THE CSR SPENDING BY THE LEADING COMPANIES IN INDIA, BOTH NATIONALLY AND INTERNATIONALLY

ABSTRACT

This article presents a comprehensive examination of Corporate Social Responsibility (CSR) expenditure landscapes, encompassing both Indian and global contexts. As CSR continues to hold increasing significance within business frameworks worldwide, this research scrutinizes its evolution in India, tracing its inception under the Companies Act of 2013 to its current status. The study analyses the CSR spending patterns of prominent Indian corporations, inspecting their fiscal year spending both domestically and internationally. Moreover, it offers valuable insights into expenditure trends, patterns, and impactful initiatives through compelling case studies. Comparative analysis across various industries shed light on the evolving strategies in CSR, emphasizing emerging trends and their potential societal and environmental ramifications. Additionally, this article compares CSR approaches across diverse regions and industries, providing an international perspective. Ultimately, the research concludes with pivotal findings and recommendations, aimed at steering future investigations in this dynamic CSR domain.

KEYWORDS

Corporate Social Responsibility (CSR), Companies Act, 2013, CSR Practises, CSR Spending, CSR Initiatives

INTRODUCTION

Corporate Social Responsibility (CSR) has transformed from a mere supplementary aspect to a pivotal and indispensable part of modern business practices. It encapsulates a company’s pledge to go beyond its primary operations and actively contribute to society’s well-being. In the context of India, where businesses wield significant influence in driving socioeconomic progress, the incentives on CSR initiatives have gained remarkable traction. This study delves deep into examining how major companies in India allocate resources for CSR, drawing comparisons between their domestic ventures and their international counterparts.

India’s corporate landscape is vibrant and multifaceted, characterized by a variety of industries and a thriving economy. The Companies Act of 2013, which mandates larger corporations to set aside a portion of their profits for CSR activities, instigated a paradigm shift. It facilitated an environment where corporate entities assumed the role of catalysts for change, actively addressing societal issues. Consequently, comprehending the strategies and trends in CSR expenditure among leading companies becomes crucial in assessing their societal impact and contribution towards sustainable development.

The primary objective of this article is to offer an exhaustive analysis of the CSR initiatives undertaken by prominent Indian companies. It aims to scrutinize the allocation patterns of resources, focus areas, geographical outreach, and the alignment of these initiatives with the nation’s developmental objectives.

This article aims to explore how these corporations strategically deploy their resources, whether the initiatives cater to national priorities, and the overall effectiveness of their efforts in promoting social welfare. By examining these facets, this article seeks to provide insights into the efficacy and significance of CSR endeavours in shaping India’s socio-economic landscape.

OBJECTIVES

The primary objective of this work is to delve into Corporate Social Responsibility (CSR) spending, examining India’s CSR landscape. It aims to trace the evolution of CSR since its incorporation in the Companies Act of 2013, analysing spending patterns of major Indian corporations locally and abroad. Using the cases of a number of corporations, it will provide insights into expenditure trends, impactful initiatives, and changing strategies across industries, highlighting emerging trends and their societal and environmental implications.

OVERVIEW OF THE CSR SPENDING LANDSCAPE IN INDIA

The landscape of Corporate Social Responsibility (CSR) spending in India has experienced a notable transformation in recent years, primarily catalysed by the enactment of the Companies Act in 2013. This legislation mandated certain companies meeting specific financial thresholds to allocate a minimum of 2% of their average net profits from the preceding three years towards CSR initiatives.^[1] Companies falling under the purview of this regulation are those with a significant net worth, turnover, or profits, thereby ensuring that larger corporations contribute meaningfully to societal welfare.

Under the ambit of CSR activities outlined in the Companies Act, companies are mandated to focus on diverse social development areas. These include eradicating poverty and hunger, promoting education, fostering gender equality, enhancing healthcare access, championing environmental sustainability, supporting rural development projects, and contributing to various social welfare schemes.

To facilitate the execution and oversight of CSR initiatives, companies are required to constitute a dedicated CSR Committee comprising board members, including at least one independent director.^[2] This committee is entrusted with formulating CSR policies, ensuring adherence to regulatory guidelines, and overseeing the implementation of CSR activities. The annual financial statements of companies must comprehensively report the details of the CSR activities undertaken, the quantum of funds allocated, and the impact generated, ensuring transparency and accountability.

