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|1||Mr. Dipak Gupta Director||Chairman|
|2||Mr. Prakash Apte, Independent Director||Member|
|3||Mr. Gaurang Shah, Director||Member|
|Document Reference No.||PARM/22-23/31|
|Document Issue Date||28/10/2022|
|Process Owner||Subhasis Ghosh, joint president,FIG|
|Reviewed by||Himanshu Nivsarkar||Whole Document||EVP, CSR, Kotak Mahindra Group||17/08/2022|
|Approved by||CSR Committee||Whole Document||-||18/10/2022|
|Approved by||Rohit Rao||Whole Document||-||19/10/2022|
|18/04/2016||V.1.1.1||Neha Mathur|| Whole
|This policy has been approved in the 79th Board Meeting dated 03/02/2015. Post which, it has been reviewed in the 81st Board Meeting dated 28/07/2015. Post which, it has been reviewed in the Board Meeting dated 26/04/2019.|
|20/04/2020||V.2.1.1||Rohit Rao|| Whole
|Entire policy revamped
to bring it in sync with
the Kotak Group level
This policy has been reviewed by Board in its meeting dated 29/04/2020
|11/08/2020||V.3.1.1||Rohit Rao||CRS Focus Areas||'Relief & Rehabilitation(COVID)' included in the scope of KLI's CSR focus areas.
This policy has been reviewed by Board in its meeting dated 22/07/2020
|20/10/2021||V.4.1.1||Rohit Rao|| Whole
|Entire policy revamped in view of the amendment to the companies (CSR) Amendment Rules,2021 and to align it in with the Kotak Bank's policy
This policy has been reviewed by Board in its meeting dated 20/10/2021
|No changes in the policy.
This policy has been reviewed by Board in its meeting dated 19/10/2022
KLI’s CSR Policy is within the scope of the CSR mandate as specified under Sections 134(3)(o), and 135 read with Schedule VII of the Act, the CSR Rules, 2014, as amended from time to time and as per the Government of India’s notifications issued from time-to-time and would be guided by permissible activities, viz.....:
Provided that the CSR activities undertaken by KLI, as stated above, shall not include the following:
(i) Activities undertaken in pursuance of normal course of business of KLI;
(ii)Activities undertaken by KLI outside India except for training of Indian sports personnel representing any State or Union Territory at National level or India at an International level;
(iii) Contribution of any amount directly or indirectly to any political party under Section 182 of the Act;
(iv)Activities benefitting employees of KLI as defined in Clause (k) of Section 2 of the Code on Wages, 2019;
(v)Activities supported by KLI on sponsorship basis for deriving marketing benefits for its products or services;
(vi)Activities carried out for fulfilment of any other statutory obligations under any law in force in India.
This policy is to be reviewed every year by CSR Committee and the Board of Directors.
To improve the quality of life of the communities through positive impacts on economic, social and environmental parameters and in alignment with India’s social development objectives and UN’s SDGs.
To create a lasting value for communities in need by promoting and supporting education, livelihood, healthcare, sports and environmental and sustainable development initiatives and others including reducing inequalities faced by socially and economically backward groups, relief and rehabilitation, and interventions towards an educated, employed, healthier and a cleaner India with an aim to serve communities at large and to transform their lives, in a collaborative manner by partnering with internal and external stakeholders.
KLI has an established CSR Committee which is responsible for the overall governance of CSR. The CSR Committee comprises of three (3) or more directors, out of which one (1) is an Independent Director.
While the CSR Committee will be responsible to review and approve of project /programmes under KLI’s CSR Policy [and the approved annual actual plan] KLI’s CSR head and his/her team will be responsible for execution of CSR Project / Programmes, which at all times will be within the scope of KLI’s CSR policy, the annual action plan, and the Act.
The CSR Committee will also be responsible for formulating an annual action plan in consonance with this CSR policy and recommending such annual action plan to the Board. The annual action plan shall include the following information:
(i) A list of CSR projects or programmes that are approved to be undertaken by KLI or subjects specified in Schedule VII of the Act;
(ii) The manner of execution of such CSR projects and programmes;
(iii) The modalities of utilization of funds and implementation schedules for the projects or programmes;
(iv) Monitoring and reporting mechanism for the projects or programmes; and
(v) Details of need and impact assessment, if any, for the projects undertaken by KLI
Based on the recommendations of the CSR Committee and reasonable justification, the Board shall approve the Corporate Social Responsibility Policy for KLI and have the right to alter such annual action plan at any time during a Financial Year.
