Developing Company Policy – an Overview Process

A CSR/Sustainability Policy does not exist in a void; it should exist as part of a fully integrated Policy Framework within a company.

This discussion follows from (or leads to, actually) the example CSR/Sustainability Policy Statement that I provided yesterday, and introduces Policy (and the Policy Framework). This is only an introduction, there's lots more, and feel free to contact me for more information on the topic of development, introduction, monitoring and updating of policy, defining responsibilities for Policy, and delegations of authority to develop, approve, introduce or alter policy.

Development of policy should be done in consultation with, and obtained agreement with representatives of Risk Management, Information Services/Technology, Human Resources, Communications and Finance among others. Senior management should review and approve the policy framework and high-level policies for submission to the Board of Directors for approval.

What is Policy

Each company’s Policy (formal and documented or informal) reflects its own culture. Fundamentally, Policy provides the guidance and boundaries for all managers and staff to enable achievement of company objectives. Policy can be a high level set of goals or objectives, or a set of directives and mandatory performance or behavioural requirements.

Policy should include objectives, responsibilities, and accountabilities and should include an identification of the owner of the policy. They should be clearly determined, setting the tone, values and governance of the company. Each policy should also include a statement of principle or prescribed general (rather than detailed) course of action, with application appropriate to the level of the policy.

What does Policy do?

• Policy provides the boundaries within which employees achieve the strategic direction of the company, as set by the Board and the Senior Management Team.
• Policy contributes to the setting of accountabilities for specific tasks in the organisation, and provides guidance to managers and staff as to how to achieve the strategic direction. Policy helps to drive behaviour.
• Policy provides cohesion and congruence to the various parts of the company, ensuring that all parts are moving in the same direction.
• Policy provides focus to address areas which are either of importance to the achievement of the company’s strategic objectives, or matters which are of considerable risk to the business.

CSR / Sustainability Policy

With that quick overview, lets return to the example CSR/Sustainability Policy statement. In that Policy, there is clear definition of ownership and responsibility, without attempting to define day to day functions of individuals. Think about the Policy Statement itself. It lays out "who we are, what each of us is responsible for doing, and what the company provides to enable us to meet our obligation".

The rest of the example policy provides context and is designed to help individuals in interpreting their responsibilities, and in providing guidance and direction, and importantly who or where to go when in any doubt.

CSR/Sustainability is not the responsibility of the CSR department, marketing or any other area. It is not the responsibility of a CSR coordinator or director of sustainability. It is part of the fabric of the company, and as such, needs to be integrated into the overall Policy Framework of the company.