Companies Act, 2013 has formally introduced the Corporate Social Responsibility to the dash board of the Indian Companies. Gong Cheng Communications Private Limited is much positive and appreciate the decision taken by the Government of India. Legal framework of CSR is an edge to Corporate Charitable/reformative approach towards the Society to which the Corporate is belonging to. By introducing the separate section for CSR in Companies Act, 2013, the Government has given legal recognition to their community development approach.

The management of the Gong Cheng Communications Private Limited expresses its willingness and support to the CSR concept, its legal framework and shall be abided to it.

VISION STATEMENT

In alignment with the Company's Vision, Company through its CSR initiatives strives to create value by addressing critical social, environmental and economic needs of the society by which to promote sustained growth for society in fulfilment of its role as a Socially Responsible Corporate. It aims at complementing the role of the Government in enhancing welfare measures of society.

OBJECTIVES

This CSR Policy shall be read in line with Section 135 of the Companies Act 2013, Companies (Corporate Social Responsibility Policy) Rules 2022 and such other rules, regulations circulars and Notifications as may be applicable and as amended from time to time and will inter-alia provide for the following:

• Establishing a guideline for compliance with the Regulations etc. to dedicate a percentage of Company's profits for Social Projects.
• Ensuring the implementation of CSR initiatives in letter and spirit through appropriate procedures and Reporting.

SCOPE OF CSR ACTIVITIES

The following activities as specified under Schedule VII to the Companies Act, 2013 will be considered as CSR activity –

• 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. Promoting education, including special education and employment enhancing vocational skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
• 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.
• 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.
• 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.
• 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 widow.
• Training to promote rural sports, nationally recognised sports, Paralympic sports and Olympic sports; construction, renovation, maintenance of stadiums, gymnasiums and rehabilitation centres.
• Contribution to Prime Minister’s National Relief Fund/Prime Minister’s Citizen Assistance and relief in Emergency 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, Tribes, other backward classes, minorities & Women.
• 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 Located within academic institutions which are approved by the Central Government;
• b. Contribution 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 Homeopathy(AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defence 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).
• Rural development projects
• 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.
• Disaster management, including relief, rehabilitation and reconstruction activities.

The following will not be included as a CSR activity –

• Activities undertaken in pursuance of normal course of business of the Company; Provided that any company engaged in research and development activity of new vaccine, drugs and medical devices in their normal course of business may undertake research and development activity of new vaccines, drugs and medical devices related to COVID-19 for financial years 2020-21,2021-22,2022-23: subject that (a) such research and development activities shall be carried out in collaboration with any of the institutes or organisations mentioned in item (ix) of Schedule VII to the Act; (b) details of such activity shall be disclosed separately in the Annual report on CSR included in the Board’s Report.
• Activities undertaken outside India except for training of Indian Sports personnel representing State or Union Territory at National Level or India at International Level; ● Contribution of any amount, directly or indirectly, to any political party under section 182 of the Act;
• Activities benefitting employees of the company as defined in clause(k) of the section2 of the code on wages,2019(29 of 2019);
• Activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services like One-off events such as marathons/awards/charitable contribution/ advertisements/sponsorships of TV programmes, etc.
• Activities carried out for fulfilment of any other statutory obligations under any law in force in India.

The Company has identified the following thrust areas for various CSR related activities:

• Education/literacy enhancement and vocational training.
• Sanitation and drinking water projects including rain harvesting;
• Healthcare/medical facility;
• Welfare and Rehabilitation of underprivileged and differently abled persons;
• Environment Protection;
• Relief to victims of natural calamities/disasters;
• Training in Sports and Development of Sports-related infrastructure;
• Any other area of contemporary importance

BUDGET & EXPENDITURE

Board shall ensure that the Company spends in every Financial Year, at least Two per cent of the Average Net Profits of the Company made during the three immediately preceding financial years in pursuance of its Corporate Social Responsibility subject to applicable provisions and availability of average net profits, provided that the company shall give preference to the local area and areas around it where it operates, for spending the amount earmarked for CSR Activities. The Surplus arising out of CSR Activities and funds in balance due to cancelled Projects (duly approved by the Board), and other such income, may be included in the CSR Corpus.

CSR expenditure shall include all expenditure including contribution to corpus for projects or programs relating to CSR activities approved by the Board on the recommendation of its CSR Committee, but does not include any expenditure on an item not in conformity or not in line with activities which fall within the approved CSR activities.

