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© 2015 SKP Business Consulting LLP. All rights reserved.
For private circulation only.
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Contents
1. Introduction ........................................................................................................................... 4
2. CSR under the Companies Act, 2013 ..................................................................................... 5
2.1 Scope and Applicability ......................................................................................................... 5
2.2 CSR Committee....................................................................................................................... 6
2.2.1 Composition ........................................................................................................................... 6
2.2.2 Roles and responsibilities: .................................................................................................... 6
2.3 CSR Policy Implementation ................................................................................................... 6
2.4 Roles and Responsibilities: Board of Directors ..................................................................... 6
2.4.1 Modalities for CSR activities .................................................................................................. 7
2.4.2 Qualifying CSR activities ....................................................................................................... 7
2.4.3 Inclusive scope of CSR ........................................................................................................... 8
2.4.4 Activities expressly disallowed as CSR activities .................................................................. 8
2.5 CSR Spending ......................................................................................................................... 9
2.5.1 Computation of the amount of CSR expenditure ................................................................. 9
2.5.2 Treatment of CSR expenditure .............................................................................................. 9
2.5.3 Mandatory disclosures ........................................................................................................ 10
3. Issues relating to CSR .......................................................................................................... 11
3.1 The MCA’s Clarifications ..................................................................................................... 11
3.2 Issues Pending Clarification ................................................................................................ 13
3.2.1 Contributions to Promoters’/Directors’ family trusts ......................................................... 13
3.2.2 Net profit of Indian companies for the calculation of profit of foreign companies ......... 13
3.2.3 Acceptable reasons for non-compliance............................................................................. 13
3.2.4 CSR activities through Section-8 companies ....................................................................... 13
3.2.5 CSR activities through the formation of charitable trusts ................................................. 13
4. Integrating CSR into Business Strategy ............................................................................... 13
5. Conclusion ........................................................................................................................... 15
1. Introduction
While India’s economic policies have been instrumental in creating a favourable climate for growth, there
are significant socio-economic disparities that still exist across the country. This issue has been the focus of
various non-governmental organisations (NGOs), businesses, and government bodies and has led to the
development of innovative approaches to uplift those in need while ensuring self-sufficiency and
sustainability for the future.
Traditionally, corporate social responsibility (CSR) has always been perceived as an act of charity. With
India’s diverse population, CSR activities also typically revolved around making donations to improve the
living standards of the community one belonged to.
With the advent of new corporate regulations, the nature and perception of CSR are expected to evolve
and it will be interesting to see how traditional companies integrate CSR into their plans while ensuring
that the spirit of the CSR regulations is strongly upheld.
The guiding principles enshrined in the Draft Corporate Social Responsibility (CSR) Rules under Section 135
of the Companies Act, 20131 specify that CSR activities are not charity or donation but a “way of conducting
business by which corporate entities visibly contribute to the social good. Socially responsible companies
do not limit themselves to using resources to engage in activities that increase only their profits. They use
CSR to integrate economic, environmental and social objectives with the company’s operations and
growth”.
India is reportedly the first country in the world to introduce statutory guidelines requiring certain
specified companies to undertake CSR activities. The Companies Act, 2013, which gives statutory force to
CSR activities, was passed in 2013. The relevant provisions under the Companies Act, 2013 (the Act) with
respect to CSR are:
Section 135;
Schedule VII;
Companies (Corporate Social Responsibility Policy) Rules, 2014 (CSR Rules); and
Notifications and Circulars issued by the Ministry of Corporate Affairs (MCA) from time to time.
The Institute of Chartered Accountants of India is working on a Guidance Note on Accounting for
Corporate Social Responsibility Expenditure, which is expected to be released soon. Section 135, Schedule
VII and the CSR Rules were notified on 27 February 2014 and came into effect from 1 April 2014.
With the concept of mandatory CSR activities being relatively new, several areas require clarifications from
the MCA. This makes interpretation of the provisions and their implementation challenging. Our note aims
to provide an insight into the regulations governing CSR activities in India, issues clarified by the MCA and
the benefits of integrating CSR activities into your business strategy.
