Corporate Social Responsibility Policy

I. INTRODUCTION
Photon is the world’s largest and fastest-growing provider of omnichannel and digital experiences. Photon works with 37 of the Fortune 100 companies as their digital innovation partner of choice and has helped them achieve their goals. With the introduction of the Corporate Social Responsibility (CSR) provisions in the new Companies Act, 2013, Photon aims to help the society and environment by improving the quality of life through nation-building, sustainable development, and social equity.
II. OBJECTIVES
The main objective of the CSR policy is to integrate CSR with the key business processes of Photon. Through the policy, Photon aims to contribute to inclusive growth and equitable development in society through capacity-building measures, empowerment of the marginalized and underprivileged sections/communities.
III. AREAS TO BE COVERED
Photon, through the policy, proposes to implement CSR activities in the following areas:
  • Healthcare;
  • Sanitation;
  • Education;
  • Hunger & poverty;
  • Rural development;
  • Employment opportunities;
  • Empowerment of women;
  • Animal welfare, protection of the environment, conservation of natural resources, and “Go Green” Initiatives;
  • Contribution to the Prime Minister’s National Relief Fund or any other funds set by the Central or State Government for socio-economic development and relief and funds for the welfare of Scheduled Castes, Scheduled Tribes and other backward classes, minorities and women;
  • Human rights; and
  • Any other area as may be prescribed by Schedule VII of the Companies Act, 2013 amended from time to time.
IV. CSR COMMITTEE
a. CONSTITUTION
The Board of Directors of Photon has appointed the following directors to be the members of the CSR Committee.
  1. Mr. Srinivas Balasubramanian
  2. Mr. Mukund Balasubramanian
  3. Mrs. Latha Balasubramanian
The Board also has the power to add or remove the members of the committee as and when needed.
b. FUNCTIONS
The following are the functions of the committee:
  1. Formulate and recommend to the Board, a CSR policy which shall indicate the activities to be undertaken by Photon as specified in Schedule VII of the Companies Act, 2013
  2. Recommend the amount of expenditure to be incurred on the activities indicated in the policy
  3. Approve to undertake CSR activities in collaboration with Photon Group companies/other companies/firms/NGOs, etc. and to separately report the same in accordance with the CSR rules
  4. Spend the allocated CSR amount on the CSR activities once it is approved by the Board of Directors of Photon in accordance with the Act and the CSR rules
  5. Submit the reports to the Board on the CSR activities undertaken by Photon
  6. Monitor the CSR policy of Photon, from time to time
  7. Any other functions as may be prescribed by the Board
c. FREQUENCY OF THE MEETINGS
The CSR committee shall meet as and when necessary. Members of the CSR committee can mutually agree upon the time and place for the said meetings. The quorum of the meetings shall be a minimum of two. The members of the committee may participate in the meeting either in person or through video conferencing or other audiovisual means in accordance with the provisions of the Companies Act, 2013 and rules made thereunder from time to time. The minutes of the CSR committee shall be placed before the Board for noting.
V. BUDGET FOR CSR ACTIVITIES

Photon, on every financial year, shall allocate 2% of its average annual net-profit during the three immediately preceding financial years for spending in the CSR activities listed above.

In case Photon fails to spend the allocated amount for CSR activities in a particular financial year, the committee shall submit a report to the Board of Directors specifying the reasons for not spending the amount which shall in turn be reported by the Board of Directors in their report for that financial year.

Any surplus arising out of the CSR activities shall not form a part of the business profit of Photon.

VI. IMPLEMENTATION OF CSR ACTIVITIES

The CSR activities may be implemented on a project or such other basis and the committee shall keep track of the progress and shall prepare a report, to be placed before the Board, detailing the budget, mode of execution/implementation, time frame for completion and other details as deemed necessary.

The project activities shall be implemented or executed by specialized agencies and not by the employees of Photon. The specialized agencies may be made to work singly or in tandem with other agencies. Such specialized agencies are not limited to but include:

  1. Community-based organizations whether formal or informal.
  2. Elected local bodies such as panchayats, municipal corporations, etc.
  3. Non Governmental Organizations (NGOs) and other voluntary agencies
  4. Academic organizations and institutes.
  5. Trusts, missions, self-help groups, etc.
  6. Government, semi-government, and autonomous organizations.
  7. Contracted agencies for civil work.
VII. MONITORING MECHANISM

The members of the committee along with certain specified employees of Photon and representatives of the entities with which Photon decides to collaborate for fulfilling its CSR obligations will ensure effective implementation and monitoring of the approved projects and activities. A report shall also be submitted to the Board of Directors of Photon as part of the monitoring mechanism on the progress, implementation, and monitoring of the approved projects and activities.