How to Build a CSR Policy and Annual Action Plan
What a CSR policy must contain under the 2021 rules, how to draft an annual action plan, and how to turn both into a focused strategy.
Every company covered by Section 135 needs a CSR policy, and its CSR committee must recommend an annual action plan to the board. Many companies treat these as formalities. Used well, they are the backbone of an effective CSR strategy.
What the CSR policy should cover
- The company's CSR vision and priority themes.
- Preferred geographies, including local areas of operation.
- How projects are selected, approved and implemented.
- Monitoring and impact assessment approach.
- Governance: roles of the board, the CSR committee and management.
What the annual action plan must include
Under the CSR Rules, the annual action plan should list:
- the projects or programmes to be undertaken, within Schedule VII;
- how they will be executed, directly or through implementing agencies;
- how funds will be used and on what schedule;
- monitoring and reporting mechanisms;
- details of any impact assessment needed; and
- whether any project is an "ongoing project".
From compliance to strategy
Focus
Companies that spread small amounts across many causes rarely achieve visible impact. Choosing one to three themes and building depth works better.
Geography
Look beyond headquarters. Underserved districts offer far greater impact per rupee. In Bihar, CSR per resident is about ₹25, against a national average of about ₹223.
Multi-year thinking
Use ongoing projects to commit for three years, so that programmes have time to show results.
Evidence
Build baselines and outcome indicators into the plan from the start.
Orvys helps CSR committees draft policies and action plans grounded in district-level data. Contact us.
