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in

Handbook on
Corporate Social
Responsibility in
India
Message from the Chairman
CIIs Development Initiative Council

A robust and thriving development sector is central to Indias quest for equitable, inclusive
and sustainable growth. Indias development sector has evolved substantially over the last few
decades and is now witnessing unprecedented interest and investments across the value chain.
With the passage of the Companies Act, 2013 the mandate for corporate social responsibility
(CSR) has been formally introduced to the dashboard of the Boards of Indian companies. The
industry has responded positively to the reform measure undertaken by the government with a
wide interest across the public and private sector, Indian and multinational companies.
The practice of CSR is not new to companies in India. However, what this Act does is bring
more companies into the fold. Also, it is likely that the total CSR spends will increase. What is
clear to many companies is that if this increased spending is to achieve results on the ground
which is the intent of the Act then it needs to be done strategically, systematically and
thoughtfully.
It is in this context, that the Handbook on Corporate Social Responsibility in India developed
by PwC India for CII can play an important role. The CII being the leading industry body,
through this handbook, envisages equipping companies for this shift of structured engagement
with communities. This handbook is aimed both at companies that are veteran CSR
practitioners as well as those that are just entering the fray. It suggests steps to develop a CSR
strategy and Policy and identifies the key building blocks for initiating and developing the CSR
programs. It walks the CSR practitioner through some of the key choices that may be required
to be made while pursuing CSR objectives and develop an organisation that is socially sensitive
and responsible.
Building a society which provides equal access to opportunities negates disparities and, is a
collective responsibility. This Act presents a unique opportunity to stand up to the challenge. It
is a call for action. And this handbook is a significant step in that direction.

Rakesh Bharti Mittal


Chairman, CIIs Development Initiative Council and
Vice Chairman and Managing Director, Bharti Enterprises
Message from the Mentor and
Chairman Emeritus
Fortis Healthcare Limited

The constitutional structure of the country was laid with an objective of one man equals one
vote, equals one value. However the socio-economic realities of the country still have a long
way to go to match this vision of independent India where today there are many first among
equals. The country presently is under intense debate of developmental growth versus welfare
based development. Our political realities and our economic senses are at cross-roads. How do
we strike a balance between the two? The choices we make today are going to influence our
generations to come.
Every single major policy initiative in this country has been driven with a perspective that an
overwhelming concern for the disadvantaged and marginalised, a multidimensional view of
poverty and human deprivation, the focus on our fundamental rights and the need to expand
opportunities while ensuring its equal distribution are fundamental for achieving strong
human development. But disparity, inequality and the growing divide in our societies define
our existence today. The inclusion of the CSR mandate under the Companies Act, 2013 is an
attempt to supplement the governments efforts of equitably delivering the benefits of growth
and to engage the Corporate World with the countrys development agenda.
Philanthropy and CSR is not a novel concept for Indian companies, however a few
organisations are likely to struggle. The role of civil society in fuelling this change is bound to
be extremely important. With the new corporate resources in their tool bag much will depend
on their ability to innovate and adapt.
The handbook is a guidance document which will facilitate development of CSR mandate
within organisations and help streamline dialogue within the industry. An addendum will
follow with details of the rules once the same have been notified by the Government. The
members of the industry are likely to find their output helpful, informative and enabling.
Confederation of Indian Industry has been in the forefront in sensitising industry on CSR
and creating necessary enablers for promoting CSR for over a decade. I am confident that all
companies will be immensely benefitted from this document too.
I would like to extend my warm appreciation to the PwC team, including Sachin Shukla,
Sharique Ahmad, Anjan Katna, Ankit Gupta and Shankar Venkateswaran who worked towards
the development of this document.

Harpal Singh
Mentor and Chairman Emeritus,
Fortis Healthcare Limited
List of abbreviations

BRR Business Responsibility Report


CSR Corporate social responsibility
DPE Department of Public Enterprises
EC European Commission
ESG Environmental, social and governance
ILO International Labour Organisation
ISO International Organisation for Standardisation
LBG London Benchmarking Group model
MCA Ministry of Corporate Affairs
NVG National Voluntary Guidelines Contents
OECD Organisation for Economic Co-operation and Development
SEBI Securities and Exchange Board of India 6 What is CSR?
SME Small and medium enterprises
SAAS Social accountability accreditation services
11 The Companies Act, 2013
SGAAP Social generally accepted accounting principles 14 CSR: Planning and strategising
SROI Social return on investments
UN United Nations 23 CSR and SMEs
UNGC United Nations Global Compact 26 Appendices
UNIDO United Nations Industrial Development Organisation
WBCSD World Business Council for Sustainable Development
About the handbook
India is a country of myriad contradictions. On the one hand, it has grown to
be one of the largest economies in the world, and an increasingly important
player in the emerging global order, on the other hand, it is still home to the
largest number of people living in absolute poverty (even if the proportion
of poor people has decreased) and the largest number of undernourished
children. What emerges is a picture of uneven distribution of the benefits of
growth which many believe, is the root cause of social unrest.
Companies too have been the target of those perturbed by this uneven
development and as a result, their contributions to society are under
severe scrutiny. With increasing awareness of this gap between the haves
and the have-nots, this scrutiny will only increase over time and societal
expectations will be on the rise. Many companies have been quick to sense
this development, and have responded proactively while others have done so
only when pushed.
Governments as well as regulators have responded to this unrest and the
National Voluntary Guidelines for Social, Environmental and Economic
Responsibilities of Business or the NVGs (accompanied by the Business
Responsibility Reports mandated by the SEBI for the top 100 companies)
and the CSR clause within the Companies Act, 2013 are two such instances
of the steps taken.
According to Indian Institute of Corporate Affairs, a minimum of 6,000
Indian companies will be required to undertake CSR projects in order
to comply with the provisions of the Companies Act, 2013 with many
companies undertaking these initiatives for the first time. Further, some
estimates indicate that CSR commitments from companies can amount to as
much as 20,000 crore INR.
This combination of regulatory as well as societal pressure has meant
that companies have to pursue their CSR activities more professionally.
This handbook attempts to bring together good practices of companies
and grant-making foundations so as to assist companies pursue their CSR
activities effectively, while remaining aligned with the requirements of the
Companies Act, 2013.
This handbook begins by building a common understanding of the concept
of CSR, based on global practices, Indian tradition, and the intent and
provisions of the Companies Act, 2013. It then goes on to bring out the key
aspects of clause 135 of the Companies Act, 2013 and the recently released
draft rules, and highlights its implications to companies.
A major part of the handbook focuses on the what and how of strategising,
planning, executing and monitoring the CSR activities of companies. It
provides a detailed guidance (rather than prescriptions) for each of these
processes covering the following:
Objective of the process
Process owners
Key inputs and outputs
Activities or tasks to be covered, including methodology and timelines
Tools, technical guidance or standards to be employed
It also has a section on what small and medium enterprises, some of whom
will be required to comply with the Act, can do collectively.
What is CSR?