FINANCIAL COMPONENT

The Company shall spend in every Financial Year at least 2 (two) percent of the Average Net Profits of the Company made during the 3 (three) immediate preceding financial years, in pursuance of its Corporate Social Responsibility Policy:

(a) TREATMENT OF UNSPENT AMOUNT: If the Company fails to spend 2% of the Average net profit, then the unspent amount shall be treated as follows

(A) TRANSFER OF UNSPENT/UNALLO CATED AMOUNT: If unspent amount not relating to an ongoing project : Board shall, in its report, made under clause (o) of sub-section (3) of Act, specify the reasons for not spending the amount; and’ unless the unspent amount relates to any ongoing project referred to in sub-section (6) Section 135 , transfer such unspent amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.
Until a fund is specified in Schedule VII for the purposes of subsection (5) and(6) of section 135 of the Act, the unspent CSR amount, shall be transferred by the company to any fund included in schedule VII of the Act.

(B) UNSPENT CSR ACCOUNT FOR ONGOING PROJECTS : If unspent amount relates to an ongoing project :- The amount shall be transferred within a period of 30 days from the end of the FY to a special account to be opened by the company in that behalf for that FY in any scheduled bank. This will be called the Unspent Corporate Social Responsibility Account (UCSRA).

(C) Failure to spend on the ongoing Project in 3 years :- Company shall transfer the amount to a Fund specified in Schedule VII, within a period of thirty days from the date of completion of the third financial year.

(b) ONGOING PROJECT: [Rule 2(1)(i)] 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.

(c) Board 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

(d) Till the time no project is being decided upon, the Company may consider contributing the unspent CSR funds to the funds specified in Schedule VII, as below:

• Prime Minister's National Relief Fund.
• Any other fund is initiated by the central government concerning socio-economic development, relief and welfare of the scheduled caste, minorities, tribes, women and other backward classes.
• An incubator funded either by the central government, the state government, public sector undertaking of the state or central government, or any other agency.
• Contributions made be made to:
• • Public-funded universities
  • Indian Institute of Technology (IITs)
  • National Laboratories and Autonomous Bodies established under:
  • Indian Council of Agricultural Research (ICAR)
  • Council of Scientific and Industrial Research (CSIR)
  • Department of Atomic Energy (DAE)
  • Department of Biotechnology (DBT)
  • Department of Pharmaceuticals
  • Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy
  • (AYUSH)
  • Ministry of Electronics and Information Technology
  • Indian Council of Medical Research (ICMR)
  • Defence Research and Development Organisation (DRDO)
  • Department of Science and Technology (DST) engaged in conducting research in technology, science, medicine, and engineering aimed at encouraging Sustainable Development Goals (SDGs).

SURPLUS

Prior to end of Financial Year, CSR Committee shall place for Board consideration and Approval, details of the Completed Projects (with Utilisation Certificates) and the surplus amount generated with reasons thereof. Any SURPLUS arising out of CSR expenditure shall not form part of the business profit of the Company.

SET OFF OF EXCESS:

In the event of the Company spending an amount in excess of requirement provided under sub section 5, such excess amount may be set off against the requirement to spend under this subsection for the immediate succeeding three financial years subject to the conditions that the excess amount available for set off shall not be included in the Surplus arising out of CSR activities. Company’s Board shall pass a resolution to that effect.

CAPITAL ASSET

A capital asset acquired or created by the Company through CSR funding shall be held only by entities as specified in Section 7(4) of the Rules 2021.

"CSR Committee" means the Corporate Social Responsibility Committee of the Board referred to in section 135 of the Act; The Committee shall formulate and recommend to the Board, an annual action Plan in pursuance of its CSR Policy which will include 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
• The modalities of the utilisation of funds and implementation schedules for the projects or programmes
• Monitoring and reporting mechanism for projects and programmes
• Details of need and impact assessment, if any, for the Projects undertaken by the Company

Provided that the Board may alter such a plan at any time during the financial year, as per the recommendation of its CSR Committee, based on the reasonable justification to the effect. Appropriate documentation of NIC CSR Policy, Annual CSR Activities, executing partners and expenditure will be undertaken on a regular basis.

