CSR Policy

SIDS HEALTH CARE PRIVATE LIMITED
(CIN: U85320GJ2017PTC098620)
Reg. Off. : Survey No 865-866-701-702 1610 T P No 6 Final Plot
No 191 To 195ring Road, Khatodra, Near Shell Petrol Pump,
Sosyo Circlelane, Khatodara, Surat-395002, Gujarat, India.

Policy for Corporate Social Responsibility
(effective from 1st April, 2023)

CORPORATE SOCIAL RESPONSIBILITY POLICY

Contents

1Introduction
2Objective / Goals of the company
3Definitions/Interpretations
4Scope of CSR Activities
5Applicability not to be mentioned
6Measures
7Role of Board of Directors in CSR
8Organizational mechanism and responsibilities
9Setting targets
10Projects, Programs and Activities
11CSR Implementation
12CSR Budget/ Expenditure
13Information dissemination
14Management Commitment
15Reporting & Review
16Record Keeping
17CSR Reporting
18Revision Details
19Grievance Redressal Mechanism
  1. INTRODUCTION
    As an integral part of our commitment to good corporate citizenship, we believe in actively assisting in improvement of the quality of life of people in communities. World Health Organization defines health as state of complete physical, mental and social well-being and not merely the absence of disease or infirmity. Upholding this definition for health, the company believes that healthcare should not be seen synonymous to treatment of diseases alone while health promotion and disease prevention should be given adequate stress. Towards this, the company recognizes the relevance of considering the social determinants of health as a step towards health of a population. According to WHO, the social determinants of health are the conditions in which people are born, grow, live, work and age. These circumstances are shaped by the distribution of money, power and resources at global, national and local levels. The 66th World Health Assembly of WHO held in May 2013 ascertained that the social determinants need to be recognized and tackled as a fundamental approach. 
    To carry out our philanthropic activities systematically and to deliver care to the public, a policy on Corporate Social Responsibility (hereinafter described as the Policy) has been prepared in line with the requirements of the Companies Act, 2013 (hereinafter described as the Act). Towards achieving long-term stakeholder value creation, we shall always continue to respect the interests of and be responsive towards our key stakeholders – the communities, especially those from socially and economically backward groups, the underprivileged and marginalized; focused on inter alia the Scheduled Castes and Scheduled Tribes, and the society at large. 
    This policy, which encompasses SIDS’s philosophy for delineating its responsibility as a corporate citizen, lays down the guidelines and mechanism for undertaking socially useful programs for welfare & sustainable development of society at large, is titled as “SIDS Corporate Social Responsibility Policy
  2. GOALS:
    SIDS defines its social responsibility as a voluntary and strategic commitment that entails attempting to achieve business targets with an approach that integrates solutions to problems to benefit the communities at large and create social and environmental impact while complying strictly with its legal and contractual obligations, applying criteria of equity and stability to relationships with its stakeholders, thus contributing to meeting the current and future needs of society.
    • To deliver top-notch medical care with compassion and innovation, utilizing up to date technology and highly skilled professionals.
    • Managing the company based on the SIDS values of solvency, integrity, vocation for service, innovation for leadership and committed team, which must be present in any project that is carried out.
    • To be recognized as a leading superspeciality hospital, delivering unparalleled patient care and contributing to the advancement of the medical field.
    • To become the leading healthcare organization of the region by providing quality healthcare services and become the first choice of patients, doctors, donors and employees.
    • Transform the human life & lead the health care services by innovation and clinical excellence. Managing the risks and business opportunities arising from the development of the environment in which SIDS does business, assuming the impact it generates on society and the environment, maximizing the positives and minimizing the negatives.
    • Create a meaningful and lasting impact on the communities in remote areas by helping them transcend barriers of socio-economic development, Extending Comprehensive Integrated Healthcare Services to the community, Develop the skills of the youth through high quality education and research in healthcare services.
    • To enhance human lives and health by enabling access to comprehensive and integrated high quality healthcare services at affordable price with human touch. 
  3. GENERAL PRINCIPALS FOR ACTION
    World Health Organization defines health as state of complete physical, mental and social well- being and not merely the absence of disease or infirmity. Upholding this definition for health, the company believes that healthcare should not be seen synonymous to treatment of diseases alone while health promotion and disease prevention should be given adequate stress. Towards this, the company recognizes the relevance of considering the social determinants of health as a step towards health of a population. According to WHO, the social determinants of health are the conditions in which people are born, grow, live, work and age. These circumstances are shaped by the distribution of money, power and resources at global, national and local levels. The 66th World Health Assembly of WHO held in May 2013 ascertained that the social determinants need to be recognized and tackled as a fundamental approach.

