03.11.2021-State of CSR Report_TCS_WIP.pptx

Annual State of CSR Report for
Tata Consultancy Services
Limited
October 2021

List of abbreviations
Abbreviation Definition
Cr Crore
CSR Corporate Social Responsibility
FY Financial Year
INR Indian Rupee
MCA Ministry of Corporate Affairs
NA Not Available/Not Applicable
SDG Sustainable Development Goal
TCS Tata Consultancy Services
UT Union Territories

Schedule VII
Item Activity
S(i) Eradicating hunger, poverty and malnutrition, [‘‘promoting health care including preventive health care’’] and sanitation [including contribution to the Swachh Bharat Kosh set-up by the Central Government for the
promotion of sanitation] and making available safe drinking water
S(ii) Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects
S(iii) Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for
reducing inequalities faced by socially and economically backward groups
S(iv) Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water [including
contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga]
S(v) Protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional art and
handicrafts
S(vi) Measures for the benefit of armed forces veterans, war widows and their dependents, [Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including
widows]
S(vii) Training to promote rural sports, nationally recognised sports, paralympic sports and olympic sports
S(viii) Contribution to the prime minister's national relief fund [or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund)] or any other fund set up by the central govt. for socio
economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women
S(ix) (a)Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector
Undertaking or any agency of the Central Government or State Government; and (b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies
established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and
Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defence Research and Development organization (DRDO); Indian Council of
Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine
aimed at promoting Sustainable Development Goals (SDGs)
S(x) Rural development projects
S(xi) Slum area development. (Slum area' shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force)
S(xii) Disaster management, including relief, rehabilitation and reconstruction activities

Sustainable Development Goals
SDG Number Goal
SDG 1 No Poverty
SDG 2 Zero Hunger
SDG 3 Good Health and Well-being
SDG 4 Quality Education
SDG 5 Gender Equality
SDG 6 Clean Water and Sanitation
SDG 7 Affordable and Clean Energy
SDG 8 Decent Work and Economic Growth
SDG 9 Industry, Innovation and Infrastructure
SDG 10 Reducing Inequality
SDG 11 Sustainable Cities and Communities
SDG 12 Responsible Consumption and Production
SDG 13 Climate Action
SDG 14 Life Below Water
SDG 15 Life On Land
SDG 16 Peace, Justice, and Strong Institutions
SDG 17 Partnerships for the Goals

08 March 2021 Interim Report: Review of the Disaster Management Practices and Guidelines
Page 5
1. Executive summary
2. Our approach & methodology
3.
Key findings
3a Analysis: Compliance with CSR Act
3b Analysis: CSR Spend
3c Analysis: CSR Strategy
4 Good practices & areas of improvement
5 Annexure
Contents

Executive summary (1/4)
Overall Outcome
EY’s Approach
EY has adopted a 5-C lens approach to review
the CSR reports of selected Tata Group
companies across three critical areas, with an
emphasis on the Amendments to the CSR
Rules released by MCA in January 2021
• Group level report
• 15 individual company reports
This approach has provided a framework that has helped us to structure our findings across 3 areas

Executive Summary (2/4)
Key findings across Compliance with CSR Act
1
► TCS reported compliance across the CSR policy regulation except for the encompassment of an annual action plan
► CSR committee is as per the criteria specified in the Companies (Corporate Social Responsibility Policy) Rules, 2014,
as amended across the 7 sub indicators
► Composition of the board of directors, role and responsibilities have been reported on in the Annual CSR Report for FY
2020-21
► TCS has reported compliance across the CSR implementation and CSR program regulation in line with the Companies
(Corporate Social Responsibility Policy) Rules, 2014, as amended
► Projects have been classified as ongoing and as other than ongoing for FY 2020-21. No surplus or unspent amount was
reported, while the excess amount to be set-off against future CSR obligations was reported as INR 11 Cr
► Capital asset creation/acquisition for FY 2020-21 was reported as Not Applicable
► Compliance on disclosure guidelines, reporting format as per Annexure II and on administrative overheads has been
reported in the Annual Report for FY 2020-21
► Internal impact assessments to monitor and evaluate CSR activities have been undertaken. However, this may not be
compliance consideration for FY 2020-21 since the mandate is applicable on minimum one-year old projects completed on or after 22
January 2021
► Given that the FY under review is FY 2020-21, formulation of annual action plan may not be a compliance consideration since it
will applicable from FY 2021-22

Key findings across CSR Spend
2
► TCS has reported 5 ongoing projects in FY 2020-21 as per the their CSR Annual Report 2020-21
► TCS focused on Covid 19 relief and has spent 273 Crores in FY 2020- 21
► They have broadened its purview of spends YoY since FY 2018-19 to 2020-21 with a Pan-India approach
► The maximum share of their CSR on activity VIII of the Schedule VII activities i.e. Contribution to Prime Ministers National Relief
Fund (PM CARES FUND) or any other fund set up by the central govt. for socio economic development and relief and welfare of the schedule
caste, tribes, other backward classes, minorities and women
► They have spent 3% of their total CSR spent amount on administrative expense which is in line with the 5% mandate as
specified by the Ministry of Corporate Affairs for FY 2020-21
► TCS has spent more than its CSR obligation in the last 2 financial years consecutively

Key findings across CSR Strategy
3
► TCS has reported 24 CSR projects in FY 2020-21 as per Annexure II format, point 8(b) and 8(c) of the Companies (Corporate Social
Responsibility Policy) Rules, 2014, as amended in their Annual Report 2020-21
► 80% (19 projects) of the projects were reported as other than ongoing projects
► TCS focused on 7 thematic areas for the CSR projects as per Schedule VII of Companies Act 2013
► The CSR projects reported in FY 2020-21 were undertaken across 19 states in India. TCS also reported pan- India
projects
► TCS has employed all three modes of implementation for the CSR projects in FY 2020-21. 9 projects were undertaken through
the mode of direct implementation as per TCS Annual Report 2020-21
► The Annual Report 2020-21 of TCS reported alignment with 13 Sustainable Development Goals (SDGs) across the thematic
areas of intervention
► As per the Annual Report 2020-21, TCS reported 1.8 million beneficiaries reached through the TCS’ global community initiatives

