VFS Global Services Pvt. Ltd.
Corporate Social Responsibility
PolicySeptember 2022

Partnering Governments. Providing Solutions.

Corporate Social Responsibility
Policy – VFS Global Services Pvt.
Ltd.
This manual contains the Corporate Social Responsibility Policy for VFS Global
Services Pvt. Ltd. (VFS Global’s Indian entity)

Document No: D/CSR/01: India Policy
Version [9] – Created 30 September 2022
Author: Ria Vaidya – Senior General Manager - Corporate Communications & CSR
Approved by: Corporate Social Responsibility Committee of VFS Global Services Pvt. Ltd.

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Table of Contents
Abbreviations

4

Amendment Summary

5

Purpose and Scope of this document6

1. Preamble

6

2. Policy objective

6

3. Governance6

4. CSR Committee

7

5. CSR activities

8

6. CSR budget

9

7. Modalities of execution of CSR activities

98. Implementation schedule

99. Monitoring

9

10. Due Diligence10

11. Reporting11

12. Display of CSR activities on website

11

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Abbreviations
CSR

Corporate Social Responsibility

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Amendment Summary
VersionNo

Process

Section No.

1

Original Issue

Full
document

2

Amendment

4

3

Amendment

4

Reasons forrevision

Rev.No.

Rev. Date

Original Issue

0

16.6.14

7

Update1

17.11.14

Intro,4,5,7

2,7,8,9Update2

31.3.16

Amendment

7

9

Update330.09.16

5

Amendment

4

7

Update415.03.18

6

Amendment

4,5,12

7,8,12Update531.03.19

7

Amendment

4,5

7,8

Update631.03.20

8

Amendment

4,8,11,12

7,10,12Update731.03.2021

9

Amendment

D/CSR/01 : CSR India Policy ; Ver-9 ; September 2022

Page
No.

Update01.10.2022

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Purpose and Scope of this document
The purpose of this document is to define a policy for CSR for VFS Global Services Pvt. Ltd.
(VFS Global’s Indian entity). VFS Global Services Pvt. Ltd. is hereinafter referred to as theCompany.
The document applies to all CSR programmes and activities conducted in India.

1.

Preamble

Corporate Social Responsibility (CSR) refers to a business practice that involves participating
in initiatives that benefit society. It covers the entire process by which an organisation
approaches, defines and develops its relationships with stakeholders for the common good,and demonstrates its commitment in this regard by adoption of appropriate strategies andprojects. Thus, CSR is not charity or mere donations but a way of going beyond business as
usual, creating shared value and contributing to social and environmental good.

2. Policy objective
The objective of this CSR Policy is to set the guiding principles for managing the CSR
function of the Company which includes conducting of CSR programmes, activities, setting up
processes of due diligence, programme planning and implementation, monitoring, andreporting of the CSR activities.

3. Governance
The CSR Committee will be responsible for administering and executing the policy. As theCompany’s CSR activities evolve further, the policy may be revised on recommendation of
the CSR Committee subject to the approval of the Board of Directors of the Company.

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4. CSR Committee
A CSR Committee be constituted consisting of minimum two Directors. The Committee willmeet as and when required complying with the Companies Act,2013. The following shall be
the terms of reference of the Committee.
1.

To formulate and recommend to the Board a CSR Policy which shall indicate theactivities to be undertaken by the Company as specified in areas or subjects specified in
Schedule VII of the Companies Act, 2013.

2.

To recommend the amount of expenditure to be incurred on the activities mentioned in
the policy.

3.

Conduct due diligence of the implementation partner i.e. the trust, society or thecompany through which the CSR activities will be undertaken.

4.

To monitor the CSR Policy from time to time.

5.

Form and delegate authority to sub-committees when appropriate.

6.

Report progress of various initiatives and make appropriate disclosures on periodic
basis.

7.

Any other matter as the CSR Committee may deem appropriate after approval of theBoard of Directors or as may be directed by the Board of Directors from time to time.

