CORPORATE SOCIAL RESPONSIBILITY POLICY
of
SAHASANKHA ADVISORY AND CONSULTING SERVICES
PRIVATE LIMITED (“the Company”)

Background

As per Section 135 of Companies Act 2013 (“the Act”), with effect from April 1, 2014, every Company having Net worth of INR 500 crores or more, or turnover of INR 1,000 crores or more, or a net profit of INR 5 crores or more during any Financial year (FY) should ensure that it spends, in every FY, at least two per cent of the average net profits of the Company made during the three immediately preceding FYs.

The Corporate Social Responsibility (“CSR”) Policy of the Company, which was adopted in September 2020, is being amended in line with (Corporate Social Responsibility Policy) Amendment Rules, 2021.

2. Objective

The objective of the CSR Policy is to benefit the society by improving the quality of life of the community at large. The Company is already engaged in promoting insurance products to women and seeks to contribute to the overall development of the society.

3. Important Definitions:

• Administrative overheads means all the general management and administration related work but excludes the expenses undertaken by an external approved agency, for designing, implementing, monitoring and evaluation of a particular CSR project or programme.
• Corporate Social Responsibility (CSR) means the activities undertaken by a Company in pursuance of its statutory obligation laid down in section 135 of the Act, but shall not include the following, namely:
  1. activities undertaken in pursuance of normal course of business of the Company: Provided that any company engaged in research and development activity of new vaccine, drugs and medical devices in their normal course of business may undertake research and development activity of new vaccine, drugs and medical devices related to COVID-19 for financial years 2020-21, 2021-22, 2022-23 subject to the conditions that-
     • such research and development activities shall be carried out in collaboration with any of the institutes or organisations mentioned in item (ix) of Schedule VII to the Act;
     • details of such activity shall be disclosed separately in the Annual report on CSR included in the Board’s Report;
  2. any activity undertaken by the Company outside India except for training of Indian sports personnel representing any State or Union territory at national level or India at international level;
  3. contribution of any amount directly or indirectly to any political party under section 182 of the Act;
  4. activities benefitting employees of the Company as defined in clause (k) of section 2 of the Code on Wages, 2019 (29 of 2019);
  5. activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services;
  6. activities carried out for fulfilment of any other statutory obligations under any law in force in India;
• Ongoing Project means a multi-year project undertaken by the Company in fulfilment of its CSR obligation having timelines not exceeding three years excluding the financial year in which it was commenced and shall include such project that was initially not approved as a multi-year project but whose duration has been extended beyond one year by the Board based on reasonable justification as prescribed under Rule 2(i) of Companies (CSR Policy) Rules, 2014.

4. Areas of Focus

In accordance with requirements under the Companies Act 2013, the Company will focus on:

• HUNGER, POVERTY, AND HEALTH: Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation and making available safe drinking water;
• EDUCATION: Promoting education, including special education and employment enhancing vocational skill especially among children, women, elderly and differently abled and livelihood enhanced projects;
• RURAL DEVELOPMENT PROJECTS: strengthening rural areas by providing / improving accessibility, housing, drinking water, sanitation, power and other essential livelihoods items, thereby creating sustainable village;
• GENDER EQUALITY AND EMPOWERMENT OF WOMEN: Promoting gender equality, empowering women, setting up homes and hostels for women and orphans, setting up old age home, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
• ENVIRONMENTAL SUSTAINABILITY: Ensure environmental sustainability, ecological balance, protection of flora & fauna, animal welfare, agro forestry, conservation of natural resources & maintaining quality of soil, air & water;
• NATIONAL HERITAGE, ART & CULTURE: Protection of national heritage, art & culture including restoration of buildings & sites of historical importance & works of art; setting up public libraries; promotion & development of traditional arts & handicrafts;
• Others :-
  • Measures for the benefit of armed forces veterans, war widows and their dependents;
  • Training to promote rural sports, nationally recognised sports, paralympic sports and Olympic sports;
  • Contribution to the Prime Minister’s National Relief Fund [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;
  • Contribute or funds provided to technology incubators located within academic institutions which are approved by the Central Government.
  • Slum area development.
  • Disaster management, including relief, rehabilitation, and reconstruction activities.
  • Any other activities specified under Schedule VII of the Companies Act, 2013 and such other rules as amended from time to time.

5. Undertaking CSR Activities

The Company will undertake its CSR activities, approved by the CSR committee, through reputed and registered Trusts/Societies/Non-Governmental Organisations (NGOs)/Companies having established track record as prescribed under the Companies (Corporate Social Responsibility) Rules, 2014 or any amendment thereof. The surplus, if any, arising out of the CSR activities, Project or programme shall not form part of the business profits of the Company.

