Corporate Social Responsibility Policy  2022-23

The Government of India has formally introduced the Corporate Social Responsibility (“CSR”) to the dashboard of the Indian Companies through the introduction of Section 135 in the Companies Act, 2013.

Kanti Sweets Private Limited is much positive and appreciate the decision taken by the Government of India. Legal framework of CSR is an edge to Corporate Charitable/Reformative Approach towards the Society to which the Corporate is belonging to. By introducing a separate section in the Companies Act, the Government has given legal recognition to their community development approach.

The Management of the Company expresses its willingness and support to the CSR Concept, its legal framework and shall be abided to it.

1.CSR Vision 
 Kanti Sweets Private Limited strongly believe in the concept of a better quality of life for everyone, now and for generations to come, whilst achieving a stable economic development. Our vision is a world in which we contribute to provide basic requirements of people such as education, health care, sanitation etc. in an environmentally, socially and economically sustainable way. We believe, as a responsible corporate citizen, it is our duty to ensure that the benefits of our growth are not just shared by the stakeholders of our organization but also by the local communities in which we operate.

2.Aims & Objectives 

  The main objective of this CSR Policy is to lay down guidelines for Kanti Sweets Private Limited to make CSR as one of the key focus areas to adhere to its interest in environment and society that focuses on making a positive contribution to society through effective impact and sustainable development programs.

This Policy defines Company’s Vision, Scope & Coverage of the Policy, CSR activities to be undertaken by the Company in line with Schedule VII to the Act as amended from time to time, constitution of CSR Committee and its functions & responsibilities, Board’s responsibilities, Implementation of CSR Policy, Monitoring and Reporting.

3.Definitions 

In this Policy unless the context otherwise requires:

(a)   'Act' means Companies Act, 2013

(b)   “Agency” (or Agencies) means any Section 8 Company or a registered trust/society/NGO/ institution, performing social services for the benefit of the society and including a registered trust / society / NGO / institution / Section 8 Company which is formed by the Company or its holding or subsidiary company/companies.

(c)   'Corporate Social Responsibility' means Corporate Social Responsibility (CSR) as defined in Section 135 of the Companies Act 2013 and Companies (Corporate Social Responsibility Policy) Rules 2014 (CSR Rules):

(d)   'Ministry' means the Ministry of Corporate Affairs.

(e) 'Net Profit' means net profit referred to in Section 135 of the Act and computed in accordance with Section 198 of the Act as set out below:

(f)   “Ongoing Project” means a multi-year project undertaken by the Company in fulfillment 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.

(g)    “Rules” shall mean the Companies (Corporate Social Responsibility) Rules 2014, including any re-enactment, modifications or amendments thereof.

Net Profit as per financial statements prepared in accordance with the applicable provisions of the Act, but shall not include the following, namely:

i)              any profit arising from any overseas branch or branches of the Company, whether operated as a separate Company or otherwise; and

ii)             any dividend received from other companies in India, which are covered under and complying with the provisions of Section 135 of the Act;

       Words and expressions used in this CSR Policy and not defined herein but defined in the Act shall have the  meaning respectively assigned to them in the Act. 

4.Scope & Coverage

The CSR activities of the Company shall include, but not limited to any or all of the sectors/activities as prescribed in the Schedule VII to the Companies Act, 2013 as amended from time to time. Further, the Company will review the sectors/activities from time to time and make additions/ deletions/ clarifications to the above sectors/activities.

5.CSR Activities under Companies Act, 2013 

The Policy recognizes that Corporate Social Responsibility is not merely compliance; it is a commitment to work for social good through such activities as would enhance the social good in accordance with one or more of the following focus areas as notified under Schedule VII to the Companies Act 2013:

(i)            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.

(ii)           Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.

(iii)          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.

(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.

(v)           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;

(vi)          Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widow;

(vii)        Training to promote rural sports, nationally recognized sports, paralympic sports and Olympic sports

(viii)         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;

               (ix)     (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 Organization (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)

(x)            Rural development projects

(xi)          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.

(xii)         Disaster Management, including relief, rehabilitation and reconstruction activities.

CSR activities shall be undertaken as projects, programs of activities (either new or ongoing) excluding activities undertaken in pursuance of the normal course of business of the Company. The Company may undertake in India, either new or ongoing, any one or more of the projects or programs or activities' (hereinafter referred to as 'Activities'), as may be decided by the CSR Committee from time to time.