Consistent with the above, the CSR Committee currently has the following members witheffect from 1 October 2022:
Mrs. Vijayashree Ranganathan

Director

Mr. Rajesh Shetty

Director

5. CSR activities
The Company may undertake any one or more of the following activities, areas or subjects,
as mentioned in Schedule VII of Companies Act, 2013 (as amended), approved by the CSR
Committee and to be decided by the Board of Directors from time to time depending on thesuitable opportunities available and need of the area concerned:
1. Eradicating hunger, poverty and malnutrition, promoting health care including
preventive health care and sanitation including contribution to the Swach Bharat Koshset-up by the Central Government for the promotion of sanitation and making
available safe drinking water.

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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 otherfacilities for senior citizens and measures for reducing inequalities faced by sociallyand economically backward groups.
4. Ensuring environmental sustainability, ecological balance, protection of flora andfauna, animal welfare, agroforestry, conservation of natural resources andmaintaining 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 andsites of historical importance and works of art; setting up public libraries; promotion
and development of traditional arts and handicrafts.
6. Measures for the benefit of armed forces veterans, war widows and their dependents.
7. Training to promote rural sports, nationally recognized sports, paralympic sports andOlympic sports.
8. 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 andwomen.
9. Contributions to incubators funded by Central Government or State Government or
any agency or Public Sector Undertaking of Central Government or State
Government, and contributions to public funded Universities, Indian Institute ofTechnology (IITs), National Laboratories and Autonomous Bodies (established under
the auspices of Indian Council of Agricultural Research (ICAR), Indian Council ofMedical Research (ICMR), Council of Scientific and Industrial Research(CSIR),Department of Atomic Energy (DAE), Defence Research and Development
Organisation (DRDO), Department of Biotechnology (DBT),Department of Scienceand Technology (DST), Ministry of Electronics and Information Technology) engaged
in conducting research in science, technology, engineering and medicine aimed atpromoting Sustainable Development Goals (SDGs).
10. Rural development projects.
11. Any other programme or project or activities or areas or subjects as amended fromtime to time which would be included in the Schedule VII of the Companies Act,2013.
(Collectively hereinafter referred to as “CSR Activities”).
12. Disaster management, including relief, rehabilitation and reconstruction activities.
CSR activities to be undertaken in India only. The Company shall give preference to the localarea(s) around which it operates, for spending amount earmarked for CSR activities.

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6. CSR budget
The Company will spend at least two per cent of the average net profits of the Company
made during the three immediately preceding financial years. It is also declared that the
surplus arising out of the CSR activities of the Company will not form part of business profits
of the Company.

7.

Modalities of execution of CSR activities

The modalities of execution of CSR activities are detailed below:
1. The Board of a company may decide to undertake its CSR activities approved by the
CSR Committee, through(a) a company established under Section 8 of the Act or a registered trust or aregistered society, established by the company either singly or along with anyother company, or(b) a company established under Section 8 of the Act or a registered trust or aregistered society, established by the Central Government or State Government
or any entity established under an Act of Parliament or State legislature:
Provided that if, the Board of a company decides to undertake its CSR activities
through a company established under section 8 of the Act or a registered trust ora registered society, other than those specified in this sub-rule, such company ortrust or society shall have an established track record of three years inundertaking similar programmes or projects; and the company has specified the
projects or programs to be undertaken, the modalities of utilisation of funds ofsuch projects and programmes and the monitoring and reporting mechanism”.
2. The Company may also collaborate with other companies for undertaking CSR
projects or programmes or CSR activities in such a manner that the CSR Committee
is in a position to report separately on such projects or programmes in accordancewith the rules. The disbursal of funds will be either in one or more tranches or onetime payment depending on the nature and requirement of the project.
3. The CSR Activities shall not include any activity undertaken by the Company inpursuance of normal course of business of the Company.
4. The Company shall not make any payment directly or indirectly to Political Party (ies)for CSR Activities.