Approach : 5-C lens to review CSR reports across three key areas
Clarity
Are the reports easy to read and comprehendible for different
stakeholders?
Comprehensiveness
What is the depth of reporting in the reports? Is it inadequate,
adequate or too deep?
‘Captivating’ communication
Where do the reports stand on good communication standards with respect
to showcasing impact, visual appeal and capturing human interest stories
COMPLIANCE
STRATEGY
SPEND
Coverage
Do the TCS reports adequately cover all aspects mandated as per the new Companies
(CSR Policy) Amendment Rules 2021?
Consistency
Do the reports from different companies follow a uniform
structure and representation of information?

Overall three-phased methodology
Key
Worksteps
Collection of documents
from identified
companies
Finalisation of report
structure and data
templates
Identification of
companies
Phase 1
Phase 3
Inception
Data Analysis
Report Creation
2 Weeks 3 Weeks
In-depth desk review
Organisation of data
Preparation and sharing
of draft reports
Submission of final
reports
Development of
inception report
Phase 2
Feedback and
clarifications with
companies and TSG
Team
3 Weeks
Analysis and preparation
of base tables

Methodology adopted for selection of 15 companies
29
Total number of listed Tata
companies
204
57
15
Companies for which CSR spend for FY 2020-21
was mapped. These included both parent entities
as well as their subsidiaries
Companies selected through a two fold-criterion of
being the highest CSR spenders of the Tata Group,
covering more than 90% of the Group's total spend.
TCS was identified as a top spender and selected for
review for FY 2020-21
TCS spent INR 674 Cr on CSR for FY 2020-21
Companies for which CSR spend
for FY 2020-21 was reported/
available on public domain by
September 2021. The total spend of
these companies approximated
INR 1126.6 Cr
Note: The embedded excel has our
research and raw data to arrive at 15
companies

Developed three checklist for data capture and analysis across the three areas
Spend
Compliance
A checklist was developed with 12 broad regulations and 60
sub-indicators against which TCS’ performance was
reviewed
The checklist has the scores of 1, Not Applicable, & Not
Available which was then aggregated at the company level
12 Broad Regulations
• CSR Policy
• CSR Committee
• Board of Directors
• Annual Action Plan
• CSR Implementation
• CSR Program Design
• Treatment of unspent amount, surplus or excess
CSR amount
• Capital Assets
• Reporting on Website, if any
• CSR Reporting
• Impact Assessment
• Administrative Overheads
A checklist was developed to analyze the strategy of the
15 companies. 5 broad areas of analysis were
considered:
The checklist has the scores of 1, 0 and Not Available
• Number of projects conducted in FY 2020-21 as per
Annexure II, point 8(b) and 8(c) of Annual CSR report
2020-21
• Thematic areas of CSR intervention as per the
Schedule VII of Companies
• Geographical CSR intervention in FY 2020-21
• Modes of implementation of CSR programs in FY
2020-21
• Alignment of CSR projects with the Sustainability
Development Goals (SDGs)
The number of beneficiaries across thematic areas and
on group level were also captured wherever reported
and applicable
Strategy
A checklist was developed to analyze the spending patterns of
15 companies.
The checklist has been made to analyze the spend pattern of
the group companies over the past three financial years
• Treatment of CSR amount asper the MCA guidelines
• Mode of spending i.e. Direct , indirect and other modes of
spending
• Schedule VII breakup of spending in FY 2020-21
• Geographical breakup of CSR spends in FY 2020-21
• Modes of implementation of CSR programs in FY 2020-21
• COVID-19 spending for FY 2020-21

3a
Analysis:
Compliance with
CSR Act

TCS compliance for FY 2020-21 was assessed against 12 broad
regulations which were mapped with reference to the Companies Act,
2013 and Companies (Corporate Social Responsibility Policy) Rules,
2014, as amended

Regulations Sub-indicators under the Companies Act, 2013 ('the Act') Reference
CSR Policy
Does the policy have a statement containing the approach and direction given by the board of the
company?
Rule 2(1)(f) of the CSR Rules
Does the policy have guiding principles for selection, implementation and monitoring of CSR
activities?
Rule 2(1)(f) of the CSR Rules
Does the policy encompass formulation of Annual Action Plan? Rule 2(1)(f) of the CSR Rules
CSR Committee
Does the CSR committee consist of 3 or more directors, of which at least one is an independent
director?
Section 135(1) of the Act
Does the Board report of the company disclose the composition of the CSR Committee? Section 135(2) of the Act
Does the CSR committee discharge its functions in line with the provisions of section 135 of the Act? Section 135 (3) of the Act
Are details regarding names and designations of CSR committee members reported as per the
Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended?
Rule 8(1) of the CSR Rules read with the format of annual
report on corporate social responsibility
Are details regarding number of CSR committee meetings held reported as per the Companies
(Corporate Social Responsibility Policy) Rules, 2014, as amended?
Are details regarding attendance of CSR committee meetings reported as per the Companies
Board of Directors
Does the Board discharge its functions in line with the provisions of section 135 (4) of the Act? Section 135 (4) of the Act
Does the Board discharge its functions in line with the provisions of section 135 (5) of the Act? Section 135 (5) of the Act
Has the Board satisfied itself that that the funds so disbursed have been utilized for the purposes
and in the manner as approved by Board?
Rule 4(5) of the CSR Rules
Has the Board monitored the implementation of the project with reference to the approved timelines
and year-wise allocation, for ongoing projects?

