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CSR Policy

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CORPORATE SOCIAL RESPONSIBILITY (CSR) POLICY

1. CSR PHILOSOPHY:

Shelke Constructions Private Limited (“the Company”) aims to carry out charitable objects and purposes wide-enough for the extension of the benefit thereof to all, irrespective of class and creed.

The CSR Vision Statement:

“Help Improve Lives by Partnering with Communities to deliver lasting Solutions.”

The Vision statement is built on the four value pillars:

  • Improving Lives
  • Sustainable Development
  • Partnerships
  • Care and Concern

The Company’s CSR Policy framework details the mechanisms for undertaking various programs in accordance with section 135 of the Companies Act 2013 (the ‘Act’) and the Companies (Corporate Social Responsibility) Rules, 2014 (the ‘Rules’) (as amended from time to time) for the benefit of the community.

2. CSR ACTIVITIES:

CSR policy recognizes that CSR is a commitment to support initiatives that measurably improve the lives of underprivileged by one or more of the following focus areas as per the Act and Rules made there under and as may be amended from time to time.

The following are the broad categories of the activities under which the Company shall identify projects to undertake CSR activities as specified under Schedule VII of the Companies Act, 2013:

  1. 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.
  2. Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
  3. Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centers and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups.iv. 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.
  4. 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.
  5. Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Paramilitary Forces (CPMF) veterans, and their dependents including widows.
  6. Training to promote rural sports, nationally recognized sports, paralympic sports and Olympic sports.
  7. 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 Government for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women.
  8. (a) 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 (b) 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 Organisation (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).
  9. Rural development projects.
  10. Slum area development.
  11. Disaster management, including relief, rehabilitation and reconstruction activities.
3. EXCLUSIONS:

Corporate Social Responsibility (CSR) means the activities undertaken by the Company in pursuance of its statutory obligation laid down in Section 135 of the Act in accordance with the provisions contained in the CSR Rules, but shall not include the following, namely:

  1. Activities undertaken in pursuance of normal course of business of the Company.
  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.iv. activities benefitting employees of the Company.
  4. Activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services.
  5. Activities carried out for fulfilment of any other statutory obligations under any law in force in India.
4. CSR COMMITTEE COMPOSITION, MEETINGS:

The CSR Committee shall consist of three or more Directors. The committee shall meet at least once a year to discuss and review the CSR activities and policy. A quorum of two members or such other Quorum as may be prescribed under the Act is required to be present at such meetings. The committee shall have the authority to call such employees, senior officials or external members as it deems fit.

