CSR Policy

1. Background

1.1. Company

Fosroc Chemicals (India) Private Limited (hereinafter referred to as the “Company” or “Fosroc”), incorporated on 22.12.1980, a 100% subsidiary of Fosroc International UK having operations across Europe, Africa, Middle East, and Asia. The Company is inter alia engaged in the business of being manufacturers, installers, maintainers, exporters, repairers, processors and dealers in chemicals and allied substances of all kinds for the construction, engineering industry and other consumers thereof.

The Company is a market leader in construction chemicals in India for over four decades known for offering solutions to various problems in construction industry, combining high quality products, excellent technical support, customer service and innovation.

1.2. CSR in India

Corporate Social Responsibility (hereinafter referred to as “CSR”) in India has been traditionally seen as a philanthropic activity. While the corporate houses have been traditionally engaged in doing CSR activities voluntarily, the CSR provisions enumerated in the Companies Act, 2013 (hereinafter referred to as the “Act”) put formal and greater responsibility on the companies to set out clear framework and process for CSR activities and ensure strict compliance under the Act.

Section 135 of the Companies Act mandates certain prescribed companies to constitute a CSR Committee to effectively monitor CSR activities of the company and to ensure that such company spends 2 per cent of their average net profit from the three immediately preceding financials years towards CSR activities. Further, the Companies (CSR Policy) Rules 2014 (hereinafter referred to as “CSR Rules”) lays down the framework and modalities for carrying out CSR activities which are specified in Schedule VII of the Act as amended from time to time (including any modification or re-enactment thereof).

2. Objective & Scope

The main objective of the CSR policy is to lay down guidelines for the Company to make CSR as one of the key focus areas and make a positive contribution to society through high impactful and sustainable CSR programs.

This Policy covers proposed CSR activities to be undertaken by the Company and examining their alignment with Schedule VII of the Companies Act as amended from time to time. It covers the CSR activities which are being carried out in India and includes strategy that defines plans for future CSR activities.

To work towards a social cause, the Company has taken up an initiative under the Skill India Policy to promote vocational training facilities in the country targeting unskilled and inexperienced personnel including artisans, small jobbers, applicators etc., in a professional manner in the field of water proofing/tile fixing, remedial engineering and industrial flooring including post training monitoring and guidance for generation of employment.

3. Composition of CSR Committee & Disclosures

The Fosroc India CSR Committee shall be comprised in accordance with the requirements of the Act and the CSR Rules. This CSR Policy, details of the composition of the CSR Committee and projects approved by the Board shall be hosted on the Company’s website.

3.1. CSR Committee Members:

4. Role of CSR committee

The CSR Committee shall broadly carry out the following functions:

• To formulate and recommend to the Board, a CSR Policy.
• To formulate action plans to undertake CSR initiatives from time to time as prescribed under specified schedule VII of the Companies Act including the manner and execution of the projects and the modalities of utilization of funds, implementation schedule, and impact assessment of the activities.
• To recommend the amount of expenditure to be incurred on the CSR activities that the Board of Directors may approve the total amount to be spent on the CSR activities for each financial year as recommended by the CSR committee.
• To ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the Company for the financial year.
• To take stock of the progress of the initiatives and to monitor the implementation of the scheduled initiative.
• To submit an annual report of CSR activities to the Board. The CSR Committee shall 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 of the Company and to perform such functions as may be entrusted by the Board from time to time.

5. Role of Board of the Company

The Board of the Company shall satisfy itself that the funds so disbursed have been utilized for the purposes and in the manner as approved by it and the person responsible for financial management shall certify & publish this periodically.

In case of ongoing project, the Board of a Company shall monitor the implementation of the project with reference to the approved timelines and year-wise allocation and shall be competent to make modifications, if any, for smooth implementation of the project within the overall permissible time period.

Further, the Board of Directors shall mandatorily disclose the composition of the CSR Committee, and CSR Policy and Projects approved by the Board on the Company’s Website, if any, for public access.

6. CSR Activities to be undertaken by the Company 

6.1. Scope

The Company envisages to work towards a social cause by setting up Fosroc Technical Training academy which would train and professionalise hands on job workers/tradesmen (Masons, technicians and other artisans) irrespective of their regional or religious background imparting better application skills/ guidelines/entrepreneurial skills in the field of water proofing, remedial engineering along with safe working practices free of cost and show them the way forward towards employment generation.   This broadly falls under the Skill India Policy framework of the Central Government.

Apart from above, under the guidance of the board and as recommended by the CSR committee, the company may also get into rehabilitation of structures such as Hospitals, old age homes, etc. in the vicinity of the factory or sales branch locations. It also may consider the setting up of concrete and other testing laboratory facilities at any Engineering college in the vicinity.

The Company will focus its CSR activities on facilitating the imparting of employment enhancing vocational skills to tradesmen and workers such as masons, technicians, and other artisans. The intended focus of the Company’s CSR activities is on accordance with Schedule VII of the Act which prescribes the list of activities in which CSR expenditure is permitted, specifically Item No. 2 of Schedule VII which provides as below:

“Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.”

