www.pwc.

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, !"# the mandate for corporate social responsibility $C%&'
has been formally introduced to the dashboard of the (oards of Indian companies. )he industry has
responded positively to the reform measure underta*en by the government with a wide interest across
the public and private sector, Indian and multinational companies.
)he practice of C%& is not new to companies in India. +owever, what this Act does is bring more
companies into the fold. Also, it is li*ely that the total C%& 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 conte-t, that the .+andboo* on Corporate %ocial &esponsibility in India developed by
/wC India for CII can play an important role. )he CII being the leading industry body, through this
handboo*, envisages equipping companies for this shift of structured engagement with communities.
)his handboo* is aimed both at companies that are veteran C%& practitioners as well as those that are
0ust entering the fray. It suggests steps to develop a C%& strategy and Policy and identifies the
key building blocks for initiating and developing the CSR programs. It wal*s the C%&
practitioner through some of the *ey choices that may be required to be made while pursuing C%&
ob0ectives and develop an organisation that is socially sensitive and responsible.
(uilding a society which provides equal access to opportunities negates disparities and, is a
collective responsibility. )his 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 1ice Chairman and 2anaging Director,
(harti 3nterprises
Message from the Mentor and
Chairman Emeritus
4ortis +ealthcare 5imited
)he constitutional structure of the country was laid with an ob0ective of one man equals one vote,
equals one value. +owever the socio6economic 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. )he
country presently is under intense debate of developmental growth versus welfare based
development. 7ur political realities and our economic senses are at cross6roads. +ow do we strike a
balance between the two? he choices we make today are going to influence our
generations to come.
3very single ma0or 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 e-pand
opportunities while ensuring its equal distribution are fundamental for achieving strong human
development. !ut disparity" ine#uality and the growing divide in our societies define our
e-istence today. )he inclusion of the C%& mandate under the Companies Act, !"# is an attempt
to supplement the governments efforts of e#uitably delivering the benefits of growth and to
engage the Corporate World with the countrys development agenda.
/hilanthropy and C%& is not a novel concept for Indian companies, however a few organisations
are li*ely to struggle. )he role of civil society in fuelling this change is bound to be e-tremely
important. With the new corporate resources in their tool bag much will depend on their ability to
innovate and adapt.
)he handboo* is a guidance document which will facilitate development of C%& 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 $overnment. he 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 C%& 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 li*e to e-tend my warm appreciation to the /wC team, including %achin %hu*la,
Shari#ue Ahmad" An%an &atna" Ankit $upta and Shankar 'enkateswaran who worked
towards the development of this document.
Harpal Singh
2entor and Chairman 3meritus, 4ortis +ealthcare 5imited
List of abbreviations
BRR (usiness &esponsibility &eport
CSR Corporate social responsibility
DPE Department of /ublic 3nterprises
EC 3uropean Commission
ESG 3nvironmental, social and governance
ILO International 5abour 7rganisation
ISO International 7rganisation for %tandardisation
LBG (ondon !enchmarking $roup model
MCA 2inistry of Corporate Affairs
!G )ational 'oluntary $uidelines
OECD 7rganisation for 3conomic Co6operation and Development
SEBI %ecurities and 3-change (oard of India
SME %mall and medium enterprises
SAAS %ocial accountability accreditation services
SGAAP %ocial generally accepted accounting
principles
SROI %ocial return on investments
" 8nited 9ations
"GC *nited )ations $lobal Compact
"IDO 8nited 9ations Industrial Development
7rganisation
#BCSD World (usiness Council for %ustainable
Development
Contents
6 What is C%&:
11 )he Companies Act, !"#
14 C%&; /lanning and strategising
! C%& and %23s
6 Appendices
"bout the handbook
India is a country of myriad contradictions. 7n 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. +hat 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
have6nots, this scrutiny will only increase over time and societal e-pectations
will be on the rise. 2any companies have been quic* to sense
this development, and have responded proactively while others have done so only
when pushed.
$overnments as well as regulators have responded to this unrest and the
)ational 'oluntary $uidelines for Social" ,nvironmental and ,conomic
Responsibilities of !usiness or the )'$s -accompanied by the !usiness
&esponsibility &eports mandated by the %3(I for the top "!! companies' and
the C%& clause within the Companies Act, !"# are two such instances of the
steps ta*en.
According to Indian Institute of Corporate Affairs, a minimum of <,!!! Indian
companies will be required to underta*e C%& pro0ects in order to comply with the
provisions of the Companies Act, !"# with many companies undertaking
these initiatives for the first time. .urther" some
estimates indicate that C%& commitments from companies can amount to as
much as !,!!! crore I9&.
)his combination of regulatory as well as societal pressure has meant that
companies have to pursue their C%& activities more professionally. )his
handboo* attempts to bring together good practices of companies and grant6
ma*ing foundations so as to assist companies pursue their C%&
activities effectively, while remaining aligned with the requirements of the
Companies Act, !"#.
)his handboo* begins by building a common understanding of the concept of
C%&, based on global practices, Indian tradition, and the intent and provisions
of the Companies Act, !"#. It then goes on to bring out the *ey aspects of
clause "#= of the Companies Act, !"# and the recently released draft rules,
and highlights its implications to companies.
A ma0or part of the handboo* focuses on the .what and .how of strategising,
planning, e-ecuting and monitoring the C%& activities of companies. It provides
a detailed guidance $rather than prescriptions' for each of these processes
covering the following;
1 /b%ective of the process
2 Process owners
3 &ey inputs and outputs
4 Activities or tasks to be covered" including methodology and
timelines
5 ools" technical guidance or standards to be employed
It also has a section on what small and
medium enterprises, some of whom will
be required to comply with the Act, can
do collectively.
#hat is CSR$
6
PwC
#hat is
CSR$
$he global
%onte&t
While there may
be no single
universally
accepted
definition of
CSR" each
definition that
currently e-ists
underpins the
impact that
businesses have
on society at
large and the
societal
e-pectations of
them. Although
the roots of
C%& lie in
philanthropic
activities $such
as donations,
charity,
relief wor*, etc.'
of corporations,
globally, the
concept of C%&
has evolved and
now
encompasses all
related concepts
such as triple
bottom line,
corporate
citi>enship,
philanthropy,
strategic
philanthropy,
shared value,
corporate
sustainability and
business
responsibility.
)his is evident in
some of the
definitions
presented
below0
)he 3C
"
defines
CSR as 1the
responsibility of
enterprises for
their impacts on
society. )o
completely meet
their social
responsibility,
enterprises
should have in
place a process to
integrate social,
environmental,
ethical human
rights and
consumer
concerns into
their business
operations and
core strategy in
close
collaboration
with their
stakeholders
he +!CS2
defines CSR
as

