CORPORATE SOCIAL RESPONSIBILITY POLICY

INTRODUCTION

The term "Corporate Social Responsibility (CSR)" can be referred as corporate initiative to assess and take responsibility for the company's effects on the environment and impact on social welfare. The term generally applies to companies efforts that go beyond what may be required by regulators or environmental protection groups.

With regard to the public sector undertaking the CSR is need to be focused in much wider aspects because of the high level of public accountability attached to Public Sector Undertakings (PSUs) as a result of their public ownership.

Keeping in mind, the Committee of Public Undertakings (COPU) in 1992 examined the issue relating to social obligation of Central Public Sector Enterprises and observed that “being part of the ‘State’, every Public Sector Enterprise (PSE) has a moral responsibility to play an active role in discharging the social obligations endowed on a welfare state, subject to the financial health of the enterprise”.

In order to construct or to develop a sustainable society, we need companies in the world to be socially responsible corporates. Many companies are either willing or called upon in playing a positive role as regards social problems, thus to contribute a sustainable development (SD). The Companies purpose should regard the interests of all its stakeholders , to meet their requirements and to serve them in large.

While this policy document defines CSR vision of WBHDCL, it also elaborates the structure and methodology of implementation adopted by WBHDCL. The policy is in compliance with Sec 135 of the Companies Act 2013 and the rules notified thereunder.

Due consideration were also given to Schedule VII of the Act while identifying the focus areas of CSR programmes.

Applicability of CSR policy and formation of CSR committee.

The companies on whom the provisions of the CSR shall be applicable are contained in Sub Section 1 of Section 135 of the Companies Act, 2013. The pictorial representation below gives the representation of Section 135 (1).

NET WORTH OF INR 500 CRORE OR MORE OR TURNOVE R OF INR 1000 CRORE OR MORE OR NET PROFIT OF INR 500 CRORE OR MORE

The Company needs to constitute CSR committee as the net worth of the Company exceeded Rs.500 Crores during the year 2014-2015.

The CSR Policy of the Company need to be framed by the company mentioning the list of CSR projects or programs which WBHDCL plans to undertake, specifying modalities of execution of such projects or programs and implementation schedules for the same and Monitoring process of such projects and program.

It is pertinent to ensure that CSR activities does not includes the activities undertaken in pursuance of normal course of business of the Company.

THE OBJECTIVES OF THE POLICY

This Policy shall be read in line with Section 135 of the Companies Act 2013, Companies (Corporate Social Responsibility Policy) Rules, 2014 and such other rules, regulations, circulars, and notifications (collectively referred hereinafter as Regulations‘) as may be applicable and as amended from time to time and will, inter-alia, provide for the following:

Establishing a guideline for compliance with the provisions of Regulations to dedicate a percentage of Company’s profits for social projects.

Ensuring the implementation of CSR initiatives in letter and spirit through appropriate procedures and reporting

Creating opportunities for employees to participate in socially responsible initiatives.

DEFINITIONS

In this Policy unless the context otherwise requires:

"Act" means the Companies Act, 2013;

"Annexure" means the Annexure appended to these policy.

"Corporate Social Responsibility (CSR)" means and includes but is not limited to

Projects or programs relating to activities specified in Schedule VII to the Act or
Projects or programs relating to activities undertaken by the Board of Directors of a company (Board) in pursuance of recommendations of the CSR Committee of the Board as Per declared CSR Policy of the company subject to the condition that such policy will cover subjects enumerated in Schedule Vll of the Act.

"CSR Committee" means the Corporate Social Responsibility Committee of the Board referred to in section 135 of the Act

"CSR Policy" relates to the activities to be undertaken by the company as specified in Schedule VII to the Act and the expenditure thereon, excluding activities undertaken in pursuance of normal course of business of a company.

"Net profit" means the net profit of a company as per its financial statement prepared in accordance with the applicable provisions of the Act, but shall not include the following, namely:-

Any profit arising from any overseas branch or branches of the company' whether operated as a separate company or otherwise;
Any dividend received from other companies in India, which are covered under and complying with the provisions of section 135 of the Act:

Provided that net profit in respect of a financial year for which the relevant financial statements were prepared in accordance with the provisions of the Companies Act, 1956 (1 of 1956), shall not required to be re- calculated in accordance with the provisions of the Act.

(2) Words and expressions used and not defined in these rules but defined in the Act shall have the same meanings respectively assigned to them in the Act.

WBHDCL'S APPROACH TOWARDS CORPORATE SOCIAL RESPONSIBILITY.

The approach of WBHDCL towards Corporate Social Responsibility would be oriented to identify and formulate CSR projects/programmes as per statutory requirement and to implement them with full involvement and commitment in a time bound manner. In cases where other agencies/organizations are involved, approach would be to focus on collaboration and partnership. It will also provide financial assistance in the form of grant-in-aid assistance, contribution etc.

WBHDCL would endeavour to adopt an integrated approach to address the community, societal & environmental concerns by taking up a range of the following activities, which shall be ta ken up strategically, in a focused manner to the extent possible and allowed as per the CSR policy.

