Purpose

UpperCrust Wealth Private Limited is committed to upholding the highest standards in terms of management practices, business conduct and play its role in making a direct contribution to the society as a part of its Corporate Social Responsibility (CSR) agenda. The Group’s mission is to ensure every individual and every enterprise has complete access to financial services. This mission is based on a strategy that envisages three-pillar of the financial system: high quality origination, orderly risk transmission and robust risk aggregation.

UpperCrust Wealth believes that “all human beings are created equal” and creates equal opportunities for all its stakeholders and ensures zero discrimination while engaging with any entity on the basis of differential ability, caste, religion, region, nationality, race or gender.

UpperCrust Wealth along with its group of entities (My Advisor Finserv Pvt. Ltd. and Smartlink Group) has launched MyAdvisor Foundation, which shall focus on building livelihood, skill and vocational development of communities traditionally marginalised by formal systems, enhancing people’s wellbeing through knowledge building and innovation. The foundation will also focus on other charitable and socially beneficial purposes related to education and other training and development initiatives.

Guiding Principles and Applicability

  • Serve – and be seen to serve – society, local and national goals where ever the group operates.
  • Create a significant and sustained impact on communities.
  • Provide opportunities for the employees, the customers and partners to contribute to these efforts through volunteering.
  • Play a significant role in promotion of financial inclusive growth through empowerment of socially and economically weaker sections of society.
  • Build partnerships and promote financial innovation through incubation of ideas and technology to address societal needs.

  • Contribute to research that aids in developing a thorough understanding of problems, designing programs, products and strategies that eventually will help in reduction of financial vulnerability of poor and weaker sections of the society

    In accordance with the above, UpperCrust Wealth has decided to adopt this CSR policy and mandates the Directors and Employees of the Group to:

  • Comply with relevant regulations governing the protection of human rights, occupational health and safety standards and labour, environmental, social and business practices of the jurisdictions in which we conduct business and are mandated with the CSR expenditure obligations as per Sec 135 of the Companies Act, 2013 read with the Companies (Corporate Social Responsibility Policy) Rules, 2014 as amended from time to time.
  • Train its staff adequately to ensure that they are sensitive to environmental and social impact of the operations of the company.
  • Adopt a responsible and ethical approach to governance including implementation of compliance policies and procedures and on-going monitoring of systems and controls, implementation of rigorous risk monitoring and adhering to the highest standards of conduct.
  • Take into account environment and social governance criteria during decision making processes. All Performance of all investments will be evaluated taking into account the non-financial aspects (governance, social and environmental) related to partner entities and consider if the investment is ethical.

Focus Areas

UpperCrust Wealth’s CSR activities shall be in line with the objectives which are as detailed below:

  • Training and skill development for potential employees of financial service providers.
  • Creating sustainable livelihoods in finance, especially for members of marginalized communities by creating employment opportunities.
  • Other charitable and socially beneficial purposes related to education and other training and development initiatives.

Governance

The President of the Foundation will be responsible for day to day implementation of the programs including those in partnership with government agencies along with training partners.

The Foundation will also have a Governing Council with the following members:

  1. One independent director
  2. One executive director
  3. One person as may be nominated by the CSR Committee

The President of the Foundation shall understand the resource requirements on the one hand and training requirement on the other, and formulate a program based on the broad objectives of the Foundation. The program/s will be presented by the President to the Governing Council of the Foundation who will evaluate the program on the following indicative parameters:

  • Viability of the program
  • Reach of the program to underserved and marginalized communities
  • Long-term impact of the program

The Governing Council will then approve the program and recommend the same for implementation to the CSR Committee of UpperCrust Wealth. The President of the Foundation shall provide periodic updates to the Governing Council on the progress of each of the programs.

The Governing Council will also be responsible for approving and recommending programs pertaining to other socially relevant initiatives proposed by the President of the Foundation to the CSR Committee of UpperCrust Wealth.

Once the project/ program is recommended by the Governing Council of the Foundation, the President of the Foundation shall present the project/ program to the CSR Committee of UpperCrust Wealth, who will approve the program based on the CSR policy of UpperCrust Wealth. The President of the Foundation will also provide quarterly updates to the CSR Committee of UpperCrust Wealth. The CSR Committee is responsible for overall supervision and monitoring of the programs.

In the event of any doubts regarding authority for implementation and monitoring of the Foundation, the decision of the CSR Committee of UpperCrust Wealth shall be final.

CSR Committee

The composition of the committee shall be as per the extant provisions stated under the Companies Act, 2013 read with Rules thereto. The committee shall be responsible for:

  • Formulation of CSR Policy which shall be in line with the objectives of UpperCrust Wealth
  • Regular monitoring and overall supervision of the programs of UpperCrust Wealth
  • Recommend to the Board CSR expenditure to be incurred
  • Recommend to the Board, modifications to CSR Policy as and when required

Geographies and target communities

The geographical focus of CSR activities will be where UpperCrust Wealth has a significant presence and excluded and under developed districts in the Indian states.

Monitoring & Review

Implementation of this policy will be monitored and reviewed periodically by the CSR committee. The CSR Committee will review the policy’s effectiveness and implementation on a regular basis and report relevant findings and recommendations to the Board.

Disclosure

UpperCrust wealth will disclose its Corporate Social Responsibility performance in a transparent manner to all its stake holders and the community at large on a regular basis through adequate information on our annual report and provision of transparent and objective information.