CSR

1. Preamble and Legal Framework

Sripathi Paper and Boards Private Limited (“the Company”) believes that its long-term success is linked not only to its financial performance but also to the well-being of the communities and environment in which it operates. The Company is committed to conducting its business in a socially responsible manner and to contributing meaningfully towards inclusive growth and sustainable development.

This Corporate Social Responsibility Policy (“Policy”) has been formulated in accordance with Section 135 of the Companies Act, 2013 (“the Act”) read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended from time to time (“CSR Rules”), and Schedule VII of the Act.

2. Objective

The objectives of this Policy are to:

Lay down the guiding principles for undertaking CSR projects/programmes by the Company.
Ensure adherence to the applicable provisions of the Act and the CSR Rules.
Provide a framework for identification, implementation, monitoring, and reporting of CSR activities and formulation of Annual Action Plan.
Ensure transparent and effective utilisation of funds earmarked for CSR.
Contribute towards the socio-economic development of communities.

3. Applicability

This Policy applies to all CSR projects, programmes, and activities undertaken by the Company, whether directly or through implementing agencies, and covers planning, budgeting, execution, monitoring, and reporting of such initiatives.

4. CSR Committee

4.1 Applicability of CSR Committee

In terms of Section 135(1) of the Act, the Company shall constitute a CSR Committee of the Board consisting of three or more Directors, including at least one Independent Director (or, where the Company is not required to appoint an Independent Director, without such requirement, as applicable to its class), where the amount required to be spent by the Company on CSR pursuant to Section 135(5) of the Act exceeds ₹50 lakh in a financial year. The CSR Committee, where constituted, shall discharge the functions set out in this Policy, and the Board shall thereafter approve such recommendations.

4.2 Non-Applicability of CSR Committee

Where the amount required to be spent on CSR does not exceed ₹50 lakh in a financial year, the requirement to constitute a CSR Committee shall not apply. In such cases, the Board of Directors shall discharge all the functions of the CSR Committee.

4.3 Functions

The CSR Committee (or Board) shall:

Formulate and recommend this Policy.
Recommend the CSR Budget and Annual Action Plan.
Approve implementing agencies.
Monitor the Policy.
Institute a transparent monitoring mechanism.
Ensure CSR activities fall under Schedule VII.
Recommend the Annual CSR Report.
Ensure administrative overheads remain within prescribed limits.
Ensure transfer of unspent CSR amounts within statutory timelines.

5. CSR Budget

The Company shall endeavour to spend at least 2% of the average net profits made during the three immediately preceding financial years (or such other percentage/period prescribed under Section 135(5) of the Act). The Board shall approve the CSR Budget annually.

6. Annual Action Plan

The Annual Action Plan shall include:

Approved CSR projects/programmes.
Mode of execution.
Utilisation of funds.
Implementation schedule.
Monitoring and reporting mechanism.
Need assessment and impact assessment, where applicable.
The Board may modify the Annual Action Plan during the year with proper justification.

7. CSR Activities

CSR activities may include:

Eradicating hunger, poverty and malnutrition.
Healthcare and sanitation.
Education and vocational skill development.
Gender equality and women empowerment.
Environmental sustainability.
Protection of heritage, art and culture.
Welfare of armed forces veterans.
Promotion of sports.
Contributions to relief funds.
Technology incubators.
Rural development.
Disaster management and rehabilitation.

8. Modes of Implementation

CSR activities may be undertaken:

Directly by the Company.
Through eligible Section 8 Companies, Trusts or Societies.
In collaboration with other companies.
The Company shall conduct due diligence before selecting implementing agencies.

9. Monitoring and Reporting

The Board shall:

Monitor ongoing CSR projects.
Obtain utilisation certificates where necessary.
Conduct impact assessments where required.
Prepare the Annual CSR Report.
Disclose CSR spending and unspent amounts.

10. Unspent CSR Amount

Unspent amounts not related to ongoing projects shall be transferred to a Schedule VII Fund within six months.

Unspent amounts related to ongoing projects shall be transferred to the Unspent CSR Account within 30 days and utilised within three financial years.

11. Surplus from CSR Activities

Any surplus arising from CSR activities shall not form part of the Company’s business profits and shall be utilised in accordance with the CSR Rules.

12. Disclosure

This Policy and details of CSR projects shall be disclosed on the Company’s website, if any.

13. Amendment

The Board may review and amend this Policy from time to time to ensure compliance with the Companies Act, CSR Rules and other applicable laws.

CSR

How we operate CSR in Sripathi

Sripathi Core CSR Focus Areas

Arising from the focus areas that have emerged are us follow:

Education
Health care
Sustainable Livelihood
Infrastructure Development
Espousing Social Causes

CSR Budget Allocation Policy

The Company will allocate a sum not less than 2% of the average net profits of the immediately preceding three financial years toward Corporate Social Responsibility (CSR) activities.

If, in any financial year, the Company is unable to spend the required CSR amount, for any reason,
The Company shall provide a suitable explanation stating the reasons for such shortfall to the Board of Directors.
The Board shall include the explanation in the Directors’ Report of the Company.

CSR Implementation Approach in Education

Being in the field of providing end-to-end human resource solutions, the Company aspired to support the education sector through its CSR initiatives by identifying suitable educational institutions. However, implementation was deferred due to foundational policy and framework development requirements.

Significant time and effort were invested in formulating a comprehensive and impactful CSR Policy.
Establishment of monitoring and evaluation mechanisms.
Identification of credible partners with innovative project proposals.
Evaluation of proposals for scalability and alignment with CSR policy objectives.

CSR Governance and Responsibility Statement

The Board is of the view that the foundational setup undertaken during the year — including the formulation of the CSR Policy, framework, processes, and internal controls — will enable the Company to scale its CSR initiatives effectively in the future and reinforce its commitment to meaningful CSR activities.

The initial setup included establishment of a structured CSR Policy.
The Board believes this foundation will support the expansion and scalability of CSR activities in the coming years.
Development of a comprehensive CSR framework.
The implementation and monitoring of the Corporate Social Responsibility (CSR) Policy is in compliance with the CSR objectives and policy of the Company.

CSR Committee

Members of the Committee

Mr. Venkataramanan Ramaswamy

Nominee Board Member