Corporate Social Responsibility (CSR) Policy

A Brief outline of the Company’s CSR policy, including overview of projects or programs proposed to be undertaken and a reference to the weblink to the CSR policy and project or programs:




  1. The CSR Policy sets out our commitment to ensuring that our activities extend beyond business and include initiatives and endeavours for the benefit and development of the community and society. The CSR Policy lays down the guidelines for undertaking programmes geared towards social welfare activities or


  1. This CSR Policy has been framed in accordance with the applicable provisions of the Companies Act, 2013 (“Act”) and the rules issued


  1. Notwithstanding anything to the contrary contained in this CSR Policy but subject to applicable law, in the event that the Company fails to meet the thresholds set out under Section 135(1) of the Act for three consecutive financial years, it shall not be required to:


  • Constitute/maintain the CSR Committee (if the CSR spent is more than Rs. 50 Lakhs p.a.); and
  • Comply with the provisions of this CSR Policy


till such time as it again meets the criteria specified in Section 135(1) of the Act.




  1. The Board shall be responsible for implementing the mandate of the CSR Policy and shall ensure that the CSR Activities are carried out in accordance with the CSR Policy read with the Act and CSR Rules and the annual action plan formulated for a particular Financial Year.


  1. The Board of Directors may also approve constitution of an implementation group for the purposes of implementation of the CSR Activities approved by the Board from time to time (the “Implementation Group”) and submitting report of the progress on the CSR Activities to the


  1. Mode of Implementation: The CSR Activities may be undertaken by the Company directly through its Implementation Group or with the prior approval of the Board, through any of the following entities as “Implementation Agency” being duly registered with the Central Government and having a unique CSR Registration Number (with effect from 1 April 2021):


  • Company established under section 8 of Indian Companies Act 2013, or Trust, or Society registered under section 12-A and 80-G of the Income Tax Act 1961, being established by the Company, either singly or along with any other company;


  • Company established under section 8 of Indian Companies Act 2013, or Trust, or Society, being established by (Indian) Central Government or (Indian) State Government;


  • Company established under section 8 of Indian Companies Act 2013, or Trust, or Society registered under section 12-A and 80-G of the (Indian) Income Tax Act 1961, and having an established track record of at least three years in undertaking similar CSR activities; or


  • Any entity established under an act of (Indian) Parliament or a (Indian) State


  1. The Company shall conduct due diligence prior to selection of an entity as its implementation agency, to inter alia verify the credentials and ensure that the proposed implementation agency is eligible and capable to be appointed as such.


The Company may also collaborate with other companies for undertaking projects or programmes or CSR activities in such a manner that the Board of respective companies are in a position to report separately on such projects or programmes in accordance with these rules.


The Company may collaborate with the group companies / affiliates, to identify, conduct due diligence and contribute to CSR projects. As part of such collaboration, any one of the CDET’s collaborating group companies / affiliates may engage with Implementation Agencies (including execution of the appropriate memorandum of understanding or any other documents as approved by the Board) on behalf of the Company.


  1. In case of failure to ensure the minimum CSR Expenditure i.e. 2% (two percent) of average Net Profits of the Company made during the three immediately preceding financial years, detailed reasons for the same must be included in the annual board of directors’




  1. The Company shall spend at least 2% (two percent) of average Net Profits of the Company made during the three immediately preceding financial years in accordance with the Act and the Rules and the CSR


  1. The Board shall be responsible for sanctioning the CSR Expenditure and for taking steps to ensure that the amount for the CSR Expenditure is available to the Implementation Group / Implementing Agency for application towards the CSR


  1. Any surplus arising out of the CSR Activities shall not form part of the business profit of the Company and may only be re-allocated to the CSR Activities being undertaken in terms of this CSR Policy and the annual action plan for the financial year in which such surplus has
  2. In order to count towards CSR Expenditure, CSR Activities must be undertaken in compliance with the applicable laws and shall not include the following:


  • activities undertaken in pursuance of normal course of business of the company any activity undertaken by the company outside India except for training of Indian sports personnel representing any State or Union territory at national level or India at international level;
  • contribution of any amount directly or indirectly to any political party under Section 182 of the Act;
  • activities benefitting employees of the company as defined in clause (k) of Section 2 of the Code on Wages, 2019 (29 of 2019);
  • activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services; and
  • activities carried out for fulfilment of any other statutory obligations under any law in force in


  1. The Board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the Company for the financial




  1. The Board shall ensure that the CSR Activities that are undertaken by the Company should be within the scope of the following activities:


  • Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water;
  • Promoting education, including special education and employment enhancing vocation skills especially among children, woman, 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 back ward groups;
  • Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro forestry, conversation of natural resources and maintaining quality of soil, air and water 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 public libraries; promotion and development of traditional arts and handicrafts;
  • Measures for the benefit of armed forces veterans, war windows 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 recognized sports, paralympic sports and Olympic sports;
  • Contribution to the Prime Minister’s National Relief Fund or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the Central Government for social-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women;
  • 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 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 purpose of this item, the item ‘slum area’ shall mean any area declared as such by the Central Government or any State Government or any other competent authority under law for the time being in force;

  • Disaster management including relief, rehabilitation and reconstruction activities; and
  • Any other project as may be specified under Schedule VII of the Companies Act, 2013, from time to


  1. The CSR Activities will be carried out in a manner that the preference is to undertake the CSR Activities in and around the local areas where the Company


  1. Based on the scope of activities set out in paragraph VI(1). above, the Board may approve such other specific CSR Activities that may be undertaken by the


  1. The Board shall ensure that appropriate designated staff or personnel provide adequate assistance (viz. data collection, survey, quotations and costs involved ) to the Board. For this purpose, the Board may also approach external consultants for necessary assistance as it may deem fit at such costs as may be approved by the Board.


  1. The following details of any CSR Activities to be undertaken by the Company shall be presented to the Board Member for their approval:
  • The list of CSR projects or programmes to be undertaken in areas or subjects specified in Schedule VII of the Act;
  • The objectives and expected results of the CSR Activity;
  • The relevant sector and the nature of the CSR Activity;
  • The focus area/ location for implementation of the CSR Activity;
  • The modalities of utilisation of funds and amount to be allocated towards the CSR Activity;
  • The implementation schedules for the projects or programmes with indicative timelines for completion of the CSR Activity;
  • The manner of execution – whether the CSR Activity should be undertaken by the Implementation Group or any Implementing Agency or in collaboration with any other company;
  • Monitoring and reporting mechanism;
  • details of need and impact assessment, if any, for the projects undertaken by the company; and
  • Such other details as it may deem


  1. In case any of the CSR Activities to be undertaken are anticipated to be long term i.e. an ongoing project being of a term of 3 (three) years excluding the financial year in which it was commenced, then a detailed estimate on implementation schedule or milestones should be made & placed before the


  1. The Board shall approve the CSR activities of the Company for a given financial




  1. To ensure that the objectives of CSR Policy are being met in an efficient and effective manner, the utilisation of the amount sanctioned towards CSR Activities should be reported by the Implementation Group to the Board on a quarterly basis in such manner as the Board may


  1. In the event any of the CSR Activities are undertaken through an Implementing Agency, the Implementation Group should obtain relevant information from the Implementing Agency and ensure that the progress on such CSR Activity is submitted to the Board on a quarterly basis in such manner as the Board may


  1. For the purposes of monitoring, if required, the Implementation Group may visit the Implementation Agency site to review CSR project and carry out inspections as approved by the Board from time to time.