Activities excluded from the purview of CSR expenditure: 

 i)    Activities which are exclusively for the benefit of employees of the Company or their family members

ii)     Activities undertaken in pursuance of normal course of business of the Company

iii)   Direct or indirect contribution to political parties, if any

vi)   Expenditure on item/s not in conformity with Schedule VII of the Companies Act 2013, as amend

6.CSR Committee

        6.1. Constitution

Pursuant to the provisions of Section 135 of the Act, the Board of Directors shall constitute the Corporate Social Responsibility (CSR) Committee. The Members of CSR Committee shall be appointed by the Board of Directors of the Company which must consist of at least two or more Directors. Accordingly, the constitution of CSR Committee formed by Kanti Sweets Private Limited is as follows:

CSR Committee for the Financial Year 2022-23

The CSR Committee of the Board further form a CSR TEAM which Consists of members who expertise in execution and supervision of various CSR initiatives and social activities, to carry out the CSR activities of the company who will work under the supervision of the CSR Committee and will support in the execution of the various CSR initiatives approved by the CSR Committee. The CSR Committee will govern the composition and functioning of the CSR Team from time to time.

6.2.Meetings of CSR Committee 

a) The CSR Committee shall hold a minimum number of two meetings in a year.

b) The members of the Committee may mutually agree between them regarding time and placefor the said meetings.

c) The quorum for the CSR Committee Meeting shall be one-third of its total strength (any fraction contained in that one-third be rounded off as one) or two members, whichever is higher.

d) The Members of the Committee may participate in the meeting either in person or through video conferencing or other audio-visual means as may be convenient.

6.3.Functions and Responsibilities of CSR Committee 

To effectively implement the objectives of the Company with respect to CSR, the Committee is vested with the following functions and powers:

a)      Formulate CSR Policy and recommend the same to the Board of Directors of the Company for approval. 

 b)Formulate and recommend to the Board, an annual action plan in pursuance of its CSR policy, which shall include the items as mentioned in rule 5(2) of the Companies (CSR Policy) Rules, 2014.

c)      Recommend CSR activities as stated under Schedule VII of the Act.

d)     Approve to undertake CSR activities, if necessary, in collaboration with group companies/other Companies/firms/NGOs etc., and to separately report the same in line with the CSR Rules.

e)      Recommend the CSR Budget.

f)       Spend the allocated CSR amount on the CSR activities once it is approved by the Board of Directors of the Company in accordance with the Act and the CSR Rules.

g)     Create transparent monitoring mechanism for implementation of CSR initiatives in India.

h)     Submit the Reports to the Board in respect of the CSR activities undertaken by the Company.

i)       Monitor CSR Policy from time to time.

j)       Monitor activities/charter of Internal Working and Monitoring Group (WG) who are authorized to ensure that the CSR activities of the Company are implemented effectively through ‘CSR Team’ formed specially for implementation of different projects.

k)      Authorize executives of the Company to attend the CSR Committee Meetings, if necessary.

7.Responsibility  of the Board

a)      After taking into account the recommendations made by the CSR Committee, approve the CSR Policy for the Company.

b)     Ensure that the CSR activities included in this Corporate Social Responsibility Policy are undertaken by the Company.

C)The Board of the Company may decide to undertake its CSR activities approved by the CSR Committee, through a registered trust or a registered society or a Company established under section 8 of the Act by the Company, either singly or along with its holding or subsidiary or associate Company, or along with any other Company or holding or subsidiary or associate Company of such other Company.

d)      If such trust, society or Company is not established by the Company, either singly or along with its holding or subsidiary or associate Company, or along with any other Company or holding or subsidiary or associate Company of such other Company, it shall have an established track record of three years in undertaking similar programs or projects/activities.

e)     Ensure that in each financial year the Company spends at least 2% of the average net profits of the Company made during the three immediately preceding financial years, calculated in accordance with Section 198 of the Act, in pursuance of its CSR policy. Further, while spending the amount earmarked for CSR activities, preference should be given to local areas and areas around the Company where it operates.

f)      As per Section 135 of the Act, specify the reasons for under spending the CSR amount in the Board’s Report and ensure that unspent amount is to any fund included in Schedule VII within 6 months from the end of the financial year.

