1. Introduction

https://www.worldoforo.com appreciates your business and trust. We are India India-based company, creating jewellery products.  Please read this Privacy Policy, providing consent to both documents in order to have permission to use our services.

2. Data Collected

Data Storage Location

We are an India-based Jewellery manufacturing company.  Our hosting provider Hetzner Online GmbH adheres to the EU/US “Privacy Shield”, ensuring that your data is securely stored and GDPR compliant. For more information on Hetzner Online GmbH privacy policy, please see here: Hetzner Data Privacy Policy

Registration Data

If you register on our website, we store your chosen username your email address and any additional personal information added to your user profile. You can see, edit, or delete your personal information at any time (except by changing your username). Website administrators can also see and edit this information.

Purchase Data

To receive product support, you have to have one or more Envato/AncoraThemes purchase codes on our website. These purchase codes will be stored together with support expiration dates and your user data. This is required for us to provide you with downloads, product support, and other customer services.

Support Data

If you have registered on our website and have a valid support account, you can submit support tickets for assistance. Support form submissions are sent to our third-party Ticksy ticketing system. Only the data you explicitly provided is sent, and you are asked for consent, each time you want to create a new support ticket. Ticksy adheres to the EU/US “Privacy Shield” and you can see their privacy policy here: Ticksy Privacy Policy.

Comments

When you leave comments on the website we collect the data shown in the comments form, and also the IP address and browser user agent string to help spam detection.

Contact Form

Information submitted through the contact form on our site is sent to our company email, hosted by Zoho. Zoho adheres to the EU/US “Privacy Shield” policy and you can find more information about this here: Zoho Privacy Policy.

These submissions are only kept for customer service purposes they are never used for marketing purposes or shared with third parties.

Google Analytics

We use Google Analytics on our site for anonymous reporting of site usage. So, no personalized data is stored. If you would like to opt-out of Google Analytics monitoring your behaviour on our website please use this link: Google Analytics Opt-out.

Cases for Using the Personal Data

We use your personal information in the following cases:

• VERIFICATION/IDENTIFICATION OF THE USER DURING WEBSITE USAGE;
• PROVIDING TECHNICAL ASSISTANCE;
• SENDING UPDATES TO OUR USERS WITH IMPORTANT INFORMATION TO INFORM ABOUT NEWS/CHANGES;
• CHECKING THE ACCOUNTS’ ACTIVITY IN ORDER TO PREVENT FRAUDULENT TRANSACTIONS AND ENSURE THE SECURITY
• OVER OUR CUSTOMERS’ PERSONAL INFORMATION;
• CUSTOMIZE THE WEBSITE TO MAKE YOUR EXPERIENCE MORE PERSONAL AND ENGAGING;
• GUARANTEE OVERALL PERFORMANCE AND ADMINISTRATIVE FUNCTIONS RUN SMOOTHLY.

3. Embedded Content

Pages on this site may include embedded content, like YouTube videos, for example. Embedded content from other websites behaves in the exact same way as if you visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Below you can find a list of the services we use:

Facebook

The Facebook page plugin is used to display our Facebook timeline on our site. Facebook has its own cookie and privacy policies over which we have no control. There is no installation of cookies from Facebook and your IP is not sent to a Facebook server until you consent to it. See their privacy policy here: Facebook Privacy Policy .

Twitter

We use the Twitter API to display our tweets timeline on our site. Twitter has its own cookie and privacy policies over which we have no control. Your IP is not sent to a Twitter server until you consent to it. See their privacy policy here: Twitter Privacy Policy .

Youtube

We use YouTube videos embedded on our site. YouTube has its own cookie and privacy policies over which we have no control. There is no installation of cookies from YouTube and your IP is not sent to a YouTube server until you consent to it. See their privacy policy here: YouTube Privacy Policy.

4. Cookies

This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. Cookies generally exist to make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser.

Necessary Cookies (all site visitors)

• CFDUID: IS USED FOR OUR CDN CLOUDFLARE TO IDENTIFY INDIVIDUAL CLIENTS BEHIND A SHARED IP ADDRESS AND APPLY SECURITY SETTINGS ON A PER-CLIENT BASIS. SEE MORE INFORMATION ON PRIVACY HERE: CLOUDFLARE PRIVACY POLICY.
• PHPSESSID: TO IDENTIFY YOUR UNIQUE SESSION ON THE WEBSITE.

