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Learn how to draft a Corporate Social Responsibility (CSR) policy that aligns with the Companies Act, 2013. So, if you are a start-up owner looking to frame a CSR Policy from scratch or a company looking to revamp your CSR policy, this practical guide has got you covered.

Introduction

Did you know that 83% of employees would consider leaving their jobs if their company fails to uphold social responsibility values? 

Or that 78% of investors consider CSR reports a key factor when evaluating companies.  

These are not just statistics for legal professionals—they highlight why businesses need strong CSR policies.

But why? What makes CSR so crucial? On the surface, it sounds like socialist propaganda against a capitalist economy. 

Let’s take a step back and understand. 

Consider the platforms that we use daily— Google, for example, where every search is free. Or the fintech apps like Paytm, GPay, and PhonePe, which allow payments without fees. If everything is free, how do these companies make money? And who’s paying for it?

After some research, I discovered these “free” apps aren’t free at all. Users pay in ways that aren’t immediately visible. While using these apps/platforms, we hand over our data—preferences, habits etc. This data fuels billion-dollar advertising machines that shape our beliefs and purchases. It’s the long game. 

Now, these “free” apps also rely on massive data centres consuming enormous amounts of electricity and water, creating an environmental footprint that rarely enters legal discussions about corporate obligations.

This is one of the many reasons why some social responsibilities have been mandated upon companies. 

But not all companies need to carry out CSR. There is a threshold– as you go further in the article, you will learn more about it. 

So what does it mean for you as a lawyer? Opportunities. 

In 2023-2024 alone, 24,392 Indian companies invested approximately ₹29,987 crore in 51,966 CSR projects. 

This represents countless legal documents, compliance requirements, and advisory opportunities for lawyers, consultants, and legal professionals.

Whether you’re advising startups or helping established corporations optimize their CSR strategies, understanding how to draft effective CSR policies is becoming an indispensable skill in corporate law practice. 

This article offers practical guidance for legal professionals on crafting CSR policies that not only ensure compliance but also help clients achieve strategic business advantages through thoughtful social impact.

A look at the regulatory regime

I cannot discuss CSR without mentioning section 135 of the Act and the Companies (Corporate Social Responsibility Policy) Rules, 2014. These laws dictate how companies should undertake CSR initiatives.

Let me just give you a quick look at the language used in section 135 in the text box below: 

Some of you might find the language of the bare act difficult to understand. That’s why I’m breaking down the provision into simpler parts to make it easier to grasp.

Here are the key points about CSR that you must know before preparing a CSR policy for a company:

Applicability:

When I first learned about CSR, I assumed that every company needed a CSR policy. But after reading section 135 of the Act, I realised that’s not the case. CSR obligations only apply if a company meets any of these thresholds in a financial year:

• net worth of ₹500 crore or more, or
• turnover of ₹1000 crore or more, or
• net profit of ₹5 crore or more​.

Tell your client that they are not legally required to have a CSR policy under the Act if they do not meet the specified thresholds.

CSR Committee:

I am assuming that the company you are advising meets the CSR threshold. This means that your company must set up a CSR committee at the Board of Directors (the Board) level. As per section 135, the committee needs at least three directors, including one independent director.

But what if you’re advising a private company that doesn’t need an independent director? In that case, a CSR Committee can be formed with just two or more directors.

If you are wondering, what exactly does this committee do? 

Well, its primary task is to draft and recommend a CSR policy to the Board and lay out how the company will fulfill its social responsibility (Section 135). 

CSR expenditure:

Now that the company has a committee in place, how much money should it spend on CSR activities? Well, as per section 135 of the Act, the company must allocate at least 2% of its average net profits from the last three financial years toward CSR activities.

But what happens if the company does not spend the required amount? 

The Board can’t just ignore it. As per section 135, they must explain the reasons in the Board report.

CSR policy disclosure:

I will not take names here, but I remember a company that had a CSR policy published on their website but failed to take measures in furtherance of the Policy. Later, the said company was penalised by the RoC for non-compliance. 

So, once you have drafted the CSR policy for a company, make sure to get it signed and approved by the Board. Thereafter, the Board is required to disclose the CSR Policy in its Board report and on its website (if the company has one).

Remember that disclosure is not enough. The Board must ensure that the CSR activities mentioned in the policy are actually carried out. 