Annual Action Plan
Has an annual action plan been duly formulated by the CSR Committee? Rule 5(2) of the CSR Rules
Does the plan include the list of CSR projects or programs approved to be undertaken? Rule 5(2)(a) of the CSR Rules
Are the CSR activities in line with the definition of CSR under the CSR Rules? Rules 2(1)(d) of the CSR Rules
Does the plan include the manner of execution of such projects or programs? Rule 5(2)(b) of the CSR Rules
Does the plan include the modalities of utilisation of funds and implementation schedules? Rule 5(2)(b) of the CSR Rules
Does the plan include monitoring and reporting mechanism for the projects or programs? Rule 5(2)(b) of the CSR Rules
Does the plan include details of need and impact assessment, if any? Rule 5(2)(e) of the CSR Rules
CSR Implementation
Are the projects implemented either by the company itself or through implementing partners (including
captive entity) as per the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended?
Is the implementing partner (if any) registered with the central government and has a unique CSR
registration number?
Does the implementing partner (if any) satisfy the eligibility criteria as prescribed under the CSR Rules? Rule 4(1) of the CSR Rules
If CSR is undertaken in collaboration with other companies, and was the same reported in its Annual
CSR Report?
CSR Program Design
Are the CSR programs undertaken aligned with Schedule VII of the Companies Act 2013 in line with the
new definitions of CSR expenditure?
Section 135(3)(a)

CSR Program Design
Are the CSR programs undertaken aligned with the CSR policy of the company? Section 135(5) read with 135(3)(a) of the Act
In case an international organization was engaged for CSR project, was it eligible as per the
provisions of the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended?
Rule 4(3) read with 2(1)(g) of the CSR Rules
Was the international organization engaged for activities limited to designing/ monitoring/evaluation
of the CSR projects/ capacity building of their own personnel for corporate social responsibility?
Rule 4(3) read with 2(1)(g) of the CSR Rules
Treatment of unspent amount, surplus or
excess CSR amount
Has the existing projects been classified into ongoing/other than ongoing project? Section 135(6) read with second provision to section 135(5)
read with clause 8(b) and (c) of annual report on CSR
Was a separate bank account opened with a scheduled bank for transfer of unspent amount
pertaining to ongoing projects?
Was the unspent amount transferred to separate scheduled bank account by 30 April 2021 with
respect to ongoing projects?
Has the company transferred unspent amount pertaining to projects other than ongoing projects to
Funds specified in Schedule VII?
Second proviso to section 135(5) of the Act read with rule
10 of the CSR Rules
In case of excess spend, has the company passed a board resolution to that effect for set-off the
CSR obligation of future years in accordance with the Companies (Corporate Social Responsibility
Policy) Rules, 2014, as amended?
In case of surplus arising from CSR activities, was it ploughed back into the same project or
transferred to Unspent CSR Account and spent or transferred to a Fund specified in Schedule VII in
accordance with the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended?
Capital Assets
Has the company reported on any capital assets acquired or created during the implementation of
CSR activity in its Annual CSR Report?
Is the ownership of capital asset acquired of created held by entities covered under rule 7 of the
Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended?

Capital Assets
Does the Annual CSR Report include details on the ownership of the capital assets acquired or
created?
Does the Annual CSR Report include details on the date of creation or acquisition of the capital
asset(s)?
Does the Annual CSR Report include details on the amount of CSR spent for creation or acquisition
of capital asset?
In case the capital assets is created prior to the Companies (CSR Policy) Amendment Rules, 2021,
are the provisions of the Companies (CSR Policy) Amendment Rules, 2021 complied by 21 July
2021?
In case the board has extended the above timeline of 21 July 2021, is the extension based on
reasonable justification and timeline is not exceeding 90 days?
Provision to rule 7(4) of the CSR Rules
Reporting on Website, if any
Has the composition of CSR committee been displayed on the company’s website? Rule 9 of the CSR Rules
Has the CSR policy been displayed on the company’s website? Rule 9 of the CSR Rules
Have the CSR projects approved by the Board been displayed on the company’s website? Rule 9 of the CSR Rules
CSR Reporting
Does the Annual CSR Report follow the reporting format as per Annexure II of the Companies
Does the Annual CSR Report specify average net profit of the company as per section 135(5)?
Does the Annual CSR Report specify what is 2% of average net profit of the company as per section
135(5)?
Does the Annual CSR Report specify the total CSR obligation for the financial year?

CSR Reporting
Does the Annual CSR Report specify amount spent or unspent for the financial year?
Does the Annual CSR Report specify details of unspent CSR amount (if any) transferred to Unspent
CSR Account or to any funds specified in Schedule VII?
Does the Annual CSR Report clearly specify whether any excess amount spent by the company is
set off against future CSR obligations?
Does the Annual CSR Report clearly specify whether any excess amount spent by the company is
set off against future CSR obligations?
Impact Assessment
Has the company carried out Impact assessment for projects as specified in Rule 8 of Companies
(CSR Policy) Rules, 2014, as amended from time to time?
Rule 8(3)(a) of the CSR Rules
Is the amount spent on impact assessment within the permissible threshold of 5%?
Is the impact assessment report (if conducted) placed before the board and annexed to Annual CSR
report?
Administrative Overheads
Has the company reported its administrative overheads in its Annual CSR Report? Rule 8(1) of the CSR Rules read with the format of annual
Are the administrative overheads in line with the definition prescribed under the CSR Rules? Rule 2(1)(b) of the CSR Rules
Are the administrative overheads within the permissible threshold of 5%? Rule 7(1) of the CSR Rules