1the
continuing
commitment by
business to
contribute to
economic
development
while improving
the quality of life
of the workforce
and their
families as well
as of the
community and
society at
large.
According to
the 89ID7
#
,
Corporate
social
responsibilit
y is a
management
concept
whereby
companies
integrate
social and
environment
al concerns
in their
business
operations
and
interactions
with their
stakeholders.
CSR is
generally
understood as
being the way
through which
a company
achieves a
balance of
economic,
environmental
and social
imperatives
!riple"
#ottom"$ine
%pproach&,
while at the
same time
addressing
the
e'pectations
of
shareholders
and
stakeholders.
(n this sense
it is important
to draw a
distinction
between CSR,
which can be
a strategic
business
management
concept, and
charity,
sponsorships
or
philanthropy.
)ven
1 http://ec.europa
.eu/enterprise/p
olicies/sustaina
ble-
business/corpo
rate-social-
responsibility/in
dex_ en.htm
2 http://www.wb
csd.org/work-
program/busin
ess-
role/previous-
work/corporate
-social-
responsibility.
aspx
3 http://www.uni
do.org/what-
we-
do/trade/csr/w
hat-is-
csr.html#pp1[g
1/!/
4 "rundtland
#ommission$s
%eport& 1'()
though the
latter can also
make a valuable
contribution to
poverty
reduction, will
directly enhance
the reputation of
a company and
strengthen its
brand, the
concept of CSR
clearly goes
beyond that.
.rom the above
definitions" it is
clear that0
1)he C%&
approach is
holistic and
integrated
with the core
business
strategy for
addressing
social and
environmental
impacts of
businesses.
2C%&
needs to
address
the well6
being of
all
sta*ehol
ders and
not 0ust
the
company
s
sharehol
ders.
3/hilanthropic
activities are
only a part of
C%&, which
otherwise
constitutes a
much larger
set of
activities
entailing
strategic
business
benefits.
CSR in In'ia
C%& in India
has
traditionally
been seen as
a
philanthropi
c activity.
And in
*eeping with
the Indian
tradition, it
was an
activity that
was
performed
but not
deliberated.
As a result,
there is
limited
documentation
on specific
activities
related to this
concept.
+owever, what
was clearly
evident that
much of this had
a national
character
encapsulated
within it,
whether it was
endowing
institutions to
actively
participating in
Indias freedom
movement, and
embedded in the
idea of
trusteeship.
As some
observers have
pointed out, the
practice of C%&
in India still
remains within
the philanthropic
space, but has
moved from
institutional
building
$educational,
research and
cultural' to
community
development
through various
pro0ects. Also,
with global
influences and
with
communities
becoming more
active and
demanding,
there appears to
be a discernible
trend, that while
C%& remains
largely restricted
to community
development, it
is getting more
strategic in
nature $that is,
getting lin*ed
with business'
than
philanthropic,
and a large
number of
companies are
reporting the
activities they
are
undertaking in
this space in
their official
websites, annual
reports,
sustainability
reports and even
publishing C%&
reports.
)he
Companies
Act, !"# has
introduced
the idea of
C%& to the
forefront and
through its
disclose6or6
e-plain
mandate, is
promoting
greater
transparency
and
disclosure.
%chedule 1II
of the Act,
which
lists out the
C%&
activities,
suggests
communities
to be the focal
point. 7n the
other hand, by
discussing a
companys
relationship to
its
sta*eholders
and
integrating
C%& into its
core
operations, the
draft rules
suggest that
C%& needs
to go
beyond
communitie
s and
beyond the
concept of
philanthrop
y. It will be
interesting to
observe the ways
in which this will
translate into
action at the
ground level, and
how the
understanding of
C%& is set to
undergo a
change.
CSR an'
s(stainabilit)
%ustainability
$corporate
sustainability'
is derived
from the
concept of
sustainable
development
which is
defined by
the
!rundtland
Commission
as
1development
that meets the
needs of the
present
without
compromising
the ability of
future
generations to
meet their own
needs
?
.
Corporate
sustainability
essentially refers
to the role that
companies can
play in meeting
the agenda of
sustainable
development and
entails a
balanced
approach to
economic
progress, social
progress and
environmental
stewardship.
C%& in India
tends to focus
on what is
done with
profits after
they are made.
7n the other
hand,
sustainability
is about
factoring the
social and
environmenta
l impacts of
conducting
business, that
is, how
profits are
made.
3ence"
much of the
Indian
practice of
C%& is an
important
component of
sustainability
or responsible
business,
which is a
larger idea, a
fact that is
evident from
various
sustainability
framewor*s.
An interesting
case in point
is the )'$s
for social"
environment
al and
economic
responsibilitie
s of business
issued by the
2inistry of
Corporate
Affairs in @une
!"". /rinciple
eight relating to
inclusive
development
encompasses
most of the
aspects covered
by the C%&
clause of the
Companies
Act, !"#.
+owever, the
remaining eight
principles
relate to other
aspects of the
business. he
*) $lobal
Compact, a
widely used
sustainability
framewor* has
"! principles
covering social,
environmental,
human rights
and governance
issues, and what
is described as
C%& is implicit
rather than
e-plicit in these
principles.
3andbook on
Corporate
Social
Responsibility
in India %
$lobally" the notion
of CSR and
sustainability seems to
be converging, as is
evident from the
various definitions of
C%& put forth by global
organisations. )he genesis
of this convergence can be
observed from the
preamble to the recently
released draft rules relating
to the C%& clause within
the Companies Act, !"#
which tal*s about
sta*eholders and
integrating it with the
social, environmental and
economic ob0ectives, all of
which constitute the
idea of a triple bottom
line approach. It is
also acknowledged
in the $uidelines on
Corporate %ocial
&esponsibility and
%ustainability for
Central /ublic %ector
3nterprises issued by the
D/3 in April !"#
=
. )he
new guidelines, which have
replaced two e-isting
separate guidelines on C%&
and sustainable
development, issued in
!"! and !"" respectively,
mentions the following;
Since corporate social
responsibility and
sustainability are so closely
entwined, it can be said
that corporate social
responsibility and
sustainability is a
company*s commitment to
its stakeholders to conduct
business in an
economically, socially and
environmentally
sustainable manner that is
transparent and ethical.
#hy is the CSR
clause of the
ne& Companies
"ct' (1! so
critical for
SMEs$
)y re*uiring
companies' &ith a
minimum net profit
of 5 crore INR, to
spend on CSR
acti+ities' the
Companies "ct' (1! is
likely to bring in many
SMEs into the CSR
fold, -his &ill usher in
a fresh set of
challenges to a sector
that is increasingly
being asked by its
)) customers to
comply &ith
en+ironmental and
social standards'
&hile remaining
competiti+e in terms
of price and *uality,
-hus' SMEs &ill
ha+e to *uickly
learn to be
compliant &ith
these di+erse set of
re*uirements and it is
hoped that this
handbook &ill
facilitate their ability
to comply &ith the
CSR clause of the
Companies "ct' (1!,
* +uidelines on #orporate
,ocial %esponsibility and
,ustainability -or #entral
.ublic ,ector /nterprises
-http://www.recindia.nic.in/d
ownload/0./_+uide-
lines_#,%_,ust.pd-
Benefits
of a
robust
CSR
progra**
e
As the business
environment gets
increasingly comple- and
sta*eholders become vocal
about their e-pectations,
good C%& practices can
only bring in greater
benefits" some of which
are as follows0
1Co**(nities provi'e
the li%en%e to operate+
Apart from internal
drivers such as values
and ethos, some of the
*ey stakeholders that
influence corporate
behaviour include
governments $through
laws and regulations',
investors and customers.
In India, a fourth and
increasingly important
sta*eholder is the
community, and many
companies have started
realising that the .licence
to operate is no longer
given by governments
alone, but communities
that are impacted by a
companys business
operations. )hus, a
robust C%&
programme that meets
the aspirations of these
communities not only
provides them with the
licence to operate, but
also to maintain the
licence, thereby
precluding the 4trust
deficit5.
2Attra%ting an'
retaining e*plo)ees+
%everal human
resource studies have
lin*ed a companys
ability to attract,
retain and motivate
employees with their
C%& commitments.
Interventions that
encourage and enable
employees to
participate are shown
to increase employee
morale and a sense of
belonging to the
company.
3Co**(nities as
s(ppliers+ )here are
certain innovative
C%& initiatives
emerging, wherein
companies have
invested in enhancing
community livelihood
by incorporating them
into their supply
chain. his has
benefitted
communities and
increased their income
levels, while providing
these companies with
an additional and secure
supply chain.
4Enhan%ing %orporate
rep(tation+
he traditional
benefit of
generating goodwill,
creating a positive
image and branding
benefits continue to
e6ist for companies
that operate effective
C%& programmes.
)his allows
companies to position
themselves as
responsible corporate
citi>ens.
. PwC
Global prin%iples an' g(i'elines
A comprehensive guidance for companies
pertaining to C%& is available in the form
of several globally recognised guidelines,
framewor*s, principles and tools, some of
which are discussed below. It must be noted
that most of these guidelines relate to the
larger concept of sustainability or business
responsibility, in *eeping with the fact that
these concepts are closely aligned globally
with the notion of C%&.
"GC
*)$C is world5s largest corporate citi7enship
initiative with the ob0ective to mainstream the
adoption of sustainable and socially responsible
policies by businesses around the world. )he "!
principles of the *) $lobal Compact have been
derived from various 89 conventions such as
the 8niversal Declaration of +uman &ights,
I57s Declaration on 4undamental /rinciples
and &ights at Wor*, the &io Declaration on
environment and development, and the 89
Convention Against Corruption. )hese prin6
ciples cover four broad areas;
8 +uman rights $support and respect the
protection of international human rights
and ensure that business is not complicit
with human rights abuses'
8 5abour rights $uphold the freedom of as6
sociation and effective recognition of the
right to collective bargaining, elimination
of all forms of forced and compulsory
labour, effective abolition of child labour
and elimination of description in respect
of employment and occupation'
8 3nvironment $support a precautionary
approach to environmental challenges,
underta*e initiatives to promote greater 4or more details refer the website of I57
,
environmental responsibility and encour6
OECD G(i'elines+ M(ltinational enterprises
age the development of environmental
friendly technology' /,C2 $uidelines for multinational enterprises
8 $overnance -work against corruption in
elaborate on the principles and standards for
responsible business conduct for multinational
all forms, including bribery and e-tor6
corporations. )hese guidelines were recently
tion'.
updated in !"". )hey cover areas such as
.or more details refer the website of *)$C
<
employment, human rights, environment,
information disclosure, combating bribery,
consumer interests, science and technology,
competition and ta6ation. hey contain defined
standards for socially and environmentally
responsible corporate behaviour, and also pro6
vide procedures for resolving disputes between
corporations and communities or individuals
adversely impacted by business activities.
4or more details refer the website of 73CD
A
6 www.unglobalc
ompact.org/
7 http://www.ohc
hr.org/0ocume
nts/.ublication
s/+uiding.rinci
ples"usiness1
%_/2.pd-
8 http://www.ilo.o
rg/empent/.ubl
ications/3#4,
_!'56(7/lang--
en/index.htm
9 http://oecdwatc
h.org/about-
oecd/guideline
s
10 http://w
ww.accountabil
ity.org/standard
s/
11 http://w
ww.sa-
intl.org/index.c-
m8
-useaction9.ag
e.:iew.age;.
age<09'6)
Instit(te of
So%ial an'
Ethi%al
A%%o(nt-
abilit)+
A%%o(ntAbilit
).s AA/000
series of
stan'ar's
)his is a series of
standards which
enable or6
ganisations to
become
accountable,
responsible and
sustainable. It
consists of the $i'
AA"!!!
accountability
principles $A/'
standard $ii'
AA"!!!
assurance
standard $A%' $iii'
AA"!!!
sta*eholder
engagement $%3'
standard. %ince
these standards
have been
formulated
through a multi6
sta*eholder
consultation
process, they
ensure that those
impacted $that is,
enter6prises,
governments and
civil societies'
stand to gain.
he 'odafone
$roup Plc has
adopted the
AA"!!!A/
standard by
focussing on three
broad areas; $i'
inclusivity
$sta*eholder en6
gagement to
develop and
implement a
strategic approach
to sustainability'
$ii' materiality
$assess the
management
effort required for
each material
issue and
determine the
content of
sustainability
reports' $iii'
responsiveness $respond with solutions to
material issues and challenges'.
4or more details refer the website of
Account6Ability
"!
So%ial A%%o(ntabilit) International
1SAI2+ SA ,000 Stan'ar'
his is one of the world5s first
auditable social certification standard.
It is based on I(/" *) and national law
conventions, and adopts
a management system approach in order
to ensure that companies that adopt this
approach also comply with it. )his
standard ensures the protection of basic
human rights of wor*ers. )he nine basic
elements of this standard in6clude $i' child
labour $ii' forced and compul6sory labour
$iii' health and safety $iv' freedom of
association and the right to collective
bargaining $v' discrimination $vi'
disciplinary practices $vii' wor*ing hours
$viii' remunera6tion $i-' management
systems. According to %AA%, there are
<A= facilities in
India that have
been accredited
with this standard.
7ut of these,
Aditya (irla
Chemicals $India'
5imited, (hilai
%teel /lant %teel
Authority of India
5imited, (irla
tyres, Dr &eddys
5aboratories
5imited and
&eliance
Infrastructure
5imited figure
prominently in
the list of
certified facili6ties
within India.
4or more details
refer the website
of %AI
""
3andbook on Corporate
Social
Responsibili
ty in India /
ISO 34000+
So%ial
responsibilit)
)his is a guidance
tool provided by
the I%7 which
enables
organisations to
understand the
meaning and
significance of
social responsi6
bility. It is
important to note
that this is not a
certification but
only a guiding
tool. 3ence" or6
ganisations which
comply with these
standards are
self9certified. It
covers si6 core
areas of social
responsibility,
including $i'
human rights $ii'
labour practices
$iii' environment
$iv' fair operating
practices $v'
consumer issues
$vi' community
involvement and
development. )his
ensures a holistic
approach to the
concept of social
responsibility and
sustainable
develop6ment.
4or more details
refer the website
of I%7
"
OECD CSR
poli%) tool
)he 73CD C%&
policy tool aims
to help
companies gain
insight into their
current C%&
activities, assess
its value and
determine other
C%& activities
that can be
employed. )his
policy tool is
based on the
/,C2
$uidelines and
the
I%7<!!!
implementation
guidelines. )he
re6sult of the
policy tool is a
complete C%&
policy,
including an
action plan
with tas*s,
responsi6
bilities and a
communication
strategy plan.
4or more details
refer the website
of 73CD
"#
Global Co*pa%t
Self-Assess*ent
$ool
he $lobal
Compact Self
Assessment
ool is an easy6
to6use guide
designed for use
by compa6nies of
all si>es and
across sectors
committed to
upholding the
social and
environmental
standards within
their respective
operations. )he
tool consists of
?= questions with
a set of three to
nine indicators
for each question.
It consists of a
.management
section and four
other sections,
including human
rights, labour,
environment and
anti6corruption
that relate to the
principles of the
*) $lobal
Compact. he
tool is in line
with the *)
$uiding
Principles on
(usiness and
+uman &ights.
4or a small
company, this
tool acts as a
measure of the
companys
performance in
all areas of the
89
$lobal
Compact and
how well these
issues are
managed. 4or a
large
organisation, this
tool helps to
continuously
improve e-isting
policies and
systems, engage
subsidiaries,
suppliers or other
sta*eholders, and
improves internal
and e-ternal
reporting.
.or more details
refer the website
of $lobal
Compact %elf6
Assessment )ool
"?
$he SROI
et5ork
)he %&7I
9etwor* is a
framewor*
based on social
generally
accepted
accounting
principles
-S$AAP: that
can be used to
help manage
and understand
the social,
economic and
environ6mental
outcomes
created by an
organisation or a
person. In order
to increase the
social value or
impact of a tas*,
%&7I helps in
understanding,
managing and
communicating
the social value
that a particular
tas* creates in a
clear and
consistent way
with
customers"
beneficiaries
and funders. It
also helps in
managing ris*s
and identifying
opportunities
and raise
finances. It
flags potential
improvements
to services"
information
systems and the
way to govern
the businesses.
(y forecasting
the value a
company
e-pects to create
using %&7I, one
can identify the
areas where
changes are
required and a
comparison of
performance
against forecasts
will help create
additional value.
4or more details
refer the website
of %&7I
"=
$he LBG *o'el
Companies
across the world
adopt (!$5s
measurement
model in order to
assess the real
value and impact
of their
community invest6
ment to both, the
business and
society. )his
model helps
companies to
understand the
total amount of
cash, time and in6
*ind invested
with6in the
community, and
enables them to
under6stand the
geographic spread
of their commu6
nity support and
the *ind of themes
supported such as
education, health
and arts and
culture. )hrough
this model,
companies can
trac* the manner
in which their
community
programme
supports wider
business goals
such as building
employee morale
or creating
reputational
advantages. Also,
it helps to measure
the differ6ence
their programmes
ma*e to the
community at
large. 8nder this
model, member
companies share
data and best
practices which in
turn help in the
benchmar*ing
process.
.or more details
refer the website
of (!$
"<
ational
!ol(ntar)
G(i'elines on
So%ial6
Environ*ental
an' E%ono*i%
Responsibili-ties
of B(siness
)hese
guidelines
rolled6out by
the 2inistry of
Corporate
Affairs in India,
were developed
through an
e-tensive
consultative
process with the
ob0ective of
providing a
distinctive India6
centric approach
for Indian
businesses to un6
derstand the
nuances of
responsible
business,
applicable to
large and small
businesses ali*e.
)hey are easy to
comprehend and
implement, and
encourage
businesses to
adopt the triple
bottom line
approach. )hese
guidelines
consist of nine
principles which
relate to ethics
and
transparency,
product life
cycle
sustainability,
employee well6
being, sta*eholder
engagement,
human rights,
environmental
stewardship,
responsible policy
advocacy,
inclusive develop6
ment and
consumer well6
being. 3ach
principle consists
of core elements
that further
articulate the
purpose and sense
of each principle.
It also provides an
approach for
adopting these
guidelines.
4or more details
refer the website
of 2CA
"B
12
http://www.
iso.org/
iso/ho
me/sta
ndards
/iso=7!
!!.htm
13
http://w
ww.o
ecdg
uidel
ines.
nl/ge
t-
start
ed/cr
eatin
g-a-
csr-
policy/
14
http://www
.global
compa
ctsel-a
ssess
ment.o
rg/abo
utthisto
ol
15
http://www.thesroinetwor
k.org/11)-home/all-
regions/17)-why-
should-i-use-sroi1!
16 http://www.lb
g-online.net/about-
lbg.aspx
17 http://www.m
ca.gov.in/4inistry/late
stnews/2ational_:olu
ntary_+uidelines_=!
11_1=>ul=!11.pd-
1( PwC
Clause 1!0'
Companies "ct'
(1!
3andbook on Corporate Social
Responsibility in India 11
-he
Companies
"ct' (1!
In India, the
concept of C%& is
governed by clause
"#= of the
Companies Act,
!"#, which was
passed by both
+ouses of the
/arliament, and had
received the assent
of the /resident of
India on A August
!"#. )he C%&
provisions within
the Act is
applicable to
companies with
an annual
turnover of ",!!!
crore I9& and
more, or a net
worth of =!!
crore I9& and
more, or a net
profit of five
crore I)R and
more. he
new rules, which
will be applicable
from the
fiscal year ;<=>9=?
onwards" also
re#uire companies
to set6up a C%&
committee consisting
of their board
members, including
at least one
independent director.
)he Act encourages
companies to spend
at least ;@ of their
average net profit
in the previous
three years on C%&
activities. )he
ministrys draft
rules, that have
been put up for
public comment"
define net profit
as the profit
before ta6 as per
the books of
accounts"
e6cluding profits
arising from
branches outside
India.
)he Act lists out a
set of activities
eligible under
C%&. Companies
may implement
these activities
ta*ing into account
the local conditions
after see*ing board
approval. )he
indicative activities
which can be
underta*en by a
company under
C%& have been
specified under
Schedule 'II of
the
Act.
)he draft rules $as of
%eptember !"#'
provide a number
of clarifications and
while these are
awaiting public
comment before
notification" some
the highlights are
as follows;
(ist of
activities
under
Schedule
'II
1%urp
lus
arisi
ng
out
of
C%&
activ
ities
will
have
to be
rein
vest
ed
into
C%&
initi
ative
s,
and
this
will
be
over
and
abov
e the
C
figur
e
2)he
com
pany
can
impl
eme
nt its
C%&
activ
ities
thro
ugh
the
follow
ing
metho
ds; 66
Direct
ly on
its
own
66

