Corporate Social Responsibility

1. Introduction

a.

As per Section 135 of the Companies Act, 2013 and rules made thereunder, every Company having net worth of rupees Five Hundred Crore or more, or turnover of rupees One Thousand Crore or more or a net profit of rupees Five Crore or more during the immediately preceding financial year shall constitute a Corporate Social Responsibility (CSR) Committee of the Board consisting of two or more directors.The CSR Committee shall formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the Company in areas or subject, specified in Schedule VII of the Companies Act.

The CSR Committee shall formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the Company in areas or subject, specified in Schedule VII of the Companies Act.

The Board's report under sub-section (3) of section 134 shall disclose the composition of the Corporate Social Responsibility Committee. 

b.

c.

The Corporate Social Responsibility Committee shall,—

i.    formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities  may be undertaken by the         company in areas or subject, specified in Schedule VII;

 

ii.    Recommend the amount of expenditure to be incurred on the activities referred to in clause (i); and

 

iii.    Monitor the Corporate Social Responsibility Policy of the company from time to time.

The Board of every company referred to in sub-section (1) shall,— 

d.

i.    after taking into account the recommendations made by the Corporate Social Responsibility Committee, approve the Corporate Social                     Responsibility Policy for the company and disclose contents of such Policy in its report and also place it on the company's website, if any, in             such manner as may be prescribed; and 

ii.    Ensure that the activities as are included in Corporate Social Responsibility Policy of the company are undertaken by the company. 

e.

The Board shall ensure that the company spends, in every financial year, at least two percent of the average net profits of the company made during the three immediately preceding financial years, in pursuance of its Corporate Social Responsibility Policy: 

 

Provided that the company shall give preference to the local area and areas around it where it operates, for spending the amount earmarked for Corporate Social Responsibility activities: 

 

Provided further that if the company fails to spend such amount, the Board shall, in its report made under clause (o) of sub-section (3) of section 134, specify the reasons for not spending the amount.

i.    Explanation.—for the purposes of this section “average net profit” shall be calculated in accordance with the provisions of section 198 of the            Companies Act, 2013 or such other amended provisions/rules as are promulgated from time to time.

f.

If Company ceases to fulfil the eligibility criteria as laid down in a) above for three consecutive years, then the company is not required to comply with CSR policy until the company will meet the eligibility criteria once again.

2. Policy Objectives

This policy, which reflects the Company’s and its parent entity Sadhan Enterprise’s philosophy and mission is designed to portray its commitment to be a responsible corporate citizen and presents the strategies and methods for undertaking social programs for well-being and sustainable development of the local community in which it operates. 

 

This policy applies to all CSR initiatives and activities taken up by Mamta Projects Pvt. Ltd., for the benefit of various segments of the society, with the emphasis on the under privileged.

This policy, which reflects the Company’s and its parent entity Sadhan Enterprise’s philosophy and mission is designed to portray its commitment to be a responsible corporate citizen and presents the strategies and methods for undertaking social programs for well-being and sustainable development of the local community in which it operates. 

 

This policy applies to all CSR initiatives and activities taken up by Mamta Projects Pvt. Ltd., for the benefit of various segments of the society, with the emphasis on the under privileged.

  2.a    The objectives of CSR Policy of the Company are to: 

  1. objectives, which also benefits the organization at large; 

  2. shape sustainability for the organization by 'Engaging the Community'; 

  3. build a corporate brand through CSR; and 

  4. for other stakeholders, make it "an integral part of the Company's DNA, so much so that it has tbuild a framework of CSR activities with a philanthropic approach in line with business unit o be an organic part of the business".

2.b    Implementation of CSR Activities / Projects

 

Each CSR activity/project of the Company to be undertaken/executed either directly by the Company or channelized through implementing agencies, to be approved by the Board. 

Planning and implementing various CSR activities shall be in line with the established objectives of the Company and its CSR Policy. 

3.    CSR Activities

  1. Enhancing environmental and natural capital 

  2. Supporting rural development 

  3. Promoting education 

  4. Providing preventive healthcare

  5. Creating livelihoods for people, especially those from disadvantaged sections of society

  6. Women Empowerment and upliftment of the under-privileged children

  7. Any such other matter as mentioned in Schedule VII of the Companies Act, 2013 read with rules made thereunder and as amended from time to time.

Preference shall be given to local area and areas around Mamta Projects Pvt. Ltd for spending the amount earmarked for CSR. 