In short, you cannot just have a policy on paper, you have to make sure that it translates into real action.

If a company fails to meet its CSR spending obligations, it faces significant financial penalties and accountability measures under section 135 (7). Here are the penalties: –

• For the Company: Twice the unspent amount or one crore rupees, whichever is less
• Defaulting officers: One-tenth of the unspent amount or two lakh rupees, whichever is less

Permitted CSR activities (Schedule VII of the Companies Act 2013):

This one is strictly the law and needs no explanation. For the purpose of CSR, companies are only permitted to undertake the following activities related to:

• eradicating hunger, poverty, and malnutrition;
• promoting education and gender equality;
• environmental sustainability;
• employment-enhancing vocational skills;
• contributions to government relief funds;
• social business projects;
• other welfare initiatives.

Activities that do not count as CSR:

If an activity does not directly benefit society, it should not be counted as CSR. In fact, the Companies Act specifically excludes certain activities from being recognised as CSR, such as: 

• employee welfare programs.
• political contributions.
• marketing disguised as CSR (e.g., sponsorships).

Local area preference:

Companies should prioritise CSR spending in local areas where they operate​. 

For instance, if a startup is operating in a rural area, it should commit to spending CSR funds in areas that could result in the overall development of the rural area. It could be anything from planting trees to repairing street lights.

Benefits of CSR

At first, I thought CSR was just another word for charity. I couldn’t be more wrong. It was not until I was drafting my first CSR policy that a law firm partner told me, “Companies use CSR as a business strategy—it drives growth, sparks innovation, and ensures long-term success.”

That completely changed the way I looked at it.

You might not know, but companies that integrate CSR into their core operations gain trust, reduce risks, and create a lasting competitive edge. Let me walk you through five benefits of a good CSR policy that can leave a positive impact on society and the company: 

• Stronger brand image & customer loyalty: People support brands that care about society and the environment.
• Attract top talent: Young professionals want to work for companies that make a difference.
• Better investor & government support: Ethical businesses get more investments and smoother government approvals.
• Cost savings through sustainability: Energy-efficient and eco-friendly practices reduce expenses.
• Competitive edge in the market: CSR sets companies apart, making them more attractive to customers 

Tracking the CSR strategy of NexaTech 

I think it’s the perfect time to walk you through how to draft a CSR policy. But before I do that, I want you to see CSR not just as a legal requirement but as a strategic tool that can actually drive business growth. 

Let’s first understand how a well-designed CSR policy can benefit a company beyond just compliance. I’m about to share a business strategy used by a startup that gained significantly from its CSR initiatives. 

However, for confidentiality, I’ll be changing the names and certain details. For this example, let’s call the startup NexaTech and take a closer look at how it leveraged CSR to drive growth.

Meet NexaTech, a Bengaluru-based AI-driven fintech startup with a vision to revolutionise financial technology. The company scaled its business in less than 2 years and was able to cross the ₹5 crore net profit mark, triggering a mandatory CSR obligation under section 135 of the Act.

At first, CSR seemed like another regulatory burden to the directors of NexaTech. All they could see was a 2% net profit deduction that had to be spent on government-approved social projects. 

However, as NexaTech’s legal advisor, I saw an opportunity and explained to the Board of Directors that CSR can be more than just an expense. It could actually strengthen the business while creating a meaningful impact.

The challenge: How to make CSR work for NexaTech

I advised NexaTech that most companies follow a standard CSR approach, i.e., donate money to an NGO or support generic social initiatives. While this checks the compliance box, it doesn’t necessarily add strategic value to the business.

So, I advised the CEO, Mr. Arnav Mehta, that:

• We should use CSR to build a stronger brand and attract socially conscious investors.
• CSR could help NexaTech hire top talent who want to work for purpose-driven companies.
• NexaTech can make CSR a long-term business strategy rather than just a legal requirement

Acting upon my advice, NexaTech formed a CSR Committee to explore options. Instead of outsourcing CSR to an NGO, it was decided that NexaTech should leverage its expertise in financial technology to create something impactful.

The strategy: Project “Future Ready”

The committee, including me, sat down for a very long meeting. At the end of the meeting, it was decided that NexaTech is going to support a rural village in Karnataka where:

• The government school lacked digital infrastructure.
• Teachers had no training in technology, making modern education impossible.
• students had never used a computer or the internet, leaving them disconnected from digital finance and career opportunities.

