Sarthak Metals Limited spent Rs. 43.39 lakh on Corporate Social Responsibility (CSR) initiatives during FY 2025–26, exceeding its statutory CSR obligation of Rs. 42.95 lakh. The company supported seven projects across healthcare, poverty alleviation, education, support for vulnerable communities and rural development, with approximately 95.4% of its itemised CSR expenditure directed towards Chhattisgarh. Implemented entirely through registered CSR organisations, the projects were undertaken in Raipur, Durg and Jaipur. While the expenditure reflects full statutory compliance and a strong local focus, the disclosures also highlight the need for more detailed reporting on beneficiaries, project outcomes and measurable social impact.
A detailed, evidence-based review of statutory compliance, governance, expenditure, project portfolio, geographic reach, impact readiness and future priorities.
| KEY METRIC | FY 2025–26 |
| Average net profit under Section 135(5) | ₹2,147.67 lakh |
| CSR obligation (2%) | ₹42.95 lakh |
| CSR expenditure disclosed | ₹43.39 lakh |
| Reported excess spend | ₹0.44 lakh |
| Projects / implementing agencies | 7 / 7 |
| Ongoing projects | Nil |
| Unspent amount | Nil |
| Impact assessment applicability | Not applicable |
| Overall assessment The company met its disclosed CSR obligation and reported no unspent amount. Its portfolio is locally concentrated and fully implemented through registered agencies. The next maturity step is to move from input-level disclosure to measurable output and outcome reporting. |
Prepared from the company’s Annual Report 2025–26. Amounts are reproduced as disclosed and rounded where stated. This is an analytical report, not a statutory audit or legal opinion.
Contents
1. Executive summary
2. Scope, approach and limitations
3. Company and CSR context
4. Statutory CSR compliance
5. CSR governance and oversight
6. Financial performance and spending analysis
7. Project portfolio review
8. Thematic and geographic analysis
9. Implementation model and partner due diligence
10. Impact measurement readiness
11. ESG and sustainability linkages
12. Disclosure quality and reconciliation observations
13. Risks, gaps and improvement opportunities
14. Recommended CSR strategy and action plan
15. Monitoring framework and KPI scorecard
16. Conclusion
Appendices: project register, compliance checklist and source index
1. Executive Summary
Sarthak Metals Limited (SML) disclosed a CSR obligation of Rs.42.95 lakh for FY 2025–26, calculated at two per cent of an average net profit of Rs.2,147.67 lakh under Section 135(5) of the Companies Act, 2013. Against this, the company reported CSR expenditure of Rs.43.39 lakh across seven projects, exceeding the disclosed obligation by Rs.0.44 lakh. No amount was transferred to an Unspent CSR Account or a Schedule VII fund, and no ongoing project was reported.
The portfolio was delivered entirely through external implementing agencies holding CSR registration numbers. Five projects, representing Rs.41.394 lakh or approximately 95.4% of the itemised spend, were identified as local projects in Chhattisgarh. Two projects totalling Rs.2.00 lakh were marked non-local, including one in Jaipur and one in Durg. The largest grant—Rs.30.50 lakh to Bhagwan Mahavir Jain Relief Trust—represented about 70.3% of the itemised portfolio, creating material concentration in a single partner and intervention.
The CSR Committee comprised three non-executive independent directors. Four meetings were held; the Chair and one member attended all four, while the third member attended three. This reflects active formal oversight. However, the public disclosure remains predominantly expenditure-based: it does not provide beneficiary counts, intervention outputs, outcome indicators, baselines, target achievement, SDG mapping, partner selection criteria or monitoring findings.
| DIMENSION | ASSESSMENT | KEY BASIS |
| Statutory spending | Compliant | ₹43.39 lakh spent against ₹42.95 lakh obligation; no unspent balance. |
| Governance | Strong formal structure | Independent-director committee; four meetings; 11 of 12 possible attendances. |
| Portfolio localisation | High | About 95.4% of itemised spending marked local. |
| Partner model | Registered but outsourced | All seven projects implemented through registered agencies; no direct implementation. |
| Impact evidence | Developing | No project-level outputs, beneficiary metrics or outcomes disclosed. |
| Concentration risk | High | Largest partner received about 70.3% of itemised spend. |
| Disclosure consistency | Needs reconciliation | Statutory CSR obligation is ₹42.95 lakh, while financial notes show gross amount required of ₹43.12 lakh; excess set-off fields require clarification. |
Source: Annual Report 2025–26, Board’s Report pp. 55–56; Annexure D pp. 79–81; financial statements note on CSR expense p. 116.