1. Appropriate documentation of KLI’s CSR Policy, annual CSR activities, executing partners, and expenditure entailed will be undertaken on a regular basis and the same will be available in the public domain.
2. CSR initiatives of KLI will also be reported in the Annual Report of KLI.
3. This CSR Policy shall be uploaded on KLI’s website for information of all stakeholders.
This CSR Policy Statement is effective from October 20, 2021 and supersedes all earlier KLI’s CSR Policy Statements.
In the event of any variation or inconsistency between the provisions of this Policy and applicable law, the provisions of the applicable law shall prevail over this Policy and the provisions of this Policy shall be deemed to have been amended so as to be read in consonance with such applicable law.
The Company, at all times, is committed to:
Given the enormity of India’s social development requirement, KLI will either directly implement its CSR projects and programmes, and /or partner with eligible organisation meeting the minimum criteria as set out under the heading ‘Implementing Partner Organisation’
CSR Projects undertaken, executed and implemented by itself (KLI) under its Direct CSR Projects may include engagement and involvement of all stakeholders including employees, across Indian geography, and for the purpose of implementation and monitoring, KLI may also engage third party organisations / consultants etc. However, for KLI’s Direct CSR Projects, the onus of responsibility on implementing and monitoring rests with KLI.
CSR Project Implementing Partner in the CSR context means KLI joining-hands (partner) with an NGO to implement its CSR Projects i.e., KLI CSR Projects funded by it, thus, KLI is CSR funding partner, and implemented by / through the partner organization, thus, an implementing partner). Further, it is clarified that KLI’s responsibility and liability is restricted to impact outcomes of its CSR Projects only, and in no manner will KLI be responsible or held liable for any acts of omission and commission, and such other civil and criminal liabilities of its implementing partner organisations.
As per development sector practice and for convenience, KLI will refer to all its implementing partners as organisations and / or NGOs and / or NPOs unless otherwise specified in this CSR Policy.
The Board shall ensure that the CSR activities are undertaken by KLI itself or through any of the following entities registered with the Central Government under the CSR Rules:
(a) A company established under section 8 of the Act, or a registered public trust or a registered society, registered under Sections 12A and 80 G of the Income Tax Act, 1961, established by the company, either singly or along with any other company, or
(b) A company established under Section 8 of the Act, or a registered trust or a registered society, established by the Central Government or State Government; or
(c) Any entity established under an Act of Parliament or a State legislature; or
(d) A company established under Section 8 of the Act, or a registered public trust or a registered society, registered under Sections 12A and 80G of the Income Tax Act, 1961, and having an established track record of at least three (3) years in undertaking similar activities.
KLI may engage International Organisation(s) for designing, monitoring and evaluation of the CSR projects or programmes as well as for capacity building of its personnel for CSR.
The Corporate Social Responsibility Committee of the Board of Directors of Kotak Mahindra Life Insurance Company Limited (“CSR Committee”) will ensure a transparent monitoring mechanism for ensuring effective implementation of the projects / programs/ activities proposed to be undertaken by KLI.
The CSR Committee would be responsible for monitoring the approved projects and/or programmes and would ensure that the funds are utilized for the approved purpose to the satisfaction of the Board of Directors of KLI in the manner approved by it and shall be certified by the Chief Financial Officer or the ‘person’ in charge of financial management.
Monitoring mechanisms may include visits, meetings and progress/status reporting by the project/programme teams. KLI’s CSR activities will be regularly reviewed by the CSR Committee. A system will be put in place to maintain a transparent monitoring and reporting mechanism across all the stakeholders involved in the CSR activities of KLI, as required under Section 135 read along with Schedule VII of the Act and the CSR Rules, 2014 as amended from time to time and in line with the Government of India’s notifications issued from time to time.
In case of a multi-year project, having timelines not exceeding three (3) years excluding the Financial Year in which it was commenced, undertaken by KLI in fulfillment of its CSR obligations (including projects that was initially not approved as a multi-year project but whose duration has been extended beyond one year by the Board) (“Ongoing Project”), the Board shall monitor the implementation of such CSR project with reference to the approved timelines and year-wise allocation. The Board may also make modifications, for smooth implementation of such project within the overall permissible time period.
