Mirum CSR Policy

Title and Applicability 

Mirum Digital Private Limited (hereby referred to as “the Company”) has developed its Corporate Social Responsibility (CSR) Policy in accordance with section 135 of the Companies Act 2013 (hereby referred to as “the Act”) and in accordance with the CSR rules (hereby referred to as “the Rules”) notified by the Ministry of Corporate Affairs, Government of India on 27th February 2014.
The Policy shall apply to all CSR Projects/Programs undertaken by the company in India as per Schedule VII of the Act.

Validity of CSR Policy

The Company CSR Policy has been approved by the Board on December 23, 2019. The CSR Policy may be amended as required by the Board.

CSR Budget

The Company Board of Directors shall endeavor to ensure that in each financial year the company spends at least 2% of the average Net Profit made during the three immediate preceding financial years.
Any surplus arising out of CSR Projects shall not form part of business profits of the company.
As per section 135 of the Act, the Company will disclose, in its annual report signed off by the Board of Directors, CSR expenditure details including under spending, if relevant, as per the guidelines provided by the Ministry of Corporate Affairs.
The Company will collaborate or pool resources with its group companies to undertake CSR activities through its own Group Foundation.

Maintenance of CSR Policy

The CSR Policy will be maintained by the CSR Committee. Further, the CSR Policy will be reviewed as and when required by the Board.

CSR Vision 

  • Objectives of the company CSR 
    Support holistic development in the communities we operate in
    Pioneer creative, need based, interventions that are backed by sound knowledge
    Ensure credibility through transparent, outcome based projects that are rigorously monitored
    Leverage our influence to accentuate the voice of organisations working with children
    Think out of the box and seek innovative solutions
  • Thematic Focus
    We aim to work along with the community, as a trusted partner, to enable children and youth to achieve their full potential and become productive members of society. To do this, our CSR programs will cover the themes of Life Skills & Education, Skill Training and Health with a focus one

    • creating a strong foundation for learning;
    • accelerating education;
    • reduction of school drop-outs; and
    • increasing potential for employment

    The Company may undertake any other activity in compliance with schedule VII, which would improve the lives of the people in the community.

  • Location and Target Population
    The CSR program will focus on children and youth from vulnerable groups and marginalized communities. We will also endeavor to reach out to girl child, people with disabilities and orphans.
    The geographic focus will primarily be on urban slums, peri-urban areas, and rural areas in the vicinity of cities where our company is located. However, this shall not prevent the company from working in other geographies based on development needs of those areas.
  • Guiding Principles 
    Interventions will be based on community needs
    Interventions aim to be sustainable and scalable
    Interventions will leverage existing resources.
    Interventions will be measurable
    Interventions will be inclusive


The Company’s CSR Programs will be identified, implemented and modified (if needed) as per the Board approved CSR Policy. The CSR Programs will be decided by the CSR team in accordance with the guidelines laid down by this CSR Policy.
The Company may work with external consultants to assist the Company in the implementation, execution and monitoring and evaluation of its programs.

    • Execution Modality
      The Company can implement its CSR activities through the following methods:

      • Directly on its own; or
      • Through its own group non-profit foundation set-up so as to facilitate this initiative; or
      • Through independently registered implementing agencies / non-profit organizations (hereby referred to as “partners”) that have a record of at least three years in similar such related activities

The Company will select its partners after adequate due diligence and alignment with the Company CSR focus.
The Company may also engage employees, where possible to assist in undertaking CSR activities
The necessary agreements, memorandum of understanding will be executed where the CSR activities are carried out through its partners.
The Company will develop a standard proposal before contributing to the partners if the CSR committee feels appropriate.

    • Monitoring
      The Company will enhance its transparent monitoring and evaluation mechanism that will ensure every program has:

      • Clearly defined objectives (developed out of existing societal needs determined through baselines/studies/research),targets and time lines;
      • A robust progress monitoring system/schedule for timely fund utilization;
      • Impact assessments mechanism as per the evaluation plan developed by the Company;
      • The evaluation parameters, expected outcomes (in qualitative and quantitative terms) must be defined;
      • A reporting framework and system aligned with the requirements of the Act; and

The monitoring mechanism may also cover field visits, documentation of the field visits in a well-defined report and regular interaction with beneficiary communities.

