Jinu Sam is a development professional and CSR practitioner and writes about NGOs and corporates to strengthen accountability, ethical partnerships, and measurable social impact across India.
Introduction
Corporate Social Responsibility (CSR) in India has emerged as a distinctive feature of corporate governance. The Companies Act, 2013 mandated that eligible companies allocate a percentage of profits to social development initiatives, sparking investments in education, healthcare, livelihoods and community infrastructure, particularly in marginalized regions (Ministry of Corporate Affairs, 2013). For NGOs, CSR opened avenues for scale, funding and long-term program sustainability, fundamentally transforming their operational landscape.
However, the Indian CSR model, while impactful, has structural limitations. Spending is largely expenditure-driven, often operating in isolation from the companies’ core business practices. This separation can allow organizations to deliver social programs while simultaneously engaging in upstream activities that cause harm, such as unsafe labour conditions, environmental degradation, or exploitative subcontracting (Ramasamy & Hsin, 2020). For example, a company may fund local schools or health programs while sourcing raw materials from supply chains characterized by informal or precarious labour. This highlights a critical gap between CSR expenditure and the ethical accountability of operations.
Globally, corporate responsibility is evolving beyond philanthropy. The United Nations Guiding Principles on Business and Human Rights (UNGPs, 2011) and the European Union Corporate Sustainability Due Diligence Directive (CSDDD, 2022) require companies to identify, prevent, mitigate, and remediate adverse impacts across their operations and supply chains. Ethical labour compliance, supply chain traceability, and human rights due diligence are no longer optional; they are core strategic imperatives for companies with global operations (Anner, 2021; ILO, 2022).
CSR in India and Global Accountability
India’s CSR framework, focused primarily on social spending, has successfully delivered tangible community benefits. Yet, by concentrating on downstream interventions, it often leaves upstream risks unaddressed. Global accountability frameworks, such as UNGPs and CSDDD, encourage proactive and systematic due diligence embedded within core business operations. NGOs are key intermediaries in this context, they bridge the knowledge gap between local realities and corporate compliance requirements, helping businesses integrate accountability, transparency, and human rights observance into their operational strategy (Chopra & Singh, 2021).
Table 1: CSR in India vs. Global Accountability Frameworks
| Aspect | India CSR (2013) | UNGPs (2011) | EU CSDDD (2022) |
| Scope | Social expenditure, community projects | Corporate responsibility to respect human rights | Mandatory due diligence across value chains |
| Enforcement | Compliance via mandated spending | Soft law guidance | Civil and legal liability |
| Focus | Philanthropy and development | Prevent, mitigate, and remediate human rights harms | Identification, prevention, mitigation, remediation |
| NGO Role | Implementation partner | Advisory, monitoring | Strategic knowledge partner in due diligence |
This comparison highlights how Indian CSR is strong in delivering social impact but weaker in operational accountability. Integrating NGOs strategically can bridge this gap by transforming CSR from philanthropy into a systemic accountability mechanism.
Business Responsibility and Sustainability Reporting (BRSR) in India
Business Responsibility and Sustainability Reporting (BRSR) framework, introduced by SEBI, is a landmark initiative to standardize ESG (Environmental, Social, Governance) disclosures by Indian companies. Replacing the earlier Business Responsibility Report (BRR), BRSR is mandatory for the top 1,000 listed companies by market capitalization from FY 2022-23. It requires detailed, quantifiable reporting on a company’s sustainable practices, aiming to enhance corporate transparency, accountability, and responsible business conduct, while providing investors and stakeholders with comparable insights into environmental and social performance.
The framework is built around the nine principles of the National Guidelines for Responsible Business Conduct (NGRBC), which cover areas such as environmental stewardship, human rights, ethical governance, stakeholder engagement and climate action. BRSR disclosures are organized into three sections: general disclosures, detailing company profile, products, and policies; principle-wise performance, capturing ESG metrics aligned with the nine principles; and management and process disclosures, outlining the implementation of sustainability policies. Companies are expected to respond to 98 mandatory questions, with the option to report 42 leadership indicators to showcase advanced ESG practices.
BRSR is categorized into three types:
- BRSR Full: A comprehensive disclosure covering all nine principles, including detailed mandatory and leadership indicators.
- BRSR Core: A focused subset of critical ESG metrics, such as greenhouse gas emissions, water usage and workforce diversity, which are subject to third-party assurance to enhance credibility.
- BRSR Lite: A voluntary, simplified version of the framework designed for smaller or non-obligated companies. It covers key ESG areas with a reduced set of indicators, making ESG reporting more accessible while allowing companies to gradually build capacity before adopting the full reporting requirements. Assurance is optional in BRSR Lite.
By introducing quantitative measures, aligning with global frameworks like GRI and TCFD (Task Force on Climate-related Financial Disclosures) and emphasizing just transition principles, BRSR represents a significant evolution from BRR (Business Responsibility Reporting). It not only strengthens corporate accountability in India but also positions companies to contribute meaningfully to global sustainability goals, while providing a flexible pathway for smaller firms to adopt ESG reporting through BRSR Lite.
Ethical Labour and Traceability
Ethical labour issues such as forced labour, unsafe working conditions, child labour and wage violations and remain prevalent in complex supply chains. Traceability, or the ability to monitor and document conditions across multiple tiers of suppliers, is critical to addressing these challenges (Anner, 2021). Traditional audits, often limited to direct suppliers, are insufficient for capturing informal labour or subcontracted arrangements.
NGOs play a central role in enhancing traceability. Their deep local knowledge and sustained engagement enable comprehensive monitoring, worker engagement and credible documentation of labour conditions. They also help implement grievance mechanisms and early warning systems, ensuring that risks are identified and addressed before they escalate.