CSR Reporting
Does the Annual CSR report specify amount spent or unspent for the financial year?
Does the Annual CSR report specify details of unspent CSR amount (if any) transferred to Unspent
CSR Account or to any funds specified in Schedule VII?
Does the Annual CSR report clearly specify whether any excess amount spent by the company is set
off against future CSR obligations?
Does the Annual CSR report clearly specify whether any excess amount spent by the company is set
off against future CSR obligations?
Impact Assessment
Has the company carried out Impact assessment for projects as specified in Rule 8 of Companies
(CSR Policy) Rules, 2014, as amended from time to time?
Rule 8(3)(a) of the CSR Rules
Is the amount spent on impact assessment within the permissible threshold of 5%?
Is the impact assessment report (if conducted) placed before the board and annexed to Annual CSR
report?
Has the company reported its administrative overheads in its Annual CSR Report? Rule 8(1) of the CSR Rules read with the format of annual
Are the administrative overheads in line with the definition prescribed under the CSR Rules? Rule 2(1)(b) of the CSR Rules
Are the administrative overheads within the permissible threshold of 5%? Rule 7(1) of the CSR Rules

TCS Compliance Analysis

Out of the 60 sub indicators, TCS has reported compliance on 33 for FY 2020-21
33
26
1
Yes Not Applicable Not Available
Legend
Not Applicable implies that the indicator is not relevant for the FY under review
Not Available implies that details have not been reported in the company’s annual report
Regulations Yes Not Available Not Applicable
CSR Policy 2 1
CSR Committee 6
Board of Directors 4
Annual Action Plan 7
CSR Implementation
4
CSR Program Design
2 2
Treatment of unspent
amount, surplus or excess
CSR amount
2 4
Capital Assets 7
Reporting on Website, if any
3
CSR Reporting 7 3
Impact Assessment
3
3
Total 33 1 26
Compliance score of TCS on 60 sub indicators across 12 board regulations

For FY 2020-21, TCS reported compliance across the CSR policy regulation
TCS performance across 3 sub indicators
*‘NA’ implies Not Available in the companies Annual CSR Report
Sr.No. Sub indicator
Reported
(Yes/NA)
1 Does the policy have a statement
containing the approach and direction
given by the board of the company?
Yes
2 Does the policy have guiding principles
for selection, implementation and
monitoring of CSR activities?
3 Does the policy encompass formulation
of Annual Action Plan? NA*
Key Insights
• Out of the 3 sub indicators, TCS has reported compliance across 2
• TCS’ CSR policy is guided by the principle of “Impact through
Empowerment” and includes the guiding principles for selection,
implementation and monitoring of CSR activities
• However, the policy does not encompass the formulation of an
Annual Action Plan
Yes Not Available
2
1
Legend

CSR committee is as per the criteria specified in the Companies (Corporate Social Responsibility
Policy) Rules, 2014, as amended
Sr.No. Sub indicator Reported (Yes/NA)
1 Does the CSR committee consist of 3 or more directors, of
which at least one is an independent director?
Yes
2 Does the Board report of the company disclose the
composition of the CSR Committee?
3 Does the CSR committee discharge its functions in line with
the provisions of section 135 of the Act?
4 Are details regarding names and designations of CSR
committee members reported as per the Companies
(Corporate Social Responsibility Policy) Rules, 2014, as
amended?
5 Are details regarding number of CSR committee meetings held
reported as per the Companies (Corporate Social
Responsibility Policy) Rules, 2014, as amended?
6 Are details regarding attendance of CSR committee meetings
reported as per the Companies (Corporate Social
TCS performance across 6 sub indicators Key Insights
100%
• TCS has reported compliance across 6 sub
indicators as per the Companies (Corporate
Social Responsibility Policy) Rules, 2014, as
amended
Yes
Legend

For FY 2020-21, the CSR committee for TSC does not have representation of women
CSR committee composition for TCS for FY 2020-21 includes the Chairman
and 2 Members
Member
Independent, Non-Executive Director
Member
Non-independent, Non-Executive Director
Chairman
Non-Independent, Non-
Executive Director
100%
Key Insights
• CSR committee composition for TCS does not include
women
• While this not a mandate and therefore is not a
compliance consideration/requirement, it may be
considered as a good to have element
No
Legend

TCS has reported on the board of directors composition, role and responsibilities in the Annual
CSR Report for FY 2020-21
1 Does the Board discharge its functions in line with the
provisions of section 135 (4) of the Act?
Yes
2 Does the Board discharge its functions in line with the
provisions of section 135 (5) of the Act?
3 Has the Board satisfied itself that that the funds so
disbursed have been utilized for the purposes and in
the manner as approved by Board?
4 Has the Board monitored the implementation of the
project with reference to the approved timelines and
year-wise allocation, for ongoing projects?
100%
• TCS has reported compliance across 4 sub indicators
as per the Companies (Corporate Social Responsibility
Policy) Rules, 2014, as amended
• The Board of Directors composition and functions are
articulated in the Annual CSR Report for FY 2020-21
Yes
Legend

TCS has reported compliance across the CSR implementation regulation in line with the Companies
(Corporate Social Responsibility Policy) Rules, 2014, as amended
1 Are the projects implemented either by the company itself
or through implementing partners (including captive entity)
as per the Companies (Corporate Social Responsibility
Policy) Rules, 2014, as amended?
Yes
2 Is the implementing partner (if any) registered with the
central government and has a unique CSR registration
number?
3 Does the implementing partner (if any) satisfy the
eligibility criteria as prescribed under the CSR Rules?
4 If CSR is undertaken in collaboration with other
companies, was the company able to separately report it
in its Annual CSR Report?
100%
• TCS has reported compliance across 4 sub indicators as
per the Companies (Corporate Social Responsibility Policy)
Rules, 2014, as amended
• The Annual CSR Report includes details regarding
implementing partners and their eligibility criteria,
registration number, and mode of implementation
• TCS has further reported that one of the projects in being
jointly implemented with Tata Community Initiatives Trust
Yes
Legend

