In terms of Section 135 of the Companies Act, 2013 (“the Act”), every company having a net worth of rupees five hundred crore or more, or turnover of rupees one thousand crore or more or a net profit of rupees five crore or more during the immediately preceding financial year, shall constitute a Corporate Social Responsibility (“CSR”) Committee of the Board.

Further, the CSR rules stipulate that the CSR initiatives be carried out through programmes or projects that align with Schedule VII of the Act, the said Schedule consisting of areas where the CSR budget needs to be expended.


The CSR Committee was constituted on June 28, 2019 and comprises of the following members:

  1. Anoop Premanand Pai Dhungat (Chairman & Member)
  2. Sanjay Kailashchandra Patodia (Member)
  3. Sonu Anoop Pai Dhungat (Member)


  1. To formulate and recommend to the Board, a CSR policy which shall indicate the activities to be undertaken by the Company as specified in areas or subject specified in Schedule VII to the Companies Act, 2013;
  2. Recommend the amount of expenditure to be incurred on the activities referred to in (1) above;
  3. Monitor the CSR policy of the Company from time to time.


The Company will primarily focus on the following areas to fulfill its responsibility towards CSR activities:

  1. Promoting education with focus on education among children, special education and education among under privileged children in backward areas.
  2. Eradication of hunger and malnutrition.
  3. Promoting gender equality and women empowerment.
  4. Ensuring ecological balance and environmental sustainability
  5. Protection of national heritage, art and culture.
  6. Measures for the benefits of armed forces, war widows and their dependents.
  7. Promotion of rural sports, Paralympic sports, nationally recognized sports.
  8. Promoting healthcare including preventive healthcare and sanitation.
  9. Contributions towards Prime Minister’s National Relief Fund or such other fund set up for socio-economic development and relief and welfare of scheduled castes and scheduled tribes etc.
  10. Contributions towards technology incubators located within academic institutions approved by the government of India.
  11. Contributions towards rural development projects.
  12. Contributions towards old age homes, day care centres and such other facilities for senior citizens.

The Company would undertake any of the activities in line with those specified in Schedule VII of the Companies Act, 2013, as amended from time to time.


The approved CSR programme will be monitored and implemented by the CSR Committee with the assistance of the designated executives of the Company.

Once in every six months or at such intervals as may be decided by the CSR Committee, the CSR activities will be reviewed and monitored by the Committee and details of such review shall be notified to the Board of Directors of the Company.

The CSR policy will also be reviewed by the CSR Committee on a periodic basis, and modifications if necessary will be made thereto.


A minimum of 2% of the average net profits of the Company made during the three immediately preceding financial years will be allocated and spent on CSR activities in every financial year.  However if such amount is not spent in any financial year, the reasons for the same will be disclosed in the Directors’ Report.

The unspent or the unutilised CSR allocation of any financial year may be carried forward to the following financial year, at the discretion of the CSR Committee and the Board of Directors.

This Policy has been approved and adopted by the Board of Directors at their meeting held on 30th August 2019.