Table 2: First-Tier Audit vs. NGO-Mediated Traceability
| Feature | First-Tier Audit | NGO-Mediated Traceability |
| Coverage | Limited to direct suppliers | Multi-tier, informal and subcontracted workers |
| Accuracy | Document-based, often surface-level | Observational, contextual and worker-informed |
| Limitations | Misses informal and subcontracted work | Requires NGO capacity and independence |
By working closely with NGOs, companies can enhance ethical compliance, operational transparency and supply chain resilience, turning CSR into a proactive tool for risk mitigation.
NGOs as Strategic Partners
NGOs are increasingly recognized not merely as implementers of CSR initiatives but as strategic partners who bring specialized knowledge, local insight and monitoring expertise to corporate responsibility programs. Their role extends far beyond project execution, shaping how companies design, implement and assess the social and ethical dimensions of their operations. By leveraging their grassroots presence and credibility, NGOs help corporations align social investments with operational accountability, ensuring that CSR programs produce sustainable impact.
Labour Governance: NGOs play a critical role in monitoring both formal and informal workers across the value chain. Through regular field visits, worker interviews and engagement with community stakeholders, NGOs can identify labour rights violations, unsafe working conditions and inequitable practices that may otherwise go unnoticed. Beyond monitoring, they actively build awareness among workers about their rights, facilitate training programs and operate grievance redress mechanisms. This ensures that workers have both the knowledge and channels to report violations, creating a responsive and transparent labour ecosystem.
Traceability: In complex supply chains, risks often extend beyond direct suppliers to subcontracted and informal networks. NGOs help corporations map these multi-tiered supply chains, providing visibility into areas that conventional audits often miss. By combining local knowledge with data collection tools, NGOs track the sourcing of materials, labour practices and environmental compliance. This traceability not only allows companies to verify ethical practices but also enables proactive interventions in areas where risks may emerge, ultimately safeguarding both communities and corporate reputation.
Remediation: Accountability is incomplete without mechanisms for correcting harm. NGOs facilitate remediation processes by working with affected communities and workers to identify suitable corrective actions. Whether mediating disputes, negotiating compensation, or restoring access to resources and services, NGOs ensure that remediation is both fair and contextually appropriate. Their engagement helps companies move beyond compliance-based approaches toward genuine responsibility, restoring trust between the corporation and its stakeholders.
Early Warning: NGOs act as early warning systems for operational, reputational and human rights risks. Their continuous engagement with local communities, field teams and supply chain actors enables them to detect emerging issues before they escalate into crises. By alerting companies to potential violations, labour unrest, environmental hazards, or community dissatisfaction, NGOs allow for timely interventions. This preemptive approach not only mitigates risk but also enhances the credibility and resilience of CSR initiatives, demonstrating a company’s commitment to ethical and sustainable operations.
In essence, NGOs provide the connective tissue between corporate strategies and community realities. They ensure that CSR programs are not just transactional acts of philanthropy but integrated mechanisms for accountability, transparency and long-term social impact.
Integrating NGOs into Corporate Accountability
Strategically integrating NGOs into CSR frameworks requires more than funding projects—it necessitates long-term partnerships with respect for NGO autonomy, capacity-building, and mechanisms to ensure independent monitoring. By establishing a structured workflow in which corporate operations are continuously monitored by NGOs, followed by timely remediation and oversight at the board level, CSR can evolve from a mere compliance exercise into a deeply embedded and accountable system of corporate responsibility.
Future Perspectives
The evolution of CSR in India is moving from expenditure-driven philanthropy to embedded accountability. Digital traceability, AI-enabled monitoring and worker voice platforms offer opportunities for enhanced transparency and ethical compliance. NGOs remain central to this future, ensuring supply chain traceability, ethical labour governance and remediation. Funders, investors and CSR leaders must prioritize long-term NGO capacity, independence and credibility to operationalize robust corporate accountability frameworks effectively.
India’s CSR ecosystem stands at a transformative crossroads. While traditional expenditure-based CSR has delivered social benefits, it falls short in addressing structural risks inherent in business operations. NGOs, acting as knowledge-driven intermediaries, provide essential expertise in labour governance, traceability and remediation. Integrating NGOs strategically enables companies to move from philanthropy to embedded accountability, mitigating risks, preventing harm and aligning operations with global human rights and sustainability standards. The future of CSR in India lies in this integration, where social impact and corporate responsibility are inseparably linked.
References
- Anner, M. (2021), Labor standards and supply chain accountability. Journal of Business Ethics, 171(2), 345–362.
- Bhattacharya, C. (2020), Corporate social responsibility in India: Context, challenges, and opportunities. Social Responsibility Journal, 16(5), 623–642.
- Chopra, S., & Singh, R. (2021), NGO engagement in corporate due diligence: Challenges and strategies. Development Policy Review, 39(4), 551–567.
- Das, K., & Mehta, P. (2019), From CSR compliance to corporate accountability: An Indian perspective. International Journal of Corporate Governance, 11(3), 211–230.
- European Commission. (2022), Proposal for a Corporate Sustainability Due Diligence Directive. Brussels: European Commission.
- Gupta, A., & Sharma, P. (2021), CSR and labour governance in India: Bridging the gap. Economic and Political Weekly, 56(9), 27–34.
- ILO. (2022), Global supply chains and forced labour: A report. Geneva: International Labour Organization.
- KPMG. (2023), ESG and due diligence in global supply chains. KPMG Global Insights.
- Ministry of Corporate Affairs. (2013), Companies Act 2013. Government of India.
- Ramasamy, B., & Hsin, C. (2020), Corporate social responsibility in emerging economies: The Indian experience. Journal of Business Research, 112, 128–137.
- UN Guiding Principles on Business and Human Rights (UNGPs) (2011), United Nations Human Rights Council.
