1. About our Company –

This Corporate Social Responsibility (“CSR”) Policy is formulated in accordance with Section 135 of the Companies Act, 2013 (“the Act”), read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, including all statutory amendments thereof.

“WinWire Technologies India Private Limited” (the Company) is a wholly owned Subsidiary of a foreign Company “WinWire Technologies Inc.”, headquartered in California, USA.

WinWire Technologies is a global IT solutions company, founded by ex-Microsoft executives, helping enterprises navigate the digital technology revolution. We help drive exponential growth and competitive advantage for our customers through aligning business value and digital transformation. We call it stitching digital fabric with systems of intelligence.

1.2. CSR in India Corporate bodies’ involvement in CSR activities is not a new concept in India. However, the Companies Act, 2013 has brought it under the legal purview. The concept of CSR is introduced through “Comply-or-Explain” mandate. It mandates qualifying companies to constitute Corporate Social Responsibility Committee to effectively monitor CSR activities of the Company. Further the Companies (Corporate Social Responsibility Policy) Rules, 2014 (hereinafter referred to as “the CSR Rules”) lay down the framework and modalities for carrying out CSR activities which are specified in Schedule VII of the Act.

2. Objective and Scope –

2.1. Objective:

The main objective of the CSR Policy is to lay down guidelines for (hereinafter referred to as ‘the Company’) to make CSR as one of the key focus areas to adhere to ’s global interest in environment and society that focuses on making a positive contribution to society through effective impact and sustainable development programs. This Policy covers the proposed CSR activities to be undertaken by the Company and ensuring that they are in line with Schedule VII of the Act as amended from time to time. It covers the CSR activities which are being carried out in India only and includes strategy that defines plans for future CSR activities.

2.2. Scope & Coverage:

The CSR activities of the Company shall include but not limited to any or all of the sectors/activities as may be prescribed by Schedule VII of the Companies Act, 2013 amended from time to time. Further, the Company will review the sectors/activities from time to time and make additions/ deletions/ clarifications to the above sectors/activities.

3. CSR Focus Areas (as per Schedule VII) –

The Company may undertake CSR activities in one or more of the following areas:

  • Education, Digital Literacy & Skill Development: Promote education, digital literacy, and IT/vocational skills, especially for underprivileged groups.
  • Healthcare & Wellness: Support health camps, preventive healthcare, sanitation, and mental wellness initiatives.
  • Environmental Sustainability: Undertake projects like afforestation, waste management, water conservation, and renewable energy.
  • Women Empowerment & Community Development: Promote gender equality, women skill development, livelihood support, and inclusive community welfare.
  • Disaster Management & Relief: Provide relief, rehabilitation, and support during natural or man-made disasters.
  • Any Other Activity under Schedule VII: Undertake any other activity permissible under Schedule VII of the Companies Act, 2013

4. CSR Spend –

The Companies Act, 2013 prescribes that the companies which meet the criteria specified U/s. Sec. 135 shall allocate certain portion of its annual net profits (calculated as per Sec. 198) during the three immediately preceding financial years to be spent on CSR Activities that fall under the categories specified under Schedule VII of the Act.

5. Responsibilities of the Committee –

  • The responsibilities of the CSR Committee include:
  • a) Formulating and recommending to the Board of Directors the CSR Policy and indicating activities to be undertaken.
  • b) Recommending the amount of expenditure for the CSR activities, and
  • c) Monitoring CSR activities from time to time.

6. Undertaking CSR Activities –

WinWire will undertake its CSR activities, approved by the CSR Committee, through such other entity/organization as approved by the CSR Committee. The surplus arising out of the CSR activities, projects or programs shall not form part of the business profit of the Company.

7. Governance

The Company through a registered trust or a registered society can undertake CSR activities as per the provisions of the Companies Act, 2013. Accordingly, WinWire with such other entity will work closely with and support the Board and the CSR Committee in implementing CSR activities of the Company. WinWire with such other entity will assist the CSR Committee in identifying the areas of CSR activities, programs and execution of initiatives as per defined guidelines. WinWire with such other entity will also assist the Board and the CSR Committee in reporting the progress of deployed initiatives and in making appropriate disclosures (internal/external) on a periodic basis.

8. CSR Initiatives –

Pursuant to Schedule VII of the Act and the CSR Rules, the Company shall undertake CSR activities included in its Annual CSR Plan, as recommended by the CSR Committee at the beginning of each year. The Committee is authorized to approve any modification to the existing Annual CSR Plan or to propose any new program during the financial year under review.

9. Reporting and publication of CSR policy –

As per the CSR Rules, the contents of the CSR Policy shall be included in the Directors’ Report and the same shall be displayed on the Company’s website, if any.

10. Funding, Selection and Monitoring Process –

WinWire with such other entity will receive requests for funding of projects throughout the calendar year. Its panel of experts will evaluate proposals received and projects will be prioritized by assessing their impact. The Company with such other entity will then forward its recommendations to the CSR Committee. The CSR Committee will deliberate on the proposals and approve proposals for implementation at its discretion. WinWire representatives with such other entity will collaborate with stakeholders to monitor the status of each project and will report its findings to the CSR Committee periodically.