Corporate Social Responsibility Policy

Version adopted by Board on 6th March 2023

About CleverTap

CleverTap is the all-in-one customer engagement platform that helps brands personalize and optimize all consumer touch points to improve user engagement, retention, and lifetime value.

CSR Philosophy 

 CleverTap Private Limited (CleverTap) believes that the role of the company should not be limited to aggressively achieving its business objectives but should mandatorily include pro-active service to the society in which it operates. The company driven with the objective of making an impact-oriented contribution for the betterment of the environment and for the up-liftment of the weaker sections of the society seeks to take positive steps towards it. 

The Company understands that there is a need to strike a balance between the overall objectives of achieving corporate excellence vis-à-vis the company’s responsibilities towards the community.

CleverTap Private Limited (CleverTap) also believes in fostering a culture of caring, trust, and continuous learning to meet the expectations of key stakeholders and society at large. The company highly values its employees, customers, partners, investors, and the communities within which it operates.

In adherence to our commitment to responsible corporate citizenship, CleverTap is investing in affirmative action initiatives geared towards education and skills development programmes that enable and support under-resourced communities. We strive to empower them with the necessary capabilities to enhance their participation in the economy and contribute to their own growth and in turn the nation’s. 

The CSR Policy of the Company has been formulated and brought into effect in order to enable the company to fulfill its responsibilities of contributing to the larger good of the people and the planet.

CSR Framework

The CSR Policy framework details the mechanisms for undertaking various programmes in accordance with section 135 of the Companies Act, 2013.

The CSR Policy framework of the Company may include multiple programmes and initiatives such as education, healthcare, skill development, rural development, sanitation, environment, and sustainability, among others. With an orientation to understanding the specific needs of the communities, these programs will be undertaken to ensure that they are relevant, impactful, and sustainable.

Our CSR policy framework is developed to assist the Company in undertaking well-planned initiatives that are participatory, outcome-oriented and measurable. 


This policy, which encompasses the company’s philosophy for delivering its responsibility as a corporate citizen and lays down the guidelines and mechanism for undertaking socially useful programmes for welfare & sustainable development of the community at large. It has been prepared keeping in mind the company’s business ethics and to comply with the requirements of Companies Act, 2013 read with Schedule VII (hereinafter called as “the Act”) and the Companies (Corporate Social Responsibility Policy) Amendment Rules, 2021, notified by the Ministry of Corporate Affairs vide Notification dated 22nd January 2021.

This policy shall apply to all CSR initiatives and activities taken up for the benefit of different segments of the society.

The objectives of this policy are to:CleverTap Private Limited’s CSR Policy aims to enhance social development,  economic empowerment, and environmental sustainability,  through an integrated, holistic, and need-based approach by way of:

The projects will be selected and developed with the objective of providing a long-term sustainable impact on communities in rural, semi-urban, or urban areas, across India. Only those projects that are over and above CleverTap Private Limited’s normal course of business will be defined as CSR.The Corporate Social Responsibility Committee shall consist of 2 Directors.

As the company is not required to appoint an independent director under sub-section (4) of section 149, CSRC of the company shall consist of two or more directors. The below is the Composition of CSRC.

Sr. No.NameDesignation
1Anand JainDirector and Chairman of the Committee 
2Suresh KondamudiDirector and Member of the Committee 

Internal Committee (CSR) 8.1. Composition of Internal Committee (CSR) 

In addition to the CSR Committee of the Board, the Company shall have an Internal Committee (CSR) consisting of the below mentioned Senior Management personnel/Key Managerial Personnel of the Company who shall be responsible for identification and then subsequently proposing to the CSR Committee on the list of entities/beneficiaries wherein various plans/budget for the CSR activities of the Company may be undertaken.

The Internal Committee (CSR) shall assist the CSR Committee in implementation and monitoring of the planned CSR activities effectively and efficiently. The Internal Committee (CSR) shall consist of below designated executives of the Company: 

Mr. Sourabh Arora (VP – Finance)
Ms. Heena Bawa (VP – HR)
Ms.Sony Shetty (Director – Corporate Marketing)

Role of Internal Committee (CSR) 

The above Committee(s) shall hold meeting as and when required, to discuss various issues on implementation of the CSR Policy of the Company.

The quorum for a meeting of the above Committee(s) on CSR shall be one-third of its total strength (any fraction contained in that one-third being rounded off as one), or two members, whichever is higher.

  1. To formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the company as specified in Schedule VII of Section 135 of the Companies Act 2013.
  2. To recommend the amount of expenditure to be incurred on the specified activities in a financial year.
  3. To monitor the Corporate Social Responsibility Policy of the company from time to time.
  4. To recommend the Board on the guiding principles for selection, implementation and monitoring of CSR activities.
  5. To formulate and recommend to the Board, an Annual CSR Action Plan in pursuance of its CSR policy.
  6. To recommend the Board to alter the Annual CSR Action Plan at any time during the financial year based on the reasonable justification to that effect.
  7. All the decisions of the CSRC shall be taken by way of a resolution passed by a majority of members of the CSRC present and voting.
  8. Any other matter/thing as may be considered expedient by the members in furtherance of and to comply with the CSR Policy of the Company.
The amount of expenditure that the company must undertake on its CSR activities shall be such as shall be recommended by the CSRC. However, the amount so recommended shall not be lesser than two percent of the average net profits of the company made during the three immediately preceding financial years.

  1. The Board of Directors shall, after considering the recommendations made by the CSR committee, approve the CSR policy and the Annual CSR Action Plan of the company.
  2. The Board of Directors shall endeavor that the Company spends 2% of the average pre-tax net profits of the Company made during the 3 immediately preceding financial years in pursuance of its CSR Policy.
  3. The Board of Directors of the Company shall disclose the composition of the CSR Committee, and CSR Policy and Projects approved by the Board on their website, if any, for public access. 
  4. The Board may extend a non-ongoing project beyond one year based on reasonable justification.
  5. The Board shall ensure that the CSR activities are undertaken by the Company itself or through a registered and eligible Implementation Agency.
  6. The Board of the Company shall satisfy itself that the funds so disbursed have been utilized for the purposes and in the manner as approved by it.
  7. In case of ongoing project, the Board of the Company shall monitor the implementation of the project with reference to the approved timelines and year-wise allocation and shall be competent to make modifications, if any, for smooth implementation of the project within the overall permissible time period.
  8. The Board may alter the CSR Annual Action Plan at any time during the financial year, as per the recommendation of its CSR Committee, based on reasonable justification to that effect.
  9. The Board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the Company for the financial year.
  10. Where the Company spends an amount in excess of requirement, such excess amount may be set off by the Board against the requirement to spend up to immediate succeeding three financial years subject to the conditions that –