h
r
o
u
g
h

i
t
s

o
w
n

n
o
n
9
p
r
o
f
i
t

f
o
u
n
d
a
t
i
o
n

se
t6
u
p
s
o
as
to
fa
ci
lit
at
e
th
is
in
iti
at
iv
e
66
)
hr
o
u
g
h
in
d
e
p
e
n
d
e
nt
ly
re
gi
st
er
e
d
n
o
n
9
pr
of
it
or
g
a
ni
s
at
io
n
s
th
at
h
a
v
e
a
re
c
or
d
of
at
le
as
t
th
re
e
y
ea
rs
in
si
m
il
ar
su
c
h
re
la
te
d
ac
tivi
ties
66
C
o
l
l
a
b
o
r
a
t
i
n
g

o
r

p
o
o
l
i
n
g

t
h
e
i
r

r
e
s
o
u
r
c
e
s

w
i
t
h

o
t
h
e
r

c
o
m
p
a
n
i
e
s

37n
ly
C%
&
act
ivi
tie
s
un
de
rta
*e
n
in
In
dia
wi
ll
be
ta*
en
int
o
co
nsi
de
rat
io
n
4A
c
t
i
v
i
t
i
e
s

m
e
a
n
t

e
-
c
l
u
s
i
v
e
l
y

f
o
r
e
m
p
l
o
y
e
e
s
a
n
d
t
h
e
ir
f
a
m
il
i
e
s
w
il
l
n
o
t
q
u
a
li
f
y
5A
forma
t for
the
board
report
on
C%&
has
been
provi
ded
whic
h
inclu
des
amon
gst
other
s,
activi
ty6
wise ,
reaso
ns for
spend
s
unde
r C
of
the
aver
age
net
profi
ts of
the
prev
ious
thre
e
year
s
and
a
resp
onsi
bilit
y
state
men
t
that
the
C%&
poli
cy,
impl
eme
ntati
on
and
mon
itori
ng
proc
ess
is in
com
plia
nce
with
the
C%&
ob0e
ctive
s, in
lette
r
and
in
spiri
t.
)his
has
to be
signe
d by
eithe
r the
C37
,
o
r
th
e
2
D
o
r
a
di
re
ct
o
r
o
f
th
e
c
o
m
p
a
n
y
G
o
v
e
r
n
a
n
%
e
C
l
a
u
s
e
"
#
=
o
f
t
h
e
A
c
t
l
a
y
s
d
o
w
n
t
he
1

P
w
C
guidelines to be
followed by
companies while
developing their
C%& programme.
)he C%&
committee will
be responsible
for preparing a
detailed plan on
C%&
activities, including
the e-penditure, the
type of activities,
roles and
responsibilities of
various
sta*eholders and a
monitoring
mechanism for
such activities. )he
C%& committee
can also ensure that
all the *inds of
income accrued to
the company by
way of C%&
activities should be
credited bac* to the
community or C%&
corpus.
Reporting
)he new Act
requires that the
board of the
company shall, after
ta*ing into account
the
recommendations
made by the C%&
committee, approve
the C%& policy for
the company and
disclose its contents
in their report and
also publish the
details on the
company5s 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
committ
ee
)et worth A ?<< Crore I)R
urnove
r A =<<<
Crore
I)R
)et profit A ? Crore I)R
)
u
s
i
n
e
s
s

r
e
s
p
o
n
s
i
b
i
l
i
t
y

r
e
p
or
ti
n
g
-he
other
reportin
g
re*uire
ment
mandat
ed by
the
go+ern
ment of
R
o
l
e

o
f

t
h
e

b
o
a
r
d
.or
m a
CS
R
com
miitt
ee
App
rove
the
CS
R
poli
cy
,ns
ure
impl
eme
ntati
on
of
the
acti
vtie
s
und
er
CS
R
,ns
ure
;@
spe
nd
2is
clo
se
rea
son
s
for
not
spe
ndi
ng
the
a
m
ou
nt
-if
ap
pli
ca
bl
e:
C
S
R
c
o
m
m
itt
e
e
hree
or
more
directo
rs with
at
least
one
indepe
ndent
directo
r
.
o
r
m
u
l
a
t
e

a
n
d

r
e
c
o
m
m
e
n
d

a

C
S
R

p
o
l
i
c
y

t
o

t
h
R
e
B
o
-
h
by
the
rele
+an
t
com
pan
ies,
-he
listi
ng
agr
eem
ent
also
pro
+ide
s
the
for
mat
of
the
)R
R,
-he
)R
R
re*
uire
s
com
pan
ies
to
rep
ort
the
ir
per
for
ma
nce
on
the
nin
e
NV
G
prin
cipl
es,
1th
er
liste
d
com
pan
ies
ha v e a
3
a
al
Res
pon
sibili
ty in
India
1!
CSR2 3lanning and
strategising
14 PwC
CSR
2
3lan
ning
and
strat
egisi
ng
he first step
towards formalising
CSR pro0ects in a
corporate structure is
the constitution of a
C%& committee as
per the
specifications in
the Companies
Act" ;<=C" clause
"#=.
Ba%kgro(n'
Clause "#= of the
Companies Act, !"#
requires a C%&
committee to be
constituted by the
board of directors.
)hey will be
responsible for
preparing a detailed
plan of the C%&
activities including,
decisions regarding
the e-penditure, the
type of
)his is an e-cellent
starting point for any
company new to
C%&. In case a
company already
practices C%&, this
committee should be
set up at the earliest
so that it can guide
the alignment of the
companys activities
with the
requirements of the
Act.
4or effective
implementation, the
C%& committee must
also oversee the
systematic
development of a set
of processes and
guidelines for C%& to
deliver its proposed
value to the company,
including;
1 one6time
processes such
as developing
the C%&
strategy and
operationalising
the institutional
mechanism
1 repetitive
processes such
as the annual
C%& policy,
due diligence
of the
implementation
partner, pro0ect
development,
pro0ect
approval,
contracting,
budgeting and
payments,
monitoring,
impact
measurement
and reporting
and
communication
A set of such enabling
processes, their inter6
relationships and the
sequence in which
they need to be
developed have been
identified below0
activities
to be
underta*e
n, roles
and
responsibi
lities of
the
concerned
individual
s and a
monitorin
g and
reporting
mechanis
m. )he
C%&
committe
e will also
be
required
to ensure
that all
the
income
accrued to
the
company
by way of
C%&
activities
is credited
bac* to
the C%&
corpus.
Co*p
anies
A%t6
30/76
Cla(s
e /78+
CSR
%o**
ittee
re9(ir
e*ent
s
1 A