The Board shall ensure that in every financial year, KLI spends at least two (2) % of its average net profits made during the three (3) immediately preceding financial years in pursuance to the provisions of this CSR Policy and in accordance with Section 135 read with Schedule VII of the Act and CSR Rules, 2014, as amended from time to time.
In the event that any CSR funds remain unspent, the Board in its report made under Section 134(3)(o) of the Act, shall specify the reasons for not spending the said amount. However, if such unspent CSR funds do not relate to any Ongoing Project, as mentioned below, such unspent funds shall be transferred to an account specified under Schedule VII of the Act, within a period of six (6) months of the expiry of the financial year.
In the event that any CSR funds remain unspent pursuant to an Ongoing Project, KLI shall transfer such unspent CSR funds to its Unspent Corporate Social Responsibility Account, within 30 (thirty) days from the end of the Financial Year. Such unspent CSR funds shall then be spent in accordance with the terms of this CSR Policy within a period of three (3) Financial Years from the date of such transfer, failing which, KLI shall transfer the same to a Fund specified in Schedule VII of the Act, within a period of thirty (30) days from the date of completion of the third financial year.
Any surplus arising out of the CSR activities carried on by KLI, shall not comprise of the business profit of KLI and shall be dealt with in the following manner:
(i) Surplus to be ploughed back either into the same CSR project and/or programme; or
(ii) Surplus to be transferred to the Unspent CSR Account and spent in pursuance of this CSR Policy and the annual action plan of KLI; or
(iii) Surplus to be transferred to a Fund specified under Schedule VII of the Act, within a period of 6 (Six) months of the expiry of the financial year.
In the event that KLI spends an amount in excess of the requirement provided under Section 135(5) of the Act, such excess amount may be set-off against the requirement to spend under Section 135(5) of the Act, up to immediate succeeding three (3) financial years subject to the conditions that such excess amount shall not include surplus arising out of the CSR activities and the Board shall pass a resolution to that effect.
The CSR funds may also be utilized for creation or acquisition of capital asset, to be held by either the beneficiaries of the CSR project such as entities, collectives or self-help groups; a public authority; or a company incorporated under Section 8 of the Act or a registered public trust, registered society with a charitable objective and a CSR registration number.
The Board shall satisfy itself that the disbursed funds have been utilized for the purposes and in the manner approved by it and the Chief Financial Officer or the person responsible for financial management shall certify to the effect.
The Board’s report pertaining to any Financial Year containing details of the CSR initiatives taken during such Financial Year, would include an annual report on CSR in the form and manner prescribed under Section 135 read with Schedule VII of the Act read along with the CSR Rules, 2014 as amended from time to time and in line with the Government of India’s notifications issued from time to time.
Where in any Financial Year, KLI has an average CSR obligation of Rupees Ten Crore or more, KLI shall undertake impact assessment of its CSR projects and/or programmes having outlays of Rupees One (1) crore or more and which have been completed not less than one (1) year before undertaking the impact assessment, through an independent agency. The impact assessment reports shall be placed before the Board and also annexed to the annual report on CSR.
While KLI will endeavour to implement its projects and programmes in and around geographies where it carries its business and operations, KLI may also implement its CSR programmes and/or projects either directly or with partner NGOs in any geography but within the India to serve and support the needy people and/or towards nation building.
KLI has defined CSR Focus Areas to make a concerted effort to achieve a meaningful and measurable social impact. On a case-to-case basis, the CSR programmes and/or projects which are outside KLI’s defined six CSR Focus Areas but are eligible CSR activities under Section 135 read with Schedule VII of the Act, and the CSR Rules, 2014 as amended from time to time and in line with the Government of India’s notifications issued from time-to-time, shall be approved by the CSR Committee.
Through its CSR focus area - Education & Livelihood, KLI will endeavor to enhance the accessibility and affordability of quality education for deserving underprivileged sections of society including special education for the differently abled children and youth.
KLI’s programmes and/or projects on Education will focus on providing financial and other resource support to educational institutions comprising infrastructure, buses, scholarships and coaching to children, teachers, headmasters, principals, administrators and trustees and parents and guardians to cater a holistic learning environment for children at school and home. The activities will also include providing mid-day meals and creating relevant infrastructure such as specialized food delivery vans, utensils, kitchens, warehouses etc. and other required nutrition and health related support to the children.
