JCB India CSR Strategy and Programme Outline

April 2021 to March 2022

Introduction:

JCB India initiated its corporate social responsibility intervention in the latter half of 2000 by supporting school children in a government school close to its Ballabhgarh factory. As the company celebrates its 2 decades of CSR work on the ground, this paper outlines the company’s present CSR outreach in alignment to Schedule VII, Section 135 of the Indian Companies Act and all related amendments. It is implemented through the following projects:

1. Creating a better quality of life for vulnerable communities (Implemented through the Lady Bamford Charitable Trust (Registered as a Trust under the Indian Trusts Act)
2. Revival and consolidation of traditional Indian heritage and craft (Implemented through the Lady Bamford Foundation (Registered as a Section 8 Company under the Companies Act)
3. Creating an environment to advance art and diversity of literature in India (Implemented through the JCB Literature Foundation (Registered as a Section 8 Company)
4. Enhancing project efficiency for social and economic welfare interventions (Implemented through projects implemented directly by the company

Programme and Implementation Overview:

For all projects and programmes, the community sits at the centre. Our projects are implemented with the objective of making these communities green, equal, resilient and diverse.

1. Creating a better quality of life for vulnerable communities works with the and through the following 3 verticals in communities in the hinterland of the JCB Group factories in Ballabhgarh, Pune, Jaipur and Vadodara (Halol). These have been commonly known by the stakeholders as the ‘3Es’:

    

• Education vertical – with the objective of universal access to quality education for children from vulnerable communities

   

• Employable Skills vertical – with the objective of providing comprehensive support for certified employable skills and income enhancement.

   

• Engagement with Community – with the objective of strengthening social and infrastructure systems within communities.

   

   

   

1. Revival and consolidation of traditional Indian heritage and craft works with and through the following activities in the traditional artisan communities with a special focus on handloom textiles and indigo dyeing. These are implemented through the following four verticals:

    

   • Revival and Mainstreaming Indian Craft traditions with a focus on natural dyes and hand-made textiles.

      

   • Strengthening the Value Chain for these artisan communities

    

   • Market facilitation for traditional artisanal craft skills

      

   • Centre of Excellence for interaction, promotion and showcasing the craft skills and traditions of India.

    

    

2. Creating an environment to advance art and diversity of literature in India works to promote the heritage and diversity of Indian literature with a focus on the vernacular through the following verticals:

    

• An annual award for contemporary Indian fiction

   

• Enhancing the prestige and success of contemporary Indian literature

   

• Research on the reading culture and publishing sector in India

   

• Strengthening the translation industry through skill enhancement

   

• Access to literature for vulnerable groups

   

   

1. Enhancing project efficiency for social and economic welfare interventions works to support and strengthen local infrastructure and governance. They include creation and maintenance of green spaces,contributions to emergency relief and rehabilitation, and any other projects that provide service delivery for social and economic welfare interventions, etc.

Need for undertaking the projects and project execution:

In the projected year, all CSR projects will be implemented through the above mentioned 4 projects. The projects will continue their objectives but revise targets and delivery mechanisms as per the LFAs.

All projects will follow the Logical Framework Analysis (LFA: https://en.wikipedia.org/wiki/Logical_framework_approach) for formulation and management of projects.

The process has already been initiated with 4 verticals from the above list. All project managers have been oriented to the LFA process and have begun working with their projects to undertake the same. The timeline for the comprehensive and integrated way ahead is as follows:

All projects implemented through the CSR entities will follow implementation schedules of the approved LFAs. Till such time as the approved LFA is ready for implementation, (as per above schedule, on or before 30^th September 2021) all existing projects will continue with post COVID rehabilitation work.

Each project will work as per its overall LFA project mandates, but will apply for and receive annual approvals for project continuation, project revisions if any and budgets.

All projects, LFAs, CSR compliances and CSR entities will be managed by the CSR team of JCBI, working directly downwards with the entity staff and reporting upwards to the project’s stakeholders/Trustees/Board Members/CSR Committee.

All projects implemented through JCBI Direct will be managed by the CSR team of JCBI working directly downwards with the selected partner and reporting upwards to the EVP Legal/HR/CSR Committee

Modalities of fund utilisation:

The budgets proposed for the above interventions for the next year – 2021-22 are as below.

Funds will be disbursed to the three CSR projects through monthly fund requests sent in by the project teams as per the LFAs adjusted against the existing fund utilisation.

Funds to projects under JCBI direct implementation will be disbursed as per their specific project plans and similarly adjusted against existing fund utilisation.

The donor will undertake quarterly expenditure reviews by a joint team of finance and CSR. This team will jointly set targets of fund utilisation quality control and work with the project teams to ensure fund utilisation for optimum impact.

