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Webinar Objectives

Introduction to The Companies Act 2013


Understanding the role & scope of CSR and Affirmative Action
Strategizing CSR for improving standard of living of the
marginalised
Highlighting efforts of Affirmative Action by India Inc
Scrutinising

company's

performance

&

building, consumer trust, increased outreach)

beyond

(brand

WEBINAR MENTOR
Mr. Soumitro Chakraborty
CEO, Fiinovation

About Fiinovation
A CSR based research consultancy working in areas of
education, livelihood, environment and health since last six
years
Assists businesses to support requirements of communities
by designing and implementation of sustainable projects
Ensuring quality in functioning of organizational value
chains

Fiinovation?
Asias first proposal research laboratory
Carries

out

primary

and

secondary

research

before

initiating an implementable project model


Has

sectoral

experts

carry

out

Implementation

and

management of innovative-sustainable project models


Uses modern analysis tools and techniques to monitor and
evaluate the performance and sustainability of the projects
implemented

Fiinovation in CSR Ecosystem

Exposure to CSR
GlobalPerspective
India
Perspective

Corporate Social Responsibility


Global Perspective
Coined in 1953with the publication of Bowen's 'Social Responsibility
of Businessmen', which posed the question What responsibilities to
society can business people be reasonably expected to assume.
In 1960s, ambit expanded, suggesting beyond legal obligations
companies had certain responsibilities to society
In 1990s companies started integrating social and environmental
concerns in their business operations and interactions with their
stakeholders

Definition:
A strategic business management concept to obtain a balance
of economic, environmental and social imperatives
Related Concepts:
Triple Bottom Line, Strategic Philanthropy, Shared Value,
Corporate Sustainability, Business Responsibility

Contd
OCED

UN

EU

Corporate
responsibility
involves the search
for an effective "fit"
between businesses
and the societies in
which they operate.

A management
concept whereby
companies integrate
social &
environmental
concerns in their
business operations
and interactions with
their stakeholders

The responsibility
of enterprises for
their impacts on
society

CSR is

How Corporations make 100% of their profits & not only how they spend it
Good business for a good society today and tomorrow
A matter of individual and institutional ethics
Not a repair center for capitalism
Not just about compliance, but going beyond it

Corporate Social Responsibility


Indian Perspective
Pre-Independence era restricted to charitable and religious
philanthropy by businessmen & rich farmers
Mahatma Gandhi and other socio-political leaders urged
rich to pool resources for nations upliftment, giving rise to
trusteeship movement.
Post Independence, PSUs & Govt. led initiatives played
prime role in social development sector
Post 1991, the local players were motivated by the global
standards of CSR due to entry of global players in the
Indian market

Synonyms of CSR
Corporate
Citizenship

The extent to
which businesses
are socially
responsible for
meeting legal,
ethical and
economic
responsibilities
placed on them
by shareholders.
Prevalence Europe

Corporate
Responsibility

Corporate Social
Responsibility

It is the dutyand
Rationalconduct
expectedofa
corporation;
accountabilityof
a
corporationtoa
codeofethicsan
d
toestablishedla
ws.

A companys
sense of
responsibility
towards the
community and
environment
(both ecological
and social) in
which it
operates.

Prevalence
North America

Prevalence
Asia

Challenges to which CSR is a


solution
Increase in inequality between the private sector and the
communities resulting in lower human development
Social unrest & humanitarian crisis
Low consumer capacity
Environmental issues, public health issues etc.

Businesses cannot be successful when the


society around them fails.

CSR THROUGH
THE COMPANIES ACT, 2013

Essence of Section 135 - The


Companies Act, 2013
Not charity, not philanthropy, not giving
If not rupee measurable, its not CSR
Activities that can be considered for CSR expenditure are listed
under Schedule VII, anything other then them will not be
considered
If you are doing CSR, say it out loud & in a transparent manner
by filing a return in the prescribed format
What you spend should add up to 2% of your PBT
Govt. building an enabling atmosphere, a culture of doing for
the society

