Corporate Social Responsibility Policy

The Hongkong and Shanghai Banking Corporation Ltd., India is committed to Corporate Social Responsibility (CSR) and demonstrates this by contributing to the economic and social development of communities; and safeguarding the environment. While these two components are universal and will be at the centre of most sustainability initiatives, there are various components which make up this huge canvas. The bank’s community investments (CI) are focused on three core themes:

Promoting education

• Financial literacy
• Livelihood enhancement
• Employment enhancing vocation skills

Environmental Sustainability

• Agroforestry, conservation of natural resources and maintaining quality of soil, air and water
• Ensuring ecological balance and protection of flora and fauna
• Conserving nature to further sustainable livelihoods

Disaster management

• Relief, rehabilitation and reconstruction

Other priorities in alignment with Schedule VII may be supported from time to time as deemed appropriate.

Selection of beneficiary projects and organisations

The Operating Committee (OpCo) of the bank is responsible for the development and funding of programmes/projects/activities – that support communities in which they operate; and are in adherence to the provisions of the Companies Act (2013) and the CSR rules there under.

The bank will undertake such CSR programmes/projects/activities as approved by the OpCo and as recommended by the CSR Committee of the OpCo. The OpCo should approve the following:

1. Annual budget for CSR activities
2. List of CSR activities, modalities of execution and implementation schedules
3. Monitoring process of such CSR activities

The OpCo will ensure that any unspent/unutilised CSR budget of a particular year will not form part of the business profit of the bank.

The OpCo will ensure programme/project/activity selection is made after a sensible assessment of the prospective beneficiaries’ standing, that potential risks have been identified and the relationship is aligned with the bank’s CSR focus.

Community investments should bring a lasting benefit to local communities, motivate staff through opportunities for direct voluntary involvement and focus primarily on promoting education, environmental sustainability and disaster management.

The CSR Committee will adhere to the due diligence guidelines (as approved by the OpCo) and undertake due diligence for all proposed relationship when electing to partner with an NGO. Due consideration will also be given to whether it is appropriate to formalise the prospective arrangement in documentation (i.e. Terms of Donation).

All CSR projects should:

• Reflect the key themes of promoting education, environmental sustainability and disaster management
• Have clear objectives and measurable impact
• Bring a lasting benefit to the community
• Be capable of evidencing HSBC’s commitment to the community
• Allow for staff engagement through volunteering where possible or appropriate

Community investments should normally avoid the following:

• Sponsorship of individuals
• Organisations that serve a limited or restricted membership (e.g. clubs, unions, etc.)
• Sporting events or sports teams
• Organisations that primarily or largely exist to develop the furtherance of faith-based issues
• Payments of salaries. Where large, long-term community investments are made it is accepted that part of the support may cover the costs of staff, but this should not normally be the primary reason, nor form a major part of the community investment
• Construction of buildings
• Purchase of land or property
• Captive conservation projects by Zoological Parks.
• Endowment of university chairs or development programmes

Governance of community investments and disbursement of funds

The bank will establish appropriate, transparent mechanisms for the management of community investments. The following process will be followed for making a community investment:

• Check request for funding against the bank’s focus areas
• Conduct due diligence (as per format approved by the OpCo)
• Request for Proposal (as per format approved by the OpCo)
• Evaluate proposal
• Maker–checker process
• Submit recommendations to the OpCo for approval
• On approval disburse the amount to the partner organisation
• Undertake third-part monitoring and evaluation for all projects
• Undertake third party impact assessment as mandated by the provisions of Companies Act 2013 (Section 135)

To ensure that decisions over the disbursement of community investment funding are subject to appropriate management control, to facilitate consistency with the objectives of the business as a whole, compliance with appropriate tax and other legal and regulatory obligations, including the UK Bribery Act 2010, and ensure relevance to genuine community needs - all disbursements should be through members of the CSR Committee or such other person authorized by the OpCo who have read and understood the policy.

Avoiding conflict of interest

Potential conflict of interest that may arise when a member of the OpCo or the CSR Committee or CSR Function has a direct interest in a not-for-profit organisation in question, must be avoided. Such conflict of interest should be avoided by a declaration of interest by the concerned individual to the OpCo.

Where HSBC executives join the Board of a not-for-profit to improve the governance and oversight over its activities, they should absent themselves from any decision to fund the organisation.

Requests made by customers to provide fund support to not-for-profits should be refused. Similarly, community investments should not be made in order to maintain or enhance any customer relationship.

Monitoring and reporting

The CSR Committee is responsible for gathering information on the social and environmental impact of programmes and projects undertaken. ‘Output’ and ‘impact’ measures will be monitored for all major programmes and projects. The CSR Committee will ensure that the non-profit partners monitor and report on the outputs and impacts of their projects. Projects will be monitored through: quarterly progress reports, annual reports by the bank appointed third part monitoring and evaluation agency along with fund utilisation reports (as per format approved by the OpCo) and field visits of programmes/projects.

The OpCo will ensure that all activities are reported at the end of each financial year as required under provision of the Act.

HSBC employee engagement

Staff can avail a minimum of two-day paid employee volunteer leave per year for volunteering initiatives organized by the bank.

General

In case of any doubt with regard to any provision of the CSR Policy and also in respect of matters not covered herein, a reference should be made to the OpCo. In all such matters, the interpretation and decision of the OpCo will be final.

Any or all provisions of the CSR Policy will be subject to revision/amendment in accordance with the guidelines on the subject as may be issued from Government, from time to time.

The OpCo reserves the right to modify, cancel, add or amend the CSR Policy.

Composition of the INM CSR Committee (PDF, 70KB)

CSR Projects approved by the Board in Financial Year 2025-26 (PDF, 79KB)