants’ interests into management systems.
Besides satisfaction surveys, other mechanisms can be used to carry out an open and regular dialogue
with tenants and local authorities, organizations’ main external stakeholders. These are described in the
reports’ narrative sections.
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DEVELOPING HUMAN RESOURCES
Main stakeholders
concerned:
Linkages with other
frameworks:
Employees
Employee representatives
Job seekers
ISO 26000 Core subjects: “Human rights”, “Labour practices”
GRI Category: Social (Labour practices and decent work; human rights)
This last section refers to organizations’ responsibility towards their employees (and job seekers) in terms
of access to employment and non-discrimination (equal opportunity and treatment in employment), of
competences and evolution (professional development of employees), health and safety at work
(good working conditions and work-life balance), as well as, more generally, employees’ interests
(respect for employees’ interests).
 Equal opportunity and treatment in employment
A first topic within this sub-section relates to the organization’s contribution to stable employment, and
integration into employment through training schemes, reflected by the breakdown of employees per type
of contract.
Discrimination has been lately a largely discussed topic. Gender equity, in terms of access to employment
but also of remuneration, is becoming more than a simple society expectation, as it has already been
regulated through various laws in some countries. The European Union estimates an average “gender
pay gap” (pay differential between men and women, for a similar type of employment) of 16% in EU
countries, to the detriment of women. This raises up to 31% when considering the higher proportion of
female part-timers. Besides gender, age is also a major discrimination factor, as evidenced by much
higher unemployment rates among young people and seniors.
Lastly, this sub-section includes the organization’s effort to promote access to employment of more
vulnerable people, such as people with disabilities, long-term unemployed, etc.
 Professional development of employees
Social housing organisations and professions in the sector are changing with the evolution of society and
of the economy. Supporting the development of employees’ knowledge and skills is essential to maintain
their employability. It is also an increasing demand from employees, fully aware of the necessity to adjust
to changing contexts and working methods.
Through training and professional development, the organization also contributes to individuals’ selffulfilment and well-being, beyond the workplace and company’s needs.
 Working conditions and work-life balance
Health and safety at work is naturally a major responsibility of employers. In addition to physical safety
(work-related accidents and diseases), the issue of work-life balance has emerged in the latter years, and
is a growing concern, closely related to psychosocial risks at work and gender balance. As such,
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voluntary part time contracts reflect organizations’ effort to take into account its employees’ constraints
and aspirations.
 Recognition of employees’ interests
Like tenant’s satisfaction surveys, employees’ satisfaction can be assessed through a specific survey,
increasingly popular and frequent among organizations. Such surveys provide a basis to identify workers’
expectations and subsequently define actions to improve their satisfaction. Employees’ satisfaction is not
only an important objective for any responsible organization, but it is also a significant driver of
employees’ engagement, increasingly recognized as a major factor of organizational performance.
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4
CSR REPORTING AND REPORTS: WHAT FOR?
Through its set of indicators, EURHO-GR® serves as a basis for social housing organisations’ CSR
reporting and narrative reports, two essential aspects of CSR.
Reporting and reports are first of all a fundamental component of the “accountability” principle inherent to
CSR; but they also support various other objectives, internally and externally.
What difference between reporting and report?
“Reporting” is hereafter understood as the regular data collection and monitoring against precise,
factual, and mostly quantitative, indicators. It thus results in a “scoreboard” of indicators and
corresponding data. CSR reporting is intended for both internal and external purposes: at internal
level, it helps assess progress and identify actions needed to continuously improve the CSR strategy;
at external level, it supports transparency and accountability towards stakeholder by providing clear
and objective data on the organization’s global performance and impact.
We call here “CSR Report” the combination of reporting (indicators) and a narrative analysis and
description. CSR reports are primarily aimed at external stakeholders, although they are also
important tools to promote and explain the CSR strategy internally. Reporting and reports are
complementary one to the other: reporting is inseparable from a narrative report providing a comment
of the company’s strategy and of its operational context. Indeed, indicators lose sense if not completed
by comments and further explanation on the context and on how and when actions were implemented,
goals achieved or failures experienced. At the same time a narrative report, as good as it may be,
lacks credibility and reliability, and therefore loses weight, if facts are not supported through solid data.
