Corporate Board : Duties, Responsibilities and Liabilities

 

Corporate Governance is concerned with the functioning of Board of Directors (BODs) –its structure, styles, process, their relationships and roles, activities etc. As Tricker (2019) says, “Corporate Governance addresses the issues facing Boards of Directors”.

The new Companies Act, 2013 makes a laudable contribution towards stipulation and elucidation of the duties and responsibilities of the directors of a company, more so of public limited companies. It removed the deficiencies of the old Companies Act, 1956 and improves the growth and prosperity of the corporate world in India. It increased the ambit of director's duties and responsibilities and explicitly clarifies (for providing a greater certainty to the directors with regards to their responsibilities and conduct) them and thus, ensures a better corporate governance and management.

DUTIES

The functioning of the corporate governance is concerned mainly with the Board of Directors. Directors are appointed by the shareholders, who sets the overall policy for the company and they appoint some persons to be the managing director/ executive director/ whole time director by the prior approval of shareholders.

A director of the company must act in accordance with AOA. A director of a company shall act in good faith in order to promote the objects of the company for the benefit of its members/ shareholders as a whole, and in the best interests of the company, its employees, the shareholders, the community and for the protection of environment.

A director of a company shall exercise his duties with due and reasonable care, skill and diligence and shall exercise independent judgment.

A director of a company shall not involve in a situation in which he may have a direct or indirect interest that conflicts, or possibly may conflict, with the interest of the company.

A director of a company shall not achieve or attempt to achieve any undue gain or advantage either to himself or to his relatives, partners, or associates.

A Director must ensure that all the affairs of Company are being done in best possible way and without compromising on legal Compliance of the Company and at same time which are not prejudicial for the interest of Company.

Thus Corporate Board duties can be summarized as follows:

1. Provide continuity for the organization 


2. Select and appoint a chief executive 


3. Govern the organization by broad policies and objectives


4. Acquire sufficient resources for the organization's operations


5. Account to the stockholders (in the case of a for-profit) or public (in the case of a nonprofit) for the products and services of the organization and expenditures 

Let us look at these items in a deeper manner:

1. Provide continuity for the organization by setting up a corporation or legal existence, and to represent the organization's point of view through interpretation of its products and services, and advocacy for them

2. Select and appoint a chief executive to whom responsibility for the administration of the organization is delegated, including:

- to review and evaluate his/her performance regularly on the basis of a specific job description, including executive relations with the board, leadership in the organization, in product/service/program planning and implementation, and in management of the organization and its personnel

- to offer administrative guidance and determine whether to retain or dismiss the executive

3. Govern the organization by broad policies and objectives, formulated and agreed upon by the chief executive and employees, including to assign priorities and ensure the organization's capacity to carry out products/services/programs by continually reviewing its work

4. Acquire sufficient resources for the organization's operations and to finance the products/services/programs adequately

5. Account to the stockholders (in the case of a for-profit) or public (in the case of a nonprofit) for the products and services of the organization and expenditures of its funds, including:

- to provide for fiscal accountability, approve the budget, and formulate policies related to contracts from public or private resources

- to accept responsibility for all conditions and policies attached to new, innovative, or experimental products/services/programs.

Directors owe a fiduciary dutyto the company and are expected to show the utmost care, diligence and skill in the exercise of their power and decision-making. They are expected to execute their duties in a manner that does not conflict with their personal interests and must disclose to the board their direct and indirect interests in any business dealing concerning the company. If there is a conflicting personal interest, they are mandated to refrain from participating in such a decision-making process. However, in the case of private companies, the interested director may participate in the meeting after disclosure of his or her interest. Specific duties of care are prescribed for directors in cases of related-party transactions (RPTs). Further, IDs have to adhere to the Code, which also prescribes certain duties of care or prudence.

Directors can be executive or non-executive. The managing director (MD) (who is an executive director) is entrusted with substantial management powers under the company’s AOA, other agreements, or resolutions passed by the shareholders or the board. Executive directors employed by the company are responsible for discharging duties as per their terms of employment and are usually assigned duties related to finance, human resources and legal compliance. Non-executive directors participate in the board’s decision-making process and discharge other duties that may be entrusted upon them.

