1. Objective of the CSR Policy

Giving back to Society is one of the core values of ASG, wherein we promise to give back 1% of our People’s time, 1% of Products and 1% of Profits to society, with an objective to improve the communities in which we live, by doing the following:

We will develop and implement solutions that are scalable and replicable across wide spectrum of our society.
We will encourage and motivate our employees across levels to relentlessly serve the communities utilizing our technology platforms in a manner that will help in achieving the set objectives and programs through partnerships.

2. Scope and Applicability

This policy shall be applicable to ASG Hospital Private Limited and its subsidiaries.

3. CSR Thrust Areas

ASG will focus its efforts within the developmental streams of education and health with a focus on imparting livelihood skills and healthy sanitation targeted towards senior citizens, women, and youth.

We will invest our resources in the following areas –

4. Governance Structure

The Company has a well-defined and robust governance structure to oversee the implementation of the CSR Policy, in compliance with the requirements of Section 135 of the Companies Act, 2013.

4.1. Total Outlay

As per the Companies Act 2013 (the Act), the Company will contribute at least 2% of the average net profits of the Company made during the 3 immediately preceding financial years towards CSR initiatives. For this purpose, the net profit and average net profit shall be calculated in accordance with the provisions of section 198 of the Act read with the Companies (Corporate Social Responsibility Policy) Rules, 2014. As per the Companies (Corporate Social Responsibility Policy) Rules, 2014, the Company may spend up to 5% of total CSR expenditure in one financial year on building CSR capabilities.

In case there is any unspent amount from out of the 2% average net profits of the Company made during the 3 immediately preceding financial years, the Board of the Company may decide to carry this forward to the next financial year. The surplus arising out of the CSR activities will not be considered as a part of the business profits of the Company.

4.2. Board-level CSR Committee –

The Board Level Corporate Social Responsibility Committee (CSR Committee) of the Company shall be responsible for monitoring the CSR Policy from time to time. The CSR Committee shall approve and recommend to the Board, after examining the projects or programmes submitted by the CSR Council. The CSR Committee consists of the following Directors:

Mr. Arun Singhvi
Mr. Shashank Gang
Ms. Priyanka Singhvi

4.3. Implementation

4.3.a. ASG has set up a dedicated team (CSR Team) for carrying out the following broad responsibilities:

Identifying projects for ASG CSR and partner with NGOs to execute the project
Work with NGOs to identify projects of interest to ASG
To work on Project plan and goals to be achieved for each Project in coordination with the NGO and ensure the project cost is within approved outlay for the project
Monitor implementation of the Project
To prepare and periodically appraise CSR Council and CSR Committee on the status of each project including funds utilization
To prepare and obtain approval from CSR Council and CSR Committee for new projects outlays and cost over runs.
CSR Team to keep track of the time spent by ASG employees on each CSR initiative to ensure over all 1% people’s time objective is met

4.3.b. CSR Council:

CSR Council will comprise of 4 senior employees of ASG.

Council’s Role:

Review of project proposals submitted by the CSR team and recommend to the CSR Committee for approval/rejection.
To review the periodic progress of implementation of each project.,
To apprise and highlight deviations and abnormal cost over runs to the CSR Committee.
To review CSR objectives and policy from time to time and recommend changes if any to the CSR Committee for consideration.
a) The NGO is a registered Society I Public Charitable Trust / not for profit organization established under section 8 of the Act.
b) Submits audited accounts and tax returns for the past 3 years.
c) The NGO has a track record of handling similar work in the past for at least 3 years.
d) Testimonials of experience.

4.4. Executing Agency/ Partners

The employees will directly implement the CSR programmes or through implementing partners which include NGOs having experience in carrying out the specific activity. The main implementation partners of the Company will continuously work with the CSR council.

The following minimum criteria will be ensured while selecting NGO’s/ voluntary organizations for programme execution

The Company may also collaborate with other companies to undertake CSR projects or programmes, provided the CSR Committees of the respective companies are able to report separately on such projects or programmes.

For CSR activities undertaken through other Executing Agency, the Company will specify the projects or programmes to be undertaken through these agencies, the modalities of utilization of funds on such projects or programmes.

4.5. Policy Guidelines

All CSR Projects must be aligned as prescribed in Schedule VII of the Companies Act, 2013
CSR projects or programmes or activities must be undertaken in India alone.
CSR activities must not include the activities undertaken in pursuance of normal course of business of the Company
Projects or programmes or activities that benefit only the employees of the Company and their families shall not be considered as CSR.
CSR activities should be in project/ programme mode. One-off events such as marathons/ awards/ charitable contribution/ advertisements I sponsorship of TV programmes etc. will not qualify as part of CSR expenditure.
Contribution of any amount directly or indirectly to any political party shall not be considered as CSR.

4.6. Monitoring

The CSR Committee shall meet at least once in a year to monitor the implementation of the CSR activities and the performance of any organisations engaged to conduct these activities. The CSR Committee shall ensure that the updated version of the CSR Policy is always displayed on the company’s website.
The CSR Committee has the powers to:
a) Request the organisations (who have been engaged by the Company for the CSR activities) to provide a monitoring and implementation report from time to time, in such detail and in such form as the CSR Committee may consider appropriate and necessary; and
b) Delegate an official from the Company or the CSR Committee, to liaise with organisations and inspect/oversee / monitor the activities undertaken by organisations, and require such official to provide necessary information to the CSR Committee in a manner and at such intervals as the CSR Committee may deem appropriate and necessary.

4.7 Reporting Framework:

The CSR Committee will monitor progress on CSR projects and CSR spends, and provide a detailed report of all aspects of the CSR activities including the current status and the intended targets (along with reasonable estimates of timelines and costs), to the Board of directors of the Company every financial quarter. The Company will report CSR performance in its annual report as per the structure and format prescribed under the CSR Rules.



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