Corporate Social Responsibility (CSR) Policy |
Policy Effective Date: 09.09.2023
No part of this documentation may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying or recording, for any purpose without express written permission of the CEO of Reflectus Infra Projects P. Limited
© 2023, Reflectus Infra Projects P. Limited. All Rights Reserved
1. Objective
Objective and Purpose
The key purpose of this Policy is to:
● Outline the developmental areas in which Reflectus Infra Projects Pvt Ltd shall get involved in through its CSR activities.
● Define governance structure for CSR management within Reflectus Infra Projects Pvt Ltd.
● Serve as a guiding document aiding in identification, execution and monitoring the CSR projects.
● Describe the treatment of surpluses from CSR activities.
● Applicable to all employees
2. Scope and Applicability
This Policy applies to all CSR projects that will be undertaken by Reflectus Infra Projects Pvt Ltd and shall fulfil all the requirements of Section 135 of the Companies Act, 2013. Reflectus Infra Projects Pvt Ltd shall ensure all these activities are over and above the normal course of business and are in line with Schedule VII of the Companies Act, 2013. This Policy will be periodically reviewed and updated in line with the relevant codes of legislation and best practices that can be adopted by Reflectus Infra Projects Pvt Ltd
CSR Policy is applicable to Reflectus Infra Projects Pvt Ltd and its branches which are mandated with the CSR expenditure obligations as per Section 135 of the Companies Act, 2013 read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended from time to time.
This policy is owned by Mrs. Jayanti Bisoi and reachable @ 8926263309 and [email protected]
3. Definition/Glossary
Term / Abbreviation | Definition / Expansion |
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4. Policy / Process
4.1. Alignment with Organisation Values
Reflectus Infra Projects Pvt Ltd is guided by its core values that it has adopted since its inception. The CSR Policy is in alignment with its core values and is central to its CSR strategy.
Being Accountable for what we do: Reflectus Infra Projects Pvt Ltd strongly believes that it is accountable for contributing back in a meaningful way to the society.
For execution of its CSR objectives and to make a positive impact with its CSR activities, Reflectus Infra Projects Pvt Ltd desires to involve its employees too in an effort to create a sense of involvement and bring about social responsibility amongst them. Wherever necessary, Reflectus Infra Projects Pvt Ltd will partner and collaborate with NGOs / other similar organizations that have experience, knowledge and a wider reach to meet its CSR objectives
4.2. Areas of Focus
(Companies can opt for specific areas of their interest and budget availability out of the areas listed below):
Reflectus Infra Projects Pvt Ltd has broadly selected 4 areas of focus under its CSR activities, as under:
Education:
Promoting education, including special education and employment enhancing vocation skills especially among lower strata or poorer sections of the society or of the differently abled adults or eligible children towards their livelihood enhancement projects.
Environment Sustainability:
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
Health 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 preventive health care and sanitation and making available safe drinking water;
● 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;
● Measures for the benefit of armed forces veterans, war widows and their dependents;
● Training to promote rural sports, nationally recognized sports, Paralympics sports and Olympic sports;
● 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;
● Rural development projects;
● Slum area development. Explanation – for the purposes of this item, 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.
Emergencies and Natural Calamities
Organization shall provide relief, support, rehabilitation etc. in case of natural calamities or emergencies.
4.3. Governance Structure
A governance structure at Reflectus Infra Projects Pvt Ltd is responsible for implementing and administering CSR Policy, in compliance with the requirements of Section 135 of the Companies Act, 2013.
4.4. CSR Committe
Organization has constituted Corporate Social Responsibility Committee (the “CSR Committee”) in line with Section 135 of the Companies Act, 2013 (the “Act”). The CSR
Committee consists of following members of the Board:
● Jayanti Bisoi , Chairperson
● Ramanuj Bisoi ,CEO
The CSR Committee of Reflectus Infra Projects Pvt Ltd shall be responsible for:
● Review of CSR activities in the Company.
● Formulation of CSR Policy.
● Monitoring of implementation of CSR Policy.
● Recommend to the Board, modifications to CSR Policy as and when required.
● Appraise to the Board the CSR expenditure done during the year.
4.5. CSR Team
Dedicated CSR team shall be constituted from among the employees at Reflectus Infra Projects Pvt Ltd, for implementing the CSR Policy and shall work under the guidance of CSR Committee and will be mainly responsible for:
● Execution of CSR Policy.
● Identify projects and key initiatives pursuant to CSR Policy.
● Facilitating allocation of funds to the projects as identified for CSR activities.
● Monitoring CSR Projects to establish effectiveness of CSR efforts and appraise the same to CSR Committee.
● Compilation of information & preparation of Annual Reports on CSR activities and presenting the same to CSR Committee.
● Any other activity necessary to ensure achievement of CSR objectives.
4.6. CSR Budget
For any reason if the CSR team is not able to follow the allocation agreed on in any of the Areas to focus described above, the same shall be utilized in such other Areas to focus as the CSR team may recommend with the reasons therefore, and the CSR Committee may approve.
5. Implementation Process
5.1. CSR Contributions
Reflectus Infra Projects Pvt Ltd will endeavour to contribute and spend at least 2% of the average net profits of Reflectus Infra Projects Pvt Ltd made during the three immediately preceding financial years or such amount as may be recommended by the CSR Committee from time to time in pursuance of this Policy.
5.2. Compliance, Monitoring and Reporting
5.2.1. Complaince
The CSR Team will plan, implement, monitor and manage all CSR projects & activities for Reflectus Infra Projects Pvt Ltd and will work closely with the CSR Committees of the Boards of Reflectus Infra Projects Pvt Ltd and the Group companies as applicable.
The CSR Team will formulate implementation plans for the projects by clearly defining the following:
● Activities to be undertaken.
● Budgets proposed.
● Time frame for implementation.
● Responsibilities and authorities for implementation.
● Results expected to be achieved post-implementation
5.2.2. Monitoring
Milestones will be decided for every project/activity undertaken, and the progress will be will be evaluated against the milestones defined in the implementation plan for each project/activity. The CSR Team will monitor the implementation and progress of the approved projects through appropriate mechanisms such as site visits, review meetings and progress reports etc. Reflectus Infra Projects Pvt Ltd will establish mechanisms to track data and monitor projects so that the CSR projects undertaken are implemented transparently and efficiently.
5.2.3. Reporting
The CSR Committee of the Board, based on reports presented by the CSR Team, will annually publish report on the CSR projects as a part of the Director’s report. The report will disclose information in the format as prescribed by the Section 135 of the Companies Act 2013.
The CSR Committee shall also submit a responsibility statement to the Board that the implementation and monitoring of the CSR Policy is in compliance with the approved Corporate Social Responsibility CSR Policy of Reflectus Infra Projects Pvt Ltd.
The CSR Policy on being approved by the Board shall be displayed on the website of Reflectus Infra Projects Pvt Ltd and any modifications carried out from time to time shall also be updated on the website of Reflectus Infra Projects Pvt Ltd respectively.
5.3. Treatment of Surplus
Any surplus generated from CSR projects undertaken w. e. f. <Financial Year> will be tracked and channelized into the CSR corpus. These funds will be further used in development of the CSR projects and will not be added to the normal business profits.
6. Special Circumstance and Exception
Any Deviation to this policy has to be approved by HR. Any changes to the policy has to be approved by Legal and Compliance.
7. Non-compliance and Consequence
Violation of this overtime policy is subject to disciplinary action, up to and including termination. If an employee, including Floor Supervisor and/or Manager, is suspected of violating the policy, he/she must undergo a thorough investigation. The circumstances of each violation will determine the severity of each scenario.