You must be thinking how addressing these issues will help NexaTech achieve its long-term goals or gain the benefits of CSR.

Well, during the committee meeting, we recognised that digital illiteracy in rural villages meant fewer people would be able to use fintech services in the future. If NexaTech could help bridge this gap, we wouldn’t just be fulfilling CSR obligations but would be building a more informed user base for the industry.

We named the project “Future Ready”. 

So, instead of donating money, NexaTech decided to implement the CSR project directly. With a ₹2 crore budget, NexaTech committed to:

• Setting up a fully functional digital lab with computers, internet access, and smart boards.
• Training teachers in digital education with free certification programs.
• Developing coding and financial literacy modules for students, aligning with NexaTech’s fintech expertise.
• Monitoring the impact with quarterly assessments and student performance reports.

The business impact: How CSR became a strategic asset

Within a year of the implementation of the CSR policy by NexaTech, the village school saw remarkable progress:

• Over 500 students gained digital literacy, with more than 100 learning basic coding.
• Teachers integrated technology into their lessons, improving engagement and results.
• Students participated in an inter-district coding competition, something unimaginable a year before.
• The Karnataka government recognized NexaTech’s initiative, leading to media coverage and increased interest from other companies.

But beyond the social impact, CSR became a business advantage for NexaTech. Let me show you how:

• Stronger brand reputation: The company’s CSR work gained visibility, positioning them as a socially responsible fintech leader in that rural village.
• Better talent acquisition: Job applicants began citing NexaTech’s CSR initiatives as a reason for wanting to work there.
• Increased investor interest: Investors saw CSR as proof of NexaTech’s long-term sustainability.
• Improved government relations: By aligning CSR with digital education, NexaTech built stronger relationships with the Local Government of Karnataka.

Preparing CSR policy for NexaTech

Now that you know the strategy deployed by NexaTech, let’s just prepare a CSR policy that reflects what was done by NexaTech:  

Corporate Social Responsibility Policy

Introduction

I included this section to help companies understand that CSR isn’t just about checking a legal box. Many businesses view it as a burden, but framing it as an opportunity to create value helps the Board see beyond the 2% spending requirement. 

When clients understand the “why” behind CSR, they’re more likely to implement meaningful programs rather than just doing the minimum.

Draft sample: 

“At NexaTech Private Limited, we recognize that businesses have responsibilities beyond profits. Our Corporate Social Responsibility (CSR) policy is designed to make a meaningful impact on society while ensuring compliance with Section 135 of the Companies Act, 2013, and the Companies (Corporate Social Responsibility Policy) Rules, 2014. Through this policy, we aim to create sustainable value for our stakeholders by promoting digital education and providing employment-enhancing vocational skills.”

Purpose and commitment

Here, I’m spelling out exactly what NexaTech is committing to do. 

Their “Future Ready” project is perfect for them because it leverages their tech background while making a real difference. 

I made sure to highlight how they are using their fintech expertise rather than just throwing money at generic causes.

Draft sample:

At NexaTech Private Limited, CSR is an opportunity to create a lasting impact while strengthening our business. Our key commitments include:

• Bridging the digital divide: Launching the Project “Future Ready” to enhance digital literacy in rural Karnataka, with a target of reaching 2,000 students across 10 schools by 2026.
• Building digital infrastructure: Set up digital labs in government schools, giving students access to technology, with a commitment to install at least 5 fully-equipped computer labs annually.
• Empowering teachers & students: Train a minimum of 50 teachers per year in digital education and introduce coding & financial literacy for students, with a goal of 80% proficiency achievement.
• Driving sustainable impact: Execute CSR in-house to align with NexaTech’s fintech expertise, ensuring long-term benefits through programs designed to be self-sustaining within 3 years of implementation.

Applicability

I included this section because there’s a lot of confusion about which companies need to follow CSR rules. Many startups think they need CSR policies from day one, while others do not realise they have already crossed the threshold. 

This section clearly spells out when the requirements kick in, helping companies understand exactly when compliance becomes mandatory. Clients ask it a common question, so clearly stating it prevents confusion.

Draft sample:

This policy applies to NexaTech Private Limited and its subsidiaries that meet any of the following criteria in a financial year:

• net worth of ₹500 crore or more, or
• turnover of ₹1,000 crore or more, or
• net profit of ₹5 crore or more.

