New Opportunity Consultancy Pvt. Ltd.

NEW OPPORTUNITY CONSULTANCY PRIVATE LIMITED (NOCPL)
CORPORATE SOCIAL RESPONSIBILITY (CSR) POLICY
(Version 3.3)
CLASSIFICATION: PUBLIC
DOCUMENT ID: NOCPL_PO_11

1. PREAMBLE

1.1 New Opportunity Consultancy Pvt. Ltd. (‘NOCPL’/ ‘The Company’), a company registered under Indian Companies Act, 1956, is a new generation service provider in the business of promoting financial inclusion. The Company acts as authorized Business Correspondents to multiple Banks and Non-Banking Finance Companies (NBFCs) in India. NOCPL’s organization goal of financial inclusion is incomplete unless it provides or enhances the livelihood opportunities of its customers and the general public. To achieve this objective, the Company has been providing them access to locally suitable and sustainable livelihood skills comprising necessary technical and networking skills besides financial credit to bridge the gap

1.2 The Company believes in an equitable society and it has been involved in a number of activities for the benefit of its customers, their children and the society in the areas of skill development, livelihood skills, education and health

2. POLICY STATEMENT/ VISION

The Company’s CSR mission is to contribute to the social and economic development of the community and society. Through a series of interventions, the Company seeks to bring the economically, physically and socially challenged groups into the cycle of growth, development and empowerment. At the core of this is its commitment to reach out to marginalized communities through sustainable livelihood initiatives.

3. CSR ACTIVITIES

3.1 The Company may undertake following CSR activities, projects and programmes (‘CSR Activities’):

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;
promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects; such activities may also include providing training for apprentices under Govt. of India sponsored National Apprenticeship Promotion scheme (NAPS);
promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
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 setup by the Central Government for rejuvenation of river Ganga);
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;
measure for the benefit of armed force veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
training to promote rural sports, nationally recognized sports, Paralympic sports and Olympics sports;
contribution to the Prime Minister’s National Relief Fund or Prime Minister's Central Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Schedule Tribes, other backward classes, minorities and women;
(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 Organisation (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).

rural development projects.
slum area development
disaster management, including relief, rehabilitation and reconstruction activities.
such other activities as covered under Section 135 of the Companies Act, 2013, the Companies (Corporate Social Responsibility Policy) Rules, 2014 and Schedule VII to the Companies Act, 2013 (including any amendments or enactments thereof) from time to time.

3.2 The Company can also spend the CSR amount for creation or acquisition of a capital asset, which shall be held by –

a company established under section 8 of the Companies Act, or a Registered Public Trust or Registered Society, having charitable objects and CSR Registration Number; or
beneficiaries of the CSR project, in the form of self-help groups, collectives, entities; or
a public authority.

4. SCOPE

This policy shall apply to all activities, projects and programmes undertaken as part of Company’s CSR initiatives and will be developed, reviewed and updated by reference to relevant codes of corporate governance.

5. CSR OUTLAY

5.1 The Company shall endeavour to spend, in every financial year at least 2% of the average net profits of the Company made during the 3 immediately preceding financial years in pursuance of this Policy and in accordance with the provisions of Section 135 of the Companies Act, 2013, read with the Companies (Corporate Social Responsibility) Rules, 2014.

5.2 Any unspent CSR amount or excess spent CSR amount shall be dealt with as provided in sub-section (5) & (6) of section 135 of the Companies Act 2013, read with the Companies (Corporate Social Responsibility) Rules, 2014 and Schedule VII to the Companies Act, 2013, as amended from time to time.

6. GUIDING PRINCIPLE

The objective as well as the practical need for the project and the credibility of the Institution involved in its implementation shall be the guiding principal for selection.

7. BOARD LEVEL CSR COMMITTEE

7.1 The CSR governance structure shall be headed by a Board Level CSR Committee that will ultimately be responsible for the CSR projects undertaken. The Committee shall report to the Board of Directors.

7.2 Members
The Committee shall be constituted consisting of three or more directors, out of which at least one director shall be an independent director.