Priority findings
- Build a three-year CSR strategy anchored in local needs around Bhilai, Durg and Raipur, with defined beneficiary groups and annual outcomes.
- Require every implementing partner to submit a standard results framework, utilisation evidence, beneficiary data and safeguarding declarations.
- Reduce single-partner concentration or document why a flagship intervention warrants it, with enhanced monitoring and milestones.
- Reconcile the ₹42.95 lakh statutory obligation with the ₹43.12 lakh “gross amount required” disclosed in the financial notes.
- Formally decide and disclose treatment of the ₹0.44 lakh excess spend, including whether it is available for set-off under applicable rules.
- Publish a concise annual impact dashboard even though statutory impact assessment is not applicable.
2. Scope, Approach and Limitations
This desk review evaluates SML’s CSR performance for the year ended 31 March 2026 using the information contained in the Annual Report 2025–26. It covers the statutory annual CSR report, the Board’s Report, corporate governance disclosures, relevant sustainability narrative and the CSR expense note in the financial statements.
Analytical method
- Recalculation of statutory obligation, total itemised project spend, variance and portfolio shares.
- Classification of projects by Schedule VII item, location, local/non-local status and implementation route.
- Review of committee composition, attendance and disclosed responsibilities.
- Assessment of disclosure completeness against the Companies Act, 2013 and the Companies (CSR Policy) Rules, 2014 as represented in the company’s reporting format.
- Qualitative maturity assessment covering strategy, partner governance, monitoring, outcomes and ESG alignment.
Limitations
The report does not independently verify expenditure vouchers, utilisation certificates, implementing-agency records, beneficiary data, CSR-1 status, field delivery or legal compliance outside the annual report. Project titles in the statutory table largely reproduce the names of implementing organisations rather than descriptive intervention names; consequently, programme content and beneficiaries cannot be inferred with confidence. Website links disclosed by the company were not treated as evidence for undisclosed outcomes in this review.
| Interpretation note “Compliant” in this report means consistent with the disclosures reviewed. It does not constitute an audit assurance conclusion or legal certification. |
3. Company and CSR Context
SML is a Bhilai-based manufacturer of metallurgical cored wires, aluminium flipping coils, wire feeder machines and flux-cored welding wires. The annual report states FY26 revenue from operations of Rs. 192.25 crore and profit after tax of Rs. 4.61 crore, with 149 permanent employees as at 31 March 2026. Its operations sit within the steel and metallurgy value chain, making local community resilience, workforce well-being, resource efficiency and environmental stewardship relevant to its responsible-business agenda.
| CORPORATE INDICATOR | DISCLOSED POSITION |
| Revenue from operations | ₹192.25 crore in FY26 (₹178.42 crore in FY25) |
| Profit after tax | ₹4.61 crore in FY26 |
| Permanent employees | 149 as at 31 March 2026 |
| Operational base | Bhilai, Chhattisgarh |
| Renewable energy initiative | 400 kW captive solar plant; report states electricity cost reduction of about 50% |
| Circularity indicator | About 75% of aluminium used in aluminium flipping coils reportedly sourced from recycled scrap |
Source: Annual Report pp. 2–5, 18–25, 50–56. Financial and sustainability claims are company-reported.
CSR philosophy and approved focus
The CSR policy seeks to link long-term business success with inclusive and sustainable development. Its stated philosophy is to improve lives in communities where the company operates, create social and economic value, encourage employee participation and manage operations using sustainable-development principles. The Annual Action Plan reportedly approved rural development, poverty and hunger eradication, education, healthcare and environmental sustainability as focus areas.