Since NexaTech has crossed the ₹5 crore net profit threshold, the company is obligated to implement CSR activities as per section 135 of the Companies Act, 2013.

CSR governance structure

This section is crucial because proper oversight makes the difference between effective CSR and mere charity. 

The law requires a formal committee structure, but beyond compliance, good governance ensures that CSR efforts are strategic and well-implemented. 

I’ve seen companies get into trouble for not having clear accountability at the Board level. This structure creates clear lines of responsibility and ensures CSR gets the senior-level attention it deserves.

Draft sample:

4.1 CSR committee

A dedicated CSR Committee, constituted by the Board of Directors, will oversee the implementation of this policy. The committee will include at least three directors, including one independent director.

The committee will meet quarterly, with minutes of each meeting documented and reported to the Board.

4.2 Roles & Responsibilities

The CSR Committee is responsible for:

• Developing and recommending CSR strategies and policies.
• Identifying priority areas for CSR activities.
• Allocating budgets and monitoring CSR spending.
• Ensuring transparent reporting and compliance with legal requirements.
• Conducting quarterly reviews of project progress against established KPIs.
• Approving any budget reallocations exceeding 10% of the original allocations.
• Recommending corrective actions when projects fail to meet established metrics.

Focus areas for CSR initiatives

I added this section with specific budget allocations because too many companies try to spread their CSR budget too thin across too many activities. 

It’s better to make a meaningful impact in a few areas than a negligible difference in many. 

The percentage breakdowns help prevent last-minute debates about where to allocate funds. Plus, having clear targets for each area makes it easier to measure success and report concrete outcomes, which is what regulators really want to see.

Draft sample:

NexaTech Private Limited shall prioritize the following CSR activities in accordance with Schedule VII of the Companies Act, 2013:

5.1 Digital & financial literacy (40% of annual CSR budget)

• Establishing digital learning centres and financial education programs in rural areas.
• Target: Increase digital literacy rates by 50% in participating communities within 2 years.
• KPI: Number of students certified in basic computer skills and financial literacy.

5.2 Education & skill development (25% of annual CSR budget)

• Scholarships, vocational training, and teacher training programs.
• Target: Train 200 youth annually in employment-ready digital skills.
• KPI: Employment placement rate of program graduates.

5.3 Environmental responsibility (15% of annual CSR budget)

• Initiatives for e-waste management, carbon neutrality, and sustainable fintech solutions.
• Target: Collect and responsibly recycle 5 tons of e-waste annually.
• KPI: Volume of e-waste collected and processed; reduction in carbon footprint.

5.4 Health & well-being (10% of annual CSR budget)

• Mental health awareness programs, medical camps, and healthcare access initiatives.
• Target: Conduct health awareness programs reaching 1,000 individuals annually.
• KPI: Number of beneficiaries, improvement in health-seeking behaviours.

5.5 Women & youth empowerment (5% of annual CSR budget)

• Promoting women in tech and supporting entrepreneurial ventures.
• Target: Support 50 women entrepreneurs in technology annually.
• KPI: Number of women-led tech startups established and sustained.

5.6 Rural development (5% of annual CSR budget)

• Infrastructure projects, water conservation, and sanitation programs.
• Target: Implement water conservation projects in 5 villages annually.
• KPI: Increase in water accessibility and reduction in water-related diseases.

CSR initiative- Project “Future Ready”

I included a detailed flagship initiative here to show what good implementation looks like. 

Too many policies stop at general intentions without explaining how they will actually be carried out. 

This section provides a concrete example with timelines, components, and success metrics. It also demonstrates how NexaTech can use its core expertise (technology) to create meaningful social impact, making the CSR effort more authentic and sustainable than just writing cheques to unrelated causes.

Draft sample:

Recognizing the digital divide in rural areas, NexaTech launched Project “Future Ready”, a flagship CSR program aimed at bridging this gap. The project includes:

6.1 Implementation timeline

• Q1 (April- June 2025): Assessment and selection of 3 schools; baseline surveys of digital literacy.
• Q2 (July- September 2025): Infrastructure setup and teacher training for the first batch.
• Q3 (October- December 2025): Curriculum implementation and mid-term evaluation.
• Q4 (January- March 2026): Expansion to 2 additional schools; annual impact assessment.

