Developing a CSR Implementation Plan

Companies often announce their corporate social responsibility (“CSR”) mission statements and commitments with great public fanfare, pledging to proactively contribute to improving social conditions and protecting the environment.  While putting the company’s brand and reputation on the line in this way is important, the reality is that CSR cannot and will not be effective unless and until it is tightly integrated into every aspect of organizational operations including products and services, governance systems and practices, culture, marketing and other external communications, training, recruiting and relationships with business partners.  Once the CSR commitments are finalized and published, attention needs to turn to the actual implementation of those commitments, which includes the day-to-day decisions, processes, practices and activities that are required in order for the company to adhere to its commitments and effectively carry out its overall CSR strategy.  A company that fails to implement its CSR commitments will find itself losing employees, customers and business partners and will see its standing in the marketplace and community plummet.

There is no universal approach to implementing CSR commitments and the methods used by companies will vary depending upon the specific content and focus of their commitments, current organizational structure, organizational culture, resources, priorities of the CEO and the other members of the senior management team and other factors.  One way to view the process is as follows: develop a CSR implementation plan; establish an internal organizational structure; implement CSR management systems; develop a sustainability-oriented organizational culture; develop an integrated CSR decision-making structure; prepare and implement a CSR business plan; set measurable targets and identify performance measures; integrate CSR into strategic values; engage employees and others to whom CSR commitments apply; design and conduct CSR training; establish mechanisms for addressing problematic behavior; create internal and external communications plans; and implement CSR partnering arrangements.  While primary responsibility for CSR implementation may be vested with a group or department, input and support will be need from the board of directors, all members of the executive team and managers and employees in all of the functional and customer departments.  Also important to effective CSR implementation is continuously building stakeholder awareness through messaging and engagement.  While most of the issues relating to the actual implementation of the CSR strategy come into play once the strategic plan is finalized it is important for those involved in the preparation of the strategy to identify and resolve the practical problems that are likely to arise when actual pursuit of the goals and objectives begins.

As the company goes through the process of identifying, vetting and approving the CSR objectives and commitments, attention also needs to be paid to translating the policy and the accompanying objectives into operational terms, a process that requires the development of an implementation plan.  The plan will be expansive and will impact the entire organization including corporate culture and employee attitudes; organizational design and structure, particularly the responsibilities and accountability of everyone in the organization with respect to the CSR objectives and commitments; information reporting systems; management systems and operational practices.  During the planning process the objectives and commitments will necessarily remain fluid since they should not be finalized and announced to the world unless and until the company has a clear and reasonable plan for implementation.  

As the plan develops consultations with stakeholders will be needed and ideas from stakeholders should be solicited about how best to realize their needs and expectations. While all stakeholders are important, input and participation from employees is essential since they will be the one called upon to implement the plans and will likely feel significant disruption to the ways in which they have worked in the past. The input from stakeholders will likely cause a series of modifications to the plan, as well as to the upper tier goals and objectives.  Eventually the plan will be ready for review and approval by the board of directors following presentation by the senior management at the same time that the board signs off on the policy and related objectives and commitments.  Given the breadth of the organizational changes that will likely be required, it should be expected that the implementation plan will cover three to five years and provide for milestones that will hopefully be achieved every six to twelve months.

Before an effective and reasonable implementation plan can be prepared, the company needs to know where it stands with respect to how its activities in their current state line up against broadly accepted sustainable development principles and the needs and expectations of its stakeholders.  Insights must come from the assessment process describe elsewhere in this publication that covers the company’s overall strategy and its operational activities, management philosophies and systems, relations with stakeholders and the functionality of the information systems that will be relied upon to generate the data about CSR performance that must be reviewed by company leaders and reported to stakeholders.  At the assessment stage the company can rely on questionnaires that have been prepared by industry groups and outside organizations such as the Global Environmental Management Initiative and Ceres and bring in outside consultants that can help facilitate the process.

The results of the assessment need to be put into context by comparing them to the status and performance of comparable organizations as well as industry standards and norms and expectations that have been established by external groups.  Comparisons can be made through a review of public disclosures by comparable organizations and data compiled by industry associations and programs that have been formed explicitly to collect and catalogue CSR information.  Comparison allows the company to identify the gaps between what it is doing and what others are doing and provides a sense of the reasonable targets that the company can establish for improving its CSR profile.  The senior management of the company should create a set of goals and objectives and a strategy, timetable and milestones for each goal and objective.  The strategy should not only be approved by the board of directors, it should also be fully vetted by all of the key players inside the organization to ensure that they have had a chance to contribute to the process and can “buy in” to the strategy because they have participated in its formulation and believe in its objectives. 