4. Statutory CSR Compliance
| REQUIREMENT / DISCLOSURE | FY26 POSITION | REVIEW |
| Section 135 applicability and policy | Policy constituted and disclosed | Reported |
| Average net profit under Section 135(5) | ₹2,147.67 lakh | Reported |
| Two per cent obligation | ₹42.95 lakh | Mathematically consistent after rounding |
| Surplus from prior CSR projects | Nil | Reported |
| Amount available for set-off | Nil at obligation computation stage | Reported |
| Total obligation | ₹42.95 lakh | Reported |
| Total expenditure | ₹43.39 lakh | Above obligation |
| Unspent current-year amount | Nil | No transfer required based on disclosed spend |
| Ongoing projects | Nil | All projects treated as other than ongoing |
| Administrative overheads | Nil | Within regulatory ceiling |
| Impact-assessment expenditure | Nil | Not applicable |
| Capital assets created/acquired | Nil / Not applicable | Reported |
| Failure to spend reason | Not applicable | Full spend reported |
Source: Annexure D, Annual Report pp. 79–81.
Compliance conclusion
Based on the statutory CSR annexure, SML met the minimum spending requirement. Itemised contributions total Rs. 43.394 lakh, which rounds to Rs. 43.39 lakh as disclosed. The arithmetic difference from the Rs. 42.95 lakh obligation is Rs. 0.444 lakh, reported as Rs. 0.44 lakh.
5. CSR Governance and Oversight
| MEMBER | ROLE | MEETINGS HELD | ATTENDED | ATTENDANCE |
| Dwadasi Venkata Giri | Chair; Non-Executive Independent Director | 4 | 4 | 100% |
| Rama Kohli | Member; Non-Executive Independent Director | 4 | 4 | 100% |
| Sunil Dutt Bhatt | Member; Non-Executive Independent Director | 4 | 3 | 75% |
Aggregate attendance was 11 out of 12 possible attendances, or 91.7%. The committee’s disclosed responsibilities include recommending the CSR Policy and Schedule VII activities, recommending expenditure and monitoring policy implementation. The Company Secretary acts as committee secretary.
Governance strengths
- Committee composed entirely of independent directors.
- Four meetings during the year, indicating regular review cadence.
- Policy, committee composition and approved-project links disclosed.
- Board-level signatures by the Managing Director and CSR Committee Chair on the statutory CSR report.
Governance enhancement opportunities
- Disclose meeting-level agenda themes and major decisions without revealing confidential information.
- Adopt a documented project approval scorecard covering need, Schedule VII fit, partner capacity, cost reasonableness, risk and measurable outcomes.
- Create a quarterly dashboard for financial progress, outputs, risks, grievances and beneficiary feedback.
- Define conflict-of-interest declarations and partner-related-party checks within CSR due diligence.
Source: Corporate Governance Report pp. 65–66; Annexure D p. 79.
6. Financial Performance and Spending Analysis
| METRIC | ₹ LAKH | ANALYSIS |
| Average net profit | 2,147.67 | Base under Section 135(5) |
| CSR obligation | 42.95 | 2.00% of average net profit, rounded |
| Itemised spend | 43.394 | Sum of seven disclosed projects |
| Reported spend | 43.39 | Rounded statutory total |
| Reported excess | 0.44 | Approximately 1.02% above obligation |
| Administrative overhead | 0.00 | 0% of total spend |
| Impact assessment | 0.00 | Not applicable |
| Unspent | 0.00 | Nil |
The spend is fully programmatic according to the statutory classification, with no administrative overhead or impact-assessment charge. This maximises the amount attributed to projects, but “zero overhead” should not be interpreted as zero management cost: internal employee time and governance resources may be absorbed elsewhere and are not quantified in the CSR table.
Year-on-year reference
The financial-note extract reports FY25 CSR addition of Rs. 62.94 lakh and utilisation of Rs. 63.30 lakh, compared with FY26 addition of Rs. 42.95 lakh and utilisation of Rs. 43.39 lakh. On that basis, the annual CSR obligation declined by approximately 31.8%, while utilisation declined by approximately 31.5%. This reflects the profit-linked nature of the statutory formula and should inform multi-year project planning.
| YEAR | OBLIGATION / ADDITION (₹ LAKH) | UTILISATION (₹ LAKH) | DIFFERENCE |
| FY 2024–25 | 62.94 | 63.30 | +0.36 |
| FY 2025–26 | 42.95 | 43.39 | +0.44 |
Source: Financial statements, CSR expense note p. 116; Annexure D pp. 79–81.