6.2 Key components and metrics

• Digital infrastructure:

• Setting up fully functional digital labs with computers, internet access, and smart boards in government schools.
• Metric: 100% uptime of lab equipment; 1:5 computer-to-student ratio.
• Teacher training:

• Training teachers in digital education through free certification programs.
• Metric: 90% of teachers achieve certification; 75% integration of digital tools into regular curriculum.
• Student curriculum:

• Developing coding and financial literacy modules for students.
• Metric: 70% of students demonstrate proficiency in basic coding; 80% show improved financial literacy scores.
• Impact monitoring:

• Quarterly assessments through standardized tests and surveys.
• Student performance tracking through digital portfolios and project-based evaluations.
• Metric: 40% improvement in digital skills year-over-year; 30% increase in school attendance.

Execution and partnerships

This section is essential because implementation can make or break a CSR program. 

The CSR Rule changes placed stricter requirements on which organizations companies can partner with.

I included clear partnership criteria to help avoid working with organisations that are not properly registered, which can create compliance problems later. 

The community engagement framework also ensures that projects reflect actual community needs rather than just what the company thinks is best.

Draft sample:

To ensure effective implementation, NexaTech will adopt a flexible approach to executing CSR initiatives. These initiatives may be carried out in the following ways:

7.1 Implementation models

• Direct implementation by NexaTech (preferred for core technology initiatives).
• Through registered NGOs, trusts, and government-recognized institutions (for specialized aspects).
• Collaborative projects with other businesses where objectives align.

7.2 Partnership selection criteria

• Partners must have a minimum 3-year track record in relevant domains.
• Financial transparency with publicly available annual reports.
• Demonstrated expertise in the specific focus area.
• Ability to provide monthly progress reports and participate in quarterly reviews.

7.3 Community engagement framework

• Local Community Advisory Committees for each project location.
• Quarterly public consultation meetings with beneficiary communities.
• Annual stakeholder survey to gather feedback and suggestions.
• Formal mechanism to incorporate community feedback into program design.

CSR funding and expenditure

I included detailed funding guidelines because money management is where many CSR programs run into trouble. The 2% requirement is well-known, but companies often scramble at year-end to meet it. 

The 2021 amendments also changed how unspent funds must be handled—they now must be transferred to specific government funds, not just explained in a report. 

The contingency reserve and quarterly disbursement schedule help avoid last-minute spending that often leads to poor outcomes.

Draft sample:

A well-defined budget is essential for driving impactful CSR initiatives. NexaTech commits to the following financial guidelines:

8.1 Budget allocation

• NexaTech Private Limited shall allocate at least 2% of its average net profits of the last three financial years to CSR initiatives.
• Budget allocation across focus areas is detailed in Section 5.
• 5% contingency reserve for emergency interventions or unexpected challenges.

8.2 Fund management

• Quarterly disbursement schedule aligned with project milestones.
• Any budget reallocation exceeding 10% requires CSR Committee approval.
• Unspent funds shall be transferred to a government-designated CSR fund, as per legal requirements.

8.3 Prohibited expenditures

• Funds shall not be used for business promotion or any activity excluded under CSR rules.
• No allocation for activities limited exclusively to NexaTech employees or families.
• No political contributions or religious activities.

Monitoring, evaluation, and reporting

This section addresses a common weakness in CSR implementation: lack of proper impact assessment. Companies often implement programs but fail to measure whether they’re actually making a difference. 

The monitoring framework creates accountability and helps identify what’s working and what isn’t. Regular reporting also satisfies disclosure requirements and builds trust with stakeholders. The third-party evaluations add credibility that internal assessments alone can’t provide.

Draft sample:

To ensure transparency and effectiveness, CSR activities will be regularly monitored and evaluated. NexaTech will follow these key measures:

9.1 Monitoring framework

• Monthly progress reports from implementation teams.
• Quarterly site visits by CSR Committee representatives.
• Real-time digital tracking dashboard for key performance indicators.
• Third-party assessment at mid-year and year-end points.

9.2 Evaluation methodology

• Baseline and endline surveys for each project.
• Control group comparisons where feasible.
• Both quantitative metrics and qualitative assessments.
• Annual third-party impact evaluation for projects exceeding ₹50 lakhs.