1 Companies Act, 2013, Ministry of Corporate Affairs, http://www.mca.gov.in/Ministry/pdf/CompaniesAct2013.pdf
2. CSR under the Companies Act, 2013
2.1 Scope and Applicability
Section 135(1) prescribes the thresholds that mandate companies to undertake CSR activities. Every
company, its holding or subsidiary company, or a foreign company having a branch or project office in
India, which individually fulfils any one of the criteria mentioned below will be considered as a
“qualifying company” and would then need to mandatorily perform all the CSR activities mentioned in
Section 135 read with the CSR Rules during any financial year.
Particulars Criteria Definition
Net worth INR 5 billion or
more
Section 2(57): “Net worth” means the aggregate value of the paid-
up share capital and all reserves created out of the profits and
securities premium account, after deducting the aggregate value of
the accumulated losses, deferred expenditure and miscellaneous
expenditure not written off, as per the audited balance sheet, but
does not include reserves created out of revaluation of assets,
write-back of depreciation and amalgamation.
Turnover INR 10 billion or
more
Section 2(97): “Turnover” means the aggregate value of the
realisation of amount made from the sale, supply or distribution of
goods or on account of services rendered, or both, by the company
during a financial year.
Net profit INR 50 million or
more
Rule 2(f) of the CSR Rules: “Net profit” means the net profit of a
company as per its financial statement prepared in accordance
with the applicable provisions of the Act, but shall not include the
following, namely:
any profit arising from any overseas branch or branches
of the company, whether operated as a separate company
or otherwise; and
any dividend received from other companies in India,
which are covered under and complying with the
provisions of Section 135 of the Act:
Provided that net profit in respect of a financial year for which the
relevant financial statements were prepared in accordance with the
provisions of the Companies Act, 1956, shall not be required to be
recalculated in accordance with the provisions of the Act:
Provided further that in case of a foreign company covered under
these Rules, net profit means the net profit of such company as per
profit and loss account prepared in terms of Section 381(1)(a) read
with Section 198 of the Act.
Once the CSR provisions become applicable to a company, they will continue to be applicable unless
the company ceases to meet any of the above criteria for three consecutive years.
2.2 CSR Committee
2.2.1 Composition
Section 135 of the Act states that the qualifying company shall constitute a CSR Committee of the
Board of Directors which would comprise of three or more directors, of which at least one director
shall be an independent director2.
2.2.2 Roles and responsibilities
The mandate of the CSR Committee shall be:
To formulate and recommend a CSR Policy. The Policy shall be formulated considering the
activities best suited as per the industry and sector-specific issues adhering to the activities and
broad principles set out in Schedule VII;
Recommend the amount of expenditure that the company shall incur on CSR activities;
Monitor the CSR Policy of the company from time to time.
2.3 CSR Policy Implementation
The Act expressly states that during implementation of the CSR Policy, preference must be given by
the company to the local area and the area around which it operates. The CSR Rules lay down the
method of implementation of CSR activities. The responsibilities, modalities and activities qualifying as
CSR expenditure have been discussed in the following section.
2.4 Roles and Responsibilities: Board of Directors
The Act provides the following roles and responsibilities for the Board of Directors (BOD):
Approval of the CSR Policy of the company;
Disclosing the content of the Policy in the report of the Board of Directors;
Placing the Policy on the company’s website in such a manner as prescribed under Section 135 of
the Companies Act, 2013 read with the CSR Rules;
Ensuring that the CSR Policy is implemented and the activities undertaken by the company are
carried out;
Ensuring that the company spends, in every financial year, at least 2% of the average net profits of
the company made during the three immediately preceding financial years;
Ensuring that, if the earmarked amount is not spent, the same is specified in its report;
The Board shall have the power to make any change(s) in the Committee constitution.
2 Refer to Section 3.1 – Issues relating to CSR, The MCA’s Clarifications related to independent directors
2.4.1 Modalities for CSR activities
Instead of carrying out the CSR activities by itself, the company may undertake CSR activities in any of
the following modes:
If CSR is undertaken through any other entity, the company should specify the project or programmes
to be undertaken through these entities, the modalities of utilisation of funds on such projects, and
the monitoring and reporting mechanism.
2.4.2 Qualifying CSR activities
The CSR Policy formulated and recommended by the CSR Committee shall lay down the activities to be
undertaken by the company and the expenditure to be incurred in implementing them. Activities
undertaken in the normal course of business are excluded from the scope of CSR activities. The
activities that qualify as CSR activities are specified in Schedule VII to the Companies Act, 2013 and are
as follows:
Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation
including contribution to the Swachh Bharat Kosh set-up by the central government for the
promotion of sanitation and making available safe drinking water;
Promoting education, including special education and employment enhancing vocation skills,
especially among children, women, the elderly, and the differently-abled, and livelihood
enhancement projects;
CSR Activities
Registered Trust or Registered Society
Establish a Section-8 company
Collaboration of Companies
Establish a trust or society
under the relevant laws by
itself or in collaboration with
other companies who may
not necessarily have to be
group companies.
