CSR Policy

Objective

This policy will serve as a guiding document for OIT’s SPVs, aiding in planning, conceptualization, formulation, collaboration, implementation, monitoring, evaluation, documentation, and reporting of CSR projects.

Scope

This policy is applicable to the CSR committees at SPVs, Sustainability and CSR Committee of OIT, and the Board of Directors of the SPVs of OIT mandated under CSR provisions.

Budget

• The Board of the Company (SPVs under OIT) shall allocate at least 2% of the average profit (as required by Companies Act 2013) during the three preceding financial years.
• The SPVs which are required to meet legal requirement on CSR shall collaborate or pool resources with other entities permissible under relevant regulations, to undertake CSR activities.
• In case of any surplus arising out of CSR programmes, the same shall not form part of business profits of the Company and shall be ploughed back into the same project or transferred as per the provisions of the CSR Rules.
• Every year, a specific budget is allocated for CSR activities. List of activities to be undertaken by the concerned SPV along with financial allocation against each activity shall be recommended by the CSR Committee and approved by the Board of Directors.

Ongoing Projects and Annual Action Plan

• The SPVs shall comply with the provisions of the Act and the CSR Rules with respect to Unspent CSR amount with regard to Ongoing Projects and projects other than Ongoing Project.
• The CSR Committee of the concerned SPV shall review the progress of each project and monitor, review and evaluate the operations of the CSR Programmes at such frequency as it may deem fit to ensure orderly and efficient implementation of the CSR Programmes in accordance with the CSR Policy.

Focus Area, Location, and Mode of Implementation

• In each financial year, the CSR Committee of the concerned SPV shall prepare a list of CSR Projects/ Activities/Programmes which the Company proposes to undertake during the financial year, the location for each of the activities, specifying the modalities of execution in the areas/sectors chosen with implementation schedules for approval of the Board.
• The CSR Projects shall be implemented directly or through partnership with eligible and credible organizations – individually or as a consortium – to design, fund, implement and review projects.
• Partner agencies shall be selected based on well-defined selection criteria by Sustainability and CSR Committee of OIT.

Governance and Roles and Responsibilities

OIT’s CSR (by SPVs under OIT) shall have a multi-tiered governance mechanism. The Board of the respective SPVshall be responsible for approval of the CSR policy. The CSR committee at the SPV level shall formulate the policy and recommend it to the Board. The Sustainability and CSR Committee at OIT Head Officeshall be responsible for identification, implementation (through mode of direct or partner implementation) and evaluation of the CSR programmes.

The Board

• Shall approve the CSR Policy of the Company and ensure spend of 2% of profits.
• Shall provide details of the CSR Committee Composition on the Company’s website as prescribed under Section 135 of the Act and the CSR Rules.
• Shall specify reasons in its report for not spending the earmarked amount in case the Company fails to spend such amount.

CSR Committee of the Board

• Shall formulate and recommend the CSR Policy to the Board for approval.
• Shall monitor the Policy from time to time.
• Shall recommend the amount of expenditure to be incurred on CSR programmes.
• Shall constitute transparent monitoring mechanism for ensuringimplementation of the CSR programme.
• Shall allocate the programmes to the CSR team to implement the same.

CSR Team

• Shall identify programmes to be undertaken during the financial year and partners for implementation and obtain CSR Committee / Board approval.
• Shall monitor the implementation of the approved programmes to achieve desired outcome.
• Shall report on the status of implementation of the programmes to the CSR Committee on quarterly basis.
• Shall facilitate the CSR impact assessment studies through an independent agency for all CSR programmes of more than Rs. 1 crore at such intervals as may be prescribed by law.

Impact Assessment

• The annual CSR report shall form a part of Board’s Report. It will include the impact assessment study. All CSR projects with an outlay of Rs.1 crore or more will be assessed for impact.
• The CSR Projects or activities that are for short-term will be assessed within three-month of their completion of their implementation and within the same financial year. These projects that span over multiple years of implementation, will be assessed at mid-term and within six months of their completion.

Review

The Sustainability and CSR Committee of OIT shall review this Policy periodically to ensure effectiveness of the Policy and recommend appropriate revisions to the Board for consideration and approval, if required.