C
%
&

c
o
m
m
it
t
e
e
o
f
t
h
e
b
o
a
r
d
s
h
o
u
l
d
b
e
c
o
n
s
ti
t
u
t
e
d
.
It
s
h
o
uld
co
nsi
st
of
at
lea
st
thr
ee
dir
ect
ors
out
of
wh
om
at
lea
st
on
e
is
an
ind
ep
en
de
nt
dir
ect
or.
)h
is
co
mp
osi
tio
n
wil
l
be
dis
clo
se
d
in
the
bo
ard
s
rep
ort
as
per
sub
6
sec
tio
n
$#'
of
secti
on
"#?.
2 )he
C%&
com
mitt
ee
shall
;
66
for
m
ul
ate
an
d
re
co
m
m
en
d a
C
%
&
po
lic
y
to
th
e
bo
ar
d,
indicating
the
activities
as
specified
in
Schedule
1II of the Act
66
recomme
nd the
amount
of
e-penditu
re to be
incurred
on the
activities
indicated
in the
policy
66 monitor the
C%& policy
regularly
CSR
processes
=
2eveloping a CSR strategy
:
/perationalising the
and policy institutional mechanism
; 2ue diligence of the
:
Pro%ect development
implementation partner
:
.inalising the
C Pro%ect approval arrangenment with the
implementing agency
Pro%ect implementation
>
Progress monitoring
and reporting
Impact measurement
:
Report consolidation
? and communication
3andbook on
Corporate Social
Responsibilit
y in India
10
While developing
these processes, no
standard set of
recommendations
e-ist for all
companies. +owever,
an overview of the
required details, the
activities required to
be completed for each
of these processes
along with some
additional guidance on
critical issues has been
provided below;
Step one+
Developin
g a CSR
strateg)
an' poli%)
+urpose
)he Companies
Act, !"# requires
every company to
put out its C%&
policy in the
public domain.
)he guidance
provided in the
Act and the draft
rules on what
constitutes a C%&
policy are that it
should;
1 e-clude
normal
business
activities of
the company
2 contain a
list of the
C%&
pro0ects or
programme
s which the
company
plans to
underta*e
during the
implementa
tion year
While specifying the
annual report
requirements, the
draft rules go on to
say is that the
company must
provide;
1 a brief outline of
its C%& policy,
including .the
statement of
intent reflecting
the ethos of the
company" broad
areas of C%&
interest and an
overview of
activities to be
underta*en
2 a web lin* to the
C%& policy
including .the
full list of
pro0ects,
activities
and
programm
es
proposed
to be
underta*e
n by the
company
%ince most of the
development requires
long6term
commitments and their
impact often ta*es a
while to accrue, a good
C%& practice requires
that a company that is
serious about its C%&
should develop a
long9term -three to
five years: vision
and strategy which is
reviewed annually and
the activities and
budgets are planned
on an annual basis.
)he latter will comply
with the C%& policy
requirements of the
Companies Act, !"#.
)o avoid confusion
regarding terms li*e
policy, strategy,
pro0ect and
programme, a brief
e-planation has
been provided here;
1 C%& strategy
refers to what the
company e-pects
to achieve in the
ne-t 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.
1 C%& policy
refers to what
the company
e-pects to
achieve over the
ne-t year. )his is
aligned with the
requirements of
the Companies
Act, !"# .
2 /rogramme
refers to a
sector or an
issue that the
company
proposes to
address
through its
C%&. )his
can, for
instance, be
.education of
the girl child
or
.agriculture
development
.
/rogrammes
will be clearly
outlined in the
companys
C%& strategy.
3 /rogramme
goals will be
achieved through
a series of
individual
pro0ects and, a
pro0ect refers to
a set of
interventions"
typically in a
specific
geography and
addressing a
specific
stakeholder
group" with a
definite set of
goals, beginning
and end and a
budget attached
to it.
4 3ach
pro0ect in
turn will
consist of a
number of
activities.
All of
which
contribute
towards the
pro0ect goals.
,rameworking
CSR strategy
An effective C%&
strategy should
articulate;
1 who it wishes
to address i e
the target group
2 where it
wishes
to wor*
i e the
geograp
hy
3 what
sectors or
issues it
wishes to
address
A brief
understanding of
these terms is
outlined below;
-arget group2 While
development and
welfare programmes
in India address all the
citi>ens, the focus is
on the disadvantaged,
marginalised and
e-cluded.
2arginalisation in
India is primarily on
the basis of gender,
disability, ethnicity
and location. )his
leads to social and
physical e-clusion of
such groups from all
*inds of development.
3ngaging the
marginalised in India
is further complicated
due to language and
literacy variances,
information
asymmetry,
infrastructure
constraints,
geographical
challenges and
cultural barriers to
name
a few. )he C%&
strategy should ideally
indicate which of
these marginalised
groups it proposes to
target.
4eography2 )he
Companies Act, !"#
encourages
companies to target
their C%&
interventions in their
local region. While
this is an obvious
choice for companies
that are in
manufacturing, those
in the services sector
$li*e ban*ing and
telecom' with a wider
footprint have no
concentrated local
region. Companies
must decide whether
their C%& activities
will be focused on a
few geographies $this
can be around their
plants or in specific
backward districts:
or
whether they will
prefer to particularly
wor* anywhere in
India.
Sector and issue2
%ector refers to the
development area
that the company
wishes to focus onD
typically, health,
education,
livelihood,
environment, and so
on.
Issue refers to a
specific aspect of a
sector for e-ample,
primary education in
the education sector,
s*ills development or
social enterprise in
the livelihoods sector.
It is important for a
company to
determine which
sector and issues it
will focus on to
ensure significant
positive impact.
Also" the reporting
format in draft rules
of the Companies
Act, !"# requires
that the company
report against the
sector ma*ing it all
the more important.
+rocess
1b5ecti+e2
Developing the C%&
strategy and policy.
3rocess o&ners2 )he
C%& committee
Inputs:
1 $uidance from
the board
2 Companies Act
requirements
3 Corporate
business
strategy, plan
and supply
chain
4 Development
priorities; both,
national and
wherever the
company has
business
interests
1utput6s72 the C%&
policy document and
an indication of
sectors and issues,
geographies and a
profile of the
beneficiaries.
16 PwC
"cti+ities
1 &eviewing the
past as well as
the current
C%& activities
and e-amining
their alignment
with %chedule
1II of the
Companies
Act, !"#.
2 %tudying
the publicly
available
information
on national
and local
developme
nt
priorities.
3 2eeting
development
e-perts in the
government
as well as the
)$/s to
understand
priorities and
identifying
potential areas
of
intervention.
4 Conducting
internal
meetings with
business leaders
to establish the
relevance of
potential C%&
activities to the
companys core
business.
5 %tudying
the good
C%&
practices
of other
companie
s and their
achievem
ents.
6 2eveloping a
CSR strategy
that defines for
the ne6t three
to five years"
what the
companys C%&
activities will
cover in terms of;
6
6

