The concept of Corporate Social Responsibility (CSR) has gained prominence from all avenues. Organizations have realized that government alone will not be able to get success in its endeavor to uplift the downtrodden of the society. With the rapidly changing corporate environment, Saral Pathlab Pvt. Ltd. (SPPL) has adopted CSR as a strategic tool for sustainable growth. SPPL has formulated the present 'CSR Policy containing a set of internal approaches/guidelines/principles to be followed while discharging CSR at different levels and as law-abiding corporate entities SPPL will adhere to all such statutes related to CSR in right earnest as and when applicable. In the aforesaid backdrop, CSR policy of SPPL has been framed after incorporating the features of the Companies Act 2013 including amendments to it and notifications issued by Ministry of Corporate Affairs (MCA) from time to time.
The main objective of CSR policy is to lay down guidelines for SPPL to make CSR a key business process for sustainable development for the society.
3. ALLOCATION OF FUND FOR CSR
SPPL shall spend for CSR 2% of average net profit of the company for the three immediate preceding financial years, as per the provision of the Companies Act, 2013. Any unspent or excess amount from CSR budget in a financial year would be accounted for as per the provisions of the extant statute. The basis for calculation of unspent or excess amount shall be the amount required to be spent as per the statutory provisions.
4. SELECTION OF CSR PROJECTS/ACTIVITIES
4.1 AREAS TO BE COVERED
SPPL are located in different parts of the state of Bihar and Jharkhand hence, the primary beneficiaries of CSR activities shall be the areas near by its installations, function and district(s) in which the functions of the Company is going on. SPPL shall ensure that the maximum benefit of their CSR activities goes to the underprivileged sections of the society. CSR activities should be undertaken as per Schedule VII of Companies Act issued from time to time.
4.2 SCOPE OF PROJECTS/ACTIVITIES
SPPL would select CSR activities out of the themes listed in Schedule-VII of the Companies Act as amended from time to time. The themes in the scope of CSR policy must be interpreted liberally so as to capture the essence of the subjects enumerated in Schedule VII of Companies Act. Any modifications in Schedule VII of Companies Act shall also deem to have been incorporated in the scope of CSR policy of SPPL from the date of such changes being notified by the Government.
5. INSTITUTIONAL ARRANGEMENT
As per the provision of the Company’s Act as of now there is no requirement of Committee however, one of the director of the Company should be directly involved in the decision, selection of activity and shall monitor and review the progress of CSR activities from time to time. Both of Directors of SPPL are empowered to approve modalities and selection of institutional arrangements if any and implementing Standard Operating Procedures for implementation of CSR works as per CSR policy.
- Around the beginning of every financial year, the designated person / department for CSR will design an Annual Action Plan. Extant statute as regard to Annual Action Plan shall be abided.
- Activities under CSR except those relating to contribution to funds specified in Schedule VII shall be in project mode and for every project, time framed periodic milestones should be finalized at the outset.
- As far as possible, the project should be completed within 2 years from the start and in no case, projects with duration exceeding three years from the start date shall be undertaken. The date of starting of work or release of first installment, whichever is earlier, shall be considered as project starting date and that year shall be considered as project start year. Director of SPPL shall monitor the implementation of ongoing projects with reference to the approved timelines and year-wise allocation and shall make modifications, if any, for smooth implementation of the project within the overall permissible time period. The designated person / CSR department of SPPL shall put up a progress report of all ongoing projects for review, preferably once in a quarter.
- Activities identified under CSR shall be implemented either by SPPL departmentally or through implementing agencies as per extant statute.
- Implementing agencies having only local presence shall be considered only for small value projects of up to Rs. 1.00 lakhs.
- Need and justification of all CSR projects / activities shall have to be ascertained. Need assessment shall be carried out either departmentally using in-house expertise or through external reputed agencies including implementing agencies.
- The suggestions given by the elected representatives/bodies shall be duly considered while finalizing the CSR activities.
- Memorandum of Understanding (MoU) shall be signed with all implementing agencies for projects having value more than Rs. 1.00 lakhs.
- Extant statute as regard to Impact Assessment of CSR Projects are to be abided.
- Extant statute as regard to Creation and acquisition of Capital assets are to be abided.
- Extant statute as regard to Surplus arising out of CSR activities are to be abided.
7. DATA MANAGEMENT
All the data related to CSR shall be maintained on a real-time basis with an inbuilt mechanism for periodic report generation.
8. MONITORING AND REPORTING
- SPPL Director shall satisfy themselves that CSR funds disbursed have been utilized for the purposes and in the manner as approved and the Director shall certify to that effect.
- Utilization Certificate with a statement of expenditure duly certified by a Practicing Chartered Accountant/Authorized Auditor shall have to be submitted by the implementing agencies for the CSR fund provided to them as a one-time grant or in installments. Public authorities may submit Utilization Certificates as per General Financial Rules (GFR) of Govt. of India/State Govt./District level Class – I officer/Divisional head of implementing agency.
- Both directors together of SPPL would decide which of the CSR projects are to be audited by an external.
- SPPL Board shall ensure that the administrative overheads shall not exceed five percent of the total CSR expenditure of the company of that year.
- SPPL subsidiaries shall take CSR mileage by leveraging print, electronic and digital media.
9. DUE DILIGENCE
SPPL and its subsidiaries would comply with all statutory provisions on CSR and the amendments thereto, as promulgated from time to time. SPPL would also comply with all rules, regulations, guidelines, orders, directives, or any such communication issued by the Central Govt. from time to time. In case of any statute coming into effect where there is already a policy provision, the said statute, from its effective date will substitute and prevail upon such policy provision. Wherever applicable, the definitions of terms such as ongoing project, administrative overheads, etc. as given in the CSR rules notified/circulated by Ministry of Corporate Affairs, Government of India from time to time shall apply.
10. LIMITATION AND AMENDMENT
The CSR policy of the company will be governed by provisions under Companies Act, 2013, or any other act that may be introduced, Government guidelines, and any other govt. instructions applicable from time to time.