Preamble

At Anunta, giving back to the communities is a part of our corporate ethos. As a corporate citizen, we are committed to operating in an economically, socially and environmentally responsible manner while balancing the interests of our diverse stakeholders. Our Corporate Social Responsibility (CSR) company policy outlines our efforts to give back to the world as it gives to us. This philosophy is seamlessly integrated into Anunta’s people, services and processes and is the foundation and underlying objective, of the Corporate Social Responsibility Policy of Anunta Technology Management Services Ltd (referred to as Anunta Tech).

The CSR Policy has been framed in accordance with the provisions of section 135 of the Companies Act, 2013 (“Act”) and the Rules prescribed thereunder and as defined hereinafter (collectively referred as “Applicable Laws”).

Definitions

• “CSR Activities” shall mean the projects and / or programmes undertaken by the Company either directly or indirectly pursuant to Applicable Laws in accordance with this CSR Policy.
• “Implementation Agencies” any other trust, society or company or any entity established under an Act of parliament or a state legislature or any other agency which is eligible to undertake CSR Activities, on behalf of the Company in compliance with the Applicable Laws
• “Rules” means Companies (Corporate Social Responsibility Policy) Rules, 2014, or any other rules prescribed under section 135 of the Act and pertaining to corporate social responsibility, as may be amended and prescribed, from time to time.

Interpretation

• Words and expressions used in this Policy and not defined herein but defined in Applicable Laws, or the Articles of Association of the Company shall have the meaning as assigned to them thereunder
• In this Policy, unless the contrary intention appears:
  • the clause headings are for ease of reference only and shall not be relevant for construction or interpretation of the Policy.
  • words in singular include the plural and vice-versa.
• All references to laws or to any specific provision of any law shall include references to all delegated legislation issued thereunder or any legislation as it may have been, or may from time to time be, amended, modified, consolidated or re-enacted (with or without modification).
• Where a word or phrase is defined, other parts of speech and grammatical forms of that word or phrase shall have corresponding meanings.

Guiding Principles

• The Company shall follow the following guiding principles for selection, implementation and monitoring of CSR Activities as well as formulation of the Annual Action Plan:
  • In undertaking CSR Activities, the Company shall give preference to the local areas wherein the Company operates or has its offices i.e. areas in the vicinity of its offices
  • The Company shall undertake only such CSR Activities, A) as are identified as Focus Areas under this Policy and B) as are permitted under the Applicable Laws. The Company shall also consider international, national, or state level priorities/ objectives, while identifying CSR Activities.
  • The Company shall not discriminate against the beneficiaries of the CSR Activities, on any grounds whatsoever, including race, gender, age, ethnicity, caste, religion, domicile, but may focus its CSR Activities to benefit the economically or socially weaker, or marginalised sections, of the society.
  • The Company shall endeavour utmost transparency in selection, implementation, monitoring and reporting of CSR Activities.
  • The Company shall ensure that all CSR Activities undertaken directly or indirectly, meet applicable standards of quality followed by Company and/or are the market standard for such activities.
  • The Company shall either undertake the project directly and shall to its best of its ability and also ensure that the partners or vendors selected by the Company or the Implementation Agency, satisfy the criterion specified by the Rules (if any) and have relevant experience, good credentials, no criminal track record, and follow the ethical standards which are at par with the Anunta Tech’s Code of Conduct.
  • The Company shall ensure that all the CSR Activities are implemented as per the approved Annual Action Plan.

Mode of Implementation

• All CSR Activities of Anunta Tech shall be undertaken by the Company either directly or through any other authorized Implementation Agency.
• Subject to Applicable Laws, Anunta Tech may collaborate with other companies for undertaking projects or programmes or CSR activities, provided that the CSR committee of Anunta Tech, shall separately report to the Board, such projects or programmes that have been undertaken as Anunta Tech’s CSR Activities.
• All contribution to the funds referred in Para 6 point (iv) and (v) shall be made directly by the Company and shall be utilized, accounted and monitored, strictly in accordance with Applicable Laws.
• In case the Company undertakes any CSR Activity through any Implementation Agency, such Implementation Agency shall satisfy the requirements prescribed under the Applicable Laws and shall be approved by the Board.

Focus Areas

• The Company is committed to support the CSR Activities undertaken in the following areas:
  • promoting education, including special education or employment enhancing vocational skills, especially among children, women, elderly, and the differently abled and livelihood enhancement projects.
  • 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 or any state government for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women.
  • (a) contribution 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; and
  • (b) contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies engaged in conducting research in science, technology, engineering, and medicine aimed at promoting Sustainable Development Goals (SDGs).
  • rural development projects.
  • disaster management, including relief rehabilitation and reconstruction.
  • any activities or subjects specified in Schedule VII of the Act.

