CSR Policy

1. Applicability

As per Section 135 of the Companies Act, 2013 and rules made thereunder, every Company having net worth of rupees five hundred crore or more, or turnover of rupees one thousand crore or more or a Net profit of rupees five crore or more during any financial year shall constitute a Corporate Social Responsibility (CSR) Committee. The CSR Committee shall formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the Company as specified in Schedule VII. The CSR vision of the Company is to build relationship of trust with local communities, society and other stakeholders to contribute to developing a sustainable society for future generations.

2. Composition of CSR Committee

The Corporate Social Responsibility Committee (CSR Committee) of the Board of Directors (Board) of the Company comprises of all directors on the Board of the Company, as indicated
below:
i. Richard Mohan Wason
ii. Shibu Mohammed
iii. Amittathody Surendran

3. Functions and Powers of Committee

To effectively implement the objectives of the Company with respect to CSR, the Committee is vested with the following functions and powers:

a. Formulate CSR Policy and recommend the same to the Board of Directors of the Company for approval
b. Recommend CSR activities as stated under Schedule VII of the Act
c. Approve to undertake CSR activities and to separately report the same in line with the CSR Rules
d. Recommend the CSR Budget
e. Spend the allocated CSR amount on the CSR activities once it is approved by the Board
of Directors of the Company in accordance with the Act and the CSR Rules
f. Create transparent monitoring mechanism for implementation of CSR initiatives in India
g. Monitor CSR Policy from time to time
h. Authorize executives of the Company to attend the CSR Committee Meetings, if necessary

4. CSR Spend

The Companies Act, 2013 prescribes that the companies which meet the criteria specified U/s. Sec. 135 shall contribute 2% of its annual net profits (calculated as per Sec. 198) during the three immediately preceding financial years on CSR Activities that fall under the categories specified under Schedule VII of the Act

5. CSR Expenditure

Net profit for the purpose of allocation towards CSR means profit more fully described under Rule 2(f) of the CSR Rules. The CSR expenditure shall include all expenditure including contribution to corpus or on projects or programs relating to CSR activities approved by the Board of Directors on the recommendation of its CSR Committee but does not include any expenditure on an item not in conformity or not in line with activities stated under Schedule VII of the Act

6. Exclusion from CSR

The following activities shall not form part of the CSR activities of the Company:-

• The activities undertaken in pursuance of normal course of business of a company.
• CSR projects/programs or activities that benefit only the employees of the Company and their families.
• Any contribution directly/indirectly to political party or any funds directed towards political parties or political causes.
• Any CSR projects/programs or activities undertaken outside India.

7. Failure to spend the CSR Money

If the Company fails to spend the required amount in a particular financial year, it is the duty of the Committee to submit a report in writing to the Board of Directors specifying the reasons
for not spending the amount, which in turn shall be reported by the Board of Directors in their Annual Report pertaining to that particular Financial Year. Surplus, if any, arising out of the CSR projects or programs or activities shall not form part of the business profit of the Company.

8. Reporting and publication of CSR policy

As per the CSR Rules, the contents of the CSR Policy shall be included in the Directors’ Report and the same shall be displayed on the Company’s website, if any

9. Implementation of the Policy:

FY 2020-21:

The CSR policy of the company may be amended at any time by the Board of the company on
the recommendation of the CSR committee.