7. Project Portfolio Review
| # | PROJECT / AGENCY | SCH. VII | LOCATION | LOCAL | SPEND (₹ L) | SHARE |
| 1 | Hare Krishna Movement | (i) | Raipur, Chhattisgarh | Yes | 0.50 | 1.15% |
| 2 | Round Table India | (ii) | Durg, Chhattisgarh | Yes | 5.00 | 11.52% |
| 3 | SOS Children’s Villages | (iii) | Raipur, Chhattisgarh | Yes | 0.594 | 1.37% |
| 4 | Friends of Tribals Society | (x) | Raipur, Chhattisgarh | Yes | 4.80 | 11.06% |
| 5 | Bhagwan Mahavir Jain Relief Trust | (i) | Raipur, Chhattisgarh | Yes | 30.50 | 70.29% |
| 6 | Nosha Foundation | (i) | Jaipur, Rajasthan | No | 1.00 | 2.30% |
| 7 | Lions Charitable Trust, Bhilai | (ii) | Durg, Chhattisgarh | No | 1.00 | 2.30% |
Source: Annexure D p. 80. Shares calculated against itemised spend of ₹43.394 lakh; totals may vary due to rounding.
Portfolio observations
- The largest grant accounts for about 70.3% of the portfolio; the top three grants account for roughly 92.9%.
- The disclosure uses agency names as project names, limiting visibility into the actual activities financed.
- Every project is classified as “other than ongoing,” suggesting grants or short-duration interventions rather than multi-year programmes.
- All spending is routed through implementing agencies; the company reports no direct implementation.
- No project-level allocation-versus-utilisation, beneficiary count, deliverable or outcome is disclosed for these non-ongoing projects.
8. Thematic and Geographic Analysis
| SCHEDULE VII CLASSIFICATION | AMOUNT (₹ L) | PORTFOLIO SHARE | PROJECTS |
| Item (i): hunger/poverty/health/sanitation-related umbrella | 32.00 | 73.74% | 3 |
| Item (ii): education, skills and livelihoods umbrella | 6.00 | 13.83% | 2 |
| Item (iii): gender equality and vulnerable groups umbrella | 0.594 | 1.37% | 1 |
| Item (x): rural development | 4.80 | 11.06% | 1 |
Schedule VII item labels are broad statutory categories. Without project descriptions, the exact sub-theme—such as nutrition versus healthcare under item (i)—cannot be established from the annexure alone.
| GEOGRAPHY / STATUS | AMOUNT (₹ L) | SHARE |
| Chhattisgarh projects marked local | 41.394 | 95.39% |
| Projects marked non-local | 2.00 | 4.61% |
| Raipur district | 36.394 | 83.87% |
| Durg district | 6.00 | 13.83% |
| Jaipur district | 1.00 | 2.30% |
Local-area analysis
The portfolio demonstrates strong Chhattisgarh orientation. The annual report marks the Lions Charitable Trust project in Durg as non-local even though another Durg project is marked local; this may reflect the company’s own local-area definition or a disclosure inconsistency and should be clarified in future reporting. Section 135 encourages preference for local areas but does not make local-only spending mandatory.
9. Implementation Model and Partner Due Diligence
Each project was implemented through a named agency with a disclosed CSR registration number. This is a positive control indicator, but registration alone does not establish delivery quality or financial integrity. A robust partner-management system should cover selection, contracting, monitoring, safeguarding and closure.
| CONTROL STAGE | MINIMUM EVIDENCE RECOMMENDED |
| Eligibility | Constitution documents, PAN, 12A/80G where relevant, CSR-1 verification, governing-body details |
| Integrity and conflicts | Sanctions/adverse-media screening, related-party declaration, conflict-of-interest review |
| Capability | Relevant track record, staffing, field systems, references, audited accounts and prior utilisation record |
| Project design | Need assessment, logical framework, budget basis, milestones, inclusion and environmental safeguards |
| Agreement | Purpose restriction, reporting timetable, audit rights, data privacy, anti-fraud, safeguarding and refund clauses |
| Monitoring | Quarterly financial and physical reports, site verification, geo-tagged evidence where suitable, beneficiary feedback |
| Closure | Utilisation certificate, statement of expenditure, asset register if any, outcome report, lessons and residual-risk review |
Partner concentration response
Because one partner received about 70.3% of total itemised spending, SML should apply enhanced oversight to that grant: milestone-based disbursement, documented site review, beneficiary/output reconciliation and independent financial verification proportionate to risk. Concentration can be strategically justified, but the rationale and controls should be explicit.