CSR Expenditure

• Every year the Company shall spend atleast 2% of its average Net profit as defined under the Rules (“CSR obligation”) during the three immediately preceding financial years, on the CSR Activities as per approved Annual Action Plan.
• The Company shall not consider any administrative expenses, except the cost of Impact Assessment, in meeting its CSR obligation, provided that, such costs shall not exceed the cap for such impact assessments, prescribed under Applicable Laws.
• Any amount remaining unspent at the end of the financial year, if any, except in case of an ongoing project, shall be transferred to a Fund to be specified in Schedule VII for this purpose, within a period of six months of the expiry of the relevant financial year.
• Any surplus arising out of CSR projects, programmes or activities shall not form part of the business profits of the Company and shall be utilized towards the eligible CSR Activities / addressed in accordance with Applicable Laws.

Approval of CSR Activities

• The CSR Activities to be undertaken by the Company under the Policy shall be approved by way of Annual Action Plan by the Board on the recommendation of the CSR Committee.
• The Annual Action Plan shall, inter alia, contain the following information with respect to the CSR Activity proposed to be undertaken by the Company:
  • list of CSR Activities to be undertaken in the relevant financial year;
  • local area where the CSR Activities are to be undertaken;
  • manner of execution;
  • modalities of utilisation of funds;
  • implementation schedule;
  • monitoring and reporting mechanism; and
  • details of need and impact assessment, if any.
• The Board on the recommendation of the CSR Committee shall be the absolute authority to update, alter, modify, amend, withdraw and replace the Annual Action Plan for justified reasons.

Monitoring of CSR Activities

• Under the overall supervision of the Board and the CSR Committee, the company or the Implementation Agency (in case, the CSR Activities are undertaken by any other Implementation Agency), shall be responsible to monitor the CSR Activities. The Implementation Agency shall devise a robust monitoring mechanism to ensure that the CSR Activities are undertaken effectively in accordance with approved Annual Action Plans in compliance with the Applicable Laws and the provisions of this Policy.
• The CSR Activities will be effectively and objectively monitored using appropriate monitoring tools that may include one or more of the third-party audit(s) or certification(s), impact assessment(s), self- assessment report(s), field visit(s), periodical review(s) or any other appropriate mechanism.
• The CSR Committee shall review the progress on Annual Action Plan preferably on quarterly basis but not less than twice in a year.
• The Board shall review the status of implementation and fund utilization of the various projects and programmes as per approved Annual Action Plan at least once in a year.

Responsibilities of the Implementation Agency

• For the purpose of CSR Activities of Anunta Tech, the team shall work under the overall supervision of the CSR Committee and the CSR Committee shall be fully authorised to issue any instruction, guidelines, direction, order, advisor etc. which shall be binding on the implementation team.
• If the CSR Activities are undertaken through any other Implementation Agency, such Implementation Agency shall ensure the following:
  • All CSR Activities of Anunta Tech comply with this CSR Policy and the Applicable Laws.
  • The Implementation Agency works only with credible institutions, non-governmental organisations (NGOs), government agencies, domain experts and visionaries and other philanthropic foundations to enhance the outreach of the
  • Company’s CSR Activities in line with the CSR Policy.
  • Undertake the CSR Activities as per the approved Annual Action Plan.
  • Update the CSR Committee and the Board on the progress of CSR Activities and status of implementation of the Annual Action Plan.
  • Maintain records of all CSR Activities undertaken on behalf of the Company.
  • Do all such acts, deeds and things as may be directed by the CSR Committee in pursuance of the CSR Policy and for the effective implementation of the Annual Action Plan.

Disclosures

• Details of composition of the CSR Committee, the CSR policy, the CSR Committee charter and details of CSR Activities approved by the Board shall be reported half yearly to the Board.
• Annual report on CSR Activities shall be included in the Board’s Report forming part of Company’s Annual Report.

Miscellaneous

• This Policy shall remain in force unless amended or withdrawn.
• The Chief Executive Officer and the Chief Financial Officer are jointly authorized to amend this Policy to appropriately incorporate statutory amendments relating to corporate social responsibility from time to time. Such amended policy shall be placed before the CSR Committee and the Board for information and noting.
• The Board may, in accordance with Applicable Laws, alter, amend, review, substitute this Policy as and when required without any prior intimation to any stakeholder for justified reasons.
• Any questions and clarifications relating to this Policy should be addressed to the Company Secretary at preeti.ghiya@anuntatech.com