Corporate Social Responsibility (“CSR”) Policy is applicable to VKC Nuts Private Limited (“Company or VKC”) which is mandated with the CSR expenditure obligations as per Section 135 of the Companies Act, 2013 (‘the Act’) read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended from time to time.
The Objective of the policy is to be define VKC’s Corporate Social Responsibility approach in alignment with Section 135 of the Companies Act, 2013 read with applicable rules.
VKC’s endeavors to reach out to underprivileged and underserved societies to address fundamental challenges of our society by identifying selected causes to work with, thereby facilitating a social impact. We shall focus on the following areas which are specified in Schedule VII of the Companies Act, 2013 (as amended from time to time):
• Eradicating poverty, hunger and malnutrition, promoting health care which includes sanitation and preventive health care, contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water;
• Improvement in education which includes special education and employment strengthening vocation skills among children, women, elderly and the differently-abled and livelihood enhancement projects;
• Improving gender equality, 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.
• Safeguarding environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining a quality of soil, air and water which also includes a contribution for rejuvenation of river Ganga;
• 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 arts and handicrafts;
• 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 widows;
• Training to stimulate rural sports, nationally recognized sports, Paralympic sports and Olympic sports;
• Contribution to the Prime Minister’s National Relief Fund, Contribution to the Prime Minister’s National Relief Fund (PM-CARES) or any other fund set up by the Central Government for socio-economic development providing relief and welfare of the Scheduled Castes, the Scheduled and backward classes, minorities and women;
• Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government, State Government, Public Sector Undertaking or any agency of the Central Government or State Government.
• Contributions to public funded Universities, IITs, National Laboratories and autonomous bodies established under DAE, DBT, DST, Department of Pharmaceuticals, Ministry of AYUSH, Ministry of Electronics and Information Technology and other bodies, namely DRDO, ICAR, ICMR and CSIR, engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs);
• Rural development projects;
• Slum area development;
• Disaster management, including relief, rehabilitation and reconstruction activities;
• Any other measures with the approval of Board of Directors subject to the provisions of Section 135 of Companies Act, 2013 and rules made there-under.
3. UNDERTAKING CSR ACTIVITIES
The Company will undertake CSR activities which are established under section 8 of the Act, or a registered public trust or a registered society, registered under section 12A and 80G of the Income Tax Act, 1961 or such other entities prescribed under the Act, who are engaged in activities or programs which fall within the purview of VKC’s CSR Policy.
4. GOVERNANCE STRUCTURE AND APPROACH
VKC Nuts Private Limited has a Governance structure to oversee the implementation of the CSR Policy and monitoring of CSR projects as per the requirements of Section 135 of the Companies Act, 2013 and rules made thereunder.
5. ROLES AND RESPONSIBILITIES OF THE BOARD/ COMMITTEE (AS APPLICABLE) WITH REGARD TO CSR
a. Formulate CSR policy of the company.
b. The mode of implementation of CSR programs / projects may include a combination of direct implementation or implementation through Government, own foundation, charity partners, registered societies, civil societies, social partners etc.
c. Spend the allocated amount on CSR activities and create a transparent monitoring mechanism of CSR initiatives.
d. The Board / CSR Committee is authorized to settle all queries, differences or doubts that may arise in relation to the implementation of the CSR programs / projects
e. Submit periodic reports to the Board for the activities undertaken.
6. CSR BUDGET
VKC has undertaken to spend at least two per cent of the average net profit made during the three immediately preceding financial years on specific CSR projects and programs in compliance to the Companies Act. The computation of average net profits will be carried out in accordance with the provisions of Section 198 of the Companies Act, 2013.
7. IMPLEMENTATION PROCESS:
A. CSR Contributions:
The Company will endeavor to contribute and spend at least 2% of the average net profits of the Company made during the three immediately preceding financial years or such amount as may be approved by the board of Directors or Committee (if applicable) from time to time in pursuance of this Policy.
B. Monitoring and Reporting Mechanism:
The Company shall institute a monitoring mechanism for its CSR programs to ensure that each program has:
a. Targets, timelines and measurable parameters, wherever possible
b. A reporting framework that is aligned with the requirements of the legal provisions.
The Board of the Company shall satisfy itself that the CSR funds disbursed have been utilized for the purposes and in the manner as approved by it.
The Board 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 and rules made thereunder.
8. ANNUAL ACTION PLAN
The Board shall formulate an Annual Action Plan in pursuance of the CSR policy, which shall include the following:
a. The list of CSR projects or programmes that are approved to be undertaken in areas or subjects specified in Schedule VII of the Act
b. The manner of execution of such projects or programmes
c. The modalities of utilisation of funds and implementation schedules for the projects or programmes
d. Monitoring and reporting mechanism for the projects or programmes
e. Details of need and impact assessment, if any, for the projects undertaken by the company
9. IMPACT ASSESSMENT
Mandatory impact assessment will be undertaken as per the criteria specified under applicable law, and that the impact assessment reports will be placed before the Board and disclosed as per the Act and CSR Rules.
10. GENERAL DISCLOSURE
VKC has obligation and commitment to follow the provisions of section 135 of the Companies Act, 2013 and rules made thereunder.
The CSR Policy on being approved by the Board shall be displayed on the website of the Company and any modifications carried out from time to time shall also be updated on the website of the Company respectively.
This CSR Policy is subject to such changes and amendments as may be notified by the Ministry of Corporate Affairs under Section 135 of the Companies Act, 2013 and rules made thereunder and the same shall be read in line with the provisions of the Act applicable to the Company from time to time.