In fact, the proliferation of “CSR reports” or “Sustainability reports” in recent years came along with an
increase in “green-washing” highlighted by a number of NGOs, as well as a number of environmental,
social, human rights or health and safety scandals. Citizens and civil society organizations have
subsequently become ever more suspicious towards “CSR communication”. Story-telling is not
enough anymore: stakeholders are in demand for facts and figures, evidence and demonstration of
companies’ effort and results.
4.1
PUTTING KEY CSR PRINCIPLES INTO PRACTICE
Deriving directly from Social Responsibility principles, accountability is the first motivation for writing and
publishing a CSR report. The report aims at demonstrating to stakeholders the organisation’s
commitments, actions, impacts and results in terms of CSR.
The report’s primary objectives are thus:

Demonstrating accountability and transparency
A CSR report responds to the first two principles of CSR, accountability and transparency. A “responsible
organization” cannot disregard these major principles; otherwise, it may lack coherence between its
engagement in CSR and the principles driving the approach.
Reporting on your
To fully meet the accountability and transparency principles, the report should
rely on factual, objective, and if possible quantified information and data: it
actions and impacts
should not only describe actions, but demonstrate, as accurately as possible,
is part of what is
organizations’ impact and performance. A reporting system is therefore
expected from a
indispensable.
responsible company.

Responding to (stakeholders’) expectations
Having access to reliable “non-financial” information is one of the first demands of civil society and of
stakeholders in general, reflected in the recent regulation. Responding to transparency and accountability
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expectations, through updated, exhaustive and verifiable information is thus a duty of any socially
responsible organisation.

Engaging in dialogue with stakeholders
A CSR report is at the very basis of the relation with stakeholders. A CSR report be a useful tool to initiate
or reinforce dialogue, and build a relationship based on mutual trust, as it enables organisations to
disclose their impacts, and explain their activities, their constraints, their strategy. Involving stakeholders
to in the report writing process, either through “interviews” included in the report, or through a report
review process with a “stakeholder committee”.

Formalizing and asserting its engagement and commitments
Formalization is key in CSR implementation: if not supported by official and visible documents, as well as
written evidence, an organization’s engagement, values and objectives may seem vain and empty.
Engaging in CSR means officially committing to a number of objectives towards its stakeholders. This is
indeed an integral part of accountability: stakeholders must be informed of the organisation’s key
orientations, so that they can assess its performance and progress against the set objectives.
Anticipating reporting obligations
A European framework on companies’ non-financial reporting is currently under discussion, following
a proposal from the European Commission (see p. XX). Although the specific modalities proposed by
the Commission may be modified, it is clear that companies will be more and more required to
monitor and disclose information on society and environmental matters. Some countries, like France
and Denmark, have already passed such legislation.
Even if the current rules target in priority listed and large (over 500 staff) companies, their scope is
likely to expand progressively to reach smaller firms. Besides, disclosure by some major companies
in a business sector will undoubtedly raise the sector’s stakeholders’ expectations towards all actors,
and thus gradually set “standards” in terms of accountability.
4.2
4.2.1
BEYOND CSR PRINCIPLES: SUPPORTING CSR IMPLEMENTATION AND VISIBILITY
To support continuous improvement
A further motivation to a CSR report is the contribution of reporting and reports to the CSR continuous
improvement approach (see chapter XX), which requires being able to measure and assess progress and
weaknesses.

Monitoring and measuring progress
Monitored indicators show precisely the progress (or stagnation) of the organization relatively to CSR
matters. They are indispensable to assess the effectiveness of the CSR actions and strategy: to identify
the successes as well as the needs for improvement, for reinforcement. Besides, objectives which are not
monitored are not credible – internally and externally-, and, very often, end up being neglected, forgotten.
CSR in itself is about managing its impacts as an organization (to increase positive effects and limit
negative ones). How can something be managed, be under control, without measurement and regular
assessment?

Analysing performance and identifying improvement needs
Figures alone though are clearly not enough: actions and practices should also be analysed from a
qualitative perspective. Beyond data, the organization should examine the potential difficulties
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encountered. It should keep a close eye on the context and its evolution, to regularly question the
relevance of its objectives and actions, and readjust them if necessary.
