Corporate Social Responsibility Policy

A. Company Overview
As a conscientious corporate citizen, ACL Mobile Private Limited recognizes its role and responsibility to address some of India’s most pressing challenges.

ACL Mobile Private Limited is a private limited company engaged in providing telecom based software solutions and services to enterprises. Business of the Company primarily includes: 
  • Messaging services  & Voice services 
  • Mobile value added services 
  • Mobile payment services
ACL Mobile Private Limited is committed to provide innovative, affordable and customer friendly services that enable people to connect and communicate or transact in a seamless manner. The services are provided to the customers (enterprises) which are located not only in India but outside India as well. It aims to lead the path not only through products and services, but also via sustainability and CSR initiatives. ACL Mobile Private Limited remains committed to act responsibly and ethically to maintain the trust of its customers, its employees and other stakeholders. 
B. CSR Programs 
ACL Mobile Private Limited’s CSR Policy is effective from May 5, 2018

ACL Mobile Private Limited acknowledges that while there are positive impacts of connectivity, there is an equally pressing necessity to mitigate the harmful environmental and social impacts of telecom services. 

ACL Mobile Private Limited’s programs/projects areas shall be aligned with the national development priorities and the needs of the communities and will be in sync with schedule VII of Section 135 of the companies Act 2013. In all our CSR programs, we shall encourage use of mobile technology, employee volunteerism, partnerships and innovations. ACL Mobile endeavors to have long term CSR programs or projects.
ACL Mobile Private Limited, through its CSR shall support long term programs/projects and activities in the following domains: 

• Support for promotion of education of all kinds (school education, technical, higher, vocational and adult education), to all ages and in various forms, with a focus on vulnerable and under-privileged, particularly for the girl child.

Health, Hygiene and Sanitation:
• Ambulance services, mobile medical units, health awareness programmes and camps, medical check-ups, HIV/AIDS awareness initiatives, health care facilities and services, sanitation facilities.
• Eradicating hunger, poverty and malnutrition, promotion of preventive health care and sanitation, and making available safe drinking water;

Community Development:
• Encouraging youth and children to form clubs and participate in community development activities such as like cleanliness drives, plantation drives, awareness drive - precautions while using the internet, etc.

Environmental Sustainability:
• Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro-forestry, conservation of natural resources and maintaining quality of soil, air and water and e-waste disposal.
• Ensuring safety, privacy and security of customer information.
Gender Equality and Empowerment of Women:
 • Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centers and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups

C. Implementation:

The Company will implement its CSR projects/programs through implementing partners within India. While executing CSR activities, the Company shall ensure that such activities are not in normal pursuance of its business. 

The board or CSR Committee shall ensure that its Implementing partners are entities registered as Trusts or Society or Company or Section 8/Section 25 company or certified technology incubators or through collaborative projects with other corporate.

These agencies will be screened based on ACL Mobile Private Limited’s internal screening criteria to ascertain the entity’s credibility and its ability to execute the proposed projects. The CSR Committee will oversee implementation and monitoring of all CSR projects / programs with periodic visits and reports. 

D. Governance:
The approval of the CSR policy and overall oversight is the responsibility of ACL Mobile Private Limited’s Board of Directors. The responsibility of the CSR committee is to promote the strategy and administer and execute the policy through implementing partner(s).

The CSR committee is to ensure that projects/programs are compliant with this Policy and are monitored and reported effectively. 

Roles and Responsibilities: 
The Board of Directors of the Company will be responsible for:
1. Approval of the CSR Policy of the Company. 
2. Disclosing 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 read with the CSR Rules.
3. Ensuring that the Company spends, in every financial year, at least two percent of the average net profits of the Company made during the three immediately preceding financial years in pursuance of the Policy.
4. Ensuring that it specifies the reasons in its report for not spending the earmarked amount in case the Company fails to spend such amount during the financial year.
 5. The Board shall have the power to make any change(s) in the Committee constitution. 

