Corporate Social Responsibility Policy

1. Preamble

With the promulgation of the Companies Act, 2013 (Act) and the notification of Section 135 of the Act read with Schedule VII, dealing with Corporate Social Responsibility, it has become mandatory for the corporate entities falling within the purview of the limits on Net Worth, Turnover or Profitability as prescribed in the said section, to undertake any one or more of the activities as laid down thereunder, towards the discharge of their obligations towards the society in general (the “Corporate Social Responsibility” or briefly “CSR”).

The Company being a corporate entity falling within the purview of Section 135 has in due compliance formulated a CSR Policy (“Policy”) as elaborated hereunder.

The Policy has been approved by the Board of Directors as the Corporate Social Responsibility Policy of the Company.

2. Vision

The philosophy of the Company is to enhance community well-being by improving access to quality healthcare, promoting preventive health awareness, and supporting sustainable social development.

3. CSR Objectives

Through this Policy and its Corporate Social Responsibility (CSR) initiatives, the Company seeks to:

a. Create and drive a positive and measurable impact on social and community development.

b. Promote initiatives that enhance capacity-building, knowledge development, and sustainable social advancement in the communities in which it operates, thereby contributing to improved quality of life.

c. Ensure sustainable investment and the optimal utilisation of resources in fulfilling its obligations as a responsible corporate citizen, while fostering meaningful engagement with stakeholders, including employees, partners, and the wider community.

d. Discharge its social responsibilities alongside its business operations in a responsible, ethical, and transparent manner.

The Company’s CSR objectives and initiatives shall evolve over time, aligning short-term actions with long-term social impact goals. The overarching objective of the Company is to create a holistic and sustainable positive impact on the communities with which it engages, irrespective of any direct linkage to its core business operations.

4. CSR Activities

The Company shall undertake one or more CSR programmes, either directly or through its own or affiliated non-governmental organisations (NGOs), or in collaboration with other eligible entities, trusts, or societies, in accordance with the provisions of the Companies Act, 2013 and the rules made thereunder.

The Company may undertake any of the following activities:

a. Promoting preventive healthcare, sanitation, and awareness initiatives, including conducting health screening and diagnostic camps, and providing support for medical assistance to underprivileged sections of society.

b. Promoting education, including special education and employment-enhancing vocational skills, particularly among children, women, the elderly, and persons with disabilities, and undertaking livelihood enhancement projects.

c. Undertaking skill development initiatives, including capacity-building and training programmes in various sectors, including healthcare, paramedical and allied services, research, and other professional fields.

d. Promoting gender equality, empowering women, setting up homes and hostels for women and orphans, establishing old age homes and day care centres for senior citizens, and undertaking measures to reduce inequalities faced by socially and economically backward groups.

e. Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources, and maintaining the quality of soil, air, and water, including contributions to funds set up by the Central Government such as the Clean Ganga Fund.

f. Protection of national heritage, art and culture, including restoration of buildings and sites of historical importance and works of art; setting up public libraries; and promotion and development of traditional arts and handicrafts.

g. Measures for the benefit of armed forces veterans, war widows, and their dependents.

h. Training and promotion of rural sports, nationally recognised sports, Paralympic sports, and Olympic sports.

i. Contributions to the Prime Minister’s National Relief Fund or any other fund set up by the Central Government for socio-economic development, relief, and welfare of Scheduled Castes, Scheduled Tribes, other backward classes, minorities, and women.

j. Contributions to technology incubators located within academic institutions approved by the Central Government.

k. Rural development projects.

l. Slum area development.

m. Any other activities as may be specified under Schedule VII of the Companies Act, 2013, as amended from time to time.

5. CSR Funds

The corpus for the purpose of carrying on the aforesaid activities shall include the following:

a. Atleast 2% of the average Net Profits made by the Company for the three immediately preceding financial years shall be contributed in tranches by the Company to fund the activities of the Trust.

b. Any income or surplus arising from the CSR projects or programs shall be used as per Annual Action CSR Plan of the Company / as per the direction given by the Board as the case may be and such surplus shall not form parts of the business profits of the Company.

c. The Board may during any financial year, approve to undertake CSR expenditure beyond the CSR obligation for that particular financial year. Such excess CSR spend may be carried forward for setting-off against the CSR obligation of the Company for next three consecutive financial year.

6. CSR Implementation

a. The focus of the CSR activities conducted by the Company shall be within the list of activities specified in this policy.

b. The Company will continue to promote and build partnership with NGOs/trusts/foundations and other charitable organizations towards implementation of social activities for the betterment of the society.

c. The Company may also collaborate with other companies for undertaking projects or programmes or CSR activities after ensuring that the entity is eligible to undertake and implement the same under the Act read with Rules.

d. The time duration over which a particular project or programme will be spread, will depend on its nature, extent of coverage and the intended impact of the project or programme.

e. The Company will comply with all relevant laws and regulations, and strive to meet the standards as per the Act.

7. CSR Committee

To effectively coordinate, communicate and oversee the CSR activities of the company, the Board may constitute a CSR Committee comprising of three or more directors, out of which at least one director shall be an independent director.

The Corporate Social Responsibility Committee, if constituted, under Section 135 of Companies Act, shall:

a) Formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the company in areas or subject, specified in Clause 4 of this Policy.

b) Recommend the amount of expenditure to be incurred on the activities referred to in clause (a).

c) Monitor the Corporate Social Responsibility Policy of the company from time to time.

d) Formulate and recommend to the Board, an annual action plan, which shall include the following, namely:

The Board may alter such plan at any time during the financial year, as per the recommendation of its CSR Committee, based on the reasonable justification to that effect.

8. Monitoring and Reporting Framework

Project Monitoring

The Board or the CSR Committee, if constituted, shall review the (a) progress of various CSR projects/programmes as per requirement (b) status of implementation and fund utilization of the various projects/programmes as per approved Annual Action Plan at least once in a year.

In case progress of CSR Projects is not as per target/ milestones, the project will be re-evaluated and if based on re-evaluation, it is determined that the project is not sustainable or needs modification, the Board may decide to take suitable action including discontinuing the project.

The Chief Financial Officer of the Company shall certify to the Board at the end of every financial year, that CSR funds disbursed have been utilised for the purposes and in the manner as approved by the Board.

Reporting Framework

The Directors Report of the Company shall include an annual report on CSR containing particulars as per prescribed format. In case of applicability of impact assessment, the said impact assessment report shall also form part of the Board’s Report of the Company.

The Board of Directors shall disclose the composition of the CSR Committee as well as the contents of the CSR Policy and Projects in its report and shall publish the Policy on the website of the Company.

9. Review and Amendments

The Board may subject to applicable laws amend any provision(s) or substitute any of the provision(s) with the new provision(s) or replace this policy entirely with a new policy. However, no such amendment or modification shall be inconsistent with the applicable provisions of any law for the time being in force.