Corporate Social Responsibility (CSR) Policy

Last updated: 2023-08-03

Introduction

Corporate Social Responsibility, commonly called CSR, covers the entire process by which an organisation approaches, defines and develops its relationship with stakeholders for the common good, and demonstrates its commitment in this regard by adoption of appropriate strategies and projects. The CSR is not charity or mere donations but a way of going beyond business as usual, creating shared value and contributing towards social and environmental good.

The core element of CSR is the continuing commitment by Stripe India Private Limited (“Stripe India”) to ethical principles and protection and care of the environment whilst improving the quality of life of all stakeholders including local communities and society at large. Stripe India aims at creating shared value for all stakeholders involved in our CSR journey.

Objective

Globally, Stripe Inc. business philosophy highlights the theme of respect and collaboration. Stripe India undertakes CSR with the basic aim of contributing towards the advancement of society and scientific progress in close partnership with others. Through its CSR programs and projects, Stripe intends to focus on supporting and empowering marginalised groups, including but not limited to micro and small entrepreneurs and women and girls, through education, capacity building and skills development.

Scope and Applicability

Ministry of Corporate Affairs (MCA), in exercise of its powers under sub-section (3) of Section 1 of the Companies Act, 2013 and vide Notifications dated 27 February, 2014, notified 1 April, 2014 as the date, on which Section 135 and Schedule VII of the Act came into effect. Further, MCA vide Notification dated January 22, 2021 notified major amendments in the CSR provisions thereby amending rules concerning CSR expenditure, implementation, reporting, disclosure and transfer of unspent CSR. This Policy applies to all CSR projects that will be undertaken by Stripe India and shall fulfil all the requirements of Section 135 of the Companies Act, 2013 (including amendments from time to time). Stripe India shall ensure all these activities are over and above the normal course of business and are in line with Schedule VII of the Companies Act, 2013. This Policy will be periodically reviewed and updated in line with the relevant codes of legislation and best practices that can be adopted by Stripe India. 

This policy shall be applicable to Stripe India which is mandated with the CSR expenditure obligations as per Section 135 of the Companies Act, 2013 read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended from time to time. This Policy takes into account all relevant provisions on CSR under the Companies Act and shall serve as a guiding document to help identify, execute and monitor CSR projects in keeping with the spirit of the Policy.

Policy Vision and Strategy

Stripe India’s business philosophy is based on a commitment to sustainable and inclusive growth  with respect and collaboration. Through our policies and programs, Stripe India seeks to promote social & economic inclusion of the communities by improving their overall quality of life and mainstreaming economically and socially challenged groups by drawing them into the cycle of growth, development and empowerment through education, skills development and capacity building, in particular for those at the bottom of the pyramid which are unequally endowed/enabled.

The CSR strategy of Stripe India shall endeavour to create long term values for communities and society. To this end, following strategies and action-plan shall be adopted by the Company:

  • Mobilise resources and expertise for the CSR initiatives.
  • Build capacities for CSR at all levels.
  • Involve employees to volunteer for CSR activities, if possible.
  • Make strategic grants to support worthwhile projects/programs.
  • Be transparent, consistent and fair in communication.
  • Carry out periodic reviews and reporting.
  • Continuous compliance with statutory requirements.

Purpose of the Policy 

The CSR policy serves as a framework for Stripe India’s CSR activities and enables adherence to laws, ethical standards and international practices in this regard. This policy will act as a guiding document to help identify, execute and monitor CSR projects in keeping with the spirit of the policy. The key purpose of this Policy is to:

  • Outline the developmental areas in which Stripe India shall get involved in through its CSR activities.
  • Define governance structure for CSR management within Stripe IN.
  • Serve as a guiding document aiding in identification, execution and monitoring the CSR projects.
  • Describe the treatment of surpluses from CSR activities.

CSR Framework and Focus Areas

Stripe India will demonstrate its alignment with the CSR laws by contributing to the economic and social development of the communities, safeguarding of the environment and humanitarian assistance to the challenged. While these components are universal and will be at the centre of most initiatives, there are various components which make up this huge canvas and shall be considered by Stripe India for its CSR activities in accordance with Schedule VII of the Companies Act, 2013. Some of these components include:

