Samarth Infra-ventures Ltd. (SIL) is a Jaipur-based infrastructure development company engaged in the construction of urban housing projects, rural connectivity roads and community utility installations across five state

Samarth Infra-ventures Ltd. (SIL) is a Jaipur-based infrastructure development company engaged in the construction of urban housing projects, rural connectivity roads and community utility installations across five states in India. Incorporated in 2009, the Company has a diversified promoter group holding 52% of the paid-up equity capital, with the remaining stake distributed among domestic institutional investors, foreign portfolio investors and retail shareholders. SIL has been listed on both the BSE and NSE and has consistently positioned itself as a socially responsible enterprise committed to sustainable development and inclusive growth. The Company's Board of Directors comprises eleven members, including four independent directors and one-woman independent director. SIL has constituted all mandatory statutory committees including Audit Committee, Nomination and Remuneration Committee, Stakeholder Relationship Committee, and a dedicated Corporate Social Responsibility and Sustainability Committee. The Company publishes an annual Sustainability Report aligned with global reporting standards and has, over successive annual reports, made strong representations to its investors and regulators regarding its robust social governance framework. In 2022, SIL successfully bid for a large state government contract to develop integrated township infrastructure in a tribal belt district of Rajasthan. As part of its project approval process, SIL submitted a social governance compliance declaration to the relevant statutory authority, claiming that its internal systems were fully equipped to identify, assess and manage all social risks associated with the project. The Company further represented that it had established comprehensive policies for community engagement, supply chain conduct and employment equality and that these were actively monitored and reported upon. However, during the third quarter of project execution, a Civil Society Organisation filed a complaint with the state government alleging that SIL had commenced construction activities without adequately assessing the project's impact on the local indigenous community, which depended on shared water body situated within the construction zone. The complaint further alleged that the Company had made no arrangements to address the displacement of seasonal agricultural workers in the affected villages, many of whom belonged to a marginalised demographic group. It was also alleged that SIL's workforce practices at the project site reflected significant wage disparity between male and female contract workers performing identical roles, and that no formal non-discrimination or equal opportunity framework had been communicated to site-level supervisors or labour contractors. The matter attracted regulatory attention when SEBI initiated a preliminary inquiry into SIL's representations made in its public disclosures and sustainability filings. SIL's subsidiary, Samarth Social Foundation (SSF), a non-profit entity registered under the Companies Act, 2013, which had been separately seeking registration on the Social Stock Exchange to raise funds for its rural skilling programmes, came under scrutiny. It emerged during the SEBI inquiry that one of the trustees of SSF had previously been identified as a wilful defaulter by a scheduled commercial bank and that a promoter-director of SIL was simultaneously a director of another company, that had been debarred from accessing the securities market by SEBI, though the debarment period for that enterprise had since concluded. The Audit Committee of SIL convened an emergency meeting and commissioned an independent review. The review revealed that while SIL had adopted several social governance policies on paper, none had been operationalised through measurable performance indicators or integrated into project-level decision-making. The Company's Social Auditor, appointed for the township project, had submitted a limited-scope report that failed to examine several critical community-level concerns, raising questions about the minimum scope of inquiry expected of a Social Auditor in infrastructure projects of this nature. The Board, now facing reputational damage and regulatory exposure, sought urgent advice from its Practising Company Secretary on multiple governance dimensions. Based on the above facts, answer the following questions: What systematic steps should the Company follow to set up a social governance framework before commencing a high-impact infrastructure project ?