Necessary Cookies (Additional for Logged in Customers)

• WP-AUTH: USED BY WORDPRESS TO AUTHENTICATE LOGGED-IN VISITORS, PASSWORD AUTHENTICATION AND USER VERIFICATION.
• WORDPRESS_LOGGED_IN_{HASH}: USED BY WORDPRESS TO AUTHENTICATE LOGGED-IN VISITORS, PASSWORD AUTHENTICATION AND USER VERIFICATION.
• WORDPRESS_TEST_COOKIE USED BY WORDPRESS TO ENSURE COOKIES ARE WORKING CORRECTLY.
• WP-SETTINGS-[UID]: WORDPRESS SETS A FEW WP-SETTINGS-[UID] COOKIES. THE NUMBER ON THE END IS YOUR INDIVIDUAL USER ID FROM THE USERS DATABASE TABLE. THIS IS USED TO CUSTOMIZE YOUR VIEW OF ADMIN INTERFACE, AND POSSIBLY ALSO THE MAIN SITE INTERFACE.
• WP-SETTINGS-[UID]:WORDPRESS ALSO SETS A FEW WP-SETTINGS-{TIME}-[UID] COOKIES. THE NUMBER ON THE END IS YOUR INDIVIDUAL USER ID FROM THE USERS DATABASE TABLE. THIS IS USED TO CUSTOMIZE YOUR VIEW OF ADMIN INTERFACE, AND POSSIBLY ALSO THE MAIN SITE INTERFACE.

5. Who Has Access To Your Data

If you are not a registered client for our site, there is no personal information we can retain or view regarding yourself. If you are a client with a registered account, your personal information can be accessed by:

• OUR SYSTEM ADMINISTRATORS.
• OUR SUPPORTERS WHEN THEY (IN ORDER TO PROVIDE SUPPORT) NEED TO GET THE INFORMATION ABOUT THE CLIENT ACCOUNTS AND ACCESS.

6. Third Party Access to Your Data

We don’t share your data with third-parties in a way as to reveal any of your personal information like email, name, etc. The only exceptions to that rule are for partners we have to share limited data with in order to provide the services you expect from us. Please see below:

Envato Pty Ltd

For the purpose of validating and getting your purchase information regarding licenses for the theme, we send your provided tokens and purchase keys to Envato Pty Ltd and use the response from their API to register your validated support data. See the Envato privacy policy here: Envato Privacy Policy.

Ticksy

Ticksy provides the support ticketing platform we use to handle support requests. The data they receive is limited to the data you explicitly provide and consent to being set when you create a support ticket. Ticksy adheres to the EU/US “Privacy Shield” and you can see their privacy policy here: Ticksy Privacy Policy.

7. How Long We Retain Your Data For

When you submit a support ticket or a comment, its metadata is retained until (if) you tell us to remove it. We use this data so that we can recognize you and approve your comments automatically instead of holding them for moderation. If you register on our website, we also store the personal information you provide in your user profile. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit that information.

8. Security Measures

We use the SSL/HTTPS protocol throughout our site. This encrypts our user communications with the servers so that personally identifiable information is not captured/hijacked by third parties without authorization. In case of a data breach, system administrators will immediately take all needed steps to ensure system integrity, will contact affected users and will attempt to reset passwords if needed.

9. Your Data Rights

General Rights

If you have a registered account on this website or have left comments, you can request an exported file of the personal data we retain, including any additional data you have provided to us. You can also request that we erase any of the personal data we have stored. This does not include any data we are obliged to keep for administrative, legal, or security purposes. In short, we cannot erase data that is vital to you being an active customer (i.e. basic account information like an email address). If you wish that all of your data is erased, we will no longer be able to offer any support or other product-related services to you.

GDPR Rights

Your privacy is critically important to us. Going forward with the GDPR we aim to support the GDPR standard. AncoraThemes permits residents of the European Union to use its Service. Therefore, it is the intent of AncoraThemes to comply with the European General Data Protection Regulation. For more details please see here: EU GDPR Information Portal.

10. Third Party Websites

AxiomThemes may post links to third party websites on this website. These third party websites are not screened for privacy or security compliance by AxiomThemes, and you release us from any liability for the conduct of these third party websites.
All social media sharing links, either displayed as text links or social media icons do not connect you to any of the associated third parties unless you explicitly click on them.

Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties or require disclosure of any personal information relating to members of the Service or Site. AxiomThemes bears no responsibility for the information collected or used by any advertiser or third party website. Please review the privacy policy and terms of service for each site you visit through third party links.