History Behind The Companies Bill


India is the first country to quantify the mandate
Argentina, Brazil, Canada, Austria, Belgium, France,
Denmark, South Africa and China have mandatory reporting
Bill first introduced in 2008, but was withdrawn due to
dissolution of Lok Sabha
Again introduced in Parliament in 2009 & sent to
theStanding Committee, which presented its report in
August, 2010
The Companies Bill 2011 was again tabled in Parliament by
the Corporate Affairs Minister in 2011
The Act replacedThe Companies Act, 1956(in a partial
manner) after receiving the assent of thePresident of
Indiain 2013
Came into force on 12th September, 2013
On 27th February, 2014, the MCA stated that Section 135 of
the Act which deals with CSR will come into effect from 1st
April, 2014

The Companies Act, 2013 Section


135
Eligibility: A company with:
Annual Turnover of Rs 1,000 crore or more,
or net worth of Rs 500 crore or more,
or net profit of Rs 5 crore or more
Net Profit

(Section 198, Subsection


5):
Net profit to be calculated as
profit before tax as per the
books of accounts and shall
not include profits arising
from branches outside India

Calculation:
Company must spend 2% of its average net profit in the
preceding three years on CSR

Implementation Process - CSR


Board members form a CSR Committee
CSR Committee drafts CSR Policy
Identification of CSR activities and target beneficiaries
CSR CSO Partnership
Implementation of CSR initiatives
Reporting

Schedule VII of The Companies Act,


2013
MINISTRY OF CORPORATE AFFAIRS NOTIFICATION
New Delhi, the 27th February, 2014

G.S.R, 130(E).-In exercise of the powers conferred by sub-section (l)


of section 467 of the Companies Act, 20l3 (18 of 2013), the Central
Government hereby makes the following amendments to Schedule
Vll of the said Act, namely :(l) In Schedule VIl, for items (i) to (x) and the entries relating
thereto, the following items and entries shall be substituted, namely
:(i) eradicating hunger, poverty and malnutrition, promoting
preventive health care and sanitation and making available safe
drinking water;
(ii) promoting education, including special education and
employment enhancing vocation skills especially among children,
women, elderly, and the differently abled and livelihood
enhancement projects;
(iii) promoting gender equality, empowering women, setting up
homes and hostels for women and orphans; setting up old age

Contd
(iv) ensuring environmental sustainability, ecological balance,
protection of flora and fauna, animal welfare, agroforestry,
conservation of natural resources and maintaining quality of soil, air
and water;
(v) protection of national heritage, alt 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;
(vi) measures for the benefit of armed forces veterans, war widows
and their dependents;
(vii) training to promote rural sports, nationally recognised sports,
paralympic sports and Olympic sports;
(viii) contribution to the P me 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;
(ix) contributions or funds provided to technology incubators
located within academic institutions which are approved by the
Central Government;

Contd
MINISTRY OF CORPORATE AFFAIRS
Notification
New Delhi, the 6th August, 2014
G.S.R. 568(E).-In exercise of the powers conferred by sub-section (1)
of section 467 of the Companies Act, 2013 (18 of 2013), the Central
Government hereby makes the following further amendments in
Schedule VII of the said Act, namely:(1) In Schedule VII, after item (x), the following item and entry shall
be inserted, namely:"(xi) slum area development.
Explanation.- For the purpose of this item, the term 'slum area' shall
mean any area declared as such by the Central Government or any
State Government or any competent authority under any law for
the time being in force."
(2) This notification shall come into force on the date of its
publication in the Official Gazette.
[F.No.1/18/2013-CL-V]
AMARDEEP S. BHATIA. Jt. Secy.

Contd
MINISTRY OF CORPORATE AFFAIRS
Notification
New Delhi, the 24th October, 2014
G.S.R. 741(E).- In exercise of the powers conferred by sub-section (1) of
section 467 of the Companies Act, 2013 (18 of 2013), the Central
Government hereby makes the following further amendments to Schedule
VII of the said Act, namely:(i) In item (i). after the words "and sanitation". the words "including
contribution to the Swach Bharat Kosh set-up by the Central Government
for the promotion of sanitation" shall be inserted;
(ii) In item (iv). after the words "and water". the words "including
contribution to the Clean Ganga Fund set-up by the Central Government for
the promotion of sanitation" shall be inserted.
2. This notification shall come into force on the date of its publication in the
Official Gazette.
[F.No. 1/18/2013-CL-V]
AMARDEEP SINGH BHATIA. Jt. Secy.