In implementing the CSR Policy, WBHDCL will extend its reach and oversight to the entire supply-chain network to ensure that as far as possible the suppliers, vendors, service providers, clients, and partners are also committed to the same principles and standards of CSR as WBHDCL itself. For the CSR agenda to be internalized in the organization, the employees at all levels in WBHDCL will be educated to the need for conducting business in a manner that is economically, socially and environmentally sustainable.

WBHDCL will devise internal communication strategies to spread awareness of CSR amongst the employees, providing them with education and training necessary for attitudinal change and their conversion to socially and environmentally sustainable methods and practices of doing business, and adopting motivational tools to provide just the right momentum to push all such initiatives.

AIMS AND OBJECTIVES OF WBHDCL FOR CSR

As a responsible corporate entity, WBHDCL will consistently strive for opportunities to meet the expectation of its stakeholders by pursuing the concept of sustainable development with focus on undertaking statutorily required CSR projects/programmes within the State of West Bengal.

Corporate Social Responsibility is WBHDCL’s commitment to its stakeholders to conduct business in an economically, socially and environmentally sustainable manner that is transparent and ethical. Stakeholders include employees, investors, shareholders, customers, business partners, clients, civil society groups, other Government and non-government organizations, local communities, environment and society and public at large.

SCOPE OF CSR AND ACTIVITIES UNDER CSR.

For attaining the above aims and objectives the following activities can be undertaken under Corporate Social Responsibility:

Education.

Support to Technical /Vocational Institutions for their self -development.

Academic education by way of financial assistance to Primary, Middle and Higher Secondary Schools.

Awareness Programmes on girl education.

Special attention on education, training and rehabilitation of mentally & physically challenged children/persons.

Provide fees for a period of one year or more to the poor and meritorious, preferably girl students of the school in the operational area of the Company to enable them to get uninterrupted education.

Providing scholarship to underprivileged children who cannot afford to study.

Water Supply including Drinking Water.

Installation/Repair of Hand Pumps/Tube Wells/ Digging/Renovation of Wells.

Gainful utilization of waste water from Under -ground Mines for Cultivation or any other purpose.

Development/construction of Water Tank/Ponds.

Rain water-harvesting scheme.

Formation of a Task Force of Volunteers to educate people regarding proper use of drinking water.

Health Care organising, health awareness Camps on.

AIDS TB and Leprosy

Social evils like alcohol, smoking, drug abuse etc.

Child and Mother care

Blood donation camps.

Fully equipped Mobile Medical Vans.

Providing assistance for artificial limbs to those who cannot afford.

Environment.

Organizing sensitizing programmes on Environment Management and Pollution Control.

Green belt Development.

Afforestation, Social Forestry, Check Dams, Park Restoration of mined out lands.

Development of jobs related to agro product i.e., Dairy/Poultry/farming and others.

Plantation of saplings producing fruit.

Animal care centres.

Providing relief in case of natural disasters.

Sponsoring medical treatment to backward section who cannot afford.

Sports and Culture.

Promotion of Sports and Cultural Activities for participation in State and National level.

Promotion of State level teams.

Sponsorship of Cultural event to restore Indian Cultural Traditions and Values such as classical music ,dance, theatres etc.

Infrastructure Support – construction, repair, extension etc. of:-

Auditorium

Educational Institutions

Rural Dispensaries initiated by reputed NGOs.

Mobile Crèches.

Check Dam

Sulabh Souchalaya,

Old Age Home.

Growth and Development of the society:

Skill building and livelihood generation.

Contribution to the approved funds for providing relief or for socio-economic development and/or welfare activities that may be prescribed from time to time.

Contribution to the Prime Minister’s National Relief Fund or any other fund set up by the Central Government for social-economic development and relief and welfare of the Scheduled caste, the Scheduled Tribes, other backward classes, minorities and women.

Contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government;

Rural development projects.

Slum area development

Swachh Bharat Abhiyan, Swachh Vidhyalaya, construction of toilet facility and connected infrastructure facilities and any other programme promoting sanitation, sewerage, toilet facilities, etc.

THE GEOGRAPHIC REACH AND PROHIBITED ACTIVITIES UNDER CSR

The Act provides that the Company shall give preference to the local area and areas around it where it operates, for spending the amount earmarked for Corporate Social Responsibility. The Company will thus give preference to conducting CSR activities in the state of West Bengal herein the Company has/will have its operations. However, the Committee may identify such areas other than stated above, as it may deem fit, and recommend it to the Board for undertaking CSR activities.

The Company will abstain from carrying out following activities under CSR which may create dissatisfaction among any section of the Society:-

Activities concerned with religion like construction of temple/mosque etc.

Activities disturbing social harmony in any manner.

Contribution of any amount directly or indirectly to any political party.

AUTHORITY AND CONSTITUTION OF CSR COMMITTEE

Constitution of CSR Committee

Authority

 

Board of Director

Ensuring that the CSR Activities included by each Company in its CSR Policy are related to the activities included in Schedule VII of the Companies Act 2013.