The Company CSR Governance Structure

    • Board of Directors
      The Board of Directors will be responsible to:
      Constitute the CSR committee through a board resolution with a defined composition and tenure
      Approve the CSR Policy as formulated by the CSR Committee through a board resolution
      Ensure funds committed by the Company for CSR activities are utilized effectively and monitored regularly
      Disclose in its Annual Report, names of CSR Committee members, the content of the CSR Policy and ensure annual reporting of its CSR activities on the Company’s website
      Ensuring annual reporting of CSR activities to the Ministry of Corporate Affairs, Government of India, as per the prescribed format
    • CSR  Committee
      Composition of the CSR committee: The CSR Committee shall consist of three directors.
      Tenure of CSR committee: It will be determined as per the governance rules of the Company as defined by the Board.
      Responsibility of the CSR committee:

      • Identify CSR team for implementation of CSR Programs and Projects
      • Formulate the CSR Policy and identify activities to be undertaken as per Schedule VII of the Act
      • Recommend the CSR expenditure to be incurred for each of the activities
      • Report back to the Board of Directors for approval of the CSR Policy
      • Regularly monitor the implementation of the CSR Policy
      • Change/modify the existing CSR Policy including the CSR activities, allocated budget and monitoring mechanism as per requirement
    • CSR Team 
      Composition of the The CSR Team:  It will consist of CSR head, responsible senior managers, managers from adminstrative and human resource department.
      Responsibility of the CSR Team:

      • Work closely with the Group’s Own Foundation and partners to receive monitoring and progress reports
      • Responsible to report to the CSR Committee on program implementation updates
      • Plan annual budgets for CSR activities based on audits (programmatic and financial)
      • Assess the proposals for new CSR initiatives/ Programs and facilitate review by the Legal Team to ensure alignment with the Companies Act.
      • Identify and allocate resources for implementation of programs
      • Responsible to provide feedback for the evaluation of CSR Policy
      • Training and capacity building of the implementation teams
      • Any other activities that may be required may be required by the CSR Committee to effectively deliver the CSR Programs

Monitoring and Reporting Framework

In compliance with the Act and to ensure funds spent on CSR Programs create the desired impact, a comprehensive monitoring and reporting framework is in place. The monitoring and reporting mechanism are divided into three distinct areas

    • Program Monitoring
      • Program monitoring mechanism will ensure:
      • The CSR Policy is implemented as per the Act and the Rules

Projects/Programs as budgeted are duly carried out
CSR spend will be audited in an accountable and transparent manner.
The Group’s Own Foundation and partners shall provide quarterly reports to the CSR Committee and CSR Team on the progress of the identified programs
Quarterly reporting and review by the CSR committee and six monthly reviews by the Board of Directors. Review can be conducted by the Board of Directors through video conferencing in specific circumstances, if required.
The above meeting should cover the minutes of the meetings, status of CSR Projects/ Programs initiated, action taken based on discussion held in last meeting, schematic presentation on the CSR spend (budgeted and factual), future course of action.

    • Evaluation
      A robust monitoring mechanism and evaluation plan will be in place.
      The purpose of the evaluation will be clearly identified. There shall be clarity about the scope of the Programs and the need before evaluations are undertaken.
      Third parties may be engaged, if required, to ensure objective assessment across baseline and end line parameters.
    • Documentation and Reporting 
      As per compliance of the Act and in preparation of the Annual Report, the CSR Committee will ensure:

      • CSR Projects and Programs are properly documented
      • An MIS is maintained on spending across sectors, geographies and beneficiaries impacted
      • The MIS structure will be in alignment with the prescribed reporting format
      • Accountability is fixed at each level of the CSR process and implementation
      • Cross checking between CSR quarterly reports prepared by the CSR team and quarterly reports of the partners
      • A repository of case studies and good practices may be maintained