10. Impact Measurement Readiness
Statutory impact assessment under Rule 8(3) was reported as not applicable because the company’s CSR obligation did not reach the prescribed ₹10 crore threshold in the immediately preceding three financial years. Non-applicability, however, does not prevent proportionate internal outcome measurement.
| LEVEL | QUESTION | ILLUSTRATIVE EVIDENCE |
| Inputs | What was invested? | Funds, staff time, partner contribution |
| Activities | What was delivered? | Meals, health camps, scholarships, training sessions, village works |
| Outputs | Who received what? | Beneficiaries, service units, completion and coverage |
| Outcomes | What changed? | Health access, attendance, learning, income, behaviour or service reliability |
| Impact | What lasting change is attributable? | Longer-term change assessed with suitable methodology |
| Learning | What should change next cycle? | Cost-effectiveness, beneficiary feedback, unintended effects, scalability |
Minimum FY27 measurement standard
- A one-page theory of change for each project above ₹5 lakh.
- Baseline or starting-status evidence for outcome-oriented projects.
- Targets disaggregated by gender, age, disability and relevant vulnerability categories, subject to lawful and ethical data collection.
- Unit-cost and reach indicators, with definitions fixed at project approval.
- Beneficiary feedback and grievance channels.
- Quarterly exception reporting and an annual outcome summary approved by the CSR Committee.
11. ESG and Sustainability Linkages
SML’s annual report links business sustainability with renewable energy, recycled input use, employee health and safety, ethical governance and community investment. The CSR programme should remain legally distinct from activities undertaken in the normal course of business, while being strategically coherent with material local needs and responsible-business priorities.
| PILLAR | COMPANY-REPORTED CONTEXT | CSR LINKAGE OPPORTUNITY |
| Environment | 400 kW solar plant; recycled aluminium input | Community climate resilience, water stewardship, waste awareness, green skills |
| Social | 149 permanent employees; health and safety emphasis | Public health, education, employability, vulnerable-group inclusion |
| Governance | Board committees, vigil mechanism and policies | Transparent partner selection, outcome dashboards, grievance and ethics controls |
Suggested SDG alignment
Subject to confirmation of actual project activities, the disclosed Schedule VII portfolio could align with SDGs 1 (No Poverty), 2 (Zero Hunger), 3 (Good Health and Well-being), 4 (Quality Education), 5 (Gender Equality), 8 (Decent Work and Economic Growth), 10 (Reduced Inequalities), 11 (Sustainable Cities and Communities), 12 (Responsible Consumption and Production) and 13 (Climate Action). Future reports should map targets only where project design and evidence genuinely support the linkage.
