Mercer | Mettl’s CSR Policy

Purpose

Induslynk is committed to its culture of Corporate Social Responsibility (CSR). Company endeavor to contribute to a healthy and sustainable world through policies and measures.

We aim to strengthen our efforts through our CSR policy that will provide guidance for selection, implementation, and monitoring of activities as well as formulation of annual action plan to identify, execute and monitor the CSR projects.

The objective of this policy is to take up CSR projects in various areas such as education, skill development, livelihoods, healthcare, infrastructural development in rural areas, environment development etc.

Induslynk is committed to act as a good corporate citizen and to comply with all the provisions as set down in Section 135 of the Companies Act, 2013 (hereinafter referred to as “Act”), the Rules.

CSR Approach & Commitments

Through its CSR programmes, Induslynk aims to reach out to underprivileged and underserved sections of the society to address developmental needs and in turn improve lives and build a more inclusive society, including environment improvement initiatives.

This Policy will be applicable to all projects/programs undertaken by Induslynk as part of its CSR initiatives. The policy is created as per the requirements of the Act and is aligned with our local and international standards /best practices /mission and policies.

Our CSR programmes would give preference to the local area and areas around where it operates, for spending the amount earmarked for Corporate Social Responsibility activities. However, depending on the nature and worthiness of a CSR programme, the Company may decide to extend its spread anywhere within the boundaries of the country.

The Company will focus on areas including but not limited to the following:

Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects
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. Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swachh Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water.
Any other project as suggested by CSR Committee that falls within the gamut of Schedule VII.

Governance

1. Board of Directors (Board)

The Board to monitor the implementation of the project with reference to the approved timelines and year-wise allocation and shall be competent to make modifications, if any, for smooth implementation of the project within the overall permissible time-period.

The Board 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.

2. CSR Committee

CSR Committee is a Committee of Board of Directors of the Company and is responsible to provide guidance on CSR activities and monitor compliance with CSR Policy, commitments as per the applicable CSR provisions as per the requirements of the Act.

The Committee shall have minimum two members who would be the Directors of the Company.

CSR Committee will be responsible for the following:

To approve the CSR policy (including revisions)
To ensure the Company spends in every financial year, at least 2% of its average net profit during the three preceding financial years, in pursuance of this policy and in line with requirements of the Act
To approve action plan and budget as per the requirements of the Act
To approve CSR projects, programs, activities as per an annual action plan
To define manner of execution / implementation, modalities of utilization of funds
To oversee monitoring of programmes and projects
Any other responsibilities as per the provisions of the Act and rules made thereto.

3. CSR Representative

The CSR representative will oversee the CSR team and will be responsible:

For day-to-day functioning, monitoring of projects/programmes including programme outcomes,
Execution of the contracts/MOU/agreements related to CSR activities of the Company
CSR fund utilization in line with the contractual requirements and CSR Rules
To present the report/outcomes/updates etc. to CSR Committee and the Board

4. CSR Spends

All CSR expenditure to be done as per the limits prescribed under the Act and CSR Rules and any amendments made thereto.

5. Annual Action Plan on CSR Activities

As prescribed under CSR Rules, at the beginning of every financial year, CSR Representative shall prepare a detailed Annual Action Plan on CSR activities for the financial year. The Annual Action Plan to be presented before the CSR Committee and the Board for its approval. The CSR Committee will recommend the Annual Action Plan for approval of Board. On approval of the Board of Directors, any deviation from Annual Action Plan will only be made with the prior approval of Board, on recommendation of CSR Committee. Annual Action Plan shall contain detailed information on the following:

List of CSR projects that are to undertaken for the financial year
Manner of execution of these CSR projects
Modalities of utilization of funds, year-wise (in case of multi-year projects)
Implementation schedules for all CSR Projects
Monitoring and reporting mechanism for all CSR projects
Details of need & impact assessment studies, if any, for CSR projects undertaken earlier
Any other information as required under the CSR rules.

The company may take up other CSR activities during the financial year, as may be considered appropriate in accordance with approval of CSR Committee and the Board.

