Corporate Social Responsibility Policy
KW Homes Private Limited's CSR framework under Section 135 of the Companies Act 2013, Schedule VII and the CSR Rules 2014 — applicable for FY 2025-26 and thereafter.
Preamble
KW Homes Private Limited, one of the KW Group companies, lays emphasis on improving and transforming the lifestyles of its occupants and users. Among the earliest adopters of eco-friendly construction methodologies, the Company has focused on sustainable growth since its inception. Beyond its business objectives it recognises its responsibility towards society and stakeholders, and undertakes CSR activities in accordance with Section 135 of the Companies Act 2013, Schedule VII to the Act and the Companies (Corporate Social Responsibility Policy) Rules 2014, as amended.
Objective
To establish the principles, framework and mechanism for identifying, approving, implementing, monitoring and reporting CSR projects, while ensuring compliance with the Act and the CSR Rules. The Company endeavours to undertake initiatives that create sustainable and measurable social, environmental and economic impact, aligned with the activities specified in Schedule VII.
Applicability and governance
The policy applies to all CSR projects undertaken by the Company in India under Section 135 and the CSR Rules. Where the Company is required to constitute a CSR Committee, the Board constitutes it in accordance with the statutory requirements. Where, under Section 135(9), the amount required to be spent does not exceed the prescribed threshold, the Board of Directors discharges the functions of the CSR Committee.
Role of the Board
The Board approves this policy and its amendments, the CSR activities and annual budget, and the Annual Action Plan and permissible modifications to it. It ensures the prescribed amount is spent in accordance with Section 135 and the CSR Rules; that administrative overheads, unspent amounts, surplus and excess expenditure are dealt with as the law requires; monitors implementation and satisfies itself on the utilisation of disbursed funds; and ensures statutory disclosure and reporting.
Role of the CSR Committee
Where constituted, the Committee formulates and recommends the CSR Policy and amendments to the Board, recommends the activities and the expenditure to be incurred, monitors the policy and the implementation of approved projects, and recommends the Annual Action Plan while tracking progress against approved objectives.
Projects and activities
The Company undertakes activities approved by the Board in one or more of the areas specified in Schedule VII, giving preference to the local area and the areas around which it operates. Activities are undertaken within India and exclude anything carried out in the normal course of business, except where the law specifically permits.
Implementation
Activities are undertaken by the Company itself or through a Section 8 company, registered public trust or registered society established by the Company and holding registration under Section 12A with approval under Section 80G of the Income Tax Act 1961; an entity of that kind established by the Central or a State Government; any entity established under an Act of Parliament or a State legislature; or any other such entity with an established track record of at least three years in similar activities. Every implementing agency must be registered with the Central Government by filing Form CSR-1 as required by Rule 4(2). The Company conducts due diligence before engaging an agency and agrees the scope, deliverables, timelines, fund utilisation, monitoring and reporting in writing.
CSR expenditure
The Company spends, in every financial year, at least two per cent of the average net profits of the three immediately preceding financial years, calculated as prescribed. Administrative overheads do not exceed five per cent of total CSR expenditure for the year. Surplus arising from CSR activities does not form part of business profits and is dealt with under the CSR Rules. Excess spend may be set off against the CSR obligation of the next three financial years, subject to the conditions in the Rules and Board approval. Capital assets may be created or acquired only on the conditions prescribed. Records, supporting documents and utilisation certificates are maintained.
Unspent amounts
Unspent CSR amounts are dealt with strictly under Sections 135(5) and 135(6). Where the amount does not relate to an ongoing project, it is transferred to a Fund specified in Schedule VII within six months of the end of the financial year. Where it relates to an ongoing project, it is transferred to the Unspent CSR Account within thirty days of the end of the financial year and utilised on the approved project within three years of that transfer. All related statutory disclosures and filings are made.
Monitoring and review
The Board establishes monitoring mechanisms to review project progress, fund utilisation and achievement of approved objectives. Implementing agencies and Company personnel provide periodic progress and financial reports. Depending on the nature and scale of a project the Company may undertake field visits, review meetings, utilisation verification and outcome assessments. Where the impact-assessment threshold in Rule 8(3) applies, the Company commissions an independent impact assessment and annexes it to the annual report on CSR.
Disclosure and reporting
The Company complies with the requirements for disclosure of the CSR Policy and CSR activities in the Board's Report or otherwise as the Act requires from time to time. In accordance with Rule 9, the composition of the CSR Committee, this CSR Policy and the projects approved by the Board are disclosed on the Company's website.
Exclusions
CSR expenditure is not incurred on activities excluded under the Act or the CSR Rules — activities in the normal course of business, contributions to political parties, activities benefitting employees exclusively, sponsorship undertaken for deriving marketing benefits, and activities outside India, except to the extent the law specifically permits.
Amendment
The Board may, based on its assessment of the Company's needs, financial soundness and legal and regulatory developments, and subject to applicable law, modify, vary, alter or amend this policy at any time.
About this policy