Corporate Social Responsibility Policy


Simpex Overseas Private Limited recognizes that business enterprises are economic organs of society and depends on societal resources. It is Simpex’s belief that a company's performance must be measured by its contribution to building economic, social and environmental capital towards enhancing societal sustainability.

While Simpex Overseas strive to deliver excellence in its business, it will whole heartedly contribute towards Ferrous and non ferrous Metal Item. Simpex Overseas will trading in Ferrous and non ferrous Metal Item and its scarp.

Note: These initiatives will be independent of the normal conduct of Simpex Overseas. Programmes, projects and activities (collectively "CSR Programmes") carried out in this regard will be the subject matter of this Policy.

  1. Compliance statement

The CSR Committee and CSR policy of the company was made and approved by the company’s Board of Directors on 05/03/2023 for adoption as the company’s CSR policy.

The contents of this policy shall be appropriately disclosed in the Board report in accordance with the requirements of the Companies Act, 2013, and rules framed there under:

In compliance with the requirements of the Companies Act, 2013 it is confirmed that -

  • a copy of this policy will be placed on the Company’s website / internal portal (if any), and
  •  any surplus arising out of the CSR projects, programmes or activities shall not form part of the business profit of the company.
  • Company will pursue CSR Programmes primarily in areas that fall within the economic vicinity of the Company's operations to enable close supervision and ensure maximum development.
  1. CSR policy: Governance structure and approach

3.1. Governance

  1. Every year, the CSR Committee will place for the Board's approval, a CSR Plan delineating the CSR Programmes to be carried out during the financial year and the specified budgets thereof. The Board will consider and approve the CSR Plan with any modification that may be deemed necessary.
  2. The CSR Committee will assign the task of implementation of the CSR Plan within specified budgets and time frames to such persons or bodies as it may deem fit.
  3. The persons/bodies to which the implementation is assigned will carry out such CSR Programmes as determined within the specified budgets and timeframes and report back to the CSR Committee on the progress thereon at such frequency as the CSR Committee may direct.
  4. The CSR Committee shall review the implementation of the CSR Programmes once a quarter and issue necessary directions from time to time to ensure orderly and efficient execution of the CSR Programmes in accordance with this Policy.
  5. Once every six months the CSR Committee will provide a status update to the Board of Directors on the progress of implementation of the approved CSR Programmes carried out during the six month period.
  6. At the end of every financial year, the CSR will submit its complete report to the Board regarding the carrying out of CSR activities during the year.

  3.2. Board of Directors:

In line with the provisions of Section 135 of the Act, Pacifica’s Board of Directors will be responsible for the following: 

  • Constitute a CSR committee and approve the CSR policy;
  • Make sure the company spends, in every financial year, at least 2% of its average net profit during the three preceding financial years, in pursuance of this policy.
  • Approve the CSR action plan and budget as proposed by the CSR committee in accordance with Schedule VII of the Companies Act, 2013.
  • Make disclosures in the Board report as per clause (o) of sub-section (3) of section 134 including particulars specified in Annexures to the CSR rules.
  • If the company fails to spend the amount, reasons for not spending to be specified in the above report.

3.3. CSR committee

Roles and powers of the CSR committee: 

  • Formulate CSR policy and seek approval from the Board of Directors of the company. Review the policy on a yearly basis.
  • Formulate and share the CSR action plan with budget for the year with the Board of Directors and seek approval. Implement the activities either through the Implementation Partner or directly through its own team.
  • Spend the allocated amount on CSR activities once approved by the Board of Directors and create a transparent monitoring mechanism of CSR initiatives.
  • Submit periodic reports to the Board for the activities undertaken.
  1. CSR Activities

As per Schedule VII of Companies Act, 2013, activities which may be included by company in our Corporate Social Responsibility Policies Activities are:—

(i) Eradicating hunger, poverty and malnutrition, ‘promoting health care including preventive 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.

However, activities to be undertaken by the company amongst the areas or subject specified above will be related to Health and Sanitation.

  1. CSR Expenditure

CSR expenditure will include all expenditure, direct and indirect, incurred by the Company on CSR Programmes undertaken in accordance with the CSR policy of the Company.

Any income arising from CSR Programmes will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.

Moreover, any surplus arising from any CSR Programmes shall be used for CSR only.

It will be ensured that the Company spends the entire allocated amount on CSR activities belonging to that year.

Provided further that if the company fails to spend such amount, the Board shall, in its report made under Section 134 of the Companies Act, 2013, specify the reasons for not spending the amount and unless the unspent amount relates to any ongoing project referred to in sub-section (6) of Section 135 of the Companies Act, 2013, transfer such unspent amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.

Any amount remaining unspent out of the allocated amount, pursuant to any ongoing project, undertaken by a company in pursuance of its Corporate Social Responsibility Policy, shall be transferred by the company within a period of thirty days from the end of the financial year to a special account to be opened by the company in that behalf for that financial year in any scheduled bank to be called the Unspent Corporate Social Responsibility Account, and such amount shall be spent by the company in pursuance of its obligation towards the Corporate Social Responsibility Policy within a period of three financial years from the date of such transfer, failing which, the company shall transfer the same to a Fund specified in Schedule VII, within a period of thirty days from the date of completion of the third financial year.

  1. Modalities of Implementation

The Company will implement the CSR programs either through itself or through a Trust or Section 8 Company or Society or Foundation or any other entity operating within India in accordance with its stated policy.

Implementation of CSR programs would be undertaken by implementation partners with an established track record with support from project management consultants and social enterprises, as may be required.

While availing services of consultants or any other organizations, the Company will seek proposals from various consultants and organizations and will then make a final decision based on criteria which are critical to the success of that particular CSR program.

  1. Monitoring and Reporting Framework and Communication

The CSR Committee shall meet as and when the need arises to review and guide the CSR activities of the Company. They shall meet to monitor the progress of CSR programs, CSR spending, and review if any changes are required.

At each of the program locations, the CSR programs will be implemented and monitored by the members of the CSR Committee. The Committee will maintain its own monitoring schedule, as appropriate, to collect the required inputs from organizations, implementation partners and beneficiaries to ensure effective implementation.

The Company may undertake an assessment, as and when needed, in order to evaluate the social impact of its CSR programs on the communities. This will also help the Company to obtain learnings which will help increase program efficiency and scalability.

The Company will incorporate the details of CSR activities in the annual report of the Company. The CSR activities will also be reflected in the annual accounts of Company and will be mentioned in the Director’s report.

Reporting will constitute an integral part of our CSR initiatives, as we at Pacifica, remain committed to being transparent and accountable to our stakeholders. The objective of reporting is not only to update our stakeholders, but also to receive their feedback, and incorporate their suggestions into our future CSR strategies.

  1. Disclosure

Publishing a CSR report:

Reporting will constitute an integral part of our CSR initiatives, as we at Pacifica, remain committed to being transparent and accountable to our stakeholders. The objective of reporting is not only to update our stakeholders, but also to receive their feedback, and incorporate their suggestions into our future CSR strategies.

  1. Amendments to the policy

The Board of Directors on its own and/or as per the recommendations of the CSR committee can amend this policy, as and when deemed fit. Any or all provisions of this CSR policy are subject to the applicable provisions of the Companies Act, 2013 and any subsequent amendments thereof from time to time.