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CORPORATE SOCIAL RESPONSIBILITY POLICY

SRIT INDIA LIMITED

CIN: U72200KA1999PLC025692

Version No. 2.0

Dated 19

June 2025

 
Corporate Social Responsibility Policy 
Version 2.0 
 
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Table Of Contents 
 
1  INTRODUCTION .......................................................................................................... 3 
1.1  Purpose:...................................................................................................................... 3 
1.2  Scope .......................................................................................................................... 3 
1.3  Objective of CSR Policy ................................................................................................ 3 
2  DEFINITIONS ............................................................................................................... 3 
3  POLICY GUIDELINES .................................................................................................... 3 
4  CSR THRUST AREAS ..................................................................................................... 4 
5  GOVERNANCE STRUCTURE .......................................................................................... 4 
5.1  Role of the Board of Directors ...................................................................................... 5 
5.2  Composition and Role of CSR Committee ..................................................................... 5 
6  FUNDING AND ALLOCATION ....................................................................................... 5 
7  IMPLEMENTATION ...................................................................................................... 6 
8  MONITORING PROCESS OF CSR INTERVENTIONS ........................................................ 6 
9  CRITERIA FOR IDENTIFYING CSR PROJECT INTERVENTIONS ......................................... 6 
10  CRITERIA FOR IDENTIFYING IMPLEMENTING AGENCIES .............................................. 7 
 
Confidentiality Notice 
This document contains proprietary information of SRIT.  No part of this document may be reproduced, stored, copied, or transmitted in any form or by any 
means now known or hereinafter invented, electronic, digital, mechanical, photocopying, scanning, recording or by any information storage or retrieval 
system, without the express consent of SRIT.

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1 INTRODUCTION

1.1 Purpose:

The purpose of a Corporate Social Responsibility (CSR) policy is to formally outline SRIT’s

commitment to operating in an ethical, sustainable, and socially responsible manner. It defines

the organization's responsibilities beyond profit-making and highlights how we will contribute

positively to society, the environment, and the stakeholders.

1.2 Scope

This Policy shall be applicable to all CSR initiatives undertaken by the Company in pursuance of

the requirements of Section 135 and Schedule VII of the Act and the Rules thereof (including

any statutory modifications, amendments, or re-enactments of any of them for the time being

in force).

1.3 Objective of CSR Policy

The objective of this Corporate Social Responsibility (hereinafter “CSR”) Policy is to continuously

and consistently:

• Define and lay down the guiding principles and strategies for implementing the Company’s

CSR initiatives which state the approach and direction laid down by the Board of Directors

of the Company, upon the recommendation of the CSR Committee, and outline the Board’s

vision and approach for undertaking CSR and creating an impact in the communities.

• Laying down guiding principles for the selection, implementation and monitoring of

activities as well as the formulation of the annual action plan

2 DEFINITIONS

• “Company” means SRIT India Limited.

• “Act” or “the Act” means the Companies Act, 2013, as amended from time to time.

• “CSR Rules” means the Company’s Corporate Social Responsibility Policy Rules, 2014, as

amended from time to time.

• “Board” means the Board of Directors of the Company.

• “CSR Committee” means the Corporate Social Responsibility Committee constituted by the

Board of Directors pursuant to Section 135 of the Companies Act, 2013.

All other terms and expressions shall be as defined in the Act and Rules.

3 POLICY GUIDELINES

• All CSR Projects/ Activities must be aligned as prescribed in Schedule VII of the Companies

Act, 2013.

• Any Project/Activity undertaken in pursuance of normal course of the business of the

Company would not be considered as CSR.

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• CSR projects or programs or Activities must be undertaken in India only, (except the training

of Indian Sports Personnel representing any State or Union territory at the National level,

or India at the International level, anywhere outside India). Projects or programs or

Interventions that benefit only the employees of the Company shall not be considered as

CSR.

• CSR interventions should be in the project/program mode. One-off events such as

marathons/ awards/ charitable contributions/ advertisements/ sponsorship of TV programs

etc. and any other sponsorship activity deriving marketing benefits for the Company’s

products or services will not qualify as part of the CSR expenditure. A contribution to any

Corpus funds would not qualify as CSR.

• A contribution of any amount directly or indirectly to any political party shall not be

considered as CSR.

• Activities carried out for the fulfilment of any other statutory obligations under any law in

force in India will not qualify towards CSR requirements.

4 CSR THRUST AREAS

The Company may do CSR in any of the headings given in Schedule VII to the Act directly, or

through any registered Implementation Agencies. The Company shall give preference to the

areas around which the Company operates and the areas with identified needs for CSR

spending.

Thrust areas:

• Education & Livelihood

- Promoting education, including special education and employment enhancing vocation

skills especially among children, women, the elderly and the differently abled and

livelihood enhancement projects.

• Health and Sanitation

- Eradicating hunger, poverty and malnutrition, promoting healthcare including

preventive healthcare and sanitation, and making available safe drinking water.

• Environment

- Ensuring environmental sustainability, ecological balance, protection of flora and fauna,

animal welfare, Agro-forestry, conservation of natural resources and maintaining the

quality of soil, air and water.

In the event the CSR spendable amount is less than ₹10 Lacs in any year, or if the Company is

not able to identify any suitable activity/ project, the Company shall contribute to the Specified

Funds such as PM Cares/ PMNRF/ Clean Ganga Fund, etc.

5 GOVERNANCE STRUCTURE

The Company shall have a well-defined and robust governance structure to oversee the

implementation of the CSR Policy, in compliance with the requirements of Section 135 of the

Act and the Rules.