ESTABLISHING LINKAGE BETWEEN


CSR & AA

Understanding Affirmative Action Globally


Known as:
Employment
Equity in
Canada

Requires
employers to
engage in
proactiveemploy
ment practices
to increase the
representation of
four designated
groups: women,
people with
disabilities,
Aboriginal
peoples, and
visible minorities

Affirmative
Action in USA
focus on issues
such as
education and
employment,
specifically
granting special
consideration to
racial minorities
and women who
have been
historically
excluded groups

Positive Action
in UK
promotion of
people based on
belonging to
nonmajorityiden
tity groups in the
workplace,
educational
institutions and
positions in
society

Understanding Affirmative Action Globally


An action favouring those who tend
discrimination; positive discrimination

to

suffer

from

AA reverses longstanding discriminatory tendencies in the


society
For people of a certain caste, gender, sexual
orientation, race, or ethnic background
AA provides supposedly fairer conditions and
past injustices

corrects

Different Approaches to AA
Affirmative Action
Recruiting employees or
providing opportunities in
the recruitment process for
SC/ST communities
Procuring
from
SC/ST
Vendors
Offering
solutions
to
address the needs and
challenges of the SC/ST
communities

Affirmative action
Through CSR
Implementing
CSR
Activities as per Schedule
VII of The Companies Act,
2013
Targeting
SC/ST
communities

Affirmative Action in India


Reservations specify that a proportion of a minority group must
be selected for education or job or other benefits
Regardless of them being under-qualified
Reverse discrimination
Justification for reverse discrimination is somewhat ambiguous
Based on retributive justice (past injustices must be paid for)
Constitution makers have proclaimed by incorporating various
provisions in the Constitution of India indicating that Scheduled
Caste and Scheduled Tribe are by and large backward in
comparison with other communities in the country

Case Study Swabhimaan


Should Have Benefitted From:

Background:
Belongs to SC Community
Occupation: Manual
Scavenger
Education:
Illiterate
House:
Not Concrete
Children: 2

Self-Employment Scheme of
Liberation and Rehabilitation for
Scavengers
Indira Awas Yojna
MGNREGA, Swaranjayanti Gram
Swarozgar Yojana
Atal Pension Yojana
Jan Dhan Yojna
Pradhan Mantri Jeevan Jyoti Bima
Yojana
Rashtriya Swasthya Bima Yojana
Indira Gandhi Matritva Sahyog
Yojana
Integrated Child Development
She couldnt
Servicesbenefit because?
And Swavalamban among others

Challenges of SC/STs
Lack of awareness of welfare schemes
Discrimination continues to occur in many different open,
covert and subtle ways today despite the Constitution
abolishing it under Article 17
Increased atrocities against SCs & STs compared to others
Lack of political will to convert provisions into fundamental
rights
Lack of opportunities for education and employment
Low Representation in Public Services and the Higher
Judiciary
Increase in backlog vacancies

due to lack of proper

Contd
Small land holding, landless labourers, low productivity in
agriculture, lack of alternative livelihood opportunities
High incidence of migration
Lack of vocational skills and adequate infrastructure
Financial constraints for entrepreneurship
Complicated nature of Financial Institutions
Low impact of Affirmative Action by private and public
sector undertakings

Population Classification
Indicato
r

Total
Rural
Urban
Total
Rural
Urban
Total
Rural
Urban

Absolute
2001

2011

Total Population
1,02,86,10,328 1,21,05,69,573
74,23,02,537
83,34,63,448
28,63,07,791
37,71,06,125
Scheduled Castes
16,66,35,700
20,13,78,086
13,30,10,878
15,38,50,562
3,36,24,822
4,75,27,524
Scheduled Tribes
8,43,26,240
10,42,81,034
7,73,38,597
9,38,19,162
69,87,643
1,04,61,872

Percentage
2001 2011

Growth
rate
(2001-11)