The enforcement of mandatory CSR spending has yielded positive outcomes, leading to a substantial increase in corporate investments in social development sectors across the country. As a result, there have been appreciable improvements in education, healthcare, sanitation, and livelihoods. However, the landscape is not without its challenges. Assessing the qualitative impact of CSR activities, addressing regional disparities in spending, ensuring the sustainability of projects beyond mandated periods, building the capacity of companies for effective implementation, and establishing robust monitoring and evaluation mechanisms are pressing concerns.

Looking ahead, future trends in the CSR domain in India are expected to emphasize innovation and technology to enhance the efficacy of CSR initiatives. Collaborations between corporations, non-governmental organizations (NGOs), and governmental bodies will likely increase to foster more impactful and sustainable projects. Moreover, there will likely be a shift towards creating long-term, enduring impacts rather than short-term interventions, marking a significant transition in the CSR approach.

EVOLUTION OF CSR IN INDIA AND GLOBALLY

India’s extensive history reflects deep-rooted business engagement in social causes, evolving from charity to Corporate Social Responsibility (CSR). Dating back to the late 1800s, practices included philanthropy and welfare, aligning with religious beliefs. By the 1900s, CSR expanded to encompass charitable donations, employee welfare, and community service. Post-Independence, JRD Tata advocated for businesses to directly contribute to societal relief, marking a shift toward broader social responsibility. This change led to initiatives like the Tata Iron and Steel Company’s community development, shaping CSR within India’s major corporations. This historical progression highlights the evolution of CSR from traditional charity to a vital part of enterprise management, shaping current CSR practices in India and globally.

The term “corporate social performance” was coined by S. Prakash Sethi. His model introduced three levels of corporate behaviour: “social obligation,” “social responsibility,” and “social responsiveness.”^[3]

Towards the end of the 20th century, there was a shift from traditional philanthropy towards direct business involvement in societal development, driven by both internal corporate intentions and external pressures for meeting increased governmental and public expectations.

Globally and in India, there is a growing realization that business success intertwines with contributing to societal well-being. This is especially relevant in India due to significant disparities in income, standards, and socio-economic status.

Infosys founder Narayana Murthy emphasized that social responsibility aims to maximize shareholder value while ensuring fairness to all stakeholders. Additionally, the Commission of the European Communities highlighted that social responsibility goes beyond legal compliance, requiring investments in human capital, the environment, and stakeholder relationships.

Some observers note that CSR practices in India have evolved from focusing solely on institutional building, such as education, research, and culture, to now emphasizing community development through diverse projects. Moreover, due to global influences and increased community engagement, there is an observable shift. While CSR efforts primarily centre on community development, they are progressively becoming more strategic, aligning with business goals rather than purely philanthropic objectives. Many companies now extensively document their CSR initiatives on official websites, annual reports, sustainability reports, and dedicated CSR publications.

ANALYSIS OF CSR SPENDING BY LEADING COMPANIES IN INDIA

CSRBOX and NGOBOX published a report, India CSR Outlook Report 2002, on the CSR expenditure of the top Indian companies in the last financial year 2021-22. The study scrutinized the CSR spending patterns of 301 prominent companies in FY 2021-22, presenting a comprehensive overview of India’s CSR landscape. The selection criteria for these 301 firms involved various factors: a CSR commitment of INR 1 crore or more in FY 2021-22, listing on BSE and/or NSE or being a PSU, availability of CSR data by September 15, 2022, and compliance with Section 135 of the Companies Act.^[4]

The report highlighted significant figures: the aggregate prescribed CSR allocation for FY 2021-22 amounted to INR 12,119 crore, while the actual CSR expenditure totalled INR 12,260 crore. On average, each company had a prescribed CSR of INR 2 crore, but the actual CSR spending per company averaged at INR 40 crore. Furthermore, the report detailed the top five companies leading CSR spending in India, namely Reliance Industries, HDFC Bank, Tata Consultancy Services, ONGC, and Tata Steel, collectively responsible for more than one-fourth of the total CSR spending. Notably, public sector undertakings contributed 26.23% to the overall CSR expenditure for the fiscal year.

Additionally, the report shed light on the sectors that received substantial CSR funding. Companies involved in oil drilling, lubricants & petrochemicals, banking & finance, and computer software & IT sectors collectively received over 50% of India’s total CSR funding. Among the Sustainable Development Goals (SDGs), SDG 3 (Good Health and Well-being), SDG 4 (Quality Education), and SDG 1 (No Poverty) were the primary focus areas, jointly receiving 65% of India’s total CSR funding. Geographically, Maharashtra, Odisha, and Delhi accounted for nearly one-fourth of the country’s total CSR funding.