Aligning with its vision, Mamta Projects Pvt. Ltd., will continue to increase  value creation in the community in which it operates, through its services and CSR initiatives planned and implemented, so as to stimulate wellbeing for the community, in fulfilment of its role as a responsible, corporate citizen.The over-arching framework of CSR activities will guarantee full compliance with the CSR requirements mandated by the new CompaniesAct, 2013 and the Companies (Corporate Social Responsibility Policy) Rules, 2014. The planning and execution of various CSR activities and projects shall involve, to the extent possible, the participation of staff members and customers of the Company and its parent Sadhan Enterprise. Mamta Projects Pvt. Ltd. will apply its CSR activities in a way that also contributes to India’s progress towards achieving the millennium development goals by skills improvement, entrepreneurship development, employment generation, health care improvement and application of environmental by sustainable growth

The below activities doesn’t include under the CSR activities of the Company

  1. Business run in the normal course.

  2. Outside the territory of the India or abroad.

  3. For the welfare of the employees and their families.

  4. Political party contribution of any amount directly and indirectly as defined u/s 182 of the Companies Act

4.    Implementation

The above described CSR activities will be implemented by Mamta Projects Pvt. Ltd. either directly or through other implementing agencies and in collaboration with other non-profit organisations. The duration of any project or program will be related to the nature of that project or program and their impact on the society. It is to be ensured that the CSR programs of Mamta Projects Pvt. Ltd., will be executed in the areas where the Company has business presence. The programs will be implemented either directly or in collaboration with specialised organisations or with its other group companies.

4.a.    Process of Implementation: 

i.    Map existing eco system: Thorough evaluation of the existing scenario in which the Company operates. This step is crucial in order to assess the existing potential and find relevant partners to collaborate with in line with this revised CSR Policy. 

ii.    Create: Designing programs, selecting partners and empaneling them. 

iii.    Enable: Commencing collaboration with the selected actors, investing the resources needed to shift from the planning to the action phase. 

iv.    Monitoring: Monitor the CSR Budget and the spends.

4.a.    Process of Implementation: 

i.    Map existing eco system: Thorough evaluation of the existing scenario in which the Company operates. This step is crucial in order to assess the existing potential and find relevant partners to collaborate with in line with this revised CSR Policy. 

ii.    Create: Designing programs, selecting partners and empaneling them. 

iii.    Enable: Commencing collaboration with the selected actors, investing the resources needed to shift from the planning to the action phase. 

iv.    Monitoring: Monitor the CSR Budget and the spends.

4.b    Powers for Approval

CSR programmes for each financial year as may be identified by the Company will be considered, reviewed by the CSR Committe and recommend to the Board for approval. After Board’s approval, the CSR programme shall be implemented. Any change in such programme shall be approveby the Board. 

 

For meeting the requirements arising out of immediate and urgent situations of  Mamta Projects Pvt. Ltd., CSR Committee is authorised to approve the proposals in terms of the powers accorded to the Committee by the provisions of the Companies Act, 2013.

4.c    Criteria for Identifying Implementing Organisations

The Company may identify other external executing organisations that will implement the CSR programs. Each executing organisation (NGOs/Voluntary organisations) needs to fulfil the following requirements: 

  1. has been in existence for a minimum period of 3 years from date of registration; 

  2. is registered as a Trust/Society/Section 8 (Charitable) Company; 

  3. the physical address given by the organisation is verifiable. 

  4. possesses a valid Income Tax exemption certificate; 

  5. the antecedents of the NGO/Organisation are verifiable/subject to confirmation; 

  6. has sufficient infrastructure facilities like office, e-mail etc. and necessary resources to implement the projects; 

  7. has prior experience in service activities in the specified areas as covered under CSR, as per Schedule VII of the Companies Act, 2013; 

  8. located in the area of planned activities with local knowledge; and 

  9. has articulated shared vision/purpose beyond the registration documents. 

 

After the approval of the CSR programs, the Company and the NGO/Organisation will be required to enter into a formal written agreement with each other.

5.    Governance

A meaningful engagement of the Board of Directors and Management in CSR will be ensured so that Mamta Projects Pvt. Ltd.,’s Leadership recognizes the Company’s social concerns and the strategic value of its CSR initiatives

5.a.    Board & CSR Engagement

Responsibilities of Board of Directors (BOD) include: 

  1. To constitute the CSR Committee, from amongst itself and fill vacancy in case of resignation by any director/ member of the CSR Committee. 

  2. To approve the CSR policy for the Company formulated by the CSR Committee. 

  3. To ensure that only the activities that are in line with the CSR Policy of Mamta Projects Pvt. Ltd. and are related to the activities included in Schedule VII of the Companies Act are undertaken.

  4. To approve the CSR Budget in line with regulations. 

  5. To ensure that funds committed by the company for CSR activities are utilized effectively and monitored regularly.

  6. To ensure that the reasons for any under spending and / or not spending of the allocated CSR budget are explained in the Directors Report.

  7.  Disclosing the content of the policy in its report and placing the policy on the Company’s website in the manner prescribed under section 135 of the Act read with CSR Rules.