    Maintaining corporate governance practices based on ethics, business transparency and diversity: respecting the rules of the free market and free competition, and rejecting any illegal or fraudulent practice contrary to the rules of good governance, to SIDS corporate policies and rules and to the guidelines of the Code of Ethics and Conduct, in order to accrue business benefits. SIDS has internal mechanisms for preventing, monitoring, reporting and penalizing any practice described in the paragraph above that occurs within the Group.To provide respectable employment:
    1. SIDS pays its employees in a upright manner, adjusted to their skills, responsibilities and duties. This payment is aligned with applicable legislation and with conditions in the market where it operates, which allows them to meet their basic needs and those of their families.
    2. SIDS guarantees the right of its employees to a workday that respects their right to rest and that facilitates flexi-work practices, acknowledging employees’ need to balance their work life with other interests and responsibilities.
    3. SIDS, likewise, guarantees people’s right to personal data privacy.
    4. To implement due diligence procedures to identify possible situations of greater risk in relation to human rights, and to develop mechanisms for preventing and mitigating these risks in its activities.
  4. OBJECTIVESIDS aims at supplementing the role of Government in enhancing the welfare measures of the society within the framework of its policy.The objective of this CSR Policy is to:
    1. Making quality healthcare accessible and affordable for all;
    2. Develop and implement the education, healthcare, water and sanitation, infrastructure development and elderly care projects for sustainable socio-economic development of the rural areas;
    3. Promote preventive healthcare to the most remote corners of the country.
    4. Provide free treatment including emergency care, ambulance support, consultation, investigation and pharmacy at identified locations and camps for the benefit of marginalized and disadvantaged.
  5. Effective Date:This policy will be effective from the beginning of financial 1st April, 2023.
  6. DEFINITIONS/INTERPRETATIONS
  1. Corporate Social Responsibility (CSR)” means the activities undertaken by the Company in pursuance of its statutory obligation laid down in Section 135 of the Companies Act, 2013 (hereinafter referred to as “Act”) read with Companies (Corporate Social Responsibility Policy) Rules, 2014. 
  2. CSR Committee” means the Corporate Social Responsibility (CSR) Committee of the Board referred to in section 135 of the Act.
  3. ‘Net profit” means the net profit of a Company as per its financial statement prepared in accordance with the applicable provisions of the Act, but shall not include the following namely
    1. any profit arising from any overseas branch or branches of the company, whether operated as a separate company or otherwise; and
    2. any dividend received from other companies in India, which are covered under and complying with the provisions of section 135 of the Act. 
  4. “Administrative overheads” mean the expenses incurred by the company for ‘general management and administration’ of Corporate Social Responsibility functions in the company but shall not include the expenses directly incurred for the designing, implementation, monitoring, and evaluation of a particular Corporate Social Responsibility project or programme. 
  5. “Ongoing Project” means a multi-year project undertaken by a Company in fulfilment of its CSR obligation having timelines not exceeding three years excluding the financial year in which it was commenced, and shall include such project that was initially not approved as a multi-year project but whose duration has been extended beyond one year by the board based on reasonable justification.
  6. “Implementing agency” means the eligible entities which can act as an implementing agency for undertaking CSR activities given as under:
    1. Company established under section 8 of Companies Act 2013, or Trust, or Society registered under section 12-A and 80-G of the Income Tax Act 1961, being established by the Company, either singly or along with any other company;
    2. Company established under section 8 of Indian Companies Act 2013, or Trust, or Society, being established by Central Government or State Government;
    3. Any entity established under an act of Parliament or a State Legislature.
    4. Company established under section 8 of Indian Companies Act 2013, or Trust, or Society registered under section 12-A and 80-G of the (Indian) Income Tax Act 1961, and having an established track record of at least three years in undertaking similar CSR activities;
  1. SCOPE OF CSR ACTIVITIES As required pursuant to the provisions of section 135 read with Schedule VII of the Companies Act, 2013 and the Companies (Corporate Social Responsibility Policy) Rules, 2014, the Company shall endeavor its CSR activities within the purview of Schedule VII in the following areas:
    1. 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. Promoting education, including special education and employment and 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 other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups. 
    4. Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining 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 and sites 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, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows; 
    7. Training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic sports. 
    8. Contribution to the Prime Minister’s National Relief Fund or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) 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. 