6 PwC
What is CSR? though the latter can also make a valuable lists out the CSR activities, suggests
contribution to poverty reduction, will communities to be the focal point. On the
The global context directly enhance the reputation of a company other hand, by discussing a companys
While there may be no single universally and strengthen its brand, the concept of CSR relationship to its stakeholders and
accepted definition of CSR, each definition clearly goes beyond that. integrating CSR into its core operations,
that currently exists underpins the impact the draft rules suggest that CSR needs
From the above definitions, it is clear that:
that businesses have on society at large and to go beyond communities and beyond
the societal expectations of them. Although The CSR approach is holistic and the concept of philanthropy. It will be
the roots of CSR lie in philanthropic integrated with the core business strategy interesting to observe the ways in which this
activities (such as donations, charity, for addressing social and environmental will translate into action at the ground level,
relief work, etc.) of corporations, globally, impacts of businesses. and how the understanding of CSR is set to
the concept of CSR has evolved and now CSR needs to address the well-being undergo a change.
encompasses all related concepts such as of all stakeholders and not just the CSR and sustainability
triple bottom line, corporate citizenship, companys shareholders.
philanthropy, strategic philanthropy, shared Sustainability (corporate sustainability)
Philanthropic activities are only a part of is derived from the concept of sustainable
value, corporate sustainability and business
CSR, which otherwise constitutes a much development which is defined by the
responsibility. This is evident in some of the
larger set of activities entailing strategic Brundtland Commission as development
definitions presented below:
business benefits. that meets the needs of the present without
The EC1 defines CSR as the responsibility of compromising the ability of future generations
enterprises for their impacts on society. To CSR in India
to meet their own needs 4. Corporate
completely meet their social responsibility, CSR in India has traditionally been sustainability essentially refers to the role
enterprises should have in place a process seen as a philanthropic activity. And in that companies can play in meeting the
to integrate social, environmental, ethical keeping with the Indian tradition, it was agenda of sustainable development and
human rights and consumer concerns into an activity that was performed but not entails a balanced approach to economic
their business operations and core strategy in deliberated. As a result, there is limited progress, social progress and environmental
close collaboration with their stakeholders documentation on specific activities related stewardship.
The WBCSD defines CSR as2 the continuing to this concept. However, what was clearly
evident that much of this had a national CSR in India tends to focus on what is
commitment by business to contribute to done with profits after they are made. On
economic development while improving the character encapsulated within it, whether
it was endowing institutions to actively the other hand, sustainability is about
quality of life of the workforce and their factoring the social and environmental
families as well as of the community and participating in Indias freedom movement,
and embedded in the idea of trusteeship. impacts of conducting business, that is,
society at large. how profits are made. Hence, much of the
According to the UNIDO3, Corporate As some observers have pointed out, the Indian practice of CSR is an important
social responsibility is a management practice of CSR in India still remains within component of sustainability or responsible
concept whereby companies integrate the philanthropic space, but has moved from business, which is a larger idea, a fact
social and environmental concerns in institutional building (educational, research that is evident from various sustainability
their business operations and interactions and cultural) to community development frameworks. An interesting case in point
with their stakeholders. CSR is generally through various projects. Also, with global is the NVGs for social, environmental
understood as being the way through which influences and with communities becoming and economic responsibilities of business
a company achieves a balance of economic, more active and demanding, there appears issued by the Ministry of Corporate Affairs
environmental and social imperatives to be a discernible trend, that while CSR in June 2011. Principle eight relating to
(Triple-Bottom-Line Approach), while at remains largely restricted to community inclusive development encompasses most
the same time addressing the expectations development, it is getting more strategic in of the aspects covered by the CSR clause
of shareholders and stakeholders. In this nature (that is, getting linked with business) of the Companies Act, 2013. However, the
sense it is important to draw a distinction than philanthropic, and a large number of remaining eight principles relate to other
between CSR, which can be a strategic companies are reporting the activities they aspects of the business. The UN Global
business management concept, and charity, are undertaking in this space in their official Compact, a widely used sustainability
sponsorships or philanthropy. Even websites, annual reports, sustainability framework has 10 principles covering
reports and even publishing CSR reports. social, environmental, human rights and
The Companies Act, 2013 has introduced governance issues, and what is described as
1 http://ec.europa.eu/enterprise/policies/sustainable- the idea of CSR to the forefront and CSR is implicit rather than explicit in these
business/corporate-social-responsibility/index_ through its disclose-or-explain mandate, principles.
en.htm is promoting greater transparency and
2 http://www.wbcsd.org/work-program/business- disclosure. Schedule VII of the Act, which
role/previous-work/corporate-social-responsibility.
aspx
3 http://www.unido.org/what-we-do/trade/csr/what-
is-csr.html#pp1[g1]/0/
4 Brundtland Commissions Report, 1987
Handbook on Corporate Social Responsibility in India 7
Globally, the notion of CSR and Benefits of a robust CSR
sustainability seems to be converging, as programme
is evident from the various definitions of
CSR put forth by global organisations. The As the business environment gets
genesis of this convergence can be observed increasingly complex and stakeholders
from the preamble to the recently released become vocal about their expectations,
draft rules relating to the CSR clause within good CSR practices can only bring in greater
the Companies Act, 2013 which talks benefits, some of which are as follows:
about stakeholders and integrating it with Communities provide the licence to
the social, environmental and economic operate: Apart from internal drivers
objectives, all of which constitute the such as values and ethos, some of the key
idea of a triple bottom line approach. It stakeholders that influence corporate
is also acknowledged in the Guidelines behaviour include governments (through
on Corporate Social Responsibility and laws and regulations), investors and
Sustainability for Central Public Sector customers. In India, a fourth and
Enterprises issued by the DPE in April 20135. increasingly important stakeholder is
The new guidelines, which have replaced the community, and many companies
two existing separate guidelines on CSR have started realising that the licence
and sustainable development, issued in to operate is no longer given by
2010 and 2011 respectively, mentions the governments alone, but communities
following: that are impacted by a companys
Since corporate social responsibility and business operations. Thus, a robust CSR
sustainability are so closely entwined, it can programme that meets the aspirations
be said that corporate social responsibility of these communities not only provides
and sustainability is a companys commitment them with the licence to operate, but
to its stakeholders to conduct business in an also to maintain the licence, thereby
economically, socially and environmentally precluding the trust deficit.
sustainable manner that is transparent and Attracting and retaining employees:
ethical. Several human resource studies have
linked a companys ability to attract,
Why is the CSR clause of the retain and motivate employees with
new Companies Act, 2013 so their CSR commitments. Interventions
that encourage and enable employees
critical for SMEs? to participate are shown to increase
employee morale and a sense of
By requiring companies, with a belonging to the company.
minimum net profit of 5 crore INR,
Communities as suppliers: There
to spend on CSR activities, the
are certain innovative CSR initiatives
Companies Act, 2013 is likely to bring emerging, wherein companies have
in many SMEs into the CSR fold. This invested in enhancing community
will usher in a fresh set of challenges livelihood by incorporating them into
to a sector that is increasingly their supply chain. This has benefitted
being asked by its B2B customers communities and increased their income
to comply with environmental and levels, while providing these companies
social standards, while remaining with an additional and secure supply
competitive in terms of price and chain.
quality. Thus, SMEs will have to Enhancing corporate reputation:
quickly learn to be compliant with The traditional benefit of generating
these diverse set of requirements and goodwill, creating a positive image and
it is hoped that this handbook will branding benefits continue to exist for
facilitate their ability to comply with companies that operate effective CSR
the CSR clause of the Companies Act, programmes. This allows companies
to position themselves as responsible
2013.
corporate citizens.
5 Guidelines on Corporate Social Responsibility and
Sustainability for Central Public Sector Enterprises
-http://www.recindia.nic.in/download/DPE_Guide-
lines_CSR_Sust.pdf
8 PwC
Global principles and guidelines The UN Guiding Principles on Business and Institute of Social and Ethical Account-
A comprehensive guidance for companies Human Rights ability: AccountAbilitys AA1000 series of
standards
pertaining to CSR is available in the form The UN guiding principles provide assistance
of several globally recognised guidelines, to states and businesses to fulfil their existing This is a series of standards which enable or-
frameworks, principles and tools, some of obligations towards respecting and protecting ganisations to become accountable, responsible
which are discussed below. It must be noted human rights and fundamental freedoms and and sustainable. It consists of the (i) AA1000
comply with the existing laws. These principles accountability principles (AP) standard (ii)
that most of these guidelines relate to the
act as global standards for addressing the risk AA1000 assurance standard (AS) (iii) AA1000
larger concept of sustainability or business of human rights violation related to business stakeholder engagement (SE) standard. Since
responsibility, in keeping with the fact that activity. In circumstances when these laws these standards have been formulated through
these concepts are closely aligned globally are breached or the guidance is not adhered a multi-stakeholder consultation process, they
with the notion of CSR. to, suitable remedies have also been recom- ensure that those impacted (that is, enter-
mended. The primary focus is on the protec- prises, governments and civil societies) stand
UNGC tion of human rights by both, the state and the to gain. The Vodafone Group Plc has adopted
UNGC is worlds largest corporate citizenship business enterprises, and the principles broadly the AA1000AP standard by focussing on three
initiative with the objective to mainstream the outline the manner in which the framework can broad areas: (i) inclusivity (stakeholder en-
adoption of sustainable and socially responsible be implemented. gagement to develop and implement a strategic
policies by businesses around the world. The 10 approach to sustainability) (ii) materiality
For more details refer the website of Office of
principles of the UN Global Compact have been (assess the management effort required for
the High Commissioner for Human Rights7
derived from various UN conventions such as each material issue and determine the content
the Universal Declaration of Human Rights, ILOs tripartite declaration of principles on of sustainability reports) (iii) responsiveness
ILOs Declaration on Fundamental Principles multinational enterprises and social policy (respond with solutions to material issues and
and Rights at Work, the Rio Declaration on This is another voluntary declaration whose challenges).
environment and development, and the UN adoption by governments, employers and mul- For more details refer the website of Account-
Convention Against Corruption. These prin- tinational organisations is encouraged, with the Ability10
ciples cover four broad areas: intention of further ensuring labour and social
standards. This is particularly for organisations Social Accountability International (SAI): SA
Human rights (support and respect the 8000 Standard
protection of international human rights that operate across multiple countries. Focus is
and ensure that business is not complicit on core labour standards such as (i) freedom of This is one of the worlds first auditable social
with human rights abuses) association and the right to collective bargain- certification standard. It is based on ILO, UN
ing (prohibition of discrimination, bonded and and national law conventions, and adopts
Labour rights (uphold the freedom of as- forced labour) (ii) industrial relations (no trade a management system approach in order to
sociation and effective recognition of the union restrictions, regular discussions between ensure that companies that adopt this approach
right to collective bargaining, elimination management and labour, and the provision of also comply with it. This standard ensures the
of all forms of forced and compulsory a forum to lodge complaints in case of labour protection of basic human rights of workers.
labour, effective abolition of child labour standard violation) (iii) employment opportu- The nine basic elements of this standard in-
and elimination of description in respect nities (creation of job security, improved living clude (i) child labour (ii) forced and compul-
of employment and occupation) and working conditions and ensuring that sory labour (iii) health and safety (iv) freedom
Environment (support a precautionary wages are on par with those of other enter- of association and the right to collective
approach to environmental challenges, prises in the same country). bargaining (v) discrimination (vi) disciplinary
undertake initiatives to promote greater practices (vii) working hours (viii) remunera-
For more details refer the website of ILO8
environmental responsibility and encour- tion (ix) management systems. According to
OECD Guidelines: Multinational enterprises SAAS, there are 695 facilities in India that have
age the development of environmental
friendly technology) OECD Guidelines for multinational enterprises been accredited with this standard. Out of
elaborate on the principles and standards for these, Aditya Birla Chemicals (India) Limited,
Governance (work against corruption in Bhilai Steel Plant Steel Authority of India
responsible business conduct for multinational
all forms, including bribery and extor- Limited, Birla tyres, Dr Reddys Laboratories
corporations. These guidelines were recently
tion). Limited and Reliance Infrastructure Limited
updated in 2011. They cover areas such as
For more details refer the website of UNGC 6 employment, human rights, environment, figure prominently in the list of certified facili-
information disclosure, combating bribery, ties within India.
consumer interests, science and technology, For more details refer the website of SAI11
competition and taxation. They contain defined
standards for socially and environmentally
responsible corporate behaviour, and also pro-
vide procedures for resolving disputes between
corporations and communities or individuals
adversely impacted by business activities.
For more details refer the website of OECD9
6 www.unglobalcompact.org/
7 http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf
8 http://www.ilo.org/empent/Publications/WCMS_094386/lang--en/index.htm
9 http://oecdwatch.org/about-oecd/guidelines
10 http://www.accountability.org/standards/
11 http://www.sa-intl.org/index.cfm?fuseaction=Page.ViewPage&PageID=937
Handbook on Corporate Social Responsibility in India 9
ISO 26000: Social responsibility The SROI Network National Voluntary Guidelines on Social,
This is a guidance tool provided by the ISO The SROI Network is a framework based on Environmental and Economic Responsibili-
which enables organisations to understand the social generally accepted accounting principles ties of Business
meaning and significance of social responsi- (SGAAP) that can be used to help manage and These guidelines rolled-out by the Ministry
bility. It is important to note that this is not a understand the social, economic and environ- of Corporate Affairs in India, were developed
certification but only a guiding tool. Hence, or- mental outcomes created by an organisation or through an extensive consultative process with
ganisations which comply with these standards a person. In order to increase the social value or the objective of providing a distinctive India-
are self-certified. It covers six core areas of impact of a task, SROI helps in understanding, centric approach for Indian businesses to un-
social responsibility, including (i) human rights managing and communicating the social value derstand the nuances of responsible business,
(ii) labour practices (iii) environment (iv) fair that a particular task creates in a clear and applicable to large and small businesses alike.
operating practices (v) consumer issues (vi) consistent way with customers, beneficiaries They are easy to comprehend and implement,
community involvement and development. and funders. It also helps in managing risks and and encourage businesses to adopt the triple
This ensures a holistic approach to the concept identifying opportunities and raise finances. bottom line approach. These guidelines consist
of social responsibility and sustainable develop- It flags potential improvements to services, of nine principles which relate to ethics and
ment. information systems and the way to govern the transparency, product life cycle sustainability,
businesses. By forecasting the value a company employee well-being, stakeholder engagement,
For more details refer the website of ISO12
expects to create using SROI, one can identify human rights, environmental stewardship,
OECD CSR policy tool the areas where changes are required and a responsible policy advocacy, inclusive develop-
The OECD CSR policy tool aims to help comparison of performance against forecasts ment and consumer well-being. Each principle
companies gain insight into their current CSR will help create additional value. consists of core elements that further articulate
activities, assess its value and determine other the purpose and sense of each principle. It
For more details refer the website of SROI15
CSR activities that can be employed. This policy also provides an approach for adopting these
tool is based on the OECD Guidelines and the The LBG model guidelines.
ISO26000 implementation guidelines. The re- Companies across the world adopt LBGs For more details refer the website of MCA17
sult of the policy tool is a complete CSR policy, measurement model in order to assess the real
including an action plan with tasks, responsi- value and impact of their community invest-
bilities and a communication strategy plan. ment to both, the business and society. This
model helps companies to understand the total
For more details refer the website of OECD13
amount of cash, time and in-kind invested with-
Global Compact Self-Assessment Tool in the community, and enables them to under-
The Global Compact Self Assessment Tool is an stand the geographic spread of their commu-
easy-to-use guide designed for use by compa- nity support and the kind of themes supported
nies of all sizes and across sectors committed such as education, health and arts and culture.
to upholding the social and environmental Through this model, companies can track the
standards within their respective operations. manner in which their community programme
The tool consists of 45 questions with a set of supports wider business goals such as building
three to nine indicators for each question. It employee morale or creating reputational
consists of a management section and four advantages. Also, it helps to measure the differ-
other sections, including human rights, labour, ence their programmes make to the community
environment and anti-corruption that relate to at large. Under this model, member companies
the principles of the UN Global Compact. The share data and best practices which in turn help
tool is in line with the UN Guiding Principles in the benchmarking process.
on Business and Human Rights. For a small For more details refer the website of LBG16
company, this tool acts as a measure of the
companys performance in all areas of the UN
Global Compact and how well these issues are
managed. For a large organisation, this tool
helps to continuously improve existing policies
and systems, engage subsidiaries, suppliers or
other stakeholders, and improves internal and
external reporting.
For more details refer the website of Global
Compact Self-Assessment Tool14

