1. INTRODUCTION
- This corporate social responsibility policy (“Policy”) encompasses the philosophy of Aavas
Financiers Limited (“Aavas”) 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.
- This policy shall apply to all corporate social responsibility (“CSR”) initiatives and activities
taken up by Aavas at the various work - centres and locations, for the benefit of different
segments of the society, specifically the deprived, underprivileged and differently able
persons.
- Under the provisions of Section 135 of the Companies Act, 2013 (“Act”) and Companies
(Corporate Social Responsibility Policy) Rules, 2014 (“CSR Rules”) Aavas is required to
incur CSR expenditure of 2% (Two Percent) of the average net profits of Aavas made during
3 (Three) immediately preceding financial years, in the event, Aavas has a net worth of Rs.
500 Crore or more or turnover of Rs. 1000 Crore or more or a net profit of Rs. 5 Crore or
more during the immediately preceding financial year.
2. PURPOSE OF THE POLICY
- In alignment with the vision of Aavas, through its CSR initiatives, shall continue to enhance
value creation in the society and in the community in which it operates, through its
services, conduct and initiatives, to promote sustained growth for the society and
community, in fulfilment of its role as a socially responsible corporate, with environmental
concern.
- This Policy will serve as a principle guiding document for Aavas’s CSR activities and will
provide for a framework and guiding principle for selection, implementation, governance,
management and monitoring of CSR initiatives and formulation of the annual action plan of
Aavas.
- Further, we believe that the wealth that one generates and holds is to be held as in a trust
for our multiple stakeholders, with regard to CSR, this means investing part of our profits
beyond business, for the larger good of society.
- The purpose of the CSR Policy is:
- To directly or indirectly take up a programme that will benefit the communities in
and around its work-centres and results, over a period of time, in enhancing the
quality of life and economic well-being of the local populace.
- To generate, through its CSR initiatives, a community goodwill for Aavas and help
reinforce a positive and socially responsible image of Aavas as a corporate entity.
- To pursue a corporate strategy that enables the realisation of the twin goals of
stakeholders' value enhancement and societal value creation in a mutually
reinforcing and synergistic manner.
- To collaborate with communities and institutions to contribute to the national
mission of eradicating poverty and hunger, especially in rural areas, through
knowledge sharing, empowering women economically, gender equality,
supplementing primary education and participating in rural capacity building
programmes and such other initiatives.
3. SELECTION OF CSR ACTIVITIES
- Identification of thrust areas and strategic initiatives:
For purposes of focusing its CSR efforts in a continued and effective manner, Aavas has
identified the following thrust areas/projects/programs:
- Employment generation
- skill development;
- Rural area development;
- Healthcare/ medical facility through investment in funds;
- Community development.
- Education/literacy enhancement through investment in Government and private
funds;
- Women empowerment;
- Environment Protection;
- Protection of natural and manmade heritage;
- Promotion of sports activity;
- Contribution to funds set up by the central government;
- Rural development projects;
- Technology promotion and up-gradation;
- Safe drinking water;
- Reducing inequality faced by socially and economically backword groups and
- Such other area/project as may be approved by Board.
- Activities which are not covered within the ambit of CSR Activities
Subject to the provisions of the Act and the CSR Rules, the following activities will not be
considered as CSR activities:
- any activity undertaken outside India except for training of Indian sports personnel
representing any State or Union territory at the 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 Aavas as defined in clause (k) of section 2 of the
Code on Wages, 2019;
- activities supported by Aavas on a sponsorship basis for deriving marketing benefits
for its products or services;
- activities carried out for the fulfilment of any other statutory obligations under any
law in force in India.
4. CSR COMMITTEE AND BOARD OF DIRECTORS
- In compliance with section 135 of the Act read with CSR Rules, the CSR Committee of Aavas
should constitute of atleast 3 Directors, out of which at least 1 (One) director shall be an
independent director. Provided, however, in the event, Aavas is not required to constitute
CSR Committee under Section 135(9) of the Act, then in such case, the functions of the CSR
Committee will be discharged by the Board of Directors of Aavas.
- Secretary:
Secretary of Aavas will be the secretary of the CSR Committee.
- Quorum:
The quorum necessary for the transaction of the business agenda at the meeting
of the CSR Committee shall be 2 (Two) Members only. A duly convened meeting of the
Committee at which a quorum is present shall be competent to exercise all or any of the
authorities, powers and discretions vested in or exercisable by the CSR Committee.
- Meetings:
The CSR Committee shall meet at least twice a year and at such other times as
the Chairman of the Committee shall require.
