I. INTRODUCTION
“Corporate Social Responsibility” (CSR) is a way of conducting business by which corporate entities visibly contribute to the social good. The essence of CSR is to integrate economic, environmental, and social objectives with the company’s operations and growth. It is the “continuous commitment by the business to behave ethically and contribute to economic development while improving the quality of life of work workforce and their families, as well as the local community and society”. It is the responsibility of the corporate entity toward society in consideration of the support given and sacrifices made by society. CSR is the concept whereby organizations serve the interests of society by taking responsibility for the impact of their activities on customers, employees, shareholders, communities, environment in all aspects of their operation.
The composition of the said Committee comprises of Three Directors:
i. Chong Ching Kee (DIN: 03099574)
ii. Sonaal Chopra (DIN: 01611458)
iii. Abbas Yunus Jabalpurwala (DIN: 08062192)
II. OBJECTIVES
The Objectives of the CSR Policy will be as follows:
- To lay down the guidelines for the company to evolve its relationship with society by way of social and economic contribution and by giving back to society for the resources it used to flourish by adopting appropriate business processes and strategies.
- To fulfil the directive of the Act enjoining prescribed companies to develop and implement a CSR policy specifying the activities to be undertaken by the Company.
- To prepare a list of activities, programmers, and projects to be undertaken during the implementation year, specifying modalities of execution and implementation schedules for the same.
III. SCOPE OF CSR POLICY
The policy would pertain to all activities undertaken by the Company towards fulfilling its CSR objectives. The policy would also ensure compliance with Section 135 of the Companies Act, 2013 (“The Act”) and would include the activities as covered under Schedule VII to the Act and the Companies (Corporate Social Responsibility Policy) Rules, 2014, and as amended from time to time (collectively “CSR Laws”).
CSR Policy approved by the Board of Directors on September 27, 2023, and amended on September 30, 2025.
The CSR Committee shall formulate, develop, implement, and recommend to the CSR policy to the Board.
IV. CSR EXPENDITURE
The total CSR Expenditure shall not be less than 2% of the average net profit made during the three immediately preceding financial years. Any surplus arising out of the CSR activities shall not form part of the business profit of the Company and shall be ploughed back into the same project or shall be transferred to the unspent CSR Account and spent in accordance with the CSR Policy.
If during any financial year the company spends an amount in excess of 2% of its average net profits, the same will be considered as excess CSR spends for the financial year and will be set off in the immediately succeeding three financial years, subject to fulfilment of conditions prescribed under the 2013 Act and the CSR Rules, if the Board decides to do so.
The CSR activities undertaken in India only shall amount to CSR Expenditure.
The Company may build CSR capacities of its own personnel as well as those of the external implementing agencies as approved under this policy, but such expenditure shall not exceed 5% (five percent) of total CSR expenditure of the Company in one financial year.
V. PROJECTS/ ACTIVITIES
The Company proposes to undertake its CSR activities from the projects/ activities, as contemplated under Section 135 of the Act read with Schedule VII thereto, or as may be permitted under the CSR Laws from time to time and also such other activities including but not limited to the
following:
i. Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation including contribution to the Swachh Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water;
ii. Promoting education, including special education and employmentenhancing vocational skills especially among children, women, elderly and the differently abled and livelihood enhancement projects;
iii. 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;
iv. 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 including contribution to the Clean Ganga Fund set up by the Central Government for rejuvenation of river Ganga;
v. Protection of national heritage, art and culture, including restoration of buildings and sites of historical importance and works of art; setting up public libraries, promotion and development of traditional arts and handicrafts;
vi. Measures for the benefit of Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents, including widows.
vii. Training to promote rural sports, nationally recognized sports, sports and Olympic sports;
viii. Contribution to the Prime Minister's National Relief Fund or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund), any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities, and women.
ix. Contributions
(a) Contribution to incubators or research and development projects in the field of science, technology, engineering, and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government;
AND
(b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense Research and Development Organization (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs)”.
x. Rural development projects
xi. Slum area development (‘Slum Area’ shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force)
xii. Disaster management, including relief, rehabilitation, and reconstruction activities. Contribution made to State Disaster Management Authorities to combat COVID-19 or other Pandemics of a similar nature.
