23 February 2010

Example of a CSR / Sustainability Policy

Most companies already have policy frameworks in place, with policies covering a range of business activities. Sometimes policy is developed at a micro-level determining just who can spend exactly how much, on what and when (as one example). I have also worked with companies to develop their policy frameworks and to create the set of “high level” policies under which detailed policies can be ‘attached’. My clients found this to be an effective way of creating the link between the Vission/Mission and individual and business behavior at a detailed level.

For your reading pleasure, A CSR / Sustainability Policy. Note that the ‘Interpretation’ and 'Specific Responsiblities' secions set out the responsibilities of various business units and functions at a high level, but at a level “below” the policy statement. This provides the bridge between “who we are” and “how we do it”.

The Policy Statement itself contains a three elements - Who we are, What individuals are responsible for, and what is provided to enable achievement.



Throughout our history we have sought to achieve our business objectives while at the same time acting as a good corporate citizen in all our communities, and across those elements of our supply chain that we have been able to directly influence. It is the intention of the company to continue to be a good corporate citizen. The assumptions of what good corporate citizenship entails have been evolving, and it is our intention to continue to evolve our business practices as such assumptions evolve.

Recent years have seen the growth of the concept of Corporate Social Responsibility and Sustainability. While neither of these is a new concept, the importance of these to effective business operations has been demonstrated from the perspective of enhancing business performance and the potential negative public relations impacts where a company fails to demonstrate these principles in action.

While we are proud of our heritage and confident that we embody these principles in our business practices, this policy statement has been developed to provide clear guidance in understanding our obligations and expectations. This policy statement is effective from xxx date xxxx and is applicable to all company divisions, Strategic Business Units (SBUs), and to our commercial relationships will all suppliers and customers.

Policy Statement

We are an ethical company dedicated to ensuring that we use only those resources required to achieve our legitimate business objectives, while doing what we can to conserve existing natural resources such as to ensure that there will be sufficient resources for future generations, while also contributing to our communities and the communities in which we and our suppliers and customers much live.

It is the responsibility of each employee of the company to ensure that these principles are upheld across our business operations and commercial relationships, and that each employee serves as an ambassador for the company in all our communities.

As a company dedicated to this vision, we will make available the tools and resources required to be this company, and will support each employee as they live this policy.


The Company’s Policy Manual sets out specific policies covering all HR policies. These policies have been developed to provide a foundation for each employee’s behavior and the behavior of the company. These policies must be followed at all times by all employees.

The Accounting and Finance Policy Manual sets out specific policies for the allocation and application of the financial and capitol resources of the company.

As an element of demonstration of adherence to our policy, and to communicate our achievement against our policy, we produce an annual consolidated CSR/Sustainability report, providing in that report all information required to comply with and meet the reporting spirit of the standard that we use (*for example, the Policy might be to meet the reporting requirements of both the UN Global Compact Communication on Progress elements and a GRI - Global Reporting Initiative - index, ISO26000, CDP - Carbon disclosure Project -  or another standards).

Specific Responsibilities

The Board of Directors (BoD) is responsible for approval of the CSR/Sustainability Policy, and to ensure the principles of the policy are included in the company’s strategic plan and statement of business objective. The BoD also monitors for compliance with the policy via review of regular briefings from the CEO.

The Chief Executive and Senior Management are responsible for implementation of the policy, and to ensure the business plans and projections are built taking the policy into consideration.

Risk Management is responsible for identification and communication of the risk environment related to CSR/Sustainability, including economic, social and environmental risk, and to provide guidance senior leadership and SBU leadership on country and regional risk. Risk Management also provides the systems and processes for the estimation, monitoring and reporting against regulatory mandated reporting (excluding SEC or other financial regulator reporting).

Corporate Communications develops the company’s annual CSR/Sustainability report. Corporate Communications works with Finance and the CFO’s office to ensure that all reported information has been reviewed and that assurance has been provided over such information. Corporate Communciations may seek guidance and support from other functions in determining approriate content for such reports and communication. Corporate Communications, in consultation with Senior Leadership, will determine the most appropriate standards to use for such communication.

SBU Presidents (Managing Directors) are responsible for implementation of all company policies, including all CSR/Sustainability policies. SBU leadership is also responsible for provision of accurate and timely CSR/Sustainability reports at defined levels of data granularity, as required by the Office of Sustainable Business Practices.

Commercial Managers and Contract Managers are responsible for ensuring that all corporate CSR/Sustainability policies are accepted by all suppliers, and built into all future contracts.

The Office of Sustainable Business Practices is responsible for the development of specific sustainability metrics, the compilation of reports based on information provided by SBUs, and management of the relationship with the CSR/Sustainability Assurance provider (until such time as such assurance is incorporated into annual and regulator reports).

Human Resources maintains an inventory of social programs and the resources provided by the company in support of such programs.

Supporting Materials

The Operational Policies Manual for each SBU and Corporate include specific CSR/Sustainability metrics and standards.

Budgeting and Performance reporting templates have been (or will be) updated to identify additional budget estimates and reporting required to achieve CSR/Sustainability mandates.

Supporting Unit

Any questions regarding this policy should be directed to the Office of the Corporate Council, or to your local Risk Management or General Council’s office. Consult your local director for contact details.

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