Corporate Social Responsibility (CSR) Policy

Effective : 01.04.2014

This policy has been formulated based on the Corporate Social Responsibility (CSR) philosophy of Surya Food & Agro Limited. In compliance with the provisions of Section 135 of the Companies Act, 2013, read with Schedule VII of the Companies Act, 2013 and Companies (Corporate Social Responsibility) Rules, 2014. This policy will at all times be subject to the provisions of the aforesaid act and rules (as amended from time to time).


Surya Food & Agro Limited (hereinafter referred to as “ Company”) is a public limited company, formed and registered under the provisions of the Companies Act, 1956, having its registered office at D-1, Sector-2, Noida U.P-201301. Company is engaged in the business of Biscuits Manufacturing . Company aims to carry out charitable objects and purpose wide enough for the extension of the benefit thereof to all, irrespective of class, creed and relief to poor, education, medical relief and advancement of object in general and or public utility besides pursuing its main object as enumerated in the MOA of the company.

Management of Company is also committed to contribute towards its societal responsibilities beyond statutory obligations. Company has a track record to contributing the funds to carry out charitable objects and purposes wide enough for the extension of the benefit to all.

Pursuant to the provisions of Section 135 of the Companies Act, 2013 (hereinafter referred to as “Act”) read with Schedule VII of the said Act and Companies (Corporate Social Responsibility Policy) Rules, 2014 as amended from time to time (hereinafter referred to as “Rules”), a Company having

  • net worth of INR 500 Crore or more ;
  • turnover of INR 1000 Crore or more ;
  • net profits of INR 5 Crore or more

shall constitute a CSR Committee. The CSR Committee has been entrusted with responsibility of formulating and recommending Corporate Social Responsibility Policy (hereinafter referred to as “CSR Policy”) to the Board of Directors of the Company (hereinafter referred to as “Board”), a Corporate Social Responsibility Policy indicating the activities to be undertaken by the Company as specified in Schedule VII to the Companies Act, 2013; recommending to the Board the amount of expenditure to be incurred; monitoring the implementation of framework of CSR Policy and ensuring that implementation of the project and programmes is in compliance with the CSR Policy of the Company.

The Board may undertake its CSR activities through its own trust or any other society/Trust to carry out CSR activities from time to time.

In line with the requirement of the Act, Schedules and Rules made there under, this CSR Policy has been formulated and recommended by the CSR Committee for approval of the Board.

CSR Committee

consists Four directors. The Composition of CSR Committee, as appointed by Board of Directors of the Company

CSR Activities

The CSR activity shall be undertaken by the company as per its CSR policy, as Projects or programs or activities (either new or ongoing), excluding activities undertaken in pursuance of its normal course of business.

The Board may decide to undertake its CSR activities approved by the CSR committee through a Registered Trust or Registered society or a section 8 Company formed by the company itself or along with its holding or subsidiary or associate company or along with any other company or holding or subsidiary or associate company of such other company or otherwise.

Company may also collaborate with other entities for undertaking projects or programs or CSR activities in such a manner that the CSR committee of respective entities are in a position to report separately on such projects or programs .

CSR Policy

recognizes that CSR is not merely compliance; it is commitment to support initiatives that measurably improve the lives of underprivileged by one or more of the following focussed areas mainly as per the Act, Schedules VII and Rules made there under:

  • eradicating hunger, poverty and malnutrition, promoting health care including preventive Health Care and sanitation including contribution to Swach 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 Supporting Schools and educational institutions in infrastructure development and Improving educational facilities, and to support children for higher education, and employment enhancing vocation skills to promote vocational training, and other Life Skill Training and livelihood enhancement projects especially among children, women, elderly, and the differently abled and livelihood enhancement projects;
  • 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;
  • ensuring environmental sustainability, ecological balance through plantation drives in schools, villages, our manufacturing units & offices/business premises and other areas in general, protection of flora and fauna, animal welfare, agro forestry, conservation of natural resources and maintaining quality of soil, air and water .
  • 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;
  • measures for the benefit of armed forces veterans, war widows and their dependents;
  • training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic sports;
  • Contribution to the Prime Minister's National Relief Fund or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women.
  • contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government;
  • rural development projects;
  • Slum area development

CSR Expenditure

The corpus for the purpose of carrying on the aforesaid activities would include the following:-

  • 2% of the average Net Profit made by the Company during immediately preceding three financial years.
  • Any surplus arising from any CSR Programmes shall be used for CSR Activity. Accordingly any income arising from CSR Program will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.