12 http://www.iso.org/iso/home/standards/iso26000.htm
13 http://www.oecdguidelines.nl/get-started/creating-a-csr-policy/
14 http://www.globalcompactselfassessment.org/aboutthistool
15 http://www.thesroinetwork.org/117-home/all-regions/167-why-should-i-use-sroi10
16 http://www.lbg-online.net/about-lbg.aspx
17 http://www.mca.gov.in/Ministry/latestnews/National_Voluntary_Guidelines_2011_12jul2011.pdf

10 PwC
Clause 135,
Companies Act,
2013

Handbook on Corporate Social Responsibility in India 11


The Companies Act, 2013 fiscal year 2014-15 onwards, also require The Act lists out a set of activities eligible
companies to set-up a CSR committee under CSR. Companies may implement
In India, the concept of CSR is governed consisting of their board members, these activities taking into account the local
by clause 135 of the Companies Act, 2013, including at least one independent director. conditions after seeking board approval.
which was passed by both Houses of the The indicative activities which can be
Parliament, and had received the assent The Act encourages companies to spend at
undertaken by a company under CSR have
of the President of India on 29 August least 2% of their average net profit in the
been specified under Schedule VII of the
2013. The CSR provisions within the Act previous three years on CSR activities. The
Act.
is applicable to companies with an annual ministrys draft rules, that have been put
turnover of 1,000 crore INR and more, or a up for public comment, define net profit The draft rules (as of September 2013)
net worth of 500 crore INR and more, or a as the profit before tax as per the books of provide a number of clarifications and while
net profit of five crore INR and more. The accounts, excluding profits arising from these are awaiting public comment before
new rules, which will be applicable from the branches outside India. notification, some the highlights are as
follows:
List of activities under Schedule VII Surplus arising out of CSR activities will
have to be reinvested into CSR initiatives,
and this will be over and above the 2%
figure
The company can implement its CSR
Promotion of activities through the following methods:
education
-- Directly on its own
-- Through its own non-profit
foundation set- up so as to facilitate
Eradication of extreme this initiative
hunger and poverty
-- Through independently registered
non-profit organisations that have a
record of at least three years in similar
Gender equity and
such related activities
women empowerment
-- Collaborating or pooling their
resources with other companies
Reducing child Combating
Only CSR activities undertaken in India
mortality and HIV-AIDS,
will be taken into consideration
improving maternal malaria and other
health diseases Activities meant exclusively for
employees and their families will not
Contribution to qualify
Prime Ministers
Social relief fund and other A format for the board report on CSR
business such state and has been provided which includes
Environmental projects amongst others, activity-wise , reasons
central funds
sustainability
for spends under 2% of the average net
profits of the previous three years and
Employment a responsibility statement that the CSR
enhancing policy, implementation and monitoring
And such
vocational process is in compliance with the CSR
other matters
skills
as may be objectives, in letter and in spirit. This has
prescribed to be signed by either the CEO, or the MD
or a director of the company
Governance
Clause 135 of the Act lays down the

12 PwC
guidelines to be followed by companies activities, including the expenditure, the Reporting
while developing their CSR programme. type of activities, roles and responsibilities
The new Act requires that the board of the
of various stakeholders and a monitoring
The CSR committee will be responsible company shall, after taking into account
mechanism for such activities. The CSR
for preparing a detailed plan on CSR the recommendations made by the CSR
committee can also ensure that all the kinds
committee, approve the CSR policy for
of income accrued to the company by way of
the company and disclose its contents in
CSR activities should be credited back to the
their report and also publish the details
community or CSR corpus.
on the companys official website, if any,
in such manner as may be prescribed. If
the company fails to spend the prescribed
amount, the board, in its report, shall
specify the reasons.
Role of the board and the CSR committee
Business responsibility
reporting
Net worth > 500 Crore INR
Turnover > 1000 Crore INR The other reporting requirement
Net profit > 5 Crore INR mandated by the government of
India, including CSR is by the SEBI
which issued a circular on 13 August
2012 mandating the top 100 listed
companies to report their ESG
Role of the board CSR committee initiatives. These are to be reported
in the form of a BRR as a part of the
annual report. SEBI has provided a
template for filing the BRR. Business
responsibility reporting is in line with
Form a CSR commiittee Three or more directors with at least one
independent director
the NVG published by the Ministry
Approve the CSR policy of Corporate Affairs in July 2011.
Formulate and recommend a CSR Provisions have also been made in
Ensure implementation of the activties policy to the board the listing agreement to incorporate
under CSR
Recommend activities and the amount
the submission of BRR by the relevant
Ensure 2% spend of expenditure to be incurred companies. The listing agreement
also provides the format of the BRR.
Disclose reasons for not spending the Monitor the CSR policy from time to The BRR requires companies to report
amount (if applicable) time
their performance on the nine NVG
principles. Other listed companies
have also been encouraged by SEBI
to voluntarily disclose information
on their ESG performance in the BRR
format.