CSR project/activities shall not include the following:
i. Activities undertaken in pursuance of the normal course of business of the Company.
ii. Any activity undertaken by the Company outside India except as specified under CSR Laws.
iii. Contribution of any amount directly or indirectly to any political party.
iv. Activities benefitting employees of the Company.
v. Activities supported by the Companies on a sponsorship basis for deriving marketing benefits for its products or services.
vi. Activities carried out for the fulfilment of any other statutory obligations under any law in force in India
VI. CSR IMPLEMENTATION
The Company may undertake the CSR activities either on its own or through other entities fulfilling the criteria laid down under the CSR Laws.
The Company may also collaborate with other companies for undertaking projects or programs or CSR activities in accordance with the Act and the applicable rules.
Education, Environment, Health care, and Sustainable Livelihood are the most basic requirements and needs of all sections of society. Ensuring that these requirements reach each and every section of the society is a responsibility of society as a whole. In most of the places, the weaker section of society is always deprived of at least one of the above basic necessities. Accordingly, the Company is willing to contribute and perform its CSR in a way which will enhance the possibilities of meeting these requirements of each member of the weaker section of society.
In order to adhere to its CSR, the Company is exploring various eligible organizations that are working towards the upliftment of the weaker sections of the Society. The Company proposes to fulfil its CSR in following manner:
In Education, our endeavour is to contribute to:
• Academic education by way of financial assistance to Primary, Middle and Higher Secondary Schools
• Organizations providing education to the weaker sections
• School specifically meant for girl children
• Schools for Blind people
• Schools for the Handicaps
• Orphanage Houses
In Environment our endeavour is to contribute to:
• Pollution Control
• A forestation, Social Forestry, Check Dams, Park.
In Health Care our endeavour is to contribute to:
• Primary health care centres
• Mother and Childcare projects
• Blood donation camps
• Camps for visually impaired and physically challenged people
• Social evils like alcohol, smoking, drug abuse etc.
In Sustainable Livelihood our endeavour is to contribute to:
• Organizations providing better livelihood to weaker sections.
• Organizations promoting women empowerment
• Projects undertaking agriculture development
VII. CSR MONITOIRING AND REPORTING FRAMEWORK
The CSR Committee shall monitor the implementation of the CSR Policy through periodic reviews of the CSR activities.
The respective CSR personnel will present their annual budgets along with the list of approved CSR activities conducted by the Company to the CSR Committee, together with the progress made from time to time as a part of the evaluation process under the monitoring mechanism.
The Company may engage external agencies to evaluate the CSR projects and monitor its progress.
The Chief Financial Officer of the Company shall certify to the Board that the funds disbursed have been utilised for the purposes and in the manner as approved by the Board.
VIII. CSR ANNUAL ACTION PLAN AND LOCATION OF CSR EFFORTS
The CSR Committee shall determine the locations for CSR activities and shall formulate and recommend to the Board the annual CSR action plan, which shall include all matters required under Applicable Law and any other matters it may deem fit from time to time.
The Board may modify the annual action plan at any time during the financial year, based on reasonable justification
IX. CSR REPORTING
The Board Report of a Company shall include an Annual Report on CSR containing particulars specified in Annexure to the CSR Rules as per the prescribed format.
X. DISPLAY OF CSR ACTIVITIES ON ITS WEBSITE
They shall mandatorily disclose CSR Policy and Projects approved by the CSR Committee and Board on their website, if any, for public access.
XI. AMENDMENTS TO THE POLICY
The Board of Directors, on its own and/or on the recommendation of the CSR committee, may make any changes/modifications and/or amendments to this Policy from time to time. In the event of any conflict between the provisions of this Policy and of the Act or any other statutory enactments, rules, the provisions of such Act or statutory enactments, rules shall prevail over and automatically be applicable to this Policy, and the relevant provisions of the Policy would be amended/modified in due course to make it consistent with the law.
