CSR Policy

1. SHORT TITLE & APPLICABILITY:

1.1. This policy, which encompasses Bharat Financial Inclusion Limited’s (“BFIL” or “the Company”) philosophy for delineating its responsibility as a corporate citizen and lays down the guidelines and mechanism for undertaking socially useful programmes for welfare and sustainable development of the community at large, is titled as the Corporate Social Responsibility Policy of BFIL (“CSR Policy”). The Initiatives guided by this policy are aligned with the guidelines laid down by the Ministry of Corporate Affairs in the Section 135 of Companies Act, 2013 & Companies (CSR Policy) Rules, 2014.
1.2. This CSR Policy shall apply to all CSR initiatives and activities (“CSR Programs”) taken up at the various branches and offices of the Company, for the benefit of different segments of the society, specifically aligned with the Mission Statement and Objective.

2. CSR MISSION STATEMENT AND OBJECTIVE:

2.1. In alignment with the vision of the Company, through its CSR Program, the Company aims to actively contribute to the social and economic development of the rural communities, through its conduct and initiatives, to enhance accessibility to their well-being and promote a sustainable way of life for the underserved sections of society and the community.
2.2. The key objectives of the CSR Policy are guided by the National Guidelines on Responsible Business Conduct (NGRBC) :
2.2 a) Ensure increased commitment at all levels in the organization to serve the economically, socially, and environmentally deprived sections in a sustainable manner, while recognizing the interests of all its stakeholders.
2.2 b) Take up CSR Programs that benefit communities at large and contribute to, over a period, enhancement in the quality of life and economic well‐being of the local populace.
2.2 c) To conduct responsible and transparent activities to meet social goals of the Company in specific and of the Stakeholders and Community at large.
2.2 d) Encourage alignment with development goals related to gender sensitivity, skill enhancement, entrepreneurship development, ecological sustainability, etc.
2.2 e) Respect the wellbeing of the beneficiaries, employees, and all stakeholders by upholding their rights and providing value.
2.2 f) Reinforce inclusiveness and equitable growth for all
2.2 g) To be environmentally conscious in conducting all CSR activities.

3. GOVERNANCE:

3.1 Constitution
3.1 a) The CSR Committee shall consist of three or more directors.
3.2 Meeting
3.2 a) The CSR Programs of the Company will be coordinated and monitored by a CSR Committee for the successful implementation of the CSR Policy. The CSR Committee shall meet as and when required to carry out its duties effectively.
3.3 Role and Responsibilities of CSR Committee
The key role and responsibility of the CSR Committee would be to implement the CSR Policy by company itself or through registered entities with the Central Government as prescribed in the CSR Rules. Broad roles and responsibilities are the following:
3.3 a) Formulation and recommendation to the Board, an annual action plan on broad guidelines for selection of CSR projects, planning, execution, monitoring and evaluation for approval.
3.3 b) Selection of CSR projects in accordance with policy framework and guidelines.
3.3 c) Submission of annual budgetary requirement for each project along with the targets.
3.3 d) Formulation of strategies for efficient implementation of projects.
3.3 e) Periodic reporting of all CSR programs, as required.
3.3 f) Disclosure of Annual Report on CSR Activity in Annual Report.
3.3 g) Display of CSR Activities on Company website along with composition of the CSR Committee, CSR Policy and projects approved by the Board for public access.
3.3 h) Funds utilised for the purposes and the manner as approved.

4. PLANNING:

4.1 Identification of Thrust Areas
As a part of its CSR strategy, in line with the aims and objectives specified above, the following thrust areas have been identified:
4.1 a) Education and Skill Development - Includes School & College Education, Digital & Assisted Learning, Non-formal Learning, Literacy Enhancement, Education Infrastructure, or any other related areas and not limited to the above.
4.1 b) Health - Includes healthcare across segments like preventive, promotive and curative, Nutrition, Mother & Childcare, Water & Sanitation, Hygiene, Healthcare Infrastructure, Disability Care, Eldercare, or any other related areas and not limited to the above.
4.1 c) Livelihood & Community Development - Includes Capacity Building, Farmers Support, Community training and Capacity building, Skilling, Women empowerment, Vocational Training, or any other related areas and not limited to the above
4.1 d) Environment - Includes Watershed management, Afforestation, Natural Resource restoration, Renewable energy, Waste Management, or any other related areas and not limited to the above.
4.1 e) Special Interest - Includes support during Disaster relief, Public Health emergencies, National and State emergencies, Welfare of Armed Forces and their families, Art & Heritage or any new area notified by the Ministry of Corporate Affairs from time to time.
4.1 f) Any other activity as may be identified by the CSR Committee.
The list is only indicative and does not restrict inclusion of additional/ fresh activities under CSR. An indicative list of CSR activities is mentioned in detail in Annexure - A of the CSR Policy.