Handbook on Corporate Social Responsibility in India 13


CSR: Planning
and strategising

14 PwC
CSR: Planning and This is an excellent starting point for any repetitive processes such as the
company new to CSR. In case a company annual CSR policy, due diligence of
strategising the implementation partner, project
already practices CSR, this committee
The first step towards formalising CSR should be set up at the earliest so that it development, project approval,
projects in a corporate structure is the can guide the alignment of the companys contracting, budgeting and payments,
constitution of a CSR committee as per the monitoring, impact measurement and
activities with the requirements of the Act.
specifications in the Companies Act, 2013, reporting and communication
clause 135. For effective implementation, the CSR
A set of such enabling processes, their
committee must also oversee the systematic
inter-relationships and the sequence in
Background development of a set of processes and
which they need to be developed have been
guidelines for CSR to deliver its proposed
Clause 135 of the Companies Act, 2013 identified below:
value to the company, including:
requires a CSR committee to be constituted
one-time processes such as developing
by the board of directors. They will be
the CSR strategy and operationalising
responsible for preparing a detailed plan the institutional mechanism
of the CSR activities including, decisions
regarding the expenditure, the type of CSR processes
activities to be undertaken, roles and
responsibilities of the concerned individuals
and a monitoring and reporting mechanism.
The CSR committee will also be required to
ensure that all the income accrued to the 1
company by way of CSR activities is credited
Developing a CSR strategy
and policy + Operationalising the
institutional mechanism
back to the CSR corpus.

Companies Act, 2013, Clause 135: CSR


committee requirements
A CSR committee of the board should
be constituted. It should consist of at 2 Due diligence of the
implementation partner + Project development

least three directors out of whom at


least one is an independent director.
This composition will be disclosed in
the boards report as per sub-section
(3) of section 134.
Finalising the
The CSR committee shall:
-- formulate and recommend a CSR
3 Project approval + arrangenment with the
implementing agency
policy to the board, indicating the
activities as specified in Schedule Project implementation
VII of the Act
-- recommend the amount of
expenditure to be incurred on the Progress monitoring
activities indicated in the policy 4
and reporting
-- monitor the CSR policy regularly

Report consolidation
5 Impact measurement + and communication

Handbook on Corporate Social Responsibility in India 15


While developing these processes, no CSR policy refers to what the company Geography: The Companies Act, 2013
standard set of recommendations exist for expects to achieve over the next year. encourages companies to target their CSR
all companies. However, an overview of the This is aligned with the requirements of interventions in their local region. While
required details, the activities required to be the Companies Act, 2013 . this is an obvious choice for companies that
completed for each of these processes along Programme refers to a sector or an are in manufacturing, those in the services
with some additional guidance on critical issue that the company proposes to sector (like banking and telecom) with a
issues has been provided below: address through its CSR. This can, wider footprint have no concentrated local
for instance, be education of the girl region. Companies must decide whether
Step one: Developing a CSR child or agriculture development. their CSR activities will be focused on a
strategy and policy Programmes will be clearly outlined in few geographies (this can be around their
the companys CSR strategy.
Purpose plants or in specific backward districts) or
Programme goals will be achieved whether they will prefer to particularly work
The Companies Act, 2013 requires every through a series of individual projects anywhere in India.
company to put out its CSR policy in the and, a project refers to a set of
public domain. The guidance provided interventions, typically in a specific Sector and issue: Sector refers to the
in the Act and the draft rules on what geography and addressing a specific development area that the company wishes
stakeholder group, with a definite set of to focus on; typically, health, education,
constitutes a CSR policy are that it should:
goals, beginning and end and a budget livelihood, environment, and so on.
exclude normal business activities of attached to it. Issue refers to a specific aspect of a sector
the company
Each project in turn will consist of for example, primary education in the
contain a list of the CSR projects or a number of activities. All of which education sector, skills development or
programmes which the company contribute towards the project goals. social enterprise in the livelihoods sector.
plans to undertake during the It is important for a company to determine
implementation year Frameworking CSR strategy which sector and issues it will focus on to
While specifying the annual report An effective CSR strategy should articulate: ensure significant positive impact. Also,
requirements, the draft rules go on to say is who it wishes to address i e the target the reporting format in draft rules of the
that the company must provide: group Companies Act, 2013 requires that the
a brief outline of its CSR policy, company report against the sector making it
where it wishes to work i e the
including the statement of intent geography all the more important.
reflecting the ethos of the company,
what sectors or issues it wishes to Process
broad areas of CSR interest and an
address
overview of activities to be undertaken Objective: Developing the CSR strategy and
a web link to the CSR policy including A brief understanding of these terms is policy.
the full list of projects, activities outlined below: Process owners: The CSR committee
and programmes proposed to be Target group: While development and
undertaken by the company Inputs:
welfare programmes in India address all the
citizens, the focus is on the disadvantaged, Guidance from the board
Since most of the development requires
long-term commitments and their impact marginalised and excluded. Marginalisation Companies Act requirements
often takes a while to accrue, a good CSR in India is primarily on the basis of gender, Corporate business strategy, plan and
practice requires that a company that is disability, ethnicity and location. This leads supply chain
serious about its CSR should develop a to social and physical exclusion of such
Development priorities: both, national
long-term (three to five years) vision and groups from all kinds of development.
and wherever the company has
strategy which is reviewed annually and the Engaging the marginalised in India is business interests
activities and budgets are planned on an further complicated due to language and
annual basis. The latter will comply with the literacy variances, information asymmetry, Output(s): the CSR policy document and an
infrastructure constraints, geographical indication of sectors and issues, geographies
CSR policy requirements of the Companies
challenges and cultural barriers to name and a profile of the beneficiaries.
Act, 2013.
a few. The CSR strategy should ideally
To avoid confusion regarding terms like
indicate which of these marginalised groups
policy, strategy, project and programme, a
it proposes to target.
brief explanation has been provided here:
CSR strategy refers to what the
company expects to achieve in the next
three to five years and incorporates the
vision, mission and goals on a broader
level. It also entails how it plans to
achieve these in terms of organisation
and approach.

16 PwC
Activities Determining the implementation Step two: Operationalising the
mechanism: institutional mechanism
Reviewing the past as well as the
current CSR activities and examining -- grant-making or direct
their alignment with Schedule VII of implementation
Purpose
the Companies Act, 2013. In order for a corporate to gain the greatest
-- institutional mechanism: in-house
Studying the publicly available leverage and a strategic advantage through
department, corporate foundation,
information on national and local the investment of intellectual and financial
partnerships with other NGOs
development priorities. resources, they are required to select their
Annually developing a CSR policy in implementation mechanism. In terms of
Meeting development experts in the
line with the Companies Act, 2013 rules implementation mechanism, a company has
government as well as the NGOs to
that defines programmes, geographies
understand priorities and identifying several options, which are permitted under
and budgets for the following financial
potential areas of intervention. the CSR draft rules:
year, aligned with the strategy and
Conducting internal meetings with ensuring that the 2% requirement of Self-execution through:
business leaders to establish the funds allocation is met
relevance of potential CSR activities to -- an in-house CSR department
Establish methods for monitoring and
the companys core business. -- a company foundation with execution
reporting
Studying the good CSR practices capabilities
of other companies and their Tools, technical guidance and Making grants to an independent
achievements. standards to be used: implementation partner (which has a
Developing a CSR strategy that defines The 10 principles of the UN global track record of at least three years).
for the next three to five years, what compact The grants can be made:
the companys CSR activities will cover
in terms of: UN guiding principles on business -- directly by an in-house CSR
and human rights department
-- vision and mission
ILO tri-partite declaration of -- through the companys grant-making
-- sectors and issues principles on multinational foundation
-- geographies: states and districts enterprises and social policy
The factors that a company needs to
-- beneficiaries OECD CSR policy tool consider while deciding between in-house
-- KPIs Global compact self assessment execution and grant-making (whether
by the department or the company
Clause 135, Companies Act, 2013 foundation) are as follows:

Decision criteria Grant making Self execution


Availability and access to Preferred when there is an easy availability and Preferred when there is a lack of availability and
implementation partner access to the implementation partners (in the target access to the implementation partners (in the
geography working on identified sector and issue) who target geography working on identified sector and
can work towards the objective that the company wants issue) who can work towards the objective that the
them to pursue. company wants them to pursue.
Customisation The flexibility of customising a CSR project to suit the The flexibility of customising a CSR project to suit
company needs is low to medium. the company needs is high.
Cost of implementation Implementation partners are more likely to have lower Overheads are usually higher and economic
costs due to their concentrated focus in pursuing efficiencies lower (at least during inception and
development activities, cumulative time spent on growth phases). Higher fixed costs are involved.
the field, cost of human resources deployed and
in general operational efficiencies. Fixed costs are
usually averaged down as the implementation partners
usually try to tap multiple sources of funding including
government assistance.
Control Low to medium levels of control over day to day High levels of control over day to day activities,
activities, efficiencies and outputs. efficiencies and outputs.
Building expertise Project management know-how is sufficient and in- Project management know-how is required along
depth domain knowledge of development issues is not with in-depth domain knowledge of development
expected. issues.