11. Release of Your Data for Legal Purposes

At times it may become necessary or desirable to AncoraThemes, for legal purposes, to release your information in response to a request from a government agency or a private litigant. You agree that we may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of a civil action, criminal investigation, or other legal matter. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you, and release your information to, third parties where we believe that it is prudent to do so for legal reasons, such as our belief that you have engaged in fraudulent activities. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants. Any passing on of personal data for legal purposes will only be done in compliance with laws of the country you reside in.

ORO Precious Metals Private Limited

PREFACE:

Section 177 of the Companies Act, 2013 requires every Listed Company and such class or classes of Companies, as may be prescribed to establish a Vigil Mechanism for the directors and employees to report genuine concerns in such manner as may be prescribed. The Company has adopted a Code of Conduct for Directors and Senior Management Executives (“the Code”), which lays down the principles and standards that should govern the Company’s and its employee’s actions. Any actual or potential violation of the Code, however insignificant or perceived as such, would be a matter of serious concern to the Company. Such a Vigil Mechanism shall provide for adequate safeguards against the victimization of persons who use such a mechanism.

Here, our Company proposes to establish a Vigil Mechanism and formulate a policy for the same.

POLICY OBJECTIVES:

The Company is committed to adhering to the highest standards of ethical, moral and legal conduct of business operations. To maintain these standards, the Company encourages its employees who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment. A Vigil Mechanism provides a channel for the employees and Directors to report to the management concerns about unethical behaviour, actual or suspected fraud or violation of codes of conduct or policy. The mechanism provides adequate safeguards against the victimization of employees and Directors to avail of the mechanism.

This neither releases employees from their duty of confidentiality in the course of their work nor can it be used as a route for raising malicious or unfounded allegations against people in authority and/ or colleagues in general.

SCOPE OF THE POLICY:

The Policy covers malpractices and events which have taken place/are suspected to have taken place, misuse or abuse of authority, fraud or suspected fraud, violation of Company rules, manipulation, negligence causing danger to public health and safety, misappropriation of monies, and other matters or activity on account of which the interest of the Company is affected.

DEFINITIONS:

“Alleged wrongful conduct” shall mean violation of law, Infringement of Company’s rules, misappropriation of monies, actual or suspected fraud, substantial and specific danger to public health safety or abuse of authority.

“Board” means the Board of Directors of the Company.

“Company” means ORO Precious Metals Private Limited and all its offices.

“Code” means Code of Conduct for Directors and Senior Management Executives adopted by ORO Precious Metals Private Limited.

“Employee” means all the present employees and Directors of the Company.

“Protected Disclosure” means a concern raised by an employee or group of employees of the Company, through a written communication and made in good faith which discloses or demonstrates information about an unethical or improper activity under the title “SCOPE OF THE POLICY” with respect to the Company. It should be factual and not speculative or in an interpretation/ conclusion and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern.

“Subject” means a person or group of persons against or in relation to whom a Protected Disclosure is made or evidence gathered while an investigation.

“Vigilance and Ethics Officer” means as per Companies Act 2013 a director appointed by the Board of Directors to play the role of Audit committee for the purpose of vigil mechanism to whom other directors and employees may report their concerns.

“Whistle Blower” is an employee or group of employees who make a Protected Disclosure under this Policy and are referred to in this policy as a complainant.

ELIGIBILITY:

All Employees of the Company are eligible to make Protected Disclosures under the Policy in relation to matters concerning the Company.

RECEIPT AND DISPOSAL OF PROTECTED DISCLOSURES:

All Protected Disclosures should be reported in writing by the complainant as soon as possible after the Whistle Blower becomes aware of the same to ensure a clear understanding of the issues raised and should be in the prescribed format.

The Protected Disclosure should be submitted in a closed and secured envelope and should be super-scribed as “Protected Disclosure under the Vigil Mechanism Policy”. If the complaint is not superscribed and closed as mentioned above, it will not be possible for the Vigilance and Ethics Officer to protect the complainant and the protected disclosure will be dealt with as if a normal disclosure. To protect the identity of the complainant, the Vigilance and Ethics Officer will not issue any acknowledgement to the complainant, and they are advised neither to write their name/ address on the envelope. The Vigilance and Ethics Officer shall assure that if any further clarification is required, he will contact the complainant.

All Protected Disclosures should be addressed to the Vigilance and Ethics Officer of the Company.

Vigilance and Ethics Officer

Name: Mr. Avinash Mohan Pahuja   Email: avinash@oro.in.   Address: Turbhe, C-67,T.T.C, Thane – Belapur Rd, MIDC Industrial Area, Turbhe, Navi Mumbai, Maharashtra 400705.