Clarifying whether the preventive and corrective actions implemented have been useful and/or properly
presented and explained can help identify needs for improvement. Analyzing the triple performance
(economic, social, and environmental) is a way of understanding if the strategy deployed is effective, or if
further modifications are needed.
A CSR report is an excellent opportunity for a comprehensive review. CSR reports, displaying information
on all different dimensions and data of all departments provide a global, detailed vision on the different
aspects of the activity and the organization’s overall performance.
It sets an annual milestone which forces organisations to carry out this in-depth analysis of their actions
and results. The report-elaboration process should be used to foster collective introspection through
internal discussions on the CSR strategy; the tangible output – the report- can then be used to then
display and explain the main conclusions and new objectives to the staff.
4.2.2
To increase visibility
Another motivation for reports is to give visibility to the organisation’s CSR strategy, with the aim of
promoting the approach externally and internally. In this case the report’s objectives are:

Internal mobilisation
Displaying through a report what has been achieved during the year is certainly a way to acknowledge
and praise the effort made by employees and managers towards CSR. It helps make CSR official and
strategic to the eyes of the entire organisation and to highlight the successes
achieved in this field, such as reached objectives, obtaining certifications or
It must be
labels, good initiatives and/or well conducted partnerships.

External promotion
A CSR report, whether printed or in an electronic version, is the most effective
and complete tool to promote an organisation’s CSR actions and results. It helps
forge the organisation’s image as a responsible actor and contributes to its
reputation and differentiation strategy, in particular locally. By showing all actions,
objectives, results and difficulties, the organization provides useful information on
its CSR approach. It highlights how it can benefit to, or from, other partners’
policies and actions (local authorities in particular), and underscores the “shared
value” it creates. In return, wide promotion and external recognition of the
company’s achievement also supports staff mobilization, by fostering satisfaction
and pride.
remembered that,
if communication
is important and
CSR reports are
essential, they are
just one output of a
CSR policy, and
not its purpose!
4.2.3 To raise awareness on CSR issues
The last motivation underlying a CSR report is to raise awareness on social responsibility and sustainable
development, within and outside the organisation. With this “educational” ambition, the report’s function is
to explain what is CSR, and how it is implemented in the company.

Raising awareness
By presenting the issues, constraints and expectations related to CSR in social housing and to the
organization, in its own context, a report enables to explain the organisation’s trade-offs and justify its
choices. Moreover, CSR reports contribute to raise awareness and inform readers on today’s issues
related to sustainable development, which is also part of an organisation’s responsibility towards society.
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
Making CSR concrete
CSR still remains, for many, an ideal or a nebulous notion. Reports help give consistency to CSR: it
shows, through descriptions, explanations and illustrations, what it means, concretely, for the oganisation.
Having a tangible support to look at and read also helps to give sense to CSR actions internally, and
spread CSR to those in the organization who are less involved in its implementation, or those who remain
skeptical or unconvinced by the utility of CSR.
4.3
4.3.1
REPORTING WITHIN CSR IMPLEMENTATION
Reporting as the main tool for CSR management review
Reporting is obviously the central part of the “Check” stage of a CSR management system. It makes the
link between CSR implementation, improvement actions and planning: it enables to readjust or set new
objectives, based on results’ assessment.
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4.3.2
Using CSR reporting for the baseline analysis
Beyond regular monitoring, CSR reporting can be used to carry out the baseline analysis, at the initiation
phase. Indeed, a certain number of social housing providers launched their CSR strategy with a report: it
enabled to produce a first baseline analysis, an overall picture of the situation, to then set priorities and
objectives. At the same time, it sends a strong signal, internally and externally, on the organisations’
decision to formally engage in CSR.
When used for the baseline analysis, the first reporting exercise is particularly important. It should be
carried out thoroughly, and lead to an extensive investigation of the organisation’s practices and actions.
Most of the time, some data is missing: not all indicators can be readily filled in. This is not an obstacle;
rather, missing data can be an indication on the organisation’s level of awareness and action on the
issue.


