Initiative to make CSR more inclusive

Dear SRRF Dialogue members

As by now most of you would be aware that Companies Bill 2012 has been passed by both the Houses of Parliament and after getting President approval and after being notified would become law. As mentioned during the recent RoundTable as well as in the Study published by SRRF, one of the problem is that the Act permits CSR activities in a very restrictive way. It has identified only 8 categories where one CSR activities can be undertaken. These are:

  • Eradication of extreme hunger and poverty
  • Education
  • Gender Equality and Women Empowerment
  • Child Mortality and Maternal Health
  • HIV/AIDS, Malaria and other diseases
  • Environment Sustainability
  • Employment enhancing vocational skills, and
  • Social Business Projects

We believe that above activities do not cover a large number of activities (disabilities, water & sanitation, human rights, to name just a few which immediately come to mind). Infact the whole approach would have been better had the Act taken an approach of identifying activities which cannot be undertaken. Now we will always struggle and this would create avoidable lobbies for including activities in the CSR list. Now that the Bill has already been passed by the parliament very little can be done in terms of legislative change, however rules are yet to be framed, perhaps we need to identify how rules can be made in a manner that would cover a large number of activities. SRRF is taking the initiative in this regard and would invite suggestions from its SRRF Dialogue members on how best it considers the changes can be brought in the Rules to cover a wider range of activities.

Looking forward to your active participation.

warm rgds

Subhash Mittal
(Secretary, SRRF)

Socio Research & Reform Foundation
(A Non Government Organisation)
512 A, Deepshikha, 8 Rajendra Place, New Delhi – 110008
e-mail:; website:

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11 Responses to Initiative to make CSR more inclusive

  1. smittal says:

    Dear SRRF Dialogue Members,

    I am sharing a document with you comprising comments on Draft rules. Please go through the same and provide your comments at the earliest. So as to reach us by Monday morning. We would be submitting these latest by Monday afternoon, after considering your comments.

    I do apologise for rather short notice, but for various reasons it could not be finalised till now.

    warm rgds
    Socio Research Reform Foundation (NGO)
    512 A, Deepshikha Building,
    8 Rajendra Place, New Delhi – 110008.

    • rkdevar says:

      Dear friends,

      Just a couple of observations.

      1) need for CSR actions to be long-term and impact oriented.
      2) focus on the backward regions based on HDI figures.
      3) all CSR projects initiated by the corporate shall be prominently displayed in the public sphere with full details of execution.
      4) in the change suggested under 1 (c) best to eliminate the term CSR. Let it just read “any project carried out towards meeting statutory obligations shall not be deemed as a CSR activity”



    • Akshay Singh says:

      Dear Mr. Mittal,

      I attended the CII-CSR summit where Sachin Pilot and the Mr. Joseph, the IAS officer incharge also spoke. They are very open to suggestions.

      This comment may be a little late but have 2 quick comments:

      1. The categories defined in the CSR bill should include ‘Housing & Shelter’
      2. Capacity building of the non-profit sector should also be included as a CSR activity. Since measurement and accountability is being strengthened it is very important for quality resource development.


      Akshay Singh
      Head – Corporate Fundraising, Fund Development & Communications

    • N K Gupta says:

      Mr Maurya

      06th feb 1978, what late jrd said :

      we must not forget to give back to society.

      it is csr only now. no statute can enforce it. yes,
      applicability can be implemented but not from the
      core of heart. it has to be voluntary offer, but not

      i contribute my mite to the differently abled society
      since that time. i get my soul to be cool.

      wish i was at the csr conclave addressed by sachin n

  2. Amitabh Singhal says:

    I am attaching a copy of the Planning Commission’s policy document on Civil Voluntary Organizations (National Policy on the Voluntary Sector). Two interesting things of note are the ‘inclusions’ of who are VO’s. Strictly speaking, it does not seem to cover CSR divisions of business entities, but secondly they do perform most or all of the activities that listed in the “scope” mentioned in clause 2.1.

