CORPORATE SOCIAL RESPONSIBILITY POLICY

1. PREFACE

1.1 Section 135 of the Companies Act 2013, dealing with Corporate Social Responsibility, has become operational from 1st April 2014. The Section has prescribed that the Corporate Social Responsibility Committee (CSR Committee) has to formulate and recommend to the Board a Corporate Social Responsibility Policy.

1.2 Based on the recommendation of CSR Committee, a Corporate Social Responsibility Policy (CSR Policy) has been formulated with a view to provide the scope for the CSR Committee to deal with the matters which are prescribed under the Companies Act 2013 (the Act).

1.3 The CSR Policy will be placed on the Company’s website at www.sakthisugars.com.

2. PRIMARY OBJECTIVES

The primary objective of Corporate Social Responsibility is the commitment of the company to contribute for sustainable economic development and social welfare like education, health, water, environment and community welfare.

 

3. COMPOSITION OF CSR COMMITTEE

3.1 The CSR Committee shall consist of minimum of three Directors as members of the Committee, out of whom at least one member will be an Independent Director.

3.2 The Board or the Members of CSR Committee shall elect a Chairman of the Committee.

3.3. The Chairman of CSR Committee may be present at the Annual General Meeting to answer shareholder queries, if any.

 

4. SECRETARY

Company Secretary shall act as Secretary to the CSR Committee.

5. MEETINGS

The CSR Committee shall meet at such intervals as the Committee may deem necessary.

6. QUORUM

The quorum for a meeting shall be either two Members or one third of the Members of the Committee, whichever is higher.

7. CSR ACTIVITIES / AREAS TO BE COVERED

7.1 Over the years the Company or Group has been involved in a number of community focused activities, in the areas of health, education and preservation of the country’s rich culture and heritage. Continuing the tradition, it is recommended that the Company may focus primarily on the following activities, areas, or subjects (hereinafter referred to as “CSR activities”):

a. Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water.

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

c. 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.

d. Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water including contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga.

e. 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 art and handicrafts;

f. Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widow;

g. Training to promote rural sports, nationally recognized sports, paralympic sports and Olympic sports

h. Contribution to the prime minister’s national relief fund 8[or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund)] or any other fund set up by the central govt. for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women;

i. (i)Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and

(ii) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense Research and Development Organization (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs)

j. Rural development projects

k. Slum area development. The term `slum area’ shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force.

l. Disaster management, including relief, rehabilitation and reconstruction activities.

7.2 Activities or projects that benefit only the employees of the Company and their families shall not be considered as CSR activities.

 

8. IMPLEMENTATION CSR ACTIVITIES

8.1 The CSR activities shall be undertaken by the Company itself or through -

a. a company established under section 8 of the Act, or a registered public trust or a registered society, registered under section 12A and 80G of the Income Tax Act 1961, established by the Company either singly or along with any other company; or

b. b.a company established under section 8 of the Act or a registered trust or a registered society, established by the Central Government or State Government; or

c. any entity established under an Act of Parliament or a State legislature; or

d. a company established under section 8 of the Act, or a registered public trust or a registered society, registered under section 12A and 80G of the Income Tax Act 1961, having established tract record of at least three years in undertaking similar activities.

8.2 The company mentioned under 8.1 above, which intends to undertake the CSR activity, should have registered itself with the Central Government by filing Form CSR-1 electronically with the Registrar of Companies.

8.3 The Company may engage international organizations for designing, monitoring and evaluation of the CSR projects or programmes as per its CSR Policy as well as for capacity building of its own personnel for CSR.

8.4 By collaborating with other companies in such manner that the CSR Committees of the respective collaborating companies are able to report separately on the project or programme or activities in accordance with the Companies (Corporate Social Responsibility Policy) Rules 2014 (CSR Rules).

8.5 By contributing to eligible projects/funds.

8.6 Notwithstanding anything contained in this Policy, where the CSR amount to be spent by the Company does not exceed Rs.50 lakhs, the functions of the Committee shall be discharged by the Board of Directors of the Company.

 

9. ANNUAL ACTION PLAN

The CSR Committee, where applicable, shall formulate and recommend to the Board an Annual Action Plan in pursuance of this Policy which shall include the details specified in the CSR Rules.

 

10. EXPENDITURE

10.1 The Company shall ensure to spend, in every financial year at least two per cent (2%) of the average net profits of the Company made during the three (3) immediately preceding financial years for CSR Activities in accordance with the Annual Action Plan approved by the Board on the recommendation of the CSR Committee.

For this purpose of "net profit", profit shall not include such sums as may be prescribed and shall be calculated in accordance with Section 198 of the Act.

10.2 In the event of there being no profit calculated in the manner specified in para 10.1 above in any financial year, the Company is not obliged to spend any money on CSR activities in that financial year.

10.3 The Company will give preference to the local areas and areas around it where it operates.

10.4 The Company may use their own personnel in executing the CSR activities and also effectively monitoring it. year.

10.5 Where any CSR amount remains unspent at the end of any financial year, unless it relates to any ongoing project with respect to CSR activities, the Company shall transfer the unspent CSR amount to a Fund specified in Schedule VII to the Act within six months from the end of the financial year.

10.6 10.6Where the Company has spent an amount in excess of the requirement in any financial year, such excess amount may be set off against the requirement to spend in the succeeding three financial years in the manner specified in the CSR Rules.

10.7 Where the unspent amount is in respect of any ongoing project with respect to CSR activities, it shall be transferred to a special account opened therefor in the name Unspent Corporate Social Responsibility Account within six months from the end of the financial year. The amount so transferred shall be spent for the ongoing project within three financial years from the date of transfer. If any amount is remaining unspent in the said account at the end of the third financial year, such amount is to be transferred to the Fund specified in Schedule VII to the Act.

10.8 It should be ensured by the Board that the administrative overheads shall not exceed five per cent of total CSR expenditure of the Company for the financial year.

10.9 Any surplus arising out of the CSR activities shall not form part of the business profit of the Company. Such surplus shall be ploughed back into the same project or transferred to Unspent CSR Account and spent as per the Annual Action Plan or transferred to the Fund specified in Schedule VII to the Act.

10.10 CSR amount may be spent for creation or acquisition of capital assets in the manner specified in the CSR Rules.

11. MONITORING PROCESS

11.1 The CFO or the person responsible for the financial management shall submit a Report to the CSR Committee on half yearly basis about the CSR activities undertaken by the Company, the amount spent in respect thereof and the proposal for spending the balance CSR expenditure, if any, to be incurred for complying with the requirements of the Act and the Rules.

11.2 The CSR Committee shall review the Report submitted by the CFO or the person responsible for the financial management and take such steps as may be necessary for proper implementation of the CSR activities as approved by the Committee.

11.3 The CSR Committee shall monitor implementation of the CSR Policy and report to the Board of Directors on the status of compliance of CSR policy by the Company.

11.4 The Board of Directors of the Company shall satisfy itself that the funds disbursed for CSR activities have been utilized for the purposes and in the manner as approved by it.

 

12. CSR REPORTING

12.1 Board’s Report shall include an Annual Report on CSR containing particulars as specified in the Act and the rules relating to it in the prescribed format.

12.2 If no amount is spent on CSR Activities, the reason for not spending two per cent (2%) of the average net profit shall be reported in the Boards’ Report.

12.3 The composition of the CSR Committee, CSR Policy and the CSR Projects approved by the Board shall be disclosed on the website of the Company.

13. REVIEW OF CSR POLICY

The CSR Policy will be reviewed by the CSR Committee / Board to update the policy based on the regulatory changes from time to time.