5. RESOURCES AND ALLOCATION OF FUNDS:

5.1 Every year a budget for CSR activities shall be decided by the Board on the recommendation of the CSR Committee. Such a budget shall not be less than 2% of the average net profit made by the Company during the three immediately preceding financial years.
5.2 The earmarked annual budget for CSR shall be transferred to a separate account called “BFIL CSR Fund”.
5.3 Any unspent/ unutilized amount of CSR Fund of a particular year, shall be carried forward to the following year, i.e., the CSR budget will be non-lapsable in nature.
5.4 CSR Programs will be planned according to the budget allocation.
5.5 The allocation of funds for CSR Programs shall be decided by the Board on the recommendation of the CSR Committee.
5.6 In addition to BFIL CSR Fund, the Company may also collaborate with IndusInd Bank Limited (IndusInd Bank) for undertaking CSR Programs with the funding support in such manner as may be agreed between the Company and IndusInd Bank.
5.7 An administrative overheads cost including employee salaries of the CSR Department and other cost towards internal capacity building shall maximum of 5% of CSR Budget only
5.8 Any surplus arising out of CSR initiatives will be onward utilised towards CSR implementation and will not form the Company’s profits.

6. IMPLEMENTATION & MONITORING

6.1 Implementation plan containing milestones and deadlines for the CSR Programs shall be drawn by the CSR Team and approved by the CSR Committee.
6.2 The CSR Team of the Company will deploy the implementation plans as laid out by the CSR Committee towards identified CSR projects. Further the CSR Team shall conduct all activities pertaining to CSR as guided by the CSR Committee
6.3 As per requirement, the Company may engage specialized agencies/ NGOs/Trusts/ Government or Semi-Government organizations/ private agencies for any assignment, who have requisite expertise of carrying out the identified CSR Programs.
6.4 Projects will be regularly monitored by the CSR team, including time to time reviews with the implementing agencies.
6.5 The Company may leverage expertise from various internal teams towards CSR implementation activities including and not restricted to Need Assessment, Impact evaluation, Employee Volunteering, Surveys, technology development and so on.
6.6 To ensure effective implementation of the CSR Programs undertaken, a monitoring mechanism will be put in place. The progress of CSR Programs under implementation will be reported by the Internal Audit Department on a half yearly basis to the CSR Committee.
6.7 The progress report of CSR Programs under implementation in the format given in Annexure - B shall be placed before the Board on a yearly basis.
6.8 The CSR Committee may conduct an impact assessment study of the CSR Programs at its absolute discretion by engaging specialized agencies like NGOs/Trusts/ Societies/ Government or Semi-Government organizations/ private agencies for any assignment, who have requisite expertise of carrying out the identified activities/ Programs.
6.9 The CSR Committee may discontinue any CSR Program, if the implementation of the said CSR Program is found that the implementation of the same is practically not feasible, at its sole discretion.
6.10 CSR Programs undertaken by the Company shall be reported in the Annual Report in the format prescribed under CSR Rule

7. GENERAL

7.1 All CSR activities and expenses made thereon will be subject to audit.
7.2 Company shall mandatorily disclose the composition of the CSR Committee, and CSR Policy and Projects approved by the Board on their website, if any, for public access.
7.3 The Company reserves the right to modify, cancel, add, or amend any of the above rules/ guidelines.
7.4 Any or all provisions of the CSR Policy shall be subject to revision/ amendment in accordance with the applicable laws/ rules/ guidelines on the subject, from time to time.
7.5 In case of any doubt regarding any provision of the policy and in respect of matters not covered herein, a reference to be made to the CSR Committee. In all such matters, the interpretation and decision of the Managing Director & CEO shall be final.

ANNEXURE A

i. Eradicating hunger, poverty, and malnutrition, promoting preventive health care and sanitation and making available safe drinking water.
ii. Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects.
iii. 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.
iv. 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.
v. 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.
vi. Measures for the benefit of armed forces veterans, war widows and their dependents.
vii. Training to promote rural sports, nationally recognised sports, Paralympic sports, and Olympic sports.
viii. Contribution to the Prime Minister's National Relief Fund or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities, and women.
ix. Contribution to incubators funded by Central Government or State Government or any agency or Public Sector Undertaking of Central Government or State Government, and contributions to public funded Universities, Indian Institute of Technology (IITs), National Laboratories and Autonomous Bodies(established under the auspices of Indian Council of Agricultural Research (ICAR), Indian Council of Medical Research (ICMR), Council of Scientific and Industrial Research (CSIR), Department of Atomic Energy (DAE), Defence Research and Development Organisation (DRDO), Department of Biotechnology (DBT) , Department of Science and Technology (DST), Ministry of Electronics and Information Technology) engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs)rural development projects.
x. Rural development projects
xi.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.
(xii) disaster management, including relief, rehabilitation, and reconstruction activities.

ANNEXURE B