v
i
s
i
o
n

a
n
d

m
i
s
s
i
o
n

6
6

s
e
c
t
o
r
s

a
n
d

i
s
s
u
e
s
66
geographies;
states and
districts 66
beneficiarie
s
66 E/Is
1 Determin
ing the
implemen
tation
mechanis
m;
66
g
ra
nt
6
m
a
*i
n
g
o
r
di
re
ct
i
m
pl
e
m
e
nt
at
io
n
66 institutional
mechanism
; in6house
department,
corporate
foundation,
partnershi
ps with
other
)$/s
1 Annually
developing a
C%& policy in
line with the
Companies Act,
!"# rules that
defines
programmes"
geographies
and budgets
for the
following
financial year,
aligned with the
strategy and
ensuring that the
C requirement
of funds
allocation is met
2 3stablish
methods for
monitoring and
reporting
$ools6
te%hni%al
g(i'an%e
an'
stan'ar'
s to be
(se'+
1 )he "!
principles
of the 89
global
compact
2 89
guiding
principles
on business
and human
rights
3 I57
tri6
partit
e
decla
ration
of
princi
ples
on
multi
natio
nal
enter
prises
and
social
polic
y
4 73CD C%&
policy tool
5 $lobal
compact self
assessment
6 Clause "#=,
Companies Act,
!"#
Step t5o+
Operationalis
ing the
instit(tional
*e%hanis*
+urpose
In order for a
corporate to gain the
greatest leverage and
a strategic advantage
through the
investment of
intellectual and
financial resources,
they are required to
select their
implementation
mechanism. In terms
of implementation
mechanism, a
company has several
options, which are
permitted under the
C%& draft rules;
1 %elf6e-ecution
through;
66 an in6house
C%& department
66 a company
foundation
with e-ecution
capabilities
1 2a*ing grants
to an
independent
implementatio
n partner
$which has a
trac* record of
at least three
years'.
2 )he grants can
be made;
66
dire
ctly
by
an
in6
hous
e
C%&
depa
rtme
nt
66 through the
companys
grant6ma*ing
foundation
)he factors that a
company needs to
consider while
deciding between
in6house e-ecution
and grant6ma*ing
$whether
by the
department
or the
company
foundation'
are as
follows;
De%ision %riteria Grant *aking Self e&e%(tion
Availability and access to /referred when there is an easy availability and /referred when there is a lac* 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 wor* towards the ob0ective that the company wants issue' who can wor* towards the ob0ective that the
them to pursue. company wants them to pursue.
Customisation he fle6ibility of customising a CSR pro%ect to suit the he fle6ibility of customising a CSR pro%ect to suit
company needs is low to medium. the company needs is high.
Cost of implementation Implementation partners are more li*ely to have lower 7verheads 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:. 3igher fi6ed costs are involved.
the field" cost of human resources deployed and
in general operational efficiencies. .i6ed costs are
usually averaged down as the implementation partners
usually try to tap multiple sources of funding including
government assistance.
Control 5ow to medium levels of control over day to day +igh levels of control over day to day activities,
activities" efficiencies and outputs. efficiencies and outputs.
(uilding e-pertise Pro%ect management know9how is sufficient and in9 /ro0ect management *now6how is required along
depth domain *nowledge of development issues is not with in6depth domain *nowledge of development
e-pected. issues.
3andbook on Corporate Social
Responsibility in India 1%
It must be noted that
whatever
implementation
mechanism the
company chooses, it
must have a basic
C%& department in
place to support the
C%& committee. )he
role and structure of
the department will
be determined by the
C%& committee.
Sele%ting
legal
str(%t(re of
the %o*pan)
fo(n'ation
2any companies have
set up their own
foundations $a term
used loosely to
describe a non9profit
entity promoted by a
company: to
implement their C%&
activities. )he
advantages that they
see in this are;
1 It enables
leveraging
of funds
from other
sources i e
the
government
schemes
and other
foundations
.
ypically"
profit
organisation
s are not
eligible for
such funds.
2 %ince the s*ills,
0ob titles, career
paths and cost
structures
required for the
e-ecution of
C%& pro0ects
are quite
different from a
companys
operations, a
separate
foundation
enables the
company to
*eep these
distinct.
8nder the draft
C%& rules, an
entity that a
company sets up
to facilitate the
implementation
of its C%&
activities is to be
registered in India
as a trust, society,
or a non9profit
company under
section D
=D
of the
Companies Act"
;<=C. )on9profit
organisations in
India are;
1 self6governed by
a board of
trustees or a
managing
committee or a
governing
council,
comprising
individuals who
generally serve
in a fiduciary
capacity
2 intended to
benefit others
outside the
membership of
the organisation
3 prohibited
from
distributing
a monetary
residual to
its
members
A detailed
comparative analysis
of the three choices
of non9profit legal
structures is
attached in Appendi-
"; Comparative
analysis of the three
choices for legal
entity.
+rocess
1b5ecti+e2
3stablishing a legal
entity and aligning
the accounting" ta6"
finance"
administration, +&
and I) systems to
deliver the
commitments made in
the C%& policy.
3rocess
o&ners2 )he
C%&
committee
Inputs: )he
C%& strategy
1utput6s72
1 creation of a
separate legal
entity or a C%&
department for
C%& activities
2 other
institutio
nal
mechanis
ms to
align the
accounti
ng"
finance"
administration,
+& and I)
systems with
C%& activities
"cti+ities2
1 %electing the
organisation
model for the
C%&
implementatio
n; in6house
versus
outsourced
and its legal
entity
-trust"
society"
Section D
"A
company , in6
house
department,
etc'
2 Identifying the
implementation
model $grant
ma*ing, direct
pro0ect e-ecution,
etc'
3 4ormalising
the 0ob
description,
the roles and
responsibilit
ies and the
reporting
relationships
for the C%&
team
$whether in6
house or in a
foundation'
4 Integrating
budgeting,
procurement,
payments and
reporting for
C%& with the
e6isting
finance"
administratio
n and I)
systems
5 Analysing
accounting
systems and
chart of
accounts and
ma*e
required
changes to
record all
e-penses
appropriately.
3stablish a
method of
allocation for
the e-penses
$or assets
created' that
are partly for
the C%& and
partly for
business or
employee
use.
$ools6
te%hni%a
l
g(i'an%
e an'
stan'ar
's to be
(se'+
1 )o be
tailore
d as
per
corpor
ate
require
ments
Step three+
D(e 'iligen%e
of the
i*ple*entatio
n partner
+urpose
Due diligence
refers to the
process a company
underta*es to
determine the risks
as well as the
benefits of
working with a
potential
implementation
partner.
his process has
to be sufficiently
robust to ensure that
a companys
implementation
partners have the
reputation,
competence and
integrity to deliver
effective
programmes on the
ground.
It begins as soon as
the discussions with
the implementation
partner suggest that
there is prima facie
interest of both
parties to enter into a
partnership. A
detailed due6
diligence is essential
for large and long
partnerships but may
be brief for a
relatively small or
opportunistic
partnership
opportunity.
he due
diligence process
consists of five
primary areas for
investigation;
1 competence
of the
implementati
on partner
2 identity
3 management
4 accountability
5 transparency
and financial
capability
)hese have been
outlined below;
1(&1' ?he non-pro-it organi@ation
-ormerly known as ,ection =* companies
are now called ,ection ( companies a-ter
the introduction o- #ompanies Act& =!16.
1. PwC
Iss(e S(b-iss(e Des%ription
Competence of the $eography Capacity, e-pertise and the number of years of e-perience with the geography under consideration
implementation %ector Capacity, e-pertise and the number of years of e-perience with the sector under consideration
partner
Issue Capacity, e-pertise and the number of years of e-perience with the issue under consideration
+istory of e-istence )he number of years the implementation partner has been in e-istence
5egal identity he organisation is registered either as a trust" a society or Section D company" a charitable company"
Identity a co6operative society or is unregistered
Affiliations he desired level of affiliation with governments" local administration and international bodies
5itigations Any ongoing litigation
Composition of the board 9umber of members, advisors, term of members and advisors and board renewal procedures
Profile of the board (ios of the members on the board, their number of years and depth of e-perience and relevant
members and advisors achievements
Diversity in e-pertise )he e-pertise available at the disposal of the board for development activities
2anagement
(oard meetings &egularity of meetings, attendance records and recent topics of discussion
1ision, mission and )he management outlines its vision, mission and strategy in its operational plans or other documents.
strategy )hese plans are communicated to all relevant employees
3-perience of the )he management personnel responsible for the day6to6day activities have the necessary depth of
management e-perience and s*ill 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. here is no conflict of interest with the local governments.
)ransparency )ransparency Awareness of the disclosure and the transparency requirements for all sta*eholders $including
regulators and funders' li*e periodic reporting, e-ternal audits and ratings
4inancial statements Availability of audited financial statements
Adequacy of reserves A formalised and institutionalised system for keeping reserves for times of financial need
4inancial capability %ection "A registration %tatus of %ection "A registration
D<$ registration Status of D<$ registration.
4C$&'A registration %tatus of the registration with the 4oreign Contribution $&egulation' Act !"!.
A more detailed due6diligence can also underta*e the evaluation of the
following five issues0
1 organisation structure
2 operations, systems and processes
3 human resource
4 financial capability
5 ris* management
CII and Credibility Alliances guidelines for identifying )$/ partners are
mentioned in
Appendi- ?.
+rocess
1b5ecti+e2 %electing the implementation partner.
3rocess o&ners2 )he C%& department or Company 4oundation
Inputs:
1 the C%& strategy and policy
2 discussions with communities, board, staff, other funders, local
government officials" local leaders or influencers" auditors
1 studying the
boo*s of
accounts and
the auditors
report
1utput6s72
1 a due diligence
report
"cti+ities2
2 3stablishin
g a due
diligence
criteria to
evaluate the
implementa
tion or
concept
development
agency
including its
incorporation,
permits and
licenses,
systems,
processes,
public image,
management,
team
deployment,
track record"
financial
soundness"
competence
level, presence
in desired
geography,
compatibility
with company
CSR policy and
any conflicts of
interest.
3 3stablishin
g a due
diligence
criteria for
evaluation
and
empanelme
nt of
private
funders for
partnership
and 0oint
pro0ects.
4 3valuating the
partnership
opportunities
for its risks
and benefits.
$ools6
te%hni%al
g(i'an%e
an'
stan'ar's
to be (se'+
1 )o be
tailored as
per
corporate
requireme
nts.
Step fo(r+ Pro;e%t 'evelop*ent
+urpose
)he C%& strategy of a company will be implemented through a
series of pro0ects which will have definite beginnings" ends"
e-pected outputs and outcomes as well as budgets associated
with it. )hese pro0ects may be of a short duration $a few months'
or multi6year.
A company may choose to implement pro0ects through its in6
house teams or in partnership with other agencies or a
combination of both. Whatever path it ta*es, it is important for
the pro0ect
to be
developed
clearly with
distinct
baselines,
defined
activities"
4monitorable5
targets and
budgets. In
the case of
multi6year
pro0ects, it is
important to
include a
provision to
underta*e
annual
reviews
which can
form the basis
to revise the
pro0ect.
3andbook on Corporate
Social Responsibility in
India 1/
+rocess
1b5ecti+e2 Developing a feasible pro0ect
proposal.
3rocess o&ners2 )he implementation
agency $the C%& department, company
foundation or the )$/ partner:
Inputs:
1 the C%& policy
2 institutional mechanisms
3 information from the government
sources, previous studies done in the
area, etc
4 information on programs targeting
similar geographies and
beneficiary groups or strategies
5 monitoring impact measurement
reports from any earlier pro0ects
1utput6s72
A pro0ect proposal that details;
1 a pro0ect conte-t including the roles of
other development actors
2 key needs of the target beneficiaries
3 pro0ect goals, E/Is, baselines and
e-pected end lines
4 pro0ect milestones for progress
monitoring purposes
5 activities and timelines to achieve the
stated pro0ect goals
6 budgets along with the basis for
estimation
7 ris*s and mitigation strategies
8 progress reporting; content, frequency
"cti+ities2
1 Developing a framewor* to identify *ey
sta*eholder groups including the local
community, the local government or
bodies, academia and research
institutions, investors, etc.
2 Conducting a needs assessment $if
required' to assess development priorities.
)he methodology for this can be
participatory processes, surveys or a
combination of the two.
3 %tudying and adopting good practices to
address similar challenges based on
prior e-periences or lessons available
from other practitioners and develop the
approach.
1 Detailing the pro0ect; the ob0ectives, the
beneficiaries and the impact on the
beneficiaries" the assumptions" the
e-pected outputs and outcomes, detailed
activities, potential to influence public
policy and practice.
2 Identifying the indicators of success with
the means of verification and establish
the baseline for each. )his can be
commissioned as a separate study or can
even be included in the needs assessment
stage.
3 3stimating the budget and how it will be
funded specifying the community
contributions, leveraging of the
government schemes and contributions
from the other donors.
4 Indicating the monitoring and
evaluation methodologies for impact
measurement.
$ools6 te%hni%al g(i'an%e an'
stan'ar's to be (se'+
1 %ocial return on investments $%&7I',
the %&7I networ*
2 $lobal impact investing
network -$II):
3 I%7 <!!!; social responsibility
Step five: Project approval
+urpose
3very pro0ect, whether developed by the in6
house team or an e-ternal agency, must be
formally e-amined and approved. )his is to
ensure that each pro0ect is in line with the C%&
strategy and policy, the monitoring indicators
are clearly defined and relevant and there is
an adequate budget available. /ro0ects that go
on for longer durations
or demand a larger amount of resources must
be scrutinised more carefully than the others.
)he C%& committee is ultimately the one
responsible for every pro0ect. It can,
however, choose to delegate authority to a
pro0ect approval committee consisting
of company staff and outside e-perts with
clearly defined roles and responsibilities.
+rocess
1b5ecti+e2 Approve the pro0ect based on
the C%& policy ob0ectives, principles and
guidelines.
3rocess o&ners2 )he C%& committee or the
delegated pro0ect approval committee.
Inputs:
1 a pro0ect proposal
2 a due diligence report
1utput6s72 An approved pro0ect proposal
including a monitoring process and
reporting and responsibility for this.
"cti+ities2
1 Determining the delegation of power
for the pro0ect approval.
2 3stablishing an evaluation framewor* for
the appraisal of the pro0ect concepts and
implementing agencies that ensure
complete alignment with the C%& policy.
3 3stablishing tests for the theory of
changeD whether the concept will be
able to deliver the intended results.
3stablishing tests for the value for
money, economy, effectiveness and
efficiency.
4 &eviewing ris*s and mitigation
measures.
5 Identifying resource availability
and any specific organisational
requirements and constraints.
6 5aying down organisational supervision
and oversight requirements.
$ools6 te%hni%al g(i'an%e an'
stan'ar's to be (se'+
1 )o be tailored as per corporate
requirements.
Step si&+ <inalising the
arrange*ent 5ith the
i*ple*enting agen%)
+urpose
While wor*ing with an e-ternal agency, it
is very important to enter into a formal
arrangement which is referred to here as a
2emorandum of 8nderstanding or
Bo*. It defines the roles" responsibilities"
deliverables, commitments and consequences
in case of any breach. )his is essentially a
formal ac*nowledgement that all the partners
have voluntarily consented to wor* together to
achieve an agreed outcome that requires each
one to play their respective roles.
)he term 2o8 is used more generically here to
refer to the arrangements between partners
which can range from a formal, legally
enforceable contract on the one hand to a
simple e-change of written documents
( PwC
on the other. +owever, what is important
for the company to *eep in mind is that it is
entering into an arrangement with a
partner, not a supplier and there is a greater
sense of mutuality in this relationship.
It may also be noted that the 2o8 is relevant
only if the pro0ect is being implemented by a
legal entity other than the companys own
C%& department. It must also be e-ecuted if
the pro0ect is being implemented by the
company foundation if it is a separate legal
entity.
-isbursement scheduling
4or a pro0ect to deliver the desired results, it
should have sufficient funds to carry out
the planned activities. At the same time,
having e-cess funds in the ban* account is
not prudent financial management.
)hus, the scheduling of disbursements is
important both for the company $to plan its
cash flows from the CSR budget: and the
implementing agency and hence needs to be
detailed in the 278.
A good practice suggests that the scheduling of
disbursements should be lin*ed with
the activities planned for the each periodD
this can be a quarter, si- months or a year
depending upon the administrative
convenience and budget si>es. )hus, the
pro0ect budget needs to be bro*en up
accordingly and the funds required for the
subsequent period should be made available in
advance.
Actual disbursements have to then be lin*ed to
the progress on the ground. )he 2o8 should
also specify the conditions that the
implementing agency should fulfil and the
documentation it should provide in support of
a disbursement request. )ypically, these
include the status of;
1 activities originally planned in the
period
2 changes and the reasons thereof
3 planned and required funds for the
period
4 utilised funds and ban* balances
5 net funds required
+rocess
1b5ecti+e2 Agree upon and sign the 2o8
with the partner.
3rocess o&ners2 )he C%& department or
company foundation
Inputs:
1 an approved pro0ect proposal
