CSR Policy
CSR Annual Action Plan
Composition of CSR Committee

Corporate Social Responsibility (CSR) is the responsibility of the corporate entity towards the society in consideration of the support given and sacrifices made by the society by sharing part of its profit.

Globus Infocom Limited, a premier Company to develop, design and deal in all kinds of software’s, software products in the field of Information Technology in India. Globus Infocom Limited (herein after called “Globus”), a Public limited company, has taken its commitment to the society and the people in need especially in underdeveloped areas, to participate/contribute and makes its presence in social, economic, infrastructural, educational, cultural activities etc., development for augmenting the quality of life of people across the country.

The Composition of the said CSR committee shall comprise of at least three directors. The other particulars of the policy are:

1. Objectives: The objective of these efforts under CSR are not only to help people by providing facilities for education, civic amenities etc. but also to create opportunities for development of skills, making digital technology reach masses, to promote greater environmental responsibilities and encourage the development and diffusion of environmentally friendly technologies for sustainable development.
Accordingly, pursuant to section 135 read with the activities that may be taken up to fulfil the objectives as prescribed in the schedule VII of the Companies Act, 2013.

2. CSR Vision: The Company’s CSR philosophy is “To build a better sustainable way of life & make educational facilities available for all sections of the society”. “Globus” vision is to be a responsible industry leader and demonstrate environmental, transparent, and ethical behavioural practices which will contribute to the economic and sustainable development of the company.
The Company’s CSR activities build an important bridge between business operations and social commitment evolving into an integral part of business functions, goals & strategy and social welfare.

3. Applicability: The CSR policy has been developed in consonance with Section 135 of the Companies Act, 2013 (herein after referred to as “the Act”) on CSR and in accordance with the CSR rules (herein after referred to as “the Rules”) as amended from time to time notified by the Ministry of Corporate Affairs. The Policy shall apply to all CSR projects/ programmes undertaken by the Company in India as per Schedule VII of the Act.

4. Role of the CSR Committee:
• Formulate and recommend to the Board, a Corporate Social Responsibility Policy in compliance with Section 135 of the Companies Act, 2013.
• Identify the activities to be undertaken as per Schedule VII of the Companies Act, 2013.
• Institute a transparent monitoring mechanism for implementation of the CSR projects or programs or activities undertaken by the Company.
• Recommend the amount of CSR expenditure to be incurred on the earmarked CSR activities.
• Monitor the implementation of the CSR Policy from time to time.

5. Role of the Board:
• After considering the recommendations made by the CSR Committee, approve the CSR Policy for the Company.
• Ensure that the CSR activities undertaken by the Company are as per the Corporate Social Responsibility Policy of the Company.
• The Board of the Company may decide to undertake its CSR activities approved by the CSR Committee, either by company itself or through a related company or registered trust or a registered society or a Company established under section 8 of the Act having track record of providing CSR activities in the areas defined in Schedule VII of the Act.
• Ensure that in each financial year the Company spends at least 2% of the average net profits of the company made during the three immediately preceding financial years, calculated in accordance with Section 198 of the Act, in pursuance of its CSR policy.
• As per Section 135 of the Act, the board shall specify the reasons for under spending the CSR amount in the Board’s Report.

6. Geographical Span
Globus being a company with pan-India operations, the amount earmarked for CSR activities in a financial year shall be utilized as under subject to the recommendation of the Committee on CSR and approval of the Board of Directors. As the operations of the Company are carried all over India, the inspiration of CSR strategy to invest the CSR amount is linked to the core function of the company. The projects may also be undertaken on Pan India basis as deemed fit and direct impact zones of Globus’s operations.

7. CSR activities for Implementation
The CSR Activities would be chosen for implementation by the Company in compliance with the provisions of Section 135 read together with Schedule VII of the Companies Act, 2013. In line with the Company’s vision, values and mission, the Board of Directors have identified the following core area for CSR. • promoting education especially among children with the vision that children from all section of the society can get access to schools with knowledge of digitisation.

8. Formulation of Annual Action Plan
CSR Committee shall prepare and recommend Annual Action Plan every year to the Board of Directors for its approval containing the following information;
i. List of CSR projects approved to be undertaken in areas or subject specified in Schedule VII of the Companies Act, 2013.
ii. The manner of execution of such CSR project iii. Utilization of CSR funds and implementation schedule of the CSR projects
iv. Monitoring and reporting mechanism for the project or programme. Board may alter such plan at any time during the financial year, as per the recommendation of its CSR Committee, based on the reasonable justification to that effect.

9. Dealing with the unspent amount
If the unspent amount relates to any ongoing project, the said unspent amount shall be transferred by the Company within a period of thirty days from the end of the financial year to a special account to be opened by the company in that behalf for that financial year in any scheduled bank to be called the “Unspent Corporate Social Responsibility Account”; and
If the unspent amount does not relate to an ongoing project, transfer such unspent amount to a Fund specified in Schedule VII of the Companies Act, 2013, within a period of six months of the expiry of the financial year.
Globus will ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the Company for the financial year, if any;
Monitoring the implementation of the ongoing project with reference to the approved timelines and year-wise allocation and make suitable modifications as may be required for the smooth implementation of the project within the overall permissible time-period.
Impact Assessment: In the event the average CSR obligation of the Company triggers ten crore rupees or more in the three immediately preceding financial years, Company shall undertake impact assessment through an independent agency, of their CSR projects having outlays of one crore rupees or more, and which have been completed not less than one year before undertaking the impact study.

10. CSR monitoring and reporting framework
In compliance with the Act and to ensure funds spent on CSR Activities are creating the desired impact on the ground a comprehensive monitoring and reporting framework has been put in place.
The CSR Committee shall monitor the implementation of the CSR Policy through periodic reviews of the CSR activities.

11. CSR expenditure CSR
Expenditure shall include all expenditure including contribution to corpus for CSR activities approved by the Board on the recommendation of the CSR Committee but does not include any expenditure on an item not in conformity or not in line with activities which fall within the purview of Schedule VII of the Act.

12. Frequency of Meetings
The meetings of the Committee could be held at such periodic intervals as may be required.

13. Quorum
Minimum two (2) members shall constitute a quorum for the Committee meeting.

14. Effective Date
The CSR Policy shall be effective from the date of its approval by the Board of Directors in their meeting held on dated 4th September 2022. Provided, however, that all the acts done in pursuance of the earlier CSR Policy shall stand ratified and covered under this policy.

15. Miscellaneous Globus reserves the right to modify, cancel, and/or amend any of the provisions of this policy in accordance with the prevailing statute.

Notwithstanding any clause in this Policy, no action pertaining to CSR activities shall be taken in contravention of the provision of Section 135 of the Companies Act, 2013 and of the Companies (Corporate Social Responsibility Policy) Rules, 2014.

This policy has been framed in compliance to the provisions of Section 135(3)(a) of the Companies Act, 2013 and Section (6) of the Companies (CSR) Rules, 2014 and approved by the Board of Directors in its meeting based on the recommendations of the Board’s Committee on CSR in its meeting.

(CSR policy was revised on 04 September 2022. This document was approved by the Board of Directors at its Meeting held on 04 September 2022)