5. ROLE OF CSR COMMITTEE:
  1. To formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the Company as specified in Schedule VII of the Companies Act 2013.
  2. To recommend the amount of expenditure to be incurred on the specified activities in a financial year.
  3. To monitor the Corporate Social Responsibility Policy of the Company from time to time.
  4. To recommend the Board on the guiding principles for selection, implementation and monitoring of CSR activities.
  5. To formulate and recommend an Annual CSR Action Plan in pursuance of its CSR policy.
  6. Any other matters/things as may be considered expedient by the members in furtherance of and to comply with the CSR Policy of the Company.
6. ROLE OF THE BOARD OF DIRECTORS:
  1. Form a CSR Committee as prescribed under the Act.
  2. 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.
  3. The Board of Directors shall, after considering the recommendations made by the CSR committee, approve the CSR policy and the Annual CSR Action Plan of the company.
  4. The Board of Directors of the Company shall disclose the composition of the CSR Committee, and CSR Policy and Projects approved by the Board on the website of the Company.
  5. The Board shall ensure that the CSR activities are undertaken by the Company itself or through a registered and eligible Implementation Agency.
  6. The Board of the Company shall satisfy itself that the funds so disbursed have been utilized for the purposes and in the manner as approved by it and the Chief Financial Officer or the person responsible for financial management shall certify to the effect.
  7. In case of ongoing project, the Board of the Company shall monitor the implementation of the project with reference to the approved timelines and year-wise allocation and shall make modifications, if any, for smooth implementation of the project within the overall permissible time period.
  8. The Board may extend a non-ongoing project beyond one year based on reasonable justification.
  9. The Board may alter the CSR Annual Action Plan at any time during the financial year, as per the recommendation of its CSR Committee, based on reasonable justification to that effect.
  10. The Board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the Company for the financial year.
  11. Approve transfer of unspent CSR Amount in accordance with the Act.
  12. Where the Company spends an amount in excess of requirement, such excess amount may be set off by the Board against the requirement to spend up to immediate succeeding three financial years subject to the conditions that – a) the excess amount available for set off shall not include the surplus arising out of the CSR activities, if any. b) the Board of the Company shall pass a resolution to that effect
  13. As per section 135 of the Companies Act 2013 (“the Act”), the Board in its report shall specify the reasons, if any, for not spending the allocated CSR Budget in any of the financial year.
7. CSR EXPENDITURE:
  1. The Company would spend at least 2% of the average net profits made during the three immediately preceding financial years.
  2. In case of any surplus arising out of CSR projects the same shall not form part of business profits of the Company.
  3. The Company may collaborate or pool resources with other companies to undertake CSR activities.
  4. In case the Company has any unspent amount, other than that relating to ongoing projects, the Company shall transfer such unspent amount to a Fund specified in Schedule VII of the Companies Act, 2013 within a period of six months of the expiry of the financial year.
  5. The CSR amount may be spent by a company for creation or acquisition of a capital asset subject to certain conditions as prescribed under the Act and CSR rules.
8. IMPLEMENTATION:
  1. CSR program will be undertaken by the Company in identified areas. The Company will undertake need assessments as and when required.
  2. The time period / duration over which a particular program will be spread, will depend on its nature, extent of coverage and the intended impact of the program.
  3. The mode of implementation of CSR programs will include a combination of direct implementation and / or through partners such as NGOs, Trusts, academic institutions, business associates, registered societies etc. The Company will select its partners after appropriate due diligence and after complying with applicable laws.
  4. The Company may use the services of internal teams, employee volunteers, expert agencies, consultancy firms etc. wherever required for carrying out base line surveys, guidance on program design and implementation, impact assessment surveys, etc.
9. IMPLEMENTING AGENCY:

The Company intends to undertake all its CSR Activities through such agency as per the rules prescribed or directly without the involvement of any trust or agency.

10. MONITORING AND EVALUATION:
  1. The progress of CSR programs under implementation at various locations will be reported to the corporate office on a periodical basis.
  2. The report on progress on the CSR program undertaken by the Company will be put forward to the CSR Committee with full details of cost incurred and results achieved on a regular basis.
  3. Appropriate documentation of the Company’s CSR activities, executing partners, and expenditure entailed will be maintained on a regular basis.
  4. An internal Audit will be conducted by the Internal Auditor of the Company for the projects executed and the Report will be submitted to the person responsible for implementation of CSR projects and the person responsible for overall financial management of CSR activities for the Company.
  5. Feedback would also be obtained and documented from the beneficiaries during the Internal Audit as and when required.
  6. Field visits would be conducted by the person responsible for implementation of CSR projects on a periodic basis to ensure the progress of the programs.
  7. Implementing Agency and Partners would be required to report narrative as well as financial updates in the format and frequency mutually decided.
  8. CSR initiatives of the Company will be reported in the Annual Report under the Board’s Report and on the website of the Company in compliance with Section 135 of the Act and the rules made thereunder.
  9. If required, Impact Assessment would be conducted on a periodic basis, by independent professional wherever applicable.
11. MONITORING MECHANISM:

The CSR Committee shall monitor the implementation of the CSR Policy through periodic reviews of the activities and will provide progress report to the Board at a frequency as may be decided. The monitoring mechanism is divided into three distinct areas:

  1. Programme Monitoring;
  2. Evaluation;
  3. Reporting and Documentation.
12. GEOGRAPHIC REACH:

The Company shall give preference to the local areas around it where it operates, for spending the amount earmarked for CSR activities. However, the CSR committee may identify such areas other than those stated above, as it may deem fit, and recommend it to the Board for undertaking CSR activities.

For and on behalf of the Board of Directors of Shelke Constructions Private Limited

Babanrao Shelke (DIN: 03246025)

Managing Director and Chairperson of CSR Committee

Vishal Shelke (DIN: 02368910)

Director and Member of CSR Committee