Introduction

ThinkPalm Technologies Private Limited (“ThinkPalm”), is committed to deliver excellence in our business, and we wholeheartedly contribute towards being a part of societal change.

ThinkPalm has always believed in giving back to the society and recognized its role and responsibility as a corporate citizen.  A formal policy on CSR is formed to align its practices with requirements of Companies Act, 2013 and rules made thereunder.

CSR Projects and Programs

ThinkPalm intends to undertake various CSR projects, programs and activities from time to time which include contributing / undertaking ongoing CSR projects, programs and activities. Such projects, programs and activities will be undertaken keeping in mind the CSR philosophy of ThinkPalm and in alignment with the permissible activities under the Companies Act, 2013 and rules framed thereunder (as amended from time to time). ThinkPalm will focus its CSR initiatives in localities surrounding its business operations. It shall be at the discretion of ThinkPalm to undertake, modify, implement and cancel CSR projects, programs and activities from time to time as it deems fit. It shall also undertake projects in relation to promoting rehabilitation centers thriving to eradicate drug and alcohol addictions in the society.

Without prejudice to the generality of the aforesaid, Thinkpalm may from time to time undertake any project, program and activity in any one or more of the following areas:

1. Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water.
2. Promoting 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, day care centers and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups.
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.
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;
6. Measures for the benefit of armed forces veterans, war widows and their dependents;
7. Training to promote rural sports, nationally recognised 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 govt. for socio economic development and relief and welfare of the schedule caste, 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 govt;
10. Rural development projects;
11. Slum area development. The term `slum area’ shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force.
12. Disaster management, including relief, rehabilitation and reconstruction activities.

CSR Committee

The Board of Directors shall constitute Corporate Social Responsibility Committee (hereinafter referred as CSR Committee) to oversee and implement the CSR programs and initiatives approved by the Board. CSR Committee shall consist of minimum of 3 or more Directors.

The CSR Committee shall consist of the following directors:

1. Manoj K P
2. Rejish Madhavan Unni
3. Santhosh

The Board of Directors may change the composition of the CSR Committee from time to time as and when required.

CSR Committee may meet at such intervals and carry out matters as it deems fit.

If any approval of the Committee required on urgent basis, the Committee may pass any resolution by circulation and the same be treated as if passed in the meeting of the CSR committee and will have the same effect.

The CSR Committee shall have, inter alia, the following roles, powers and responsibility:

1. Formulate and recommend the CSR Policy and any amendments therein to the Board of Directors of ThinkPalm;
2. Develop and approve various CSR projects, programs and activities to be undertaken from time to time either directly by ThinkPalm or through a company established under section 8 of the Companies Act, 2013 or a registered trust or a registered society, established by the company, either formed by ThinkPalm or along with any other company or any other organization established by the Central Government or State Government or any entity established under an Act of Parliament or a State legislature.
3. Determine modalities of execution of such CSR projects, programs and activities;
4. Undertake all necessary steps to implement the CSR activities;
5. To set ThinkPalm’ s CSR budget for each year;
6. Monitor the CSR activities in such manner as it deems fit
7. Carry out all such acts, deeds, matters and things as may be required in connection with aforesaid matters and generally for any matter connected with the CSR policy / activities of ThinkPalm; and
8. To perform such functions as may be entrusted by the Board of Directors from time to time.

CSR Spending

ThinkPalm may, in every financial year, spend such amount on its CSR activities within the limits approved by the Board of Directors.

Any surplus arising out of CSR projects, programs and activities shall not form part of the business profits of ThinkPalm. During any financial year, if CSR expenditure is not fully spent by ThinkPalm, the same shall be kept in reserve shall be utilized in the next financial year or subsequent years. Presently we are running the following CSR projects.

• ThinkPalm School support 2020-21
• ThinkPalm Medicare support 2020-21
• ThinkPalm Rehabilitation support 2020-21
• ThinkPalm House construction project 2022-23

CSR committee may provide quarterly report on CSR activities spent by ThinkPalm to the Board.

Monitoring Mechanism

CSR Committee shall monitor the implementation of various programs, projects and activities in such manner as it deems fit including. Further the Committee shall have the authority to delegate the monitoring function to any executives of ThinkPalm who shall directly report to the CSR committee.

If CSR Committee decides to undertake its CSR activities through a company established under section 8 of the Act or a registered trust or a registered society, other than those specified above, such company or trust or society shall have an established track record of three years in undertaking similar programs or projects; and the company has specified the projects or programs to be undertaken.

CSR Committee shall also determine the manner of submission of information/ reports by third parties / executives as a part of the monitoring process.

Documentation and Reporting

All vouchers, expenditure statement, receipts and other documents for each expenditures shall be kept by ThinkPalm.

Further ThinkPalm shall keep the records for a minimum period of 8 years from the date of completion of the project as required under the provisions of the Companies Act, 2013.

Annual report on CSR will be presented along with Board’s report for every financial year as required under the provisions of the Companies Act, 2013. If during any financial year, company is not spending the required amount, reason for the same be given in the CSR report.

NOTE: Without prejudice to the generality of the contents of this policy, ThinkPalm may undertake CSR projects, programs and activities as permitted under the framework of Companies Act, 2013 from time to time (including any amendments, clarifications, circulars, notifications or other official communications from time to time). ThinkPalm may also carry out the purposes of this CSR policy in accordance with any amended position of law from time to time notwithstanding that such amended position is not reflected in this policy.