Corporate Social Responsibility Policy

Regulatory framework

This Corporate Social Responsibility (hereinafter referred to as 'CSR') Policy is framed in terms of the Companies Act, 2013 (hereinafter referred to as 'the Act') read with the Companies (Corporate Social Responsibility Policy) Rules, 2014 (hereinafter referred to as 'the CSR Rules'), as amended from time to time.

The Companies Act, 2013 together with the rules notified there under ('the Act') and Schedule VII to the Act provides a framework for companies to define the focus areas in the CSR space. The law also guides companies to apply the scope as defined under Schedule VII liberally. Further, the Act also provides instructions on agencies eligible for implementation through which the Companies may spend its CSR expenditure. Vineeth Precious Catalysts Pvt. Ltd.'s (hereinafter referred to as 'The Company') CSR Policy, focus areas and the implementing agencies shall therefore remain within the boundary set by the law.

Philosophy

This CSR Policy of the Company, as recommended by the Corporate Social Responsibility Committee (hereinafter referred to as CSR Committee) and approved by the Board of Directors (hereinafter referred to as Board), outlines a clear agenda through which we will continue to contribute to the communities directly or through various CSR eligible entities engaged in such activities. The objective of this policy set the direction for the CSR activities of the Company and defines the governance and monitoring framework for ensuring the effectiveness of the policy.

Programmes, projects , activities and contributions to other CSR eligible entities engaged in such activities(hereinafter collectively referred to as 'CSR Programmes') will be carried out in this regard are the subject matter of this Policy.

CSR Policy

It is the Company's CSR Policy to direct and contribute to other CSR eligible entities under its CSR Programmes, inter alia, towards achieving one or more of the following - poverty alleviation; promoting education and skill development; promoting healthcare including preventive healthcare; providing sanitation and drinking water; ensuring environmental sustainability; enabling climate resilience; rural development projects; creating livelihoods for people, especially those from disadvantaged sections of society; protection of national heritage, art and culture; preserving and promoting music and sports; and providing relief and assistance to victims of disasters and calamities.

In pursuit of the above, the Company has identified the following focus areas for its CSR Programmes based on comprehensive need assessment surveys of its stakeholders :

Create sustainable livelihoods and alleviate poverty through promotion of, inter alia, forestation, water stewardship, sustainable agriculture and climate smart practices, livestock development and women empowerment;
Uplift the social life of the backward areas through providing better education facilities;
Build capabilities for tomorrow through interventions in, inter alia, education, vocational training, sanitation, school WASH (Water, Sanitation & Hygiene), safe drinking water and solid waste management;
Promote healthcare, including preventive healthcare, and improve critical nutritional & health status of at-risk population through interventions to strengthen mother & child health, nutritional content, delivery, outreach and outcomes;
Protect national heritage, art & culture, and preserving & promoting music and sports; and
Provide relief and assistance to victims of disasters and calamities.

Aims Of The Company

To develop the required capability and self-reliance of beneficiaries at the grass roots, especially of women, in the belief that these are pre-requisites for social and economic development;
To improve the social life through educating children in backward areas.
To engage in affirmative action interventions such as skill building and vocational training;
To pursue CSR Programmes primarily in areas that fall within the economic vicinity of the Company's operations to enable close supervision and ensure maximum developmental impact;
To enter into public-private-people partnerships to multiply the impact of the CSR Programmes;
To carry out CSR Programmes in relevant local areas to fulfil commitments arising from requests by government / regulatory authorities;
To provide equal opportunities to beneficiaries of the CSR Programmes;
To promote sustainability in partnership with industry associations, like the Confederation of Indian Industry (CII) through the CII-ITC Centre of Excellence for Sustainable Development.

Implementation

The Company's CSR Programmes will be implemented through (i) Company personnel, or (ii) external implementing agencies, or (iii) Company's Trusts if any, and (iv) such other Trusts, Societies, Foundations and Section 8 companies that may be established by the Company from time to time.

In case CSR Programmes are implemented through external agencies or ITC Trusts, the programmes to be undertaken by those agencies or Trusts will be specified, and it will be ensured that such programmes are covered in the Objects laid down in the respective Trust Deeds / Memoranda and Articles of Association of the external agencies / Company's Trusts.

Governance

The CSR will review, monitor and provide strategic direction to the Company's CSR practices towards fulfilling its objectives. The Committee will also guide the Company in crafting unique models to support creation of sustainable livelihoods together with environmental re-generation.
Every year, the CSR Committee will place for the approval of the Board of Directors of the Company (hereinafter referred to as 'the Board'), an annual CSR Action Plan (hereinafter referred to as 'CSR Plan') delineating the CSR Programmes to be carried out during the financial year, including the budgets thereof, their manner of execution, implementation schedules, modalities of utilisation of funds, and monitoring & reporting mechanism for the CSR Programmes. The Board will consider and approve the CSR Plan with such modification that may be deemed necessary; the CSR Plan may also be modified by the Board during the financial year, on the recommendation of the CSR Committee.
The Board will ensure that the Company's CSR Programmes address major development challenges of the country and are aligned with the priorities of the Government.
The Board will also assign the task of implementation of the CSR Plan within specified budgets and timeframes to such persons or bodies as it may deem fit, and ensure implementation thereof.
CSR committee will provide report back to the board on the progress of the CSR Programmes at half-yearly intervals, or at such other frequency as the board may direct.
The aforesaid report back will also include the following: Summary of impact assessment report(s) for the CSR Programmes highlighting their impact and outcome against the goals and objectives; and
In case of ongoing CSR Programmes (having time schedule of three years or more), progress of their implementation with reference to approved timelines and year-wise allocation.
The Board will review the report back and issue necessary directions from time to time to ensure orderly and efficient execution of the CSR Programmes in accordance with this Policy.
Once every six months, the Board will provide a report back to the CSR Committee on the progress of implementation of the approved CSR Programmes carried out during the six month period, covering details of achievement against planned deliverables for each intervention.
The aforesaid report back will also include confirmation from the Chief Financial Officer that the funds disbursed for the CSR Programmes are being utilised for the stated purpose and in the specified manner. The CSR Committee will review the report back and keep the Board apprised, once every six months, on the status of implementation of the CSR Programmes.
At the end of every financial year, the CSR Committee will consider an Annual Report on CSR activities and recommend the same for the approval of the Board. The said Report will be disclosed as part of the Report of the Board of Directors & Management Discussion and Analysis of the Company (hereinafter referred to as the 'Board's Report').

CSR Expenditure

It will be the Company's endeavour to spend in every financial year, two percent of its average net profits during the three immediately preceding financial years (or such other limit as may be prescribed under the Act), on CSR Programmes in pursuance of this Policy.
The CSR expenditure will include all expenditure, direct and indirect, incurred by the Company on CSR Programmes undertaken in accordance with the CSR Plan.
Any surplus arising from the CSR Programmes will be used for CSR activities within six months from the end of the relevant financial year. Accordingly, any income arising from CSR Programmes will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.
If CSR expenditure in a financial year exceeds the statutory limit, such excess may be set-off against CSR expenditure for the next three financial years with the approval of the Board, on the recommendation of the CSR and Sustainability Committee.