CSR Policy

This policy sets out the Company’s commitment & approach towards Corporate Social Responsibility based on our philosophy of always acting in the interest of others be it our clients, employees, vendors or the society that we operate in. The Company is committed to the society for improving the quality of life of the communities we serve through the CSR theme of ‘Building Sustainable Community’. The Company intends to be a significant contributor to CSR initiatives in India by devising, implementing and contributing to projects focused on education, enhancement of livelihood, equality, environmental sustainability, and socio-cultural development in the areas where it operates. Constitution of Corporate Social Responsibility Committee:

The Board of directors of the Company (“Board”) constituted a Corporate Social Responsibility Committee (“CSR Committee”) in terms of Section 135 of the Companies Act, 2013 (“Act”).

Focus Areas:

In line with the requirements of the Act, the Company’s CSR programmes shall mainly focus on the following areas:

promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects;

promoting gender equality, empowering women, setting up homes and hostels for women and orphans, setting up old age homes, day care centers and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;

ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water;

measures for the benefit of armed forces veterans, war widows and their dependents;

initiating Green Drives focusing on cleaning and making India green by planting more trees or harvesting rainwater, installing sewage treatment plant etc.

However, the Company may choose to undertake additional CSR Activities falling within the purview of Schedule VII of the Act, as may be amended from time to time, based on the recommendations of the CSR Committee and as may be approved by the Board.

Responsibility of the Board:

The Board shall be responsible for –

Approving the CSR policy of the Company as may be recommended by the CSR Committee, subject to such changes/modifications as the Board may deem fit.

Ensuring that in each financial year the Company spends such amounts for CSR activities as may be stipulated in the Act and as may be amended from time to time.

Ensuring that the activities included in the CSR Policy are undertaken by the Company.

CSR Committee:

The CSR Committee of the Company shall be responsible for:

Formulating and recommending to the Board the CSR Policy which shall indicate activities to be undertaken in terms of Section 135 read with Schedule VII of the Act and the Rules framed thereunder with such amendments, modifications and/or alterations as may be made from time to time. Any or all provisions of the CSR policy may be amended by the Board based on the recommendations of the CSR Committee or sua sponte/suo motu either in accordance with any statutory guidelines that may be issued from time to time or otherwise.

Recommending to the Board the CSR expenditure to be incurred.

Monitoring the implementation of the CSR Policy from time to time

CSR Budget:

The amounts to be spent by the Company shall be as stipulated under the Act with such amendments, modifications and/or alterations as may be made from time to time and as approved by the Board. Any surplus arising out of the CSR projects or programmes or activities shall not form part of business profits of the Company.

Target Communities & Project Locations:

The Company’s target communities shall include children, marginalised youth and women, differently abled, armed forces veterans, war widows and their dependents, socially and economically backward groups and other such groups associated with our focus areas. Relevant projects and locations pertaining to the outlined focus areas and target communities shall be undertaken around the areas in which we operate as well as other identified locations from time to time.

Implementation, monitoring and review mechanism:

The CSR activities will be driven by a Project Leader under the aegis of the CSR Committee and the Board. The CSR Committee will play a significant role in assimilation of the CSR policy across the Company at all levels and ensuring that the CSR initiatives are in line with this policy;

The CSR Committee will be responsible for monitoring approved projects and fund disbursals for such projects. The CSR Committee will put in place a transparent monitoring and reporting mechanism for ensuring effective implementation of the projects, programmes and activities proposed to be undertaken by the Company. Such monitoring mechanisms will include onsite visits, meetings and progress/status reporting by the project team;

The CSR Committee shall periodically review the CSR project reports and the same shall be presented to the Board at such intervals as the Board deems fit and atleast on an annual basis.

Stakeholder Communication:

The Company shall share updates regarding our key projects and its impact through our Annual Report, or the Company’s web platforms and other relevant mechanisms from time to time