In the financial year 2021-22, Tata Consultancy Services allocated Rs 727 crores toward corporate social responsibility, which increased to Rs 783 crores in FY 2022-23. Rooted in the Tata Group’s values, TCS in India is deeply committed to CSR, prioritizing community, environment, and employees. Amidst the COVID-19 pandemic, while many companies were downsizing or cutting salaries, TCS distinguished itself by raising salaries for all its employees, being the first IT firm in India to do so during that period.^[5]

TCS’s global community development initiatives encompass health, biodiversity, education, STEM, digital literacy, skill enhancement, and disaster management within its CSR framework. Their primary objectives include creating employment opportunities for youth and marginalized groups, fostering education for 21st-century skills, and supporting health, sanitation, and hygiene needs, especially among marginalized communities.

TCS’ CSR endeavours in the fiscal year 2022-23 showcased significant achievements across various initiatives. Notably, their partnership with the State Literacy Mission Authority in Madhya Pradesh aimed at bridging the literacy gap, reaching all 52 districts. The goIT program continued its commendable work, empowering 41,971 students globally, with a strong focus on girls and marginalized communities, fostering digital innovation to solve real-world issues. Moreover, Ignite my Future impacted 293,697 students, fostering computational thinking in countries like India, US, Canada, and ANZ. The Youth Employment Program (YEP) successfully empowered 10,869 rural youths, paving the way for 21st-century job opportunities, extending its reach across every state and union territory in India. Furthermore, the Bridge IT initiative transformed marginalized youth into digital entrepreneurs, serving 1,736 rural villages by providing crucial last-mile services. Additionally, TCS extended support to institutions like the Tata Memorial Centre and Cancer Institute in India, underscoring their commitment to societal welfare.^[6]

During the fiscal year 2022-23, Reliance Industries Limited (RIL) committed a substantial sum of Rs 1,271 crore towards advancing its Corporate Social Responsibility (CSR) initiatives. This announcement was made by Chairman Mukesh Ambani during RIL’s annual general meeting. The execution of these CSR endeavours is channelled through the Reliance Foundation, RIL’s dedicated CSR arm.

This allocation for CSR in FY 2022-23 represents a notable upsurge from the preceding year’s expenditure, which amounted to Rs 1,184.93 crore. These funds were strategically distributed across various sectors, resulting in the creation of an impressive 260,000 new job opportunities within the company’s diverse business portfolio. This surge in employment not only positively impacted the direct workforce, which now stands at nearly 390,000 employees, but also led to the emergence of numerous indirect livelihood prospects.^[7]

RIL’s CSR endeavours encompass a broad spectrum of activities, spanning health and sanitation, education and skill development, rural advancement, and environmental sustainability. These comprehensive initiatives underscore the company’s dedication to societal welfare and its active role in addressing critical needs in India, particularly in areas like employment generation and sustainable development.

In the fiscal year 2022-23, HDFC Bank witnessed a notable 15.92% increase in their CSR spending, reaching Rs 736 crore. Under their ‘Parivartan’ initiatives, the bank endeavoured to make a meaningful difference in communities throughout India. Their allocation strategy focused on pivotal areas such as education, where they impacted 2.09 crore students and provided training for 19.94 lakh teachers. Additionally, they supported skill training and livelihood opportunities for over 8.08 lakh women entrepreneurs and more than 8,470 Self-Help Groups. Health care saw a boost through the execution of 1.18 lakh health camps, while sports programs received backing. Environmental sustainability was a priority, evident in the development of more than 10,500 water conservation structures, installation of more than 41,810 solar lights, and planting of more than 17.69 lakh trees. Rural development initiatives like the Holistic Rural Development Programme (HRDP) aided 9.88 lakh households and 3,335 villages across 23 states. Aligned with UN Sustainable Development Goals (SDGs) encompassing poverty reduction, zero hunger, clean water, education, and sustainable communities, HDFC Bank’s CSR endeavours reached over 9.6 crore beneficiaries, demonstrating a robust commitment to sustainable growth. Furthermore, the bank has set ambitious goals aiming for carbon neutrality by FY32, intending to curtail emissions and reduce energy and water consumption.^[8]

TATA Steel, a prominent global steel manufacturer, places a high priority on corporate social responsibility (CSR) to create a beneficial influence on society and the environment. During FY 2022-23, the company spent Rs. 481 crores in its CSR allocations.^[9] Its CSR endeavors encompassed crucial areas such as education, health, livelihood, sports, culture, environment, and disaster relief.

