A framework for responsible, lawful and transparent corporate social responsibility initiatives undertaken by Expertpro Realty Private Limited.
EXPERTPRO REALTY PRIVATE LIMITED (the “Company”) was incorporated on 18.05.2016. This Corporate Social Responsibility (“CSR”) Policy sets out the framework within which the Company shall undertake CSR activities in accordance with Section 135 of the Companies Act, 2013, the Companies (Corporate Social Responsibility Policy) Rules, 2014, Schedule VII to the Act, and other applicable provisions, as amended from time to time.
This Policy is intended to provide a continuing framework for identifying, approving, implementing, monitoring and documenting the Company’s CSR activities. The Company’s first CSR contribution under this Policy is proposed to be made to the Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund), subject to approval of the Board and applicable law.
The Company seeks to contribute to social welfare and public benefit through responsible and lawful CSR initiatives, with particular regard to activities and purposes falling within Schedule VII of the Companies Act, 2013.
This Policy shall apply to CSR activities undertaken by the Company in accordance with Section 135 of the Companies Act, 2013 and the rules made thereunder. The Policy shall be read with the applicable provisions of law as amended from time to time.
The Board of Directors shall have overall responsibility for the Company’s CSR matters, including approval of the CSR Policy, identification and approval of CSR activities, approval of the amount to be spent, monitoring of implementation and ensuring the disclosures and reporting required under applicable law.
Where the amount required to be spent by the Company on CSR does not exceed Rupees Fifty Lakh in a financial year, constitution of a separate CSR Committee shall not be mandatory and the functions otherwise assigned to the CSR Committee shall be discharged by the Board of Directors.
Accordingly, for the relevant financial year in which the Company’s prescribed CSR obligation is within the applicable threshold, the Company shall operate through Board approval and oversight without constituting a separate CSR Committee.
The Board shall review the CSR Policy and CSR activities from time to time and shall ensure that the Company’s CSR expenditure, implementation and disclosures comply with applicable law.
The Company may undertake activities falling within the subjects specified in Schedule VII to the Companies Act, 2013, as amended from time to time.
For the Company’s first CSR contribution, the Board may approve contribution to the PM CARES Fund. The Ministry of Corporate Affairs has clarified that contribution to PM CARES Fund qualifies as CSR expenditure under item (viii) of Schedule VII.
The PM CARES Fund also expressly states that it accepts contributions as part of CSR from companies and PSUs.
CSR activities may be undertaken by the Company itself or through eligible implementing agencies, wherever required under applicable law.
Where a contribution is made to a fund specifically recognised under Schedule VII, the Company shall retain the Board approval, payment proof, receipt/acknowledgement and other supporting records.
The Company shall ensure that CSR expenditure is incurred only for eligible CSR purposes and is properly accounted for and documented.
The amount to be spent on CSR shall be determined in accordance with Section 135 of the Companies Act, 2013 and the applicable CSR Rules.
CSR expenditure shall be incurred only on eligible activities and in accordance with the requirements prescribed under applicable law.
Administrative overheads, surplus arising from CSR activities, treatment of excess expenditure, unspent CSR amounts and other expenditure-related matters shall be dealt with in accordance with the applicable provisions of law.
The Company shall determine its CSR obligation in accordance with Section 135 and the applicable rules for the relevant financial year.
The exact amount approved for the Company’s first CSR contribution shall be recorded separately in the relevant Board Resolution and accounting records.
The Company proposes to make its first CSR contribution to the Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) for the relevant financial year, in such amount as may be approved by the Board.
PM CARES Fund is a public charitable trust. Its official FAQ confirms that contributions by a company or PSU to PM CARES Fund qualify as CSR expenditure under the Companies Act, 2013.
The Ministry of Corporate Affairs has likewise identified PM CARES Fund among the funds to which contributions are admissible as CSR expenditure.
The Board Resolution approving the contribution shall specify the financial year, amount and authorised signatory. After payment, the Company shall retain the transaction proof and formal contribution receipt/acknowledgement generated through the PM CARES process, as applicable.
CSR expenditure shall not include activities which are excluded by Section 135, Schedule VII or the CSR Rules, including:
The Company shall maintain records relating to CSR approval, expenditure, and implementation and reporting, including Board resolutions, CSR Policy, project/activity details, payment proofs, receipts, utilisation records where applicable, website disclosures and annual CSR reporting.
The Company shall ensure that the approved CSR activity is properly recorded in its books and that supporting documents are preserved for the period required under applicable law.
Where the Company has a website, the Company shall disclose the CSR Policy and projects approved by the Board on its website for public access, in accordance with the applicable CSR Rules.
For the first CSR contribution, the Company may disclose the approved PM CARES Fund contribution as the CSR project/activity for the relevant financial year, along with such particulars as are required under applicable law.
The Company shall also make the annual CSR disclosures/ reporting required to be included in the Board’s Report, as applicable.
The Board may review, modify or amend this CSR Policy from time to time to ensure conformity with changes in the Companies Act, 2013, the CSR Rules, Schedule VII and other applicable laws, regulations or governmental clarifications.
This Policy shall be interpreted in accordance with applicable law. In the event of any inconsistency between this Policy and any mandatory provision of law, the mandatory provision of law shall prevail.
This Policy is a continuing policy and does not require replacement merely because a new financial year commences. Where amendments are approved by the Board, the updated Policy shall be maintained and disclosed as required.
Amount, financial year, meeting date, CIN, registered office, authorised signatory and DIN have intentionally been left blank where the Company-specific information has not been provided.
M18B, 2nd Floor, Lajpat Nagar Part-2, New Delhi-110024