Approving the CSR policy as recommended by the CSR Committee

Ensuring that in each financial year, the Company spends the approved budget in compliance with the Companies Act 2013 - Section 135 and notified rules

Ensuring that every financial year, funds committed by the Company for CSR activities are utilized effectively and monitored as per a structured process

Constitution of CSR Committee

The Company have to constitute a CSR Committee of the Board as per the provisions of the Act, read together with the Companies (Corporate Social Responsibility Policy) Rules, 2014, to ensure that the purpose of this Policy is being effectively served as above mentioned in Point 1.1.

The same will be constituted in the 18th meeting of the Board of Directors. The Committee shall have powers as mentioned and specified in Point in 9

Managing Director

Managing Director shall implement the decision taken by the CSR Committee through CSR Cell or functional heads and shall be authorised to spend within the approved Annual CSR Budget as per the following approval matrix;

  Level of Approval Remarks
Roll-on plans, broad suballocation of expenditure, reappropriation, carry forward etc. CSR Committee of Director Approval obtained once in a year.
With a view to effectively take up CSR activities without any delay also, the Managing Director of the Company is authorised to spend within the approved Annual CSR Budget as well as also to use the budget allocated to particular head into such other head as may be deemed fit. Managing Director and Chairman – CSR Activity --
Hiring of external agencies as an when found necessary for identifying CSR Projects/programmes, carrying out CSR Projects/programmes, undertake assessment of the Project/programme while it is being implemented, undertake impact assessment of the project at the end of the Projects/programmes, carry out audit of utilisation of CSR expenditure spend on the Projects/programmes Managing Director --

ROLES & RESPONSIBILITIES OF THE CSR COMMITTEE

Prepare, revise and modify the CSR Policy for the Company and place the same with the Board of Directors for its approval.

Ensure that the programmes /projects undertaken by the Company on its own or through the implementing partners are aligned with the approved CSR policy of the Company and are also aligned to Schedule VII and Section 135 of the Act.

Will provide guidelines for selection of projects/ programmes or implementing partners to the respective Human Resource or CSR teams, wherever applicable

Review and approve annual budgets with respect to CSR programs.

In case the Company is not able to spend the stipulated two percent of the average net profits of the preceding three financial years or any part thereof, the CSR Committee shall provide the reasons for not spending the amount to the Board and such reasons shall also be included in the Board’s report

Reviewing the findings and recommendations regards the CSR initiatives from any investigation or audit conducted by regulatory agencies or external auditors or consultants

Respond to any query, observation or clarification sought by the Ministry of Corporate Affairs or any other regulatory authority with regard to the Company’s CSR supported initiatives.

Ensure that the Company’s website displays the approved CSR policy.

Develop and institutionalize a CSR reporting mechanism.

Develop, recommend and oversee CSR Action Plan.

Monitor the Corporate Social Responsibility Policy of the company from time to time.

And any other responsibility, as may be suggested by the Board.

IMPLEMENTATION:

The investment in CSR should be project based and for every project time framed periodic mile stones should be finalised at the outset.

Project activities identified under CSR are to be implemented by Specialised Agencies and generally NOT only by the staff of the organisation to ensure proper and justified utilisation of the company’s fund. Specialised Agencies could be made to work singly or in team with other agencies.

Such specialised agencies would include:

Community based organization whether formal or informal.

Elected local bodies such as Panchayats.

Voluntary Agencies (NGOs).

Institutes/Academic Organisations.

Trusts, Mission etc.

Self-help groups.

Government, Semi Government and autonomous Organisations.

Standing Conference of Public Enterprises (SCOPE)

Mahila Mondals/Samitis and the like Contracted agencies for civil works Professional Consultancy Organization etc.

FUNDING

As per the regulations the company will set aside, for annual CSR activities, an amount equal to 2% of the average net profits of the Company made during the three immediately preceding financial years.

Any unutilized CSR allocation fund of a particular year, will be carried forward to the next financial year i.e. the CSR budget will be non lapsable in nature.

The tax treatment of CSR spent will be in accordance with the Income Tax Act, 1961 as may be notified by the central board of Direct taxes.

BUDGET

The Company Board of Directors shall ensure that in each financial year the Company spends at least 2% of the average Net Profit made during the three immediate preceding financial years.

As per section 135 of the Companies Act, the Company will report reasons for under spending of the allocated CSR budget of the current financial year in the template provided by the Ministry of Corporate Affairs. This reporting will be done Annual Report and signed off by the Board of Directors.

In case of any surplus arising out of CSR projects the same shall not form part of business profits of the Company.

AMENDMENTS TO THE POLICY.

The Board of Directors on its own and/or on the recommendation of CSR committee can amend its policy as and when required deemed fit. Any or all provisions of CSR Policy would be subjected to revision/amendment in accordance with the regulations on the subject as may be issued from relevant statutory authorities, from time to time.

IMPLEMENTATION OF THE POLICY.

The policy has been implemented w.e.f 30th March, 2016 with the approval of the CSR Committee of WBHDCL.