Plans / Key Focus Area for contribution of Funds

Board of the Company is very keen to focus on CSR activities (either through its own trust/ society or other trust / society or otherwise) towards areas as enumerated in Schedule VII read with section 135 of the Companies Act, 2013 and Company (Social Responsibility Policy) Rules, 2014 as enacted or amended from time to time.

Procedure for CSR activities

The Committee shall recommend to the Board, suitable CSR Activities to be undertaken during the financial year along with the detailed plan and amount to be incurred on such activities;

The Board shall give its approval based on the recommendation of the Committee and in compliance of this Policy;

The Committee, after approval, shall submit its report giving status of the CSR Activities undertaken, expenditure incurred and such other details, as may be required by the Board.

Implementing Agency

Company intends to undertake its CSR activities through its own trust or through such other agencies as may be prescribed under the Act, Schedules and Rules made there under. The Company may also undertake CSR activities directly and involvement of any other trust /agency. Board is also free to take decision to contribute any amount in Prime Minister Relief Funds.

Trust of the Company shall inter alia undertake CSR activities as per this Policy and also in conformity with the provisions of the said Act, Schedule and Rules made there under (as amended from time to time).

Company may explore the possibility of collaboration with other corporate/ companies / group companies (if any), for undertaking CSR project(s), programme(s) or activity (ies).

Monitoring Mechanism

A list of CSR project(s) / activity (ies) / programme(s) which the Company plans to undertake either by itself or through any other agency (ies) or trust(s) or charitable institution(s) or any other institution(s) or organisation(s) during the implementation year shall be laid down before the CSR Committee, specifying modalities of execution in the area(s) / sector(s) chosen and implementation schedule for the same.

The CSR Committee will further review the CSR activities of the Company and will provide progress report to the Board from time to time as may be deemed fit by the Board.

Reporting of CSR Initiatives

Details of CSR activities undertaken by Company and amount contributed along with the reasons for short fall in CSR expenditure ,if any, shall be reported in Directors Report.

This CSR Policy will be subject to review and changes as may be required from time to time.

A copy of this CSR Policy shall also be on website of the Company i.e., in line with the requirement of provisions of the Act and Rules made there under.

Implementation Plan

Surya Food & Agro Ltd. will undertake CSR activities/initiatives which are closely linked to the defined objectives, in partnership with institutions, NGOs and local communities. The implementation of the CSR activities/initiatives will be broad-based to employees as volunteers or through implementing agencies such as NGOs, Trusts, Institutions, Confederations, section 25 A companies or in partnership with like-minded Organisations.

The CSR steering committee will put up to the Board CSR committee the appropriate details of proposed projects including implementation modalities, implementing agency details, impact that it could create, stakeholder involvement and budgetary details for approval. On approval of the CSR committee, the steering committee will be responsible to roll out the project and to monitor its implementation.

SFAL may work on both vertical as well as horizontal approaches to achieve its CSR vision. SFAL would implement CSR programs that have wider coverage in terms of beneficiary and geography in one hand and on the other hand it would also design programs which are intense and in-depth.

Thrust Area

To optimize impact of its CSR activities, SFAL will focus its support and CSR spends specific pre-determined causes and areas of interventions. SFAL will focus its CSR activities on

  • Child Health, Hygiene and education
  • Vocational training focused on employable skills
  • Neighbourhood projects as per the local needs identified by SFAL Plants / Offices.