  • Eradicating poverty, hunger and malnutrition, promoting health care which includes sanitation and preventive health care, contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water.
  • Improvement in education which includes special education and employment strengthening vocation skills among children, women, elderly and the differently-abled and livelihood enhancement projects.
  • Improving gender equality, 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.
  • Safeguarding environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining a quality of soil, air and water which also includes a contribution for rejuvenation of river Ganga.
  • 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 arts and handicrafts.
  • Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows.
  • Training to stimulate rural sports, nationally recognized sports, Paralympic sports and Olympic sports.
  • Contribution to the Prime Minister’s National Relief Fund, Contribution to the Prime Minister’s National Relief Fund (PM-CARES) or any other fund set up by the Central Government for socio-economic development providing relief and welfare of the Scheduled Castes, the Scheduled and backward classes, minorities and women.
  • Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government, State Government, Public Sector Undertaking or any agency of the Central Government or State Government.
  • Contributions to public funded Universities, IITs, National Laboratories and autonomous bodies established under DAE, DBT, DST, Department of Pharmaceuticals, Ministry of AYUSH, Ministry of Electronics and Information Technology and other bodies, namely DRDO, ICAR, ICMR and CSIR, engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).
  • Rural development projects.
  • Slum area development.
  • Disaster management, including relief, rehabilitation and reconstruction activities.

Implementing Agency Guidelines

Stripe India endeavours to create programs that create sustainable impact for its beneficiaries and geographies. For this purpose, Stripe India can partner with any of the following (as an Implementation Agency) for undertaking various CSR activities, as mentioned above to fulfil its CSR obligation:

  • Registered NGOs/Trusts/Societies/Foundations or any not-for-profit implementing agency(ies) that has expertise in the identified areas of intervention with established track record of carrying out such activities.
  • Implementing agency(ies) should be eligible and compliant with the provisions of the law and other rules and guidelines required to carry out CSR activities.
  • Partner with implementing agency(ies) having a clear intent of “no commercial benefit” and “no conflict of interest” criteria. The primary intent of funding, supporting projects and programmes is to ensure benefit to society and no undue intended or unintended “profit or commercial benefit outcome” is created for the implementing agency.
  • Partner with corporate CSR entities which share alignment with Stripe India’s values and themes, for programs aimed at achievement of Stripe India’s CSR objectives.
  • Stripe India will not form partnership with any registered NGO/Trust/Society/Foundation or any entity wherein there is a Related Party Transaction with any member of the said entity. 

Roles and responsibilities of the Implementation Agency

  • Implementing Agency should ensure that the roles, responsibilities and membership committee and/or Board or other decision making bodies are clearly defined and documented and the information is accessible for all the stakeholders.
  • Implementing Agency should ensure adequacy of in-house expertise to ensure implementation of the CSR project.
  • It is the ethical and legal obligation of the Implementing Agency that it shall use the grant in an efficient and planned manner.
  • Implementing Agency should give appropriate acknowledgment and prominence towards Stripe India’s branding for implementation activities in Stripe India funded projects.
  • Implementing Agency to provide the project progress report and Utilisation Certificate on a quarterly basis or as required by Stripe India.
  • With effect from 1 April, 2021, registration of such entities shall be mandatory by filing form CSR 1. A Unique CSR registration number shall be generated for each entity.
  • Implementing agency(ies) shall satisfy all statutory requirements as specified in the Companies Act, 2013 and also have necessary registration as specified under sections 12A and 80G of the Income Tax Act, 1961.

CSR Budget and Contribution

Stripe India will endeavour to contribute and spend at least 2% of the average net profits of the Company made during the three immediately preceding financial years or such amount as may be recommended by the Board from time to time in pursuance of this Policy.

Stripe Board shall decide the CSR budget for the CSR activities in each of the financial years in accordance with the applicable provisions of the Companies Act, 2013 and CSR Rules. The Board shall propose to distribute the budget on CSR activities in such proportion and in a manner that meets the objectives of the Stripe India CSR Policy. It shall also ensure that Stripe India spends the allocated budget on CSR initiatives that are consistent with the applicable law, guidelines, regulations and Stripe India CSR Policy or any other specific approval accorded by the Board. All the utilisation certificates, agreements, invoices and any other supporting document pertaining to the actual CSR spend will be diligently documented and periodically audited and reviewed.

In case of failure to spend the amount related to an ongoing project (a multi-year project undertaken by Stripe India to fulfil its CSR obligation within three years, excluding the financial year in which it was commenced)  in a financial year, the amount shall be transferred within a period of thirty days from the end of the financial year to a special account to be opened by the company for that purpose in any scheduled bank to be called the ‘Unspent Corporate Social Responsibility Account (UCSRA)’ latest by 30th day of April of next financial year. The amount transferred to UCSRA should be utilised for the project within a period of 3 years, else the same needs to be transferred to a fund specified in Schedule VII.