2 a due diligence report
1utput6s72 2o8 with the implementing
agency including the disbursement
schedule.
"cti+ities2
1 Developing template 2o8s based on
the conte-t. %pecify the outputs and
outcomes, the approach and
methodology, the E/Is, *ey parameters to
be monitored and reported, the mode of
communication, contract management
team, scope of change
in management procedures, dispute or
conflict resolution mechanisms"
inspection and audit requirements,
contract closeout requirements, time6
lines, milestones and deliverables,
budgets, process of invoicing and
release of payments, etc
2 3stablishing a process for negotiation
of the 2o8 with the implementing
agency.
3 9egotiating, agreeing upon and signing
the 2o8
$ools6 te%hni%al g(i'an%e an'
stan'ar's to be (se'+
1 )o be tailored as per corporate
requirements.
Step seven+ Progress *onitoring
an' reporting
+urpose
&outine progress monitoring serves the
following three important purposes;
1 It highlights any slippages and helps to
determine a corrective action that must be
ta*en if need be.
2 It provides an e-cellent opportunity for
learning; what wor*ed and what did not.
)his can then be immediately applied to
other pro0ects.
3 )his is an essential part of the directors
report as per the C%& clause of the
Companies Act, !"#
)o ensure ob0ectivity, it is critical that the
monitoring is done by someone other than
the people directly engaged in the pro0ect
implementation. In cases where the
implementation is done by a partner or
corporate foundation, this role can either be
outsourced or played by the companys C%&
department. In case the C%& department itself
is implementing a pro0ect, then monitoring
should either be outsourced to a third party or
the department structure should include an
independent monitoring cell. )his decision
should be ta*en by the C%& committee.
+rocess
1b5ecti+e2 2onitoring progress, distilling
lessons and forming the basis for reporting.
3rocess o&ners2 )he C%& committee
Inputs:
1 )he approved pro0ect proposal
2 /revious monitoring reports
1utput6s72
3 Determining mid6course corrections
4 &ecommendations for future pro0ect
designs
5 /ro0ect monitoring reports to the C%&
committee
"cti+ities2
1 Determining the monitoring schedule for
each pro0ect based on the approved
pro0ect proposal.
2 7btaining all relevant progress reports
from the pro0ect, studying them and
ma*ing a note of the gaps.
3 +olding discussions with the
implementation team on reasons for
slippages $if any' and agreeing on a
corrective action. )his may be done
through a field visit or remotely" based
on what has been agreed in the 2o8.
4 +olding discussions with the
implementation team regarding what
lessons are emerging and how they can
be applied within the pro0ect as well as
outside.
$ools6 te%hni%al g(i'an%e an'
stan'ar's to be (se'+
1 )o be tailored as per corporate
requirements.
3andbook on Corporate Social
Responsibility in India 1
Step eight+ I*pa%t *eas(re*ent
+urpose
Impacts of the development pro0ects typically
ta*e a while to manifest. 4or instance, a girl
child education programme can show an
increased enrolment and retention of girls and
on a monthly basis, but further impacts such
as improved learning levels will ta*e at least
a year.
%o, impact measurement studies have different
ob0ectives from pro0ect monitoring and
typically have to be underta*en after
providing sufficient time for them to
manifest.
Impact measurement is often quite
specialised and needs to be underta*en by
an independent team with specific
s*ills depending upon pro0ect design. 4or
instance, if a girl child education
programme has a strong component for
mobilising communities, then the
members of the evaluation team must not only
understand education but also have
*nowledge of gender and the community in
order to assess the impact.
)here are several tools and framewor*s for
measuring impact. 3ach has its pros and cons
depending upon the nature of interventions,
time and budgets available for the study and
the availability of people. )hus, selecting the
impact measurement methodology is
important.
)hus, impact studies have to be carefully
planned in terms of team composition, timing
and methodology. )he process must be driven
by the C%& committee which can delegate the
day6to6day management of the process to an
appropriate structure within the company.
+rocess
1b5ecti+e2 2easuring the outcome and
impact of the pro0ects.
3rocess o&ners2 )he C%& committee
Inputs:
1 resource planning
2 the pro0ect 2o8
1utput6s72
1 impact measurement report
2 recommendations for the future pro0ect
designs
"cti+ities2
1 Identifying methods for conducting the
impact assessment and outcome
measurement suited to the conte-t and
the si>e of the pro0ect and budgets
available.
2 Identifying the s*ills set required for the
impact measurement team and
accordingly identifying, selecting and
appointing the team.
3 Assisting the team to prepare the
methodology for selecting a sample,
conducting surveys, focus group
discussions collecting information on
the identified indicators.
4 2a*ing the provisions for the site visits
by the team, involvement of the agency
involved during the baseline and needs
assessment.
5 8nderta*ing the impact measurement
e-ercise and preparing the report.
6 Identifying the lessons for future
interventions.
$ools6 te%hni%al g(i'an%e an'
stan'ar's to be (se'+
1 (ondon !enchmarking
$roup-(!$: model
2 %ocial return on investments $%&7I',
)he %&7I networ*
3 $lobal impact investing
network -$II):
4 Accountability 6; AA "!!!, Institute of
%ocial and 3thical Accountability
5 I%7 <!!!; social responsibility
6 /ublic consultation guidelines of
$overnment of India" etc
Step nine+ Report %onsoli'ation
an' %o**(ni%ation
+urpose
&eporting and communication closes the loop
between intent and achievement and is hence a
crucial element of the C%& process. In the
conte-t of the Companies Act, !"# this is also
a mandatory requirement as it provides crucial
inputs to preparing the directors report.
/ro0ect6level reporting forms the base and
hence getting it right is critical. /ro0ect
reports have to be consolidated in
programme related reports, aligned with the
C%& policy stated by the company
as a requirement under the Companies
Act, !"#. )he report has to conform to the
requirements of C%& rules under the
Companies Act, !"# in terms of form and
content as non6compliance attracts
penalties. )his report will also form a *ey
input into the companys %3(I (usiness
&esponsibility &eport and sustainability
report. )he C%& committee may choose to
go beyond the requirements of the
Companies Act, !"# and issue a stand6
alone C%& report.
+rocess
7b0ective; &eporting the C%& at an
individual pro0ect level, consolidated at a
programme level and aligned with the
requirements under the Companies Act,
!"# and the C%& committee.
3rocess o&ners2 )he C%& department
Inputs:
1 C%& strategy and policy
2 the pro0ect 2o8
3 monitoring reports from individual
pro0ects
1utput6s72
1 consolidated C%& reports
2 e-ternal sta*eholder communication
"cti+ities2
1 Identifying the recipient of the report; the
board of directors, investors, government
agencies" beneficiaries" etc.
2 %electing the appropriate reporting
framewor* that is aligned with the
requirements of the Companies Act,
!"# and the global best practices.
3 Consolidating pro0ect reports into
programme reports and an overall C%&
report.
)he reporting format will form a part of the
C%& rules being drafted by the 2inistry of
Corporate Affairs.
$ools6 te%hni%al g(i'an%e an'
stan'ar's to be (se'+
1 S,!I directive on ,S$ disclosure -if
applicable' , &(I guidelines on C%&,
sustainable development and non6
financial reporting -if applicable:
2 Clause "#=, Companies Act, !"# $if
applicable'
PwC
CSR and SMEs
3andbook on Corporate Social
Responsibility in India !
CSR an' SMEs
.hat are S/)s0
%mall and medium
enterprises $%23s'
significantly contribute
towards
Indias economic growth.
)hese serve independently
and also as ancillary to larger
units and help generate
employment and industrialise
the rural and bac*ward
regions of India. )hey employ
nearly ?!C of Indias
wor*force and contribute
around ?=C to Indias
manufacturing output
!
.
.hat do they do0
)he business activities of
%23s are performed in
pro-imity to the locals. )his
enables them to be aware of
community needs, manage
e-pectations and develop
C%& programmes
appropriately.
9ow that the C%& clause in
the Companies Act, !"#
covers companies that have
a net profit of five crore
I)R and above" it is
e-pected that while micro6
enterprises will not qualify,
many small and medium
enterprises $%23s' will.
%23s are being treated
separately in this handboo*
because of their distinct
features. )he C%& activities
of these enterprises
are driven by the personal
interests of promoters who
hold a significant financial
sta*e in the business. )hey
tend to be in clusters and
engaged in similar business
activities. While the quantum
of revenue available for C%&
with individual %23s is
e-pected to be small, all
eligible companies in a
specific geographical
cluster" who single handed
as well as collectively impact
the same community, can pool
their resources to create a
si>eable C%& fund.
1ow can S/)s
contribute to CSR
initiatives0
)his section analyses the
option of underta*ing
collaborative C%&
activities by %23s. )his
collaboration can also be
used by other companies
to ma-imise the impact of
their C%& initiatives
while reducing the
operational costs for fund
management.
.hy
collaborat
e for CSR
initiatives0
C%& is for all companies.
%23s in India have
participated in C%& activities
but these efforts have not been
optimally delivered.
"
7ne
possible reason can be the fact
that C%& activities depend
on the profits of an SB,
and any fluctuations in
profits can adversely affect
their capability to continue
their contribution for C%&.
Another reason can be the
limited human resources
available to %23s which may
also result in the lac* of a
professional approach.
%23s tend to focus on short6
term activities that involve
lesser operational costs. A
survey conducted by
*)I2/ in ;<<D on five
%23 clusters in India, found
that #"C to BAC of the %23s
in these clusters, preferred
charity donations rather than
long6term programmes for
local communities.
With the introduction of the
new Companies Act, !"#, the
%23s approach to C%& has
to be modified while
keeping operational costs
low. 7ne viable alternative is
to pool resources with other
%23s in the cluster and create
0oint C%& programmes
managed by a single entity.
)his collaboration can be
formed within the units in a
cluster as they interact with
the same communities and
have already established
associations that cater to the
business needs of the units.
Collaboration
has the follo&ing
ad+antages2
1 Reduces operational
cost2 Individual C%&
efforts by a company
consist
of establishing a C%&
department, assessing the
needs of local
communities,
underta*ing programmes
directly or through an
)$/ and conducting
regular impact
assessment studies. A
common organisation
catering to a number of
companies will carry out
these activities
collectively and thus
reduce the operational
cost of management.
2 8ndertake long9term
pro5ects2 A ma0or
hindrance in developing
long6term pro0ects is the
uncertainty in the C%&
budget. )his is
dependent on the
financial performance
of the company. A
fluctuating
performance implies
that the C%& budget
allocations can be
unreliable and can
0eopardise a programme
initiated earlier. /ooling
resources addresses this
issue to a
20. htt
p://articles.
economicti
mes.indiati
mes.com/
=!16-!7-
!'/news/6
'(65(*)_
1_smes-
work-orce-
small-and-medium-enterprises
21. http://www.business-
standard.com/article/sme/smes-to-
get-pro-essional-help-on-corporate-
social-responsibility-
1!(!7!*!1!'!_1.html
4 PwC
certain e-tent as the
other partners can
increase their share in
case there is variance in
allocation from a
certain segment of the
cluster. )he long6term
programmes also have
greater impact than the
short6term pro0ects.
Communities are
increasingly realising
the importance of the
support offered by these
programmes in ma*ing
their lives better. 5ong6
term programmes also
lead to better
community relations and
this ensures avoiding
situations
of community
unrest that hamper
business activities.
1 :earning from
e;periences2 A common
entity with multiple
participants from the
cluster will help assess
community needs,
underta*e relevant
programmes based on
past e-periences and
address a greater number
of community issues.
Collaboration among the
%23s in a cluster also
provides an opportunity to
manage social and
environmental issues and
respond better to the pressure
from buyers, who are trying
to establish ethical supply
chains and gain appreciation
from the international
community. Collaborations
can also be forged amongst
larger companies, possibly
through industry
associations, to enable them
to address common issues
plaguing a geographical
region or an industry.
!he process for an S/)
he first step involved in
collaborating is to create an
alliance of interested %23s.
)his may be initiated by the
cluster association in case of
large6scale participation
from the cluster.
Alternatively, it can be
initiated by an individual
%23 in case there are only
a few units interested in
underta*ing C%& activities
in collaboration.
Involvement of the cluster
association will ensure that
the local priorities are given
due consideration while
developing C%&
programmes. In case a
sufficient number of SB,s
in a cluster do not wish to
participate or are not
required under the
Companies Act, !"# to
spend on C%& activities, the
boundary may be e-tended
to other clusters, though this
increases comple-ity.
)he alliance should then form
a steering committee with the
representatives from each
%23 so as to democratically
decide on issues. )he steering
committee should study the
institutional method of
implementation, i.e.
underta*ing activities through
an established trust"
society" a Section D
company or forming a new
entity or directly managing
the funds.
)he steps other than the
guidelines mentioned by the
steering committee in the
section 1CSR0 Planning
and strategisingE of this
handboo*, include the
following;
1 Deciding the
thematic areas
from %chedule 1II
of the Companies
Act" ;<=C" beneficiary
groups and
geographies that it will
target based on the
inputs from participants.
2 Developing internal
processes to trac*
individual contribution
by members and their
utilisation in C%&
activities, finalising
long9term pro%ects
based on pro0ected
contributions by
members and
addressing non6
payment by members.
)he C%& policy of individual
%23s should be designed to
allow for fle6ibility in case of
a collaborative effort to
underta*e C%&. )his implies
that the policy, over and above
the guidelines mentioned in
the section 1Step one0
2evelop CSR strategy and
policyE" should allow the
following;
1 4le-ibility in selecting
thematic areas from
%chedule 1II of
Companies
Act" ;<=C" beneficiary
groups and
geographies as per the
priorities of the entire
association.
2 %upport to initiate
C%& programmes to
the e-tent possible, in
case the association is
abandoned.
)he ne-t steps involved in
the due diligence of
implementation or the
concept development partner
are;
1 /ro0ect development
2 7perationalisi
ng
institutional
mechanism
3 Contracting
4 (udgeting and payments
5 2onitoring
6 Impact measurement
&eporting and
communication are as
described in section
1CSR0 Planning and
strategisingE
In cases where the
total C%& funds are
insufficient to
cover the cost of
collaboration, %23s can
also contribute to the /rime
2inisters 9ational &elief
4und or any other fund set
up by the central
government or the state
governments as per activity
i- of the %chedule 1II of
the Companies Act, !"#.
3andbook on Corporate Social
Responsibility in
India 0
"ppendi; 1
Comparative analysis of the three choices for legal entity
Differential fa%tors $r(st
Basi% 'o%(*ent )rust deed which
contains ob0ects of
the trust
$bye6law'
<or*ation %imple
=(ris'i%tion Deputy registrar
or charity
commissi
oner
Legislation > stat(te &elevant state
trust act
Ob;e%tives Social benefits
and charitable
Re-a*en'*ent Alteration can be
underta*en only
or modification of by the founder or
settler
ob;e%ts
Re9(ire' *e*bers 2inimum F ,
ma-imum F no limit
Registration As trust with the
registrar
Sta*p '(t) ?C of trust
property value will be
e-ecuted in non 0udicial stamp paper
with the
registrar
a*e 3asy to choose
Manage*ent boar' )rustees
S(%%ession in (y election
*anage*ent
Meetings 9o provisions
Stat(tor) reg(lations
9ominal
Me*bership transfer 9ot
possible
Me*ber a'*ission 9ot
applicable
Pa)*ent to *e*bers
As notified in
trust deed
So%iet) Se%tion , %o*pan)
33
1earlier kno5n as Se%tion 38 %o*pan)2
2emorandum of association 2emorandum of association
Articles of association with rules and Articles of association
regulations
%imple Slightly difficult
&egistrar of %ocieties &egistrar of Companies
Societies Registration Act =DF< Companies Act !"#
(iterary" charitable" scientific and )onprofit activities
resource oriented
3asy, legal procedures Complicated, legal procedures
2inimum F B, ma-imum F no limit 2inimum F B, ma-imum F no limit
As society with society registrar As per Companies Act under Section D -earlier
%ection ='
9o stamp paper required for 9o stamp paper required for memorandum and
memorandum of association, and articles of association
rules and regulations
3asy to choose /rior approval required from &egistrar of
Companies
$overning body !oard of directors and management
committee
(y election (y appointment
Annual meeting as per law, Guite e-tensive as per the provision of
governing body meeting as per the Company 5aw
rules of society,
5imited 2aturable and e-haustive
9ot possible 4ree or control as per desire
$overning body control $eneral body or board control through issue
of capital
9ot restricted As approved by company and state
22 ?he non-pro-it
organi@sation -ormerly known as
,ection =* companies are now
called ,ection ( companies a-ter
the introduction o- #ompanies Act&
=!16.
6 PwC
"ppendi;
Designing a volunteering programme
As part of their
corporate social
responsibility
efforts,
companies
encourage their
employees to
volunteer for a
cause $usually
pre6selected by
corporate
human
resources or
foundations'
during wor*
hours under
formalised
employee
volunteering
programmes
$31/s'. )hese
31/s involve
substantial
opportunity
cost for
employers and
therefore must
be carefully
planned and
e-ecuted.
#
h
o