KLI’s Livelihood programmes and/or projects will work towards imparting vocational skills and development training courses to children, youth, women, war widows, war veterans, elderly, and the differently-abled including school and college dropouts or anyone who never had any formal education (illiterate) through technical, soft and trade and commerce skills which will help them earn a livelihood and/or enhance their livelihood in rural, semi urban.
KLI may also undertake any other programmes and/or projects which would focus on the education sector and/or livelihood sector, as may be approved by the CSR Committee.
Through its CSR focus area – Healthcare, KLI will undertake projects and programmes directly and/or through implementing partners working in the healthcare and sanitation domain including but not limited to improving access to healthcare facilities by providing ambulances, screening vans and mobile health units etc.
KLI will undertake projects and programmes in the fields of healthcare, sanitation, eradication of hunger and malnutrition, and provision of access to safe drinking water. The CSR projects and/or programmes will aim to provide preventive and curative care and also palliative care, health check-up camps to various age groups to spread awareness for prevention and cure of cancer, HIV/AIDS, tuberculosis, malaria, and other communicable and non-communicable diseases and illnesses. KLI will also undertake projects and programmes to sensitize communities on personal and community health and hygiene. To give life a fighting chance, KLI will promote, encourage and implement blood and organ donations.
KLI may also undertake any other programmes and/or projects which would focus on the healthcare sector, as may be approved by the CSR Committee.
Through its CSR focus area – Environment and Sustainable Development, KLI will partner with NGOs working in the area of maintaining ecological balance, protection of flora and fauna, animal welfare, agriculture, agro forestry, forestry, conservation of natural resources and maintaining quality of soil, air and water.
KLI will also invest in projects and programmes for water conservation, rain water harvesting, adopting green technologies, waste reduction and recycling including effluent treatment, and reusing (3Rs) and promote, encourage and use alternate energy. Further, KLI will undertake projects and/or programmes with NGO partners that are committed to and work in areas of Environmental, Social and Governance (ESG), Sustainability, SDGs and CSR either through direct activities or in the form of advisory, policy advocacy and stakeholder awareness programmes either directly or with eligible institutions under the CSR mandate.
KLI may also undertake any other programmes and/or projects which would focus on the environment and sustainable development sector, as may be approved by the CSR Committee.
Corona Virus (COVID-19) has been declared as pandemic by the World Health Organisation (WHO), and Government of India has treated this as a notified disaster. The spread of COVID-19 in India has been widespread. Economic and social impact of the pandemic has been equally significant. Many of these issues require sustained and long term CSR support. Thus, KLI may undertake and support various relief and rehabilitation activities related to COVID-19 including item nos. (i) and (xii) of Schedule VII of the Act relating to promotion of health care, preventive health care and sanitation, and disaster management or under such other areas as may be specified by the Ministry of Corporate Affairs from time to time in this regard. Such CSR projects and/or programmes may aim to provide immediate response to reduce or avoid potential spread of disease and losses resulting from same, assure prompt and appropriate assistance to victims of the pandemic or resulting lockdowns. KLI may also undertake projects and programmes that engage with the community for long-term rehabilitation solutions including but not limited to focusing on livelihood enhancement, providing shelter and infrastructure for education and health services to achieve rapid and effective recovery.
In case of other calamities, pandemic or a notified disaster, KLI may commit significant portion of the CSR funds towards disaster management projects and programmes for dealing with humanitarian aspects of emergencies in particular preparedness, response and recovery in order to lessen the impact of disaster either directly and/or through implementing partners working in relief, rehabilitation and reconstruction domain, providing immediate and long term solutions, during and after a disaster with the purpose to avoid a disaster, reduce its impact or recover from its losses including but not limited to providing essential relief material such as safe drinking water, meals, clothes, medical aid & camps, and supply of daily essentials to the affected communities.
KLI may also undertake any other programmes and/or projects which would focus on the Relief & Rehabilitation (COVID-19), as may be approved by the CSR Committee.
A significantly high percentage of Indian children and youth are from the underprivileged and less privileged segment where basic education and sports education including training and coaching is not available. Sport is an activity for children and youth, and is often used as a draw card to recruit children and young people to health and education programmes. Sport development projects that focus on educational outcomes use sport as a means to deliver educational messages to participants and spectators in some cases.
The United Nations is using sport and games related projects and programmes to encourage young people, particularly girls and young women, to attend school within refugee camps across the world. The United Nations Children's Fund (“UNICEF”) also lays strong emphasis on ‘sport’ while campaigning for girls’ education, promoting education through events and other awareness campaigns.
