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CSR Policy



A. BACKGROUND In compliance with the requirements of Section 135 of the Companies Act, 2013 read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, ATOMY ENTERPRISE INDIA PRIVATE LIMITED (hereinafter referred to as “the Company”) is, inter alia, required to:

  1. i. Constitute a Board Committee, to formulate and recommend to the Board a Corporate Social Responsibility (CSR) Policy, recommend the amount of CSRexpenditure and monitor the CSR activities of the Company from time to time;
  2. ii. Ensure that the Company spends, in every financial year, at least 2 % (two) per cent of the average Net Profits Before Tax (PBT) of the Company, made during the three immediately preceding financial years, in pursuance of its CSR Policy.

B. PHILOSOPHY Corporate Social Responsibility (hereinafter referred to as “CSR”) is a public-spirited cause that has been well introduced in the Companies Act 2013. Through the CSR there is a formation of a dynamic relationship between a company on one hand and the society and environment on the other. CSR is traditionally driven by a moral obligation and philanthropic spirit. Therefore, the policy will function as a built-in, self-regulating mechanism whereby the business will monitor and ensure its active compliance with the spirit of law, ethical standards and international norms.
The main objective of the Policy is to establish the basic principles and the general framework of action for the management to undertake and fulfil its corporate social responsibility.


  1. 1. "Board" means the Board of Directors of the Company.
  2. 2. "Company" means Atomy Enterprise India Private Limited.
  3. 3. "CSR Activities" means such programs and projects as may be approved by the Board in terms of this CSR Policy.
  4. 4. "CSR Committee" means a committee constituted by the Board of Directors in terms of Section 135 of the Act and the CSR Rules.
  5. 5. "CSR Rules" means the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended from time to time.
  6. 6. "CSR Expenditure" means the amount recommended by the CSR Committee to be incurred on the CSR Activities in India in terms of the Act and the CSR Rules as approved by the Board from time to time.
  7. 7. "Director" means a member of the Board of the Company.
  8. 8. "Implementing Agency" means an implementing agency as defined under point H. 3
  9. 9. "Net Profits" means the net profit of the Company as per its financial statement prepared in accordance with the applicable provisions of the Act, but shall not include (i) any profit arising from any overseas branch or branches of the Company (whether operated as a separate company or otherwise); and (ii) any dividend received from other companies in India, which are covered under and complying with the provisions of Section 135 of the Act.

D. CORPORATE SOCIAL RESPONSIBILITY COMMITTEE The Corporate Social Responsibility Committee (hereinafter referred to as “CSR Committee”) shall consist of two directors.
The Company Secretary shall act as the Secretary to the Committee.


  1. o The Committee shall hold meeting as and when required, to discuss various issues on implementation of the CSR Policy of the Company. The members would thrive to hold at least two meetings in a financial year.
  2. o The Committee shall approve constitution of an implementation group for the purposes of implementation of the CSR Activities approved by the Board from time to time (the "Implementation Group") and submitting report of the progress on the CSR Activities to the Committee, which shall be further laid before the Board.


  1. o The Committee shall formulate and recommend the CSR Policy to the Board
  2. o The Committee shall periodically review the implementation of the CSR Programmes and issue necessary direction from time to time to ensure orderly and efficient execution of the CSR programmes in accordance with this Policy.
  3. o It would be the responsibility of the CSR Committee to periodically keep the Board apprised of the status of the implementation of CSR activities.
  4. o The Committee shall recommend the Board on the guiding principles for selection, implementation and monitoring of CSR activities.
  5. o The Committee shall recommend the amount of expenditure to be incurred on the activities in a financial year.
  6. o The Committee shall monitor the Corporate Social Responsibility Policy of the company from time to time.
  7. o The Committee formulate and recommend to the Board, an annual action plan in pursuance of its CSR policy, which shall include the items as mentioned in rule 5(2) of the Companies (CSR Policy) Rules, 2014.
  8. o The Committee shall ensure any other matter/thing as may be considered expedient by the Members of the Committee in furtherance of and to comply with the CSR Policy of the Company.