i
s

a

%
o
r
p
o
r
a
t
e

v
o
l
(
n
t
e
e
r
?
A corporate
volunteer is
an
employee
who
actively
ta*es on a
tas*,
responsibilit
y, or pro0ect
on his or
her own
accord
without
needing to
be assigned
or told to do
so as part of
his or her
daily 0ob
duties.
Corporate
volunteerin
g is
generally
considered
an altruistic
activity and
is intended
to promote
larger social
or
environmen
tal good or
improve the
quality of
life of a
target
beneficiary
or a
community
.
Bost
often"
there are
no
financial
gains for
the wor*
or service
provided
by such
volunteer
s.
+owever,
sometime
s this
volunteeri
ng
involves
incentive
s such as
persona
lity or
profile
develop
ment"
skill
develop
ment,
socialisa
tion, and
fun. In
certain
areas of
voluntee
ring
wor*
such as
health
services,
educatio
n or
emergen
cy
rescue
voluntee
rs
receive
training
before
they can
contribut
e.
Design
para*eter
Organi
sation
goals+
5aying
out the
overall
ob0ecti
ve of a
compan
y from
its
31/.
E*plo)ee
vol(nteering
*e%hanis*+
Developing
the
institutional
framewor*
under which
employee
volunteerism
can be
channelled
for a larger
good.
Re%r(it*en
t an'
enrol*ent+
Attracting,
screening
and
selecting
#ualified
individuals
for a
specific
volunteer
role.
In'(%ting
an' training+
Welcoming
new
volunteers to
the 31/ and
preparing
them for their
role. It
provides an
introduction
to the wor*ing
environment where
they will volunteer
and available
resources. )he
process will cover
volunteer rights, the
terms and conditions
of volunteering,
legal and
compliance
requirements and
health and safety
guidance. It also
covers any
necessary training
needs of the
volunteers to
perform their duties.
A%tivities
1
I
d
e
n
t
i
f
y

v
o
l
u
n
t
e
e
r
i
n
g

g
o
a
l
s

o
f

y
o
u
r

o
r
g
a
n
i
s
a
t
i
o
n
.

2
3st
a
b
l
i
s
h

i
n
s
t
i
t
u
t
i
o
n
a
l

o
w
n
e
r
s
h
i
p

o
f

v
o
l
u
n
t
e
e
r
i
n
g

p
r
o
g
r
a
m
m
e
.

3 3
stablish
volunteer
codes of
practice.
4 3
stablish
volunteer
ing
governin
g
principles
.
5 D
esign
volunteer
program
mes and
pro0ects.
6
Draft
volu
ntee
ring
agre
eme
nt
inclu
ding
the
state
ment
of
volun
teer
rights
and
respo
nsibil
ities.
7
5ay
o
u
t
r
o
l
e
s
a
n
d

r
e
s
p
o
n
s
i
b
i
l
i
t
i
e
s
o
f
c
o
o
r
d
i
n
a
t
o
r
s
f
o
r
t
h
e
3
1
/
.
8 3n
sure
continuity
in
volunteer wor*.
9 5
ay out the
volunteer
recruitmen
t and
enrolment
process.
10 Create
volunteer roles
and writing
position
descripti
ons.
11 %e
gment and
target
volunteers.
12 W
rite
volunteer
advertisem
ents.
13 /
rocess
enquiries
and
applicatio
ns.
14 8
nderta*e
selection
and
interview
process.
15 De
sign and
deliver
induction
and
orientation
programm
es.
16 )r
ain
volunteers.
+owever,
most
volunteers
serve on a
need basis
without
any prior
educationa
l or wor*
e-perience
of related
bac*groun
d.
%eve
ral
desi
gn
para
mete
rs
and
relat
ed
activ
ities
need
to
cons
idere
d
whil
e
deve
lopi
ng
an
31/
;
Men
torin
g
an'
s(pe
rvisi
ng+
Ad
hoc
assist
ance
by a
more
e-per
ience
d and
*now
ledge
able
perso
n to
help
facili
tate a
less
e-per
ience
d
a
n
d

*
n
o
w
l
e
d
g
e
a
b
l
e

p
e
r
s
o
n

t
o

r
e
a
c
h

h
i
s

o
r

h
e
r

i
n
d
i
v
i
d
u
a
l

g
o
a
l
s

a
n
d

o
b
0
e
c
t
i
v
e
s

i
n

t
h
e
vol
unte
erin
g
pro
gra
mm
e.
%up
ervi
sion
inv
olve
s
mana
geme
nt of
the
indivi
duals
perfor
manc
e
again
st a
prescr
ibed
ob0ect
ive on
a
routin
e
basis
and
provi
ding
action
able
feedb
ac*.
Re
5a
r'i
ng
an'
re%
ogn
isin
g+
&e
war
ds
and
rec
ogn
itio
n
are
giv
en
wh
en
an
org
anis
atio
n
wa
nts
to
mot
ivat
e
vol
unt
eers
in
ac
hie
vi
ng
a
go
al
or
or
ga
nis
ati
on
al
ob
0ec
tiv
e.
&e
wa
rds
an
d
rec
og
nit
io
n
are
de
sig
ne
d
to
dis
tin
gu
ish
an
d
motiv
ate
emplo
yees.
)his is
import
ant in
the
case
of
volunt
eering
where
emplo
yees
do not
have
any
financ
ial
incent
ives.
En%
o(ra
ging
'ive
rsit)
+
3nc
oura
ging
empl
oyee
s
with
uniq
ue
e-pe
rienc
es
and
bac*
grou
nds
t
o
w
o
r
*
t
o
g
e
t
h
e
r
t
o
i
n
c
r
e
a
s
e
p
r
o
d
u
c
t
i
v
i
t
y
,
e
f
fec
tiv
en
ess
an
d
res
po
nsi
ve
nes
s
to
ch
an
gin
g
co
ndi
tio
ns
to
en
ha
nc
e
the
ir
co
ntr
ibu
tio
n
an
d
be
ne
fit
fro
m
th
e
vol
un
te
eri
ng
e6
er
cis
e.
1 D
esign
and
deliver
mentorin
g
program
me.
2
Assign,
supervi
se and
establis
h *ey
perfor
mance
indicat
ors for
volunte
er
w
or
*.
3
/rovid
e
perf
orm
anc
e
feed
bac
* to
vol
unte
ers.
4
Eeep
vol
unte
ers
m
oti
vat
ed.
5
2ana
ge
dis
pu
tes
an
d
gri
ev
an
ce
s.
6
2a*e
volu
ntee
ring
attra
ctive
.
7
Develo
p
awar
ds
and
reco
gniti
on
fram
ewo
r*.
8
Comm
uni
cat
e
the
val
ue
of
div
ersi
ty.
9
Devel
op
pro
gra
mm
es
to
en
co
ur
ag
e
di
ve
rsi
ty.
10
&ecr
uit
an
d
en
rol
l
vo
lu
nt
e
er
s
fr
o
m
di
v
er
se
b
a
c
*
gr
o
u
n
d
s.
3an
dbo
ok on
Corpo
rate
Soci
al
Res
ponsi
bility
in India
%
"ppendi; !
Community engagement
A
commu
nity can
be
defined
as a
homoge
nous
group of
individu
als
bound
together
geograp
hically,
politicall
y,
culturall
y or by
certain
values,
principle
s or
shared
characte
ristics.
4or the
purposes
of this
discussi
on" we
define
commu
nity as
the
collectio
n of
sta*ehol
ders
who
reside in
the local
vicinity
of
compan
y
operatio
ns and
who rely
on or are
impacte
d by its
shared
resource
s.
Co
m
mu
nit
y
en
ga
ge
m
en
t
is
de
fin
ed
as
a
pr
oc
ess
in
wh
ich
the
ne
ed
s,
pri
ori
tie
s
an
d
val
ue
s
of
va
rio
us
in
di
vi
du
als
$n
ot
dir
ect
ly
ass
oci
ate
d
wi
th
or
de
pe
nd
ent
on
a
gi
ve
n
co
m
pa
ny
'
a
n
d
th
at
of
ot
h
er
e
-t
er
n
al
or
g
a
ni
sa
ti
o
n
s
in
a
c
o
m
m
u
ni
ty
are
inco
rpor
ated
into
corp
orat
e
deci
sion
6
ma*
ing
and
man
age
men
t
acti
vitie
s.
$
o
o
l
s
6

t
e
%
h
n
i
%
a
l

g
(
i
'
a
n
%
e

a
n
'

s
t
a
n
'
a
r
'
s

t
o

b
e

(
s
e
'
+
1 /a
rti
ci
pa
tor
y
rur
al
ap
pr
ais
al
2 4o
cu
s
gr
ou
p
dis
cu
ssi
on
s
3 D
oo
r6
to
6
do
or
su
rv
ey
s
Steps for
rob(st
%o**(n
it)
engage*
ent
Assess
the
lo%al
%onte&
t+
8nders
tandin
g the
charact
eristics
and
comple
-ities
of the
local
landsc
ape
and
use
this
inform
ation
for
strateg
ic
planni
ng of
comm
unity
engage
ment.
Involv
e
%o**
(nities
+
%uppor
t and
facilitat
ion of
the
process
of
commu
nity6
driven
plannin
g to
enable
comm
unities
to
define
their
own
goals"
identif
y
opport
unities
and
assets
they
plan
to
utilise
or
share,
and
priorit
ise
areas
of
potent
ial
engag
ement
with
the
compa
ny
and
other
local
develo
pment
actors.
I'entif)
an'
%ategori
se ke)
stakeho
l'ers+
Creation
of a list
of the
individu
als,
groups,
and
instituti
ons that
could
affect or
be
affected
by any
commu
nity
engage
ment
pro0ect.
)his
step
identi6
fies
and
generat
es
knowle
dge
about
individu
als and
local
organisa
tions in
order to
understa
nd their
behavio
urs,
intentio
ns,
inter6
relation
s and
interests.
Set
operati
onal
para*
eters+
%etting
up the
scope
and
target
of such
an
engage
ment in
line
with
the
activiti
es a
compa
ny will
support
.
Pro;e%
t
i*ple
*enta
tion+
Identif
ying
the
best
way to
deliver
a
pro0ect
in
view
of
severa
l
variabl
es,
such
as the
ob0ecti
ves of
comm
unity
engageme
nt, pro0ect
timefram
e, budget
and local
operating
conte-t.
Meas(re
an'
%o**(ni
%ate
res(lts+
2onitorin
g and
evaluatio
n to use
the
informati
on
collected
in future
planning
and
communi
cating
these
results to
all
sta*ehold
ers
including
the com6
munity,
the
company
and other
developm
ent
partners.
@e)
a%tivities
1
8nderta*
e
socioe
cono
mic
assess
ment.
2
2ap
local
comm
unitie
s and
netwo
r*s.
3
2ap
*e
y
in
sti
tut
io
ns
en
ga
ge
d
wi
th
lo
ca
l
co
m
m
un
iti
es
.
4
Identify
potent
ial
partne
rs.
5
Identify
ob0ect
ives
of
comm
unity
engag
ement
and
its
guidi
ng
princi
ples.
6
3nable
com
munit
y
plan
ning,
visio
ning
and
prior
itisat
ion
thro
ugh
parti
cipat
ory
meth
ods.
7
2
a
n
a
g
e

c
o
m
m
u
n
i
t
y

e
-
p
e
c
t
a
t
i
o
n
s

a
n
d

p
e
r
c
e
p
t
i
o
n
s
.