If the registered trust or
society is not established by
the company, its holding or
subsidiary company, it
should have an established
track record of three years in
undertaking programmes or
projects similar to those the
company wishes to execute
through its CSR policy.
Group companies, related
companies and unrelated
companies can collaborate
for such activities. More
inflow of funds shall enable
effective management and
execution for a dedicated
cause.
A Section-8 company can be
established either:
by the company singly, or
jointly with its holding,
subsidiary or associate
company, or
jointly with any other
company or with such other
company’s holding,
subsidiary or associate
company.2
(Refer to Section 3 - Issues)
Promoting gender equality, empowering women, setting up homes and hostels for women and
orphans; setting up old-age homes, day-care centres and such other facilities for senior citizens,
and measures for reducing inequalities faced by socially and economically backward groups;
Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal
welfare, agro forestry, conservation of natural resources and maintaining quality of soil, air and
water including contribution to the Clean Ganga Fund set up by the central government for
rejuvenation of the river Ganga;
Protection of national heritage, art and culture including restoration of buildings and sites of
historical importance and works of art; setting up public libraries; promotion and development of
traditional arts and handicrafts;
Measures for the benefit of armed forces veterans, war widows and their dependents;
Training to promote rural sports, nationally recognised sports, Paralympics sports and Olympic
sports;
Contribution to the Prime Minister's National Relief Fund or any other fund set up by the central
government for socio-economic development and relief and welfare of Scheduled Castes,
Scheduled Tribes, other backward classes, minorities and women;
Contributions or funds provided to technology incubators located within academic institutions
that are approved by the central government;
Rural development projects; and
Slum area development.
2.4.3 Inclusive scope of CSR
The Companies Act, 2013, in Schedule VII, listed down the activities that may be included by
companies in their CSR policies. The MCA has issued a clarification regarding the scope of Schedule VII
vide a circular3 stating that the activities undertaken by a company in pursuance of the CSR Policy
must be relatable to Schedule VII indicating that it is not necessary that for an activity to qualify as a
CSR activity, it should squarely fall within any of the entries under Schedule VII. Furthermore, the MCA
states that the entries in Schedule VII must be interpreted liberally in order to capture the essence of
the subjects enumerated in the Schedule and that the items enlisted in the Schedule VII are broad-
based and are intended to cover a wide range of activities. The inclusive definition of CSR assumes
significant importance as it allows companies to engage in projects or programmes related to activities
enlisted under the Schedule. It also gives flexibility to companies by allowing them to choose their
preferred CSR engagements that are in conformity with the CSR Policy.
2.4.4 Activities expressly disallowed as CSR activities The MCA, through the abovementioned circular, provided that CSR activities should be carried out in a
project or programme mode and shall not include the following:
Activities undertaken outside India;
Activities meant exclusively for employees and their families;
One-off events such as marathons/awards/charitable contributions/advertisements/sponsorships
of television programmes, etc.;
Expenses incurred by companies for the fulfilment of any Act/Statute of regulations (such as
Labour Laws, Land Acquisition Act, etc.);
Contributions made to a political party under Section 182 of the Companies Act, 2013.
3 General Circular No. 21 dated 18 June 2014
2.5 CSR Spending
2.5.1 Computation of the amount of CSR expenditure
It is the responsibility of the Board of Directors to ensure that the company spends at least 2% of the
average net profit of the three immediately preceding financial years to pursue and implement its CSR
Policy. The average profits are to be computed in accordance with the provisions of Section 198 of the
Act as shown below:
Statement showing computation of net profit as per Section 198 for the calculation of 2% of the
net profit for the purpose of CSR
Particulars* Amount
Profits as per Profit & Loss account XXX
Credit to be provided for:
Bounties and subsidies received from the government XXX
Credit not to be provided for:
Premium/profit on sale of shares
Profits of capital nature – including profits on sale of undertakings
Profits from sale of immovable property/ fixed assets – unless undertaken
Permissible deductions:
Usual working Charges – revenue expenditures, bonus or commission, abnormal or
special tax, interest on debentures, loans or advances, compensations/damages in
virtue of legal liability, bad debts written off, etc.
