CSR

Preamble

Corporate Social Responsibility [CSR] is a Company’s commitment to operate in an economically, socially and environmentally sustainable manner, while recognizing the interests of its stakeholders. This commitment is beyond statutory requirements. Corporate Social Responsibility is, therefore, closely linked with the practice of Sustainable Development. Corporate Social Responsibility extends beyond philanthropic activities and reaches out to the integration of social and business goals. These activities need to be seen as those which would, in the long term, help secure a sustainable competitive advantage.
Fores Elastomech Private Limited (here in after referred to as the “Company”) is engaged in the businesses of manufacturing of Automobile components. The Company has always conducted its business responsibly, mindful of its social accountability, respecting applicable laws with regard for human dignity.  The Company wants to be viewed as a responsible corporate citizen ready for giving back to the society and contributing in activities, which promote various social and charitable objectives.

A. Applicability of CSR

The provisions of section 135 of the Companies Act, 2013 and the Companies (Corporate Social Responsibility Policy) Rules, 2014 have become applicable to the Company from the financial year 2019-2020.

B. Objective

The purpose of this policy is:
1. To define CSR projects or programs which the Company plans to undertake and which fall within the purview of the Companies Act 2013, The Companies (Corporate Social Responsibility Policy) Rules, 2014 and the Guidelines on CSR as and when issued by the Government of India.
2. Modalities of execution of such CSR projects or programs.
3. Monitoring process of such CSR projects or programs.

C. Scope

1. This policy broadly covers all relevant clause(s)/ sections of the Companies(Corporate Social Responsibility Policy) Rules, 2014 [CSR Rules] and the Companies Act, 2013 [the Act].

2. This Policy relates to the activities to be undertaken by the Company asspecified in Schedule VII of the Companies Act, 2013 and the expenditure thereon,excluding activities undertaken in pursuance of normal course of business of theCompany.

3. As clarified by the Ministry of Corporate Affairs vide General Circular no. 21/2014dt. June 18, 2014, CSR activitiesmust be relatable to Schedule VII of the Companies Act 2013, the entries in the said Schedule VII must be interpreted liberally so as to capture the essence of the subjects enumerated in the said Schedule. Further, one-off events such as marathons/ awards/ charitablecontribution/ advertisement/ sponsorships of TV programmes etc. would notqualify as part of CSR expenditure.

4. The CSR projects or programmes or activities that benefit only the employees of thecompany and their families shall not be considered as CSR activities. Expenses by the Company for fulfillment of any other act or statute or contribution (direct or indirect) to any political party) would not qualify as CSR expenditure.

5. This policy document will be applicable for all offices for implementation ofCSR activities/programs. However, any expenditure made by the Company for projects or programmes or activities undertaken outside India would not qualify as CSR expenditure.

6. Working instructions/ guidelines for this policy will be issued separately for theoffices, with the approval of Center Head /General Manager/Managing Director.

D. Composition of CSR Committee

As per the provisions of section 135 of the Companies Act, 2013, where the amount to be spent by the Company towards its Corporate Social Responsibility exceeds fifty lakh rupees, the Board of Directors shall constitute a Corporate Social Responsibility Committee for discharge of functions related to CSR in line with terms of reference enumerated in point E hereunder.
Where the amount to be spent towards CSR doesnot exceed fifty lakh rupees the functions of such Committee as provided under section 135 of the Act shall be discharged by the Board of Directors of the Company.Accordingly, the Board of Directors shallconstitute a CSR Committee comprising such number of directors and with suchcomposition as required under the Companies Act, 2013.
The Committee, when constituted will meet as frequently as may be required, to review policies, discuss the strategy, review project progress and set the direction for the future.

E. Terms of reference

The terms of reference of the CSR Committee (or the Board of Directors, where CSR Committee is not required to be constituted) are as follows:
(i) Formulate and recommendto the Board, a CSR Policy (and modifications thereto from time to time) which shall indicate the CSR initiatives to be undertaken by the Company in areas or subject,specified in Schedule VII.
(ii) Recommend the amount of expenditure to be incurred on the activities specified in (i) above.
(iii)Monitor the CSR Policy of the Company from time to time and institute a transparent monitoring mechanism for implementation of the CSR projects referred to above.
(iv)Review the progress of CSR initiatives undertaken by the Company.

F. CSR Policy Statement

To attain its CSR objectives in a professional and integrated manner, the Company has chosen the following areas for its CSR projects, which may be by way of direct participation or by way of providing donations or financial assistance. These are –
(i) Eradicating hunger, poverty and malnutrition,promoting health care including preventive health care and sanitation including contribution to the Swachh Bharat Kosh set-up by the Central Government for the promotion of 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, agro-forestry, conservation of natural resources and maintaining quality of soil, air and waterincluding contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga;
(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 art and handicrafts;
(vi) Measures for the benefit of armed forces veterans, war widows and their dependents,Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows];
(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 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 socio-economic development and relief and welfare of the Schedule Castes, the Scheduled Tribes, other backward classes, minorities and women;
(ix) Contributions or funds provided 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;
• 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)

(x) Rural development projects
(xi) Slum area development;
(xii) Disaster management, including relief, rehabilitation and reconstruction activities.
(xiii) Providing donations or contributions or financial assistance to other CSR entities or to any Fund as may be permitted under the Companies Act, 2013 for the purpose of CSR.
These focus areas may be reviewed by the CSR Committee (or the Board of Directors) from time to time and may be modified to also include such other CSR initiatives which are covered under Schedule VII of the Companies Act, 2013 (as amended from time to time. The CSR Committee, whenever constituted(or the Board of Directors) is also authorized to recommend changes in the policy, in line with the emerging societal circumstances and in consideration of changing national priorities of the government.

