Corporate Social Responsibility

The main objective of the Corporate Social Responsibility Policy (“CSR Policy”) of OCL Iron and Steel Limited is to lay down the guidelines for proper execution of Corporate Social Responsibility Activities and to support the sustainable development of the society. The policy on Corporate Social Responsibility (CSR) is adopted by the Company to align its philosophy/ activities with measures, programmes and activities envisaged and incorporated in the Companies Act, 2013 and the rules made thereunder.

This policy has been recommended by the Corporate Social Responsibility Committee (‘CSR Committee’) to the Board of Directors of the Company for adoption at their meeting and the terms, rules and regulations mentioned in this policy are as per the Companies Act, 2013 and the rules made thereunder.

The Board may upon the recommendation of CSR Committee, amend or modify this CSR policy as and when necessary. This policy shall be effective with immediate effect.

The Company will do its best to follow the requirements of the Companies Act, 2013 on the CSR obligation in letter and spirit.

The Corporate Social Responsibility Committee is constituted as per the requirements of the Companies Act, 2013, comprising of three (3) or more members out of which at least one Director shall be an Independent Director. The composition of CSR Committee shall be disclosed in the Board’ Report.

• The Committee shall meet at least once in a year.
• The Committee may, at its discretion, invite other Directors/such executives as and when required
• The quorum necessary for transacting business at a meeting of the Committee shall be two members or one-third of the total number of members of the Committee whichever is greater.
• The Chairperson of the Committee shall be present at the Annual General Meeting (AGM) to answer shareholder queries.
• While invitees to the Committee shall have a right to be heard at the meetings, they shall not have a right to vote. The right to vote shall vest only with the members of the Committee.

The Corporate Social Responsibility Committee shall:

• Formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the company in areas or subject, specified in Schedule VII;
• Recommend the amount of expenditure to be incurred on the activities referred to in clause (a); and
• Monitor the Corporate Social Responsibility Policy of the Company from time to time.

The Company may undertake any of the following activities as its CSR activities:

• Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water.
• promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
• promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups.
• ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water including contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga.
• protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional art and handicrafts;
• measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
• training to promote rural sports, nationally recognised sports, paralympic sports and Olympic sports
• 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 govt. for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women;
• 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
• Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense Research and Development Organisation (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).
• rural development projects.
• slum area development.
• disaster management, including relief, rehabilitation and reconstruction activities.

• The Company will endeavor to spend the following amounts for CSR activities in pursuance of this Policy:
  • In every financial year, at least two (2%) percent of the ‘average net profits’ of the Company made during the three immediately preceding financial years. The ‘average net profits’ shall be calculated in accordance with the provisions of Section 198 of the Companies Act, 2013 and the rules made thereunder from time to time.
  • Any income arising from the activities mentioned above.
  • Surplus arising out of CSR activities.
• The company shall give preference to the local area and areas around it where it operates, for spending the amount earmarked for Corporate Social Responsibility activities.
• if the Company fails to spend the amount embarked for CSR activities, the Board shall, in its report made under section 134, specify the reasons for not spending the amount and unless the unspent amount relates to any ongoing project, transfer such unspent amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.
• If company spends an amount in excess of amount embarked for CSR activities, such excess amount may be set off against the requirement to spend up to immediate succeeding three financial years subject to the conditions that –
  • the excess amount available for set off shall not include the surplus arising out of the CSR activities, if any;
  • the Board of the company shall pass a resolution to that effect.
• Amount spent on CSR activities shall include all expenditure including contribution to corpus for projects or programs relating to CSR activities approved by the Board on the recommendation of its CSR Committee, but will not include any expenditure on an item not in conformity or not in line with activities which fall within the purview of Schedule VII of the Companies Act, 2013.
• Any surplus arising out of the CSR activities will not be part of the business profits of the Company.
• The CSR Committee will approve the expenditure on CSR activities within monetary limits sanctioned by the Board for such activities.
• The administrative overheads shall not exceed five percent of total CSR expenditure of the Company for the financial year.

• The activities to be undertaken by the Company as CSR activities shall be the projects/ programs relating to the activities/ subjects specified enumerated in the Schedule VII of the Companies Act, 2013 or any amendment thereto or modification thereof from time to time.
• CSR activities may be initiated/ implemented/ executed by the Company itself or through:
  • a company established under section 8 of the Companies Act, 2013 or a registered public trust or a registered society, exempted under sub-clauses (iv), (v), (vi) or (via) of clause (23C) of section 10 or registered under section 12A and approved under 80 G of the Income Tax Act, 1961 (43 of 1961), established by the company, either singly or along with any other company; or
  • a company established under section 8 of the Companies Act, 2013 or a registered trust or a registered society, established by the Central Government or State Government; or
  • any entity established under an Act of Parliament or a State legislature; or
  • a company established under section 8 of the Companies Act, 2013 or a registered public trust or a registered society, exempted under sub-clauses (iv), (v), (vi) or (via) of clause (23C) of section 10 or registered under section 12A and approved under 80 G of the Income Tax Act, 1961, and having an established track record of at least three years in undertaking similar activities.
    Provided that the entity covered above, who intends to undertake any CSR activity, shall register itself with the Central Government by filing the form CSR-1 electronically with the Registrar, with effect from the 01st day of April 2021.
• The Company may engage international organisations for designing, monitoring and evaluation of the CSR projects or programmes as per its CSR policy as well as for capacity building of their own personnel for CSR.
• The Company may also collaborate with other Companies for undertaking projects or programmes or CSR activities in such a manner that the CSR committees of respective Companies are in a position to report separately on such projects or programmes in accordance with the rules.
• The programs/projects which benefit only to the employees of the Company and their families shall not be considered for CSR activities.

• The Committee shall monitor periodically the implementation and execution of the projects/ programs/ activities under CSR policy and to ensure compliance of the provisions related to CSR mentioned in the Companies Act, 2013 and rules made thereunder from time to time and report the same to the Board of Directors on a regular basis.
• The Committee shall on completion of every Financial Year, submit to the Board, details of the CSR spent during the Financial Year and reasons for the actual spent being less than the limits prescribed by the law, if any.
• The report on CSR shall form part of Boards’ Report (Directors’ Report) of the Company.
• The Committee shall recommend changes/ modifications to be carried out in the policy to the Board from time to time.
• A robust monitoring mechanism and evaluation plan will be put in place.
• Expected outcomes, outputs and inputs will be clearly defined for each program as per stated timelines.
• There shall be clarity about the scope of the program and the need before evaluations are undertaken.

The role and responsibility of the Board shall include:

• Approval of CSR policy after taking into account recommendations of the CSR Committee.
• Reporting in the Board’s Report brief outline of this CSR policy including overview of projects or programs, composition of CSR Committee, average net profits of the Company for the last three financial years and prescribed CSR expenditure as required under the Companies Act, 2013 and rules made thereunder along with the total amount spent on CSR activities in the financial year and (ii) amount unspent, if any.
• Ensure that the CSR activities are undertaken and executed by the Company as per this CSR policy and the applicable laws.
• Specify in the Boards’ Report, the reasons, if amount embarked for CSR activities is not fully spent.
• The Board of a Company shall satisfy itself that the funds so disbursed have been utilized for the purposes and in the manner as approved by it and the Chief Financial Officer or the person responsible for financial management shall certify to the effect.