Handbook on Corporate Social Responsibility in India 17


It must be noted that whatever Process Step three: Due diligence of the
implementation mechanism the company implementation partner
Objective: Establishing a legal entity and
chooses, it must have a basic CSR
aligning the accounting, tax, finance, Purpose
department in place to support the CSR
administration, HR and IT systems to deliver
committee. The role and structure of the Due diligence refers to the process a
the commitments made in the CSR policy.
department will be determined by the CSR company undertakes to determine the
committee. Process owners: The CSR committee risks as well as the benefits of working
Selecting legal structure of the Inputs: The CSR strategy with a potential implementation partner.
This process has to be sufficiently robust to
company foundation Output(s):
ensure that a companys implementation
Many companies have set up their own creation of a separate legal entity or a partners have the reputation, competence
foundations (a term used loosely to describe CSR department for CSR activities and integrity to deliver effective
a non-profit entity promoted by a company) other institutional mechanisms programmes on the ground.
to implement their CSR activities. The to align the accounting, finance,
It begins as soon as the discussions with
advantages that they see in this are: administration, HR and IT systems with
CSR activities the implementation partner suggest that
It enables leveraging of funds from there is prima facie interest of both parties
other sources i e the government Activities: to enter into a partnership. A detailed
schemes and other foundations. due-diligence is essential for large and
Selecting the organisation model for
Typically, profit organisations are not
the CSR implementation: in-house long partnerships but may be brief for a
eligible for such funds.
versus outsourced and its legal entity relatively small or opportunistic partnership
Since the skills, job titles, career paths (trust, society, Section 819 company , opportunity.
and cost structures required for the in-house department, etc)
execution of CSR projects are quite The due diligence process consists of five
different from a companys operations, Identifying the implementation model primary areas for investigation:
a separate foundation enables the (grant making, direct project execution,
etc) competence of the implementation
company to keep these distinct. partner
Formalising the job description,
Under the draft CSR rules, an entity identity
the roles and responsibilities and
that a company sets up to facilitate the the reporting relationships for the management
implementation of its CSR activities is to CSR team (whether in-house or in a
be registered in India as a trust, society, foundation) accountability
or a non-profit company under section 818 transparency and financial capability
Integrating budgeting, procurement,
of the Companies Act, 2013. Non-profit payments and reporting for CSR with
organisations in India are: These have been outlined below:
the existing finance, administration
self-governed by a board of trustees or and IT systems
a managing committee or a governing Analysing accounting systems and
council, comprising individuals who chart of accounts and make required
generally serve in a fiduciary capacity changes to record all expenses
intended to benefit others outside the appropriately. Establish a method of
membership of the organisation allocation for the expenses (or assets
created) that are partly for the CSR
prohibited from distributing a and partly for business or employee
monetary residual to its members use.
A detailed comparative analysis of the
three choices of non-profit legal structures Tools, technical guidance and
is attached in Appendix 1: Comparative standards to be used:
analysis of the three choices for legal To be tailored as per corporate
entity. requirements

18,19 The non-profit organization formerly known as Section 25 companies are now called Section 8 companies after the introduction of Companies Act, 2013.

18 PwC
Issue Sub-issue Description

Competence of the Geography Capacity, expertise and the number of years of experience with the geography under consideration
implementation Sector Capacity, expertise and the number of years of experience with the sector under consideration
partner Issue Capacity, expertise and the number of years of experience with the issue under consideration
History of existence The number of years the implementation partner has been in existence
Legal identity The organisation is registered either as a trust, a society or Section 8 company, a charitable company,
Identity a co-operative society or is unregistered
Affiliations The desired level of affiliation with governments, local administration and international bodies
Litigations Any ongoing litigation
Composition of the board Number of members, advisors, term of members and advisors and board renewal procedures
Profile of the board Bios of the members on the board, their number of years and depth of experience and relevant
members and advisors achievements
Diversity in expertise The expertise available at the disposal of the board for development activities
Board meetings Regularity of meetings, attendance records and recent topics of discussion
Management
Vision, mission and The management outlines its vision, mission and strategy in its operational plans or other documents.
strategy These plans are communicated to all relevant employees
Experience of the The management personnel responsible for the day-to-day activities have the necessary depth of
management experience and skill set to manage the current and the future growth plans.
Conflict of interest Any conflict of interest between the board members, the advisors or the management personnel with
the company. There is no conflict of interest with the local governments.
Transparency Transparency Awareness of the disclosure and the transparency requirements for all stakeholders (including
regulators and funders) like periodic reporting, external audits and ratings
Financial statements Availability of audited financial statements
Adequacy of reserves A formalised and institutionalised system for keeping reserves for times of financial need
Financial capability Section 12A registration Status of Section 12A registration
80G registration Status of 80G registration.
FC(R)A registration Status of the registration with the Foreign Contribution (Regulation) Act 2010.

A more detailed due-diligence can also studying the books of accounts and the Step four: Project development
undertake the evaluation of the following auditors report
five issues: Purpose
Output(s):
organisation structure The CSR strategy of a company will be
a due diligence report
implemented through a series of projects
operations, systems and processes Activities: which will have definite beginnings, ends,
human resource expected outputs and outcomes as well as
Establishing a due diligence criteria
financial capability to evaluate the implementation or budgets associated with it. These projects
concept development agency including may be of a short duration (a few months)
risk management its incorporation, permits and licenses, or multi-year.
CII and Credibility Alliances guidelines for systems, processes, public image,
management, team deployment, A company may choose to implement
identifying NGO partners are mentioned in
track record, financial soundness, projects through its in-house teams or
Appendix 4.
competence level, presence in desired in partnership with other agencies or a
Process geography, compatibility with company combination of both. Whatever path it
CSR policy and any conflicts of interest. takes, it is important for the project to be
Objective: Selecting the implementation
Establishing a due diligence criteria developed clearly with distinct baselines,
partner.
for evaluation and empanelment of defined activities, monitorable targets and
Process owners: The CSR department or private funders for partnership and budgets. In the case of multi-year projects,
Company Foundation joint projects. it is important to include a provision to
Inputs: Evaluating the partnership undertake annual reviews which can form
opportunities for its risks and benefits. the basis to revise the project.
the CSR strategy and policy
discussions with communities, board, Tools, technical guidance and
staff, other funders, local government standards to be used:
officials, local leaders or influencers, To be tailored as per corporate
auditors requirements.
Handbook on Corporate Social Responsibility in India 19
Process Detailing the project: the objectives, Inputs:
the beneficiaries and the impact on
Objective: Developing a feasible project a project proposal
the beneficiaries, the assumptions,
proposal. the expected outputs and outcomes, a due diligence report
Process owners: The implementation detailed activities, potential to Output(s): An approved project proposal
agency (the CSR department, company influence public policy and practice.
including a monitoring process and
foundation or the NGO partner) Identifying the indicators of success reporting and responsibility for this.
with the means of verification and
Inputs: establish the baseline for each. This can Activities:
the CSR policy be commissioned as a separate study Determining the delegation of power
or can even be included in the needs for the project approval.
institutional mechanisms
assessment stage.
information from the government Establishing an evaluation framework
Estimating the budget and how it will for the appraisal of the project concepts
sources, previous studies done in the
be funded specifying the community and implementing agencies that ensure
area, etc
contributions, leveraging of the complete alignment with the CSR
information on programs targeting government schemes and contributions policy.
similar geographies and beneficiary from the other donors.
groups or strategies Establishing tests for the theory of
Indicating the monitoring and change; whether the concept will be
monitoring impact measurement evaluation methodologies for impact able to deliver the intended results.
reports from any earlier projects measurement. Establishing tests for the value for
Output(s): money, economy, effectiveness and
Tools, technical guidance and efficiency.
A project proposal that details: standards to be used: Reviewing risks and mitigation
a project context including the roles of Social return on investments (SROI), measures.
other development actors the SROI network Identifying resource availability
key needs of the target beneficiaries Global impact investing network and any specific organisational
project goals, KPIs, baselines and (GIIN) requirements and constraints.
expected end lines
ISO 26000: social responsibility Laying down organisational supervision
project milestones for progress and oversight requirements.
monitoring purposes Step five: Project approval
Tools, technical guidance and
activities and timelines to achieve the
stated project goals
Purpose standards to be used:
Every project, whether developed by the To be tailored as per corporate
budgets along with the basis for
estimation in-house team or an external agency, must requirements.
be formally examined and approved. This
risks and mitigation strategies Step six: Finalising the
is to ensure that each project is in line with
progress reporting: content, frequency the CSR strategy and policy, the monitoring arrangement with the
Activities: indicators are clearly defined and relevant implementing agency
and there is an adequate budget available.
Developing a framework to identify Projects that go on for longer durations Purpose
key stakeholder groups including the
or demand a larger amount of resources While working with an external agency,
local community, the local government
or bodies, academia and research must be scrutinised more carefully than the it is very important to enter into a formal
institutions, investors, etc. others. arrangement which is referred to here
Conducting a needs assessment (if The CSR committee is ultimately the as a Memorandum of Understanding or
required) to assess development one responsible for every project. It can, MoU. It defines the roles, responsibilities,
priorities. The methodology for this can however, choose to delegate authority to deliverables, commitments and
be participatory processes, surveys or a a project approval committee consisting consequences in case of any breach. This is
combination of the two. of company staff and outside experts with essentially a formal acknowledgement that
Studying and adopting good practices clearly defined roles and responsibilities. all the partners have voluntarily consented
to address similar challenges based on to work together to achieve an agreed
prior experiences or lessons available Process outcome that requires each one to play their
from other practitioners and develop Objective: Approve the project based on respective roles.
the approach. the CSR policy objectives, principles and The term MoU is used more generically
guidelines. here to refer to the arrangements between
Process owners: The CSR committee or the partners which can range from a formal,
delegated project approval committee. legally enforceable contract on the one hand
to a simple exchange of written documents