CSR programs undertaken by the company are in alignment with Schedule VII of the Companies
Act & the new definitions of CSR expenditure
*‘NA’ implies Not Applicable for the FY under review
**Please refer to the Annexure for the CSR expenditure definition
Key Insights
• Of the 4 sub indicators, TCS has reported compliance across 2
and 2 are not applicable for the FY under review
• CSR programs undertaken by TCS are in alignment with
Schedule VII of the Companies Act 2013 in line with the new
definitions of CSR expenditure**
• TCS has not undertaken any CSR projects with international
organizations in FY 2020-21
2
2
Yes Not Applicable
Legend
1 Are the CSR programs undertaken aligned with
Schedule VII of the Companies Act 2013 in line
with the new definitions of CSR expenditure? Yes
2 Are the CSR programs undertaken aligned with
the CSR policy of the company?
3 In case an international organisation was
engaged for CSR project, was it eligible as per
the provisions of the Companies (Corporate
Social Responsibility Policy) Rules, 2014, as
amended? NA*
4 Was the international organisation engaged for
activities limited to designing/
monitoring/evaluation of the CSR projects/
capacity building of their own personnel for
corporate social responsibility?

TCS has classified projects as ongoing and as other than ongoing for FY 2020-21
Reported
(Yes/NA)
1 Has the existing projects been classified into ongoing/other
than ongoing project?
Yes
2 In case of excess spend, has the company passed a board
resolution to that effect for set-off against the CSR obligation
of future years in accordance with the Companies (Corporate
Social Responsibility Policy) Rules, 2014, as amended?
3 Was a separate bank account opened with a scheduled bank
for transfer of unspent amount pertaining to ongoing projects?
NA*
4 Was the unspent amount transferred to separate scheduled
bank account by 30 April 2021 with respect to ongoing
projects?
5 Has the company transferred unspent amount pertaining to
projects other than ongoing projects to Funds specified in
Schedule VII?
6 In case of surplus arising from CSR activities, was it ploughed
back into the same project or transferred to unspent CSR
Account and spent or transferred to a Fund specified in
Schedule VII in accordance with the Companies (Corporate
Social Responsibility Policy) Rules, 2014, as amended?
5
19
Ongoing Other than ongoing
Key Insights
• For FY 2020-21, 5 projects have been classified as
ongoing, while 19 are other than ongoing projects
• Excess amount of INR 11 Cr to be set-off against CSR
obligations of future years has been reported for the FY
under review
• No unspent amount or surplus amount has been reported
for FY 2020-21
Ongoing Other than ongoing
Legend

Capital asset creation/acquisition for FY 2020-21 for TCS is not applicable
NA*
• For FY 2020-21, TCS has reported capital asset
creation/acquisition as none
• Reporting on 7 sub indicators is not applicable
for the FY under review
• No CSR amount was spent for capital asset
creation/acquisition for FY 2020-2021
Reported
(Yes/NA)
1 Has the company reported on any capital assets acquired or created during
the implementation of CSR activity in its Annual CSR Report?
NA*
2 Is the ownership of capital asset acquired of created held by entities covered
under rule 7 of the Companies (Corporate Social Responsibility Policy)
Rules, 2014, as amended?
3 Does the Annual CSR Report include details on the ownership of the capital
assets acquired or created?
4 Does the Annual CSR Report include details on the date of creation or
acquisition of the capital asset(s)?
5 Does the Annual CSR Report include details on the amount of CSR spent for
creation or acquisition of capital asset?
6 In case the capital assets is created prior to the Companies (CSR Policy)
Amendment Rules, 2021, are the provisions of the Companies (CSR Policy)
Amendment Rules, 2021 complied by 21 July 2021?
7 In case the board has extended the above timeline of 21 July 2021, is the
extension based on reasonable justification and timeline is not exceeding 90
days?
Not Applicable
Legend

For FY 2020-21, TCS reported compliance with respect to reporting on their website as per the
disclosure guidelines
Reported
(Yes/NA)
1 Does the Annual CSR report follow the
reporting format as per Annexure II of
the Companies (Corporate Social
Responsibility Policy) Rules, 2014, as
amended?
Yes
2 Has the CSR policy been displayed on
the company’s website?
3 Have the CSR projects approved by
the Board been displayed on the
company’s website?
Key Insights
• For FY 2020-21, TCS reported compliance on 3 sub indicators
with respect to reporting on their website
• Links to the CSR Policy, composition of the CSR Committee
and CSR projects approved by the board have been made
available in the Annual CSR Report 2020-21
100%
Yes
Legend

CSR reporting format for FY 2020-21 for TCS is as per Annexure II of the CSR Rules 2014, as
amended (1/2)
1 Does the Annual CSR Report follow the reporting format as per Annexure II of the Companies (Corporate Social
Yes
2 Does the Annual CSR Report specify average net profit of the company as per section 135(5)?
3 Does the Annual CSR Report specify what is 2% of average net profit of the company as per section 135(5)?
4 Does the Annual CSR Report specify the total CSR obligation for the financial year?
5 Does the Annual CSR Report specify amount spent or unspent for the financial year?
6 Does the Annual CSR Report clearly report on detail of amount available for set off
7 Does the Annual CSR Report clearly specify whether any excess amount spent by the company is set off against future
CSR obligations?
8 Does the Annual CSR Report specify details of unspent CSR amount (if any) transferred to Unspent CSR Account or to
any funds specified in Schedule VII?
NA*
9 Does the Annual CSR Report specify detail of surplus arising out of CSR activities?
10 Does the Annual CSR Report specify whether surplus is ploughed back into the same project or transferred to an Unspent
CSR Account or transferred to funds specified in Schedule VII?