(XXX)
(XXX)
(XXX)
(XXX)
Non-permissible deductions:
Income tax paid under the Income Tax Act, 1961
Capital loss
Compensations/damages paid voluntarily
Profits as per Section 198 XXX
Source: Companies Act, 2013
Note: Net profit shall not include any profit arising from any overseas branch or branches of the
company whether operated as a separate company or otherwise; and any dividend received from
other companies which are required to comply under Section 135 of the Act.
2.5.2 Treatment of CSR expenditure
The Income Tax Act, 1961 states that expenses that are not incurred wholly or exclusively for carrying
on business cannot be considered as application of income, i.e. expenditure. Further, Section 37 of the
Income Tax Act disallows expenditure incurred under Section 135 as a deduction.
However, CSR expenditure that is in the nature described in other sections such as Section 35AC,
which coincides with the list of items mentioned in Schedule VII of the Companies Act, 2013 for CSR
purposes may be eligible for 100% deduction of the contribution made and one may have greater
comfort in claiming deduction regardless of whether there is deductibility under Section 37 of the
Income Tax Act or not as no direct nexus of the same with the business of the company needs to be
proved.
Furthermore, it is pertinent to note that in the Union Budget 2015-16, it has been proposed that
contributions/donations made towards the Swachh Bharat Kosh and Clean Ganga Fund with the aim of
fulfilling CSR requirements would not be eligible for a tax deduction under Section 80G. However, any
other assessee contributing to such funds would be eligible for a 100% deduction under Section 80G,
which seems discriminatory.
Activity (vii) in Schedule VII of the Companies Act, 2013 covers contributions to the Prime Minister’s
National Relief Fund or any other fund set up by the central government for socio-economic
development and relief and welfare of the Scheduled Castes, Scheduled Tribes, other backward
classes, etc. Hence, a company can contribute to such funds under its CSR initiatives and claim a 100%
tax deduction for the same.
2.5.3 Mandatory disclosures
The Companies Act, 2013 mandates the following disclosures with respect to the CSR Policy of
the company:
The Board of Directors must disclose the contents of the CSR Policy in the Board Report as per
Section 134(3) of the Companies Act, 2013 (for a foreign company, the balance sheet filed under
381(1)(b) of the Act should contain an annexure with a report on CSR);
The contents of the CSR Policy must be placed on the company’s website;
The Board shall disclose by way of Notes to the Statement of Profit and Loss, the amount of
expenditure incurred on CSR activities;
The Board shall disclose the composition of the CSR committee in the Board Report which shall be
attached to the financial statements of the company and be laid before the members in the
general meeting.
The disclosures mandated by the CSR Rules are as under:
Rule 9 of the CSR Rules requires the company to disclose the contents of its CSR Policy on the
company website as per the Annexure to the CSR Rules. The format of this disclosure is as under:
Format for disclosure of CSR Policy on company website
Sr.
no.
CSR
activity
project/
activity
identified
Sector in
which the
project is
covered
Projects/
programmes
(1), local area
(2), separate
state/district
Amount of
outlay: Project/
programme-
wise
Cumulative
expenditure
of reporting
Amount spent:
Direct or
through
implementing
agency
1
2
3
...
Total
Specific inclusions to be made in the CSR Policy
As per Rule 6(1) of the CSR Rules, the CSR Policy of a company shall specifically include the following:
List of specified projects or programmes that a company plans to undertake within the purview of
Schedule VII;
Modalities of execution of such projects or programmes and implementation schedules for the
same;
Monitoring process of such projects or programmes
The CSR Policy is also required to specifically state that the surplus arising out of the CSR projects or
programmes or activities shall not form part of the business profit of the company.
CSR Corpus
The disclosure under the CSR Policy in respect of Corpus would include the following:
2% of the average net profits;
Any income arsing thereon; and
Surplus arising out of CSR activities.
Failure to disclose
The Act mandates spending of at least 2% of the average net profits; there is no provision of rolling
over the unspent amount to succeeding financial years. In case the company fails to spend the
amount, the Board shall specify its reason of this failure in its report.
Failure to explain or report is punishable by a fine on the company of not less than INR 50,000
and up to INR 2.5 million; and
Officers who default on the reporting provision could be subject to up to three years in prison
and/or fines of not less than INR 50,000 and as high as INR 500,000.
