Corporate Social Responsibility Policy

PART I - CSR POLICY

A. Company Overview

As a conscientious corporate citizen, ACL Mobile Private Limited (“Company”) recognizes its role and responsibility to address some of India’s most pressing challenges.

We are a private limited company engaged in providing telecommunications and cloud communications platform as a service to enterprises.

Business of the Company primarily includes:

  • Messaging, Voice, and Email Services 
  • WhatsApp, Chatlayer, and Sinch Engage
  • Axiom and Credence

The Company is committed to provide innovative, affordable and customer friendly services that enable people to connect and communicate or transact in a seamless manner. The services are provided to enterprises, globally. The Company aims to lead the path not only through products and services, but also via sustainability and CSR initiatives. We remain committed to act responsibly and ethically to maintain the trust of our employees, customers, and investors.

 

B. CSR Programs  The Company’s CSR Policy is effective from May 5, 2018, and was last updated on April 30, 2023.

The Company understands that while there are positive impacts of connectivity, there is an equally pressing necessity to mitigate the environmental and social impacts of telecom services. 

The Company’s programs are aligned with national development priorities, need of communities, and schedule VII of Section 135 of the Companies Act 2013. In all our CSR programs, we encourage use of technology, employee volunteerism, partnership and innovation.

The Company endeavours to have long term CSR programs in the following domains: 

Education:

Support for promotion of education of all kinds (school education, technical, higher, vocational and adult education), to all ages and in various forms, with a focus on vulnerable and under-privileged, particularly for the girl child.

Health, Hygiene and Sanitation:

• Ambulance services, mobile medical units, health awareness programmes and camps, medical check-ups, HIV/AIDS awareness initiatives, health care facilities and services, sanitation facilities.

• Eradicating hunger, poverty and malnutrition, promotion of preventive health care and sanitation, and making available safe drinking water.

Community Development:

Encouraging youth and children to form clubs and participate in community development activities such as like cleanliness drives, plantation drives, awareness drive - precautions while using the internet, etc.

Environmental Sustainability:

• Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro-forestry, conservation of natural resources and maintaining quality of soil, air and water and e-waste disposal.

• Ensuring safety, privacy and security of customer information.

Gender Equality and Empowerment of Women:

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

 

C. Implementation

The Company implements its CSR programs through implementing agencies. While executing CSR activities, the Company ensures that such activities are not in normal pursuance of its business. 

The Board and the CSR Committee ensure that implementing agencies are entities registered as Trusts or Society or company or Section 8/Section 25 company or certified technology incubators or through collaborative projects with other corporates.

These agencies are screened based on screening criteria articulated in the Company’s CSR - Standard Operating Procedure to ascertain the agencies’ credibility and its ability to execute the proposed programs. The CSR Team oversees implementation and monitoring of all CSR programs. 

 

D. Governance The approval of the CSR policy and overall oversight is the responsibility of the Company’s Board of Directors. The responsibility of the CSR Committee is to promote the strategy and administer and execute the CSR policy through implementing agencies.

The CSR Committee ensures that programs are compliant with this policy and are monitored and reported effectively. 

Roles and Responsibilities:   

Board of Directors of the Company are responsible for: 

1. Approval of the CSR Policy of the Company.

2. Disclosing the content of the CSR Policy in its report and place the CSR Policy on the Company’s website in such a manner as prescribed under Section 135 of the Companies Act 2013 read with the CSR Rules.

3. Ensuring that the Company spends, in every financial year, at least two percent of the average net profits of the Company made during the three immediately preceding financial years.

4. Ensuring that it specifies the reasons in its report for not spending the earmarked amount in case the Company fails to spend such amount during the financial year.

 5. And, shall have the power to make any change(s) in the CSR Committee’s constitution.

CSR Committee is responsible for:

1. Revising and modifying the CSR Policy and placing the same before the Board of Directors for their approval. 

2. Ensuring that the programs, projects and activities supported through the Company are aligned with the CSR Policy and are also aligned to the activities prescribed in Schedule VII of Companies Act 2013. 

3. Reviewing and approving annual budgets with respect to CSR programs.

4. Ensuring that unspent amounts are transferred to the Company’s CSR Unspent Account in compliance with Schedule VII of Companies Act 2013, in the event that the Company is unable to spend two percent of the average net profits of the last three financial years or any part thereof.

5. Preparing the annual CSR report to be filed by the Company on approval of the Board. The CSR Committee to ensure that:

  1. CSR programs are being properly documented.
  2. An MIS is maintained on expenditure and beneficiaries impacted. The MIS structure is in alignment with the prescribed reporting format.
  3. Accountability is fixed at each level of CSR process and implementation.
  4. A repository of case studies and good practices are maintained.

6. Developing and institutionalizing a CSR reporting mechanism under with Section 135 of the Companies Act 2013 read with Rule 8 of the CSR Rules framed thereunder. 

7. Responding to any query, observation or clarification sought by the Ministry of Corporate Affairs or any other regulatory authority with regard to CSR programs supported. 

8. Ensuring that the Company’s website displays the approved CSR Policy. 

9. Reviewing the findings and recommendations from any investigation or audit by regulatory agencies or external auditors or consultants concerning the Company’s CSR matters.

 

E. CSR Expenditure

CSR expenditure will include all expenditure, direct and indirect, incurred by the Company on CSR programs undertaken in accordance with the approved CSR Policy. Accordingly, any income arising from CSR programs will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.

 

PART II - CSR COMMITTEE

The CSR Committee of the Board is responsible for overseeing the execution of the Company’s CSR Policy and dispersal of CSR funds.

As on 15 March 2023, CSR Committee comprises of:

  1. Mr. Nitin Singhal, Chairman
  2. Mr. Bjorn Zethraeus, Member

 

PART III - CSR PROJECTS

Pustakalaya

In an effort to support long-term projects that add value to communities, the Company is going strong with the Pustakalaya Project in South Delhi Municipal Corporation (SDMC) schools. The initiative, in collaboration with Anandaya Foundation (formerly known as Angelique Foundation), and the Municipal Corporation of Delhi (MCD), attempts to help students from economically weaker sections access educational resources within a functional, comfortable, and motivating environment. These libraries or Pustakalayas are equipped with proper furniture and appropriate books. The aim is to enable each child to cultivate reading, comprehension, and expression skills.

In Financial year 2020-21, the Company sponsored 52 SDMC schools by providing them with equipped and functional Pustakalayas with training being conducted for 100 teachers and students. In Financial Year 2022-23, the Company has further committed to develop 34 new libraries in NDMC schools in Delhi area.

Impact of the project

With the MCD at its helm, the project is sustainable. The MCD has been supportive by providing a dedicated room in SDMC schools for a library, by ensuring its upkeep and adding new books purchased out of the school’s allocated budget. Owing to the project’s success, there has been a clear change in the mindset of the MCD as also the community.

Navgurukul

In an effort to support welfare of the underprivileged, the Company is sponsoring and supporting girls, women and those identifying as trans women in the age group of 17-30 years to acquire technology skills. The initiative called Navgurukul, is in association with state governments of Tripura and Delhi. The target segment in both the campuses of Tripura and Delhi are matriculate women from rural or semi-urban areas but preference has been to take in candidates from under-served communities.

The Company has sponsored education of 45 students at Tripura campus which, was started in November 2021 and 55 students at the Delhi campus which, kickstarted in April 2022.

Sinch India Students photo

Impact of the project

Between November 2021 and April 2023, several activities were conducted which included the pre-campus set-up, onboarding, induction, orientation, training on technology, soft skill training, cultural and community sessions, engagement, and activities.