Corporate Social Responsibility (CSR) Policy

Empowering communities, driving sustainable development, and championing social welfare across all Gujarathi Empire Group initiatives.

Purpose & Statutory Framework

This policy sets out how GE gives back to society, chooses CSR projects and spends CSR funds. It follows Section 135 and Schedule VII of the Companies Act, 2013 and the Companies (CSR Policy) Rules, 2014.

Mandatory CSR Applicability

Applies to any group company that in the preceding financial year meets any of the statutory thresholds. Mandatory spend is at least 2% of average net profit of the preceding 3 financial years. GE may also adopt this policy voluntarily.

Net Worth

≥ INR 500 Cr

Turnover

≥ INR 1,000 Cr

Net Profit

≥ INR 5 Cr

Focus Areas (Schedule VII)

Focus Area Schedule VII Item Example Programmes
Education and scholarships (ii) Promoting education KGF Merit-cum-Means Scholarship; school support
Skilling and livelihoods (ii) Vocational skills Maritime and commercial shipping training for youth and ex-seafarers
Health and sanitation (i) Healthcare, sanitation, safe drinking water Health camps; sanitation initiatives
Environment (iv) Environmental sustainability Tree planting; coastal and river clean-ups
Seafarer welfare (iii) / (xii) As applicable Support for families of seafarers in distress

Governance & Oversight

  • CSR Committee / Board Role: A dedicated committee recommends the annual action plan. If the annual CSR obligation is INR 50 lakh or less, the Board performs this role directly.
  • Board Approval & Monitoring: The Board approves the action plan, authorizes budget allocations, and monitors ongoing project execution.
  • CFO Certification: The CFO formally certifies that allocated funds are utilized strictly for approved CSR purposes.

Implementation Mechanisms

GE executes initiatives directly or via designated implementing partners under formal written agreements.

  • Kumar Gujarathi Foundation (KGF): Acts as the primary implementing agency upon meeting MCA requirements (Section 8 company, registered trust/society, Form CSR-1).
  • Project Governance: Every project operates under structured milestone tracking, clear financial budgets, and periodic performance reporting.

CSR Financial Guidelines & Exclusions

Activities Excluded from CSR

  • Activities carried out in the normal course of GE's business operations.
  • Projects benefiting exclusively GE employees and their family members.
  • Direct or indirect political contributions or brand marketing sponsorships.
  • Activities outside India (except training of Indian sports personnel).

Spending Rules & Unspent Funds

Administrative Overheads: Capped at maximum 5% of total annual CSR spend.

CSR Surplus: Any surplus generated from CSR projects must be ploughed back into CSR activities.

Unspent Funds Management: Ongoing project unspent funds transfer to an Unspent CSR Account within 30 days (to be spent within 3 years). Other unspent amounts transfer to a Schedule VII fund within 6 months of year-end.

Impact Assessment: Mandatory for projects costing ≥ INR 1 Cr where average CSR obligation is ≥ INR 10 Cr.

Public Disclosure & Transparency

GE publishes on its official website the CSR Committee's composition, this CSR Policy, and all Board-approved projects. The detailed annual CSR report forms an integral part of the Board's annual report.