1. INTRODUCTION OF THE COMPANY

Sarita Handa Exports Private Limited (SHEPL) is incorporated on 22nd January 1993 with its Registered Office at D-11, Ground Floor, Defence Colony, New Delhi-110024 and Corporate Office is at Plot No.29, Sector-4, IMT Manesar, Gurugram, Haryana. SHEPL is a renowned name in luxury home decor. The Company specializes in products that involve intricate workmanship and artisanal techniques as well as products that require sophisticated state-of-the-art machinery. The brand is known for its unique blend of traditional Indian craftmanship and contemporary international design. The Company is engaged in the business of design, manufacture and export of home furnishing products. The product range includes, among others, quilts, duvet covers, comforters, cushion covers, table clothes, drapes, runners etc.

2. CSR VISION

At Sarita Handa Exports, our corporate social responsibility (CSR) is deeply rooted in the principles of sustainability, inclusivity and community empowerment. We are committed to creating a positive social impact by promoting access to education for underprivileged children and supporting community initiatives for upliftment of lives. Our CSR initiatives reflect our belief that success is not only measured by business growth but also by the positive difference we make in society and environment. As a responsible manufacturer, our vision is to align our growth with the development of people, the community, and the environment. Over the years, we have been consciously developing our Corporate Social Responsibility (CSR) initiatives that contribute to the sustainable development of society and the environment. It is not just business but business with a purpose.

3. OBJECTIVE OF THIS CSR POLICY

To lay down guidelines to make CSR a key business process for sustainable development of the society. Ensuring the implementation of CSR initiatives in letter and spirit through appropriate procedures and reporting.

To directly/ indirectly undertake projects/ programs which will enhance the quality of life and economic well-being of the communities in and around our facilities across country and society at large.

Establishing a guideline for compliance with the provisions of regulations to dedicate a percentage of Company’s profits for social projects.

4. SCOPE AND APPLICABILITY

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4.1 The Company’s Corporate Social Responsibility (“CSR”) policy is developed pursuant to Section 135 of the Companies Act and relevant rules prescribed therein (“Act”).

4.2 Any surplus arising out of CSR programs shall not form part of the business profits of the Company.

4.3 The Policy lays down the criteria for identifying programs eligible for financial assistance and for determining the quantum of assistance in relation to such programs.

4.4 This Policy shall apply to all CSR initiatives and activities taken up at the various work centers and locations of the company for the benefit of different segments of society.

4.5 This Policy shall be called “Sarita Handa CSR Policy”.

5. CORPORATE SOCIAL RESPONSIBILITY COMMITTEE COMPOSITION

The SHEPL’s Board of Directors has formed CSR Committee consisting of following members:
1. Ms. Suparna Handa- Managing Director
2. Mrs. Sarita Handa- Director
3. Mr. Rahul Puri- Director

The above Committee members would be responsible for the decision making with respect to Sarita Handa CSR policy.

6. IMPLEMENTATION

The CSR Committee of the Board shall meet at least twice a year to review the implementation of CSR projects/ programs and give suitable directions.

The CSR Committee shall recommend to the Board, the projects/programs to be undertaken, and the modalities of execution and implementation schedule from time to time. The company will set up a CSR team to support the CSR Committee and implementation of the CSR activities.

The CSR team will set up a formal process of evaluation of the CSR activities under the guidance of the CSR Committee.

7.ELIGIBLE PROGRAMSS AND CSR EXPENDITURE

7.1 Only those programs that are eligible in accordance with the Act and are consistent with the CSR themes identified by the CSR Committee shall be eligible for grants.

7.2 CSR Committee will recommend the programs wise expenditure to the Board for its consideration and approval as per the provisions of the Companies Act, 2013.

7.3 The Board of SHEPL ensures that a minimum of 2% of average net profit of the last three financial years is spent on CSR initiatives undertaken by SHEPL.

7.4 In case of minimum 2% of average net profit of the last 3 years is not spent in the financial year, reasons for the same to be specified in Boards’ Report.

7.5 Any surplus generated out of the CSR activities not to be added to the normal business profits of SHEPL.

7.6 The administrative overheads used for the personnel/consultants’/experts etc. for carrying out the CSR activities shall not exceed 5% of total CSR expenditure
of the Company for the financial year.

