Enlightened Circle Foundation (ECF)
01. PREAMBLE, INTENT & INSTITUTIONAL POSITIONING
Enlightened Circle Foundation (“ECF”, “we”, “our”, “us”) is a duly incorporated Section 8 non-profit organization under Indian law, established to advance emotional well-being, meditation, inner development, and societal resilience through structured programs and community engagement.
ECF operates under a principle-driven governance architecture, wherein all financial inflows are treated as:
- Mission-aligned capital, not transactional revenue
- Entrusted resources, not discretionary inflows
- Accountable funds, subject to regulatory and ethical oversight
Foundational Principle:
Contributions to ECF are not payments for services — they are commitments toward a structured social impact mission.
This Policy establishes a comprehensive, enforceable, and auditable framework governing:
- Receipt, classification, and acceptance of funds
- Corporate Social Responsibility (CSR) engagements
- Financial governance and utilization controls
- Risk management and compliance obligations
- Donor rights, limitations, and institutional safeguards
02. LEGAL & REGULATORY COMPLIANCE FRAMEWORK
ECF undertakes strict adherence to applicable Indian legal and regulatory frameworks, including but not limited to:
- Companies Act, 2013
- Section 80G of the Income Tax Act, 1961
- Relevant provisions of the Income Tax Act governing charitable entities
- Digital Personal Data Protection Act, 2023
- Prevention of Money Laundering Act (PMLA)
- Applicable Ministry of Corporate Affairs (MCA) and Income Tax Department regulations
2.1 Compliance Obligations
ECF shall:
- Maintain valid statutory registrations
- Ensure timely filing of returns and disclosures
- Maintain financial records in accordance with prescribed standards
- Ensure audit compliance and transparency
03. POLICY OBJECTIVES & RISK COVERAGE
This Policy is designed to:
- Ensure legal compliance and regulatory alignment
- Establish clear boundaries between contribution and entitlement
- Enable CSR onboarding at institutional scale
- Protect ECF from:
- Financial disputes
- Misuse allegations
- Reputational risks
- Compliance violations
04. GOVERNANCE STRUCTURE & FINANCIAL OVERSIGHT
4.1 Governing Authority
All financial matters are subject to oversight by:
- Board of Directors / Governing Body
- Authorized financial signatories
- Finance and compliance leadership
4.2 Internal Control Framework
ECF maintains a structured internal control system, including:
- Segregation of roles across:
- Fund collection
- Authorization
- Accounting
- Utilization
- Defined approval hierarchies
- Periodic financial reviews and reconciliations
4.3 Audit & Financial Reporting
- Annual statutory audits conducted by qualified auditors
- Maintenance of audit-ready documentation
- CSR-specific utilization tracking where applicable
05. CLASSIFICATION, NATURE & TREATMENT OF FUNDS
5.1 Unrestricted Contributions
Includes:
- Individual donations
- Recurring community contributions
Characteristics:
- Non-earmarked
- Used at ECF’s discretion
5.2 Restricted Contributions
Includes:
- Program-specific funding
- Earmarked donations
Characteristics:
- Purpose-bound
- Subject to defined usage conditions
5.3 CSR Contributions
Includes:
- Corporate funding under CSR mandate
- Strategic institutional partnerships
Characteristics:
- Contractually governed
- Reporting and compliance driven
06. PRINCIPLES GOVERNING ACCEPTANCE OF FUNDS
6.1 Voluntary Nature
All contributions are:
- Made voluntarily
- Free from coercion, inducement, or misrepresentation
6.2 No Quid-Pro-Quo
Contributions do not entitle donors to:
- Financial returns
- Ownership or equity
- Governance rights
- Guaranteed outcomes
6.3 Acceptance & Rejection Rights
ECF reserves the right to:
- Accept or reject any contribution
- Evaluate ethical, legal, and reputational alignment
- Decline funds from inappropriate or high-risk sources
07. CSR GOVERNANCE FRAMEWORK
7.1 CSR Partner Eligibility
ECF engages only with entities:
- Compliant with CSR regulations
- Aligned with ECF’s mission
- Passing internal due diligence
7.2 CSR STRUCTURING MODELS
- Program-based funding
- Multi-year partnerships
- Co-created initiatives
7.3 CSR DUE DILIGENCE
ECF may conduct:
- Legal verification of entity
- Financial and reputational screening
- Risk assessment
7.4 CSR AGREEMENTS
All CSR engagements shall include:
- MoU or Agreement
- Scope of Work (SOW)
- Budget and fund allocation
- Disbursement schedules
- Reporting requirements
- Termination clauses
7.5 CSR REPORTING & IMPACT LIMITATION
ECF shall provide:
- Utilization reports
- Narrative impact summaries
Limitation Clause
ECF does not guarantee:
- Behavioral outcomes
- Measurable transformation beyond scope
08. FINANCIAL UTILIZATION & CONTROL MECHANISMS
8.1 Utilization Scope
Funds may be used for:
- Program implementation
- Technology and infrastructure
- Human resources
- Operational expenses
8.2 Administrative Cost Allocation
Funds may be allocated to:
- Overheads
- Administrative support
As per:
- Legal limits
- CSR agreements
8.3 Fund Segregation
- CSR funds tracked separately
- General funds pooled
09. TAXATION & 80G COMPLIANCE
Donations qualify under:
- Section 80G of the Income Tax Act, 1961
ECF shall:
- Issue compliant receipts
- Maintain donor records
- Ensure audit traceability
10. NON-REFUNDABILITY & FINALITY
All contributions are:
- Irrevocable
- Non-refundable
11. ANTI-MONEY LAUNDERING & FRAUD PREVENTION
ECF reserves the right to:
- Reject suspicious transactions
- Conduct verification checks
- Report irregularities
12. CONFLICT OF INTEREST & NON-DIVERSION
ECF ensures:
- No personal benefit to trustees
- No diversion of funds
Disclosure of conflicts
13. DONOR RIGHTS & LIMITATIONS
Donors:
- May receive acknowledgment and reports
- Shall not influence governance
14. BRANDING & VISIBILITY
- Controlled by ECF
- Subject to agreement
15. FOREIGN CONTRIBUTION POLICY
- No FCRA registration
- No foreign donations accepted
16. LIMITATION OF LIABILITY
ECF shall not be liable for:
- Misinterpretation
- Indirect losses
Tax implications
17. POLICY MODIFICATION
ECF may update policy as required.
18. GOVERNING LAW
Jurisdiction: New Delhi, India
19. CONTACT, DONOR SUPPORT & GRIEVANCE REDRESSAL
ECF maintains a structured communication and grievance redressal mechanism to ensure transparency, responsiveness, and compliance with applicable laws.
19.1 Contribution & CSR Communication
For all queries related to:
- Donations and contributions
- CSR partnerships and proposals
- Utilization and reporting
- 80G receipts and documentation
Please contact:
Email: deepali.agnihotri@enlightenedcircle.org
19.2 Grievance Redressal Mechanism
For any concerns related to:
- Fund utilization
- Receipt issuance
- Compliance queries
- Disputes or clarifications
Users may write to:
Email: info@enlightenedcircle.org
Response Timeline:
- Acknowledgment: Within 3 working days
- Resolution: Within 7–15 working days, depending on complexity
19.3 Escalation Protocol
If a query or grievance remains unresolved:
- The matter may be escalated internally to the ECF Governing Authority / Compliance Team
- Final resolution shall be provided after internal review
19.4 Documentation Requirement
All communication must include:
- Full Name
- Contact Details
- Transaction ID (if applicable)
- Nature of request or concern
Incomplete requests may delay processing.