The initiatives undertaken were diverse and impactful. Education efforts by the company targeted more than 150,000 children, emphasizing scholarships, infrastructure development, and vocational education. In healthcare, TATA Steel provided quality services to over 1.2 million individuals, focusing on preventive programs. Moreover, the company created sustainable opportunities for over 100,000 individuals, particularly women and tribal communities, by supporting agricultural ventures and entrepreneurial initiatives.

TATA Steel also actively promoted sports and fitness, nurturing talent for national and international competitions. Additionally, the company took initiatives to preserve India’s cultural heritage through various events and programs. Environmentally, TATA Steel contributed to conservation through activities such as afforestation, waste management, and renewable energy projects. During times of calamities like COVID-19, floods, and cyclones, the company provided aid and relief to affected areas.

These CSR initiatives are in alignment with the United Nations’ Sustainable Development Goals, underscoring TATA Steel’s commitment to creating a sustainable and positive impact on both society and the environment.

CSR SPENDING BY LEADING COMPANIES IN INDIA INTERNATIONALLY

CSR Spending by Infosys: Infosys, a leading IT firm in India, is committed to corporate social responsibility (CSR) globally. In the fiscal year 2022-23, Infosys allocated Rs. 517 Cr. for CSR, with Rs. 391.51 Cr. directed within India and Rs. 125.49 Cr. for projects outside India. This marked an increase from the previous year’s Rs. 106.6 Cr. spent internationally.^[10]

The company operates under a global CSR policy focusing on economic development, minimal resource impact, and addressing issues like hunger, poverty, malnutrition, environment, and community welfare. The policy highlights key areas like education, rural development, environmental sustainability, arts and culture preservation, health improvement, and supporting causes aligned with its values for social welfare.

Infosys supported various initiatives across the globe in FY 2022-23. In the United States, they backed the Infosys Foundation USA and collaborated with the New York Academy of Sciences and the Rhode Island School of Design. In the UK, they supported the British Asian Trust and the Royal Shakespeare Company’s educational programs. In Australia, they supported Indigenous education through the Australian Indigenous Education Foundation and collaborated with the Australian Business and Community Network and the University of Melbourne. In Canada, they supported Pathways to Education and the SickKids Foundation, along with partnering with the University of Toronto for an innovation lab. Infosys also contributed to relief efforts for disasters like the COVID-19 pandemic, Australian bushfires, Beirut explosion, and others.^[11]

CSR Spending by Sun Pharma: As per the ESG Overview for FY 2022-23, Sun Pharma spent INR 852.32 million on CSR initiatives, impacting over 1 million lives in India. Though specifics on spending outside India are not detailed, the report highlights projects in various countries like providing medical aid, COVID-19 relief, education, environmental conservation, and community development in the USA, Canada, Brazil, South Africa, Egypt, and Bangladesh.^[12]

The CSR Policy also outlines the process, monitoring and evaluation plan, communication and reporting, and exclusions for the CSR activities. The CSR Policy is approved by the Board of Directors of Sun Pharma, which is responsible for ensuring that the CSR activities are undertaken in accordance with the policy and the applicable laws and regulations.

CSR Spending by Wipro: Wipro invested Rs. 215.7 Crore in its CSR efforts during FY 2022-23, surpassing the mandated Rs. 198.6 Crore required by the Companies Act of 2013 by over 8%. This demonstrates Wipro’s strong dedication to social responsibility.^[13]

Operating with over 230 partner organizations, Wipro executes around 300 projects spanning India, the US, UK, the Philippines, Romania, France, and other countries. Rooted in longstanding corporate citizenship, Wipro’s CSR policy is based on fundamental principles and strategies.

The allocated CSR spending by Wipro is directed towards four main areas: education (Rs. 145.3 crores), primary healthcare (Rs. 32.4 crores), ecology (Rs. 24.6 crores), and disaster response (Rs. 13.4 crores). These domains are selected for their recognized role in driving societal progress and community resilience, leading to lasting positive effects on livelihoods, health, gender equality, economic productivity, and democratic engagement.