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5.1 Role of the Board of Directors

The roles and responsibilities of the Board of Directors towards CSR shall include:

• Provide recommendations and approval for the annual action plan formulated and

presented by the CSR Committee for spending of the prescribed CSR budget.

• Alter the recommended annual action plan at any time during the financial year, if required,

as per the recommendation of its CSR Committee, based on the reasonable justification to

that effect.

• Ensure that the Company spends, in every financial year, at least 2% of the average net

profits made during the three immediately preceding financial years, in pursuance of its CSR

Policy.

• Ensure that the Company treats the CSR Spends i.e. CSR surplus, excess expenditure and

unspent CSR funds, as prescribed in the Rules.

• Specify in its Report u/s 134 of the Act the reasons for not spending the amount if the

Company fails to spend such amount.

• Disclose the composition of the CSR Committee, and CSR Policy and Projects approved by

the Board on the Company’s website, if any, for public access.

5.2 Composition and Role of CSR Committee

The Board shall constitute or reconstitute the CSR Committee in compliance with the provisions

of the Act and Rules. The role of such a committee would be aligned to the provisions of the Act.

The Committee shall meet at least twice in a financial year or as frequently as required.

6 FUNDING AND ALLOCATION

For achieving the CSR objectives through implementation of meaningful and sustainable CSR

Projects, the Company will allocate for its Annual CSR Budget, 2% of the average net profits of

the Company made during the three immediately preceding financial years, calculated in

accordance with the relevant provisions of the Act and the Rules. The Company may spend up

to 5% of the total CSR expenditure in one financial year on building CSR capabilities and other

general and administrative overheads.

For an ongoing project, if any amount budgeted to be spent for the year remains unspent, then

such an unspent amount will be allocated towards such ongoing projects for spending in any of

the three succeeding financial years and will be transferred to the “Unspent Corporate Social

Responsibility account”, opened with a scheduled bank by the Company within 30 days from

the end of the financial year. For other projects, such amount will be contributed to a fund,

specified in Schedule VII, within 6 months of the expiry of the financial year.

Any surplus arising out of the CSR Projects or Programs or activities shall not form part of the

business profit of the Company and will be ploughed back into the project in the current financial

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year, or be allocated for an ongoing project to be spent in any of the 3 succeeding financial

years, or will be transferred to a fund specified in Schedule VII.

Any excess expenditure, i.e., beyond the prescribed CSR budget, will be disclosed in the Board’s

CSR Report and shall be made available for set off against the CSR requirement to spend in any

of the three succeeding financial years. The Board of Directors will satisfy itself that the funds

so disbursed have been utilised for the purposes and in the manner as approved by it and the

Chief Financial Officer, (and in his absence any other office in charge of the finance function),

will certify the same to that effect.

7 IMPLEMENTATION

The CSR Committee shall provide guidance on the allocation of the CSR budget among the thrust

areas on an annual basis and seek approval from the Board.

The CSR Projects will be undertaken based on the annual action plan formulated and

recommended by the CSR Committee, if any and approved by the Board. The Board may alter

the annual action plan at any time during the financial year, as per the recommendation of the

CSR Committee based on reasonable justification to that effect.

8 MONITORING PROCESS OF CSR INTERVENTIONS

• To ensure the effective implementation of the CSR intervention, a monitoring mechanism

shall be established by the CSR Committee/ Board to maintain a regular connect with the

implementing partner and take corrective actions at the right time.

• The implementing partners will report on a quarterly basis the progress of the project

activities, the utilization of funds disbursed and plans for sustainability of the project.

• The Board will monitor and review on a regular basis, or as and when required, the progress

of the CSR initiatives undertaken.

• The fund utilization made in projects as approved by the Board will be certified by the

Director of the Company, who gives instructions to the Finance Team in this regard.

• Applicable projects, as required by the Rules, shall be subjected to an in-depth impact study

to assess the impact created through the project.

• In case of deviation in implementation as defined in the annual action plan, such changes

will be approved by the CSR Committee/ Board.

• The CSR Policy and the list of approved projects will be uploaded on the Company’s website

and made available in the public domain.

9 CRITERIA FOR IDENTIFYING CSR PROJECT INTERVENTIONS

While identifying the CSR interventions, all efforts would be made to the extent possible to

define the following:

• Project objectives.

• Base line Survey/Need Assessment

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• Implementation schedules.

• Defined fund disbursement schedules.

• Responsibilities and authorities.

• Major results expected and measurable outcome.

• Impact on the lives of the Genuine Beneficiaries

10 CRITERIA FOR IDENTIFYING IMPLEMENTING AGENCIES

The CSR initiatives will be implemented either directly by the Company or through Implementing

Agencies (IA). The IA(s) being considered for a partnership will need to comply with the following

criteria:

• The IA can be a company established by the Company, either singly or along with any other

company, and can be a company established under Section 8 of the Companies Act, 2013 /

Registered Public Trust / Registered Society with a registration under Section 12A and

Section 80G of the Income Tax Act, 1961, or

• The IA can be a company registered under Section 8 of the Companies Act, 2013/ Registered

Public Trust / Registered Society with a registration under Section 12A and Section 80G of

the Income Tax Act, 1961 and with an established track record of at least 3 years, or

• The IA can be an entity established under the Act of Parliament or State Legislature, or

• The IA can be an entity established by the Central or State Government,

• The IA will need to have a permanent office in India.

All IAs meeting the above-mentioned conditions, will need to register themselves with the

Central Government by filing the e-form CSR-1 electronically, and obtain a unique CSR

Registration Number from the MCA. The Company may also collaborate with other companies

to undertake CSR Projects or Programs, provided the CSR Committees of the respective

companies are in a position to report separately on such projects or programs.