TABLE OF CONTENTS
I. Introduction………………………………………………………………………………..2
II. Objective of this Policy……………………………………………………………………2
III. Definitions………………………………………………………………………………….2
III (a) Act
III (b) Committee
IV. Philosophy, Approach and Direction……………………………………………………2
V. Guiding Principles for Selection, Implementation, and Monitoring of Activities……3
V (a) Selection of Projects
V (b) Implementation of Projects
V (c) Monitoring & Evaluation
VI. Governance Structure…………………………………………………………………….4
VI (a) Board of Directors
VI (b) CSR Committee
VII. Annual Action Plan (AAP)………………………………………………………………..4
VIII. Effective Dates and Amendments……………………………………………………….5
I. INTRODUCTION
In accordance with Section 135 of the Companies Act, 2013 and the Companies Corporate Social Responsibility (CSR) Rules, 2014, XDBS has formulated and adopted this CSR Policy. This policy has been duly approved by the Board of Directors of the company at its meeting held on 11th July, 2017.
This document outlines the company’s commitment to driving positive social impact through ethical, transparent, and sustainable practices that create long-term value for all stakeholders and society at large.
II. OBJECTIVE OF THIS POLICY
The objective of this XDBS CSR policy is to establish a clear framework that guides XDBS in conducting its business responsibly, ensuring its operations contribute meaningfully to the well-being of society and the sustainability of the environment.
III. DEFINITIONS
III (a) Act refers to the Companies Act, 2013 as amended from time to time.
III (b) Committee refers to the CSR committee constituted by the Board of Directors of the Company and referred to in section 135 of the Act.
IV. PHILOSOPHY, APPROACH & DIRECTION
At XDBS, we believe that business excellence is inseparable from social responsibility. Guided by the vision and philosophy of our founder, Kartik Anand who champions the principle of trusteeship in business, we have embedded a strong sense of responsibility into our core values and operations.
Our CSR approach focusses on creating meaningful change in areas that matter most:
- Promoting health and wellbeing
- Advancing quality education and empowering children
- Enabling gender equality and empowering women
- Supporting sustainable livelihoods and uplifting underserved communities at the grassroots level
Through this policy XDBS reaffirms its role as a responsible corporate citizen. We’re committed to adopting a holistic and inclusive approach in designing and implementing initiatives that contribute to the welfare, development, and sustainability of the communities in which we operate.
V. GUIDING PRINCIPLES FOR SELECTION, IMPLEMENTATION & MONITORING OF ACTIVITIES
Our CSR activities are driven by the following guiding principles:
V (a) SELECTION OF PROJECTS
- XDBS will prioritize projects with long-term impact that address critical social, economic and environmental challenges.
- Focus will be placed on underserved, underprivileged, and differently-abled sections of the society, especially in areas proximate to XDBS’ operations. We design and implement initiatives that integrate disadvantaged and vulnerable communities into our value chain, with a focus on individuals unable to afford essential medical treatments, procedures and palliative care.
- Initiatives will adhere to the principles of ethical conduct, human rights protection, and environmental care aligned with schedule VII of the Companies Act.
- Preference will be given to programs that are scalable, replicable, and sustainable.
V (b) IMPLEMENTATION OF PROJECTS
- CSR initiatives may be implemented:
– Through eligible implementing agencies as per Rule 4 of the CSR Rules.
- The CSR Committee shall formulate and recommend an Annual Action Plan (AAP) to the Board for approval, detailing projects, fund allocations, timelines, and monitoring mechanisms.
- Collaborative partnerships with NGOs, government bodies, and other institutions will be encouraged to leverage expertise and maximize impact.
V (c) MONITORING & EVALUATION
- Release of funds for projects will be milestone-based, subject to periodic reviews and approvals by the CSR Committee.
- Utilization Certificate: Funds released / to be released to the implementing agency would be generally based on satisfactory utilization certificate duly certified by an authorized officer / CEO / CFO of the donor entity and satisfactory performance report submitted by the said person, as may be decided by the CSR committee.
- The CSR Committee will monitor implementation progress while ensuring compliance with applicable laws and standards.
VI. GOVERNANCE STRUCTURE
VI (a) Board of Directors
The Board shall:
- Approve the CSR Policy and disclose it as per statutory requirements.
- Ensure compliance with the statutory requirement of spending at least 2% of the average net profits of the company during the preceding three financial years.
- Include appropriate disclosures in the Director’s Report.
VI (b) CSR Committee
The CSR Committee shall:
- Formulate and recommend the CSR Policy and Annual Action Plan to the Board.
- Recommend budget allocations and project approvals.
- Monitor implementation and review outcomes of CSR initiatives periodically.
VII. ANNUAL ACTION PLAN (AAP)
Each year, the CSR Committee shall recommend an Annual Action Plan to the Board, which shall include:
- Identified CSR projects / programs as per Schedule VII of the Act.
- Geographies and beneficiaries to be covered.
- Implementation modalities (direct or through partners).
- Budget allocations and fund utilization plan.
- Monitoring mechanisms and reporting schedules.
- Provisions for impact assessment (if applicable).
The AAP may be amended by the Board on the recommendation of the CSR Committee to address emerging needs and priorities.
VIII. EFFECTIVE DATE AND AMENDMENTS
The CSR Policy shall be effective from 11th July, 2017, and will be subject to periodic review by the CSR Committee and Board to ensure relevance and alignment with evolving societal needs and regulatory frameworks.