20 PwC
on the other. However, what is important Process To ensure objectivity, it is critical that the
for the company to keep in mind is that monitoring is done by someone other
Objective: Agree upon and sign the MoU than the people directly engaged in the
it is entering into an arrangement with a
with the partner. project implementation. In cases where
partner, not a supplier and there is a greater
sense of mutuality in this relationship. Process owners: The CSR department or the implementation is done by a partner or
company foundation corporate foundation, this role can either be
It may also be noted that the MoU is
outsourced or played by the companys CSR
relevant only if the project is being Inputs:
department. In case the CSR department
implemented by a legal entity other than an approved project proposal itself is implementing a project, then
the companys own CSR department. It
a due diligence report monitoring should either be outsourced to
must also be executed if the project is being
a third party or the department structure
implemented by the company foundation if Output(s): MoU with the implementing
should include an independent monitoring
it is a separate legal entity. agency including the disbursement
cell. This decision should be taken by the
schedule.
Disbursement scheduling CSR committee.
Activities:
For a project to deliver the desired results, Process
it should have sufficient funds to carry out Developing template MoUs based
on the context. Specify the outputs Objective: Monitoring progress, distilling
the planned activities. At the same time,
and outcomes, the approach and lessons and forming the basis for reporting.
having excess funds in the bank account
methodology, the KPIs, key parameters Process owners: The CSR committee
is not prudent financial management.
to be monitored and reported, the
Thus, the scheduling of disbursements is mode of communication, contract Inputs:
important both for the company (to plan its management team, scope of change
cash flows from the CSR budget) and the The approved project proposal
in management procedures, dispute
implementing agency and hence needs to be or conflict resolution mechanisms, Previous monitoring reports
detailed in the MOU. inspection and audit requirements,
Output(s):
contract closeout requirements, time-
A good practice suggests that the scheduling lines, milestones and deliverables, Determining mid-course corrections
of disbursements should be linked with budgets, process of invoicing and
the activities planned for the each period; Recommendations for future project
release of payments, etc designs
this can be a quarter, six months or a
Establishing a process for negotiation Project monitoring reports to the CSR
year depending upon the administrative
of the MoU with the implementing
convenience and budget sizes. Thus, the committee
agency.
project budget needs to be broken up Activities:
accordingly and the funds required for the Negotiating, agreeing upon and signing
subsequent period should be made available the MoU Determining the monitoring schedule
for each project based on the approved
in advance. Tools, technical guidance and project proposal.
Actual disbursements have to then be linked standards to be used:
Obtaining all relevant progress reports
to the progress on the ground. The MoU To be tailored as per corporate from the project, studying them and
should also specify the conditions that the requirements. making a note of the gaps.
implementing agency should fulfil and the
Holding discussions with the
documentation it should provide in support Step seven: Progress monitoring implementation team on reasons for
of a disbursement request. Typically, these
and reporting slippages (if any) and agreeing on a
include the status of: corrective action. This may be done
activities originally planned in the Purpose through a field visit or remotely, based
period on what has been agreed in the MoU.
Routine progress monitoring serves the
changes and the reasons thereof following three important purposes: Holding discussions with the
implementation team regarding what
planned and required funds for the It highlights any slippages and helps to lessons are emerging and how they can
period determine a corrective action that must be applied within the project as well as
be taken if need be.
utilised funds and bank balances outside.
It provides an excellent opportunity
net funds required for learning: what worked and what Tools, technical guidance and
did not. This can then be immediately
standards to be used:
applied to other projects.
To be tailored as per corporate
This is an essential part of the directors
report as per the CSR clause of the requirements.
Companies Act, 2013

Handbook on Corporate Social Responsibility in India 21


Step eight: Impact measurement Activities: Act, 2013. The report has to conform to
Identifying methods for conducting the requirements of CSR rules under the
Purpose Companies Act, 2013 in terms of form
the impact assessment and outcome
Impacts of the development projects measurement suited to the context and content as non-compliance attracts
typically take a while to manifest. For and the size of the project and budgets penalties. This report will also form a key
instance, a girl child education programme available. input into the companys SEBI Business
can show an increased enrolment and Identifying the skills set required for Responsibility Report and sustainability
retention of girls and on a monthly basis, the impact measurement team and report. The CSR committee may choose
but further impacts such as improved accordingly identifying, selecting and to go beyond the requirements of the
learning levels will take at least a year. appointing the team. Companies Act, 2013 and issue a stand-
So, impact measurement studies have Assisting the team to prepare the alone CSR report.
different objectives from project monitoring methodology for selecting a sample, Process
and typically have to be undertaken after conducting surveys, focus group
providing sufficient time for them to discussions collecting information on Objective: Reporting the CSR at an
manifest. the identified indicators. individual project level, consolidated at
Making the provisions for the site visits a programme level and aligned with the
Impact measurement is often quite
by the team, involvement of the agency requirements under the Companies Act,
specialised and needs to be undertaken
involved during the baseline and needs 2013 and the CSR committee.
by an independent team with specific
assessment.
skills depending upon project design. Process owners: The CSR department
For instance, if a girl child education Undertaking the impact measurement
Inputs:
programme has a strong component exercise and preparing the report.
CSR strategy and policy
for mobilising communities, then the Identifying the lessons for future
members of the evaluation team must not interventions. the project MoU
only understand education but also have monitoring reports from individual
knowledge of gender and the community in Tools, technical guidance and
projects
order to assess the impact. standards to be used:
Output(s):
There are several tools and frameworks London Benchmarking Group(LBG)
model consolidated CSR reports
for measuring impact. Each has its pros
and cons depending upon the nature of Social return on investments (SROI), external stakeholder communication
interventions, time and budgets available The SROI network Activities:
for the study and the availability of people.
Global impact investing network Identifying the recipient of the report:
Thus, selecting the impact measurement
(GIIN) the board of directors, investors,
methodology is important.
government agencies, beneficiaries, etc.
Accountability -: AA 1000, Institute
Thus, impact studies have to be carefully Selecting the appropriate reporting
of Social and Ethical Accountability
planned in terms of team composition, framework that is aligned with the
timing and methodology. The process must ISO 26000: social responsibility requirements of the Companies Act,
be driven by the CSR committee which can Public consultation guidelines of 2013 and the global best practices.
delegate the day-to-day management of the Government of India, etc Consolidating project reports into
process to an appropriate structure within programme reports and an overall CSR
the company. report.
Step nine: Report consolidation
Process and communication The reporting format will form a part of the
Objective: Measuring the outcome and CSR rules being drafted by the Ministry of
Purpose Corporate Affairs.
impact of the projects.
Reporting and communication closes the
Process owners: The CSR committee loop between intent and achievement and is Tools, technical guidance and
Inputs: hence a crucial element of the CSR process. standards to be used:
In the context of the Companies Act, 2013 SEBI directive on ESG disclosure (if
resource planning
this is also a mandatory requirement as it applicable) , RBI guidelines on CSR,
the project MoU provides crucial inputs to preparing the sustainable development and non-
Output(s): directors report. financial reporting (if applicable)
impact measurement report Project-level reporting forms the base Clause 135, Companies Act, 2013 (if
recommendations for the future project and hence getting it right is critical. applicable)
designs Project reports have to be consolidated in
programme related reports, aligned with
the CSR policy stated by the company
as a requirement under the Companies

22 PwC
CSR and SMEs

Handbook on Corporate Social Responsibility in India 23


CSR and SMEs Why collaborate for CSR
What are SMEs? initiatives?
CSR is for all companies. SMEs in India
Small and medium enterprises (SMEs)
have participated in CSR activities but these
significantly contribute towards
efforts have not been optimally delivered.21
Indias economic growth. These serve
One possible reason can be the fact that CSR
independently and also as ancillary to larger
activities depend on the profits of an SME
units and help generate employment and
and any fluctuations in profits can adversely
industrialise the rural and backward regions
affect their capability to continue their
of India. They employ nearly 40% of Indias
contribution for CSR. Another reason can
workforce and contribute around 45% to
be the limited human resources available to
Indias manufacturing output20.
SMEs which may also result in the lack of a
What do they do? professional approach.
The business activities of SMEs are SMEs tend to focus on short-term activities
performed in proximity to the locals. This that involve lesser operational costs. A
enables them to be aware of community survey conducted by UNIDO in 2008 on five
needs, manage expectations and develop SME clusters in India, found that 31% to
CSR programmes appropriately. 79% of the SMEs in these clusters, preferred
charity donations rather than long-term
Now that the CSR clause in the Companies
programmes for local communities.
Act, 2013 covers companies that have a
net profit of five crore INR and above, it With the introduction of the new Companies
is expected that while micro-enterprises Act, 2013, the SMEs approach to CSR has
will not qualify, many small and medium to be modified while keeping operational
enterprises (SMEs) will. costs low. One viable alternative is to pool
resources with other SMEs in the cluster
SMEs are being treated separately in this
and create joint CSR programmes managed
handbook because of their distinct features.
by a single entity. This collaboration can be
The CSR activities of these enterprises
formed within the units in a cluster as they
are driven by the personal interests of
interact with the same communities and
promoters who hold a significant financial
have already established associations that
stake in the business. They tend to be in
cater to the business needs of the units.
clusters and engaged in similar business
activities. While the quantum of revenue Collaboration has the following
available for CSR with individual SMEs is advantages:
expected to be small, all eligible companies Reduces operational cost: Individual
in a specific geographical cluster, who single CSR efforts by a company consist
handed as well as collectively impact the of establishing a CSR department,
same community, can pool their resources assessing the needs of local
to create a sizeable CSR fund. communities, undertaking programmes
directly or through an NGO and
How can SMEs contribute to CSR conducting regular impact assessment
initiatives? studies. A common organisation
catering to a number of companies will
This section analyses the option of carry out these activities collectively
undertaking collaborative CSR activities and thus reduce the operational cost of
by SMEs. This collaboration can also be management.
used by other companies to maximise
Undertake long-term projects: A
the impact of their CSR initiatives while major hindrance in developing long-
reducing the operational costs for fund term projects is the uncertainty in the
management. CSR budget. This is dependent on the
financial performance of the company.
A fluctuating performance implies
that the CSR budget allocations can
be unreliable and can jeopardise a
programme initiated earlier. Pooling
resources addresses this issue to a

