Corporate Social Responsibility Policy

Background

In compliance with the requirements of Section 135 of the Companies Act, 2013 read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended, the Company is, inter alia, required to:

  • Authorize Board of Directors to formulate a Corporate Social Responsibility (CSR) Policy, recommend the amount of CSR expenditure and monitor the CSR activities of the Company from time to time.

  • Ensure that the Company spends, in every financial year, at least two per cent of the average Net Profits (computed as per Section 198 of the Companies Act, 2013) of the Company, made during the three immediately preceding financial years, in pursuance of its CSR Policy.

Philosophy

Corporate Social Responsibility (CSR) is a public spirited cause that has been well introduced by the new Companies Act 2013. Through the CSR there is a formation of a dynamic relationship between a company on one hand and the society and environment on the other. CSR is traditionally driven by a moral obligation and philanthropic spirit which resonates with the policy of the Company, i.e. Bonushub Digital Solutions Private Limited.

Focus Areas

The main responsibilities of the Company towards society at large are to educate people, eradicate hunger, poverty and malnutrition, and promote health care and preventive health care and sanitation.

Our Vision

  • The Company completely endorses reliability. It is committed to conduct business in a true, fair and ethical manner and takes up the responsibility to create a good impact in the society it belongs.

  • The Company is committed towards improving the quality of lives of people in the communities in which it operates because, the society is an essential stakeholder and the purpose of its existence. The Company believes that giving back to the society through CSR activities is its moral duty.

  • The Company aims to fulfil the requirements laid down under the Companies Act, 2013 and act diligently to comply with all its Rules and Regulations on CSR.

Applicability of the policy

  • The Company’s CSR Policy has been developed in conformity with the provisions of Section 135 of the Companies Act, 2013 (referred to as the Act in this Policy) and in accordance with the CSR Rules (hereby referred to as the Rules) notified by the Ministry of Corporate Affairs, Government of India.

  • This Policy shall apply to all CSR initiatives and activities taken up at New Delhi and/or Noida (Uttar Pradesh), where Bonushub Digital Solutions Private Limited, carries out its business operations and for the benefits of different segments of the society, specifically the deprived and under‐ privileged.

Objectives of the CSR Policy

  • To ensure that the Company is committed to operate its business in an economically, socially and environmentally sustainable manner, while recognizing the interests of all its stakeholders.

  • To take up programs that benefit the communities in and around its work centers and over a period of time, results in enhancing the quality of life of the people in the area of its business operations.

  • To generate a community goodwill for the Company and help reinforce a positive and socially responsible image of Company as a good corporate citizen of the Country.

Responsibility of the board

The Board shall:

  • Approve the CSR Policy after taking into account the recommendations made by the Board Members.

  • Place the CSR Policy on the Company’s website.

  • Ensure implementation of the activities under CSR.

  • Ensure expenditure of requisite amount on CSR every year as per law.

  • Disclose reasons for not spending the amount (if applicable) in the Annual Report to the Shareholders of the Company.

  • Ensure that the administrative overheads are not more than 5% of the total CSR Expenditure.

  • Ensure that the funds so disbursed have been utilized for the purposes and in the manner as approved by Board.

  • Approve transfer of unspent CSR Amount in accordance with the law. The Accounts and Finance Team of the Company shall prepare the statement of spent and unspent CSR amounts and shall assist and facilitate for transfer of the same.

CSR Project

The Company would focus the CSR activities around following thrust areas:

  • Educating people.

  • Promoting health care and preventive health care and sanitation.

  • Eradicating hunger, poverty and malnutrition.

  • Any other program, which the Board shall deem fit.

Healthcare Centre CSR Contribution Guidelines

A key area of our CSR focus is the improvement of healthcare infrastructure. We will provide financial contributions to healthcare centers to help them enhance their capacity to serve the community.

Important Condition: The funds provided to healthcare centers under this CSR initiative will strictly be used for the purchase of medical equipment or hospital machinery only. The healthcare centers receiving these contributions will not be allowed to use these funds for day-to-day operational expenses, staff salaries, or other non-capital costs. The purpose of the funding is to improve medical facilities and services directly, ensuring that these resources go towards enhancing patient care through advanced equipment and technology.

Implementation, identification and selection of programmes

The programs would be identified as per the requirement in the community/schools, etc. Professional agencies may be engaged in conducting need based assessment in some programs, wherever required.

Partnership to implement the programmes

Collaborative Partnerships may be formed with the Government Agencies, the village Panchayats, NGOs and other like-minded stakeholders. This would help widen the Company's reach and leverage upon the collective expertise, wisdom and experience that these partnerships bring to the table.

Criteria for identifying executing partners/CSR implementing agency

In case of programme execution by NGOs/Voluntary organizations the following minimum criteria should be required to be ensured:

  • The NGO / Agency must have a permanent office / address in India.

  • The NGO should be a registered public Trust or a Society having a duly executed Trust Deed / Memorandum of Association.

  • It should have registration Certificates under Section 12A, Section 80G, etc. of the Income Tax Act, 1961, and other applicable registrations.

  • It should have a Permanent Account Number (PAN).

  • Last 3 years audited statement of accounts.

  • Last 3 years income tax return.

  • Should have a team of professional expertise and system to maintain Books of Accounts and to generate necessary Reports on the supported programmes.

Agreement between BonusHub Digital Solution Private Limited and CSR implementing agency

Once the programs and the CSR implementing agency has been finalized, the concerned work centers would be required to enter into an agreement/MOU with each of the implementing agency as per the Standard Agreement format.

Monitoring and evaluation mechanism

Monitoring and Evaluation Mechanisms include the following, one or more of which shall be implemented based on the size, quantum and tenure of the CSR programs:

  • To ensure effective implementation of the CSR programs undertaken at each work center, a monitoring mechanism will be put in place by the Board of Directors. The progress of CSR programs under implementation at work center will be reported to Noida Office of the Company.

  • Feedback would also be obtained and documented from the beneficiaries and influential local leaders by the respective work centers about the programs, as and when required.

  • Field visits would be conducted by the respective CSR teams to ensure the progress of the programs at their work centers. The visits would be informed and surprised also.

  • Partners would be required to report narrative as well as financial updates on an annual basis in the format mutually decided.

  • The Finance and Accounts Team of the Company in consultation with the Board of Directors would conduct audit of the CSR programs as and when required. The Finance and Accounts team would, from time to time, also guide the respective partners and CSR team of the Company on necessary compliances.