Friday, 5 September 2014

Mandatory Corporate Social Responsibility under Companies Act, 2013


The Ministry of Corporate Affairs had introduced Corporate Social Responsibility Voluntary Guidelines in 2009. Mandatory corporate social responsibility has now been incorporated in the Companies Act, 2013.
Every company having a net worth of rupees five hundred crore or more, or turnover of rupees one thousand crore or more or net profit of rupees five crore or more during any financial year.[1]
Every company to which this provision becomes applicable shall constitute a committee of the board of the company consisting of three or more directors, of which at least one shall be an independent director.[2] An unlisted public company or a private company which is not required to appoint an independent director under the provisions of the Companies Act shall have its CSR Committee without such director.[3] A private company having only two directors on its board shall constitute its CSR Committee with two such directors.[4] The board shall disclose the composition of the CSR Committee in its report under Section 134(3) of the Companies Act.[5]  
The CSR Committee shall:[6]  
·         Formulate and recommend to the board, a corporate social responsibility policy which shall indicate the activities to be undertaken by the company as specified in Schedule VII. 
·         Recommend the amount of expenditure to be incurred on the activities referred to above.
·         Monitor the CSR Policy of the company from time to time.
The board of every company shall[7] (a) after taking into account the recommendations of the CSR Committee, approve the CSR Policy and disclose the contents of the CSR Policy in its report and also place it on the company’s website[8], if any. (b) ensure that the activities as are included in the CSR Policy are undertaken by the company.   
The board’s report of a company to which these CSR provisions apply, shall include an annual report on CSR containing particulars specified in the Annexure to the Companies (Corporate Social Responsibility Policy) Rules, 2014.[9]  Annexure to the CSR Rules has given the format for the annual report on CSR initiatives to be included in the board report and includes inter alia a brief outline of the CSR Policy, web-link to the CSR Policy, composition of the CSR Committee, average net profit of the company for last three financial years, threshold limit (2% of the average net profit of the last three financial years), details of CSR activities/projects undertaken, reasons for not spending the amount if the company has failed to spend 2% of the average net profit of the last three financial years and a responsibility statement of the CSR Committee that the CSR Policy implementation and monitoring thereof is in compliance in letter and spirit with the CSR objectives. 
The board of every company must ensure that the company spends, in every financial year, at least two per cent of the average net profits of the company made during the three immediately preceding years.[10] The company shall give preference to the local area and areas around it where it operates, for spending the amount earmarked for CSR activities.[11] If the company fails to spend such amount, the board shall in its report under clause (o) of Section 134(3), specify the reasons for not spending such amount.[12] 
Schedule VII of the Companies Act has provided an indicative list of the activities which may be included in the company’s CSR Policy. The list provides for activities relating to:
o   Eradicating extreme hunger and poverty;
o   Promotion of education;
o   Promoting gender equality and empowering women;
o   Reducing child motility and improving maternal health;
o   Combating human immunodeficiency virus, acquired immune deficiency syndrome, malaria and other diseases;
o   Ensuring environmental sustainability;
o   Employment enhancing vocational skills;
o   Social business projects;
o   Contribution to the Prime Minister's National Relief Fund or any other fund set up by the Central Government or the State Governments for socio-economic development and relief and funds for the welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women; and
o   Such other matters as may be prescribed.

                        



[1] Section 135(1) of the Companies Act
[2] Section 135(1) of the Companies Act
[3] Rule 5(1)(i) of the CSR Rules
[4] Rule 5(1)(ii) of the CSR Rules
[5] Section 134(3) of the Companies Act provides for the statements laid before a company in general meeting by the board of directors.
[6] Section 135(3) of the Companies Act
[7] Section 135(4) of the Companies Act
[8] Rule 9 of the CSR Rules
[9] Rule 8 of the CSR Rules
[10] Section 135(5) of the Companies Act
[11] First proviso to Section 135(5) of the Companies Act
[12] Second proviso to Section 135(5) of the Companies Act

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