12. Disclosure Quality and Reconciliation Observations
| OBSERVATION | WHY IT MATTERS | RECOMMENDED ACTION |
| ₹42.95 lakh obligation in Annexure D versus ₹43.12 lakh gross amount required in financial note | Creates an internal reporting inconsistency | Reconcile calculation basis and correct or explain in the next filing/report. |
| ₹0.44 lakh excess disclosed, but “amount available for set-off” shown as dash | Treatment is unclear | Record the Board/finance decision and disclose whether set-off conditions are satisfied. |
| Closing provision shown as negative ₹1.62 lakh | May represent cumulative excess, but label is counter-intuitive | Explain accounting treatment and reconcile with CSR set-off register. |
| Agency names used as project names | Readers cannot understand intervention content | Use distinct project title, objective, beneficiary group and activity description. |
| No output/outcome metrics | Spend cannot be connected to social value | Publish project-level targets, achievements and evidence. |
| Durg project classified both local and non-local across different entries | Local-area logic is unclear | Define local-area geography and apply consistently. |
| Material reconciliation point The statutory annexure is arithmetically coherent at ₹42.95 lakh obligation and ₹43.39 lakh spend. The separate ₹43.12 lakh figure in the financial notes should be reconciled before the information is reused externally. |
13. Risks, Gaps and Improvement Opportunities
| RISK | LEVEL | CURRENT SIGNAL | MITIGATION |
| Single-partner concentration | High | 70.3% with one agency | Enhanced due diligence, milestones, site verification and diversification review |
| Outcome opacity | High | No beneficiary/output/outcome disclosure | Mandatory results frameworks and annual dashboard |
| Partner-delivery dependence | Medium | 100% indirect implementation | Risk-tier partners and maintain audit/termination rights |
| Short-term project bias | Medium | No ongoing projects | Add selected multi-year programmes where outcomes require continuity |
| Disclosure inconsistency | Medium | Conflicting required-spend figure; set-off ambiguity | Finance-secretarial-CSR reconciliation checklist |
| Geographic classification | Low–Medium | Durg entries differ on local status | Adopt documented local-area definition |
| Safeguarding/data risk | Unknown | Not disclosed | Partner codes, consent, child protection, privacy and grievance controls |
14. Recommended CSR Strategy and Action Plan
Strategic direction for FY 2026–27 to FY 2028–29
SML should move toward a focused “Responsible Industrial Communities” portfolio: a small number of evidence-led programmes improving human development and environmental resilience in and around its operating geography. A practical portfolio could combine one flagship multi-year programme, two supporting themes and a limited responsive-grant window.
| PORTFOLIO LAYER | ILLUSTRATIVE ROLE | GUIDING SHARE |
| Flagship local programme | Multi-year health, education/skills or rural-resilience intervention with measurable outcomes | 50–60% |
| Supporting thematic programmes | Two targeted partnerships complementing the flagship | 25–35% |
| Responsive and humanitarian grants | Small, time-bound local needs and relief | Up to 10% |
| Measurement and permitted administration | Monitoring, evaluation and compliant overhead within regulatory limits | As appropriate |
Twelve-month action plan
| TIMING | ACTION | OWNER / OVERSIGHT |
| Q1 | Approve local needs assessment, theory of change, partner due-diligence standard and FY27 results framework. | CSR team; CSR Committee |
| Q1–Q2 | Reconcile prior-year accounting/set-off records and define local-area geography. | Finance, Secretarial, CSR |
| Q2 | Contract partners with milestones, KPI definitions, safeguarding and audit clauses. | CSR/Legal/Finance |
| Quarterly | Review financial utilisation, outputs, risks, grievances and field evidence. | CSR Committee |
| Q3 | Conduct sample beneficiary verification and financial review of high-value grants. | Internal audit/independent reviewer |
| Q4 | Complete outcome review, partner scorecards and next-year portfolio decision. | CSR Committee and Board |
| Annual report | Publish project descriptions, beneficiaries, targets, achievement, lessons and SDG links. | Secretarial/CSR/Communications |
15. Monitoring Framework and KPI Scorecard
| DOMAIN | CORE KPI | FREQUENCY |
| Finance | Spend versus approved budget; utilisation supported; variance and unspent status | Monthly/quarterly |
| Delivery | Activities completed versus plan; outputs and beneficiary reach | Quarterly |
| Inclusion | Beneficiary profile by relevant demographic/vulnerability dimensions | Quarterly |
| Quality | Service standards met; drop-out/non-completion; beneficiary satisfaction | Quarterly/annual |
| Outcomes | Theme-specific change from baseline or starting status | Six-monthly/annual |
| Risk | Safeguarding incidents, grievances, fraud flags, data/privacy breaches | Immediate + quarterly |
| Partner health | Timeliness, evidence quality, governance and financial-control score | Quarterly/annual |
| Efficiency | Cost per output/beneficiary and co-funding leveraged | Annual |
| Sustainability | Continuation plan, community ownership, maintenance and exit readiness | Annual |
Illustrative theme KPIs
- Health/nutrition: people screened or served; referrals completed; treatment adherence; nutrition-status change where appropriate.