100.0 100.0
100.0 100.0
100.0 100.0

17.7
12.3
31.7

16.2
17.9
11.7

16.6
18.5
12.6

20.8
15.7
41.3

8.2
10.4
2.4

8.6
11.3
2.8

23.7
21.3
49.7

Concentration - SCs

Concentration - SCs

Poverty Ratio for Social Groups


In rural areas, Scheduled Tribes exhibit the highest level of
poverty (47.4%), followed by Scheduled Castes (SCs),
(42.3%), and Other Backward Castes (OBC), (31.9%),
against 33.8% for all classes.
In urban areas, SCs have HCR of 34.1% followed by STs
(30.4%) and OBC (24.3%) against 20.9% for all classes.
In rural Bihar and Chhattisgarh, nearly two-third of SCs and
STs are poor, whereas in states such as Manipur, Orissa and
Uttar Pradesh the poverty ratio for these groups is more
than half.
Source: Press Note on Poverty Estimates, 2009-10 - GOI,
Planning Commission, March 2012

Poverty Percentage among Social


Groups
70

60

65.9
62.3

62.4

51.7

60

50

53.5
50.1

50

45.3
41.8

39.8

40

35.5

30

27.1

25.7

22.6

16.1

15.4

15.5

10

10
SC

0 OBC

'93-94

ST

'04-05
Rural

0Others

All Population

'11-12

25.7

24.1

21.7

20

20

31.8

30.6

30

31.5

40

41.1

40.6

13.7

8.2

SC

0 OBC

'93-94

--- Data not available in the official estimates for 1993-94


Source: Planning Commission

ST

'04-05
Urban

0Others

All Population

'11-12

Total SC & ST Population Top 5 & Bottom 5


(Census, 2011)
Total SC Population
35

Total ST Population
100
90
80
70
60
50
40
30
20
10
0

30
25
20
15
10
5
0

Top 5
States/UTs

Bottom 5
States/UTs

Total SC & ST Population Top 5 & Bottom 5


(Census, 2011)
(Major States: States having Population 10 million and
Total SC Population
Total ST Population
above)
35
30
25
20
15
10
5
0

35
30
25
20
15
10
5
0

Top 5
States/UTs

Bottom 5
States/UTs

Affirmative Action - Indian


Perspective
Affirmative
Public/Private
Action
Sector
in India

Affirmative Action - GOI


Category as per GoI

Reservation
Percentage
as per GOI

Scheduled Castes (SC)

15.0%

Scheduled Tribes (ST)

7.5%

Other Backward Classes (OBC)

27%

Total constitutional percentage

49.5%

General (open to all incl.


SC/ST/OBC)

50.5%

ource: Ministry of Personnel & Public Grievances & Pension, GOI

It was this consciousness and awareness of the Constitution-makers about the


neglected position of certain section of Indian Society which inspired them to make
provisions of reservation in favour of Backward Classes, Scheduled Caste and Schedule
Tribe citizens

Govt. Schemes for SCs/STs


Self-Employment Scheme of Liberation and Rehabilitation
for Scavengers
Scholarship/stipend to aspiring SC/ST Pilot Trainees
Special Central Assistance for Scheduled Castes Component
Plan
Pre and Post Matric Scholarship Scheme
Machinery for implementation of Protection for Civil Rights
Act, 1955 and Protection for Civil Right Act, 1989
Girls Hostels for SCs, Boys Hostels for SCs
Assistance to Voluntary Organisations for welfare of
Scheduled Castes
National Scheduled Castes Finance and Development
Corporation
Credit
Based/Self-Employment
Loan
Schemes , Non-Credit Based/Skill & Entrepreneurial
Development Training Programmes
National Vector Borne Disease Control Programme

Contd
National Programme for Control of Blindness
Vocational Training in Tribal Areas
Investment/Price support to TRIFED/ Market Development of
Tribal Products/ Produce
Support to National/State Scheduled Tribes Finance &
Development Corporations
Swaranjayanti Gram Swarozgar Yojana
Indira Awas Yojana

Challenges
Lack of awareness
Lack of accessibility to schemes
Lack of monitoring & evaluation
Decentralization of policies, schemes
Addressing

concerns

of

financial

implementation of the provisions


Lack of social capital

institutions

for

Affirmative Action Public Sector


Percentage of Reservation in Vacancies
(A) Direct Recruitment
Schedul Sched
e Castes ule
Tribes
1

Direct recruitment on an All-India basis by means of Open


Competitive Test i.e by written examination

Direct recruitment on an All-India basis otherwise than at (i)


above i.e. by not conducting written competitive
examination

Direct recruitment to Group C and D posts normally


attracting candidates from a locality or a region

The principle of reservation for SCs and STs, should


generally be suitably applied to the extent possible, to work
charged posts also except those required for emergiences,
like flood relief work, accident restoration and relief etc.
The percentage of reservation in such appointments may
correspond to what is applicable to Group C and Group D
posts in that locality or region

