It's enough to pick a contractible manifold $M$ with two non-homotopic actions. For example, let us pick $M=\mathbb{R}^2$ with two actions of $S^1$, the trivial one and the one given by rotations. These two actions are not homotopic. In fact for every action $\rho$ of $S^1$ on $\mathbb{R}^2$ we can consider the map $\mathbb{R}^2\times S^1\to GL_2^+(\mathbb{R})$ sending $(x,\lambda)$ to the differential of $\rho(\lambda)$ at $x$. This map is clearly homotopy invariant under the action, and its degree as a map $S^1\to S^1$ is 0 for the trivial action and 1 for the defining action. However all continuous maps with target $\mathbb{R}^2$ are homotopic.