CSR reporting format for FY 2020-21 for TCS is as per Annexure II of the CSR Rules 2014, as
amended (2/2)
• Across 10 sub indicators, TCS has reported
compliance on 7, while 3 are not applicable for
the FY under review
• TCS has reported total CSR obligation as 2%
of Average Net Profit for FY 2020-21
• For FY 2020-21,excess amount of INR 11 Cr is
to be set-off against CSR obligations of future
years has been reported
• No unspent or surplus amount was generated for
FY 2020-21 and is therefore not applicable for
the year in review
7
3
Yes Not Applicable
Legend

TCS has reported administrative overheads for FY 2020-21 within the permissible limit of 5%
1 Has the company reported its administrative overheads in its Annual CSR Report?
Yes
2 Are the administrative overheads in line with the definition prescribed under the CSR
Rules?
3 Are the administrative overheads within the permissible threshold of 5%?
Key Insights
100%
• For FY 2020-21, TCS reported compliance across 3 sub indicators for
administrative overheads
• The amount reported was within the permissible threshold of 5%
Yes
Legend

Annual Action Plan and Impact Assessment is not applicable for the FY 2020-21
Given that the financial year under review is FY 2020-21,
formulation of annual action plan may not be a compliance
consideration
• TCS has undertaken internal impact assessments to monitor
and evaluate their CSR activities. However, this may not be
compliance consideration for FY 2020-21 since the mandate is
applicable on minimum one-year old projects completed on or after
22 January 2021
• Steps have been initiated to undertake Impact Assessment of
CSR projects through an independent agency in line with sub-
rule (3) of rule 8 of the Companies CSR Policy Rules 2014
 Has an annual action plan been duly formulated by the CSR
Committee?
 Does the plan include the list of CSR projects or programmes
approved to be undertaken?
 Are the CSR activities in line with the definition of CSR under
the CSR Rules?
 Does the plan include the manner of execution of such
projects or programmes?
 Does the plan include the modalities of utilisation of funds
and implementation schedules?
 Does the plan include monitoring and reporting mechanism
for the projects or programmes?
 Does the plan include details of need and impact assessment,
if any?
Sub indicator
 Has the company carried out Impact assessment for
projects as specified in Rule 8 of Companies (CSR Policy)
Rules, 2014, as amended from time to time ?
 Is the amount spent on impact assessment within the
permissible threshold of 5%?
 Is the impact assessment report (if conducted) placed
before the board and annexed to Annual CSR?
Sub indicator
Source: https://www.tcs.com/content/dam/tcs/investor-relations/financial-
statements/2020-21/ar/annual-report-2020-2021.pdf

A few good governance indicators for TCS CSR for FY 2020-21
A few good-to have indicators: while these are not a mandate, adoption of the same may be recorded as good
practice for the companies to report
Does the policy identify the focus/thrust areas of the company?
Does the policy have a mechanism of treatment of unspent CSR
amount in alignment with the Companies (Corporate Social
Responsibility Policy) Rules, 2014, as amended ('CSR Rules’)?
Are roles and responsibilities of company board given as per the
Companies (Corporate Social Responsibility Policy) Rules, 2014,
as amended?
Yes Not Applicable
Legend
Is the impact assessment report displayed on
company's website?
CSR Policy CSR Reporting CSR Implementation
In case the project is implemented through implementing
partners, is the necessary due diligence/background check
done for the them?
Was the amount disbursed to implementing partners spent
during the relevant financial year (FY 2020-21)?
Has the company obtained necessary fund utilisation report for
from the implementing partners for the funds?
Not Applicable implies that the indicator is not relevant for the FY
under review

A total of INR 674 Cr has been spent by TCS towards CSR in FY 2020-21
Total amount spent
on COVID 19
Geographical
Coverage
Average spend as a
percentage of
average net profit
Pan-India
~2.03
INR 273 Cr Number of
ongoing projects
Reported number
of beneficiaries
Number of
projects with more
than 1 crore outlay
18,00,000*
5
12
* The reported number of beneficiaries does not include the impact or outcome numbers

TCS spends as per Prescribed v/s Actual CSR Expenditure over the past three financial years
2018-19 2019-20 2020-21
Prescibed spend 542 600 663
Actual spend 434 602 674
542
600
663
434
602
674
0
100
200
300
400
500
600
700
800
CSR Amount (in INR crores)
Prescibed spend
Actual spend
• A total of INR 674 Cr has been spent by TCS towards CSR in FY 2020-21
• TCS has spent more than its CSR obligation in the last 2 financial years consecutively

TCS CSR spend across the Schedule VII activities
296
-
36
3 - - - - - - - - -
176
114
6 - - - - - - - - -
107 100
4
88 89
- -
256
- - - -
9
-
50
100
150
200
250
300
350
i ii iii iv v vi vii viii ix/a ix/b x xi xii
CSR Amount (in INR crores)
2018-19 2019-20 2020-21
Promotion of education
and livelihood
enhancement
Women
empowerment and
gender equality
Ensuring
environment
sustainability
Protection and promotion
of Art, Culture and
Heritage
Measures and
benefits for
armed forces
PM cares and central government
contributions
Preventive Healthcare
and eradication of
hunger
Promotion of
sports
Contribution to
incubators
Contribution to public
funded universities
Rural Development
Slum Development
Disaster relief
Most prominent areas addressed under schedule were Preventive Healthcare (i), Promotion of education (ii), Environment sustainability
(iv), Art, Culture & Heritage (v) and PM cares and government contributions (viii) in FY 2020-21
INR 189
Not Applicable
INR 1074
Not
Quantifiable
Spend Per Beneficiary for FY 20-21
Not Quantifiable
Not
Quantifiable
Not Applicable
Despite the reporting of spend in S(i),S(iii), S(iv), S(v) and S(viii), spend per beneficiary is not quantifiable as beneficiaries have not been reported for these
thematic areas

