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ORO Precious Metals Private Limited (Formerly known as Raia Jewels Private Limited) (“the Company”) introduced a brand, ORO that has established itself as a trustworthy and innovative gold product manufacturer in the jewellery sector of India and abroad. The Company has expertise as jewellery manufacturers comes from a heritage of over 125 years and believes in, constantly innovating products and styles to match its expertise with constantly evolving technology.

Through our efficient manufacturing systems and quality craftsmanship, the company’s focus has always been to constantly innovate its product such that it is in sync with customer expectations and looks to surpass its vision of design and quality.


Corporate bodies’ involvement in CSR activities is not a new concept in India. Industrial majors have been engaged in social development activities for long back. However, Section 135 of the Companies Act, 2013 has brought it under the legal purview. The concept of CSR is introduced through the “Comply-or-Explain” mandate. It mandates qualifying companies to constitute a Corporate Social Responsibility Committee to effectively monitor CSR activities of the Company. Further, the Companies (Corporate Social Responsibility Policy) Rules, 2014 lay down the framework and modalities for carrying out CSR activities which are specified in Schedule VII of the Act.

The management of the Company expresses its willingness and support for the CSR concept, and its legal framework and shall abided to it. The CSR Committee of the Board had drafted a CSR Policy which was approved by the Board of Directors.


The policy for Corporate Social Responsibility is designed and governed with a clear focus on promoting and preventing health, promoting education in India, including giving special attention towards children, women, the elderly, and the differently abled etc. As part of its dedicated approach to creating economic opportunity in the communities in which it operates, the Company has been contributing its time, expertise and resources to help communities and undertaking a series of initiatives that are locally relevant.

The CSR activities of the Company shall include, but not be limited to any or all of the sectors/activities as may be prescribed by Schedule VII of the Companies Act, 2013 and Companies (Corporate Social Responsibility Policy) Rules, 2014 (“Rules”). Unless the context otherwise requires, the definitions mentioned in the notification dated February 27, 2014, and the Companies Act, 2013 shall apply to this CSR Policy. 


Pursuant to Section 135 of the Companies Act 2013, The Company, in cases, where the amount required to be spent by a company on CSR does not exceed INR 50 Lakh, the requirement for constitution of the CSR Committee is not mandatory. The functions of the CSR Committee, in such cases, can be discharged by the Board of Directors of the company.

Hence our Company has not constituted a CSR committee and all the responsibilities related to CSR are taken care of by the Board of Directors –

  1. Mr. Ravish Pahuja
  2. Mr. Avinash Mohan Pahuja

The Board shall decide the CSR programs and initiatives for each financial year and accordingly as per the agenda. The CSR agenda for the financial year shall indicate the activities to be undertaken for the financial year and the expenditure to be incurred on the CSR programs and initiatives.

The Board of Directors of the Company may re-constitute the Committee, as and when required to do so, by following the sections, sub-sections, rules, regulations, and notifications issued or to be issued, from time to time, by the Ministry of Corporate Affairs or the Central Government of India. The Board shall exercise powers and perform the functions assigned to it by the Act.


Pursuant to Schedule VII of the Companies Act, 2013, the Committee has approved the following activities as “CSR Activities” to be undertaken under the CSR policy of the Company. The Board of Directors of the Company has reviewed the said activities and expressed its consent to the Committee to pursue the said activities under the CSR policy of the Company as per the Act.

Further, the Company will review the sectors/activities from time to time and make additions/ deletions/ clarifications to the above sectors/activities.


The Committee can undertake one or more of the following activities, which relate to Schedule VII of the Companies Act, 2014 as its projects for CSR activity viz.,

  1. Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation including contribution to the Swachh Bharat Kosh set up by the Central Government for the promotion of sanitation and making available safe drinking water;
  2. Promotion of education, including special education and employment enhancing vocation skills, especially among children, women, elderly, and the differently abled and livelihood enhancement projects;
  3. Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, daycare centres and other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
  4. ensuring environment 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;
  5. 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;
  6. measures for the benefit of armed forces veterans, war widows and their dependents;
  7. training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic sports;
  8. Contribution to the Prime Minister’s National Relief Fund or any other fund set up by the Central Government for Socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women;
  9. contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government;
  10. rural development projects.
  11. Slum area development

The Committee intends to carry out its CSR activities through its own personnel/ department established with persons qualified to undertake such activities.


The CSR committee will decide on the locations for CSR activities. 


The Company shall allocate the budget for CSR Activities. The minimum budgeted amount for a financial year shall be 2% of average net profit of three immediately preceding financial years. The Company may allocate more fund/amount than the amount prescribed under section 135 of the Companies Act, 2013 for CSR Activities of any financial year. The Committee shall calculate the total fund for the CSR activities and recommend to the Board for approval. The Board shall approve the total fund to be utilized for CSR activity for the respective financial year.

CSR expenditure shall include all expenditure including contribution to corpus for projects or programs relating to CSR activities approved by the Board on the recommendation of its CSR Committee, but does not include any expenditure on an item not in conformity or not in line with activities which fall within the approved CSR activities.


Out of the approved CSR activities, the Committee shall decide which activity/project should be given priority for the respective financial year. While arriving at the decision of the activity to be undertaken for the respective year, the Committee shall analyse the basic need of the community/ area in which the Organisation operates or at the place where its registered office is situated. The Committee shall record its findings and prioritise the CSR activities.


After prioritizing the activity the Committee shall finalise the detail implementation project/programme, including planning for expenses against the total budget allocated for CSR activities.


At the organisational level for the implementation of the agreed CSR activity, the committee may constitute an implementation team or authorise any of the Department of the Company to organize the implementation of the CSR activity. The team or respective department shall monitor the implementation process from time to time, on behalf of the CSR committee and place a report to the Committee regarding the progress of the activity implementation, on a quarterly basis. The respective department or implementation team would be responsible for reporting of any irregularity to the Committee on an immediate basis.


The Board of Directors shall constantly monitor the implementation of the CSR activities. The CSR committee shall place a progress report, including details of expenses, before the Board on a quarterly basis. The Board shall review the same and suggest recommendations, if any, to the committee with regard to the implementation process.


The Committee is responsible for undertaking CSR activities as per the approved CSR Policy. Apart from quarterly reports to the Board about the implementation of CSR activity, a detailed report containing the implementation schedule, total budget allocated, actual expenses incurred, surplus arising, if any, result achieved, further work to do in the concerned CSR activity, Recommendation for the CSR activities for next year etc. should be placed before the Board for its consideration. Any surplus arising out of the fund allocated for CSR activity shall not be part of the business profit of the Company.


Our Board of Directors, our Management and all our employees support to the philosophy of compassion, characterised by a willingness to build a society that works for everyone. This is the cornerstone of our CSR policy.

Our Corporate Social Responsibility policy conforms to the relevant section of the Corporate Social Responsibility, Rules made under Companies Act, 2013 and amendment(s) to be made thereto in future.


The Committee or the Board reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification shall be inconsistent with the applicable provisions of the Act or any law for the time being in force