8
Identify
and
segm
ent
vario
us
target
groups.
9
8nderta*e
needs
assess
ment.
10
Develop a
baselin
e.
11
Identif
y
the
com
pan
y
and
any
shar
ed
asse
ts
avai
labl
e.
12
Identify
invest
ment
areas
and
budget
s.
13
Develop
*ey
perfor
mance
indicat
ors.
14
%elect
impl
eme
ntati
on
mod
el;
in6
hous
e or
foun
dati
on,
impl
eme
ntati
on
part
ner,
mult
i6
sta*
ehol
der
part
ners
hip,
any
othe
r
hyb
rid
mod
el.
15
,ngag
e
and
influ
enc
e
key
opin
ion
lead
ers
in
local
com
mun
ity.
16
Develop
comm
unity
forums
.
17
Invest in
capacit
y
buildin
g of
comm
unity.
18
Co6
design
detaile
d
develo
pment
pro0ect
s with
comm
unity
partici
pation.
19
7
p
er
at
io
n
al
is
e
d
e
v
e
l
o
p
m
e
n
t
p
r
o
0
e
c
t
s
a
n
d
m
a
n
a
g
e
p
r
o
0
e
c
t
c
y
c
l
e
.
20
D
o
c
u
m
e
n
t
r
e
s
u
l
t
s
o
n

*
e
y

p
e
r
f
o
r
m
a
n
c
e

i
n
d
i
c
a
t
o
r
s
.

21
Calculat
e
socia
l
retur
n on
inves
tment
s.
22
D
e
v
e
l
o
p
c
o
m
m
u
n
i
c
a
ti
o
n
s
s
t
r
a
t
e
g
y
t
o
p
e
r
i
o
d
i
c
a
l
l
y

d
i
s
s
e
m
i
n
a
t
e

i
n
f
o
r
m
a
t
i
o
n

t
o

c
o
m
m
u
n
i
t
y

a
n
d

o
t
h
e
r

s
t
a
*
e
h
o
l
d
e
r
s
.

. PwC
"ppendi; 4
CII and Credibility Alliance5s guidelines for identifying )$/ partners
1. I'entit)+ he )$/ should e6ist and be
registered under the appropriate law under
which it is governed. It should comply with
the provisions of the Act and other relevant
laws.
1 )he organisation has been functioning for
a minimum of one year from the date of
registration.
2 )he physical address given by the
organisation is verifiable.
3 )he organisation is registered as a trust or
society or %ection = company.
4 Registration certificates and documents
issued by the appropriate authority are
available upon request.
2. !ision6 ai*s6 ob;e%tives6 a%hieve*ents+
)he vision, purpose and aims of the )$/
should be e6plicitly stated and be
reflected in the activities being
underta*en.
1 A vision, purpose or mission, which drives
the organisation, is articulated beyond the
registration documents in the form of
activities and pro0ects, etc.
2 he organisation has a defined aim and
a set of ob0ectives.
3 )he organisation is able to show
performance through defined indicators
against stated ob0ectives.
3. Governan%e+ )here must be a clear
commitment towards good
governance for the )$/ to enhance its
effectiveness, serve all sta*eholders, meet
the needs of society and to ensure its
accountability towards society in
accordance with its charter of ob0ects and
purposes.
1 )he organisation has a governing
board.
2 )he organisation follows a consultative and
democratic decision6ma*ing process.
3 )here is disclosure of the details of board
members vi>, name, age, gender, position
and occupation. All family affiliations
should be indicated.
4 )he board has at least two meetings a
year suitably spaced with quorum
stipulated in its own articles of
association, reviewing the functioning of
the )$/" evaluating the pro%ects
underta*en
by them and
discussing the
way forward.
1 he
organisatio
n is not for
profit and
its resources
are
deployed
only for
accomplishi
ng the
ob0ectives
for which it
has been
formed.
2 )he
organisati
on has
attained
recognitio
n under
%ection
"A of the
Income a6
Act. -D<$ of
the Income
a6
Act is
preferable'.
3 2i
nut
es
of
boa
rd
me
etin
gs
are
doc
um
ent
ed
and
circ
ulat
ed.
4 )he
board
approves
program
mes,
budgets,
annual
activity
reports
and
audited
financial
stateme
nts.
5 )he board
ensures the
organisatio
ns
complianc
e with
applicable
laws and
statutory
regulations
.
6 All pending
legal disputes
are declared.
4. Operations+
7perations
refer to the
capacity to
conduct
programmes
and
administrativ
e activities
efficiently
and
effectively in
the public
interest. )he
)$/
should
have
norms in
respect to
the nature of
the
programme
it
underta*es,
the nature
and style of
its
management
D and the
roles and
responsibilit
ies of its
human
resources
including
personnel
and
volunteers.
1 )he activities
are in line
with the
vision, aim
and ob0ectives
of the
organisation.
2 )he
organisation periodically reviews the
progress of programmes.
3 )he accounts of the organisation are
regularly maintained and those with an
annual income above =!,!!! I9& are
audited by the chartered accountant.
4 )he roles and responsibilities are
defined for all personnel and
volunteers.
5 All personnel are issued letters of
contract and appointment.
6 An appropriate +& policy is in place.
5. A%%o(ntabilit) an' transparen%)+
Accountability and transparency are *ey
requirements of good governance and
necessary for building trust among
sta*eholders. )his wor*s as a testimony to
the fact that the organisation has been
working efficiently and effectively.
1 A financial management policy has
been developed and is adhered to.
1 %igned audited
statements are
prepared
annually and
available on
request;
balance sheet,
income and
e-penditure
statement,
receipts and
payments
account,
schedules to
these, notes on
accounts and
the statutory
auditors
report.
2 %tatem
ent of
account
s
indicati
ng
whethe
r
constru
cted on
a cash
or
accrual
basis.
3 )here are
no serious
adverse
notes on the
veracity of
the
functioning
of the
organisation
.
4 )here are no
material
transactions
involving
conflict of
interest
between a
board or staff
member
andHor
adverse
comment
and
observation
relating to
operational
issues or
financial
dealing in
the record
of public
authority.
5 )he
organisatio
ns annual
report is
distributed
and
communic
ated to
sta*eholde
rs and
others and
is made
available
upon
request
every year,
within
eight
months of
the end of
the
organisati
on5s
financial
year.
6 )he annual
report
contains a
description of
the main
activities, a
review of the
progress and
results
achieved in
the year and
information
on board
member
names,
positions,
remuneration
or
reimburseme
nt as well as
brief
financial
details.
7 he )$/
shall
disclose
their funding
details i.e.
the sources
of funds,
annual
revenue
$7I2' and
pro0ect
e-penditure.
)he
organisation
shall produce
timely
reports on the
use and
management
of funds
which should
be made
available on
request.
8 Dovetailing
with
government
schemes will
be preferred.
9 he )$/
should give
out
accurate
information
regarding
their pro0ects
i.e. survey
reports,
target
population,
location,
sustainabilit
y of the
pro0ects,
their success
ratio, etc on
request.
$he organisation
sho(l' be rea')
to submit an
affidavit by the
authorised
signator)
attesting to the
a(thenti%it) of
the infor*ation
givenA
3andbook on
Corporate Social
Responsibility in
India /
"ppendi; 0
Illustrative list of )$/s and platforms for information on )$/s prepared by CII
1. GiveIn'ia $http;HHwww.giveindia.orgH'; $iveIndia is a donation platform that allows
companies to support a cause of choice from about ;<< )$/s that have been
scrutinised for transparency and credibility.
2. !ol(ntar) A%tion et5ork In'ia $http;HHwww.vaniindia.orgH'; 1oluntary Action
9etwor* India wor*s towards building a society where voluntarism and voluntary
organisations play a dominant role in social cohesion, economic empowerment and
nation6building.
3. Charities Ai' <o(n'ation $http0GGwww.cafindia.orgG:0 CA4 India provides strategic and
management support to corporates, individuals and /%8s in order to ensure greater impact
of their philanthropic and C%& investments.
4. O&fa* In'ia $http;HHwww.o-famindia.orgH'; )he 7-fams are rights6based organisations
that fight poverty and in%ustice by linking grassroots programming -through partner
)$/s: to local" national and global advocacy and policy9making.
5. Confe'eration of !ol(ntar) Asso%iations $covanetwor*.orgH'; C71A wor*s in the areas
of communal harmony, peace and social 0ustice through sensitisation of all sections of
society and empowerment of the marginalised and the poor.
6. Partners in Change $http;HHwww.picindia.orgH'; /iC focusses on building sustainable
partnerships between the corporate sector and social development initiatives in India. /iCs
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. Cre'ibilit) Allian%e $http;HHcredibilityalliance.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. Sa*hita $http;HHsamhita.orgH'; Samhita provides a platform for )$/s to showcase
their wor* and attract donation.
9. In'ian Confe'eration of GOs $http;HHwww.icongo.inH'; iC/)$/ is a collective of
various credible" transparent and accountable )$/ members registered as
promoting members and privilege members.
10. G(i'eStar In'ia $http;HHwww.guidestarindia.orgH'; $uideStar India is India5s leading
provider of )$/ information. heir portal provides a fully searchable database of
reliable and comparable information on over C"?<< )$/s.
"bout CII
)he Confederation of Indian Industry $CII' wor*s to create and sustain an environment conducive
to the growth of industry in India, partnering industry and government ali*e through advisory
and consultative processes. CII is a non9government" not9for9profit" industry6led and
industry6managed organisation, playing a proactive role in Indias development process. 4ounded
over ""B years ago, it is Indias premier business association, with a direct membership of over
D=<< organisations from the private as well as public sectors, including %23s and 29Cs,
and an indirect membership of over A!,!!! companies from around ?!! national and regional
sectoral associations.
CII catalyses change by wor*ing closely with government on policy issues, enhancing
efficiency" competitiveness and e6panding business opportunities for industry through a
range of specialised services and global lin*ages. It also provides a platform for sectoral
consensus building and networ*ing. 3mphasis is laid on pro0ecting a positive image of
business, assisting industry to identify and e-ecute corporate citi>enship programmes.
Partnerships with over =;< )$/s
across the country carry forward
our initiatives in integrated and
inclusive development, which
include health, education, livelihood,
diversity management, s*ill
development and water, to name a
few. CII has envisaged a national
movement for mainstreaming C%&
for sustained inclusiveness as part of
its social development agenda. )he
CII 9ational Committee on
Corporate %ocial &esponsibility and
Community Development was
constituted in !!" to ma*e C%& an
actionable business agenda. )he
committee develops C%& guidelines
and promotes the sharing of C%& e-periences and best practices. CII also organises an annual
C%& summit to enable sta*eholders to review and strengthen the C%& movement. CII
development initiatives ensure the continuity of these programmes, particularly with respect to
women empowerment" industry9)$/ partnership" and persons with disabilities.
+ith F> offices" including nine Centres of ,6cellence" in India" and H overseas offices
in Australia, China, 3gypt, 4rance, %ingapore, 8E, and 8%A, as well as institutional
partnerships with ? counterpart organi>ations in A! countries, CII serves as a reference point
for Indian industry and the international business community.
Confederation of
Indian Industry
;>I9." Sector =D *dyog 'ihar" Phase
I'" $urgaon9=;;<=?" 3aryana"
India
)elephone; JA" "? ?!"?!<!6<B
.a60JI= =;> ><=><D<
3mail; 0awahar.*Kcii.in
sarbani.cha*ravartyKcii.in
PwC India
(uilding "!, )ower C, D54 Cyber City
$urgaon9=;;<<;"
+aryana, India
)elephone; A" "? ##! <!!! 4a-; J A"
"? ##! <AAA 3mail;
prashant.vi*ram.singhK in.pwc.com
sachin.shu*laKin.pwc.com
"bou
t
3&C
/wC helps
organisations
and individuals
create the value
theyre loo*ing
for. Were a
network of
firms in =?H
countries with
more than
=D>"<<<
people who
are committed
to delivering
quality in
Assurance, )a-
and Advisory
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you and find out
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In India" PwC
has offices in
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Indias service
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Hin
PwC refers to
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/lease see www.pwc.comHstructure for further
details.
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his publication does not constitute professional advice. he information in this publication has been obtained or derived from sources believed by PricewaterhouseCoopers Private
(imited -PwCP(: to be reliable but PwCP( does not represent that this information is accurate or complete. Any opinions or estimates contained in this publication represent the
%udgment of PwCP( at this time and are sub%ect to change without notice. Readers of this publication are advised to seek their own professional advice before taking any course of
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company in India having Corporate Identity )umber or CI) 0 *H>=><+!=IDCPC<CF<IC:" which is a member firm of PricewaterhouseCoopers International (imited
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