Policy Governance
Policy Owner(s) Senior Vice President, HR
Policy Approver(s) Board of Directors of Probe Information Services Private Limited
Version 1.0
Original Approval Date December 11th 2023
Last Approved on December 11th 2023
1. Background
  • Probe is an information service provider and independent financial analytics company.
  • Probe shall continue to relentlessly strive in our endeavor of nation-building, sustainable development, accelerated inclusive growth and social equity.
  • Corporate Social Responsibility (CSR) is the way and means through which corporates can repay the obligations made by the Society by contributing the resources in its various forms as required for the efficient operation of the Business. Corporate Social Responsibility is strongly connected with the principles of sustainability. Organizations should make decisions based not only on financial or operational factors, but also on the social and environmental consequences. Therefore, it is the core corporate responsibility of Probe to practice its corporate values through its commitment to grow in a socially and environmentally responsible way, while meeting the interests of its stakeholders.
2. Title and Applicability
  • Probe Information Services Private Limited (the ‘Company /Probe’) has developed this Policy titled ‘Probe CSR Policy’ (the ‘Policy’) encompassing the Company’s philosophy for being a responsible corporate citizen and lays down the principles and mechanisms for undertaking various programmes in accordance with Section 135 of the Companies Act, 2013 (the ‘Act’) and Companies (Corporate Social Responsibility Policy) Rules, 2014 (‘CSR Rules’), as amended from time to time, for the community at large.
  • The Policy shall guide the CSR programmes and activities undertaken by the Company in the communities in which it operates.
3. CSR Vision Statement
  • Probe’s vision is to support responsible and sustainable initiatives, while taking care of the concern for People and the Planet.
  • Probe does this through its social responsibility programmes and the collective efforts of its colleagues. By aligning Probe’s Social responsibility strategy to its skills and experience - the positive impact of these activities is much more than just a financial contribution.
4. Review of CSR Policy
  • The Board may review the CSR policy and make necessary amendments, as and when required.
5. CSR Programme Areas & Objectives
  • Probe seeks to undertake Corporate Social Responsibility (“CSR”) activities, which extend beyond the scope of the business and focus on human, environmental and social assets, with a special focus on addressing, education, health and sports.
  • Promoting education through:
    • Adoption of non-formal school programmes and other educational institutions;
    • Provision of educational and material assistance to under-privileged children to build an educated and literate population.
    • Institution of infrastructure in schools like benches, toilets, potable water, fans, security cameras, etc. and improvisation of educational facilities. Or
    • Providing financial and/or other assistance to any Agency/Trust involved in education and knowledge enhancement.
  • Health:
    • Provision of end-to-end access to affordable and quality healthcare for socially and economically backward classes;
    • Provision for construction and operation of medical hospitals, colleges and institutions for promotion of healthcare activities, facilities and initiatives;
    • Promoting social business projects like giving medical aid, appliances, support and treatment to disabled persons.
  • Sports:
    • To enable sports excellence for social change.
    • Training to promote rural sports, nationally recognised sports, Paralympic sports and Olympic sports.
    • To encourage sports among the youth in both rural and urban schools to nurture talent and to encourage, realize the potential of sport which leads to overall personality development and brings about positive behavioral change.
  • Any other programme or project in areas or subject enumerated in Schedule VII:
    • The Company mayundertake any other project or programme in areas or subject specified in Schedule VII of the Act.
6. CSR Budget
  • The Board shall endeavor that the Company spends, in every financial year, at least 2% of its average net profits of the Company (“net profit” shall not include such sums as may be prescribed and shall be calculated in accordance with the provisions of Section 198 of the Act) made during the immediate three preceding financial years.
  • Any surplus arising out of the CSR projects or programs or activities shall not form part of the business profit of the Company and shall be utilized only for CSR purposes and shall be ploughed back into the same project or shall be transferred to the Unspent CSR Account and spent in pursuance of CSR policy and annual action plan of the Company or transfer such surplus amount to a Fund specified in Schedule VII, within such period and with such terms and conditions as may be prescribed under Section 135 of the Act read with relevant rules applicable.
  • The Company may collaborate or pool resources with group companies, other organizations or companies to undertake CSR activities in such a manner that the respective companies are in a position to report separately on such projects or programmes in accordance with the CSR Rules.
  • For any reason if the CSR Team is not able to follow the allocation agreed on in any of the Areas to Emphasize described above, the same shall be utilized in such other Areas to Emphasize as the CSR team may recommend with the reasons therefor, and the Board may approve.
7. Implementation Process
  • The mode of implementation of CSR programmes may include a combination of direct implementation or implementation through own foundation, Non-Government Organizations(NGOs), business partners, civil society, registered societies, trusts etc. The Company will select itspartners after appropriate due diligence.
  • The Board may undertake the CSR activities through following implementing agencies:
    • 2.1 A Company established under Section 8 of the Act;
    • 2.2 A Registered Public Trust;
    • 2.3 A Registered Society
    • 2.4 established by the Central Government or State Government either singly or along with any other Company having a track record of at least 3 years in undertaking similar activities established under an Act of Parliament or a State Legislature.