    9. A) Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and B) Contributions to public funded Universities; Indian Institute of Technology (IITs), National Laboratories and Autonomous Bodies (established under the auspices of Indian Council of Agricultural Research (ICAR), Indian Council of Medical Research (ICMR), Council of Scientific and Industrial Research (CSIR), Department of Atomic Energy (DAE), Defence Research and Development Organization (DRDO), Department of Science and Technology (DST), Ministry of Electronics and Information Technology) engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs);
    10. Rural development projects. 
    11. Slum area development (The term “Slum area” shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force). 
    12. Disaster management, including relief, rehabilitation and reconstruction activities. However, the following activities are excluded from considered as eligible CSR activity:
      1. Activities undertaken in pursuance of normal course of business of the Company.
      2. Any activity undertaken by the company outside India except for training of Indian Sports personnel representing any state or Union territory at national level of India at international level.
      3. Contribution of any amount directly or indirectly to any political party under section 182 of the Act.
      4. Activities benefitting employees of the company as defined in clause (k) of section 2 of the code on wages, 2019.
      5. Activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services.
      6. Activities carried out for fulfilment of any other statutory obligations under any law in force in India.
  2. APPLICABILITY Corporate Social Responsibility is required for all companies viz. private limited company, limited company. These companies are required to form a CSR committee consisting of its directors. This committee oversees the entire CSR activities of the Company. Criteria: If any of the below financial strength criteria are met, the Corporate Social Responsibility (CSR) provisions and related rules will be applicable to the company.
    • Companies with a net worth of Rs. 500 crores or greater, or
    • Companies with a turnover of Rs. 1000 crores or greater, or
    • Companies with a net profit of Rs. 5 crores or greater.Presently, SIDS will fall in this category due to third criteria as above and therefore needs to comply with CSR requirement. 
  3. MEASURESIn the aforesaid backdrop, policy on CSR of SIDS is broadly framed taking into account the following measures:
    • The CSR activities shall be undertaken by SIDS as stated in this Policy, as projects or programs or activities (either new or ongoing projects), excluding activities undertaken in pursuance of its normal course of business.
    • SIDS shall give preference to the local area or areas around it where it operates, for spending the amount earmarked for CSR activities.
    • SIDS may collaborate with other companies for undertaking projects or programmes or CSR activities in such a manner that the CSR committees of respective companies are in a position to report separately on such projects or programmes in accordance with these rules.
    • SIDS may engage international organisations for designing, monitoring and evaluation of the CSR projects or programmes as per its CSR policy as well as for capacity building of their own personnel for CSR.
    • In case of ongoing project, the Board of the 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. 
  4. ROLE OF BOARD OF DIRECTORS IN CSRThe Board of directors plays a significant role in CSR activities of the Company. The role of SIDS Board is as follows:
    • Approval of the CSR policy.
    • Ensuring its implementation.
    • Disclosure of the contents of CSR policies related to its report.
    • Placing the same on Company’s website, if any.
    • Ensuring that amount specified as per law is spend by the company with reference to CSR activities.
    • Satisfy itself regarding the utilization of the disbursed CSR funds and the Chief Financial Officer or the person responsible for financial management shall certify to the effect. 
  5. ORGANIZATIONAL MECHANISM AND RESPONSIBILITIES
    1. Constitution of Corporate Social Responsibility Committee:Where the amount to be spent by a company under section 135(5) does not exceed fifty lakh rupees, the requirement under section 135(1) for constitution of the Corporate Social Responsibility Committee shall not be applicable and the functions of such Committee provided under this section shall, in such cases, be discharged by the Board of Directors of such company.*Note: The Board shall hereinafter be referred to as CSR Committee. The CSR Committee shall-
      1. Formulate and recommend to the Board, activities to be undertaken by the company in areas or subject as per Schedule VII;
      2. Recommend the amount of expenditure to be incurred on the above activities; and
      3. Monitor the CSR Policy of the Company from time to time.
      4. Formulate annual action plan in pursuance of the CSR Policy in accordance with the applicable law, and inclusive of the following items: 
        1. the list of CSR projects or programmes, that are approved to be undertaken in areas or subjects specified in Schedule VII of the Act;
        2. the manner of execution of such projects or programmes;
        3. the modalities of utilisation of funds and implementation schedules for the projects or programmes;
        4. monitoring and reporting mechanism for the projects or programmes;
        5. details of need and impact assessment, if any, for the projects undertaken by the company.
       Provided that the 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. 
    2. Frequency of MeetingsThe meetings of the CSR Committee could be held at such periodic intervals as may be required. 