8.Budget for CSR Activities 

       a)    Every year, the Company shall with the approval of its Board spend at least two (02) per cent of the average net profit made during the three (03) immediately preceding financial years on specific CSR projects and programs in compliance with the Companies Act.

b)    The computation of average net profits will be carried out in accordance with the provisions of Section 198 of the Companies Act, 2013.

c)     The Company expects to spend the budgeted amount allocated for CSR activities/ projects planned for each financial year, within that year. If for any reason, the budget of a year remains unutilized, the same would not lapse and would be carried forward to the next year for expenditure on CSR activities, which were planned for implementation in the previous year, but could not be completed due to some reason.

d)    The CSR Committee and the Board of Directors will disclose the reasons for not being able to spend the entire budgeted amount on the CSR activities as planned for that year in the Company’s Annual Report.

e)    The unutilized CSR budget from the two (02) per cent of the average net profit, if any, will be transferred to a separate bank account within 30 days from the end of financial year.

f)     The Board shall make disclosures in the Annual Report as per clause (o) of sub-section (3) of section 134 including particulars specified in annexures to the CSR Rules.

g)    Surplus arising out of CSR projects, programs or activities shall not form part of the business profits of the Company. Instead, the same will be further deployed for future CSR projects only.

9.Implementation of CSR Activities 
a)      The CSR Activities would be chosen for implementation by the Company in compliance with the provisions of Section 135 read together with Schedule VII of the Companies Act, 2013.

b)     The mode of implementation of CSR programs may include a combination of direct implementation and partnership with government institutions, training institutes external professionals/firms/agencies etc. and will select its activity partners after appropriate due diligence.

c)      The time period over which a particular project or program will be spread, will depend on its nature, extent of coverage and the intended impact of the program.

d)     The Company, may collaborate with other companies, including its Group Companies if required, for fulfilling its CSR objects through the Direct method, provided that the CSR Committees of respective companies are in a position to monitor separately such CSR Projects.

e)      The Company may encourage its employees to volunteer for community service.

10.Monitoring 

a)      The Company recognises that monitoring is critical for assessment of the progress as regards timelines, budgetary expenditure and achievement of targets. Monitoring maybe done periodically with the help of identified key performance indicators, the periodicity being determined primarily by the nature of key performance indicators.

b)     Monitoring will be done in project mode with continuous feedback mechanism, and recourse always available for mid-course correction in implementation, whenever required.

c)      The performance of the Company’s CSR activities would be monitored on the basis of their achievement of annual targets and the utilization of their annual budgets for the activities planned and the targets set for each year.

d)     Implementation and monitoring of the CSR activities will be overseen by the CSR Committee. The monitoring and evaluation may be assigned by the CSR Committee to an independent external agency for the sake of objectivity and transparency.

Reporting and Publications of Policy

a)        Annual Report on CSR activities shall be included in the Board's Report as per the formats notified in the Act.

b)       Additionally, the CSR Policy, Composition of CSR Committee and Approved CSR Projects shall be made available on the Company's website, if any

c)        If the Company fails to spend the required amount on CSR Activity, the Board shall, in its report made under Section 134(3)(o) of the Companies Act, 2013, specify the reasons for not spending the amount.

General Considerations
a)  In case of any doubt with regard to any provision of this CSR Policy and also in respect of matters not covered herein, a reference should be made to the CSR Committee. In all such matters, the interpretation and decision of the CSR Committee shall be final.

b)     All provisions of the CSR Policy would be subject to revision/amendment in accordance with the applicable laws.

c)      The Company reserves the right to modify, cancel, add, or amend this CSR Policy.

d)     Proceedings of all meetings must be signed by the Chairman of the Committee and tabled at the subsequent Board and Committee meeting.

 Review of the Policy 

The CSR Committee shall review the CSR Policy from time to time based on the changing needs and make suitable modifications as may be necessary with the approval of the Board. In case of any amendment(s), clarification(s), circular(s) etc. issued by the relevant authorities, not being consistent with the provisions laid down under this Policy, then such amendment(s), clarification(s), circular(s) etc. shall prevail upon the provisions hereunder and this Policy shall stand amended accordingly from the effective date as laid down under such amendment(s), clarification(s), circular(s) etc.

*** End of the Policy***