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1. PREAMBLE
Corporate Social Responsibility is strongly connected with the principles of Sustainability; an
organization should make decisions based not only on financial factors, but also considering the
social and environmental consequences. As a Corporate Citizen receiving various benefits out
of society, it is our co-extensive responsibility to pay back in return to the society in terms of
helping needy people by providing foods, clothes, etc., keeping the environment clean and safe
for the society by adhering to the best industrial practices and adopting best technologies, and
so on. It is the Company’s intention to make a positive contribution to the society in which the
Company operates.
2. CSR POLICY: SCOPE AND OBJECTIVES
In order to carry out the charitable activities in a structured manner and to streamline and
provide more focus and direction to the activities undertaken by the Company in its sphere, it is
decided to formulate a policy on Corporate Social Responsibility (hereinafter described as “the
Policy”).
Further, Section 135 of the Companies Act, 2013 (hereinafter described as “Section 135”) and
the Companies (Corporate Social Responsibility Policy) Rules, 2014 (hereinafter described as
“the rules”) have also laid down Guidelines for CSR Programme for the Companies falling into
the criteria of mandatory provision for CSR which is Net Profit of rupees five crores or more
during a financial year.
This policy is formulated in line with the requirements of the Companies Act, 2013 (hereinafter
described as “the Act”) and shall be applicable on uniform basis.
3. CSR COMMITTEE
A. Composition:
The Corporate Social Responsibility Committee (CSR Committee) shall comprise of the
following Directors of the Board of Directors of the Company as members of CSR Committee:
Mr. Kuldeep Goel
Mr. Naveen Goel
B. Role: The Committee, referred above, shall
a. formulate and recommend to the Board, a Corporate Social Responsibility Policy which
shall indicate the activities to be undertaken by the company as specified in Schedule VII
of the Companies Act, 2013;
b. recommend the amount of expenditure to be incurred on the activities referred to in
clause (a);
c. monitor the Corporate Social Responsibility Policy of the company from time to time.
d. Institute a transparent monitoring mechanism for implementation of the CSR projects or
programs or activities undertaken by the company.
e. Any other matter as the CSR Committee may deem appropriate to discharge its
functions or as may be directed by the Board of Directors from time to time.;
4. AREAS OF ACTIVITIES TO BE UNDERTAKEN : All the following activities are
OnGoing in Nature
(i) Activities towards, eradicating hunger, poverty and malnutrition, promoting preventive
health care and sanitation and making available safe drinking water:
(ii) Activities promoting education, including special education and employment enhancing
vocation skills especially among children, women, elderly, and the differently abled and
livelihood enhancement projects;
(iii) Activities towards 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;
(iv) Activities ensuring environmental sustainability, ecological balance, protection of flora and
fauna, animal welfare, agro forestry, conservation of natural resources and maintaining
quality of soil, air and water;
(v) Activities towards protection of national heritage, alt and culture including restoration of
buildings and sites of historical importance and works of art; setting up public libraries;
promotion and development of traditional and handicrafts:
(vi) Measures for the benefit of armed forces veterans, war widows and their dependents;
(vii) Training to promote rural sports, nationally recognised sports, paralympic sports and
Olympic sports;
(viii) contribution to the Prime Minister's National Relief Fund or any other fund set up by the
Central Government for socio-economic development and relief and welfare of the
Scheduled Caste, the Scheduled Tribes, other backward classes, minorities and women;
(ix) contributions or funds provided to technology incubators located within academic
institutions which are approved by the Central Government
(x) rural development projects.
The Company will review the sectors from time to time and make additions / deletions /
amendments and suitable Allocations to the above sectors.
♦ CSR AMOUNT SHALL NOT BE SPENT FOR THE FOLLOWING ACTIVITIES: A. Activities
undertaken by the company in the normal course of the business. B. Activities undertaken by
the company outside India except for training of Indian sports personnel. C. Contribution to any
political party directly or indirectly. D. Activities benefitting employees of the company. E.
Activities carried out for fulfilment of any other statutory obligations under any other law. F.
Activities supported by the companies on sponsorship basis for deriving marketing benefits for
its own products and services.
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5. Activities not Allowed
CSR AMOUNT SHALL NOT BE SPENT FOR THE FOLLOWING ACTIVITIES:
a. Contribution to any political party directly or indirectly.
b. Activities undertaken by the company outside India
c. Activities supported by the companies on sponsorship basis for deriving marketing
benefits for its own products and services.
d. Activities benefitting employees of the company.
e. Activities carried out for fulfilment of any other statutory obligations under any other law.
6. IMPLEMENTATION OF CSR ACTIVITIES
CSR initiatives of the Company shall consider the following parameters for
identification/selection of schemes/projects:
(i) Local Areas shall be preferred
(ii) The time frame and periodic milestones shall be finalized and reviewed.
(iii) CSR activities may be implemented
a. Either Directly
b. Or through specialized agencies, like
(1) Community based organizations;
(2) Elected local bodies such as Panchayats;
(3) Voluntary Agencies (NGOs), Trusts, Missions,Self-help Groups in the form of
registered societies;
(4) Contracted agencies for civil works;
(5) Professional Consultancy Organizations, etc.
While assigning CSR projects to specialized agencies, every possible effort shall be made to
verify the reliability and clean track record of such agencies.
The Company shall generate awareness among all levels of their staff about CSR activities and
the integration of social processes with business processes. Those involved with the
undertaking of CSR activities shall be provided with adequate training and re-orientation.
6. THE CSR BUDGET
1. The amount of expenditure to be spent for CSR shall be as calculated based on the
formula given by the section 135.
2. The Brought forward and carry forward CSR expenses shall be adjusted as per law.
7. PROCEDURE FOR CSR ACTIVITIES
1. The selected projects, programmes or activities undertaken in each financial year will be
recommended by the CSR Committee of the Company
2. The above will be approved by the Board of Directors with or without modification in their
meeting as may be required.
8. TERRITORY FOR CSR SPEND
The Company should give preference to the local area and areas around the project sites,
registered office, branch offices and administration offices of the Company for spending the
amount earmarked for CSR activities
9. CSR MONITORING AND REPORTING MECHANISM
The CSR Committee shall monitor the amount of expenditure as approved by the Board of
Company. Apart from the above, the Directors’ Report of the Company shall include an annual
report on CSR containing the particulars in the prescribed format. CSR initiatives of the
Company will be reported in the Board’s Report in compliance with Section 135 and rules made
thereunder.
10. AMENDMENT TO THE POLICY
The Board of Directors may amend this Policy from time to time as the situation warrants and as
may be recommended by the CSR Committee.
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