IDs take part in the decision-making process at the board, the audit committee, the NRC and the corporate social responsibility (CSR) committee meetings. They bring about ‘independence’ to the decision-making process and generally ensure the company’s compliance with the corporate governance norms.

Owing to the varied roles of the directors, the Companies Act 2013 follows the concept of ‘officer who is in default’ as persons responsible for the breach of the provisions of the Companies Act.

 

RESPONSIBILITY

The Board of Directors focuses on four key areas:

  1. by establishing vision, mission and values;
  2. by setting strategy and structure;
  3. by delegating authority and responsibility to management; and,
  4. by exercising accountability to shareholders and be responsible to relevant stakeholders.

Thus there are some responsibilities which board of directors has to shoulder:

      Determining the company’s strategic objectives and policies.

      Monitoring progress towards achieving the objectives and policies.

      Appointing senior management.

      Accounting for the company’s activities to relevant parties, e.g. shareholders.

      It covers observing transparency and disclosing every material fact or report to be disclosed. Other key functions include monitoring the effectiveness of company’s governance practice, setting performance objectives, aligning board remuneration and other key executive with interest of the company and shareholders etc..based on the principles layed out in Listing agreement clause 49(1).

    DIRECTORS’ POWERS

The decisions which must be made by a resolution of the members are:
Most of the companies have not inserted any special article or did not pass any resolution which says that director does not possess the power to perform certain actions. But according to the Act, it needs a resolution in general meeting which specifies this type of power. The following decisions should be made by the directors but usually also require a resolution of the shareholders:

  • Some loans to directors
  • Directors’ fixed term service contracts for more than 2 years
  • Substantial property transactions in which directors have a personal interest
  • Issue shares
  • Delegation to individual directors:-

The powers noted above are given to the directors collectively. For this, the board must delegate power to the director concerned. Both the Model Articles and Table A permit this.


Liabilities of Director in a Company

The Liabilities of Director of Company are broadly defined in two categories:

1.   Liability to Stakeholders: 

The directors are not personally liable to stakeholders if they act within the scope of powers vested in them. The general rule in this regard in that wherever an agent is liable, those directors would be liable, but where the liability would attach to the principal only, the liability is the liability of the company. The Director shall also be liable in case of negligence & fraud by the Company, knowingly making any mis-statement or sharing false-information with the stakeholder, Failure to repay deposits on time, payment of dividend out of capital and entering into contract with related parties.

2.    Liability to Company: 

The directors shall be liable to the company for the following:

  1. Where they have acted ultra-vires the company: Directors have powers subject to Companies Act, Memorandum and Articles of association. Whenever they exceed these limits they are personally liable for the act being ultra vires. But if acts are intra-vires the company such acts can be subsequently ratified by the shareholders in the general meeting, otherwise, if a company suffers a loss on ultra-vires acts of its directors, the company can claim such loss from the directors.

  2. When they have acted negligently: Negligence may give rise to liability; there need not be fraud. But they will not be liable where they have acted bonafide and for the benefit of the company. However, the error of judgement will not be deemed as negligence.

  3. Where there is a breach of trust: Directors are the trustees for the money and property of the company. They hold an office of trust and if they misuse their powers they will be liable for breach of trust and may be required indemnify the losses incurred to Company. They also need to make regular disclosures on their profits, if any, earned in course of the performance of duties. Director can also be held liable for misconduct, provided it is not willful.
      
  4. Misfeasance: Directors are liable to the company for misfeasance. The word misfeasance covers willful negligence. Mere failure on the part of the director to take necessary steps for recovery of debts due to the company does not constitute misfeasance. If the company is in the course of winding up, the court may, on the application of the liquidator, creditor or contributory examine the conduct of a director for any misfeasance or breach of trust in relation to the company.

How does the Duties & Responsibilities of Corporate Board change over the life span of the business?

A company passes through several stages in its life cycle. In the first stage ‘Start-up’ strategy is developed and implemented by the founder and a close team.

At this stage it is not often clear who is doing what. The team will switch from their shareholder role, to their executive role and then their board role quickly whenever the need arises.

Usually, whichever role the founder plays most can be said to be the place in the organisation where the strategy is developed.

As the company enters the second stage ‘Growth’ more people join and the roles start to be defined with greater clarity.

Skilled or qualified staff start to offer their inputs to strategy and the board needs to be explicit about the sharing of the roles to ensure that efforts are coordinated so that people feel engaged.