7.3 Responsibilities

Formulate and update the Company’s CSR Policy for approval by the Board
Suggest areas of intervention to the Board
Approve projects that are in line with the CSR policy along with expenditure to be incurred
Put monitoring mechanism in place to track the progress of each project
Meet at least once a year to review the progress made.

8. ANNUAL ACTION PLAN

The CSR Committee shall formulate and recommend to the Board, an annual action plan in pursuance of its CSR policy, which shall include the following, namely:

(a) the list of CSR projects or programmes that are approved to be undertaken in areas or subjects specified in Schedule VII of the Act;

(b) the manner of execution of such projects or programmes;

(d) monitoring and reporting mechanism for the projects or programmes; and

(e) details of need and impact assessment, if any, for the projects undertaken by the company:

Provided that the Board may alter such plan at any time during the financial year, as per the recommendations of the CSR Committee, based on the reasonable justification to that effect.

9. MANNER OF EXECUTION OF PROJECTS, MODALITIES FOR UTILISATION OF FUNDS, IMPLEMEN-TATION SCHEDULE, MONITORING AND REPORTING PROCESS

9.1 Manner of Execution of Projects
The Company will undertake its CSR activities either directly or through a Registered Trust or through a Registered Society or establish another company under Section 8 of the Companies Act, 2013 or through collaboration with other entities. The Company will give preference to the local area(s) in and around its offices in India.

9.2 Modalities for Utilisation of Funds
The Company will utilise the CSR outlay for each financial year in sectors or activities specified as ‘CSR Activities’. It must be ensured that the contributions are made only to institutions/ agencies that have obtained a CSR Registration Number from the Ministry of Corporate Affairs.
In case of ongoing projects, stoppage of the activities may adversely impact the beneficiaries in particular and the society at large. Accordingly, the Company may continue incurring regular expenses on such projects even if there is no or insufficient CSR obligation during the Financial Year (FY); the excess expenditure (over and above the CSR budget for the FY) may be set off in next FY against CSR obligation of that FY.
The Chief Financial Officer of the Company shall issue a certificate to the effect that the funds disbursed towards CSR have been utilized for the relevant purposes and in the manner as approved by the CSR Committee/ Board.

9.3 Implementation Schedule, Monitoring and Reporting Process
The Internal Audit Team or such other person as may be nominated by the Managing Director of the Company/ CSR Committee shall monitor the implementation schedules of various CSR projects/ activities/ programmes towards which the Company has made contributions, on the basis of the timelines indicated by the respective Institutions. For this purpose, the CSR Committee may lay down processes and procedures to facilitate such monitoring.
The CSR Committee will oversee the implementation and monitoring of all CSR projects/ programmes/ activities and periodic reports shall be provided for review to the Board.
Further, the Internal Audit Team or such other person as may be nominated by the Managing Director of the Company/ CSR Committee will monitor the progress of various in-house CSR projects, utilization of funds and timeliness of implementation.
Where considered necessary, the Board and/or the CSR Committee may advise on-site visits for the purpose of carrying out due diligence in the case of a single project (projects implemented at multiple locations by multiple branches or agencies not covered under this clause) involving an outlay of Rs.25 lakhs or more, except in the case of contributions made to the Central/State Government(s).
A report shall be submitted by the CSR Committee after the closure of each financial year, providing therein brief details about various contributions made during the year under each broad head.

10. RESOURCE UTILISATION

The Company may use the CSR capabilities/skills of its employees and/or avail of the services of one or more external agencies towards executing, overseeing and monitoring the overall CSR programme. The administrative expenses to be incurred in this connection shall not, however, exceed 5% of the total CSR outlay of the Company for the respective financial year.

11. REVIEW AND DISCLOSURE REQUIREMENT

This Policy shall be reviewed on an annual basis or earlier (whenever required) and a copy of the latest Policy shall be hosted on the Company’s website.
The Company shall also make proper disclosure on CSR activities in its Annual Report as per relevant provisions of the Companies Act.

(Ver. 3.3_May’24)

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