India has a severe dearth of training and coaching facilities for sports training for the underprivileged and less privileged segment. Through its CSR Programme on Sports, KLI will either directly or with/through NGOs impart training and coaching programmes as well as work towards development of infrastructure and training facilities to enable children, youth and adults who cannot play, get training opportunities for them to take up rural sports, nationally recognised sports, international and world championships, Olympics and Para Olympics.
KLI may also undertake any other programmes and/or projects which would focus on the sports sector, as may be approved by the CSR Committee.
KLI’s priority will be to implement CSR projects and programmes which come under CSR Focus areas as defined in this CSR Policy statement, but it will not be restricted to these defined CSR focus areas only. On a case to case basis, KLI may also consider undertaking CSR programmes and/or projects on CSR focus areas which are eligible under Section 135 read with schedule VII of the Act along with the CSR Rules, 2014 as amended from time to time and in line with the Government of India’s notificationsissued from time-to-time and as may be approved by the CSR Committee.
As per the provisions of the CSR Rules the Board shall ensure that the administrative overheads (the definition has been set out below) shall not exceed five percent of total CSR expenditure of KLI for the financial year.
Meaning and scope of ‘Administrative Overheads’ for CSR as defined under the CSR Rules
“Administrative overheads” means 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
|CSR Project Unique ID||CSR Focus Area/ CSR Project||Implementing Partner / Direct Implementation||CSR Project -Other than ongoing /Ongoing||Location|
|01||Education & Livelihood||Kotak Education Foundation||Other than Ongoing||Mumbai||Maharashtra|
|02||Healthcare||Wockhardt Foundation||Other than ongoing||Kolkata, Bangalore and Chennai||West Bengal, Karnataka and Tamil Nadu|
|03||Relief & Rehabilitation COVID-19||Annamrita Foundation||Other than ongoing||Mumbai||Maharashtra|
|04||Relief & Rehabilitation – COVID-19||Direct Implementation||Other than ongoing||Chennai, Coimbatore, Madurai & Thanjavur Baidyabati||Tamil Nadu and West Bengal|
|05||Healthcare||Eastern India Heart Care & Research Foundation||Ongoing||Kolkata||West Bengal|
|CSR Project Unique ID||CSR Focus Area/ CSR Project||Implementing Partner||CSR Project -Other than ongoing /Ongoing||Location|
|KLI202122001||Relief & Rehabilitation – COVID-19||Direct Implementation||Other than ongoing||Kolkata||West Bengal|
|KLI202122002||Healthcare||Wockhardt Foundation||Ongoing||Kolkata, Bangalore and Chennai||West Bengal, Karnataka and Tamil Nadu|
|KLI202122003||Healthcare||Eastern India Heart Care & Research Foundation||Ongoing||Kolkata||West Bengal|
|KLI202122004||Healthcare||CanKids… KidsCan||Ongoing||Ahmedabad, Rajkot and Vadodara||Gujarat|
|CSR Project Unique ID||CSR Focus Area/ CSR Project||Implementing Partner||Location|
|KLI202223001||Healthcare||Eastern India Heart Care and Research Foundation||Kolkata||West Bengal|
|KLI202223002||Healthcare||Wockhardt Foundation||Chennai, Bangalore, Maysore||Tamil Nadu, Karnataka|
|KLI202223003||Healthcare||Maharogi Sewa Samiti||Chandrapur||Maharashtra|
|KLI202223004||Healthcare||Nana Palkar Smruti Samiti||Mumbai||Maharashtra|
|KLI202223005||Healthcare||Late Ratilal Devji Chawhan Charitable Trust||Palghar||Maharashtra|
|KLI202223006||Healthcare||Hindu Mission Hospital||Chennai||Tamilnadu|
|KLI202223007||Healthcare||Free Ophthalmic Hospitals Society||Mumbai||Maharashtra|
|CSR Project Unique ID||CSR Focus Area/ CSR Project||Implementing Partner||CSR Project -Other than ongoing /Ongoing||Location|
|KLI202324001||Healthcare||Gremaltes Referral Hospital And Leprosy Centre||Other Than On Going||Chennai||Tamilnadu|
|KLI202324002||Healthcare||Wockhardt Foundation||On Going||Mysore||Karnataka|
|KLI202324003||Healthcare||Smile Foundation||Other Than On Going||Chennai, Virudhunagar||Tamilnadu|