3. Issues relating to CSR
3.1 The MCA’s Clarifications
Issue Clarification SKP’s Comments
Scope and Applicability
Foreign company The CSR Rules prescribe the following:
CSR provision shall be applicable to a
foreign company that has its branch
or project office in India.
The balance sheet and profit and loss
account of a foreign company will be
prepared in accordance with Section
381(1)(a) and net profit is to be
computed as per Section 198 of the
Companies Act.
No clarity is provided towards any
mechanism that allows computation of
accounts of a foreign company in order
to determine the net worth or turnover of
a branch or a project office. Ascertaining
the incidence of CSR exposure in the
absence of any clear provision for
financial computation of branch or
project offices of foreign companies may
prove challenging and create practical
difficulties.
Independent
directors
The CSR Rules have done away with the
requirement of appointing an
independent director on the CSR
Committee of the Board of an unlisted
company as well as a private company.
The CSR Rules have relaxed the
requirement regarding the presence
of three or more directors on the CSR
Committee of the Board. In case a
private company has only two
directors on the Board, the CSR
Committee can be constituted with
these two directors.
The CSR Committee of a foreign
company shall comprise of at least
two persons wherein one or more
persons should be resident in
India and the other person is
nominated by the foreign company.
This is a constructive development which
will provide relief to many companies
that were not otherwise required to have
independent directors on their Board.
CSR Spending
Section 135(5)
requires profit to
be calculated as
per Section 198.
Section198 is to
be used to
calculate profits
only for the
purposes of
Section197.
There is no direct clarification on this
aspect.
Section 198 of the Companies Act, 2013
lays down the method of computation of
profits specifically for the purpose of
Section 197, i.e. managerial
remuneration.
A harmonious application of Section 135
dealing with CSR and Section 197 dealing
with managerial remuneration would
imply that the net profit to be calculated
would be on the same lines for the
purposes of both sections.
Surplus arising
out of CSR
activities
The surplus from CSR activities shall not
form a part of the business profits of the
company.
This implies that surplus shall be re-
invested to perform CSR activities.
This surplus shall not be included in the
spend to be calculated for any future
years. This amount shall be over and
above the mandatory contribution the
company has to make towards CSR
activities.
Costs incurred to
build capacities
for carrying out
CSR activities
forming part of
CSR expenditure
These costs cannot exceed 5% of the
total CSR expenditure of the company in
one financial year.
The computation is to be noted carefully.
Reconciliation of
profits calculated
as per the Act of
1956 and 2013
The proviso to Rule 3(1) of the CSR
Rules, 2014 states that net profit in
respect of a financial year to which the
relevant financial statements were
prepared under the Companies Act,
1956 shall not be required to be re-
computed.
-
Disclosure
Profit and loss
statement vs
Note in the
financials
- Schedule III to the Companies Act, 2013
has given the format of statement of
profit and loss account. According to this
format, expenditures are classified based
on the nature of expenses and not based
on function.
Hence, expenditure incurred on CSR
activities cannot be shown on the face of
the statement of profit and loss.
However it will be shown under “Other
expenses” with a detailed break up in the
Notes to accounts with a separate line
item on CSR spending.
3.2 Issues Pending Clarification
3.2.1 Contributions to Promoters’/Directors’ family trusts
The MCA is yet to clarify whether contributions to Promoters’/Directors’ family trusts or trusts in which
they are interested parties will be considered as compliance to CSR obligations, if such trusts are
promoting the areas mentioned in Schedule VII of the Companies Act, 2013.
3.2.2 Net profit of Indian companies for the calculation of profit of foreign companies
Rule 2(f) of the CSR Rules specifically states profits of foreign companies are to be calculated as per the
profit and loss account prepared in terms of Section 381(1)(a) read with Section 198 of the Act to
determine applicability of CSR provisions.
Rule 2(f) is clear on the exclusions to be made from the profits of Indian companies. However, the Act,
Rules, Notifications and Circulars are silent on whether the amounts of net profit that determine
applicability for an Indian company are either:
Profits computed as per Section 198; or
Profits calculated as per Schedule III of the Companies Act, 2013 i.e. Profits as per the audited
financial statements.
Further, if they are to be net profits as disclosed as per the audited financial statements, another issue
that requires clarification from the MCA is whether these profits are to be considered before tax or
after tax.