Available data should be analysed, against set objectives, or compared to the sector’s average for
instance;
In case of missing data, the reasons for the data’s absence shall be identified: is it because this
issue has never been considered before? Are there actions on the issue, even though not monitored
through quantitative indicators? If no action is carried out on the issue, why is it so?
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Lastly, in all cases, beyond indicators, some key questions have to be addressed in order to properly
identify improvement opportunities:

« What shall we do on this subject? »
 « Are we doing enough»? / « Could we do any better»?
 « Are these actions systematised? Are there precise objectives? Are they monitored? »
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5
CSR REPORTING WITH EURHO-GR®:
The EURHO-GR® reporting framework was developed in the late 2000s, as a means to encourage and
help social housing organisations meet the fundamental CSR principle of “accountability”, considered as
particularly essential in this sector. More than a simple tool or list of indicators, EURHO-GR® corresponds
to a philosophy, a certain viewpoint on CSR reporting, reflected by a number of rules to follow.
This section presents the key rules underlying the creation and use of EURHO-GR®, as well as some
recommendations on how to set up and manage a CSR reporting system.
5.1
EURHO-GR® FUNDAMENTAL PRINCIPLES
EURHO-GR® relies on a number of basic
principles, mainly drawn from the Global
Reporting Initiative Guidelines. They guided
the reporting framework’s development, and
determine a number of rules that EURHOGR® users have to follow.
EURHO-GR® Principles:
Principle n°1: Reporting must be global
Principle n°2: Reporting must be relevant
Principle n°3: Reporting must be clear and understandable
Principle n°4: Reporting must be regular
Principle n°5: Reporting must be pluriannual
Principle n°6: Reporters must « Comply or explain »
Principle n°1: Reporting must be global
It must cover:
all CSR dimensions (social, environmental, economic) and the major impacts of the activity
all key issues for the sector (and not only those that are better managed by the company)
impacts on external and internal stakeholders
Partial or selective data communication, deliberately ignoring some key aspects of the organisation’s
impact and responsibility, is indeed not compatible with the principles of accountability and transparency.
It greatly weakens the reporting’s relevance and reliability, and reduces the organisation’s capacity to fully
monitor and manage its impacts and results.
 The five main sections of the EURHO-GR® framework cover all dimensions of CSR.
Principle n°2: Reporting must be relevant
The first principle should nonetheless be balanced with the imperative of “materiality”: an organisation
should provide a comprehensive vision, but must focus on what really matters. An excessive number of
indicators is not only nearly impossible to monitor, but also undermines the effort towards transparency,
as it makes it difficult for readers to understand the organisation’s real impacts and strategy.
It is thus necessary to concentrate on what is essential, with regard to the sector’s issues and
stakeholders’ interests. Indicators should measure, where possible, impacts and results, rather than
means.
 To ensure its relevance, EURHO-GR® was co-constructed with representatives of the sector’s
main stakeholders. It besides includes country-specific indicators, to reflect concerns which are
particularly important in some countries, but may not be relevant in others.
Principle n°3: Reporting must be clear and understandable
Indicators have to be clear and understood by the organisation’s employees and external readers.
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They have to rely on commonly accepted and well known notions, expressed in clear measurement units
(€, m2, %...). Indicators which are too complex to measure and understand should be avoided.
Some aspects are hardly quantifiable and measurable. Qualitative indicators or description may then be
included (for example: responsible procurement policy).
 Social housing providers’ stakeholders are mostly local. Therefore, some indicators vary from
one country to another, to adjust to the national common usages, measurements and units, and
thus ensure that they are properly understood by those who monitor and read them.
Principle n°4: Reporting must be regular
Information has to be provided on a regular basis, at least through an annual publication. Yet, some
indicators can be measured, internally, on a shorter periodicity, to enable quick reaction when needed.
 EURHO-GR® reports are published every year.
Principle n°5: Reporting must be pluriannual
As per CSR philosophy and long-term sustainability objectives, information should be disclosed on
several years. This enables to show and explain trends and evolutions, which are more significant in
terms of actual change and impact on society and environment. It also reflects the organisations’
progress towards its objectives, thus measuring the effectiveness of its actions and investments, and its
effort in “continuous improvement”.