In case of failure to spend the amount not related to an ongoing project in a financial year, the amount shall be transferred within a period of 6 months of the close of the financial year to a Fund specified in Schedule VII, in addition to disclosure of reason for not spending in the Board Report. For example, the amount remaining unspent (other than ongoing projects) for the current financial year shall be transferred to Schedule VII fund latest by 30th day of September of next financial year.

Treatment of Surplus

Any surplus generated from CSR projects undertaken w.e.f. Financial year 2022-23 will be tracked and adjusted towards the CSR expenditure of the subsequent financial year.

Activities not permissible under CSR 

The below activities will be not undertaken or considered under the ambit of CSR projects or as part of any CSR initiatives:

  • Activities that significantly benefit the employees of the company.
  • Contribution of any amount directly or indirectly to any political party under section 182 of the act.
  • Any activity undertaken by the company outside India (except for training of Indian sports personnel representing any State or Union territory at National level or India at International level).
  • Activities undertaken in pursuance of normal course of business of the company (except COVID-19 related R&D up to the financial year 2022-23, subject to certain conditions).
  • Activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services.
  • Activities carried out for fulfilment of any other statutory obligations under any law in force in India.

Governance Structure

The governance structure for the CSR interventions of Stripe India will be headed by the Board in accordance with the requirements of Section 135 of the Companies Act, 2013. The Board will meet at least once a year to consider the CSR expenditure, approve the CSR projects/programs and their implementation. The Board of Directors of Stripe India are ultimately accountable for the CSR projects undertaken by the Company.

  • To carry out due diligence before execution of any project approved by the Board of Stripe India.
  • Due diligence process shall include analysing below mentioned details of prospective Implementing Agency (IA):
    • Audited financial statements of last 3 years;
    • Annual Project Report of last 3 years;
    • PAN of Implementing Agency and of Board members/Trustees;
    • 12A/80G of the Income tax Act;
    • Details of Board members & regularity of Board meetings;
    • To ensure declaration of any conflict of interest with Stripe India.
  • To be the central co-coordinating point for handling Stripe India’s overall CSR programs across the company.
  • To interface with the various organisational units internally and externally to ensure effective implementation of projects undertaken.
  • To ensure proper utilisation of funds through screening of UCs (Utilisation Certificate) and other financial documents and reporting on actual field implementation through quarterly field visits.
  • To ensure that any deviation of budget/timeline/quality of work is reported to the Chief Executive Officer in a timely manner.
  • Interface with the Stripe India’s Board to obtain necessary approvals and resolutions as may be required.
  • Reporting to the Management progress made in the CSR interventions throughout the year.
  • To plan the annual budgets for CSR activities to be undertaken.
  • To get the audit done for all projects under implementation.
  • To maintain transparency in project monitoring by maintaining a dashboard on the Stripe India website.

Compliance, Monitoring and Reporting

To plan, implement, monitor and manage all CSR projects & activities for Stripe India. As part of compliance, monitoring and reporting, following is expected to be delivered:

  • Monitoring of the approved projects, which may include site visits, independent beneficiary reviews and impact analysis. This will be done based on the milestones and success indicators, together with the Implementing Agency. 
  • Impact assessment shall be required only when the CSR obligation is INR 10 crore or more in the preceding three financial years (as per the provisions laid down under the Companies Act, 2013, as amended from time to time).
  • Stripe India shall undertake impact assessment, through an independent agency, of CSR projects having outlays of INR one crore or more, and which have been completed not less than one year before undertaking the impact study. The impact assessment reports shall be placed before the Board and shall be annexed to the annual report on CSR.
  • Conduct an impact assessment and monitor the project sites on a quarterly basis or as required by Stripe India and submit a visit report on the basis of milestones/achievements and actual findings.
  • Project spend against the allocated budget shall be strictly monitored and any actual/likely spend overflow/deviation must be reported to the Board. Any further expenditure must be approved by the CEO before further progress.
  • Stripe India will report on significant CSR activities as part of its Board Report. The reporting format shall be the same as prescribed in the rules notified by the Ministry.

To formulate implementation plans for the CSR activities by clearly defining the following:

  • Activities to be undertaken.
  • Budgets proposed.
  • Time frame for implementation.
  • Responsibilities and authorities for implementation.
  • Results expected to be achieved post-implementation. 

Special Circumstance and Exception

Any deviation to this policy must be approved by the Board of Directors of the Company.

Amendment to the Policy

Stripe India reserves the right to amend or modify the Policy in whole or in part, so long as it is not inconsistent with the provisions of the Companies Act, 2013 and Rules as laid down by the Ministry, from time to time.