CSR Policy

Preface

At OutsourcingHubIndia.com, it is our conviction that the engagement with social issues must be deep, meaningful, and formed on the bedrock of long-term commitment; for that is the only way by which real change can happen on the ground. This is also reflective of the fact that such an approach serves both, enlightened business interest and social good. We run our social programs on a strong foundation of ethical principles, good governance, and sound management. This includes, among other things, holding ourselves up to public scrutiny through a framework of transparent, rigorous reporting.

We are committed to further capacity building, empowerment of communities, inclusive socio-economic growth, environment protection, promotion of green and energy-efficient technologies, development of backward regions, and upliftment of the marginalized and underprivileged sections of society.

Objective and Purpose

The key purpose of this Policy is to:

• Outline the development areas in which the Company shall get involved
• Define governance structure for CSR management within the Company
• Serve as a guiding document aiding the identification, execution, and monitoring of the CSR projects
• Describe the treatment of surpluses from CSR activities
• Define the approach and direction of the Board of the Company regarding CSR activities
• Provide guidance for the selection, implementation, and monitoring of activities
• Formulate an Annual Action Plan every year as per applicable rules

Areas to Emphasize

Education

• Promoting education, including special education and employment enhancing vocation skills, especially among children, women, elderly, and the differently abled and livelihood enhancement projects.

Environment Sustainability

• Ensuring environmental sustainability ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources, and maintaining the quality of soil, air, and water.

Protection of National Heritage

• Protection of national heritage, art, and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional arts and handicrafts.

Medical and other Welfare

• Providing medical relief and rehabilitation to communities who either don’t have access to quality health care or cannot afford it
• Eradicating hunger, poverty, and malnutrition, promoting health care, preventive health care, and sanitation, and making available safe drinking water
• 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 castes, the scheduled tribes, other backward classes, minorities, and women
• Contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government

In addition to the Areas to Emphasize specified above, the Company may select any area/ sector/ activity or head of activities, as may be specified in Schedule VII to the Companies Act, 2013 including any amendments or modifications as may be introduced from time to time.

Board’s Rights and Responsibilities

Following rights and responsibilities vests with the Board of the Company in connection with the CSR Policy and framework:

• To approve the CSR Policy
• To ensure that Company makes mandatory disclosures in the Company’s Annual Reports and website, relating to CSR Policy, and the activities undertaken
• To ensure annual reporting of CSR Policy and activities to the appropriate governmental authority as mandated by applicable law
• The Board shall approve the CSR policy and oversee that identified work is duly undertaken and that in each financial year at least 2% of the average net profit of the preceding three financial years is spent effectively
• To ensure that the funds so disbursed have been utilized for the purposes and in the manner, as approved by Board
• To approve for transfer of unspent CSR Amount if any in accordance with the law
• In case of an ongoing project, the board shall monitor the implementation of the project with reference to the approved timelines and year-wise allocation and shall be competent to make modifications, if any required

CSR Budget

• The Board of the Company will ensure that in each Financial Year (FY), at least two percent of the average net profit (calculated as per Section 198 of the Act) accrued during the three immediately preceding FYs, is spent on CSR projects/programs
• In the event of the company failing to spend the allocated annual budget, reasons for not spending will be provided in the Company’s Annual Report
• The computation of average net profits will be carried out in accordance with the provisions of Section 198 of the Companies Act, 2013
• The unutilized CSR budget from the two (02) percent of the average net profit, if any, will be transferred to a separate bank account within 30 days from the end of the financial year
• The Board shall make disclosures in the Annual Report as per clause (o) of sub-section (3) of section 134 including particulars specified in annexures to the CSR Rules
• Surplus arising out of CSR projects, programs, or activities shall not form part of the Company’s business profits. Instead, the same will be further deployed for future CSR projects only

Monitoring Mechanism

• The goals and objectives along with the annual budgets of CSR to be discussed and signed off at the beginning of every financial year with the Board of Directors
• The Board of Directors shall formulate an annual action plan in pursuance of its CSR policy which includes:
  – list of CSR projects to be undertaken
  – the manner of execution of such projects,
  – utilization of funds,
  – monitoring and reporting mechanism for the projects or programs; and
  – details of need and impact assessment, if any, for the projects undertaken
  by the Company
• Along with the approval of the annual plan, the Board to review the progress of all key programs vis-à-vis objectives for the previous year including effective utilization of the funds and a formal assessment of outcomes and impacts as considered relevant

Special Unspent CSR Account

• A special bank account called an Unspent CSR Account for each financial year to be opened by the Company in any scheduled bank. The account shall be credited with the following:
• Any amount remaining unspent pursuant to any ongoing project, undertaken by a Company in pursuance of its CSR Policy shall be transferred by the Company to the unspent CSR Account within a period of thirty days from the end of the financial year
• The amount transferred to the unspent CSR account shall be spent by the Company in pursuance of its obligation towards the CSR Policy within a period of three financial years from the date of such transfer
• Any surplus amount from CSR Project which is discontinued or completed
• For ongoing projects, if the Company fails to spend the amount within a period of three financial years, the amount shall be transferred to a Fund specified in the Act and rules made there under, within a period of thirty days from the date of completion of the third financial year

Disclosure

The Company shall comply with Section 135 (2), 135 (4) (1), and 134 (3)(o) of the Act thereby ensuring that it makes full disclosure of its CSR Policy, Strategy, Projects /Programs, Activities, monitoring mechanism, Implementing Agencies, Expenditure details as well as the composition of the CSR Committee of the Board (If applicable).

Reporting

The Company will, at the beginning of the Financial Year following the year being reported upon, make a full report of its CSR projects /programs in the format prescribed for ‘The Annual Report on CSR Activities ‘(Annexure B). This will be in consonance with Section 134 (3) (o) of the Companies Act.