7.7 In case of any excess CSR amount spent (i.e. more than 2% mandated expenditure), the amount will be set off over the next 3 financial years as per the Rules.

7.8 The unspent amount of an ongoing or multi-year projects (not exceeding three years excluding the year of commencement of a particular financial year) will be transferred to a designated account called the “Unspent Corporate Social Responsibility Account” within 30 days of the end of the Financial Year.

7.9 The unspent amount of other than ongoing projects (not exceeding one year) will be transferred to a fund specified in Schedule VII of the Act within 6 months from the end of the financial year.

7.10 All expenditure towards the programs to be diligently documented.

8. CSR ACTIVITIES

The Company may incur its CSR Expenditure on any of the following theme areas as prescribed by the Central Government under Schedule VII of the Companies Act, 2013:

8.1 Eradicating hunger, poverty and malnutrition, promoting health care including 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.

8.2 Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.

8.3 Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centers and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups.

8.4 Ensuring environmental 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.

8.5 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 art and handicrafts.

8.6 Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Paramilitary Forces (CPMF) veterans, and their dependents including widow.

8.7 Training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic sports.

8.8 Contribution to the prime minister’s national relief fund [or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund)] or any other fund set up by the central govt. for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes,
minorities and women.

8.9 (a) Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and

(b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information

Technology and other bodies, namely Defense Research and Development Organization (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).

8.10 Rural development projects.

8.11 Slum area development.
Explanation: – For the purposes of this item, the term `slum area’ shall mean any area declared as such by the Centra Government or any State Government or any other competent authority under any law for the time being in force.

8.12 Disaster management, including relief, rehabilitation and reconstruction activities.

9. EVALUATION, MONITORING, REPORTING AND MODIFICATION FRAMEWORK

9.1 Evaluation
Prospective programs shall be presented to the CSR Committee for evaluation. The proposals shall set out the proposed budget, social need for the programs and benefits expected.

9.2 Monitoring
Programs monitoring mechanism will ensure:
9.2.1 The CSR policy is implemented as per the Act.
9.2.2 The CSR policy is implemented ensuring that all programs are duly carried out as budgeted.

9.2.3 CSR spends will be closely monitored and funds shall be released against verifiable utilizations as per the approved work plans. This may include field visits, comprehensive documentation, and regular interaction with beneficiary communities.

9.3 Reporting
The CSR Committee will prepare the annual CSR report and present for approval of the Board. This report will ensure that CSR programs are being properly documented and taken care of.

9.4 Amendments to the Policy

The Board of Directors on its own and/or as per the recommendations of CSR Committee can amend this Policy, as and when required as deemed fit. Any or all provisions of the CSR Policy would be subject to revision/amendment in accordance with the Act on the subject as may be issued by relevant statutory authorities, from time to time.

10. MISCELLANEOUS

10.1 Information dissemination
As per Section 135(4)(a) of the Act, SHEPL will disclose CSR Policy on the company’s website and disclose contents of such policy in its report in such manner, as prescribed.

10.2 Partnerships
Collaborative partnerships may be formed with NGOs and like-minded organizations. This helps widen the Company’s reach and leverage upon the collective expertise, wisdom and experience that these partnerships bring to the table.

The Company may engage with well-established and recognized programs and national platforms to achieve the objective of inclusive growth.

10.3 Implementing Agencies
The implementation agencies may include:
10.3.1 a company established under section 8 of the Act, or a registered public trust or a registered society, registered under section 12A and 80G of the Income Tax Act, 1961, and has an established track record of at least three years in undertaking similar activities.

10.3.2 a company established under section 8 of the Act or a registered trust or a registered society, established by the Central Government or State Government; or any entity established under an Act of Parliament or a State legislature.

10.3.3 Every implementing agency shall mandatorily register itself in the MCA21 portal to enable it to undertake CSR activities

11. EXCLUSION IN THE CSR EXPENDITURE

11.1 Activities undertaken in pursuance of a normal course of business of the company.

11.2 Activities undertaken outside India, except for training of Indian sports personnel representing any State or Union Territory at national level or India at international level.

11.3 Contribution of any amount, directly or indirectly, to any political party under section 182 of the Act.

11.4 Activities benefiting employees of the company as defined in section 2(k) of the Code on Wages, 2019.

11.5 Sponsorship activities for deriving marketing benefits for
products/services.

11.6 Activities for fulfilling statutory obligations under any law in force in India.

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