15%

7.5%

16.67%

7.5%

Vary from State to State


and UT to UT

Contd
Percentage of Reservation in Vacancies
(B) Promotion
Schedul Sched
e Castes ule
Tribes
1

Posts filled by promotion through limited Departmental


Competitive Examinations within or to Group B, C & D in
which the element of Direct Recruitment, if any, does not
exceed 75%

15%

7.5%

Posts filled by promotion made by selection from Group B


(Class II) to the lowest rung of category in Group A (Class 1)
and in Group B, C & D posts in grades or services in which
the element of Direct Recruitment, if any, does not exceed
75%

15%

7.5%

Posts filled on the basis of seniority subject to fitness in


Group A, B, C & D posts in grades or services of Direct
Recruitment does not exceed 75%

15%

7.5%

Contd
A comprehensive Presidential Directive incorporating all
important instructions on reservation for SCs and STs was
issued
by
DPE
to
all
the
administrative
Ministries/Departments concerned on 25th April, 1991 for
formal issuance of the same to CPSEs.
Reservation for OBCs was made effective w.e.f. 8.9.1993.

Affirmative Action - Private Sector


A policy or action by Indian companies to help in the national
endeavour for ensuring equal opportunity to members of the
Scheduled Castes, Scheduled Tribes and other marginalized
communities
In 2006, PM Manmohan Singh appealed to India Inc to
incorporate Affirmative Action policies to diversify workforce
Industry bodies responded to PMs call & outlined basic
criteria for Affirmative Action
DPE guidelines on CSR and Human Resources for CPSEs
were released in 2010
NVGs were established by Ministry of Corporate Affairs in
2011 which was later adopted by SEBI

Contd
According to Partners in Change Survey 2011

Only 9.5% companies have Affirmative Action policy


67% doesnt have a formalized policy
23.8% did not have a policy

Tata Conglomerate incorporated Affirmative Action focusing on four areas of


development: employment, employability, entrepreneurship and education

Believed to be highest CSR spenders (Rs. 1000 Crores) for the year 2013-2014

CII initiatives for SC/ST includes:

Trained 32922 candidates from SC/ST community


Provided scholarships
Established skill development centres
Contributed to improvement of Government Primary Schools in 104 districts
Provided employment (24% eastern region, 16% western region, 22% northern
region, 16.2% southern region)
Offered training in entrepreneurship development programmes

Contd
The Infosys-STP programme, CII-Finishing School & LABS training
programme

Approximately 800 SC/ST candidates have been imparted training in


English, communications, basic IT, hospitality, customer relations & sales,
bed side patient assistance etc.

CII and Tata Communications, have partnered with Ahmedabads


Entrepreneurship Development Institute to train 270 SC/ST youth
in the fundamentals of entrepreneurship;

HUL has a written policy statement on Affirmative Action in the


workplace

Also focus on upskilling and continual training of employees apart from


partnering with educational institutions to support and aid students from
socially disadvantaged sections of society

ITC engagees in affirmative action interventions such as skill


building and vocational training, to enhance employability and
generate livelihoods for persons from disadvantaged sections of
society

Challenges of Private Sector to AA

Lack of formalized policies


Lack of participation
Risk of unionization
Lack of will to conduct census within the organization
No incentivisation for vendors
No entrepreneurship support
Limited progress on What is Said and What
Incentivised

is

Affirmative Action & CSR The


Backdrop
Challenges at present:
Prevalence of economic inequality due to lack
of inclusive development
Rising disparity between the upper strata and
the economically weaker sections of the society
Constant
friction
between
the
socioeconomically empowered and left out sections
of the society
Absolute top down approach
Solutions:
Affirm Action to address challenges of
marginalized communities
Rational, feasible, justifiable action/initiatives
Incorporating AA within the CSR policy itself
CSR Implementing affirm actions leading to
improved standard of living

Linking Affirmative Action with CSR


Generating awareness among the members of historically
marginalized communities in a geographical area.
Providing educational facilities for children from these
communities. Rewarding Scholarships to meritorious
children.
Providing assistance on health and sanitation issues to
historically marginalized communities.
Enhancing entrepreneurial and employability of eligible
youth from the SC/ST communities.
Employing trained workforce from SCs/STs communities at
various levels to carry out operations in the organization.
For example - Deciding on a sourcing a minimal specified
percentage of material from a SC/ST vendor without
compromising on quality of the product.

