CORPORATE SOCIAL RESPONSIBILITY POLICY
Approved by the Board on March 20, 2025
1.Title and Applicability
OnEMI Technology Solutions Limited is a company, incorporated under the provisions of the Companies Act, 2013, Corporate Identification Number (CIN) U72900MH2016PTC282573 and having its registered office at 10th Floor, Tower 4, Equinox Park, LBS Marg, Kurla West Mumbai 400070 Maharashtra India ("OnEMI" or "Company"). The Company is, inter alia, engaged in the business of (i) providing financial technology solutions to enable use of instant EMI / instalment solutions to consumers, and in providing the technology platform to enable the above, (ii) providing customer acquisition services and loan origination services to financiers/lending partners. The Company has articulated this Corporate Social Responsibility Policy ("CSR Policy/Policy") in alignment with its objective, principles and values, delineating its responsibility as a socially and environmentally responsible corporate citizen. The Policy lays down the principles and mechanisms for undertaking various programs in accordance with the requirements provided under Section 135 of the Companies Act 2013, read with Schedule VII thereto and The Companies (Corporate Social Responsibility Policy) Rules, 2014 (together referred as "Act") including the Schedule VII to the Act and in line with the subsequent amendments released thereto by the Ministry of Corporate Affairs. The Policy shall apply to all the CSR projects, programs and activities undertaken by the Company at various locations in India for the benefit of diverse sections of the society.
2. Objective and Philosophy
The objective of the policy is to actively contribute to the social, environmental and economic development of the society in which the Company operates.
3. Approval of CSR Policy
The Board has approved this Policy. The Board may amend the Policy as may be required from time to time. The provisions of this Policy are subject to the applicable provisions of the Act and any subsequent amendments made thereto from time to time.
4. CSR Focus Areas
The Board may take up projects, programs or activities (“CSR activities”) as envisaged in Schedule VII of the Act, as it may deem expedient from time to time, which may include but not be limited to the following areas:
- (i) eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water.
- (ii) promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
- (iii) 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.
- (iv) 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.
- (v)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 art and handicrafts;
- (vi)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;
- (vii) training to promote rural sports, nationally recognised sports, paralympic sports and olympic sports
- (viii) contribution to the prime minister's national relief fund or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund)] or any other fund set up by the central government for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women;
- (ix) (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
- (ix) (b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense Research and Development Organisation (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).
- (x) rural development projects
- (xi) slum area development.
- (xii) disaster management, including relief, rehabilitation and reconstruction activities.
In case of any ambiguity as regards categorization of an activity as CSR, Board shall have the discretion to take a call on whether any activity falls within the entries above and in Schedule VII of the Act and its decision shall be final. The Company shall give preference to the local areas and areas around it where it operates, for spending the amount earmarked for CSR activities.
5. Governance Structure.
- The Board is the governing body that will articulate the scope of CSR Activities for the Company on recommendation from the Corporate Social Responsibility Committee (“CSR Committee”) and ensure compliance with the CSR Policy.
- 5.2 The Board shall: a) Formulate budget for spending the CSR expenditure during a financial year; b) Formulate the CSR Policy and make any amendments thereto; c) Indicate the CSR Activities to be undertaken by the Company as specified in the Act; d) Review the annual CSR plan; e) Monitor the CSR Activities and compliance with the CSR Policy from time to time; and f) Review and implement, if required, any other matter related to CSR initiatives.
6. Operating Framework.
6.1CSR Activities will be undertaken in areas identified by the CSR Committee. 6.2 CSR Activities shall be undertaken by the Company directly or through any implementing agencies as defined under the Act. 6.3. The CSR Committee shall be responsible for implementation of the identified CSR Activities/ projects. 6.4 The annual plan shall incorporate the following: • the list of CSR projects or programmes that are approved to be undertaken in areas or subjects specified in Schedule VII of the Act; • the manner of execution of such projects or programmes as specified in sub-rule (1) of rule 4; • the modalities of utilisation of funds and implementation schedules for the projects or programmes; • monitoring and reporting mechanism for the projects or programmes; and • details of need and impact assessment, if any, for the projects undertaken by the company.
7. Monitoring and Reporting.
The CSR Committee shall ensure a transparent monitoring mechanism for CSR Activities.
• The CSR Committee shall review the progress of CSR Activities periodically, including the annual review and report the same to the Board. • The CSR Activity/(ies) along with requisite information on the expenditure, etc. shall be reported every year in the annual report of the Company. • Form CSR – 2 shall be filed by the Company as per Rule 1B of Companies (Accounts) Rules, 2014.
• Review of the Policy
The Board shall review this Policy annually or on a need-basis i.e., in the event of change in regulatory framework or for business or operational need (whichever is earlier). Such updates / changes to the Policy will be communicated to the relevant staff/personnel (both in-house or outsourced) and relevant stakeholders across the Company.
Any deviations from this Policy can only be undertaken with the approval of the Board, unless specified otherwise in this Policy.
For OnEMI Technology Solutions Private Limited
Krishnan Vishwanathan Director
Approved by the Board of Directors at its meeting dated March 20, 2025.