 EURHO-GR® reporting tables display data on three consecutive years.
Principle n°6: Reporters must « Comply or explain »
Lastly, EURHO-GR® has fully adopted the now internationally recognized principle of “Comply or
explain”. Indeed, some organisations may not be able to provide all data, or may not want to disclose
some particularly sensitive information. In those cases, some flexibility is allowed, provided that the
transparency principle is respected: when data is not provided, the organisation must explain why, be it
due to confidentiality reasons, or because the organisation’s information system does not enable to
measure the requested indicator.
 EURHO-GR® includes a common legend to explain missing data: specific symbols are used for
three different situations: 1. Data is not available; 2. The organisation does not want to disclose
the data; 3. Indictor not relevant for the organisation on that year (for example: no new production in
2012, so the indicator on the typology of new dwellings is not relevant).
As a result of these principles, EURHO-GR® users must:
1. Display all indicators of the EURHO-GR® framework (even it data is
missing) in use in their country;
2. Disclose data on three successive years;
3. Comply or explain: in case some data is missing, the common legend
shall be used to explain why;
4. Use the collectively agreed indicators’ titles and calculation formulas;
5. Publish a report every year.
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Be honest: Tell what you do… and do what you tell!
Communicating also means exposing yourself. Once data and statements are available to all,
stakeholders will be willing to check whether what is declared corresponds to what is actually done.
The organisation must be ready to respond to stakeholders’ expectations; it must be ready to explain
why its objectives may not always be met as expected; it must be ready to accept criticism.
In addition, it must be fully aware that false information, inexact data, or weak coherence in CSR
implementation (“green-washing” or “social-washing”) may deeply affect your relation to stakeholders.
It raises suspicion and breaks the “confidence bond”. In some cases, it can even lead to strong
opposition and conflict. This is highly damageable not only to your collaboration with your
stakeholders, but also to your overall image and reputation.
5.2
SETTING UP A REPORTING SYSTEM
The set-up of a CSR reporting system is a proper project in itself, and should as such not be overlooked.
It should be carefully planned and implemented in order to ensure the understanding and full contribution
of those concerned by the reporting process.
Below are some guidance and recommendations to help organizations set up their CSR reporting
process and system.
Main steps:
1. Top management commitment
As well as for the whole CSR implementation process, formal and visible commitment at the highestlevel of the organization is fundamental to ensure the project’s success, and stress the importance given
to reporting. The management must be fully aware of the implications of CSR reporting, in particular in
terms of transparency and recurrence over time.
2. Mobilisation
When not well explained, CSR reporting is often perceived as a useless, time-consuming burden to
everyday tasks. In order for employees to actively cooperate, it is necessary to explain the purpose of
reporting and its essential place in the CSR strategy and CSR management (see chapter n°). This also
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contributes to value the effort carried out all throughout the data collection and treatment process. At the
same time, it is necessary to reaffirm that reporting is only a CSR tool, a step in the whole strategy, but in
no case the ultimate purpose of CSR.
3. Planning
As for any project, roles and responsibilities must be clearly defined, along with a precise schedule.
Roles and responsibilities:
Data collection cannot be the sole responsibility of one person: not only would it be very demanding, but,
more importantly, reporting would then lose much of its interest, as it would not be done by those in a
position to analyse and use the data. On the contrary, each of the organization’s departments must be
responsible for collecting and analysing the data corresponding to its activity (with the support of the
Information management department if needed). Some data may concern several departments; in such
case, the responsibility for data collection and monitoring should be clearly defined and coordination
between the concerned departments must be ensured.
Therefore, at the reporting system set-up stage, it is recommended to set-up a “project group”, gathering
at least one person (a “pilot”) per department, and led by a coordinator in charge of overseeing the
system’s set-up and centralizing all data, in particular for the report’s publication.
The coordinator needs to have a global vision of the organization’s activity and different departments.
He/she must also be able to carry out an internal, transverse project, which requires project management
and group facilitation skills, but also leadership and charisma. His/her legitimacy towards other
departments, including heads of departments, is essential to be able to efficiently run the project; clear
support from the top management may be required.