20. http://articles.economictimes.indiatimes.com/2013-06-09/news/39834857_1_smes-workforce-small-and-medium-enterprises
21. http://www.business-standard.com/article/sme/smes-to-get-professional-help-on-corporate-social-responsibility-108060501090_1.html

24 PwC
certain extent as the other partners The steps other than the guidelines
can increase their share in case there mentioned by the steering committee in the
is variance in allocation from a certain section CSR: Planning and strategising of
segment of the cluster. The long- this handbook, include the following:
term programmes also have greater
impact than the short-term projects. Deciding the thematic areas from
Communities are increasingly realising Schedule VII of the Companies
the importance of the support offered Act, 2013, beneficiary groups and
by these programmes in making their geographies that it will target based on
lives better. Long-term programmes the inputs from participants.
also lead to better community relations Developing internal processes to track
and this ensures avoiding situations individual contribution by members
of community unrest that hamper and their utilisation in CSR activities,
business activities. finalising long-term projects based on
Learning from experiences: A common projected contributions by members
entity with multiple participants from and addressing non-payment by
the cluster will help assess community members.
needs, undertake relevant programmes The CSR policy of individual SMEs should
based on past experiences and address be designed to allow for flexibility in case of
a greater number of community issues.
a collaborative effort to undertake CSR. This
Collaboration among the SMEs in a cluster implies that the policy, over and above the
also provides an opportunity to manage guidelines mentioned in the section Step
social and environmental issues and one: Develop CSR strategy and policy,
respond better to the pressure from buyers, should allow the following:
who are trying to establish ethical supply Flexibility in selecting thematic areas
chains and gain appreciation from the from Schedule VII of Companies
international community. Collaborations Act, 2013, beneficiary groups and
can also be forged amongst larger geographies as per the priorities of the
companies, possibly through industry entire association.
associations, to enable them to address Support to initiate CSR programmes
common issues plaguing a geographical to the extent possible, in case the
region or an industry. association is abandoned.
The process for an SME The next steps involved in the due
diligence of implementation or the concept
The first step involved in collaborating is to
development partner are:
create an alliance of interested SMEs. This
may be initiated by the cluster association Project development
in case of large-scale participation from the Operationalising institutional
cluster. Alternatively, it can be initiated by mechanism
an individual SME in case there are only Contracting
a few units interested in undertaking CSR
activities in collaboration. Involvement of Budgeting and payments
the cluster association will ensure that the Monitoring
local priorities are given due consideration Impact measurement
while developing CSR programmes. In case
a sufficient number of SMEs in a cluster do Reporting and communication are as
described in section CSR: Planning and
not wish to participate or are not required
strategising
under the Companies Act, 2013 to spend
on CSR activities, the boundary may be In cases where the total CSR funds
extended to other clusters, though this are insufficient to cover the cost of
increases complexity. collaboration, SMEs can also contribute to
the Prime Ministers National Relief Fund
The alliance should then form a steering
or any other fund set up by the central
committee with the representatives from
government or the state governments as
each SME so as to democratically decide on
per activity ix of the Schedule VII of the
issues. The steering committee should study
Companies Act, 2013.
the institutional method of implementation,
i.e. undertaking activities through an
established trust, society, a Section 8
company or forming a new entity or directly
managing the funds.
Handbook on Corporate Social Responsibility in India 25
Appendix 1
Comparative analysis of the three choices for legal entity

Differential factors Trust Society Section 8 company22


(earlier known as Section 25 company)
Basic document Trust deed which contains objects of Memorandum of association Memorandum of association
the trust (bye-law) Articles of association with rules and Articles of association
regulations
Formation Simple Simple Slightly difficult

Jurisdiction Deputy registrar or charity Registrar of Societies Registrar of Companies


commissioner
Legislation / statute Relevant state trust act Societies Registration Act 1860 Companies Act 2013

Objectives Social benefits and charitable Literary, charitable, scientific and Nonprofit activities
resource oriented
Re-amendment Alteration can be undertaken only Easy, legal procedures Complicated, legal procedures
ormodification of by the founder or settler
objects
Required members Minimum = 2, maximum = no limit Minimum = 7, maximum = no limit Minimum = 7, maximum = no limit

Registration As trust with the registrar As society with society registrar As per Companies Act under Section 8 (earlier
Section 25)
Stamp duty 4% of trust property value will be No stamp paper required for No stamp paper required for memorandum and
executed in non judicial stamp paper memorandum of association, and articles of association
with the registrar rules and regulations
Name Easy to choose Easy to choose Prior approval required from Registrar of
Companies
Management board Trustees Governing body Board of directors and management
committee
Succession in By election By election By appointment
management
Meetings No provisions Annual meeting as per law, Quite extensive as per the provision of
governing body meeting as per the Company Law
rules of society,
Statutory regulations Nominal Limited Maturable and exhaustive

Membership transfer Not possible Not possible Free or control as per desire

Member admission Not applicable Governing body control General body or board control through issue
of capital
Payment to members As notified in trust deed Not restricted As approved by company and state

22 The non-profit organizsation formerly known as Section 25 companies are now called Section 8 companies after the introduction of Companies Act,
2013.

26 PwC
Appendix 2
Designing a volunteering programme

As part of their corporate social Design parameter Activities


responsibility efforts, companies encourage
their employees to volunteer for a cause Organisation goals: Laying out the overall Identify volunteering goals of your
objective of a company from its EVP. organisation.
(usually pre-selected by corporate
human resources or foundations) during Employee volunteering mechanism: Establish institutional ownership of
work hours under formalised employee Developing the institutional framework under volunteering programme.
which employee volunteerism can be channelled Establish volunteer codes of practice.
volunteering programmes (EVPs). These
for a larger good. Establish volunteering governing principles.
EVPs involve substantial opportunity
cost for employers and therefore must be Design volunteer programmes and projects.
carefully planned and executed. Draft volunteering agreement including
the statement of volunteer rights and
Who is a corporate responsibilities.
volunteer? Lay out roles and responsibilities of
coordinators for the EVP.
A corporate volunteer is an employee who
actively takes on a task, responsibility, or Ensure continuity in volunteer work.
project on his or her own accord without Recruitment and enrolment: Attracting, Lay out the volunteer recruitment and
needing to be assigned or told to do so as screening and selecting qualified individuals for enrolment process.
part of his or her daily job duties. Corporate a specific volunteer role. Create volunteer roles and writing position
volunteering is generally considered an descriptions.
altruistic activity and is intended to promote Segment and target volunteers.
larger social or environmental good or Write volunteer advertisements.
improve the quality of life of a target Process enquiries and applications.
beneficiary or a community. Undertake selection and interview process.
Most often, there are no financial gains Inducting and training: Welcoming new Design and deliver induction and orientation
for the work or service provided by such volunteers to the EVP and preparing them for programmes.
volunteers. However, sometimes this their role. It provides an introduction to the Train volunteers.
volunteering involves incentives such as working environment where they will volunteer
personality or profile development, skill and available resources. The process will cover
volunteer rights, the terms and conditions of
development, socialisation, and fun. In
volunteering, legal and compliance requirements
certain areas of volunteering work such as and health and safety guidance. It also covers
health services, education or emergency any necessary training needs of the volunteers to
rescue volunteers receive training before perform their duties.
they can contribute.
However, most volunteers serve on a need Mentoring and supervising: Ad hoc assistance Design and deliver mentoring programme.
basis without any prior educational or work by a more experienced and knowledgeable Assign, supervise and establish key
experience of related background. person to help facilitate a less experienced performance indicators for volunteer work.
and knowledgeable person to reach his or Provide performance feedback to volunteers.
Several design parameters and related her individual goals and objectives in the
activities need to considered while Keep volunteers motivated.
volunteering programme. Supervision involves
developing an EVP: management of the individuals performance Manage disputes and grievances.
against a prescribed objective on a routine basis
and providing actionable feedback.
Rewarding and recognising: Rewards and Make volunteering attractive.
recognition are given when an organisation Develop awards and recognition framework.
wants to motivate volunteers in achieving a
goal or organisational objective. Rewards and
recognition are designed to distinguish and
motivate employees. This is important in the case
of volunteering where employees do not have
any financial incentives.
Encouraging diversity: Encouraging employees Communicate the value of diversity.
with unique experiences and backgrounds Develop programmes to encourage diversity.
to work together to increase productivity, Recruit and enroll volunteers from diverse
effectiveness and responsiveness to changing backgrounds.
conditions to enhance their contribution and
benefit from the volunteering exercise.

