INTRODUCTION

Corporate Social Responsibility (CSR) refers to a Company’s practice of contributing to the economic and social development of communities in which it operates. AGRIPLAST TECH INDIA PRIVATE LIMITED (“ATIPL” or “the Company”) strives to make a positive difference to society through its CSR activities.

This Policy has been framed in compliance with Section 135 of the Companies Act, 2013 (the “Act”), read with the Companies (Corporate Social Responsibility Policy) Rules, 2014 (the “CSR Rules”), and is designed to determine the scope of CSR activities to be undertaken by the Company in accordance with Schedule VII of the Act.

RESPONSIBILITY FOR IMPLEMENTATION OF CSR

Initially, the Board of Directors of the Company constituted a Corporate Social Responsibility Committee (“CSR Committee”) to assist in effectively discharging its CSR obligations. However, pursuant to Section 135(9) of the Act, effective from January 22, 2021, where the amount required to be spent by a company on CSR does not exceed fifty lakh rupees, the requirement for constituting a CSR Committee does not apply. In such cases, the Board of Directors shall discharge the functions of the CSR Committee.

Accordingly, after January 22, 2021, the CSR Committee was no longer required. The Board of Directors, at its meeting held on April 30, 2022, passed a resolution to dissolve the CSR Committee with immediate effect. Henceforth, all the functions and responsibilities of the CSR Committee, as specified under the Act and the CSR Rules, or any re-enactment thereof, shall be exercised by the Board.

CSR ACTIVITIES

The Company endeavors to undertake one or more activities as covered or authorized under Schedule VII of the Act, as may be in force and amended from time to time.

CSR EXPENDITURE

  1. The Board shall determine the applicability of the provisions of Section 135 of the Act regarding the requirement for CSR spending, based on the criteria specified therein.
  2. The Board shall ascertain and approve the total amount required to be spent on CSR activities for the respective financial year. The Company shall ensure that it spends, in every financial year, at least two percent of its average net profits made during the three immediately preceding financial years.
  3. The Company may allocate funds for CSR activities beyond the statutory minimum prescribed under Section 135 of the Act, if it deems fit.
  4. CSR expenditure includes all expenditures, including contributions to any corpus, for projects or programs related to CSR activities approved by the Board. It does not include any expenditure that is not in conformity with the approved CSR activities.

IDENTIFICATION OF ACTIVITIES/PROJECTS

From the approved CSR activities, the Board shall decide which activity or project to prioritize for each financial year. In making this decision, the Board shall analyze the basic needs of the community or area in which the Company operates, or where the Registered Office of the Company is located. The Board shall record its findings and set priorities accordingly.

IMPLEMENTATION PROCESS

  1. After prioritizing an activity, the Board shall finalize a detailed implementation plan, including an estimate of expenses against the total CSR budget.
  2. The Company shall undertake CSR activities on its own or through:
    • A company established under Section 8 of the Act, or a registered public trust, or a registered society, registered under Section 12A and 80G of the Income Tax Act, 1961, established by the Company (either singly or along with another company).
    • A company established under Section 8 of the Act, or a registered trust, or a registered society established by the Central or State Government.
    • Any entity established under an Act of Parliament or a State Legislature.
    • A company established under Section 8 of the Act, or a registered public trust, or a registered society, registered under Section 12A and 80G of the Income Tax Act, 1961, with at least three years of established track record in undertaking similar activities.
  3. The Board shall identify eligible entities or organizations for CSR implementation and allocate funds to them for specific CSR projects. Specialized agencies may be engaged, if necessary, to assist in identifying such entities.
  4. With effect from April 1, 2021, the Board shall ensure that the entity or organization selected for CSR implementation is registered with the Central Government by filing the necessary forms and has obtained a unique CSR Registration Number.
  5. The Company may engage international organizations for designing, monitoring, and evaluating its CSR projects or programs, as well as for capacity building of its own personnel involved in CSR.
  6. The Company may collaborate with other companies for undertaking projects, programs, or CSR activities in a manner that allows each participating company to report separately on such projects or programs in accordance with the CSR Rules.
  7. The Board shall ensure that the administrative overheads do not exceed five percent of the total CSR expenditure of the Company for the financial year.

CSR MONITORING

  1. The Board of Directors shall monitor the implementation of CSR activities on an ongoing basis.
  2. The Board of Directors shall ensure that the funds disbursed for CSR activities have been utilized for the approved purposes and in the approved manner. The Chief Financial Officer or the person responsible for financial management shall certify to this effect.
  3. In the case of ongoing projects, the Board shall monitor the project’s implementation with reference to the approved timelines and year-wise allocations. It may make modifications, if necessary, to ensure smooth implementation within the overall permissible timeframe.
  4. The Board shall determine the need for any impact assessment of the CSR projects undertaken by the Company, if required.

CSR REPORTING

  1. The Board is responsible for undertaking CSR activities in line with the approved CSR Policy.
  2. The Board’s Report for any financial year shall include an annual report on CSR containing particulars specified under the CSR Rules.

CSR DISCLOSURE

The Board of Directors shall mandatorily disclose the composition of the CSR Committee (if applicable), the CSR Policy, and the projects approved by the Board on the Company’s website.

MISCELLANEOUS

  1. This Policy may be updated from time to time by the Company, in accordance with amendments, if any, to the Act, the CSR Rules, or any other applicable enactments in force.
  2. Any term used in this Policy shall have the meaning as defined under the Act and the CSR Rules, as amended.
  3. If any provision of this Policy contradicts or is inconsistent with the provisions of Section 135 of the Act or the CSR Rules, as may be amended from time to time, the provisions of the Act and the Rules shall prevail.