  1. o Form a CSR Committee and disclose the composition of the CSR Committee.
  2. o Approve the CSR Policy after taking into account the recommendations made by the CSR Committee.
  3. o Place the CSR Policy on the Company’s website.
  4. o Ensure implementation of the activities under CSR.
  5. o Ensure expenditure of requisite amount on CSR every year as per law.
  6. o Disclose reasons for not spending the amount (if applicable) in the Annual Report to the Shareholders of the Company.
  7. o Ensure that the CSR activities are undertaken by the Company itself or through a registered and eligible Implementation Agency
  8. o Ensure that the administrative overheads are not more than 5% of the total CSR Expenditure
  9. o Ensure that the funds so disbursed have been utilized for the purposes and in the manner as approved by Board / CSR Committee and the Chief Financial Officer shall certify to the effect.
  10. o Ensure that the surplus arising out of the CSR Activities shall be utilised only for CSR purposes.
  11. o Approve transfer of unspent CSR Amount in accordance with the law. The Accounts and Finance Team of the Company shall prepare the statement of spent and unspent CSR amounts and shall assist and facilitate for transfer of the same.
  12. o Where the Company spends an amount in excess of requirement, such excess amount may be set off by the Board against the requirement to spend up to immediate succeeding three financial years subject to the conditions that –
    1. • the excess amount available for set off shall not include the surplus arising out of the CSR activities, if any.
    2. • the Board of the Company shall pass a resolution to that effect.


  1. 1. Focus Areas
    The Company shall identify projects / programmes which will fall in any one or more of the following areas /sectors for its CSR spending:
    1. i. 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.
    2. ii. Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
    3. iii. 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.
    4. iv. Training to promote rural sports, nationally recognized sports, paralympic sports and Olympic sports.
    5. v. Rural development projects.
    The Company will prefer to take up projects for spending the amount earmarked for CSR at local areas and areas where the Company operates.
    All expenses and contributions for CSR activities will be made after approval from the Chairman of the CSR committee, which would then be placed before the forthcoming CSR committee for noting and record. The Chairman will ensure that the expenses/contribution will be in full compliance of the CSR Policy.
  2. 2. Officers for Implementation
    The Company shall appoint officers at its Corporate Office to undertake, supervise and monitor the CSR activities and expenditures. Such officers will be responsible to ensure that the expenditures are made in full compliance with this policy. They will submit periodical report to the committee. The Company will see that these officers have CSR capacities of their own and if required, they will be given required training to take up these tasks.
  3. 3. Implementing Agency
    The Board shall ensure that the CSR activities are undertaken by the Company itself or through –
    1. a) a company established under section 8 of the Act, or a registered public trust or a registered society, registered under section 12A and 80 G of the Income Tax Act, 1961, established by the company, either singly or along with any other company, or
    2. b) 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
    3. c) any entity established under an Act of Parliament or a State legislature; or
    4. d) 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 having an established track record of at least three years in undertaking similar activities.
    Every entity who intends to undertake any CSR activity, shall register itself with the Central Government by filing the form CSR-1 electronically with the Registrar.
    The Company shall specify the project or programs to be undertaken through these entities, modalities of utilization of funds on such projects and programmes.

I. EXCLUSIONS The activities to be undertaken by the Company under CSR shall not include the following:

  1. o activities undertaken in pursuance of normal course of business of the Company.
  2. o any activity undertaken by the Company outside India except for training of Indian sports personnel representing any State or Union territory at national level or India at international level.
  3. o contribution of any amount directly or indirectly to any political party.
  4. o activities benefitting employees of the Company.
  5. o activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services.
  6. o activities carried out for fulfilment of any other statutory obligations under any law in force in India.


  1. o The CSR Committee shall maintain proper minutes of all its meetings.
  2. o The Board's report of the Company shall include an annual report on CSR and such other details as may be prescribed from time to time under the Act and the CSR Rules.
    The Board of the Company may, subject to compliance with applicable law, at any time alter, amend or modify the CSR Policy as it deems fit to comply with the statutory obligation of the Company to undertake the CSR Activities.

Composition of CSR Committee:

S. No. Name of Director Designation/Nature of Directorship
1. Seikh Imtiaz Ali Managing Director
2. Seok Gyun Kwon Director

*The Company Secretary, Ms Shruti Agarwal shall act as the Secretary to the Committee.