CSR Policy

Background: In conformity with the requirements laid down under the Companies (Corporate Social Responsibility Policy) Rules, 2014 (hereinafter referred to as the “CSR Rules”) issued by the Ministry of Corporate Affairs (“MCA”), Government of India under Section 135 of the Companies Act, 2013 (“the Act”) the CSR Committee of the Board had drafted a CSR Policy, which was approved by the Board of Directors at their meeting held on 1/2/2020.

Preamble: Incture Technologies Private Limited (hereinafter referred to as “the Company”), recognizes the impact it has on community in which it operates and believes that it has an opportunity to change the lives of the community and aims to be a trusted partner contributing to the social, economic and environmental progress of India. As part of its dedicated approach to create economic opportunity in the community in which it operates, the Company has been contributing its time, expertise and resources to help the community and undertaking a series of locally relevant initiatives.

CSR Objectives: As a responsible corporate citizen, the Company is committed to sustainable development and inclusive growth and has been focusing on issues relating to the environment, healthy living, skill-building, social advancement and promoting gender equality and empowerment of women over the past several years. Whilst the Company will continue to support activities as per Schedule VII of the Act listed below, the Company will focus its efforts on three key areas: i.e., Education, Environment and Prime Minister’s National Relief Fund. The specific projects under these pillars are being worked on and more specifics will be finalized in due course. In terms of the CSR rules issued by the MCA the Company will be focusing on undertaking the projects listed below, as specified in Schedule VII to the Act excluding activities undertaken in pursuance of the normal course of business of a Company:

i. Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly, and differently-abled and livelihood enhancement projects

ii. Ensuring environmental sustainability, ecological balance, and protection of flora and fauna, animal, welfare, agroforestry, conservation of natural resources and maintaining the quality of soil, air and water including contribution to the “Clean Ganga Fund” set up by the Central Government for rejuvenation of river Ganga

iii. Contribution to the Prime Minister’s national relief fund or any other fund set up by the central govt. for socio-economic development and relief and welfare of the scheduled caste, tribes, other backward classes, minorities and women


CSR Spend: Beginning with the financial year 2019-2020, the Company has undertaken to spend on its CSR activities every year, 2% of its average Net Profits during every block of three years. ‘Net Profit’ shall be calculated in the manner prescribed by the Act and the CSR Rules. Any ‘Income’ or ‘Surplus’ that may arise from its CSR activities would also be included in the CSR corpus and will not form part of the business profits of the Company. The CSR activities of the Company shall not include any benefits which are exclusively for the employees of the Company or their family members.

Monitoring of CSR Projects: The CSR Committee of the Board has devised a “transparent monitoring mechanism” for various CSR Projects undertaken by the Company including the conduct of impact studies of CSR Projects periodically, through independent third party agency as and when necessary. Simultaneously, it also obtains feedback from various beneficiaries of CSR Projects undertaken by the Company to measure their benefits.

CSR Projects: At the beginning of each financial year, the CSR Committee of the Board will prepare a list of CSR Projects which the Company proposes to undertake during the financial year, specifying the modalities of execution in the areas/sectors chosen with implementation schedules for approval of the Board.

Amendments to the CSR Policy: The Board of Directors of the Company shall have the powers to revise/modify/amend this Policy from time to time, as the Board may think fit, based on the recommendations to be made by the CSR Committee to conform to the revision/amendment, if any, to be made to the CSR Rules by the MCA, under the Act.

CSR Dashboard: The CSR Committee of the Company would prepare the CSR activity dashboard reporting the project status and fund utilization and compliance adherence every quarter and present it to the Board of Directors of the Company for review and approval.