Annual statutory audits and project wise internal audits will be undertaken by the donor.

All expenditure will follow a delegation of authority (DoA) that will be set in place as a standard operating procedure. The existing DoA will be reviewed and revised by Finance and the CSR team, based on an analysis of transactions and project requirements. This will be presented to the Trustees and Board Members and approved by this body. This DoA will be reviewed on an annual basis by the proposing team and approved/re-approved by the Trustees and Board also on an annual basis.

Monitoring and reporting mechanism:

This mechanism will include monitoring and evaluation (M&E) of projects as mandated by the approved LFA, impact assessments as required, all monthly quarterly, bi-annual and annual reports as mandated by the CSR framework.

The above mechanism will be run through an internal “M&E vertical” with resources drawn from the project staff. These will be staff who bring with them the required competency of undertaking such activities. They will undertake this in addition to their project delivery roles.

Further each project manager will retain direct responsibility of collecting, collating and providing on time M&E data to the M&E vertical. Cross entity and cross project reviews, process audits and impact assessments will also be undertaken to consolidate project efficiency and learning.

All the above data will also feed into a “Knowledge Management” vertical. This too will be an internal vertical structured like the M&E vertical. This Knowledge Management vertical will run annual cycles of working with project teams to incorporate project level learning as well as sectoral best practices into the next year’s activities and budgets.

The above remains a dynamic document and will be reviewed and revised on an annual basis and/or to align with legal amendments and/or any revisions that the board deems fit for purpose.

                        -------------------------------------------------------------------------

JCB INDIA LIMITED

REVISED POLICY ON CORPORATE SOCIAL RESPONSIBILITY (CSR) – March 17, 2021

The Corporate Social Responsibility Policy (‘’CSR Policy’’) of JCB India Limited (‘the Company’) has been formulated in accordance with and is subject to section 135 of the Companies Act 2013 and the rules made there under including Company (CSR) Rules, 2014 as amended from time to time (“CSR Laws”).The CSR Policy shall apply to all the CSR activities undertaken by the Company.

CSR Vision Statement

To work in partnership with communities and relevant stakeholders in order to benefit society through cooperation and the creation of shared value.

CSR Objectives

The CSR objective of the Company is to carry out CSR activities as aligned to the Schedule VII of the Companies Act, 2013 or any amendment thereof from time to time. The Company will, therefore, focus on the range of activities as mentioned in the same.

The CSR activities to be undertaken by the Company shall include:-

1. Efforts for the eradication of hunger, poverty and malnutrition, or the promotion of health 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 providing access to safe drinking water,

2. Promotion of education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood
    enhancement projects,

3. Promotion of 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;

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; including the promotion of Indian literary activities and literature created by authors of Indian origin.

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 recognised 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) or 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. 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.

10. 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);

11. Rural development projects;

12. Development of areas declared as “slum areas” by the Central Government or State Government or any other competent authority.

13. Disaster management, including relief, rehabilitation and reconstruction activities.

The Company would also seek to collaborate with duly registered entities as per the CSR laws and most importantly with the communities themselves to implement the above objectives.

CSR Programme Areas

The Company will focus on the areas as mentioned above.

In keeping with the larger body of development work in the country and the rapidly changing sector of CSR, the Company will also invest in relevant opportunities to add to and consolidate this work.

Validity of CSR Policy

The CSR policy as approved by the CSR Committee and the Board of Directors of the Company shall be implemented with immediate effect and shall be amended from time to time as may be required under the CSR Laws.

CSR Budget

The Board of Company shall ensure that in each financial year, the Company spends at least 2% of the average net profit made during the immediate three preceding financial years. Any unspent amount from out of the CSR Budget shall not form part of business profits of the Company. Any unspent amount from the CSR Budget (including any unspent amount in relation to ongoing projects) shall be transferred and/or utilized as per the CSR Laws.

In the event that the CSR activities of the Company generate a surplus out of the CSR activities, then, the surplus shall be transferred/ utilized by the Company as required under CSR Laws. If the Company spends an amount excess of requirement provided under Section 135, then, such excess amount shall be set off / treated as per the provisions of the CSR Laws

Implementation

The Company’s CSR projects will be implemented in a time-bound manner with clear objectives, plan, targets and robust monitoring and evaluation mechanisms.

This Policy builds on the learnings and good practices of the CSR projects initiated by the Company as well as the expertise of the development sector.

The Company may choose to undertake a multi-year project (an “Ongoing Project”) in fulfilment of its CSR obligations. The period and treatment of  such Ongoing Projects shall be as per the CSR Laws.