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8. Implementation schedule
The Committee will meet as and when necessary to discuss about the CSR activities,
projects or programmes which the Company would undertake.

9. Monitoring
The CSR Committee shall:
1.

Constitute a transparent monitoring mechanism for implementation of CSR projects orprogrammes or activities undertaken by the Company; and2.

Monitor and if required, recommend modification in the CSR Policy of the Company fromtime to time.

10. Due Diligence
Due Diligence to be conducted on the following parameters :
1.
2.
3.

Competence: Expertise and the number of years of experience in the chosen sector.
Identity: Is it an entity registered as a trust, society or Section 8 Company? Availability of
all relevant registration documents as per requirements of the Companies Act.
Financial Capability: Availability of documents like audited Financial Statements, Statusof 80G Registration and so on.

After the selection of the implementation agency, the Memorandum of Understanding giving
the details of the outputs and outcome, approach, key parameters to be reported andmonitored, scope of change in management procedures, audit requirements, release of
payments, etc. need to be signed.
MANDATORY CHECKS OF THE THREE CHOICES FOR LEGAL ENTITY (TRUST/SOCIETY/COMPANY)

DIFFERENTIAL

TRUST

SOCIETY

Trust deed whichcontains objects of thetrust (bye-law)Memorandum ofassociation Articles ofassociation with rules andregulations

SECTION8 COMPANY

FACTORSBASIC DOCUMENT

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Memorandum ofassociation Articles of
Association

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JURISDICTION

Deputy registrar orcharity commissioner

Registrar of Societies

Registrar ofCompanies

LEGISLATION /Relevant state trust act

Societies Registration Act
1860

Companies Act 2013

REQUIRED MEMBERS

Minimum = 2,
maximum = no limit

Minimum = 7, maximum =no limit

Minimum = 7,
maximum = no limit

REGISTRATIONAs trust with theregistrar

As society with society
registrar

As per Companies Act
under Section 8

MANAGEMENT BOARD

Trustees

Governing body

Board of directors andmanagement
committee

TRACK RECORD, IF

Established trackrecord of 3 years inundertaking similar
programmes or
projects

Established track recordof 3 years in undertaking
similar programmes or
projects

Established trackrecord of 3 years inundertaking similar
programmes or
projects

STATUTENOT ESTABLISHED BY
THE COMPANY

11. Reporting
The Board of Directors Report of the Company shall include an Annual Report on CSR
containing particulars specified and in compliance with the Companies Act, 2013. The Annual
Report on CSR activities may include the following particulars and other details to comply
with the Act.
1. A brief outline of the company's CSR policy, including overview of projects orprogrammes proposed to be undertaken and a reference to the web-link to the CSR
policy and projects or programmes.
2. The Composition of the CSR Committee.
3. Average net profit of the company for last three financial years.
4. Prescribed CSR Expenditure
5. Details of CSR spent during the financial year:(a) Total amount to be spent for the financial year(b) Amount unspent, if any(c) Manner in which the amount spent during the financial year
6. In case the Company has failed to spend the two per cent, of the average net profit of thelast three financial years or any part thereof, the Company shall provide the reasons fornot spending the amount in its Board report.

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7. A responsibility statement of the CSR Committee that the implementation and monitoringof CSR Policy, is in compliance with CSR objectives and Policy of the Company.

12. Display of CSR activities on the website
The CSR policy of the Company will be hosted on the official website of the Company. Our
Corporate Social Responsibility policy conforms to the provisions of the Companies Act,
2013, and rules framed thereunder.

Annexure-1
The officials of the Company who will be permanent invitees to the meetings of the CSR
Committee, and they shall form a part of the CSR Team is mentioned in Annexure-1.
Ms. Sukanya Chakraborty

Chief Communications Officer

Ms. Arnaz Kotwal

Head - Legal and Compliance

Mr. Atul Arora

Head - Corporate Controlling

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