Kusum Healthcare Private Limited

CORPORATE SOCIAL RESPONSIBILITY POLICY 

1. Introduction

Kusum Healthcare Pvt Ltd (“Kusum” or the “Company”) is deeply committed to fulfilling its responsibility as a corporate citizen and integrating it into the Company’s core business strategy. Kusum’s guidelines and mechanism for undertaking socially beneficial programs for the welfare & sustainable development of the community at large is titled the “Kusum CSR Policy.”

2. Applicability  

Kusum’s CSR Policy has been prepared in accordance with Section 135 & Schedule VII of the Companies Act, 2013 (“Act”) along with Companies (CSR Policy) Amendment Rules 2021 (“Rules”).

3. Board Responsibility

The Board of KUSUM will be responsible for:

4. Constitution of the CSR Committee

The board constituted the “CSR Committee” on April 15, 2014. The Committee shall consist of at least two directors of the Company as members of the Committee. Board reconstituted the CSR Committee on April 1, 2021. The present constitution of the CSR Committee is as follows:

Mr. Badri Prasad Gupta	Chairman
Mr. Sanjeev Gupta	Member
Mr. Chand Rashekhar Tippasandra Gowripathi	Member

The Board has the authority to reconstitute this Committee from time to time.

5. Roles and Responsibilities of the Committee:

The roles and responsibilities of the Committee shall be the following:

6. Meetings and Quorum

The committee shall hold meetings as and when required. Two members present shall form the quorum for the meeting of the Committee.

7. CSR Funding And Allocation

KUSUM shall spend in each financial year at least 2% of the average net profits before taxation of the Company made during the three immediately preceding financial years. The total budgetary allocation shall be approved by the Board of Directors.

The CSR Committee will review any unspent CSR allocation of a particular year, and a decision would be taken on whether the unspent amount should be carried over to the subsequent year/s. The CSR Committee, while determining the requirement for carrying over to next year, will consider various factors like availability of desired projects, utilization trend, practical aspects of spending the required amount in a particular timeframe, and best interests of all the stakeholders.

However, the reason for not being able to spend shall be disclosed.

8. CSR Projects/Activities

The thrust of CSR shall be in the following areas, with special attention to the development of weaker/marginalized/underprivileged sections of the society, including SC/ST/OBC/ Minorities, women and children, BPL families, old and aged, physically challenged, etc.

9. Selection & Need Assessment of CSR Projects/ Activities

All the requests/applications from Villagers/Gram Sabha’s / Panchayat / Ward Members/NGOs/ Trusts/ Societies/Beneficiaries/ Government authorities etc. shall be scrutinized and screened by CSR Cell and then their need assessment would be arranged. The need assessment/baseline survey shall be carried out through in-house expertise and recourses.

However, in the case of specialized CSR projects/activities for which in-house capacity is not available, the baseline survey/need assessment shall be carried out by specialized agencies.

In any case, the Company shall maintain the documentary evidence of having got the needed assessment study done through its own expertise and resources, or through some specialized agencies, or having accessed reliable data in this regard from recognized authoritative secondary sources.

10. Approval of CSR Projects/Activities

All the CSR projects/activities shall be approved by CSR Committee and ratified by the Board of Directors.

11. Planning, Implementation & Monitoring

CSR initiatives will be implemented either directly by the Company or through Kusum Charitable Trust which shall act as its implementing agency which is a registered trust and having an established track record of at least 3 years in undertaking CSR activities for which the grant is being given. This Trust is also registered under section 12A and 80 G of the Income Tax Act, 1961 (43 of 1961). The Company may engage International Organisations (as defined in Clause 2(g) of the Companies (Corporate Social Responsibility Policy) Rules 2014) for designing, monitoring, and evaluation of CSR Projects as well as capacity building of their personnel. The Company may also collaborate with other companies to undertake CSR projects, provided the CSR Committees of the respective companies are able to report separately on such projects.

The CSR policy is implemented as per the Act and the Rules. The CSR policy will be implemented ensuring that all projects/programs as budgeted are duly carried out. CSR spending will be closely monitored and funds shall be released against verified utilizations as per the approved work plans. This may include monthly field visits, comprehensive documentation, and regular interaction with beneficiary communities. Further, CSR spending will be audited in an accountable and transparent manner.

Reporting

• The contents of the CSR Policy shall be disclosed in the Director’s Report forming part of the Company’s Annual Report. It shall also be placed on the Company’s website in the prescribed format. It shall include the following.
  • A brief outline of the CSR Policy, including an overview of projects undertaken and a reference to the web link to the CSR policy and projects.
  • Composition of the Board’s Sub-Committee on CSR.
  • Average net profit for last three Financial Years and the Prescribed CSR Allocation (Budget).
  • The details of the amount spent on CSR during the financial year are in the prescribed format.
  • A responsibility statement of the CSR Committee that the implementation and monitoring of CSR Policy are in compliance with CSR objectives and policy of the Company.
• The report would be signed by the Director (Personnel) or Chairman of the CSR Committee.

12. Policy Review

This Policy is framed based on the provisions of the Companies Act, 2013 and the rules thereunder. n case of any subsequent changes in the provisions of the Companies Act, 2013 or any other regulations which make any of the provisions in the Policy inconsistent with the Act or regulations, then the provisions of the Act or regulations would prevail over the Policy and the provisions in the Policy would be modified in due course to make it consistent with the law.

This Policy shall be reviewed by the Corporate Social Responsibility Committee as and when any changes are to be incorporated in the Policy due to changes in regulations or as may be felt appropriate by the Committee. Any changes or modifications to the Policy as recommended by the Committee would be given for approval by the Board of Directors.

This Policy is dated April 1, 2021.

For and on behalf of the

Corporate Social Responsibility Committee of Kusum Healthcare Pvt Ltd

Badri Prasad Gupta

Chairman of the Corporate Social Responsibility Committee