  • The time period/duration over which a particular programme would be spread will depend on its nature, extent of coverage and the intended impact of the program.
  • The Company may enter into partnerships with any statutory authority, civil society and communities to create multiplier effects of its social projects.
  • The mode of implementation will also include employee volunteering. Probe’s employee volunteering may involve the Company’s employees in the community initiatives it undertakes and help them contribute towards society.
  • The Company will use the services of expert agencies, consultancy firms etc. wherever required for carrying out baseline surveys, guidance on project design and implementation, impact assessment surveys, etc.
8. Roles and Responsibilities of the Board
    The Board of Directors of the Company will be responsible for:
  • Approving the CSR Policy of the Company including any revisions thereof, after considering the recommendations made by the CSR working team.
  • Disclosing contents of CSR Policy in the Board’s Report and also place the Policy on the Company’s website, in such manner as may be prescribed under Section 135 of the Act read with CSR Rules.
  • Ensuring that the activities undertaken by the Company are as per its stated CSR Policy.
  • Ensuring that the Company endeavors to spend, in every financial year, at least 2% of its average net profits of the Company (“net profit” shall not include such sums as may be prescribed and shall be calculated in accordance with the provisions of Section 198 of the Act) made during the three immediately preceding financial years in pursuance of the Policy.
  • Ensuring that the Company gives preference to the local areas around its operations within India for spending the amount earmarked for CSR projects.
  • Ensuring that it specifies the reasons in the Board’s report for not spending the allocated amount in case the Company fails to spend such an amount.
9. CSR Committee:
  • Pursuant to Section 134(9) of the Companies Act, 2013 effective from January 22, 2021, where the amount to be spent by a company under CSR does not exceed fifty lakh rupees, the requirement for constitution of the Corporate Social Responsibility Committee shall not be applicable and the functions of such Committee provided under this section shall, in such cases, be discharged by the Board of Directors of such company. Accordingly, the requirement for constitution of the Corporate Social Responsibility Committee is not applicable to the Company and the functions of the committee shall be discharged by the Board.
  • However, the Board has selected some of the employees as a CSR Team and shall be responsible for day-to-day monitoring of CSR activities as mentioned in Point 14 here in below.
10. Monitoring and Reporting Framework
  • 1. Project Monitoring:
    • The CSR Team nominated by the Board has instituted “transparent monitoring mechanism” for various CSR Projects / Programs / Activities undertaken by the Company.
    • The Board shall review the implementation of the approved CSR Program;
    • The performance of the Company’s CSR activities shall be reviewed and monitored at least on quarterly basis, including annual review by the Board.
    • The Board shall be responsible for monitoring the expenditure on CSR activities with respect to the plan and submission of the same to the CSR Team.
    • The CSR Team will submit a report to the Board at the end of the year as per the format prescribed under Companies Act, 2013 and applicable law. The Board will report CSR performance in its report of the Board of Directors.
  • 2. Reporting:
    • The Company will ensure to do CSR reporting annually in the format recommended in the CSR Rules,as part of its Annual Report.
11. Impact Assessment
  • If the Company having average CSR obligation of Rs. 10 Crores (Rupees Ten crores) or more in pursuance of subsection (5) of section 135 of the Act, in the three immediately preceding financial years, the Company will undertake impact assessment (through an independent agency) for CSR projects that have outlays of Rs. 1 crore or more and have been completed atleast one year before undertaking the impact study and the impact assessment reports will be placed before the Board and disclosed as per the Act and CSR Rules.
12. Amendments To The CSR Policy
  • The Board of Directors of the Company shall have the powers to revise / modify / amend this Policy from time to time, as the Board may think fit.
  • Any subsequent amendment / modification in the CSR Rules made by the MCA, under the Act and / or any other laws in this regard shall automatically apply to this Policy.
13. CSR Team:
  • CSR Team shall consist of designated employees at Probe selected by Board of directors of the Company who shall be responsible for day-to-day monitoring of CSR activities. They are:
    • Sowmya Devaiah V – Senior Vice President – HR
    • Vikram Singh Rawat – Vice President - Engineering
    • Shailesh Dube – Vice President – Outsourced Operations
    • Varun Ramanathan – Vice President - Finance
    • Jhansi Latha R – Company Secretary
    • Naghma Shadabh – Vice President - Sales
    • Amit Singh - Vice President – Engineering
  • The CSR Team shall be responsible for:
    • Execution of the CSR Policy.
    • Identify projects and key initiatives pursuant to CSR Policy.
    • Facilitating allocation of funds to the projects as identified for CSR activities.
    • Monitoring CSR Projects to establish effectiveness of CSR efforts and appraise the same to the Board.
    • Compilation of information & preparation of Annual Reports on CSR activities and presenting the same to the Board.
    • Any other activity necessary to ensure achievement of CSR objectives.