- Duties of the CSR Committee:
The CSR Committee shall:
- a.Formulate and recommend to the Board, a CSR Policy which shall indicate the
activities to be undertaken by Aavas in areas or subject, specified in Schedule VII;
- b. Recommend the amount of expenditure to be incurred on such activities;
- c. Monitor the CSR policy from time to time;
- d. Formulation and recommend to the Board, an annual action plan of Aavas; and
- e. Approve the projects, recommend the amount to be spent, set project selection
guidelines and monitor implementation to ensure that spending is undertaken in
accordance with this Policy.
- Duties of Board:
- a. The Board shall approve the CSR Policy, based on the recommendation of the CSR
Committee and ensure that the activities included in this Policy are undertaken by
Aavas.
- b. Ensure the implementation of this Policy and monitoring of CSR expenditures.
- c. Disclose the contents of the CSR policy in the Board report.
- d. Ensure CSR spending amounting to at least 2% (Two Percent) of the average net
profit of the preceding 3 (Three) financial years in accordance with Section 135 of
the Act.
- e. The Board shall satisfy itself that the funds so disbursed have been utilised for the
purpose of and in the manner as approved by it and the chief financial officer or the
person responsible for financial management shall certify to the same;
- f. The Board shall ensure disclosure of names of the CSR Committee members, the
content of this Policy and reporting of its CSR activities on the website of Aavas and
in annual reports in the formats prescribed under the Act and/or the CSR Rules.
- The CSR committee will formulate and recommend to the Board, an annual action plan in
pursuance of this Policy, which will include the following:
- a. the list of CSR projects or programmes that are approved to be undertaken in areas
or subjects specified in Schedule VII of the Act;
- b. the manner of execution of such projects or programmes as specified in Rule 4(1) of
the CSR Rules;
- c. the modalities of utilisation of funds and implementation schedules for the projects
or programmes;
- d. monitoring and reporting mechanism for the projects or programmes; and
- e. details of need and impact assessment, if any, for the projects undertaken by Aavas.
5. IMPLEMENTATION OF CSR ACTIVITIES
- Aavas shall synergize its efforts with the State Governments, District Administration, Local
Administration as well as Central Government departments, agencies, fund managers,
organizations, etc., for fulfilling its corporate social responsibility, if required.
- Upon identification of CSR activities/programmes, the Board may decide and approve to
undertake its CSR activities as recommended by the CSR Committee, itself or through
(“Implementing Agency”):
- A company established under Section 8 of the Act or a registered public trustor
registered society, registered under Section 12A and 80G of the Income Tax Act,
1961 established by Aavas, either singly or along with other company; or
- A company established under Section 8 of the Act or a registered public trustor
registered society, registered under Section 12A and 80G of the Income Tax Act,
1961 established by the Central Government or State Government; or
- Any entity established under an Act of Parliament or State legislature; or
- A company established under Section 8 of the Act or a registered public trustor
registered society, registered under Section 12A and 80G of the Income Tax Act,
1961 and has an established track record of at least 3 (Three) years in undertaking
similar activities.
- Aavas will specify the projects or programs to be undertaken, the modalities of utilisation of
funds of such projects and programs and the monitoring and reporting mechanism to the
Implementing Agency, if implemented through any Implementing Agency.
- Aavas may also collaborate with other companies for undertaking projects or programs or
CSR activities in such a manner that the CSR Committees of respective companies are in a
position to report separately on such projects or programs.
- According to the proviso to Section 135(5) of the Act, Aavas shall give preference to the
local area and areas around it where it operates, for spending the amount earmarked for
CSR activities. Aavas shall strive to focus that its CSR Activities are concentrated in nearby
areas where the business operation of Aavas is carried at H.O. or Branch level.
- The CSR Committee and/or Board may authorize any director/official of Aavas or may
constitute any sub-committee of such members as it may deem fit for purpose of
implementation of CSR Policy. To ensure effective implementation of the CSR programmes
undertaken at the work centre, a monitoring mechanism will be put in place by the
committee/sub-committee.
6. RESOURCES AND FUNDING
- Aavas, being a responsible corporate citizen, will make a provision from the annual CSR
Budget allocation, towards the following expenditure heads, on a year on year basis:
- Eradicating hunger, poverty and malnutrition, promoting 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, women, 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, daycare centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially
and economically backward groups.
- Ensuring environmental sustainability, ecological balance, protection of flora and
fauna, animal welfare, agro-forestry, conservation 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 widows and their dependents.
- Training to promote rural sports, nationally recognized sports, Paralympic sports
and Olympic sports.
- 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.
- Contributions or funds provided to technology incubators located within academic
institutions which are approved by the Central Government.