Towards this goal, the Company will focus on the following activities: 

• Establish a Technical Training Academy.
• Tie-up with established skills training institutes and organizations for conducting workshops and courses to impart the skills training.
• Sourcing of tools and tackles required for training.
• Preparing a course curriculum/material with in-house inputs.
• Conduct regular training programmes along with competency assessment.
• Keep a data base of tradesmen trained in different fields in the academy and direct them towards various employment channels viz. Applicators, builders, and Resident Welfare associations.
• Collect data about their progress and provide them further opportunities with higher levels of the training.
• To train aspiring civil engineering professionals to become specialised contractors/service providers through structured programmes in the field of water proofing, remedial and flooring segments.
• Post training the tradesmen will be provided with a certificate which would enable them to be considered for specialised applications at different work sites.
• Offering free lectures at Engineering colleges for graduate/PG courses where Repairs & Rehabilitation, Concrete technology/ is being taught as elective and approach colleges to make specialised services as an elective for civil engineering courses.
• The training will be provided in the fields of Water proofing, Tile adhesives, Flooring, Grouting, Repairs, and other related fields as may be decided.

6.2. Duration of Training

Training duration will vary depending upon the nature of training, training course, basic skill, and knowledge level of trainees etc, however, on normal basis it will be as follows:

• For semi-skilled tradesmen, duration of training will be between 1 – 3 days.
• For skilled tradesmen and technicians, duration of training will be 2 – 4 days.
• For trainees who are sent by engineering colleges or other institutes, duration of training would be from 3-6 days.

6.3. Potential source of candidates

• Tradesmen working with various distribution applicators.
• Through advertisements in construction sites.
• Through referrals from other associated institutions.
• Tradesmen who are being referred by distributors to small clients.
• Tradesmen involved in regular building maintenance employed by Resident Welfare Associations.
• Supervisors/Mistris who have graduated from being tradesmen and are now working in supervisory cadre.
• Unskilled, semi-skilled workers, artisans, painters, carpenters and the like working at construction sites & other common business workplaces faculty.

6.4. Reporting

A monthly report will be submitted to CSR Committee which would consist of the following:

• Month Objective Vs Actual.
• Objectives for next Month.
• Highlights of activities during the month.
• Number of trainees with details regarding segments trained.
• Brief on post training monitoring.
• Feedback from Trainees.
• Expenses

Through the above listed activities, the Company shall persevere to achieve its objective of providing at no-cost to the trainee’s employment enhancing vocational skills training to better equip the tradesmen and workers to self-generate employment and opportunities.

7. Implementation

In accordance with the Rule 4 of the CSR Rules, the Company may implement the CSR undertaking as envisioned above, through either or both modes mentioned below:

7.1. Through its own academy and functionaries:

The Company may appoint a CSR Lead to organize and manage its CSR expenditure and to oversee, with the approval of the CSR Committee, the designing and implementation of the CSR activities from the establishment of the Technical Training Academy to the designing of the courses, to hiring the relevant faculty and instructors, and procuring the tools and tackles required, etc. The CSR Lead shall also screen any requests that the Company may receive for disbursal of CSR funds and assess such funding opportunities for the approval by the CSR Committee.

The CSR Lead shall also be tasked with closely monitoring the progress of the CSR project at every step of the way and evaluating and reporting back to the CSR Committee the progress of the project in a systematic manner as detailed above, to ensure that the CSR expenditure is utilized in an efficient manner resulting in maximum social impact and benefit.

7.2. Through an implementing agency:

The Company may disburse the earmarked CSR expenditure amount to an implementing agency as prescribed under Rule 4 of the CSR Rules mentioned above, such as a Trust or a Section 8 company or a Statutory Body, which provides imparting of skills training intended for the benefit of workers/tradesmen and which is in consonance with the Company’s CSR objectives. The CSR Lead appointed by the Company shall act as the point of contact between the Company and the implementing agency and shall be tasked with the responsibilities of monitoring and evaluating the project, from the stage of disbursal of funds, to the designing of the project, and evaluating and reporting the progress of the project as detailed above, to the CSR Committee at every stage of implementation, so as to ensure that the CSR expenditure is utilized in an efficient manner resulting in maximum social impact and benefit.

8. Impact Assessment

Impact assessment shall be undertaken by the Company or by recipient or by implementing agency as required by and in the manner set out under the Act and the CSR Rules, and the impact assessment report(s) shall be placed before the CSR Committee and the Board and shall be disclosed as legally required.

9. Fund Allocation 

The Company shall spend not less than 2% of its average net profits for the immediately preceding three financial years to CSR initiatives. In the event the Company fails to spend the said prescribed amount towards CSR activities in any financial year, the Board shall, in its report, specify the reasons for not spending the amount and, unless the unspent amount relates to any ongoing project (i.e. a multi-year project not exceeding three years), transfer such unspent amount to a Fund specified in Schedule VII of the Act, within a period of six months of the expiry of such financial year.

Any amount remaining unspent, pursuant to any ongoing project, 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 CSR Account, and such amount shall be spent by the Company towards CSR activities within a period of three financial years from the date of such transfer, failing which, the Company shall transfer the same to a Fund specified in Schedule VII of the Act, within a period of thirty days from the date of completion of the third financial year.

Any unspent amount arising out of the CSR Projects or Programs or Activities shall not form part of the business profits of the Company and shall be ploughed back into the same project or shall be transferred to the Unspent CSR Account and spent in pursuance of CSR activity or transferred to a Fund as specified in Schedule VII of the Act to be earmarked for the purpose of spending on CSR activity in the future.

The Company shall not spend more than 5% of the amount allocated annually for CSR activities towards administration and management expenses in accordance with the CSR rules. In case of the Company incurring any excess expenditure towards the CSR activities in any financial year then, such excess amount may be set off against future CSR obligations for the next three financial years immediately following the financial year in which such excess expenditure was incurred.

10. Policy Review

The CSR Committee shall periodically review its CSR Policy from time to time and make suitable changes including documentation and others as may be required and submit the same for the approval of the Board.