On receipt of the protected disclosure the Vigilance and Ethics Officer shall make a record of the Protected Disclosure and ascertain from the complainant whether he was the person who made the protected disclosure or not. He shall also carry out the initial investigation either himself or by involving any other Officer of the Company or an outside agency before referring the matter to Board of the Company for further appropriate investigation and needful action. The record will include:

• BRIEF FACTS;
• WHETHER THE SAME PROTECTED DISCLOSURE WAS RAISED PREVIOUSLY BY ANYONE, AND IF

so, the outcome thereof;

• WHETHER THE SAME PROTECTED DISCLOSURE WAS RAISED PREVIOUSLY ON THE SAME SUBJECT.
• DETAILS OF ACTIONS TAKEN BY THE VIGILANCE AND ETHICS OFFICER FOR PROCESSING THE COMPLAINT
• FINDINGS OF THE VIGILANCE AND ETHICS OFFICER
• THE RECOMMENDATIONS OF THE VIGILANCE AND ETHICS OFFICER OR OTHER ACTION(S). 

• INVESTIGATION:

1. All Protected Disclosures under this Policy will be recorded and thoroughly investigated. The Vigilance and Ethics Officer may investigate and may at its discretion consider involving any other Officer of the Company and/ or an outside agency for the purpose of investigation
2. The decision to investigate is by itself not an accusation and is to be treated as a neutral fact-finding process.
3. Subject(s) will normally be informed in writing of the allegations at the outset of a formal investigation and have opportunities for providing their inputs during the investigation.
4. Subject(s) shall have a duty to cooperate with the Officer appointed by it in this regard.
5. Subject(s) have a right to consult with a person or persons of their choice, other than the Vigilance and Ethics Officer
6. Subject(s) have a responsibility not to interfere with the investigation. Evidence shall not be withheld, destroyed or tampered with and witness shall not be influenced, coached, threatened or intimidated by the subject(s).

VII. Unless there are compelling reasons not to do so, subject(s) will be given the opportunity to respond to material findings contained in the investigation report. No allegation of wrong doing against a subject(s) shall be considered as maintainable unless there is good evidence in support of the allegation.

VIII. Subject(s) have a right to be informed of the outcome of the investigations. If allegations are not sustained, the Subject should be consulted as to whether public disclosure of the investigation results would be in the best interest of the Subject and the Company.

1. The investigation shall be completed normally within 90 days of the receipt of the protected disclosure and is extendable by such period as the Vigilance and Ethics Officer deems fit.

DECISION AND REPORTING:

1. If an investigation leads the Vigilance and Ethics Officer to conclude that an improper or unethical act has been committed, the Vigilance and Ethics Officer shall recommend to the management of the Company to take such disciplinary or corrective action as he may deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures.
2. The Vigilance and Ethics Officer shall prepare a report and inform the Board on a regular basis about all Protected Disclosures referred to him/her since the last report together with the results of investigations, if any.
3. The Vigilance and Ethics Officer shall appropriately and expeditiously investigate the Protected Disclosure.
4. If the report of the investigation is not to the satisfaction of the complainant, the complainant has the right to report the event to the appropriate legal or investigating agency.
5. A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the subject to the Vigilance and Ethics Officer shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.

PROTECTION:

1. No unfair treatment will be meted out to a Whistle Blower by virtue of his/ her having reported a Protected Disclosure under this policy. The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistle Blowers. Complete protection will, therefore, be given to Whistle Blowers against any unfair practice like retaliation, threat or intimidation of termination/ suspension of service, disciplinary action, transfer, demotion, refusal of promotion or the like including any direct or indirect use of authority to obstruct the Whistle Blower’s right to continue to perform his duties/ functions including making further Protected Disclosure. The Company will take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. Thus, if the Whistle Blower is required to give evidence in criminal or disciplinary proceedings, the Company will arrange for the Whistle Blower to receive advice about the procedure, etc.
2. A Whistle Blower may report any violation of the above clause to the Vigilance and Ethics Officer, who shall investigate the same and recommend suitable action to the management.
3. The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. The identity of the complainant will not be revealed unless he himself has made either his details public or disclosed his identity to any other office or authority. In the event of the identity of the complainant being disclosed, the Vigilance and Ethics Officer is authorized to initiate appropriate action as per extant regulations against the person or agency making such disclosure. The identity of the Whistle Blower, if known, shall remain confidential to those persons directly involved in applying this policy, unless the issue requires investigation by law enforcement agencies, in which case members of the organization are subject to subpoena.
4. Provided however that the complainant before making a complaint has reasonable belief that an issue exists and he has acted in good faith. Any complaint not made in good faith as assessed as such by the Audit Committee shall be viewed seriously and the complainant shall be subject to disciplinary action as per the Rules/ certified standing orders of the Company. This policy does not protect an employee from an adverse action taken independent of his disclosure of unethical and improper practice etc. unrelated to a disclosure made pursuant to this policy.