Coca-Cola India Private Limited (CCIPL): In compliance with the India CSR Spending Report 2022-23, Coca-Cola India Private Limited (CCIPL) was mandated to allocate a minimum of Rs. 1375 Lakhs towards CSR during the fiscal year 2022-23, based on the average net profits of the preceding three financial years. CCIPL adjusted its annual action plan (AAP) for CSR activities for 2022-23 and distributed its CSR budget across various focus areas and projects. The focus areas and projects are Project Unnati (Rs. 750 lakhs for apple, Rs. 84 lakhs for litchi, Rs. 162.50 for grapes), World Without Waste (Rs. 180 lakhs), contribution towards sports and athlete development (Rs. 71.49), Support a Child (Rs. 10 lakhs), COVID-19 Relief (Rs. 17.01 lakhs) and Anandana (Rs. 100 lakhs).^[14]

Coca-Cola, beyond its operations in India, implements a global CSR strategy focusing on six main areas: water leadership, waste reduction, beverage diversity, climate action, sustainable agriculture, and supporting communities. In 2022, the company allocated $1.1 billion for CSR efforts globally, equal to 1.4% of its net operating revenues.

CSR Spending by Nestlé India: Nestlé India exceeded the mandated 2% CSR expenditure of its net profits in the 2018-19 fiscal year, spending INR 38.31 crore compared to the prescribed INR 38.07 crore. The company’s CSR focus areas include nutrition, water, sanitation, rural development, livelihood, education, and the environment. ^[15]All expenses align with approved annual plans and are not meant to generate surplus beyond normal operations.

Globally, Nestlé discloses its CSR efforts through annual and sustainability reports. In 2022, it invested CHF (Swiss Franc) 1.9 billion in R&D, CHF 1.6 billion in environmental sustainability, and CHF 0.3 billion in social impact.^[16] The company reduced greenhouse gas emissions and increased renewable electricity usage. Nestlé’s shared value approach revolves around promoting healthier lives, resilient communities, and safeguarding natural resources for future generations.

EMERGING TRENDS IN CSR PRACTICES AND THEIR POTENTIAL IMPACT

Corporate social responsibility (CSR) involves businesses acknowledging their societal and environmental impact. This includes ethical conduct, environmental sustainability, social welfare, human rights, diversity, inclusion, and philanthropy. These practices can positively affect businesses by bolstering their reputation, attracting talent, building customer loyalty, fostering innovation, mitigating risks, and creating value for stakeholders. The emerging trends in CSR may include:

Adoption of digital tools and CSR software for managing, monitoring, and reporting CSR activities: This move aims to automate processes, generate insights, enhance communication, and engage stakeholders, ultimately improving efficiency, transparency, and participation.
Emphasis on CSR reporting and impact measurement to demonstrate accountability, compliance, and value creation: This trend seeks to elevate credibility, competitiveness, and inform decision-making and strategy.
Recognition of the importance of workplace diversity and inclusion to cultivate a culture of respect, innovation, and collaboration: Leveraging diverse talents and perspectives can address challenges and capitalize on opportunities arising from globalization and societal shifts, ultimately boosting productivity, creativity, and overall performance.

Exploration of blockchain and cloud computing for enhancing CSR practices, particularly in supply chain management, traceability, and verification: These technologies aim to create secure, decentralized records, analyse vast data, and increase trust, accountability, and efficiency, fostering collaboration and innovation.

CONCLUSION

Corporate social responsibility (CSR) has emerged as a critical element in India’s business strategy and performance, notably following the introduction of mandatory CSR spending in 2013. This analysis scrutinized the CSR expenditure of top companies, revealing substantial investments in diverse CSR pursuits, both nationally and globally. This article indicated substantial evolution in India’s CSR landscape but underscored opportunities for further enhancement and originality, especially amid and after the COVID-19 pandemic. It is recommended that Indian firms embrace a more comprehensive and strategic CSR approach, aligning it closely with their fundamental business values and goals, aiming for a long lasting and beneficial societal influence.

