1. Objective & Philosophy
  2. Hella Infra Market Private Limited ("Company" or "We" or "Our") has articulated this Corporate Social Responsibility Policy ("CSR Policy") in alignment with its objective, principles, and values, delineating its responsibility as a socially and environmentally responsible corporate citizen and to define the governance and monitoring framework for ensuring effectiveness of the CSR Policy.

    The Company believes in 4 (four) core essence of corporate social responsibility ("CSR") viz. (i) sustainability of environment, (ii) ethical functioning, (iii) charitable support and (iv) care for stakeholders. Our objective is to pro-actively support meaningful socio-economic development in India and enable a larger number of people to participate in and benefit from India's economic progress. This is based on the belief that growth and development are effective only when they result in wider access to opportunities and benefit a broader section of society. The Company aims to identify critical areas of development that require investments and intervention, and which can help to realize India's potential for growth and prosperity.

  3. The Regulatory Framework of CSR Policy
  4. Section 135 of the Companies Act, 2013 read with the rules framed thereunder ("Act") and Schedule VII of the Act provides framework for the companies to define the key thrust areas in CSR domain. The Company's CSR Policy would pertain to all CSR activities undertaken by the Company within the contours of the Act.

  5. The Key CSR Activities
  6. The Company's primary focus areas for CSR activities within the ambit of the Act includes the following ("CSR Activities"):

    1. Education
    2. Support the transformation of the education system in India to achieve its goals of increasing equity and employability among children and support teachers and schools to develop high quality learning spaces.

    3. Hunger, poverty, malnutrition, and healthcare
    4. Work with various non-profit organizations that run mid-day meal programs in schools across India and may establish kitchens that provide meals to schoolchildren.

      The Company hopes to innovately create impact in the healthcare sector. It aims towards preventive as well as facilitative healthcare of India's populace.

    5. Rural development
    6. The Company believes that the well-being of people living in rural areas ensures sustainable development. The Company may work with local administrations to achieve community development goals. The Company may partner with governments and NGOs and support them in improving infrastructure such as constructing roads, providing drainage systems, electricity, rehabilitating natural-disaster affected victims, etc. in rural areas.

    7. Gender equality, Environmental sustainability, Art and Culture
    8. The Company shall, among other things focus on empowering women by supporting them to develop a gender equitable society, where women have equal opportunities and rights to engage, participate and contribute to national development.

      Engage with communities to build an awareness for biodiversity, undertake activities and projects to protect our environment and may also work towards protection of national heritage, art and culture including restoration of buildings and sites of historical importance.

    9. National Emergency & Disaster Relief
    10. Provide support to specific needs such as natural disasters, through financial as well as logistical support.

      Apart from the CSR Activities undertaken in the above focus areas, the Governing Body may choose to select activities in areas or subjects, as prescribed in Schedule VII of the Act.

  7. Governance Structure
    1. The Board of Directors of the Company and/ or the CSR Committee (as applicable under the Act) ("Governing Body") is the governing body that will articulate the scope of CSR Activities for the Company and ensure compliance with the CSR Policy. The Governing Body would comprise of such minimum number of Directors as may be prescribed under the Act.
    2. The Governing Body shall:
      1. Formulate the CSR Policy and make any amendments thereto;
      2. Indicate the CSR Activities to be undertaken by the Company as specified in the Act;
      3. Review the annual CSR plan to the Board;
      4. Monitor the CSR Activities and compliance with the CSR Policy from time to time; and
      5. Review and implement, if required, any other matter related to CSR initiatives
    3. The Governing Body may meet at least once in every financial year

  8. Operating Framework
    1. CSR Activities will be undertaken in areas identified by the Governing Body. An annual CSR plan shall be presented by the Governing Body
    2. CSR activities shall be undertaken by the Company directly
    3. The responsibility for implementation of identified CSR Activities/ projects shall be as per the organizational structure approved by the Governing Body
    4. The annual plan shall incorporate the following:

      1. The prescribed outlay on CSR as per the Act and related rules as amended from time to time; 
      2. Key CSR Activity/ ies proposed to be undertaken during the year, including analysis of their eligibility for classification as CSR under the Act, their conformity with the CSR Policy and their implementation schedules;
      3. Proposed outlay on each CSR Activity;
      4. CSR Activity/ ies to be undertaken by the Company directly
      5. Aggregate proposed outlay and reasons for shortfall, if any, compared to the prescribed outlay
      6. Funds would be disbursed either in tranches or as one-time payment. The terms, conditions and timing of disbursement would be conditional upon the nature and requirement of the CSR project or programme
      7. Surplus arising out of CSR projects shall not form part of the business profit of the Company

  9. Monitoring
  10. The Governing Body shall ensure a transparent monitoring mechanism for CSR Activities.

    1. The Governing Body shall review the progress of CSR Activities periodically, including the annual review
    2. The CSR Activity/(ies) along with requisite information on the expenditure, etc. shall be reported every year in the annual report of the Company

  11. CSR Expenditure
  12. The CSR expenditure will include all expenditure, direct and indirect, incurred by the Company on CSR Activity/(ies) undertaken in accordance with the approved CSR plan. Moreover, any surplus arising from any CSR Activity/(ies) shall be used for CSR. Accordingly, any income arising from CSR Activity/(ies) will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.

  13. General
    1. The power to interpret and administer the CSR Policy vest with the Chairman of the Governing Body whose decision shall be final and binding
    2. Any or all the provisions of this CSR Policy would be subject to revision/amendment in accordance with the guidelines on the subject as may be issued by Government, from time to time
    3. The conditions or terms of this CSR Policy can be modified/ amended, cancelled or added in writing with the approval of Board of the Company. However, in the event of any conflict between the contents of this CSR Policy and the Act, the provisions of the Act shall supersede and will be made applicable to the matter. Further, the CSR Policy shall stand automatically amended in accordance with the amendments to the Act