The departments’ pilots will be in charge of disseminating all necessary information within their respective
departments, and defining the responsibilities and planning for their own department’s data collection.
When pilots are not the department heads themselves, they must be closely supported by the latter.
Defining the schedule
A precise schedule is necessary to ensure that data is collected on time for the CSR report, and for
effective project implementation.
It should include the following steps:
- review and explanation of the reporting framework
- identification of available data
- development of data collection tools (including evidence materials)
- reporting test, including: staff training, data collection, tools’ adjustments.
It is recommended to conclude this pilot project with the publication of a first CSR report, which
“materializes” the reporting exercise through a tangible output disseminated internally and externally.
Experience shows that setting a clear objective of report publication creates a good incentive, whereas
choosing not to publish the first report undermines the reporting process.
4. Review and explanation of the reporting framework
In order to ensure correct reporting against the set indicators, a comprehensive review of the reporting
framework is to be carried out with the project group, with the following objectives:
- Clarifying the frameworks’ indicators to ensure proper understanding of their meaning and purpose,
in line with the CSR strategy;
- Appointing, for each indicator, the department responsible for its measuring and monitoring, as per
the corresponding CSR issues;
- Clarifying the indicators’ calculation methods;
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- Answering all potential questions raised by the various contributors on indicators’ signification or
composition.
It is important to involve the actors who are in charge of collecting data, and listen to their issues as well
as to their suggestions. This is not only operationally essential, but also helps overcoming potential
resistance and soothes the feeling of frustration that may be caused by a new and unexplored task.
Moreover, contributions from employees are useful inputs for further improvement of the reporting
framework, together with the other user organizations.
To that aim, national EURHO-GR® guidebooks and tools were developed, providing detailed
explanations and specifications on indicators’ calculation methodology, aimed at ensuring
harmonized indicators’ measurement at national-level and facilitating data collection.
5. Identification of available data and needs for new data collection tools and processes
Organizations already use a number of data that are regularly monitored, either for internal purposes or to
be communicated to external actors (such as public authorities for example). The project group will
therefore first identify, among the set indicators, those relating to available data, which do not require
specific collection tools or processes and can be collected quite rapidly.
6. Development of data collection tools and processes
As for the missing elements, appropriate collection and measurement tools and methods
(who/when/how?) need to be developed, while relying as much as possible on existing reporting and
databases. The more complex data may require developing fully new reporting instruments (including, for
example, surveys, procedures, etc.). In that case, the organization can decide to postpone the calculation
of this data to the second reporting cycle, leaving more time to the development of the appropriate tools
(it will thus explain in the report that the data is not yet available).
Along with data collection tools, it is necessary to define “traceability elements”: procedures describing
precisely the scope (which elements to include in the calculation), the sources to be used, etc; as well as
evidence documents (such as signed contracts or certifications, for example). This is essential to ensure
that the same methodology is used over time, and to be able to demonstrate data reliability (in particular
in the case of a report “assurance process”, as described below).
7. Reporting test
The final step is the actual “test” of the reporting tools and method. Further training may be required, in
particular for those who were not part of the project group.
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After collecting all data, it is important to debrief with all actors involved, in order to address the difficulties
they may have faced, and make the necessary adjustments to the reporting tools and procedures for the
following reporting cycles.
Be indulgent with yourself with the first reporting cycle! The organization should not aim to fill in
absolutely all indicators, but rather to carry out a first assessment of what data is available or can be
easily collected and what needs to be further developed: as per the “comply or explain” principle (see
section 5), it is always possible to indicate that the data is not yet available. A progressive approach is
easier to implement and facilitates staff’s adherence to the reporting process.
5.3
CSR REPORTING STEPS
Following the first, “experimental” reporting cycle, CSR reporting must be systematized and CSR
indicators integrated into the overall organization’s reporting process, so that regular reports can be
produced, both internally and for external accountability.
Once the reporting system is fully established and mature enough, the organization can consider a further
step towards increased data credibility, through “external assurance”. This procedure is becoming more
and more common among larger companies, and is required by law in some countries (France for
instance). Similar to the annual audit of financial accounts, it aims to verify the validity and reliability of
CSR data, through an audit carried out by a third party. External assurance thus reinforces the credibility
of CSR reports and addresses stakeholders’ potential scepticism towards “self-declared” information. It
also helps identify weaknesses and improvement opportunities within the organization’s reporting system.
