CSR Policy
Corporate Social Responsibility Policy
Introduction
Aparajitha Corporate Services Limited (“Aparajitha”), with a legacy spanning 25 years, has grown into one of India’s most respected professional organisations. As we mark this milestone, we reaffirm our unwavering commitment to delivering superior and sustainable value to all our stakeholders, including employees, clients, partners, communities, shareholders, and regulatory bodies, through transparent, ethical, and socially responsible practices.
Aparajitha is committed to undertaking Corporate Social Responsibility (“CSR”) activities in accordance with the provisions of Section 135 of the Companies Act, 2013 and the related Rules. Aparajitha believes that corporate development must be inclusive and that every corporate entity bears responsibility for contributing to the development of a just and humane society capable of building a strong national enterprise. Aparajitha commits itself to contributing to society in all possible ways and has established Aparajitha Foundations, its core CSR team, as a means to fulfil this commitment.
Acronyms
- Aparajitha - Aparajitha Corporate Services Limited
- Act - Companies Act, 2013, as amended from time to time
- CSR - Corporate Social Responsibility
- CSR Policy – The official policy governing Aparajitha’s CSR efforts
- CSR Rules – Companies (Corporate Social Responsibility Policy) Rules, 2014
Objective
The objective of the CSR Policy (“Policy”) is to lay down the guiding principles for undertaking various programs and projects by or on behalf of the company relating to Corporate Social Responsibility (“CSR”), within the meaning of section 135 of the Companies Act, 2013 read with Schedule VII of the Act and the CSR Policy Rules, 2014 (“Rules”).
The objective of this Policy is to formalise Aparajitha’s approach to CSR, building on 25 years of impact and aligning with regulatory frameworks. Our goals include:
- Reinforcing our long-term vision and strategy for Aparajitha’s CSR objectives, built on 25 years of responsible corporate citizenship.
- Establishing the relevance of potential CSR activities to Aparajitha’s core business and creating an overview of activities to be undertaken, in line with Schedule VII of the Companies Act, 2013.
- Aparajitha shall promote projects that are:
- Sustainable and create a long-term change;
- Have specific and measurable goals aligned with Aparajitha’s philosophy;
- Address the most deserving causes or beneficiaries.
- To establish processes and mechanisms for the implementation and monitoring of CSR activities at Aparajitha.
Applicability
This Policy applies to Aparajitha Corporate Services Limited and has been in effect since 1st July 2014, with revisions reflecting current regulations and our evolving CSR strategy.
CSR Activities-Projects
- Aparajitha Foundations, the core CSR team of Aparajitha, has been fulfilling the company’s CSR commitment for the past several years. Over Aparajitha’s 25-year journey, Aparajitha Foundations has focused on projects relating to Education, Health, Environment and Sports as detailed in Appendix 2.
- Aparajitha shall promote CSR activities/Projects in the field of:
- Promotion of Education: Including life skills education and employment-enhancing vocational skills, especially among adolescent school and college students.
- Environment: Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintenance of soil, air and water quality.
- Sports: Training to promote rural sports, nationally recognised sports, Paralympic sports and Olympic sports.
- Health and Nutrition: Eradicating extreme hunger, poverty, and malnutrition; promoting preventive healthcare and sanitation; and making safe drinking water available.
- Aparajitha may also undertake other CSR activities in line with Schedule VII.
- The CSR activities shall be undertaken in locations within India. Aparajitha shall give preference to the local areas and the region where it operates, while considering the activities to be undertaken and allocating the amount earmarked for CSR activities. However, with a multi-state presence built over 25 years, Aparajitha may also be guided by the specific requirements of each CSR activity or program when determining the locations within India.
Committee Composition
The CSR Committee means the Committee of the Board constituted in terms of Section 135 of the Companies Act, 2013, read with Rule 5 of the rules. The CSR Committee shall be composed of at least three (3) Directors. The CSR Committee shall include one (1) Independent Director, effectively within the time period prescribed under law. Members of the CSR Committee may be replaced by any other member of the Board.
Committee Members
| Names | Role in Committee |
|---|---|
| Mr. Bharath Krishna Sankar | Chairperson |
| Mr. Krishnan Nagaraj | Member |
| Mr. S Venkatesh Kumar | Compliance Officer |
Committee Meetings
The Committee will meet at least twice a year to discuss and review CSR activities and the Policy. A quorum of two members is required to be present for the proceedings to take place. Other meetings of the Committee can be convened as and when deemed appropriate. The Committee members may attend the meeting physically or via such audio¬ visual means as permitted under the Act. The Committee shall have the authority to call such employee(s), senior official(s) and or externals, as it deems fit. The Compliance Officer shall act as Secretary to the Committee.
Duties & Responsibilities of CSR Committee
- Review the CSR activities to be undertaken by the Committee. The Committee shall be guided by the list of activities specified in Schedule VII to the Companies Act, 2013, and appended to this Policy as Appendix - 1. Appendix 1 may be revised in line with any amendments/inclusions made to Schedule VII of the Companies Act, 2013.