- Education: enrolment/retention; attendance; learning improvement; transition or completion rate.
- Livelihoods/skills: course completion; certification; placement/self-employment; income change at defined follow-up.
- Rural development: households or institutions served; functionality at 3/6/12 months; community contribution and maintenance.
- Environment: people reached is not sufficient alone—track waste avoided, water saved, survival rate, energy generated or other verified physical outcomes relevant to the intervention.
16. Conclusion
Sarthak Metals Limited’s FY 2025–26 CSR disclosure demonstrates full spending of the statutory obligation, a high local-area orientation, an independent-director governance structure and use of registered implementing agencies. These are sound foundations. The principal opportunity is qualitative: convert a contribution-led portfolio into a strategy-led and evidence-led programme in which each rupee can be connected to a defined beneficiary, output and outcome.
The most immediate priorities are to reconcile the financial disclosure differences, clarify treatment of excess spend, strengthen descriptions of funded projects, formalise partner risk controls and publish a proportionate outcome dashboard. With these measures, SML can improve not only compliance assurance but also credibility, learning and lasting community value.
Appendix A. Detailed Project Register
| AGENCY / DISCLOSED PROJECT | CSR REG. NO. | ITEM | LOCATION | MODE | ₹ L |
| Hare Krishna Movement | CSR00047880 | (i) | Raipur, Chhattisgarh | Through agency | 0.50 |
| Round Table India | CSR00000895 | (ii) | Durg, Chhattisgarh | Through agency | 5.00 |
| SOS Children’s Villages | CSR00000692 | (iii) | Raipur, Chhattisgarh | Through agency | 0.594 |
| Friends of Tribals Society | CSR00001898 | (x) | Raipur, Chhattisgarh | Through agency | 4.80 |
| Bhagwan Mahavir Jain Relief Trust | CSR00026129 | (i) | Raipur, Chhattisgarh | Through agency | 30.50 |
| Nosha Foundation | CSR00039958 | (i) | Jaipur, Rajasthan | Through agency | 1.00 |
| Lions Charitable Trust, Bhilai | CSR00089531 | (ii) | Durg, Chhattisgarh | Through agency | 1.00 |
Source: Annual Report, Annexure D p. 80.
Appendix B. CSR Compliance Checklist
| CHECK | STATUS | EVIDENCE / COMMENT |
| CSR policy disclosed | Yes | Web link provided in Board’s Report and Annexure D |
| CSR Committee disclosed | Yes | Three independent directors |
| Board-approved projects link disclosed | Yes | Web link provided |
| Average net profit disclosed | Yes | ₹2,147.67 lakh |
| Two per cent obligation disclosed | Yes | ₹42.95 lakh |
| Current-year spend disclosed | Yes | ₹43.39 lakh |
| Ongoing-project schedule | Nil | No ongoing projects reported |
| Other-than-ongoing schedule | Yes | Seven projects listed |
| Administrative overhead disclosed | Yes | Nil |
| Impact assessment disclosed | Yes | Not applicable; nil expense |
| Unspent amount disclosed | Yes | Nil |
| Capital asset disclosure | Yes | None / not applicable |
| Failure-to-spend explanation | Not applicable | Full spending reported |
| Board signatories | Yes | Managing Director and CSR Committee Chair |
| Internal consistency | Partial | ₹43.12 lakh financial-note figure needs reconciliation |
Appendix C. Source Index and Calculation Notes
| SOURCE SECTION | PRINTED PAGES | USE IN THIS REPORT |
| Strategic Review / company profile | 2–25 | Business context, solar, circularity and sustainability narrative |
| Board’s Report | 50–61 | CSR philosophy, focus areas, workforce and corporate data |
| Corporate Governance Report | 62–76 | Committee responsibilities, composition and attendance |
| Annexure D: Annual Report on CSR Activities | 79–81 | Core statutory obligation, spend, projects, partners, unspent and capital assets |
| Financial statements: CSR expense note | 116 | Prior-year comparison, gross required amount, utilisation and provision movement |
Primary source
Sarthak Metals Limited, Annual Report 2025–26, 118 pages. All company-specific factual statements in this review derive from that report unless explicitly identified as an analytical calculation or recommendation.