Failure to separate and define roles will lead to dissent and disorder.

Failure to share opportunities to contribute will disenfranchise management.

The board need to be especially vigilant that the founder does not continue to dominate the process although they may still design the process so that the founder has the final say.

Eventually growth will start to slow down. This is a stage at which a company needs to focus efforts on internal effectiveness, systems and processes.

It is also a stage during which the strategy development, in good companies, is formally delegated to the now strong and experienced management team and the board moves into the more traditional role of understanding, testing and endorsing strategy.

 Much will depend on the decision of the founder to remain as an executive (usually CEO) or to move to a non executive role (often Chairman but not necessarily always so).

If the transition is an abrupt or unexpected slowing of growth and represents a deviation from agreed plans it is not uncommon for a board, at this stage, to step in and remove the CEO or undertake other actions to restructure management so as to gain better visibility of the path ahead.

 If the transition is smooth, expected and well prepared for then the role of the board is not as overt.

At this point the company needs to decide if there are additional activities they wish to undertake that would effectively renew the organisation and continue the growth or if they are happy to transition to a less volatile mature operating state as the company becomes ‘Sustainable’ or ‘Mature’. This is the stage of life of most large blue chip organisations.

They undertake enough new developments to maintain their sustainability but never so many that they revert to the risky volatile growth phase.

Outcomes are expected to conform to plans and the board spends as much or more time monitoring strategy implementation as they do developing strategy.

Finally the organisation will enter the stages of decline and, if this is not arrested by reinvention, decay.

A good board will be alert for indications that decline is imminent and will ensure that management are challenged with the task of developing new strategies for growth to counteract the tendency of the organisation to drift into these stages.

Companies in decline are often paradoxically very profitable as investment in new lines of business and growth projects slows whilst tried and tested products are efficiently produced and sold.

Many family businesses enjoy this phase as a means of creating funding for the retirement of the founder.

Other businesses work hard to transcend the tendency towards decline and decay.

The board may, again, need to become more active (and possibly even forceful) to ensure that management focus their efforts appropriately depending on the owners’ desires for the organisation.

Some not-for-profit businesses look forward to these stages as they will indicate that the mission has been achieved;

When a cure is found for cancer most cancer-related charities will focus on transitional arrangements to assist current sufferers, on providing information about the cure and on closing down in an honourable manner. A few will move into other disease related work whilst most will seek to exit the marketplace.

For commercial companies the imperative will be to either create new business streams or to return capital to the shareholders whilst meeting obligations to stakeholders. The board must step into their role as the ultimate endorsers of strategy during these phases.

 The Companies Act 2013 and the Listing Obligations and Disclosure Requirements 2015(LODR) have embodied these aspects as can be seen from the details given below:

  Both the Audit Committee and the Nomination and Remuneration Committees need to be constituted as per Section 177 of the Act read with rule 6 of the Companies (Meetings of  the Board and its Powers) Rules, 2014, every Listed Public Companies and Public Companies having a Paid-up share capital of 10 crore rupees or more, and a turnover of Rs. 100 Crore or more .

Additionally All Public Companies which have in aggregate outstanding loans, debentures and deposits exceeding 50 crore rupees are required to constitute an Audit Committee as also the Nomination and Remuneration Committee.

Under Section 178 of the Companies Act 2013, every company which has more than 1000 shareholders, deposit holders or other security holders, shall constitute a Stakeholders Relationship Committee (‘SRC’), with a  non-executive director as Chairperson with the objective of grievance redressal of various stakeholders.

 Sec 135 (1) of Companies Act 2013 read with rule 3 of Companies (Corporate Social Responsibility Policy) Rules, 2014, mandates  that every company having :

Net worth of not less than Rs.500 crores or more

or Turnover of not less than Rs. 1000 crores or more

Or Net Profit of Rs.5crore or more shall constitute a Corporate Social Responsibility Committee.

 

Networth, Turnover or Net Profit are according to Financial year and has been clarified as to imply any of the three(3) preceding financial years.  Such companies has to earmark 2% of it’s net profits and should be spent on CSR activities

 SEBI LODR Regulation 2015 Regulation 21, the Top 500 listed entities determined on the basis of market capitalisation at the end of immediate previous financial year need to have Risk Management Committee


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