G. Implementation and capacity building of CSR activities

The CSR initiatives of the Company shall either be undertaken by the Company as projects or programmes or activities, whether new or ongoing, in line with the CSR Policy, or by way of providing donations, contributions or financial assistance to such projects or to other companies or entities undertaking such projects, as may be permitted under the Companies Act, 2013 and applicable Rules prescribed thereunder.
Accordingly, shall be undertaken by the Company through itself 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, and having an established track record of at least three years in undertaking similar activities, having a unique CSR Registration Number as specified under the CSR rules.
The Company may build CSR capacities of its own personnel as well as those of its implementing agenciesthroughinstitutionswith established track record of atleast 3 (three) financial years but such expenditure, including expenditure on administrative overheads shall not exceed five percent of total CSR expenditure of the Company in one financial year.
The Company shall generate awareness among all levels of their staff about CSRactivities and the integration of social processes with business processes. Those involved with the undertaking of CSR activities shall be provided with adequate training and re-orientation.
While assigning CSR projects to specialized agencies, every possible effortshall be made to verify the reliability and clean track record of such agencies.

H. Governance

Every year, a CSR Plan delineating the CSR Programmes to be carried out during the financial year and the specified budgets thereof shall be approved by the Board of Directors (as recommendedby the CSR Committee, whenever constituted). The Board will accordingly consider and approve the CSR Plan with modifications, if any.
The Company shall also ensure regular monitoring and reporting of progress from the senior management team or from the teams of the CSR companies responsible for implementing these projects either undertaken by the Company or for which the Company provides donations or contributions or financial assistance.
The Company will report on the implementation of its CSR Policy every year in the Annual Report of the Company, as prescribed under the CSR Rules.

I. CSR Funding and Expenditure

The Board shall ensure that the amount spent in CSR in every financial year is, at least, two percent of the average net profits of the Company made during the three immediately preceding financial years. The amount of net profit will be calculated in accordance with the CSR Rules prescribed under the Companies Act, 2013, as amended from time to time.
The Company shall give preference to the local area and areas around it where it operates, for spending the amount earmarked for Corporate Social Responsibility activities.
Where the Board is unable to spend two percent of net profits referred to above, it shall provide reasons for being unable to do so, in the Board’s Report to shareholders for that financial year, in accordance with the applicable provisions of the Companies Act, 2013 (as amended from time to time). The unspent portion of the budgeted amount of a financial year shall be carried forward and added to the budget of the next financial year as may be approved by Board.Any expenditure in excess of the mandatory requirement may be set off in immediately three succeeding years in manner specified under the CSR rules.
CSR expenditure shall include all expenditure, direct and indirect, including contribution to corpus by the Company on projects or activities relating to CSR activitiesapproved by the Board (on recommendation of its CSR Committee, whenever constituted). Any expenditure on an item not in conformity or in line with activities which fall within the purview of Schedule VII of the Act. Any surplus arising from any CSR Programmes shall be used only for CSR purposes. Accordingly, any income arising from CSR Programmes will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.

J. CSR Monitoring and Reporting Mechanism

The CSR Committee shall monitor the amount of expenditure as approved by the Board of Company. Apart from the above, the Board’s Report of the Company shall include an annual report on CSR containing the particulars in the prescribed format.

K. Display of the CSR Policy on the website of the Company

This policy shall be placed on the website of the Company, alongwith composition of the CSR committee and CSR projects approved by the Board of Directors of the Company in compliance with the CSR rules.

L. Validity and authority for modification/ amendments

This CSR policy shall be effective from the date of its approval by the Board of Directors and for the Financial Year beginning from 1st April, 2021and will be in force till such time it is modified or amended by the Board of Directors (on recommendation of the CSR Committee).
The Board of Directors may amend this Policy from time to time as the situation warrants and as may be recommended by the CSR Committee.

M. General

The provisions of the CSR Policy would be subject to revision / amendments in accordance with the guidelines/ notifications/ circulars/ orders/ rules as may be issued by theGovernment from time to time.

FORES ELASTOMECH PRIVATE LIMITED

Corporate Social Responsibility Committee

Composition

FOR FORES ELASTOMECH INDIA PRIVATE LIMITED

JANARDANA SWAMY POTHAPRAGADA

CHAIRMAN AND MANAGING DIRECTOR

DIN: 00040030

ADD: 2-2-7/1/A, 401 Harmony Classic, D D Colony, Opp Auromira International School, Bagh Amberpet, Sec Underabad, Hyderabad 500007