    3. QuorumMinimum two (2) Directors shall constitute quorum for the CSR Committee meeting. 
    4. ChairmanIn the absence of the Chairman, the members of the CSR Committee present at the meeting shall choose one amongst them to act as Chairman. 
    5. Minutes of CSR Committee Meeting
    Proceedings of all meetings must be recorded and signed by the Chairman of the CSR Committee and tabled at the subsequent Board meeting. 
  6. PROJECTS, PROGRAMS AND ACTIVITIESThe CSR Committee shall identify and evaluate areas of intervention where funding of CSR activities is required and projects will be prioritized by assessing their impact. The CSR committee will then forward its recommendations to the CSR Committee. The CSR Committee will then assess the proposals and approve proposals for implementation at its discretion. 
  7. CSR IMPLEMENTATIONSIDS may undertake CSR activities through three modes of implementation:
    1. Implementation by itself; or
    2. Implementation through eligible implementing agencies; or
    3. Implementation in collaboration with one or more companies.
  8. CSR BUDGET/ EXPENDITURE
    1. In every financial year, the Company shall spend atleast 2 (two) % of the average net profits of the Company made during the three immediately preceding financial years, in pursuance of this policy.
    2. In any financial year, if CSR spending could not be achieved, the Company shall in its Board’s Report specify the reasons for not spending the amount and unless the unspent amount relates to any ongoing project, transfer such unspent amount to a Fund specified in Schedule VII of the Act within a period of 6 months after expiry of the financial year.
    3. In any financial year, if any amount remains unspent pursuant to any ongoing project, shall be transferred within a period of 30 days from the end of the financial year into a separate bank account called “Unspent Corporate Social Responsibility Account” and such amount will be utilised within a period of three consecutive financial years, failing which, the Company need to transfer to any fund specified under schedule VII of the Act with in a period of 30 days from the date of completion of 3rd financial year.
    4. If in any financial year, the Company spends more than 2% of average net profit of three immediately preceding years as mandated by the Act, the excess amount can be carried forward and set off against the requirement up to immediate succeeding three financial years subject to the conditions that the excess amount available for set off shall not include the surplus, if any, arising out of the CSR activities and the Board of the Company shall pass a resolution to that effect.
    5. Any surplus arising out of the CSR activities shall not form part of the business profit of the company and may only be re-allocated to the CSR Activities being undertaken in terms of this CSR Policy and the annual action plan for the financial year in which such surplus has arisen.
    6. SIDS may incur expenses towards general management and administration of CSR functions as “administrative overheads”. However, such administrative overheads shall not exceed 5 (five) percent of total CSR expenditure of the Company for the financial year.
    7. CSR Committee shall recommend CSR budget to Board every year by September for that financial year. HOD-Finance shall be responsible for calculation of CSR budget as per Section 135 of the Companies Act, 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014 and Schedule VII of the Companies Act, 2013 and any further amendments therein.
  9. INFORMATION DISSEMINATIONSIDS need to disclose CSR Policy, Committee Composition, projects approved by the Board on its website, if any.
  10. MANAGEMENT COMMITMENTOur Board of Directors, our management and all of our employees subscribe to the philosophy of compassionate care. We believe and act on an ethos of generosity and compassion, characterized by a willingness to build a society that works for everyone. This is the cornerstone of our CSR policy.
  11. REPORTING & REVIEWThe CSR Committee will review the policy from time to time and is empowered to amend or modify the CSR Policy and such changes shall be placed before the Board for its approval. The Board may subject to compliance with applicable law, at any time approve or alter, amend or modify the CSR Policy, as it deems fit to comply with the statutory obligation to undertake the CSR Activities. 
  12. RECORD KEEPING
    1. All relevant statutory records pertaining to the CSR shall be kept by the Company Secretary.
    2. All other records pertaining to CSR programs/projects/activities of the Company shall be kept by the Secretary.
    3. The documents to be preserved till a period of 8 years unless prescribed any other retention period as per law.
  13. CSR REPORTINGSIDS shall make appropriate disclosure as revised under the Act, laws or rules as may be applicable from time to time, including an Annual Report on CSR activities in the Board’s Report of the Company for every financial year in the format as prescribed in Annexure-1 or as amended from time to time.
  14. GRIEVANCE REDRESSAL MECHANISM

Anyone who wants to raise grievance under this Policy, should reach out to the Compliance Officer, at sidshospital.acc@gmail.com (“Grievance Redressal Officer”). The board of directors of the Company shall authorize the CEO of the Company to approve any appointment, removal or change the Grievance Redressal Officer under this Policy, whenever any such change is required for any reason whatsoever.

COMPOSITION OF CORPORATE SOCIAL RESPONSIBILITY COMMITTEE

S. NoName of DirectorCategoryPosition
1Dr. Dhaval MangukiyaDirectorChairman
2Dr. Keyur BhattDirectorMember
3Dr. Rajiv MehtaDirectorMember