At Abhya Life, Corporate Social Responsibility (“CSR”) has evolved over decades with the simple objective of ‘giving back to the society’. We are, therefore, committed to integrating CSR with the business processes for sustainable growth and development. We would like to emphasize our initiatives in specific areas of social development that would include Quality education for the underprivileged children, skills development, health & hygiene, women empowerment, environmental sustainability, water & sanitation and handicrafts & handloom. We believe our initiatives in these areas would continue to contribute significantly to the overall welfare of society to make a difference in the quality of life of people from rural and urban areas.
Our Corporate Values in identification and execution of the CSR initiatives include
Empathy - Empathy towards the needy
Transparency - Transparency in conduct, monitoring and reporting
Integrity - Upholding integrity in all aspects
Accountability - Accountable for what is committed
Excellence - Excellence in execution
At Abhya Life, we are committed to work in PAN India on 6 major indicators - water harvesting, livelihood, health & hygiene, education, women empowerment, environment. We are also committed to address issues pertaining to but not limited to women empowerment and environmental sustainability, health & hygiene cleanliness, skill education and promote handicrafts & handloom, etc.
CSR programs undertaken also provide opportunities for our employees, our customers, suppliers and partners to contribute to these efforts through volunteering.
This policy is applicable across Abhya Life. The said policy can be read in alignment with the requirements of Section 135 of the Companies Act, 2013 (‘the Act’) and the corresponding rules made there under, as amended from time to time (‘CSR Rules’), Schedule VII of the Act. The scope of this policy is to strategically draw the guiding principles for selection, implementation and monitoring of CSR projects/programs as well as formulation of the annual action plan by the Board of the Company, after considering the recommendations of its CSR Committee.
In this policy, unless the context otherwise provides/requires, words and expressions used in the policy shall have the same meanings respectively assigned to them in the Act or rules made there under.
a. The Company will consistently explore and undertake CSR Projects or programs relating to the activities in any of the fields enumerated in Schedule VII of the Act with a preference to carry on such activities within the local area(s) around it, wherever it operates. Also, the Company may also undertake CSR Projects or programs for activities notified as CSR by the Ministry of Corporate Affairs (MCA) through its notifications, circulars and clarifications.
b. The time period/duration over which a particular program/ projects shall be spread over, shall depend on its nature, extent of coverage and the intended impact of the program/project.
c. Following activities will not be considered as CSR projects/programs:
i. CSR projects/programs that benefit only the employees of the company and their families.
ii. Contribution of any amount directly or indirectly to any political party under the Companies Act, 2013.
iii. Activities undertaken in pursuance of the normal course of business of a Company.
iv. Activities to be excluded as notified by the MCA through its notifications, circulars and clarifications.
d. A company may also collaborate with other companies for undertaking projects or programs or CSR projects/programs in such a manner that the CSR Committees of respective companies are able to report separately on such projects or programs in accordance with Companies (Corporate Social Responsibility Policy) Rules, 2014 (as amended).
a. Project activities identified under CSR are to be implemented either by personnel of the Company or through a registered trust or a registered society with established track records in the respective domains or a company established by the company or its holding or subsidiary or associate company under section 8 of the Companies Act, 2013 or otherwise or by specialized agencies nominated by CSR Committee from time to time.
b. Specialized agencies and personnel authorized in this regard could be made to work singly or in tandem with other agencies. The Company shall specify the project to be undertaken by such entity and modalities of utilization of funds for such projects with implementation schedules, monitoring and reporting mechanism.
c. The Company shall ensure that all the CSR projects/programs are implemented as per the approved annual action plan authorized by the Board.
The organizational mechanism for CSR shall be as follows-
i. Management
a. CSR programs/projects identified by the Management within the framework of CSR areas must be put up to the CSR Committee at the beginning of each financial year.
ii. CSR Team
a. The project implementation team will be hired as per project requirements. The team shall undertake and periodically report a progress report of all ongoing projects for review/information of the Board through the CSR committee.
b. The team shall be responsible for implementing the CSR projects as per the Annual Action Plan approved by the Board. It shall tell the CSR committee of any deviation from the approved Annual Action Plan with reasons thereof.
c. The team shall, sometimes and in consultation with the related project head, finalize periodic milestones for project-based CSR projects/programs for monitoring the projects efficiently.
d. The committee shall follow the following process for undertaking/funding CSR projects/programs/projects through Implementing Agency/NGOs:
1. Conduct due diligence before partnering with any implementing agency/NGO for CSR projects/programs.
2. Execution of Memorandum of Understanding (MoU) with the Partnering NGOs, which will detail the key roles and responsibilities of each of the parties for the projects having value more than Rs. 5.00 lakhs.
3. Scheduling of disbursements of funds relating to the program and monitoring system in accordance with pre-agreed milestones with partners.
iii. CSR Committee
a. Formation: Companies are required to form a CSR Committee of the Board.
b. Composition: The committee should consist of at least three directors, with at least one being an independent director.
c. Responsibilities: The committee oversees the implementation of the CSR policy, monitors the activities, and ensures compliance.
iv. Board of Directors
a. The Board will consider and approve the CSR Annual Action Plan recommended by the CSR Committee with such modification that may be deemed necessary. The CSR Annual Action Plan may also be modified by the Board during the financial year, on the recommendation of the CSR Committee.
b. For meeting the requirements arising out of immediate & urgent situations with regard to formulated CSR projects/programs, the Managing Director is authorized to approve such proposals in terms of the empowerment accorded to him by the CSR Committee.
c. Compliance with this policy including the following implementation schedules for such CSR projects/programs shall be periodically monitored by CSR Committee subject to review by the Board of Directors from time-to-time.
III. MONITORING, IMPACT ASSESMENT AND RECORD MAINTAINENCE:
a. The CSR projects/programs undertaken directly by the Company shall be monitored by the CSR team and those undertaken through Implementing Agencies shall be monitored by the designated person of the Implementing Agency, if any and/or the CSR team on a continuous basis. The CSR team may obtain periodic progress reports from the Implementing Agencies.
b. An Impact assessment shall be undertaken if the average CSR obligation in pursuance of subsection (5) of section 135 of the Act in the three immediately preceding financial years is ten crore rupees or more. The assessment shall be undertaken for CSR projects having outlays of one crore rupees or more, and which have been completed not less than one year before undertaking the impact study, through an independent agency.
c. Appropriate documentation of the CSR Policy, annual CSR projects/programs, executing partners, and expenditure entailed shall be undertaken regularly.
d. The contents of the Policy and Annual Report on CSR projects/programs to be included in the Board Report and shall also be placed on the Company’s website – www.abhyalife.org as per the particulars specified in the Companies (Corporate Social Responsibility Policy) Rules, 2014.
a) In case of any doubt with regard to any provision of the policy and also in respect of matters not covered herein, a reference to be made to CSR Committee. In all such matters, the inputs and the final decision/determination/ interpretation shall rest with the Chairman and Managing Director of the Company.
b) Any or all provisions of the CSR Policy would be subject to revision/amendment in consultation with CSR Committee and in accordance with the guidelines on the subject as may be issued by the Government, from time to time.
c) The Company reserves its right to modify, cancel, add, or amend any of these Rules. However, this policy, in whole or in part, shall stand modified / amended from time-to-time, without any further act on the part of the Company, as and when there would be any statutory modification(s)/ amendment(s) / revision(s) to the applicable provisions thereto.