Affirmative Action & CSR Benefits


An enabling atmosphere for companies to engage in social
development activities
Responsibility now aligned with accountability
CSR
& AA can be a concept that can travel beyond
backrooms into boardrooms
CSR & AA can now be a part of companys core business
strategy
CSR seen as a tool for brand building, customer outreach,
employee engagement etc.
Feel good factor throughout the value chain from internal
mechanisms to the consumer who picks up the final product

WHY AFFIRMATIVE ACTION & CSR

Present

Future

Reduce inequality

Equitable distribution of income

Reaching out to the


suppressed

Sustained accessibility

Providing education, jobs,


social benefits etc.

Create entrepreneurship
opportunities & strengthen rural
economy

Eradication of Poverty

Improved Standard of Living

Empowerment of the
marginalized communities

Increasing participation in
mainstream society

Opportunities for Economic


Growth

Increasing local trade, higher


per capita income

Present
Infrastructure development
(Schools, Toilets, Warehouses,
Housing, Roads)
Tackling Humanitarian Crisis
Social safety nets for the poor

Future
Supply and Value Chain
Management
Restoring and maintaining
peace
Ensuring Social Security for all

Bridging the economic gap

Inclusive and holistic

Creating a balanced workforce


mix

development for all

Protecting interests of
minorities and lower castes

Strengthening and capacity


building of the workforce
Protecting Religious freedom
and human rights

THE ANTICIPATED IMPACT OF AA


THROUGH CSR

Short Term

Long Term

Increased investments for


social development

Increased opportunities for the


marginalized

Increased household incomes

Eradication of Poverty

Access to healthcare facilities

Improved healthcare facilities

Higher enrollment of
marginalized children in
schools

Universal education for the


marginalized communities

Improved access to water and


sanitation
Higher agriculture production

Reduction on healthcare
expenditure
Food security for all

Short Term

Long Term

Increased participation of
marginalized communities

Empowerment of marginalized
communities

Increased out reach of


companies, brand awareness

Increased availability of
product & services, consumer
trust

Increased awareness about


rights women empowerment
and laws
Reduction in migration
Increase in number of skilled
professionals
Platform for innovation

Protection of Human Rights


and Religious Freedom apart
from safety of women
Increase in number of
economic clusters in India
Higher productivity leading to
higher exports
Challenges addressed through
smarter solutions

The Way Forward


Need to incorporate Affirmative Action in organizational policy
CSR & Affirmative Action to be viewed as an opportunity to
invest, establish trust & interact with the target community
Need to align CSR activities with broader national goals, with
major focus on inclusive development
Explore partnerships with CSOs for implementation of initiatives
Important to create solutions & processes that improve Indias
HDI ranking
Stringent implementation of CSR initiatives in areas with higher
SC/ST population & marginalized communities.
Provide smart solutions (renewable energy, sanitation and
drinking water facilities, education, housing, reducing emissions
etc.) to Indian villages to reduce the burden on Indian cities

Contd
Promote entrepreneurship among marginalized communities
to boost rural economy and improve the supply chain
Communicate CSR to not only showcase a corporations CSR
achievements but create goodwill among stakeholders
Promote Affirmative Action not only in community initiatives
but workplace, marketplace & supply chain initiatives
Creating awareness of the schemes available for the welfare
of the SCs and STs and linking the CSR initiatives with them
for sustained benefits
Mobilizing and empowering SC and ST communities
Addressing the mindsets of people and encouraging
participation of all in education, economic activities and
other societal aspects
Providing collateral less financial services for SCs and STs
Focus on developing sustainable processes rather than
investing in assets

Contributors to the PPT


Soumitro
Chakraborty
CEO, Fiinovation

Jaya Sinha
Dy. Director Media &
Communication, Fiinovation

Aditi Singh
Programme Manager, Fiinovation

Rahul Choudhury
Dy. Manager,
Fiinovation

Rohit Srivastava
Graphics Designer, Fiinovation

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