REFERENCES

The CSR Journal, (2023), <https://thecsrjournal.in/top-companies-india-csr-sustainability-2022/>
Farhan Khan, (2002), Sigma Earth, <https://sigmaearth.com/the-evolution-of-csr-policies-in-india-from-philanthropy-to-sustainable-development/#:~:text=During%20this%20period%2C%20CSR%20initiatives,communities%20and%20promoting%20social%20welfare.&text=The%20third%20phase%20of%20CSR,competition%20in%20the%20global%20market.>
Ankita Pandey, CSRBox, <https://csrbox.org/Impact/description/Article_full_Top-50-Companies-in-CSR-Activities-Funding-in-India_36 >
Hency Thacker, (2023), The CSR Journal, <https://thecsrjournal.in/corporate-social-responsibility-csr-report-wipro-india/>
Hency Thacker, (2023), The CSR Journal, <https://thecsrjournal.in/corporate-social-responsibility-csr-report-infosys-limited/>
http://timesjourney.co.in/wp-content/uploads/2021/05/TJ_2021_JAN_05.pdf
Team Goodera, (2023), Goodera, <https://www.goodera.com/blog/corporate-social-responsibility-trends

^[1] The Companies Act, 2013, Section 135, No. 18, Acts of Parliament, 2013 (India)

^[2] ibid

^[3] Mehrnaz Ashrafi, Gregory M. Magnan, Michelle Adams, Tony R. Walker, Understanding the Conceptual Evolutionary Path and Theoretical Underpinnings of Corporate Social Responsibility and Corporate Sustainability, MDPI, (January 21, 2020), <https://www.mdpi.com/2071-1050/12/3/760#:~:text=In%20Sethi’s%20schema%2C%20social%20obligation,%E2%80%9D%3B%20and%20social%20responsiveness%2C%20which

^[4] CSRBox, https://csrbox.org/media/CSRBOX-India-CSR-Outlook-Report-2022_Full-version.pdf, (last visited January 6, 2024)

^[5] Complete CSR Report of Tata Consultancy Services (TCS) in India FY 2022-23, The CSR Journal, (June 9, 2023), https://thecsrjournal.in/csr-report-tcs-india-tata-consultancy-services/

^[6] ibid

^[7] Hency Thacker, CSR Spending of Rs. 1271 Cr. in FY 23, Says Mukesh Ambani in Reliance AGM 2023, The CSR Journal, (August 7 2023), https://thecsrjournal.in/csr-report-reliance-industries-limited/

^[8] HDFC Bank, https://www.hdfcbank.com/personal/about-us/news-room/press-release/2022/q3/hdfc-bank%E2%80%99s-csr-spend-at-rs-736-crore-in-fy2022, (last visited January 6, 2024)

^[9] Amit, Khurana, Tata Steel’s Exemplary CSR Initiatives: Driving Sustainable Development and Social Impact, Cross Barriers (August 2, 2023), https://crossbarriers.org/tata-steel-csr-sustainable-development-and-social-impact/#:~:text=This%20significant%20investment%20reflects%20their,impacting%20over%203.15%20million%20lives.

^[10] Hency Thacker, The Ultimate Report on CSR of Infosys Limited, The CSR Journal, (June 8, 2023) https://thecsrjournal.in/corporate-social-responsibility-csr-report-infosys-limited/

^[11] ibid

^[12] Amazon Web Services, https://stockdiscovery.s3.amazonaws.com/insight/india/2757/Annual%20Report/AR-23.pdf, (last visited January 6, 2024)

^[13] Hency Thacker, CSR Report: Wipro Spent Rs. 215.7 Cr. On CSR in FY23, The CSR Journal, (July 13, 2023), https://thecsrjournal.in/corporate-social-responsibility-csr-report-wipro-india/

^[14] Coca-Cola, https://www.coca-cola.com/content/dam/onexp/in/en/legal/privacy-policy/pdf/AAP%20CSR%20(Revised)%20FY%202022-23%20Feb%2002%202023.pdf, (last visited January 6, 2024)

^[15] Hency Thacker, The Complete Report on CSR Activities of Nestlé, The CSR Journal, (October 6, 2020), https://thecsrjournal.in/the-complete-report-on-csr-activities-of-nestle/

^[16] Roche, https://assets.roche.com/f/126832/x/8971737b76/fb22e.pdf, (last visited January 6, 2024)

Disclaimer: The materials provided herein are intended solely for informational purposes. Accessing or using the site or the materials does not establish an attorney-client relationship. The information presented on this site is not to be construed as legal or professional advice, and it should not be relied upon for such purposes or used as a substitute for advice from a licensed attorney in your state. Additionally, the viewpoint presented by the author is of a personal nature.