5.b.    CSR Committee

The Mamta Projects Pvt. Ltd. CSR Committee consists of the following 3 Members: 

 

To be constructed


 

The terms of reference of the Committee are as under: 

  1. Formulate and recommend to the Board, a CSR policy which shall indicate the activities that may  be Undertaken by the Company as specified in Schedule VII of the Companies Act, 2013;

  2. Identify the projects/activities to be undertaken by the Company for CSR 

  3. Recommend to the Board CSR Activities to be undertaken along with detailed plan, modalities of execution, implementation schedule, monitoring process and amount to be incurred on such activities; 

  4. Monitor the CSR Policy of the Company from time to time; 

  5. Constitute a transparent monitoring mechanism for ensuring implementation of CSR Projects

  6. Ensure compliance of CSR Policy and the Rules;

  7. To be directly responsible to the Board for any act that may be required to be done by the CSR Committee in furtherance of its statutory obligations, or required by the Board fromtime to time. 

6.     CSR Team

The Mamta Projects Pvt. Ltd., CSR Team will consist of a minimum of three members and maximum of seven members. Three departments namely - Human Resources, Compliance and Accounting will have permanent representation in the team. CSR Team members (except permanent members) will function for two continuous fiscal years. The Human Resource department will initiate new appointment process basis requirement so that the term of new team will start at the beginning of the new fiscal year. The existing members can re-nominate themselves for selection. The nomination of the new team will be recommended by the existing team and then approved by the CSR Committee.

 

 

The CSR team will be responsible: 

  1. To execute and monitor the CSR activities approved by the Company’s Board of Directors. 

  2. To ensure systematic development of a set of processes, procedures and guidelines for CSR activities.

  3. To submit an annual comprehensive report of all the activities and projects to the CSR Committee.

  4. To submit a quarterly progress report of the CSR activities and projects to the CSR Committee. 

  5. To monitor the budget and spends.

  6. To seek guidance from the CSR Committee whenever needed. 

7.    Monitoring and Feedback

The comprehensive monitoring mechanism that will be followed shall ensure that the CSR process functions as mandated by the Act and the Rules, ensuring that all Projects/ Programmes are duly implemented as budgeted. 

The following forms the basis of the monitoring mechanism: 

  1. Allocation of a separate budget for setting up and running the monitoring system; 

  2. Installation of an electronic MIS and human architecture that shall work together to ensure a firm check on spends and the actual implementation of activities as planned; and 

  3. Release of funds only against verified utilizations. 

 

The CSR Committee will be responsible for monitoring approved projects/programmes. The monitoring system will include: 

i.    Regular field visits to project/programme sites by designated teams; 

ii.    Comprehensive documentation/compilation of field reports; 

iii.    Regular interaction with beneficiary communities to obtain feedback; 

iv.    Monitoring of timely fund utilization to ensure that projects/programmes as budgeted are actually being carried out and/or; and 

v.    Any other activity that the CSR Committee may deem necessary in the larger initiatives. 

 

Mamta Projects Pvt. Ltd. will conduct impact studies on a regular basis, especially on the “flagship programs”. Mamta Projects Pvt. Ltd. will communicate with the beneficiaries in order to obtain feedback about the programs. The CSR programs and their impact will also be reported in the Annual Report of Mamta Projects Pvt. Ltd.

7.a.    Impact Assessment / Evaluation of CSR 

 

In order to assess the impact of its CSR projects and programmes, maximize outcomes and build-in sustainability, scalability and replicability, Mamta Projects Pvt Ltd. shall undertake the following activities:

 

i.    Ensure that the projects/programmes undergo concurrent and final evaluation; and 

ii.    Engage credible third parties to undertake evaluation of all or selected projects/ programmes.

iii.   And in case of evaluation not being satisfactory to consider alternate agencies and / or revised programs in line with the provision of                      Schedule VII of Companies Act, 2013.

 

 

 

7.b.    Documentation

Meticulous documentation of projects/programmes is the only way to ensure that progress is continuously tracked, course corrections are provided, lessons learnt and objective feedback received. 

 

Good quality documentation enables Mamta Projects Pvt. Ltd., to effectively address questions and queries and also to prepare instructive and good quality case studies. 

 

Keeping this end in sight, Mamta Projects Pvt. Ltd., will endeavour at all times to put in place, for all projects/programmes, an effective documentation process. 

 

Comprehensive documentation will include printed materials, audio recordings, video recordings, etc. This will also be of great value to Mamta Projects Pvt. Ltd. in brand building, market positioning, enhancing its competitive advantage and embedding CSR values within the organization. 

8.    Amendments to the Policy 

The Board on its own and/ or as per the recommendations of CSR Committee can amend this Policy, as and when required as deemed fit. All or any of the provisions of CSR Policy would be subject to revision/amendment in accordance with the Regulations on the subject as may be issued from relevant statutory authorities, from time to time.

9.    General

Any term or aspect not specifically defined or set out in this Policy shall be construed to mean what is laid down in respect thereof under the Company Act or the CSR Rules, as the case may be.