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CSR Policy
Corporate Social Responsibility Policy
Introduction

The Board of Directors (“Board”) of Altico Capital India Private Limited (the “Company”) have adopted the Corporate Social Responsibility Policy (“CSR Policy”) based on the recommendation of the CSR Committee in accordance with the provisions of the CSR Charter dated February 16, 2015. The Policy reflects the CSR Charter which requires the CSR Committee the obligation to develop a CSR policy which reflects the Company’s adherence to the provisions Section 135 of the Companies Act, 2013 (“Act”) read along with the rules and schedules framed thereunder and as amended from time to time.

Applicability

This CSR policy guide all the CSR project(s) / programme(s) undertaken by the Company, as per the Schedule VII of the Act.

CSR Vision Statement

The Company, through its CSR project(s)/programme(s), will enhance value creation in the society and communities in which it operates, through its services, conduct and initiatives, so as to promote sustained growth for the society and community, in fulfilment of its role as a socially responsible corporate citizen.

CSR Objectives, Projects-Activities

In accordance with the CSR Committee Charter the Company will distribute its CSR funding around the following themes: Education, Personal Hygiene; Clothing for the Needy, and such other projects/programmes as may be recommended by the CSR Committee and approved by the Board.

Roles & Responsibilities of the Board of Directors

As detailed in the CSR Charter the Board of Directors is responsible for the appointment of a CSR Committee, its Chairman and committee members and approving a CSR Charter as recommended by the CSR Committee.

The Board of Directors is also responsible for ensuring that at least 2% of the average net profile of the Company over the three preceding years is spent on CSR initiatives in pursuance of its CSR policy.

In addition, the Board will be responsible:

  • To ensure that the reasons for any under spending and / or not spending of the allocated CSR budget are specified in the Board’s annual report;

  • To ensure that the surplus arising out of CSR activities is not considered as a part of the business profits of the Company and credited back to the CSR corpus;

  • To disclose in the Company’s Annual Report the composition of the CSR Committees, the CSR Policy and projects, the average net profits over the three last years, prescribed CSR spending, details of the CSR spending during the fiscal year, and a statement from CSR Committee that the implementation and monitoring of the CSR policy is in compliance with CSR objectives and Policy;

  • To place the content of the CSR Policy on the Company’s website, in such manner as may be prescribed; and

  • To ensure that in every financial year, funds committed by the Company for CSR projects/programmes are utilized effectively and monitored regularly.

The CSR Committee will be responsible for
  • Developing a CSR Policy;

  • Recommending the CSR activities to be undertaken;

  • Recommending the spending amount on each CSR project;

  • Monitoring the Company’s CSR policy;

  • Regularly updating the Board about Committee activities and making appropriate recommendations;

  • Ensure the Board is aware of matters what may significantly impact on the Company’s adherence to the rules; and

  • Advise the Board of any material regulatory changes.

The CSR Policy requires
  • All CSR projects/programmes detail the modalities of execution, implementation schedules, and monitoring processes;

  • Allow the Company to collaborate or pool resources along with other companies to undertake their CSR activities. Each company must separately report their CSR activities;

  • All CSR activities must be undertaken in India; and

  • That CSR activities which are for the exclusive benefit of employees or their families, contributions to political parties and activities in the normal course of business are EXCLUDED from CSR spending.

CSR Policy Implementation Process
  • CSR project/programme to be undertaken will be identified by the CSR Committee;

  • The CSR Committee shall recommend to the Board for approval, the CSR project/programme, specifying the mechanism of its execution and the expenditure to be incurred;

  • The time period over which a particular project/programme will be specified, for example, if such spending will occur over time, the extent of project/programme coverage and the intended impact;

  • The mode of implementation of CSR project/programme may include direct implementation or implementation through charity partners, government, own foundation, registered trusts or societies, civil societies, social partners etc. The same shall be selected after performing necessary due diligence;

  • The Company may avail services of external expert agencies, consultancy firms etc., for carrying out any survey, assessment or report with regards to any CSR project(/programme to be undertaken by the Company; and

  • The CSR Committee is authorised to settle all queries, differences or doubts that may arise in relation to the implementation of CSR project(s)/programme(s).

Monitoring and Reporting Framework

The Company will perform a periodic assessment of the relevance, performance, efficiency and impact of the CSR project/programme. The CSR implementing agencies will report on the project)/programme and the expenditure on a regular basis in addition to a yearly report which will include project/programme undertaken along with the incurred expenditure incurred, future plans of action for the subsequent financial year and any cash balance to be carried forward.

Progress on CSR initiatives will be reviewed and monitored on a half yearly basis by the CSR Committee and once in a financial year by the CSR to the Board.

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