    My suggestion is that since this is a central policy document, the shortcoming in the legislation can be overcome if the rules and regulations get closely aligned to the CVO scope and mandate.
    IMHO, this could be a way to overcome the limited mandate in the Companies Bill 2012.

    Amitabh Singhal
    Telxess Consulting Services (Pvt) Ltd
    C-73, Upkar Apartments
    Mayur Vihar Phase – I, Extn
    Delhi – 110091
    Board Director – .ORG, The Public Interest Registry
    Founder, Former President – ISP Association of India
    Founder, Member of Board & Former CEO – National Internet Exchange of India
    Non Executive Director – Virtuosos Solution (P) Ltd.
    Member, Governing Body – Digital Empowerment Foundation
    Member, Working Group on Internet Prolifieration and Governance, Department of Information Technology

    • Subhash Mittal says:

      Thank you Amitabh for bringing in context of the Voluntary Sector policy. It is a good suggestion.

  3. Kaithang says:

    As discussed, CSR of corporates can move beyond their respective domains. There are plenty of opportunities for CSR to be deployed like alternative livelihood for traditional jhoom cultivators in Northeastern India. Such ventures will bring about great benefits in the long run.

  4. Satyadeo Bareth says:

    The last line of Asif\’s observation is conclusive and most important. I am also of this opinion that a CSR regulatory body, may be in the form of a trust be created so as to ensure that the CSR is utilized appropriately wseithout any limitations as mentioned by Mr. Asif in his initial two paras. The very purpose of CSR is not to serve the limited interests of the concerned corporate house but to serve the people outside its arena.

  5. Asif Zaidi says:

    Dear Mr Mittal

    I think there are many other issues that require clarity while framing the rules.I understand there are three ambit of area of interventions adopted by present CSR activities.

    1. Large number of corporate prefer to take up CSR activities within their own fence or in the campus of production units for many a time for their own employees only. Many a times symbolic in nature and where a few political allies, Pradhan and sarpanch, local government admin officials and some outsiders are invited. Such events are largely aimed to maintain relations with political and administrative authorities. The investments are meager but claims of impacts normally arbitrarily high.
    2. There are other set of companies who go a little beyond their campus, may be a few Kms outside the fence. But in most of such cases the scope is very limited, because most of the larger companies are located in industrial areas and there are many such units. Therefore there is lot of over lapping of villages and interventions also such areas any way have higher priority of government agencies also therefore a very little scope left for CSR interventions.
    3. The third and the most important area of intervention is beyond the fence, 40-100 km away or may be far from the production units or in the interior places. Only a few corporate with enlightened outlook like to intervene in this area.

    The other concern is grabbing of CSR funds by some agencies. I understand that there is a CII Hub to grab the CSR funds. My apprehension is that being associated with Corporates they might take away the larger chunk of CSR funds and might not be able to do much in the field since they have no grassroots experience. CII for instance has already started mobilising funds in many places and started their own implementation wings. If they do it sincerely and transparently then there is no issue. I feel there is a need to have an NGO forum, may be a separate trust which could interact with corporates and selected NGOs and facilitate partnerships.

    With regards,

  6. Satyannarayan Samdani says:

    CSR actvities must include the programmes relating to heritage conservation,Culture,Promotion of Folk Culture & social patronage to the folk artists who have been always neglected by the Govt.since independence. I agree with the idea or suggestion that only a negative list be declared so that a vast field can emerge for CSR activities.I am of the opinion that at the micro level a Committee under the chairmanship of the Deistrict Collector may be constituted in which representatives of Corporates,Local bidies and eminent citizens from the fields of Social Activities,Art,Culture,Heritage etc. may be nominated as members for preparing an action plan for the proper use of CSR funds and its monitoring.

  7. Pramod says:

    Thanks for your valuable infomation.

    Seva Bharati

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