- Rural development projects.
- Slum area development
- Swachh Bharat Abhiyan
- Clean River Ganga Project
For achieving its CSR objectives through the implementation of meaningful and sustainable CSR
programmes, Aavas will allocate 2% (Two Percent) of the average net profits of Aavas made during
3 (Three) immediately preceding financial years, as its Annual CSR Budget.
- The Board shall ensure that the administrative overheads does not exceed 5% (Five
Percent) of the total CSR expenditure of Aavas for the financial year.
- Any surplus arising out of the CSR activities will not form part of the business profit of
Aavas and will be ploughed back into the same project or will be transferred to unspent CSR
Account and spent in pursuance of the CSR policy and annual action plan of Aavas or
transfer such surplus amount to a fund specified in Schedule VII within a period of 6 months
from the expiry of the financial year.
- Aavas may spend the CSR Amount for the creation or acquisition of a capital asset, which
will be held by:
- a company established under section 8 of the Act, or a Registered Public Trust or
Registered Society, having charitable objects and CSR Registration Number under
Rule 4(2) of the CSR Rules; or
- beneficiaries of the said CSR project, in the form of self-help groups, collectives,
entities; or
- a public authority.
- In the event, Aavas spends an amount in excess of the requirement provided under Section
135(5) of the Act in a financial year, such excess amount may be set off against the
requirement to spend under Section 135(5) of the Act up to immediate succeeding 3
(Three) financial years subject to following:
- the excess amount available for set-off shall not include the surplus arising out of
the CSR activities, if any, in pursuance of Rule 7(2) of the CSR Rules.
- the Board of Directors passes a resolution to that effect.
7. MONITORING OF CSR ACTIVITIES
- CSR programmes/projects shall be undertaken to the best possible extent within the
defined ambit of the identified 'thrust areas'.
- The time period/duration over which a particular programme shall be spread shall depend
on its nature, the extent of coverage and the intended impact of the programme.
- Appropriate documentation of Aavas CSR Policy, annual CSR activities, executing partners,
agreements, report and expenditure entailed will be undertaken on a regular basis and the
same will be reported to the Committee and/or Board.
- The CSR Committee has the power to appoint authorized officials, employees of Aavas, any
consultant and professional to monitor CSR programmes.
8. CSR REPORTING AND DISCLOSURE
- The Board’s Report of Aavas pertaining to a financial year shall include an annual report on
CSR containing particulars as specified in the Act and CSR Rules.
- Powers for approval
- CSR programmes as recommended by the CSR Committee to the Board at the
beginning of each financial year and be approved by the Board and be implemented
in accordance with this Policy.
- For meeting the requirements arising out of immediate and urgent situations,
MD/CEO of Aavas is authorised to approve proposals/ project/ programme
covering the CSR activities on the basis of the recommendation accorded to him by
the CSR Committee.
- Implementing Agency:
Aavas will seek to identify suitable programmes and Implementing
the Agency for implementation in line with the CSR objectives of Aavas and also benefit the
stakeholders and the community for which those programmes are intended.
- Agreement between Aavas and Executing agency:
Once the programmes approved by
the CSR Committee of the Board, if required, any of the Senior team members shall enter
into an agreement with Implementing Agency of CSR Programmes.
9. IMPACT ASSESSMENT
- If Aavas is required under Rule 8(3) of the CSR Rules to undertake impact assessment,
Aavas will undertake an impact assessment of its CSR projects in accordance with said Rule.
- The impact assessment reports will be placed before the Board and shall be annexed to the
Annual Report on CSR.
- Aavas undertaking impact assessment may book the expenditure towards Corporate Social
Responsibility for that financial year, which shall not exceed 5% (Five Percent) of the total
CSR expenditure for that financial year or Rs. 50 Lakh, whichever is less.
10. MISCELLANEOUS PROVISIONS
- The Board of Directors of Aavas, either on its own or in accordance with the
recommendations of the CSR committee, can amend this Policy, as and when required. The
decision of the Board of Directors on all matters, relating to this Policy shall be final and
binding on all entities/person concerned. This Policy is subject to continuous review and
updates as required from time to time.
- Words and expressions used and not defined in these rules but defined in the Act shall have
the same meanings respectively assigned to them in the Act and/or the CSR Rules.
- In case of any conflict between the provisions of this Policy and the Act/CSR Rules as
applicable on Aavas, the provisions of the Act/CSR Rules shall prevail over this Policy.
- Any reference to the Act and/or the CSR Rules shall mean the Act and/or the CSR Rules,
respectively, as amended from time to time.