CSR COMMITTEE STRUCTURE

The present Directors of the Company shall constitute as members of the CSR Committee. As per present set up of the Board of Directors of the Company, the following Directors are the members of the CSR committee:

1. Mr. Wang Jiaer, Director to be the Chairman of the CSR Committee.

2. Mr. Yuan Jinxuan, Director.

Board of Directors of the Company may re-constitute the Committee, as and when required to do so, by following the sections, sub-sections, rules, regulations, notifications issued or to be issued, from time to time, by the Ministry of Corporate Affairs or the Central Government of India. The Committee shall exercise powers and perform the functions assigned to it by the Board of Directors of the Company pursuant to section 135 of the Companies Act, 2013 and CSR Rules notified with regard thereto.

SELECTION OF THE PROJECT:

Out of approved CSR activities, the Committee shall decide which activity/project should be given priority for the respective financial year. While arriving at the decision of the activity to be undertaken for the respective year, the Committee shall analyse the basic need of the community/ area in which the Organization operates or at the place where its registered office is situated. The Committee shall record its findings and prioritized the CSR activities

All Proposals/projects submitted/referred by Institutions/statutory authorities/government agencies and other eligible intermediaries will be examined by the CSR Committee. Once shortlisted, a physical inspection shall be conducted. In case of a positive feedback and detailed inspection report, the CSR Committee will submit their report/recommendation to the Chairman of CSR committee. After obtaining approval of Chairman, the proposal shall be placed before the CSR committee members for their onward recommendation to the Board for consideration.

IMPLEMENTATION OF PROJECTS: ELIGIBILITY CRITERIA

Board shall ensure that CSR activities are undertaken by the Company itself or through –

• A company established under section 8 of the Act, or a registered public trust or a registered society, registered under section 12A and 80 G of the Income Tax Act, 1961 (43 of 1961), established by the company, either singly or along with any other company, or
• 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
• Any entity established under an Act of Parliament or a State legislature; or
• A company established under section 8 of the Act, or a registered public trust or a registered society, registered under section 12A and 80G of the Income Tax Act, 1961, and having an established track record of at least three years in undertaking similar activities
• Every entity, covered under sub-rule (1), who intends to undertake any CSR activity, shall register itself with the Central Government by filing the form CSR-1 electronically with the Registrar, with effect from the 01st day of April 2021
• To avoid Conflict of interest, CSR Funding may not be extended to Institutions/eligible intermediaries where an employee of our Company or a Board Member is associated in an Official capacity or otherwise.
• Preference to be given to NGOs/Institutions undertaking projects in underdeveloped and backward areas, particularly tribal areas, predominantly inhabited by economically and socially marginalised populace.
• At organizational level for implementation of agreed CSR activity, the committee may constitute an implementation team or authorized any of the Department of the Company to organize for the implementation of the CSR activity. The team or respective department shall monitor the implementation process from time to time, on behalf of the CSR committee and place a report to the Committee regarding the progress of the activity implementation, on a quarterly basis. The respective department or implementation team would be responsible for reporting of any irregularity to the Committee on immediate basis.

EXPENSES

“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. Administrative overheads shall not exceed five percent of total CSR expenditure of the company for the financial year.

REVIEW OF THE POLICY:

The CSR Committee will review the policy on an annual basis and submit their recommendation for suitable modifications, if necessary, to the Board for their approval. The Board approved Company’s Corporate Social Responsibility(CSR) Policy shall be displayed on the website of the Company.

MANAGEMENT COMMITMENT:

Our 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 c ornerstone of our CSR policy. Our Corporate Social Responsibility policy conforms to the relevant section of the Corporate Social Responsibility, Rules made under Companies Act, 2013 and amendment(s) to be made thereto in future.

The Company contributed eligible CSR amount to Prime Minister’s relief fund at the end of March 2024.

Annual Action Plan (2024-25) :
Board has approved appointment of two implementation agencies which will lay down specific implementation plans as per allocated budget in areas of education including Basic and moral education for under privileged children, focusing on children who do not have access to quality education due to socio- economic factors.

This Policy will form the framework for functioning of the CSR activities of the Company. In case of any difficulty/doubt in interpreting any provision of the Policy and also in respect of matters not covered herein, a reference will be made to the General Manager (CSR). In all such matters, the interpretation and the decision of the CMD shall be final. Any or all provisions of the CSR Policy will be subject to revision/amendment in accordance with guidelines issued by the Appropriate Authority, from time to time.