3.2.3 Acceptable reasons for non-compliance
The MCA is yet to clarify the reasons that shall be accepted for failure in spending the prescribed
amounts on CSR activities.
3.2.4 CSR activities through Section-8 companies
Rule 4 provides that a company may carry out CSR activities through a Section-8 company established
by the company itself, or jointly by the company and any other company as specified therein.
However, the proviso mentions that if CSR activities are carried out through a Section-8 company that
is not established by the qualifying company, then it should have an established track record of three
years in undertaking similar programmes or projects.
3.2.5 CSR activities through the formation of charitable trusts
The CSR Rules also contain guidance on how companies can conduct CSR activities through trusts. This
leads to another issue that for income tax purposes, whether contribution to the trust would be
allowed wholly or be restricted to 50% under Section 80G of the Income Tax Act or be completely
disallowed. Furthermore, whether such trusts would get approvals for 80G from Income Tax
Commissioners is also not clarified.
4. Integrating CSR into Business Strategy
As mentioned at the start of this note, the practice of CSR in India remains within the philanthropic space
and needs to evolve into having a much wider scope. It is essential for CSR to become more strategically
linked with business than being restricted to acts of charity.
While CSR is not a new concept for many Indian companies, formulating relevant and sustainable policies
and practices will depend largely on a company’s ability to innovate and adapt. It is important that social
objectives are not superficially tied to business objectives. A well-aligned strategy would lead to
improvements for both, the organisation and the society it functions in.
In the Indian context, maternal health, infant mortality, food security, availability of clean drinking water,
education and gender equality are some vital areas in need of attention. In fact, the first draft of Schedule VII
was entirely in line with the United Nations’ Millennium Development Goals (MDGs) on hunger, health and
sustainability. The mandatory CSR Policy can enable the corporate sector to accelerate action towards achieving
the MDGs.4
Creating a strategy that results in improvements in social welfare would also help strengthen the brand of the
contributing company, eventually leading to economic benefits. This can be seen in Vodafone India’s
contribution to the Gujarat government’s e-Mamta Mother-Child programme. Vodafone developed a voice-
based closed user group (CUG) solution providing 42,000 SIM cards to ASHAs (Accredited Social Health
Activists), doctors and health workers connecting them to expectant mothers to monitor their health status and
ensure timely care. This not only resulted in reducing infant mortality but also helped Vodafone’s image
building, improved its rural reach, increasing business as the health workers consumed 200,000 minutes within
the CUG and 500,000 outgoing minutes on a daily basis.5
The key to maximising returns from the newly mandated statutes is to emphasise on developing effective,
need-based CSR strategies so that these investments can yield the intended results. CSR initiatives should be
sustainable, scalable and result oriented. These initiatives may be better undertaken in a project-based manner
to ensure that tangible results and real-time benefits are enjoyed both, by the company and the recipients of its
assistance.
4 The CSR Policy outlined in the Companies Act 2013 offers enormous potential for businesses in India to accelerate action
towards the most pressing MDGs, UNDP in India, http://www.in.undp.org/content/india/en/home/presscenter/pressreleases/2013/12/19/the-corporate-social-responsibility-policy-outlined-in-the-companies-act-2013-offers-enormous-potential-for-businesses-in-india-to-accelerate-action-towards-the-most-pressing-mdgs.html 5 Press release: Vodafone’s e-Mamta initiative helps reduce infant mortality in Gujarat,
www.vodafone.in/documents/pdfs/pressreleases/pr_1178.pdf
Customer Retention
Opportunities
Brand Development
Social Capital
Value Creation
Effective CSR policy
integrated with
business goals
5. Conclusion
The inclusion of the CSR mandate under the Companies Act, 2013 is an attempt to complement the Indian
government’s efforts of delivering the benefits of economic development to all sections of society by
engaging the corporate world.
While an organisation’s CSR activities and business goals can be compatible, the activities specified in the
Act may seem restrictive and could lead to forced participation instead of a truly sincere approach. The
success of a company’s CSR activities will be determined by how the company attempts to integrate the
mandate into its core business strategy. If pursued in a planned, organised manner, it could maximise
value and justify the investment made, while contributing to the betterment of society.
Contact
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Tokyo 102-0074
Japan
T: +81 (0) 3 5211 7878
www.skpgroup.com
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