Below is a proposed overview of the reporting process’s successive steps and corresponding
responsibilities:
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6
CSR NARRATIVE REPORTS WITH EURHO-GR®
EURHO-GR® is not just a set of indicators and related reporting rules. It is also based on a certain vision
of CSR reports, as major accountability tools, which determines reports’ scope and content, as well as a
number of “golden rules”.
6.1
REPORTS’ SCOPE:
Too many CSR reports are mostly compilations of “good practices”. However, from an accountability
perspective, reports should not focus strictly on the actions implemented by the organizations, but should
adopt a more strategic approach to CSR. They should therefore include, in particular:
 the organization’s commitment towards CSR and its objectives at short-, mid- and long
term;
 the main CSR issues faced by the organization, and measures taken to address them;
 the organization’s impact and performance on the main CSR dimensions, as well as
results of its actions (which may not always be as positive as expected);
 actions considered for further improvement;
 the organization’s relation to its stakeholders, and how their interests are taken into
account.
Narrative reports should therefore provide both a retrospective analysis on achievements of the past year,
and a prospective view on the organization’s strategy. They should include information on the
organization’s context and stakeholders’ expectations in order for the readers to understand the
organization’s decisions, strategy, actions, and to properly assess its performance, taking into account
the local background and constraints.
6.2
THE “GOLDEN RULES”
Rule n°1 : The report has to mirror the organization and its Board’s commitment
The report has to reflect the organization’s identity and its own CSR project, with
Be
regard to its values, its history, its culture. Top management and Board commitment
to CSR must be visible and reflect a clear positioning on the organization’s vision of
yourself!
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its responsibility and contribution to sustainable development. Throughout the report, the organization’s
priorities must be presented and explained as per its vision and specific issues.
Rule n°2 : The report has to combine a strategic and prospective vision to a quantified and
qualitative report on past actions and achievements
The narrative sections of the report should present an analysis of the major issues on which the
organization develops its CSR approach. The organization’s strategy on a short and medium term and its
objectives, which should be quantified as far as possible, should be stated and
Report on
explained with regard to these issues. Similarly, the results and performance of
the past and
the previous year should be presented through figures, accompanied and
commented through a qualitative, contextualized analysis. It should provide a
look at the
clear and comprehensive vision of the organization’s achievements against the
future!
set objectives, taking into account the local context and its evolutions.
Rule n°3 : The report has to display a balanced global performance, including economic, social
and environmental dimensions
Like indicators, the report should cover all dimensions of CSR and, where possible and relevant,
underline connections between social, environmental and economic aspects. It should
also include a description of the organization’s governance mechanisms and how they
Be
integrate CSR considerations.
sincere ! Besides, the report should not exclusively highlight the past successes. To be credible and
constructive, it should be nuanced and sincere, and should thus also present what was not
achieved and the difficulties encountered to meet the planned targets, as well as improvement’s
objectives. This reinforces the report’s authenticity, while raising stakeholders’ awareness on the
organization’s dilemmas and constraints.
Rule n°4 : The report has to be clear and synthetic
Since the report targets all stakeholders, it has to be understandable by everyone. Terms which are too
technical or specific have to be avoided, or at least defined; similarly,
Avoid the
abbreviations have to be reduced as much as possible, and explicated. It is also
recommended to limit the length of the narrative sections of the report to about 20
professional
pages. An excessive quantity of text risks creating a repulsive effect on readers,
jargon!
and blurring the most significant information. This forces to focus on what is
essential, and to question which messages are the most important to
disseminate. Where possible, visuals (pictures, schemes, graphs…) are also effective ways to
communicate these key messages.
Rule n° 5 : The report has to be published on an annual basis and show evolutions over time
The regularity of the report’s publication is essential: it shows that the CSR approach is constant and
stable. The CSR report publication should thus become an annual “rendezvous” with
Be
stakeholders, like the traditional activity report. Reports are usually released on major
punctual! events, such as the organization’s General Assembly, the employees’ day or an
annual meeting with stakeholders. In the report, the results have to be presented on a
pluri-annual period in order to show the evolutions and the global trends.