- Formulate and recommend to the Board, a Corporate Social Responsibility Policy, which shall indicate the CSR activities/programmes to be undertaken by Aparajitha in areas or subjects, specified in Schedule VII.
- Recommend the CSR expenditure to be incurred on the CSR activities/programmes.
- Prepare an annual report of the CSR activities undertaken for Aparajitha and submit such report to the Board.
- Review and recommend any amendments to be made in the CSR policy of the Company.
- Carry out such other functions as may be delegated to it by the board relating to CSR activities of the company.
- The CSR Committee shall formulate and recommend to the Board an annual action plan in pursuance of its CSR policy, which shall include the following, namely:
- The list of CSR projects or programmes that are approved to be undertaken in areas or subjects specified in Schedule VII of the Act;
- The manner of execution of such projects or programmes as specified in sub-rule (1) of rule 4;
- The modalities of utilisation of funds and implementation schedules for the projects or programmes;
- The monitoring and reporting mechanism for the projects or programmes;
- Details of need and impact assessment, if any, for the projects undertaken by the company:
Responsibility of the Board
- Approve the CSR Policy and the CSR expenditure after taking into consideration the recommendations made by the CSR committee.
- Ensure CSR spending every financial year of at least 2% of average net profits made during the immediately preceding 3 financial years, in pursuance of the Policy.
- Ensure that the CSR activities included in the CSR Policy are undertaken by Aparajitha and that such activities are related to those specified in Schedule VII of the Companies Act.
- Ensure disclosure of the contents of the CSR Policy on the Aparajitha website.
- The Directors’ Report for FY 2013-14 onwards shall include:
- The contents of the CSR Policy and Composition of the CSR committee;
- An annual report on the CSR in the prescribed format;
- Reasons for failure (if any) to spend required amount on CSR activities.
- Aparajitha shall undertake CSR activities through Aparajitha Foundations, which is a trust qualifying under the provisions of Companies (Corporate Social Responsibility Policy) Rules, 2014.
CSR Expenditure
- In every financial year, Aparajitha shall spend a minimum of 2% of its average net profits in the immediately preceding three (3) financial years. “Average Net profits” shall mean the net profits of the Company as per the Profit & Loss Statement prepared in accordance with the Companies Act, 2013; Net Profits shall exclude
- Profits arising from any overseas branch or branches of Aparajitha (whether operated as a separate company or otherwise); or
- Dividends received from other companies in India.
- CSR expenditure shall mean all expenditure incurred in respect of specific projects/programmes relating to the approved CSR activities.
- CSR expenditure shall not include expenditure on items not in conformity with, or not in line with activities which fall within the purview of the CSR activities listed in Schedule VII.
- CSR expenditure shall not include projects, programmes or activities undertaken outside India.
- CSR expenditure shall not include any amounts spent toward activities that benefit only the employees of the Company.
- The surplus arising out of the CSR activities or projects shall not form part of the business profit of Aparajitha.
- Contributions by other Aparajitha affiliates or employees may also be received and utilized in respect of the CSR activities undertaken.
Implementing CSR Activities
- The day-to-day implementation and execution of the CSR activities/projects shall be carried out through Aparajitha Foundations.
- Aparajitha shall undertake CSR activities directly and also through various implementing agencies such as NGO’s, non-profit organisations, etc. Such implementing agencies shall have an established track record as prescribed under the law.
- Some of the initiatives taken up by Aparajitha Foundations will facilitate the involvement of Aparajitha employees as volunteers in ongoing projects and events, giving them an opportunity to engage in socially meaningful activities, thus enabling them to realise their full potential and role as socially responsible citizens (Employee Volunteer Programmes).
- The initiatives undertaken may be communicated to the employees through specific awareness campaigns, to enable maximum participation.
- Aparajitha may also collaborate or pool resources with other companies to undertake CSR activities in such a manner that each company is able to report separately on such CSR projects
- The following activities do not qualify as CSR activities under the Companies Act, 2013:
- Projects or activities not falling within Schedule VII (Appendix 1);
- Activities undertaken in pursuance of normal course of business;
- Projects, programmes or activities that benefit only the employees of Aparajitha and their families.
- Direct or indirect contributions to any political party.
CSR Activities in Partnership
The company may undertake programmes in collaboration with other companies only in cases where such programmes are separately reportable in the CSR report of participating companies.
CSR Reporting
The Board, in its Annual Report shall include the details of the CSR activities undertaken during the Financial Year. The particulars to be stated in the report shall be in the prescribed format.
The CSR Committee shall provide a responsibility statement on the implementation and monitoring of the CSR Policy and that it is in compliance with CSR objectives of Aparajitha, which statement shall form part of the Boards’ Report.
