1. Introduction and Objectives:

TSR Consultants Private Limited ("The Company") is Registrar and Transfer Agent. The Company is a part of the global Link Group based in Sydney, Australia.

The Company strongly believes that business growth & success, is intertwined with the development, growth and prosperity of the larger society in which it operates. The external social environment has to progress meaningfully, and therefore it is imperative for businesses to invest in the future by actively associating with social development & enabling activities. With this objective, the Board of Directors of the Company hereby adopts the Corporate Social Responsibility Policy.

2. Corporate Social Responsibility (CSR)Philosophy:

Our approach to CSR is to create and monitor sustainable programs that actively contribute to and support the socio-economic development of the communities in which we operate. The Company's CSR is beyond its own immediate business interests, and intended to make a positive difference to the environment in which we operate. At the Company, we are:

  • 1) Committed to promote the principle of inclusive growth and equitable development.
  • 2) Committed to respect the cultures and practices of each region of India, where we operate and actively engage with the larger society as a good corporate citizen.
  • 3) Committed to engage and work actively in areas of promoting education in general.
  • 4) Committed to human development through skill development& skill upgradation activities.
  • 5) Committed to the Swacch Bharat initiative of the Prime Minister and actively contribute to activities connected with this initiative.
  • 6) Committed to encourage fine arts, music, sports & yoga.

3. Focus Areas:

The Company will explore and actively participate in multiple initiatives either directly or through donations or contributions to the approved Non-Government Organizations or Non-Profit Organizations for focusing on the following broad areas of activities as mentioned in Schedule VII of the Act:

  • 1) Education - Especialy for the underprivileged sections & rural areas. To ensure access to quality education at affordable cost to deserving, meritorious and those students who are otherwise economically/ physically/ location challenged. The The Company would also engage actively with entities who are engaged in such similar activities.
  • 2) Cleanliness, sanitation & hygiene - Around the zones where our offices are located, to begin with, and later on replicate in other zones. This would involve taking initiative s in setting up local area management councils and continuous monitoring of the activities undertaken.
  • 3) Skill development- Especially in the IT-enabled service industry domain. This would mean active engagement with those entities/ programmes which are providing basic & enhanced skill sets to those sections of the society, who are otherwise deprived of such opportunities, and ensuring that the skill-enabled students who come out of such initiatives are set on fulfiling career paths.
  • 4) Medical Aid - Especially for critical illnesses or mass sponsored programmes like eye-care camps, awareness camps etc. either directly or through NGOs.
  • 5) Sports - In the areas of training, fitness, & sustained development. This would involve interacting with schools or sports associations, in identifying potential candidates, and funding them through a structured programme, for ensuring both their skill & physical development, till they arrive at a take-off stage or attain the age of 16 years.
  • 6) Indian traditional fine arts & music - Encouragement to young artists. To identify talented youngsters with potential to grow, by funding part of their expenses during their learning training period till they arrive at a take-off stage or attain the age of 16 years.

Besides the above-mentioned focus areas, the Company will also undertake any other CSR activities listed in Schedule VIll of the Companies Act, 2013 as amended from time to time.

4. Financial Resources:

In order to achieve the policy objectives, the Company will endeavor to determine in the first quarter of every financial year the funds to be expended till end of the next year, and will allocate for each focus activity a certain percentage of the funds available. The Company's Board, will then evaluate the proposals during the course of the year, and disperse the funds after due process of approval.

In the light of Companies (Corporate Social Responsibility Policy) Amendment Rules, 2021, unless the unspent amount relates to any ongoing project referred to in section 135(6) of the Act, the Company shall transfer such unspent amount to a Fund specified in Schedule VIl, within a period of 6 months of the expiry of the financial year.

5. Governance Structure:

The Board of the Company will be responsible for formulating and implementation of all the CSR projects or contributing to the approved funds as mentioned in Schedule VIl of the Act. The Board will be responsible for ensuring that all the funded activities are properly evaluated before fund release, and will also put in place a monitoring mechanism to track project progress.

The Board will also be empowered to add / co-opt members as and when required, who may either be employees of the Company or outside experts, who will help in coordinating the various activities and also help to monitor the same. The Board will also determine whether any non-budgeted fund release is warranted and if so, will ensure that it is ratified in the next Board meeting immediately following.

6. Monitoring and Reporting Mechanism:

The Chief Financial Officer ("CFO") of the Company or any senior personnel from the Financial Management Function shall ensure that the Board of Directors of the Company has been informed about the projects to be undertaken for the financial year and the funds so disbursed are utilized for the activities stated in the CSR Policy or that the contribution is duly made to the funds as approved in the Schedule VIl of the Act. In this regard, the CFO or any such senior personnel shall certify annually that funds so disbursed have been utilized for the purposes and in the manner as approved by the Board and such certification shall be annexed to the Board's Report for the respective Financial Year.