CSR Committee will be responsible for:
1. Revise and modify the CSR Policy for the Company and place the same with the Board of Directors for their approval; 
2. Ensure that the programs, projects and activities supported through ACL Mobile Private Limited are aligned with the approved CSR policy of the Company and are also aligned to the activities prescribed in Schedule VII (annexed); 
3. Review and approve annual budgets with respect to CSR programs; 
4. In case the Company is not able to spend two percent of the average net profits of the last three financial years or any part thereof, the CSR Committee shall provide the reasons for not spending the amount to the Board which shall also be included in the Board’s report; 
5. The CSR Committee will prepare the annual CSR report to be filed by the Company on approval of the Board. This report will ensure:
  •  CSR projects and programs are being properly documented.
  • An MIS is maintained on expenditure across sectors and geographies and beneficiaries impacted. The MIS structure will be in alignment with the    prescribed reporting format.
  • Accountability is fixed at each level of CSR process and implementation.
  • A repository of case studies and good practices is being maintained.
6. Develop and institutionalize a CSR reporting mechanism in light with Section 135 of the Companies Act 2013 read with Rule 8 of the CSR rules framed thereunder; 
7. Respond to any query, observation or clarification sought by the Ministry of Corporate Affairs or any other regulatory authority with regard to CSR supported activities; 
8. Ensure that ACL Mobile Private Limited’s website displays the approved CSR policy of the Company; 
9. Reviewing the findings and recommendations from any investigation or audit by regulatory agencies or external auditors or consultants concerning ACL Mobile Private Limited’s CSR matters; 

E. CSR Expenditure:
CSR expenditure will include all expenditure, direct and indirect, incurred by the Company on CSR Programs undertaken in accordance with the approved CSR Plan. Moreover, any surplus arising from any CSR Programs shall be used for CSR. Accordingly, any income arising from CSR Programs will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.

(Pursuant to Section 135, Companies Act 2013)
Activities which may be included by companies in their Corporate Social Responsibility Policies Activities relating to:—
(i) Eradicating hunger, poverty and malnutrition, promoting health care including preventinve 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. 
(ii) promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
(iii) 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.
(iv) 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.
(v) 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; 
(vi) measures for the benefit of armed forces veterans, war widows and their dependents;
(vii) training to promote rural sports, nationally recognised sports, paralympic sports and olympic sports
(viii) contribution to the prime minister's national relief fund or any other fund set up by the central govt. for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women;
(ix) contributions or funds provided to technology incubators located within academic institutions which are approved by the central govt.
(x) rural development projects
(xi) slum area development.
Explanation.- For the purposes of this item, 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.
The CSR Committee of the Board is responsible for overseeing the execution of the Company’s CSR Policy and dispersal of CSR Funds.
As on 15 September 2022, CSR Committee comprises of:
1. Mr. Nitin Singhal, Chairman
2. Mr. Anders Olin, Member
3. Mr. Sanjay Krishna Goyal, Member
As part of our CSR Policy, Sinch India in an effort to support long-term projects that add value to communities is going strong with the Pustakalaya Project in South Delhi Municipal Corporation (SDMC) schools. The initiative, in collaboration with NGO, Anandaya Foundation, formerly known as Angelique Foundation, and the Municipal Corporation of Delhi (MCD), attempts to help students from economically weaker sections access educational resources within a functional, comfortable, and motivating environment. These libraries or Pustakalayas are equipped with proper furniture and appropriate books. The aim is to enable each child to cultivate reading, comprehension, and expression skills.
So far, 52 SDMC schools have been equipped with functional Pustakalaya and training has been conducted for 100 teachers and students.
Impact of the project
With the MCD at its helm, the project is sustainable. The MCD has been supportive by providing a dedicated room in SDMC schools for a library, by ensuring its upkeep and adding new books purchased out of the school’s allocated budget. Owing to the project’s success, there has been a clear change in the mindset of the MCD as also the community. Sinch India looks forward to continuing this initiative for the welfare and progress of those concerned.
In an effort to support the welfare of underprivileged girls, Sinch India as part of its CSR Policy is sponsoring and supporting girls, women and those identifying as trans women in the age group of 17-30 years to acquire technology skills. The initiative called Navgurukul, is in association with state governments of Tripura and Delhi. The target segment in both the campuses of Tripura and Delhi are matriculate women from rural or semi-urban areas but preference has been to take in candidates from under-served communities.
Sinch India has sponsored education of 45 students at Tripura campus which was started in November 2021 and 55 students at the Delhi campus project which kickstarted in April 2022.
Impact of the project
Between November 2021 and April 2022, several activities were conducted which included the pre-campus set-up, onboarding, induction, orientation, training on technology, soft skill training, cultural and community sessions, engagement, and activities.