NESPORTS FOUNDATION

1. Preamble

NESPORTS FOUNDATION (hereinafter "the Foundation") is a Section 8 non-profit company registered under the Companies Act 2013, dedicated to unlocking the sporting potential of athletes across the eight states of Northeast India. Operating at the intersection of sports science, media, and community development, the Foundation addresses the unique structural barriers - funding deficits, geographic isolation, and limited media visibility - that prevent talented athletes from the region from reaching their full potential.

This policy articulates the Foundation's framework for identifying, approaching, and formalising CSR partnerships with Indian and multinational corporations that are required, or choose, to deploy CSR funds under Section 135 of the Companies Act 2013 and the Companies (CSR Policy) Rules 2014 (as amended). The Foundation is a recipient-seeker of CSR resources, not a CSR-granting entity.

2. Purpose and Scope

This policy governs how NESPORTS FOUNDATION:

• Identifies and prioritises prospective CSR partner companies;
• Prepares and presents CSR funding proposals;
• Evaluates the alignment of corporate CSR priorities with the Foundation's mission;
• Negotiates, formalises, and manages CSR partnership agreements;
• Reports on the utilisation of CSR funds received; and
• Maintains compliance with applicable laws and donor-governance standards.

The policy applies to all staff, Board members, and authorised representatives of the Foundation engaged in CSR fundraising and partnership activities.

3. Regulatory Alignment

The Foundation's CSR-seeking activities are grounded in Schedule VII of the Companies Act 2013, which specifies eligible CSR activities. The programmes of NESPORTS FOUNDATION fall under the following Schedule VII heads:

Partner companies may direct their CSR obligations under any of the above clauses to the Foundation's eligible programmes, subject to confirmation by their own CSR Committee.

4. Foundation Programmes Eligible for CSR Funding

The following programmes constitute the core portfolio available to CSR partners. Companies may fund one specific programme or opt for a multi-programme partnership.

5. CSR Partner Eligibility Criteria

The Foundation will approach and accept CSR partnerships from companies that meet the following minimum criteria:

• The company is obligated to spend on CSR under Section 135 of the Companies Act 2013, or voluntarily chooses to deploy CSR funds in accordance with the Rules;
• The company's CSR policy permits funding in areas covered by Schedule VII, Clauses (vii), (ii), (iii), or (x);
• The company has no ongoing regulatory proceedings that would prevent it from entering into a valid legal and financial agreement;
• The company is willing to deploy funds through a formal CSR implementation agreement with the Foundation; and
• The company's values and public conduct are consistent with the Foundation's commitment to athlete welfare, gender equity, and community development.

The Foundation reserves the right to decline a CSR partnership if, in the judgment of the Board, the association would compromise the Foundation's integrity, independence, or mission alignment.

6. CSR-Seeking Process

Step 1 - Prospect Identification

The Foundation's CSR Partnerships team will maintain a live prospect list of eligible companies, identified through public CSR disclosures, MCA-21 filings, industry networks, and referrals. Priority will be given to companies with operations or business presence in Northeast India, and to companies in sectors aligned with the Foundation's thematic areas (FMCG, telecom, BFSI, infrastructure, sports goods, media).

Step 2 - Expression of Interest

An Expression of Interest (EoI) letter or email will be sent to the company's CSR Committee, outlining the Foundation's mission, eligible programmes, and the specific CSR requirement it can fulfil. The EoI will include a summary impact sheet and registration credentials.

Step 3 - Detailed Proposal

Upon positive response, the Foundation will submit a structured CSR Proposal containing:

• Programme description, objectives, and measurable outcomes;
• Proposed budget and year-wise utilisation plan;
• Geographic scope and target beneficiary profile;
• Monitoring & Evaluation (M&E) framework;
• Compliance documents: 12A, 80G, FCRA (if applicable), Darpan registration; and
• Audited financial statements for the prior year.

Step 4 - Due Diligence

The Foundation will co-operate fully with any due-diligence process initiated by the prospective partner, including site visits, third-party verification, and document audits.

Step 5 - Agreement Execution

Approved partnerships will be formalised through a CSR Implementation Agreement signed by the Executive Director of the Foundation and an authorised representative of the partner company. The agreement will specify: fund quantum, disbursement schedule, programme targets, reporting obligations, branding rights, and exit clauses.

Step 6 - Implementation & Reporting

The Foundation will implement the agreed programme and submit periodic progress and utilisation reports as per the schedule in the Agreement. A final impact report with third-party verification will be provided at programme close.

7. Fund Utilisation and Governance

All CSR funds received by the Foundation will be:

• Maintained in a separate, dedicated bank account or tracked through a dedicated cost-centre in the Foundation's accounting system;
• Utilised exclusively for the programme(s) specified in the CSR Implementation Agreement;
• Subject to annual statutory audit by a Chartered Accountant;
• Reported to the partner company through quarterly utilisation statements and an annual impact report;
• Disclosed in the Foundation's annual report and public accounts; and
• Refunded to the partner company, to the extent of unspent balance, in accordance with the agreement and applicable CSR rules, if the programme is discontinued.

The Foundation's Board of Directors holds oversight responsibility for all CSR funds received. The Finance & Audit Sub-Committee reviews utilisation on a quarterly basis.

8. Branding and Partner Recognition

All branding arrangements are subject to the Foundation's brand guidelines. The Foundation retains editorial control over all content. Partner logos will not be placed on content that conflicts with the partner's brand values.

9. Impact Metrics Committed to CSR Partners

NESPORTS FOUNDATION commits to reporting the following outcome indicators to all CSR partners:

In addition to programme-specific metrics, the Foundation will provide: fund utilisation certificates, Chartered Accountant-certified utilisation statements, geotagged photographic documentation, and beneficiary testimonials.

10. Ethical Standards and Conflict of Interest

The Foundation upholds the highest standards of transparency and integrity in its CSR-seeking activities:

• No gifts, honoraria, or personal benefits will be offered to or accepted from corporate representatives in connection with a CSR partnership;
• Board members or staff with a personal or financial interest in a prospective CSR partner must declare such interest and recuse themselves from related decisions;
• The Foundation will not misrepresent its activities, beneficiary numbers, or outcomes in any CSR proposal or report;
• The Foundation will not accept CSR funds from companies engaged in activities that are incompatible with its values (e.g., tobacco, weapons, child exploitation); and
• All CSR proposals and agreements will be approved by the Executive Director and noted by the Board.

11. Compliance and Legal Framework

This policy operates within the following legal and regulatory framework:

• Section 135, Companies Act 2013 - Corporate CSR obligations;
• Companies (CSR Policy) Rules 2014 (as amended up to date);
• Schedule VII, Companies Act 2013 - Eligible CSR activities;
• FCRA 2010 - Foreign contribution regulations (applicable if overseas funding is received);
• Income Tax Act 1961, Sections 12A and 80G - Tax-exempt status and donor deductions;
• NGO-Darpan (NITI Aayog) registration requirements; and
• Foundation's own Articles of Association and Board-approved financial policies.

12. Policy Review

This CSR Seeking Policy will be reviewed annually by the Board of Directors, or earlier if there is a material change in applicable legislation, the Foundation's scale of operations, or its programme portfolio. Amendments require Board approval.

13. Contact for CSR Partnerships

Approved by the Board of Directors
NESPORTS FOUNDATION
June 2025  |  Version 1.0

Disclaimer: This document is a policy statement of NESPORTS FOUNDATION governing its approach to seeking CSR partnerships. It does not constitute legal, financial, or regulatory advice to any corporate entity. Companies are advised to consult their own CSR Committees and legal counsel before entering into any CSR partnership.