9.3 Reporting protocol

• Monthly internal progress reports to management.
• Quarterly updates to the Board of Directors.
• Annual CSR reports included in the Company’s Annual Report.
• CSR activities and financials disclosed on the Company’s website, with quarterly updates.
• Publication of annual impact assessment reports accessible to all stakeholders.

9.4 Escalation procedure

• Project managers empowered to make decisions within 5% of budget allocation.
• Issues requiring additional resources should be escalated to the CSR Head within 48 hours.
• Critical challenges requiring policy exceptions brought to CSR Committee within one week.
• Standardized issue documentation and resolution tracking system.

Activities not considered CSR

I included this section because there is a lot of confusion about what counts as CSR. I have seen companies try to classify marketing sponsorships, employee benefits, and even routine business activities as CSR. 

The CSR Rules have specifically clarified what does not qualify, and getting this wrong can create serious compliance issues. 

This section creates clear boundaries to prevent misclassification and helps protect the company from potential penalties for the improper use of CSR funds.

Draft sample:

Not all activities qualify as CSR under the law. To maintain compliance, NexaTech will ensure that the following are not included as CSR initiatives:

• Employee welfare programs that benefit only NexaTech employees.
• Contributions to political parties.
• Marketing campaigns disguised as CSR.
• Activities conducted in pursuance of normal course of business.
• Projects implemented outside India.
• Any activity undertaken to fulfill statutory obligations.

Risk assessment and mitigation

I added this section because even well-designed CSR programs can face implementation challenges. Infrastructure problems, staff turnover, or community resistance can derail projects. 

While not explicitly required by law, having contingency plans shows that the company has thought seriously about execution, not just compliance. 

This planning helps prevent wasted resources and demonstrates to regulators that the company takes its CSR obligations seriously, not just as a box-checking exercise.

Draft sample:

11.1 Identified risks

• Implementation delays: Mitigated through buffer time in project timelines and alternative implementation partners.
• Resource constraints: Addressed through contingency budget allocations and flexible resource planning.
• Community adoption: Mitigated through stakeholder engagement strategies and community ownership models.
• Infrastructure challenges: Backup plans for power supply, connectivity issues, and hardware maintenance.
• Sustainability concerns: Transition strategies including community ownership and skill transfer.

11.2 Contingency planning

• Backup implementation partners identified for each major project.
• Alternative technology solutions documented for various constraint scenarios.
• Disaster recovery plan for all digital infrastructure projects.
• Documented escalation procedures for each category of risk.

Policy review and amendments

I included this section because CSR regulations have changed several times since 2014 and will likely continue to evolve. Companies without formal review processes often get caught off guard by regulatory changes. 

The half-yearly assessment and stakeholder engagement process ensures that the policy stays current with both legal requirements and community needs. 

It’s easier to make small adjustments regularly than major overhauls when regulations change significantly.

Draft sample:

CSR policies need to evolve with legal changes and business priorities. To keep the policy relevant, NexaTech will:

• Conduct comprehensive annual policy reviews by the CSR Committee.
• Hold a half-yearly assessment of policy effectiveness against stated objectives.
• Propose updates to the Board as necessary, particularly following regulatory changes.
• Engage stakeholders in the policy revision process to incorporate diverse perspectives.
• Ensure that any amendments align with evolving legal requirements and business priorities to maximize societal impact.

This enhanced CSR policy reflects NexaTech Private Limited’s firm commitment to corporate citizenship and sustainable development. By aligning business objectives with social impact, we aim to create lasting change in the communities where we operate while maintaining the highest standards of transparency, accountability, and effectiveness in our social responsibility initiatives.

The final policy of NexaTech can be accessed here.

I designed this policy to be both legally robust and practically implementable for NexaTech. 

The digital education focus leverages its core strengths while creating a meaningful social impact. I am confident this framework will serve NexaTech well as it grows.

Remember that CSR works best when it’s authentic to your client’s identity rather than just a compliance exercise.

Final thoughts

Let’s get one thing straight—CSR isn’t just some corporate checklist. It’s a legitimate strategy for building lasting success.

So, whether you are developing a CSR policy to satisfy regulations or to enhance your company’s market position, think expansively. Move beyond simplistic notions of charity toward creating ga enuine impact.

Ultimately, no business exists in a vacuum—your company’s growth is intrinsically connected to the communities you serve.