6. CSR Budget and Expense Management

The CSR Committee will approve the CSR fund allocation in each financial year.

CSR expenditure shall include all expenditure including contribution to corpus for projects or programs relating to CSR activities approved by the Board on the recommendation of its CSR Committee but does not include any expenditure on an item which is not in conformity or not in line with activities which fall within the perview of Schedule VII of the Act.

The administrative overheads* shall not exceed five percent of total CSR expenditure of the company for the financial year.

Guiding principles for selection, implementation and monitoring of CSR activities

1. Selection principles:

Name of the person proposing or referring the CSR partner to be recorded in the proposal made to CSR Committee and the Board
Partner selected to be aligned to the areas/themes agreed for CSR activities
The proposed CSR partners may be selected post clearance of the Due diligence as per Annexure 1.

2. Implementation principles:

CSR Representative to ensure:

Induslynk undertakes its CSR activities through partnerships with reputed not-for-profit organizations holding a track record of 3 years or more in undertaking CSR activities. The non-profit organization will be selected after appropriate due diligence exercise and basis their experience and expertise will be on-boarded as a project partner and in line with the requirements of the Act, and rules made thereto.
The implementation of the CSR activities approved by the CSR Committee and the Board.
That the disbursed CSR funds have been utilized for the purposes and in the manner as approved by the CSR Committee and the Board and also ensure the Chief Financial Officer or the person responsible for financial management shall certify to the effect.
To inform any delay in spending of the allocated CSR funds to the CSR partners.
To get utilization certificate by a Chartered Accountant
To take any other steps as per guidance or instruction of the CSR Committee and the Board.

3. Monitoring principles:

The CSR Representative to ensure periodic monitoring of projects as per the contractual requirements and CSR Rules and submit a quarterly report on CSR activities to the CSR Committee and Compliance.
The CSR Representative may appoint a reputed external agency, in consultation with Compliance to monitor implementation of projects on the ground, who are responsible to report end-to-end activities vis a vis objective of projects.
The CSR representative shall present a monitoring report to the CSR Committee and the Board on quarterly basis.

Annexure 1

Sr. No.	Particulars	Response
01	Complete Name of the Trust/ Society/ Company
02	Registered office address and local office address, if any
03	Certificate of registration/ incorporation of the Trust/ Society/ Company (provide a copy of the referred documents
04	Background of the proposed CSR activity
05	Please confirm if the Trust or Society or Company has track record of three years in undertaking similar programs or projects.
06	Please share the proposed CSR funds to be utilized for the transaction.
07	Please confirm the monitoring mechanism of the CSR activity.
08	Please confirm the relevant CSR head (Approved by the Board/ CSR Committee) for the CSR activity.
09	Please confirm if we already have any relationship with the said Trust/ Society/ Company.
10	Please confirm if there is any conflict of interest with said Trust/ Society/ Company
11	Please confirm if the Trust/ Society/ Company is involved with promoting religious doctrine.
12	If the Trust/ Society/ Company or its members/ partners/ Directors/ Trustees/ key management employee or work for government contracts/ tenders/ bids etc. or relate to the Government.
13	Please confirm if due diligence or other information indicates that transaction with the said Trust/ Society/ Company could embarrass or harm the reputation of the company or its clients.
14	Please share approval from CSR leader to proceed with the said CSR activity.
15	Please confirm whether CSR Team has obtained certification from Finance prior to every CSR Committee / Board Meeting
16	Please share confirmation mail from Finance Controller certify that the CSR Fund disbursed by the Company have been utilized for the purposes and in the manner as approved by the Board. (Quarterly Monitoring activity)
17	Please share confirmation mail from Finance / Tax to ensure that CSR partners registered under the income Tax ACT
18	Has the referred Society, Trust, NGOs etc. filed CSR registration number, if yes, please share the CSR registration number/ document.
19	Please share the link wherein the details with aforementioned CSR partner would be displayed
20	Any other queries which may be relevant for due diligence.

Revision No.	Revision Date
01	7th April 2023

Corporate Social Responsibility Policy

Annexure 1

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