TCS spend bifurcation for FY 2020-21 in INR Crores
INR 107
16%
INR 100
15%
INR 3
1%
INR 88
13%
INR 89
13%
INR 256
38%
INR 8
1%
INR 22
3%
PM cares and central government
contributions
Administrative
expenses
Women empowerment
and gender equality
Ensuring Environment
Sustainability
Protection and promotion of
Art, Culture and Heritage
Slum
Development
Promotion of education
and livelihood
enhancement
Preventive Healthcare
and eradication of
hunger
PM cares and central government funds saw the
highest 38% i.e. INR 256 Cr out of INR 674 spent by TCS
for FY 2020-21
Preventive Healthcare and Promotion of Education
and Livelihood followed the highest contribution by TCS
with a an expenditure of INR 107 Cr and INR 100 Cr
respectively for FY 2020-21
Administrative expenses are around 3% for TCS for FY
2020-21
Slum development has the lowest expenditure of about
1% of the total 674 Cr
TCS has spent a total of 674 Cr on their CSR for FY 2020-21

CSR spend across geography over the years
427
599 625
0
100
200
300
400
500
600
700
2018-19 2019-20 2020-21
CSR Amount spent Pan-India in INR crores
PAN India
0.2 0.2
4.2
1.5
0.2
11.0
0.5
3.0
6.2
-
2.0
4.0
6.0
8.0
10.0
12.0
CSR amount spent in INR crores across states other than Pan-
India
FY 2020-21
States with high CSR Spend other than Pan-India
(in INR Crores)
Maharashtra 11
Uttar Pradesh 6
West Bengal 4
Tamil Nadu 3
Karnataka 2
Maharashtra has seen highest state spends in FY 2020-21 followed by Uttar
Pradesh and West Bengal
TCS has broadened its purview of spends YoY since FY 2018-19 to 2020-21
with a Pan-India approach

CSR amount spent through implementing partners is increasing over the years
3 6
32
427
599
652
-
100
200
300
400
500
600
700
2018-19 2019-20 2020-21
CSR spent in INR crores
CSR amounts spent directly by the company
CSR amounts spent through implementing agency
For FY 2020-21, almost 97 % of the total spends on CSR was done
through implementation partners and only 3 % of the total spends was
through direct implementation activities
2
1
3
0
0.5
1
1.5
2
2.5
3
3.5
2018-19 2019-20 2020-21
Administrative spend over the last three financial years
Admin spend as a % of overall spend
TCS has spent 3 % of its overall CSR spends for FY 2020-21 on
administrative expenses (vs ~1% in the year 2019-20)

Total number of CSR projects reported by TCS in FY 2020-21 is 24
5
19
Number of CSR Projects in FY 2020-21
Ongoing projects Other than ongoing
TCS has reported 24 CSR projects in FY 2020-21. Total CSR amount spent (exclusive of administrative expenses) was approximately INR 652
crores in FY 2020-21 as per Annexure II format, point 8(b) and 8(c) of the Companies (Corporate Social Responsibility Policy) Rules, 2014, as
amended in their Annual Report 2020-21.
Out of the 24 CSR projects reported in FY 2020-21, 80% of
the projects were reported as other than ongoing
5
647
Amount spent on CSR projects (in INR Crores)
Ongoing projects Other than ongoing
Out of the approx. INR 652 crores spent on CSR in FY 2020-
21, 99% of the amount was spent on projects other than
ongoing

CSR interventions focused on 7 thematic areas among CSR areas specified in Schedule VII of
Companies Act, 2013
TCS focused on 7 thematic areas for the CSR projects in FY 2020-21
Healthcare, water and eradication of
hunger and poverty
S(I)
Promotion of education and livelihood
enhancement
S(II)
Empowering women and reducing
inequalities
S(III)
Ensuring environmental
sustainability
S(IV)
Protection and promotion of art, culture
and heritage
S(V)
Contribution to central Government Fund
S(VIIII)
Disaster management and relief activities
S(XII)
Rural development
projects
S(X)
Thematic areas with no CSR intervention
by TCS in FY 2020-21
Measures for the benefit of armed forces
veterans
S(VI)
Contribution to government fund, PSUs,
public funding universities
S(IX)
Slum area development
S(XI)
Promotion of
sports
S(VII)

TCS carried out CSR interventions pan-India in FY 2020-21
► Andhra Pradesh
► Bihar
► Goa
► Gujarat
► Jharkhand
► West Bengal
► Karnataka
► Madhya Pradesh
► Maharashtra
► Manipur
► Mizoram
► Odisha
► Rajasthan
► Sikkim
► Tamil Nadu
► Uttarakhand
► Uttar Pradesh
► Haryana
► Himachal Pradesh
► Delhi
TCS carried out CSR interventions across 20 states/UTs in
India in FY 2020-21. They are:
Further, several of the projects by TCS have a multi-state presence,
hence making TCS’ reach pan-India
CSR Intervention

TCS employed varied implementation modes for different CSR projects in FY 2020-21
TCS has employed all three modes of implementation for the
CSR projects in FY 2020-21
Indirect
Implementation
3
Through captive
organizations
2
Direct Implementation
1
Following are the captive organisations which
TCS partnered with for CSR projects in FY
2020-21:
► Tata Medical Centre Trust
► TCS Foundation
► Taj Public Service Welfare Trust
► Tata Community Initiatives Trust
Out of the 24 projects reported by TCS in FY 2020-21
• 9 projects were undertaken through the mode of direct implementation
• 3 projects were undertaken through captive organisations
• 12 projects were undertaken through the mode of indirect implementation
9
12
3
Number of projects in FY 2020-21
Direct
implementation
Indirect
implementation
Captive
organisations

Alignment of projects with Sustainable Development Goals (SDGs) was showcased throughout the
report
TCS reported the alignment of CSR activities with 13 Sustainable Development Goals (SDGs) in their Annual Report FY
2020-21
Source: Home | Sustainable Development (un.org)
The Sustainable Development Goals (SDGs) reported
across each thematic area were in alignment with the
projects reported under the respective focus area

