CSR Policy

Our vision for CSR continues to reflect the programs that we have undertaken through decades. These also qualify as CSR initiatives under S.135 of the Companies Act, 2013 (“the Act”) read with Schedule VII of the Act and The Companies (Corporate Social Responsibility Policy) Rules, 2014 (“CSR Regulations”).

We are committed to sustainable and reliable initiatives in areas of education, health care and environment. We would undertake these initiatives within our corporate structure by formulating and implementing programs in the initiatives mentioned below. Furthermore the Board may also undertake, such programs through a third party entity as permissible under the Act and or the Regulations.

Promoting education and employment enhancing vocation skills, by providing opportunities for learning, acquiring knowledge, building technical and vocational competence inter alia, through :

• Government schools and colleges
• Libraries
• Child development
• Women empowerment
• Awareness programmes
• Programs on Technology and Partnering with Industrial Training Institutes
• Vocation Training

Promoting healthcare through :

• Prevention and Awareness Programs
• Nutritional programs
• Health care facilities
• Providing health care equipment & medication
• Health oriented technology incubators

Promoting environmental sustainability, ecological balance, and protection of flora and fauna through:

• Awareness for protection and Preservation of flora and fauna
• Institutes and organisations for preservation and protection of flora & fauna
• Ecological balance and Animal Welfare
• PMO Relief Funds during natural calamities

Activities specified under Schedule VII of the Act

CSR Committee comprises of:

• Leena Gandhi Tewari: Chairperson
• M Venkatachalam: Director
• Vilas Tewari: Director
  
  The CSR Committee shall operate as per the CSR Policy. The Committee shall also formulate and recommend to the Board for its approval the CSR activities/initiatives to be undertaken by the Company including the expense to be incurred on such activities. The Committee shall function under the approach and direction given by the Board and as per the CSR policy.

To Execute and monitor the CSR Activities, the CSR Committee has formed an operating team.

Guiding principles for selection, implementation and monitoring of CSR Activities

Selection of CSR Activities

Sustainable projects / programs will form part of the CSR Activities. These may be altered from time to time by the Board on the recommendation by the Committee with respect to their scope and allocated budget. The Committee shall evaluate the projects to be undertaken as CSR Activity and shall recommend to the Board the identified projects which fit into the vision and comply with the requirements under the Companies Act, 2013. The CSR Activities recommended by the CSR Committee to be approved by the Board.

Implementation of CSR Activities

Identified CSR Activities implementation strategy is as under :

• Direct : Most CSR Activities to be conceptualized and executed directly through the operating team and professionals. Operating team, under the supervision and guidance of the Chairperson of the CSR Committee, shall identify/execute and monitor the CSR Activities. CSR Activities may also be implemented with the help of contractors/facilitators having technical expertise and experience to achieve improved outcomes.
  
• Indirect : Company may contribute the CSR amount to the entities having CSR Registration Number for certain projects which fit into the vision of the Company and comply with the CSR requirements under the Companies Act, 2013 as also the Regulations. Company may also make contribution to the Funds specified under Schedule VII to the Companies Act, 2013.

Monitoring of CSR Activities

CSR Activities monitoring is being done by the Operating Team in following manner :

• Direct CSR Activities are being monitored on a continuous basis.
• Indirect CSR Activities are being monitored based on defined milestones in the agreement with the third party entity. Contributions are being released upon completion of defined milestones of the such CSR Activities.
• Impact Assessment Studies of the specific projects to be carried out by independent agencies in compliance with the requirement under the Regulations.

The operating team tracks the progress of the CSR Activities, provides continuous updates on the progress of the CSR Activities and appraises the CSR Committee of the same. The Committee evaluates the progress of the CSR Activities and presents the same before the Board for approval.

Annual Action Plan

The surplus arising out of the CSR Activities shall not form part of the business profit of the Company.

The CSR Committee proposes the annual action plan to the Board for approval. Annual Action Plan includes:

• List of CSR Activities that are proposed to be undertaken as per CSR policy and Schedule VII of the Act.
• The manner of execution of such CSR Activities - direct or indirect through permitted entities/agencies specified in the Regulations.
• The modalities of utilisation of funds and implementation schedules for the CSR Activities.
• Monitoring and reporting mechanism for the progress in the CSR Activities. and
• Details of need and impact assessment, if any for the CSR Activities undertaken by the Company.