PREAMBLE

As a responsible corporate citizen, Harbinger Systems Private Limited (“Hereinafter referred to as the “Company”/”We”) tries to contribute towards social causes on a regular basis. We believe that to succeed, an organization must maintain highest standards of corporate behavior towards its employees, customers and society in which it operates. We are of the opinion that Corporate Social Responsibility (hereinafter referred to as “CSR”) underlines the objective of bringing about a difference and adding value in the lives.

This Policy encompasses our Company’s philosophy for delineating its responsibility as a social corporate citizen and lays down the guidelines and mechanism for undertaking socially useful programs for the sustainable development of the underprivileged group.

IDEOLOGY AND PHILOSOPHY

Inside each one of us there is a socially conscious, global citizen who yearns for opportunities to make a difference. Given our hectic lives, many of us end up feeling a little disappointed with our efforts to be socially responsible. In our Company, we want to work on some initiatives that help us to fulfill our aspirations to become a more socially responsible person.

VISION & MISSION

CSR Vision:- “Empowering through education, skill enhancement for the underprivileged section of the society and supporting ecological sustainability.”

CSR Mission:- Company’s CSR initiatives aim at creating an environment which is conducive for self and peer development of underprivileged sections of the society and assist in overall environmental conservation.

KEY WORDS & MEANING

  • Act- Act means the Companies Act, 2013 as amended from time to time
  • Company- as stated above means Harbinger Systems Private Limited, company incorporated under the Companies Act 1956.
  • CSR or Corporate Social Responsibility’ means and includes but is not limited to
    i)Projects or programs specified in Schedule VII of the Act, undertaken by the Company in pursuance of the recommendations of the CSR Committee and approved by the Board as per this Policy.
  • CSR Committee – means the Corporate Social Responsibility Committee of the Board constituted pursuant to Section 135 of the Act.
  • CSR Policy – means the policy approved by the Board as the Corporate Social Responsibility Policy of the Company, and as amended from time to time.
  • CSR Rules or Rules – means Companies (Corporate Social Responsibility Policy) Rules 2014 or as may be amended from time to time.

OBJECTIVES

For HSPL, CSR is not only compliance but also a commitment towards social well-being, and the CSR Policy will inform implementation of impactful activities for sustainable development. With this statement of intent, the objectives of the CSR Policy are to:

  • Promote quality education, environment sustainability and Skill development, through its CSR initiatives / projects
  • Design processes and ensure an increased commitment at all levels in the organization towards social responsibility
  • Create a larger support base for CSR initiatives of the Company by involving large number of people

APPLICABILITY

  • HSPL CSR policy has been developed in consonance to Section 135 of the Act, (referred to as the Act in this policy) on CSR and in accordance with the Rules notified by the Ministry of Corporate Affairs, Government of India in 2014.
  • The CSR Policy shall apply to all CSR projects/programs undertaken by the Company in India in accordance to the Schedule VII of the Act.

CSR FOCUS AREAS AND INITIATIVES

  • Education: Promoting education, including special education, the Company may undertake projects or programs or activities aimed at the promotion of education from elementary to professional level to support the students belonging to weaker sections of the society by helping the existing schools in development of their perspective and advocacy programs to contribute in the social sector for sustainable development.
  • Employment Enhancement and Entrepreneurship Development: The Company may undertake projects / programs / activities for employment enhancing skills vocational skills among children, and the differently abled for livelihood enhancement projects.
  • Environmental sustainability: The Company may take up projects and programs that assist in environmental conservation and support ecological sustainability as part of its initiative towards developing a Green India.
  • Contribution to Prime Ministers Relief Fund: In case of a catastrophe, we will contribute some part of our funds to the Prime Minister’s Relief Fund.

GOVERNANCE STRUCTURE

The CSR Governance Structure shall consist of CSR Committee of the Board, CSR Steering / Operations Committee which shall consist of the following members.

  • CSR Committee of the Board (“CSR Committee”):
    The CSR Committee consists of Ms. Swati Ketkar, Mr. Vikas Joshi and Mr. Vasudeo Joshi, Directors of the Company, who shall approve the CSR Policy, CSR Budget and CSR projects and programs in alignment with Section 135 of the Act and Rules.
  • CSR Steering / Operations Committee:
    The CSR Committee shall be assisted by Mr. Abhay Patil, Senior Vice President – Talent and Operations and Ms. Swati Madathamana, Manager – Employee Engagement who shall assess Projects / Programs and allocate budgets. They shall further submit the same to the CSR Committee for approval.

ROLE AND RESPONSIBILITIES OF CSR COMMITTEE

The Roles and Responsibilities of the CSR Committee shall consist of the following:

  • To draft the CSR Policy and recommend the same to the Board of Directors (“Board”) of the Company for approval
  • To review and recommend any new CSR initiatives to be taken up by the Company including the selection/appointment of implementation agencies
  • To monitor and review the progress of CSR projects already undertaken by the Company
  • To recommend the amount of expenditure to be incurred on the activities undertaken by the Company and the utilization of budgets for each of such projects
  • To review and recommend the CSR Report to be included in the Board’s Report
  • To review and recommend any amendments to be made in the CSR Policy of the Company
  • To carry such other functions as may be delegated to it by the Board relating to CSR activities of the Company

BUDGET

The CSR Committee shall recommend the annual budgeted expenditure (project wise) to the Board for its consideration and approval. For achieving the CSR Objectives through implementation of meaningful & sustainable CSR Programs, the Company shall allocate in each financial year 2% of the average net profits made by the Company during the three immediately preceding financial years, as its Annual CSR Budget.

SURPLUS

Surplus arising out of CSR projects or programs, if any, shall not be part of business profits of the Company and the same shall be utilized for CSR activities in accordance with this Policy.

IMPLEMENTATION

The CSR programs or projects under this CSR Policy will be implemented directly by the Company or indirectly through the following implementing agencies:

  • Through a Registered Trust or a Registered Society or Section 8 Company, whether or not established by the Company or its holding or subsidiary or associate company; or
  • In collaboration with other companies; or
  • Combination of one or more of the above

In case one or more CSR projects or programs are undertaken in collaboration with implementing agencies, clear demarcation with respect to responsibility, contribution, implementation, monitoring, etc. of each of such agencies shall be established.

EXECUTION

Company shall identify suitable programs for implementation, in line with its CSR objectives under this CSR Policy and also benefit the community for which those programs are intended. These programs would be done through:

  • Community based organizations whether formal or informal
  • Voluntary Agencies (NGOs)
  • Institutes / Academic Organizations
  • Trusts, Missions
  • Self-help Groups
  • Mahila Mandals / Samitis
  • Professional Consultancy Organizations
  • Corporate with similar CSR Vision

MONITORING AND REVIEW

To ensure effective implementation of the CSR programs undertaken by the Company, the Company will put a monitoring mechanism in place. The progress of CSR programs under implementation will be evaluated and monitored by third party agencies of repute, which shall report to the CSR Committee on quarterly basis.

The CSR Steering Committee will conduct impact studies on a periodic basis, through independent professional third parties / professional institutions / individuals, especially with regard to strategic and high budget projects and programs.

AMENDMENT

Any or all provisions of the CSR Policy would be subject to revision / amendment in accordance with the guidelines on the subject as may be issued from Government, from time to time. The Board reserves the right to alter in any manner whole or part of this CSR Policy as and when necessary, subject however to the provisions of the Section 135 of the Act and Rules made there under.

REPORTING

The Company will prepare an annual Report on CSR pertaining to the financial year, in the prescribed form to be attached to the Board’s Report of the Company.

Harbinger Systems