Outreach: TCS reported 18 lakh beneficiaries reached through TCS’ global community initiatives
► The beneficiary figures reported in the Annual Report
2020-21 include the numbers reached through both
Indian as well as global initiatives. Therefore, the
exact number of beneficiaries reached in India for FY
2020-21 is unclear
► Similarly, the beneficiary figures are reported only for
select projects and thematic areas and not for all.
For example, while the number of beneficiaries reached in India for FY 2020-21
under activities conducted within the thematic areas S(ii) and S(xii) can be
calculated, the same cannot be done for the rest of thematic areas as no
beneficiaries are reported in those areas
► The approximate spend per beneficiary was
calculated to be INR 3,744
TCS reported 18 lakh beneficiaries reached globally in
FY 2020-21
As for which projects or thematic areas these beneficiaries come under, is not clearly
decipherable
Promotion of education and
livelihood enhancement
Approx. 9,33,626 beneficiaries were
reached in FY 2020-21
Spend/beneficiary
Approx. INR 1073.77
S(II) Disaster management and relief
activities
4,50,000 beneficiaries were reached
in FY 2020-21
Spend/ beneficiary
INR 188.88
S(XII)
933,6
26
450,0
00
S(ii) S(xii)
The total beneficiaries reached in India across projects under
S(ii) and S(xii) is calculated to be approx. INR 13.8 lakh in
FY 2020-21.
Our Key Observations on Beneficiary Reporting
by TCS:
The beneficiaries reached figures in India for FY 2020-21 can be calculated only
for thematic areas S(ii) and S(xii), as follows:
1.The spend/ beneficiary has been calculated using the total number of beneficiaries
reported globally and the total CSR amount spent by TCS in FY 2020-21 as per TCS
Annual Report 2020-21
2.The calculation of beneficiaries in S(ii) is done by the dividing the total beneficiaries
reported globally by the number of countries the programs were conducted in FY 2020-
21
1
2

Impact: TCS has reported global impact till date for various projects under S(ii)
In the TCS Annual CSR Report 2020-21, impact till date has been represented at a global level in approximate percentages for multiple
projects in education, skilling, employment and livelihood theme.
Education
► 81% of learners encouraged their own children,
especially girls, to go to school.
► 75% reported that their self-esteem had increased
as a result of being literate.
► 67% reported that they were now more
participative in family decisions.
Skilling
► 80% of students showed higher order design
thinking skills.
► 55% wanted to continue using technology to
create solutions for the community.
► 70% of students showed an increase in empathy.
Employment
► 1.5x enhancement in income in comparison to
overall males employed in a rural area.
► 74% indicated an enhancement of status in the
family and community
Entrepreneurship
► 2x earnings for men in comparison to other self-
employed in rural areas.
► 95% indicated increased income and improved
standard of living.
► 92% women indicated higher self esteem at home.
► INR 4 crore aggregate earnings of entrepreneurs.
The impact is only reported for one
thematic area ( i.e. S(ii)). Impact has not
been reported for the other projects or
thematic areas
Target Beneficiaries
TCS largely focuses on the following
groups/ communities:
► Women/ girl students
► Youth
► Marginalised/ disadvantaged
communities

4
Good practices &
areas of
improvement

A few good practices by TCS
► TCS has been spending more than the CSR
obligation amount since the previous two financial
years
► TCS is the highest spender in the 15 group
companies
Spend
Key Awards & Recognitions in India
• Awarded by SHRM India for Excellence in Community Impact at the HR Excellence Awards 2020.
• Named the 2020 Corporate Citizen of the Year by Economic Times for demonstrating a deep commitment to society.
NOTABLE
HIGHLIGHTS FOR
TCS IN FY 2020-21
► TCS reported SDGs across each thematic area of
CSR intervention
► TCS reported human interest stories throughout the
report for projects conducted in the year
Strategy
► TCS CSR policy provides details on the focus/thrust
areas of the company
► TCS discloses its CSR policy and projects approved
by the board on the website
Compliance

Suggested areas of improvement for TCS
► TCS may want to mention the type of organisation
structure in the mode of implementation while
declaring spends (However, this is not a reporting
mandate)
Spend
SUGGESTED
AREAS OF
IMPROVEMENT
FOR TCS IN FY
2020-21
► The outreach and impact numbers can be provided in a geographically segregated manner to capture India-
specific numbers
► The outreach and impact could be reported for each thematic area of intervention. Currently, while spend is
provided for each Schedule VII list (owing to the mandate), beneficiary segregation is not available in the report
► An India-specific report can be considered to be formed, as opposed to a global report
Strategy
► TCS may consider providing information on the
amount disbursed to implementing partners spent
during the relevant financial year
Compliance

Definition of CSR expenditure as per the Companies Act 2013 and in line with the new definitions
of CSR expenditure
“Corporate Social Responsibility (CSR)” means the activities undertaken by a Company in pursuance of its statutory obligation laid
down in section 135 of the Act in accordance with the provisions contained in these rules, but shall not include the following, namely:-
C
• Activities undertaken in pursuance of normal course of business of the company:
• Provided that any company engaged in research and development activity of new vaccine, drugs and medical devices in their normal course of business
may undertake research and development activity of new vaccine, drugs and medical devices related to COVID-19 for financial years 2020-21, 2021-22,
2022-23 subject to the conditions that:
• Such research and development activities shall be carried out in collaboration with any of the institutes or organizations mentioned in item (ix) of
Schedule VII to the Act
• Details of such activity shall be disclosed separately in the Annual report on CSR included in the Board’s Report
• Any activity undertaken by the company outside India except for training of Indian sports personnel representing any State or Union territory at
national level or India at international level
• Contribution of any amount directly or indirectly to any political party under section 182 of the Act
• Activities benefitting employees of the company as defined in clause (k) of section 2 of the Code on Wages, 2019 (29 of 2019)
• Activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services
• Activities carried out for fulfilment of any other statutory obligations under any law in force in India
Source: https://www.mca.gov.in/Ministry/pdf/CSRAmendmentRules_22012021.pdf

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