In case the company fails to spend 2% of the average net profit of the last three financial years or any part thereof, the company shall provide the reasons for not spending the amount in its Board report.
Review and Audit
The CSR committee shall be apprised on the implementation of the CSR activities and the progress shall be monitored on a quarterly basis.
Aparajitha shall, through its internal controls, monitor and evaluate system implementation, and assess, document, and report the impact of its CSR activities/projects.
Records relating to the CSR activities and the CSR Expenditure shall be meticulously maintained. The Records shall be submitted for reporting and audit.
The financial audits of the implementing agencies shall also be done through periodic audits. In this regard, Aparajitha may appoint independent external consultants for carrying out such audits.
Amendment of Policy
The CSR policy of the company may be amended at any time by the Board of the company, based on the recommendation of the CSR committee.
Policy Review
This policy will be reviewed annually; however, management reserves the right to revise the policy as and when required, with or without notice.
Policy Applicability
| S.No | Legal Entities |
|---|---|
| 1 | Aparajitha Corporate Services (P) Limited |
Appendix - 1
CSR Activities Listed in Schedule VII of the Companies Act, 2013
CSR shall focus on social, economic and environmental impact rather than mere output and outcome. Activities that are ad hoc and philanthropic in nature shall be avoided. Various activities that can be undertaken in general under CSR are outlined below:
- Eradicating extreme hunger,poverty and malnutrition, promoting preventive healthcare including sanitation; Contribution to the Swach Bharat Kosh set up by the Central Government for the promotion of sanitation; and making available safe drinking water;
- Promotion of education; including special education and employment-enhancing vocation skills, especially among children, woman, elderly, and the differently abled, as well as livelihood enhancement projects.
- Promoting gender equality and empowering women; setting up homes and hostels for women and orphans, establishing old age homes, day care centres, and such other facilities for senior citizens and implementing 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 maintenance of soil, air and water quality, including contribution to the Clean Ganga Fund set up by the Central Government for rejuvenation of river Ganga
- Protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up of public libraries; promoting and developing of traditional arts and handicrafts;
- Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents, including widows.
- Training to promote rural sports, nationally recognised sports, and paralympic and Olympic sports;
- Contribution to the Prime Minister's National Relief Fund or Prime Minister's Central Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Schedule Tribes, other backward classes, minorities and women;
- (a) Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and
- (b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense Research and Development Organisation (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).
- Rural development projects.
- Slum Area Development Explanation.— For the purposes of this item, the term ‘slum area’ shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force.” (As amended by Notification dated 06.08.2014).
- Disaster management, including relief, rehabilitation and reconstruction activities.
Appendix - 2
Aparajitha Foundations Existing Projects
Following projects are the existing and current CSR activities being handled through Aparajitha Foundations:
a. Education
By implementing projects named ThalirThiranThittam (TTT) and Tim Tim Tare in Tamil Nadu and Gujarat respectively, AF has been involved in providing Life skills education for adolescent children in the age group of 13 – 17(Std 7 – 12) in Government as well as Government aided schools an MOU signed with the respective State Government.
Aparajitha believes in working in areas that create long-term impact on the society. Therefore focusing on ‘projects in life education’, has been chosen, considering the impact they have in creating more empowering opportunities, building a better society, and nation-building at large.
b. Project Green: For a Cleaner, Greener Tomorrow
Project green focuses on adopting environment friendly measures and initiatives in every activities and processes at Aparajitha.
c. Anganwadi Centers
Anganwadi Centers launched by the Indian government in 1975 under the Integrated Child Development Services Programme aim to combat child hunger and malnutrition. Aparajitha has sponsored the construction of five Anganwadi centers in collaboration with the Government of Tamil Nadu. These centers are located in Kilaneri, Thenpalanzhi, Thanakkankulam, Silaiman & Valayankulam, Thiruparankundrum Taluk in Madurai District, Tamil Nadu.
Document Revision History
| Version Number | Effective Date | Change / Review Description | Author | Reviewer | Approver |
|---|---|---|---|---|---|
| 1 | 01-07-2014 | Original | Shimmy Saiesh - CHR | Shobana R - CPO | MD |
| 2 | 21-06-2016 | Policy Redrafted | Shimmy Saiesh - CHR | Shobana R - CPO | MD |
| 3 | 22-03-2022 | Committee Member list Updated | Shimmy Saiesh - CHR | Ganesh VS - BHR | MD |
| 4 | 21-03-2023 | Policy amended as per Rule 5(2) of the CSR Rules. | Shimmy Saiesh, AGM- HR Initiatives | CFO | MD |
CSR
Aparajitha Foundations, the not-for-profit wing of Aparajitha Corporate Services Limited, has pioneered Life Skills Education for adolescent children. ThalirThiranThittam (TTT) is a unique programme designed by Aparajitha Foundations to impart Life Skills that would bring about a transformational change through awareness amongst the children between the age group of 12 and 17.