The Company will facilitate the coming together of the scale provided by the government, the development expertise provided by the NGOs, the mobilization provided by the agency of the communities and the core competencies of the corporate sector, to design and implement innovative, scalable and replicable models of CSR.

The Company will implement its CSR projects primarily through the following:

• Directly by the Company
• The Lady Bamford Charitable Trust, a trust registered under Section 12A and 80G of Income Tax Act, 1961;
• The Lady Bamford Foundation, a company established by the Company under Section 8 of the Companies Act, 2013, bearing CIN U74140DL2015NPL278759;
• JCB Literature Foundation, a company established by the Company under Section 8 of the Companies Act, 2013, bearing CIN U92490DL2018NPL331461;

In addition to the above, , the Company may also engage any entity as permitted and prescribed under Rule 4 of the Company (CSR) Rules to implement its CSR activities

The Company will select its partners after appropriate due diligence. It will use services of expert agencies, consultancy firms etc. wherever required for carrying out base line surveys, guidance on project design and implementation, impact assessment surveys etc.

The teams responsible for implementing the various CSR projects are mentioned in the section on the Governance Structure of the Policy.

The head of the CSR team in JCBI will be authorised to sign Memorandums of Understanding (MOUs)/Agreements with the implementing partners after taking due approvals.

In the event that the Company, pursuant to the CSR Policy or the Annual Action Plan, chooses to create or acquire a Capital Asset, it shall ensure that the same is acquired/held as per process and in the manner described under the CSR Laws

CSR Governance Structure

In accordance with the provisions of Section 135 of the Companies Act, 2013 and the rules made thereunder, the Company has constituted the CSR Committee of Directors, comprising of the following members:

The responsibility of the CSR Committee shall be to:

• Formulate and recommend the CSR Policy to the Board for approval. The Committee shall indicate the projects to be undertaken by the Company in areas or subject specified in Schedule VII of the Companies Act, 2013.
• Recommend the Annual Action Plan or alteration of the same in pursuance of the Company’s CSR Policy as per CSR Laws
• Recommend the amount of expenditure to be incurred on activities undertaken in CSR projects.
• Monitor the CSR Policy and recommend changes from time to time.
• Perform all such actions as may be required under the CSR Laws.

The Board of the Company will be responsible for the following:

Perform all such actions as may be required under the CSR Laws.

• Approve the CSR Policy of the Company as recommended by CSR Committee and disclose the content of the Policy in its report and place the Policy on the Company's website in such a manner as prescribed under Section 135 of the Companies Act 2013 and rules thereunder.

   

• Ensure that the activities included in CSR Policy are undertaken by the Company.

   

• Ensure that the Company spends, in every financial year, at least 2% of the average net profits of the Company made during the three immediately preceding financial years in pursuance of the CSR Policy.

   

• Establish a monitoring mechanism to ensure that the CSR activities as recommended by CSR Committee and undertaken by the Company are implemented.

CSR Team

1. Composition of the CSR Team:
   The Company's existing CSR team under the HR department is accountable for coordinating the CSR activities.
2. Responsibility of the CSR Team:
3. • Act as central coordinating point for the CSR implementing projects.
   • Coordinate with the implementing teams for project designing in compliance with the Section 135 of the Companies Act and the CSR Rules.
   • Plan annual budgets for CSR projects in coordination with the implementing departments and make a proposal to the CSR Committee.
   • Interface with various implementing departments within the Company to ensure effective implementation of CSR projects.
   • Report to the CSR Committee the progress on CSR projects and status of CSR expenditure half yearly.
   • Documentation and reporting of all CSR activities of the Company in pursuit of the Companies Act and the CSR Rules

Monitoring and Reporting Framework

Project monitoring

The Company has in place and will consolidate its well-defined monitoring and evaluation mechanism to ensure that each social project has:

• Clear objectives developed out of the societal needs that are determined through baselines studies and research
• Clear targets, time lines and measureable parameters wherever possible.
• A progress monitoring and reporting framework that is aligned with the requirements of the section 135 of the Companies Act and the CSR Rules.

The Company shall undertake “impact assessment”, if required, and in the manner prescribed under the CSR Laws.

The CSR progress monitoring authorities and the frequency of review is given below.

Budget monitoring

The Company will establish an accounting system to ensure project wise accounting of CSR spend, and to check compliance with the Annual Action Plan of the Company.

Reporting framework

• The Company will monitor progress on the CSR projects and CSR spend and report to the top management quarterly and the CSR Committee half yearly.

   

• The Company will report CSR performance in its annual report as per the structure and format prescribed in the notified CSR Rules.