RETENTION OF DOCUMENTS:

All Protected disclosures in writing or documented along with the results of Investigation relating thereto, shall be retained by the Company for a period of 5 (five) years or such other period as specified by any other law in force, whichever is more.

ADMINISTRATION AND REVIEW OF THE POLICY:

The Vigilance and Ethics Officer shall be responsible for the administration, interpretation, application, and review of this policy. The Vigilance and Ethics Officer shall be empowered to bring about necessary changes to this Policy if required at any stage.

AMENDMENT:

The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification will be binding on the Employees and Directors unless the same is notified to them in writing.

INTRODUCTION

ORO Precious Metals Private Limited (Formerly known as Raia Jewels Private Limited) (“the Company”) introduced a brand, ORO that has established itself as a trustworthy and innovative gold product manufacturer in the jewellery sector of India and abroad. The Company has expertise as jewellery manufacturers comes from a heritage of over 125 years and believes in, constantly innovating products and styles to match its expertise with constantly evolving technology.

Through our efficient manufacturing systems and quality craftsmanship, the company’s focus has always been to constantly innovate its product such that it is in sync with customer expectations and looks to surpass its vision of design and quality.

CSR IN INDIA

Corporate bodies’ involvement in CSR activities is not a new concept in India. Industrial majors have been engaged in social development activities for long back. However, Section 135 of the Companies Act, 2013 has brought it under the legal purview. The concept of CSR is introduced through the “Comply-or-Explain” mandate. It mandates qualifying companies to constitute a Corporate Social Responsibility Committee to effectively monitor CSR activities of the Company. Further, the Companies (Corporate Social Responsibility Policy) Rules, 2014 lay down the framework and modalities for carrying out CSR activities which are specified in Schedule VII of the Act. 

The management of the Company expresses its willingness and support for the CSR concept, and its legal framework and shall abided to it. The CSR Committee of the Board had drafted a CSR Policy which was approved by the Board of Directors.

SCOPE AND COVERAGE OF CSR POLICY

The policy for Corporate Social Responsibility is designed and governed with a clear focus on promoting and preventing health, promoting education in India, including giving special attention towards children, women, the elderly, and the differently abled etc. As part of its dedicated approach to creating economic opportunity in the communities in which it operates, the Company has been contributing its time, expertise and resources to help communities and undertaking a series of initiatives that are locally relevant.

The CSR activities of the Company shall include, but not be limited to any or all of the sectors/activities as may be prescribed by Schedule VII of the Companies Act, 2013 and Companies (Corporate Social Responsibility Policy) Rules, 2014 (“Rules”). Unless the context otherwise requires, the definitions mentioned in the notification dated February 27, 2014, and the Companies Act, 2013 shall apply to this CSR Policy.

CONSTITUTION OF CORPORATE SOCIAL RESPONSIBILITY COMMITTEE:

Pursuant to Section 135 of the Companies Act 2013, The Company, in cases, where the amount required to be spent by a company on CSR does not exceed INR 50 Lakh, the requirement for constitution of the CSR Committee is not mandatory. The functions of the CSR Committee, in such cases, can be discharged by the Board of Directors of the company.

Hence our Company has not constituted a CSR committee and all the responsibilities related to CSR are taken care of by the Board of Directors –

1. Mr. Ravish Pahuja
2. Mr. Avinash Mohan Pahuja

The Board shall decide the CSR programs and initiatives for each financial year and accordingly as per the agenda. The CSR agenda for the financial year shall indicate the activities to be undertaken for the financial year and the expenditure to be incurred on the CSR programs and initiatives.

The Board of Directors of the Company may re-constitute the Committee, as and when required to do so, by following the sections, sub-sections, rules, regulations, and notifications issued or to be issued, from time to time, by the Ministry of Corporate Affairs or the Central Government of India. The Board shall exercise powers and perform the functions assigned to it by the Act.

CSR ACTIVITIES:

Pursuant to Schedule VII of the Companies Act, 2013, the Committee has approved the following activities as “CSR Activities” to be undertaken under the CSR policy of the Company. The Board of Directors of the Company has reviewed the said activities and expressed its consent to the Committee to pursue the said activities under the CSR policy of the Company as per the Act.

