CSR Policy

Background:

MHFSL recognises that Section 135 of the Companies Act, 2013 and the rules framed there under afford an opportunity to involve itself in socially beneficial programmes and activities to create a positive social impact through engagement with community. The CSR programme of MHFSL will stand focused primarily on sections of local communities which are disadvantaged, vulnerable and marginalised. The CSR programme will be focused on building social infrastructure. MHFSL has strong roots in social causes as evidenced by the work done by Dr T M A Pai, the founder of innumerable Manipal Institutions in the field of implementation of various activities beneficial to community at large.

Objectives of the Policy:

The Board directed that objectives be spelt out more comprehensively as indicated below:-

• To make CSR a key business process for sustainable development by means of formulation and adoption of suitable guidelines for adherence on an on-going basis.
• To contribute to the welfare of the community by implementing such projects, programmes and activities as may provide benefit to the community.
• To ensure visibility and transparency in CSR spending and also in the implementation of CSR activities and programmes.
• To build up and maintain favourable public image in the process of utilisation of CSR spending opportunities.
• To utilise the opportunities afforded by CSR activities to expand the market for MHFSL products.
• To build up strong ties with the community and amass goodwill.
• No contribution will be made by MHFSL towards activities/programmes undertaken/to be undertaken outside India.

CSR Activities:

The CSR activities listed in the modified Schedule VII are the following:-

• Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation and making available safe drinking water;
• Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects;
• Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
• 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;
• 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;
• Training to promote rural sports, nationally recognised sports, paralympic sports and Olympic sports.

Apart from the list of activities taken from modified Schedule VII of the Companies Act, 2013, the Board resolved to add the following additional activities to the list, thereby further expanding scope of the policy. The Board felt that the scope of the policy must be as wide as possible to allow MHFSL to respond to the changing requirements from time to time and also to provide for flexibility in the matter of implementation of CSR programme. The additional activities added by the Board are the following:-

• Funding and supporting Trusts, NGOs and Charitable Organisations operating in the command area and preferably those having 80G approval and engaged in such activities as promotion of education in general and to the differently abled in particular, health care to the weaker sections of community, etc.
• Skill development by means of sponsoring programmes of rudesetti/self-employment training institutions.
• Participation in Swatch Bharath Abhiyan by funding construction of toilets in government schools/private schools in the local areas.
• Funding installation of CC camera in girls’ schools/girls’ high schools/girls’ colleges.

Role of the CSR Committee:

The Board of the MHFSL constituted a Corporate Social Responsibility Committee of Directors. The Committee will play the role detailed below in the matter of implementation of CSR activities and fulfilling MHFSL’s CSR objectives.

• Formulation and review of CSR policy;
• Identification and selection of activities to be undertaken by MHFSL under CSR programme
• Recommendation of the amount of expenditure to be incurred on CSR activities and allocation of amounts already decided upon between different activities selected for implementation.
• Formulation and adoption of suitable monitoring mechanism for ensuring the implementation of the projects/activities/programmes to be undertaken by MHFSL and also the end use of the amount spent under CSR programme.
• Monitoring the implementation of this policy from time to time.
• Reporting to the Board, the CSR activities identified and adopted from time to time and status of implementation of different activities and the amount spent for different activities from time to time.
• Any other requirement/responsibility mandated under the Act and the Rules framed there-under.

CSR Amount:

The MHFSL shall ensure that it spends in every fiscal year atleast 2% of its average net profits made during the three immediately preceding financial years in pursuance of its corporate social responsibility subject to what is stated in section 135 of the Companies Act and the Rules framed there-under. The Net Profit mentioned above implies Net Profit of MHFSL as defined under the Provisions of the Companies Act and Companies (Corporate Social Responsibility Policy) Rules, 2014. For the purpose of this policy, the first CSR spending financial year is 2014 and the amount ear marked for this purpose is 13,79,396/-. For future years, amounts will be ear marked in terms of the above formula.

Spending of CSR amount:

The CSR Committee will decide following with regard to spending of CSR amount:-

• Percentage of the amount to be contributed to Prime Minister’s Relief Fund or any other funds of the Central Government or State Government.
• Percentage of amount to be spent for the activities selected for the purpose activity-wise.
• Instalments of disbursement/utilisation.
• Any surplus arising from CSR projects/programmes/activities will not be brought back to MHFSL by way of surplus/profit/revenue.
• The Committee may recommend for contribution of amounts to any other trust/organisation for such purposes as medical aid to poor patients, scholarships for students belonging to weaker sections of society/provision of benefits to differently abled, etc.

Process for undertaking CSR programme/activities/projects:

Following procedure will be adopted while undertaking/funding CSR projects/activities and programmes.

• Assessing the activities from the point of view of its suitability/appropriateness to provide benefit to the community around and recommending the same to CSR Committee.
• Contribution to be made will be for a particular project identified by MHFSL.
• Disbursement of the contribution by MHFSL to identified trusts/charitable organisations/NGOs shall be made only if they have the requisite approvals/authority/registration under the appropriate statutes/rules.
• The disbursement will be made only on receipt of the request from the trust/NGO/charitable organisation indicating the amount required for the project identified in that behalf.
• Such request should be accompanied by a statement of activities and the request will be placed before the CSR Committee for decision. MHFSL will indicate the activity for which amount has to be spent as per the approval of the CSR Committee to the NGO/trust/charitable organisation and it must be ensured that amount is spent for that purpose alone and end use is done.

Monitoring:

MHFSL will monitor utilisation of the amounts contributed to different organisations under the CSR activity.

• MHFSL may call for detailed reports/statements indicating details of expenditure and physical results
• Operational/progress reports from time to time indicating therein the progress made in implementation of the activities by trusts/charitable organisations/NGOs.
• Copies of any other reports or communication received from auditors relating to the activities/spendings of the trust/charitable organisation/NGO, if any.
• Any other information which may be required by MHFSL in connection with monitoring the spendings and implementation of the activities/projects and achievement of the physical targets.

Monitoring mechanism:

To review or assess the progress of implementation of CSR activities and end use of the contributions, the following monitoring mechanism be adopted by MHFSL.

• Field visits by the staff/individuals to be deputed by MHFSL
• Undertaking sample internal audit of the projects/activities by MHFSL staff
• Review of reports/statements to be submitted by NGOs/trusts/charitable organisations.
• The MHFSL may engage external agencies to evaluate CSR projects and monitor its progress wherever necessary. Internal staff may also be authorised to evaluate and monitor the progress.

Reporting to the Board:

MHFSL shall report to the Board of Directors through the CSR committee regarding the CSR activities and projects implemented during the year, the amount spent thereon activity-wise and the impact created by such projects/activities implemented during the year, etc and the report should be on an yearly basis covering the activities undertaken during the entire previous year and the report, should be placed in the first meeting to be held in the fiscal year. Detailed status report regarding CSR activities/projects/programmes undertaken by MHFSL will also be disclosed every year in the Director’s Report that forms part of the Annual Report.