Handbook on Corporate Social Responsibility in India 27


Appendix 3
Community engagement

A community can be defined as a Steps for robust community engagement Key activities
homogenous group of individuals bound
Assess the local context: Understanding the Undertake socioeconomic assessment.
together geographically, politically,
characteristics and complexities of the local Map local communities and networks.
culturally or by certain values, principles or landscape and use this information for strategic
shared characteristics. For the purposes of Map key institutions engaged with local
planning of community engagement. communities.
this discussion, we define community as the
collection of stakeholders who reside in the Identify potential partners.
local vicinity of company operations and Involve communities: Support and facilitation Identify objectives of community engagement
who rely on or are impacted by its shared of the process of community-driven planning to and its guiding principles.
resources. enable communities to define their own goals, Enable community planning, visioning and
identify opportunities and assets they plan to prioritisation through participatory methods.
Community engagement is defined as utilise or share, and prioritise areas of potential Manage community expectations and
a process in which the needs, priorities engagement with the company and other local perceptions.
and values of various individuals (not development actors.
directly associated with or dependent
on a given company) and that of other Identify and categorise key stakeholders: Identify and segment various target groups.
external organisations in a community Creation of a list of the individuals, groups, and Undertake needs assessment.
are incorporated into corporate decision- institutions that could affect or be affected by any
making and management activities. community engagement project. This step identi-
fies and generates knowledge about individuals
and local organisations in order to understand
Tools, technical guidance and their behaviours, intentions, inter-relations and
standards to be used: interests.
Participatory rural appraisal Develop a baseline.
Set operational parameters: Setting up the Identify the company and any shared assets
Focus group discussions
scope and target of such an engagement in line available.
Door-to-door surveys with the activities a company will support. Identify investment areas and budgets.
Develop key performance indicators.
Select implementation model: in-house or
Project implementation: Identifying the foundation, implementation partner, multi-
best way to deliver a project in view of several stakeholder partnership, any other hybrid
variables, such as the objectives of community model.
engagement, project timeframe, budget and local Engage and influence key opinion leaders in
operating context. local community.
Develop community forums.
Invest in capacity building of community.
Co-design detailed development projects with
community participation.
Operationalise development projects and
manage project cycle.
Measure and communicate results: Monitoring Document results on key performance
and evaluation to use the information collected indicators.
in future planning and communicating these Calculate social return on investments.
results to all stakeholders including the com- Develop communications strategy to
munity, the company and other development periodically disseminate information to
partners. community and other stakeholders.

28 PwC
Appendix 4
CII and Credibility Alliances guidelines for identifying NGO partners

1. Identity: The NGO should exist and be The organisation is not for profit and Signed audited statements are prepared
registered under the appropriate law its resources are deployed only for annually and available on request:
under which it is governed. It should accomplishing the objectives for which balance sheet, income and expenditure
comply with the provisions of the Act it has been formed. statement, receipts and payments
and other relevant laws. account, schedules to these, notes on
The organisation has attained
accounts and the statutory auditors
The organisation has been functioning recognition under Section 12A of the
report.
for a minimum of one year from the Income Tax Act. (80G of the Income Tax
date of registration. Act is preferable). Statement of accounts indicating
whether constructed on a cash or
The physical address given by the Minutes of board meetings are
accrual basis.
organisation is verifiable. documented and circulated.
There are no serious adverse notes on
The organisation is registered as a trust The board approves programmes,
the veracity of the functioning of the
or society or Section 25 company. budgets, annual activity reports and
organisation.
audited financial statements.
Registration certificates and documents
There are no material transactions
issued by the appropriate authority are The board ensures the organisations
involving conflict of interest between a
available upon request. compliance with applicable laws and
board or staff member and/or adverse
statutory regulations.
2. Vision, aims, objectives, comment and observation relating to
achievements: The vision, purpose and All pending legal disputes are declared. operational issues or financial dealing
aims of the NGO should be explicitly in the record of public authority.
4. Operations: Operations refer to the
stated and be reflected in the activities capacity to conduct programmes and The organisations annual report is
being undertaken. administrative activities efficiently and distributed and communicated to
A vision, purpose or mission, which effectively in the public interest. The stakeholders and others and is made
drives the organisation, is articulated NGO should have norms in respect available upon request every year,
beyond the registration documents in to the nature of the programme it within eight months of the end of the
the form of activities and projects, etc. undertakes, the nature and style of organisations financial year.
its management; and the roles and
The organisation has a defined aim and The annual report contains a
responsibilities of its human resources
a set of objectives. description of the main activities, a
including personnel and volunteers.
The organisation is able to show review of the progress and results
The activities are in line with the vision, achieved in the year and information
performance through defined indicators
aim and objectives of the organisation. on board member names, positions,
against stated objectives.
The organisation periodically reviews remuneration or reimbursement as well
3. Governance: There must be a as brief financial details.
the progress of programmes.
clear commitment towards good
governance for the NGO to enhance its The accounts of the organisation are The NGO shall disclose their funding
effectiveness, serve all stakeholders, regularly maintained and those with an details i.e. the sources of funds,
meet the needs of society and to ensure annual income above 50,000 INR are annual revenue (O&M) and project
its accountability towards society in audited by the chartered accountant. expenditure. The organisation shall
accordance with its charter of objects produce timely reports on the use and
The roles and responsibilities management of funds which should be
and purposes. are defined for all personnel and made available on request.
The organisation has a governing volunteers.
board. Dovetailing with government schemes
All personnel are issued letters of will be preferred.
The organisation follows a consultative contract and appointment.
and democratic decision-making The NGO should give out accurate
An appropriate HR policy is in place. information regarding their projects
process.
5. Accountability and transparency: i.e. survey reports, target population,
There is disclosure of the details of location, sustainability of the projects,
Accountability and transparency are
board members viz, name, age, gender, their success ratio, etc on request.
key requirements of good governance
position and occupation. All family and necessary for building trust among The organisation should be ready to
affiliations should be indicated. stakeholders. This works as a testimony submit an affidavit by the authorised
The board has at least two meetings to the fact that the organisation has signatory attesting to the authenticity of
a year suitably spaced with quorum been working efficiently and effectively. the information given.
stipulated in its own articles of A financial management policy has
association, reviewing the functioning been developed and is adhered to.
of the NGO, evaluating the projects
undertaken by them and discussing the
way forward.

Handbook on Corporate Social Responsibility in India 29


Appendix 5
Illustrative list of NGOs and platforms for information on NGOs prepared by CII

1. GiveIndia (http://www.giveindia.org/): GiveIndia is a donation platform that


allows companies to support a cause of choice from about 200 NGOs that have been
scrutinised for transparency and credibility.
2. Voluntary Action Network India (http://www.vaniindia.org/): Voluntary Action
Network India works towards building a society where voluntarism and voluntary
organisations play a dominant role in social cohesion, economic empowerment and
nation-building.
3. Charities Aid Foundation (http://www.cafindia.org/): CAF India provides strategic
and management support to corporates, individuals and PSUs in order to ensure
greater impact of their philanthropic and CSR investments.
4. Oxfam India (http://www.oxfamindia.org/): The Oxfams are rights-based
organisations that fight poverty and injustice by linking grassroots programming
(through partner NGOs) to local, national and global advocacy and policy-making.
5. Confederation of Voluntary Associations (covanetwork.org/): COVA works in the
areas of communal harmony, peace and social justice through sensitisation of all
sections of society and empowerment of the marginalised and the poor.
6. Partners in Change (http://www.picindia.org/): PiC focusses on building sustainable
partnerships between the corporate sector and social development initiatives in India.
PiCs goal has been to become an organisation that is recognised both by companies
as well as civil society as a reliable facilitator for building partnerships for social
development.
7. Credibility Alliance (http://credibilityalliance.org): Credibility Alliances mission is to
build the credibility of the voluntary sector through the creation and promotion of the
norms of good governance and public disclosure.
8. Samhita (http://samhita.org/): Samhita provides a platform for NGOs to showcase
their work and attract donation.
9. Indian Confederation of NGOs (http://www.icongo.in/): iCONGO is a collective of
various credible, transparent and accountable NGO members registered as promoting
members and privilege members.
10. GuideStar India (http://www.guidestarindia.org/): GuideStar India is Indias leading
provider of NGO information. Their portal provides a fully searchable database of
reliable and comparable information on over 3,500 NGOs.
About CII
The Confederation of Indian Industry (CII) works to create and sustain an environment
conducive to the growth of industry in India, partnering industry and government alike
through advisory and consultative processes. CII is a non-government, not-for-profit,
industry-led and industry-managed organisation, playing a proactive role in Indias
development process. Founded over 117 years ago, it is Indias premier business association,
with a direct membership of over 8100 organisations from the private as well as public
sectors, including SMEs and MNCs, and an indirect membership of over 90,000 companies
from around 400 national and regional sectoral associations.
CII catalyses change by working closely with government on policy issues, enhancing
efficiency, competitiveness and expanding business opportunities for industry through
a range of specialised services and global linkages. It also provides a platform for
sectoral consensus building and networking. Emphasis is laid on projecting a positive
image of business, assisting industry to identify and execute corporate citizenship
programmes. Partnerships with over 120 NGOs across the country carry forward our
initiatives in integrated and inclusive development, which include health, education,
livelihood, diversity management, skill development and water, to name a few. CII has
envisaged a national movement for mainstreaming CSR for sustained inclusiveness as
part of its social development agenda. The CII National Committee on Corporate Social
Responsibility and Community Development was constituted in 2001 to make CSR an
actionable business agenda. The committee develops CSR guidelines and promotes the Confederation of Indian
sharing of CSR experiences and best practices. CII also organises an annual CSR summit
Industry
to enable stakeholders to review and strengthen the CSR movement. CII development
249-F, Sector 18 Udyog Vihar,
initiatives ensure the continuity of these programmes, particularly with respect to women
Phase IV, Gurgaon-122015, Haryana,
empowerment, industry-NGO partnership, and persons with disabilities.
India
With 64 offices, including nine Centres of Excellence, in India, and 7 overseas offices Telephone: +91 124 4014060-67
in Australia, China, Egypt, France, Singapore, UK, and USA, as well as institutional Fax:+91 124 4014080
partnerships with 224 counterpart organizations in 90 countries, CII serves as a reference Email: jawahar.k@cii.in
point for Indian industry and the international business community. sarbani.chakravarty@cii.in

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