While the board of directors and senior management will retain ultimate responsibility for the success of the company’s CSR goals and objectives, responsibility for overseeing and tracking the company’s progress toward the goals and objectives should be assigned to a specific group within the organizational structure that is provided with the resources and authority required to discharge its duties.  When creating the strategy and the accompany implementation plan, the following steps and issues should always be part of the process[1]:

• The job descriptions of everyone in the organization, managers and employees, should be reviewed and revised to integrate specific CSR roles, responsibilities and accountability.  Everyone needs to know their place in the plan and to whom they are expected to report.
• Changes to the organizational culture will be required, as will retraining of employees to empower them to carry out their new roles and responsibilities.  As part of this process, reward systems and incentives will also need to assessed and modified to align with the activities required to achieve the CSR objectives and commitments.  It is also likely that new skills and experience will need to be added to the workforce and the human resources department will need to understand the needs of the company and set up new recruiting initiatives.
• Changes to the strategic planning processes should already have begun as the CSR objectives and commitments were being developed; however, at the implementation stage an investment must be made in the resources and skills necessary to handle stakeholder engagement and external monitoring.
• Each of the CSR objectives and commitments will have their own unique set of metrics, most of which will be new to the company, and this means that the company’s management information systems will need to be changed in order to ensure that everyone has access to the information they need in order to be sure they are on track with the new metrics and see their progress toward achieving the objectives and commitments.
• The company’s marketing research efforts will need to be overhauled to place customer attitudes and expectations regarding CSR and sustainability front and center.  While customers as a group will be consulted during the stakeholder engagement process, detailed market research, including interviews and tests, will be needed to determine the best way to position the company’s CSR initiative and the related features in its products and services.  The results of this research should be reflected in updated plans with respect to pricing, sales, marketing and promotion.  Companies often find that existing markets will need to be redefined and that new markets should be added.
• The engineering and product design groups will need to determine what changes must and can be made to products and processes in order to achieve the CSR objectives and commitments and satisfy the needs and expectations of the company’s stakeholders.  The company should not commit publicly to a specific leap in the energy efficiency of its products until it is satisfied that progress can be made in a manner that does not endanger the company’s ability to survive financially or adversely impact another group of stakeholders (e.g., displacing a large number of workers).  Specific consideration should be given to regulatory requirements, industry standards and benchmarking.
• Suppliers are key partners in any company’s efforts with respect to CSR and other stakeholders, such as customers and human rights activists, will hold companies accountable for the social responsibility (or lack thereof) of their suppliers.  This means that everyone involved in the procurement process must be trained in supply chain management and held accountable for the products procured from vendors and the manner in which those products are produced.
• The CSR objectives and commitments cannot be realized unless the company remains profitable throughout the process and is able to survive and thrive to the point where the objectives have been achieved.  As such, the implementation plan must be supported by comprehensive financial planning that takes into account and addresses all of the capital requirements that must be satisfied in order for the plan to be successful including making sure that capital required for investment in new technologies and other resources will be available at the appropriate times during the three- to five-year span of the plan.  Among the issues to be considered is the impact of the sustainability focus on attracting capital from outside investors and the availability of tax incentives and financing through governmental programs.

The process of creating a CSR implementation plan is extremely challenging and will require a thorough understanding of the tools associated with organizational design.  In addition to the issues described above, senior management needs to be acutely aware of potential barriers and sources of resistance to the changes that will be needed in order to implement the plan effectively.  The transition toward a stronger focus on CSR will inevitably upset people in the organization who prefer that things continue as they have always been and individuals and groups will be reluctant to embrace change and agree to new roles and reporting channels.  As such, it is essential that senior management involve everyone in the organization in the planning process and refrain from finalizing the plan until those who will be responsible for executing the plan have had a chance to voice their concerns and ask about the uncertainties that are bothering them.

This article is an excerpt from the author’s forthcoming book on Strategic Planning for Sustainability to be published by Business Experts Press in Fall 2020. For further information see the website of the Sustainable Entrepreneurship Project.

[1] Business Strategy for Sustainable Development: Leadership and Accountability for the 90s (Winnipeg, CN: International Institute for Sustainable Development, 1992).