6.3
EURHO-GR® REPORTS’ MAIN CONTENT
Based on these main principles, EURHO-GR® reports follow a similar overall outline. They all include, in
particular, the following sections:
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Foreword: management commitment
The opening scene when the curtains are pulled to the sides of a stage is the first impression that
spectators receive to the story that follows: it creates a first idea of the atmosphere and the actions that
will take place. Similarly, the foreword opening a CSR report is a first introduction to the organization’s
activity and prospective.
As such, the CSR report’s foreword, signed by the Top management, should reflect their commitment and
vision, as well as providing a first overview of the organization’s economic, political and social context,
main objectives and key achievements over the last reporting period. It is also the chance to recall the
organization’s values on which is built its CSR strategy.
Organization’s profile
Key facts and figures on the organization help understand its strategy and results. In addition to a
statement on the organization’s core mission, information on its housing stock (quantity and
characteristics), its turnover, its staff and its areas of operation is indeed crucial to analyse performance
data. Membership to local, national and international networks can also be highlighted in this section.
EURHO-GR® themes
Each of the five EURHO-GR® themes constitutes a whole report section; all 5 sections make up the core
of the CSR report. In each section, an analysis is provided on:
Issues : local context, needs, stakeholders’ expectations
Strategy : organism’s positioning and objectives
Performance: actions and results, including the disclosure of EURHO-GR® indicators.
The narrative analysis and description of performance should include comments and explanations on
indicator’s data, as well as highlighting more specifically those related to the organization’s priorities.
6.4
CSR REPORTS OR “COMBINED REPORTS”?
These last years have seen a growing trend towards “integrated reporting”, which aims at integrating CSR
data into the traditional management reports, in order to provide investors and shareholders with a
broader view of a company’s performance, risks and opportunities. Research and multi-stakeholder
discussions at international level are currently exploring opportunities and modalities for a global
integrated reporting framework.
In the social housing sector, a growing number of organizations are now producing reports which
combine their usual “activity report” and their CSR report. While this cannot be considered as proper
“integrated reporting” since it is not merged with legal and financial data and analysis, it nonetheless
provides stakeholders with a global picture on the organization’s activity and achievements. “Combined
reports” have indeed several advantages:
- it saves time and resources, as it avoids writing two separate reports;
- it provides a global, coherent vision of the organization’s strategy and performance (whereas two
separate reports can create confusion);
- it underlines the importance and full integration of CSR within the overall strategy.
Yet, it is recommended to produce “combined reports” only when the CSR reporting process if wellfunctioning. Besides, when an organization first engages in CSR reporting, a distinct CSR report enables
to highlight this commitment. It also helps inform on CSR and CSR issues and clarify what is meant by
Social Responsibility, for a social housing organization.
6.5
REPORTS’ DISSEMINATION
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A CSR report is written to be read by all stakeholders, or at least by most of them, internal as well as
external ones. Wide dissemination should therefore be considered; nonetheless, in order to be effective, it
should not be undertaken randomly, and should target in priority the most strategic stakeholders, as
described in chapter 1.
It is recommended to give priority to internal stakeholders: Board members (whose approval is required),
employees and their representatives. In order to raise employees’ interest, the report can be formally
handed over during a specific event, to promote it through a brief but effective presentation by the Top
management, reflecting once again its commitment, and thus supporting reporting implementation
throughout the company. It can also be disseminated through managers. Indeed, asking managers to
present the report to their teams can be an effective means to raise employees’ awareness and engage
discussion on the organization’s CSR strategy, with a specific focus on the objectives which directly relate
to them. It is also an opportunity to praise achievements and give sense to employees’ actions and
practices, by connecting them to the broader objectives of the organization, thus strengthening
employees’ engagement.
Dissemination to external stakeholders can also follow various processes. Besides mailing and individual
handover through one-to-one meetings, some organizations hold annual stakeholder conferences during
which they officially release the report…
Lastly, the report should be easily accessible on the company’s website !
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