Further, the Company will review the sectors/activities from time to time and make additions/ deletions/ clarifications to the above sectors/activities.

ACTIVITIES TO BE UNDERTAKEN:

The Committee can undertake one or more of the following activities, which relate to Schedule VII of the Companies Act, 2014 as its projects for CSR activity viz.,

1. Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation including contribution to the Swachh Bharat Kosh set up by the Central Government for the promotion of sanitation and making available safe drinking water;
2. Promotion of education, including special education and employment enhancing vocation skills, especially among children, women, elderly, and the differently abled and livelihood enhancement projects;
3. Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, daycare centres and other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
4. ensuring environment sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water including contribution to the Clean Ganga Fund set up by the Central Government for rejuvenation of river Ganga;
5. protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional arts and handicrafts;
6. measures for the benefit of armed forces veterans, war widows and their dependents;
7. training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic sports;
8. Contribution to the Prime Minister’s National Relief Fund or any other fund set up by the Central Government for Socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women;
9. contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government;
10. rural development projects.
11. Slum area development

The Committee intends to carry out its CSR activities through its own personnel/ department established with persons qualified to undertake such activities.

LOCATION OF CSR EFFORTS

The CSR committee will decide on the locations for CSR activities.

BUDGET FOR CSR ACTIVITIES AND & CSR EXPENSES:

The Company shall allocate the budget for CSR Activities. The minimum budgeted amount for a financial year shall be 2% of average net profit of three immediately preceding financial years. The Company may allocate more fund/amount than the amount prescribed under section 135 of the Companies Act, 2013 for CSR Activities of any financial year. The Committee shall calculate the total fund for the CSR activities and recommend to the Board for approval. The Board shall approve the total fund to be utilized for CSR activity for the respective financial year.

CSR expenditure shall include all expenditure including contribution to corpus for projects or programs relating to CSR activities approved by the Board on the recommendation of its CSR Committee, but does not include any expenditure on an item not in conformity or not in line with activities which fall within the approved CSR activities.

IDENTIFICATION OF ACTIVITIES/PROJECTS:

Out of the approved CSR activities, the Committee shall decide which activity/project should be given priority for the respective financial year. While arriving at the decision of the activity to be undertaken for the respective year, the Committee shall analyse the basic need of the community/ area in which the Organisation operates or at the place where its registered office is situated. The Committee shall record its findings and prioritise the CSR activities.

IMPLEMENTATION PROCESS:

After prioritizing the activity the Committee shall finalise the detail implementation project/programme, including planning for expenses against the total budget allocated for CSR activities.

ORGANISATIONAL RESPONSIBILITY:

At the organisational level for the implementation of the agreed CSR activity, the committee may constitute an implementation team or authorise any of the Department of the Company to organize the implementation of the CSR activity. The team or respective department shall monitor the implementation process from time to time, on behalf of the CSR committee and place a report to the Committee regarding the progress of the activity implementation, on a quarterly basis. The respective department or implementation team would be responsible for reporting of any irregularity to the Committee on an immediate basis.

MONITORING BY THE BOARD:

The Board of Directors shall constantly monitor the implementation of the CSR activities. The CSR committee shall place a progress report, including details of expenses, before the Board on a quarterly basis. The Board shall review the same and suggest recommendations, if any, to the committee with regard to the implementation process.

COMPLIANCE AND REPORTING TO THE BOARD:

The Committee is responsible for undertaking CSR activities as per the approved CSR Policy. Apart from quarterly reports to the Board about the implementation of CSR activity, a detailed report containing the implementation schedule, total budget allocated, actual expenses incurred, surplus arising, if any, result achieved, further work to do in the concerned CSR activity, Recommendation for the CSR activities for next year etc. should be placed before the Board for its consideration. Any surplus arising out of the fund allocated for CSR activity shall not be part of the business profit of the Company.

MANAGEMENT COMMITMENT:

Our Board of Directors, our Management and all our employees support to the philosophy of compassion, characterised by a willingness to build a society that works for everyone. This is the cornerstone of our CSR policy.

Our Corporate Social Responsibility policy conforms to the relevant section of the Corporate Social Responsibility, Rules made under Companies Act, 2013 and amendment(s) to be made thereto in future.

AMENDMENT

The Committee or the Board reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification shall be inconsistent with the applicable provisions of the Act or any law for the time being in force