6. CSR Expenditure

1. In every financial year, the Company shall, with the recommendation of its CSR Committee and approval of its Board of Directors, make a budgetary allocation for CSR and Sustainability activities /projects for the year. The budgetary allocation will be at least two percent of the average net profits of the Company made during the three immediately preceding financial years. The Company shall give preference to the local area(s) around where it operates, for spending the amount earmarked for CSR activities. CSR expenditure shall include all expenditure including contribution to corpus, for projects or programs relating to CSR activities approved by the Board on the recommendation of its CSR Committee, but does not include any expenditure on an item not in conformity or not in line with activities covered under the purview of Schedule VII to the Act.
2. The Board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure for the financial year. The same will cover only the administrative overhead incurred by the Company for conducting CSR Activities. This clause will not cover the applicable administrative overhead incurred by the implementing agency as any expenditure incurred as administrative overheads by the implementing agency is an operational /Project cost of the Company.
3. Any surplus arising out of the CSR activities shall not form part of the business profit and shall be ploughed back into the same project or shall be transferred to the Unspent CSR Account and spent in pursuance of CSR policy and annual action plan or transferred to a Fund specified in Schedule VII, within a period of six months from the expiry of the financial year.
4. Where an amount spent on CSR activities is in excess of requirement provided under sub-section (5) of section 135, such excess amount may be set off against the requirement to be spent under sub-section (5) of section 135 up to immediate succeeding three financial years subject to the conditions that:
   1. the excess amount available for set off shall not include the surplus arising out of the CSR activities, if any, in pursuance of sub-rule (2) of this rule.
   2. the Board shall pass a resolution to that effect.
5. The CSR amount may be spent for creation or acquisition of a capital asset, which shall be held by:
   1. a company established under section 8 of the Act, or a Registered Public Trust or Registered Society, having charitable objects and CSR Registration Number under sub-rule (2) of rule 4; or
   2. beneficiaries of the said CSR project, in the form of self-help groups, collectives, entities; or
   3. a public authority:

Provided that any capital asset created prior to the commencement of the Companies (Corporate Social Responsibility Policy) Amendment Rules, 2021, shall within a period of one hundred and eighty days from such commencement comply with the requirement of this rule, which may be extended by a further period of not more than ninety days with the approval of the Board based on reasonable justification.

7. Failure to spend the CSR Money.

In case the Company fails to spend the targeted amount in any particular financial year, the Committee shall submit a report in writing to the Board of Directors specifying the reasons for not spending the amount which in turn shall be reported by the Board of Directors in their Directors’ Report for that particular Financial Year.
The unspent amount, unless such amount relates to any ongoing project, shall be transferred to a fund specified in Schedule VII of the Act, within a period of six months of the expiry of the financial year.

Any amount remaining unspent, pursuant to any ongoing project, fulfilling such conditions as may be prescribed, undertaken by the Company in pursuance of the Policy, shall be transferred within a period of thirty days from the end of the financial year to a special account to be opened by the Company in that behalf for that financial year in any scheduled bank to be called the “Unspent Corporate Social Responsibility Account”. Such amount shall be spent by the Company in pursuance of its obligation towards the policy, within a period of three financial years from the date of such transfer, failing which, the Company shall transfer the same to a Fund specified in Schedule VII of the Act, within a period of thirty days from the date of completion of the third financial year.

8. Composition of CSR Committee

The CSR Committee consists of Ms Sahaana Sankar, Managing Director and Mr C V Sankar, Director.

9. Responsibility of CSR Committee

The responsibility of CSR Committee includes:

• Formulating and recommending to the Board of Directors the CSR Policy and
  indicating activities undertaken
• Recommendation of the amount of expenditure for CSR activities and
• Monitoring CSR activities from time to time

10. Locations for focusing CSR activities

The Company shall give preference to the local areas that fall within the economic vicinity of the Company’s operations to enable close supervision and ensure maximum development impact.

11. CSR Reporting

A report, as specified, shall be submitted to the Board about the amount spent for CSR activities during the FY. The Composition of the CSR Committee, contents of the CSR approved policy and CSR initiatives undertaken by the Company shall be disclosed in the annual Board of Directors’ report to the General Body of the Company, in the specific format as required in the notification, and shall also be displayed on the Company’s website.

12. Review of the CSR policy

The CSR committee/ Board shall monitor and review the CSR policy from time to time.