PREAMBLE

The concept of Corporate Social Responsibility ("CSR") has gained prominence from all avenues. Organizations have realized that Government alone will not be able to get success in its endeavour to uplift the downtrodden in the society. For the Company in the present context, CSR means not only investment of funds for social activity but also integration of business processes with social processes. The Company believes that an organisation's true worth lies beyond its business, and is best reflected by the service it renders to the community and the society. An organisation has a responsibility to sub-serve larger societal goals as they have the ability to contribute for the welfare of the society. Social welfare and community development is therefore at the core of the Company's Corporate Social Responsibility philosophy.

Corporate Social Responsibility is strongly connected with the principles of sustainability; an organization should make decisions based not only on financial factors, but also on the social and environmental consequences. Therefore, it is the responsibility of the Company to practice its corporate values through its commitment to grow in a socially and environmentally responsible way, while meeting the interests of its stakeholders.

The Company recognizes that its business activities have wide impact on the societies in which it operates, and therefore an effective practice is required giving due consideration to the interests of its stakeholders including shareholders, customers, employees, suppliers, business partners, local communities and other organizations. The company endeavours to make CSR a key business process for sustainable development. The Company is committed towards aligning with nature; and has adopted eco-friendly practices..

GUIDING PRINCIPLES

The main objective of this CSR Policy is to lay down guidelines for the companies to make CSR a key business process for sustainable development for the Society. It aims at supplementing the role of the Government in enhancing welfare measures of the society based on the immediate and long term social and environmental consequences of their activities. Company will act as a good Corporate Citizen, subscribing to the principles of Global Compact for implementation.

In undertaking CSR Activities, the Company shall give preference to the local areas wherein the Company operates or has its offices i.e. areas in the vicinity of its factory /plant and offices.

The Company shall undertake only such CSR Activities:

A) as are identified as Focus Areas under this Policy and
B) as are permitted under the Applicable Laws.

The Company shall also consider international, national, or state level priorities/ objectives, while identifying CSR Activities.

The Company shall endeavour utmost transparency in selection, implementation, monitoring and reporting of CSR Activities.

Every year the Company shall spend atleast 2% of its average Net profit as defined under the Rules during the three immediately preceding financial years, on the CSR Activities as per approved Annual Action Plan, authorised by the Board on the recommendation of the CSR Committee.

The Annual Action Plan shall, inter alia, contain the following information with respect to the CSR Activity proposed to be undertaken by the Company:

i) list of CSR Activities to be undertaken in the relevant financial year;
ii) local area where the CSR Activities are to be undertaken;
iii) manner of execution;
iv) modalities of utilisation of funds;
v) implementation schedule;
vi) monitoring and reporting mechanism; and
vii) details of need and impact assessment, if any.

The Board on the recommendation of the CSR Committee shall be the absolute authority to update, alter, modify, amend, withdraw and replace the Annual Action Plan for justified reasons.

THE POLICY

The Company shall constantly strive to ensure strong corporate culture which emphasizes on integrating CSR values with business objective. It shall also pursue initiatives related to quality management, environment preservation and social awareness, in the areas as detailed below:

• (i)Promoting health care including preventive healthcare and sanitation and making available safe drinking water;
• (ii) Promoting education, including special education and employment enhancing vocational skills especially among children, women, elderly and the differently abled and livelihood enhancement projects;
• (iii) Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining of soil, air and water;
• (iv) Contribution to the Prime Minister's National Relief Fund or 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;
• (v) Rural development projects;
• (vi) Promote and participate in projects for cleanliness of Narmada river;.
• (vii) Promote education of girl child and the underprivileged by providing academic support, assistance to schools, sponsorships for eradicating illiteracy;
• (viii) Emphasise on regular health checks and medical aid/ health care facilities with special focus for the mother and child as well as the old aged persons of surroundings and making available of safe drinking water;
• (ix) Promote and sponsor various sports activities and games organized by local gram panchayat;
• (x) Promote and support local religious and cultural programmes.
• (xi) Other areas as may be notified by the Government from time to time.
• (xii) any activities or subjects specified in Schedule VII of the Act.

IMPLEMENTATION

a) The Company shall have a Committee of Directors, which will recommend to the Board for approval of the amount of expenditure to be incurred on the Corporate Social Responsibility (CSR) activities to be undertaken during a particular financial year.

b) The investment in CSR activity should be project-based and for every project, the time frame and periodic milestones should be finalized at the outset.

c) Project activities identified under CSR may be implemented by the Company or by Implementing Agency . Implementing Agency could be made to work singly or in tandem with other agencies. The Company shall either undertake the project directly or preferably through Principal Implementation Agency and shall to its best of its ability also ensure that the partners or vendors selected by the Company or the Implementation Agency, satisfy the criterion specified by the Rules.

d) In case the Company undertakes any CSR Activity through any Implementation Agency other than the Principal Implementation Agency, such Implementation Agency shall satisfy the requirements prescribed under the Applicable Laws and shall be approved by the Board.

e) Such specialized implementing agencies would include:

• Community based organization whether formal or informal.
• Elected local bodies such as Panchayats
• Voluntary Agencies (NGOs)
• Institutes/Academic Organizations
• Trusts, Missions, etc.
• Self-help groups
• Government, Semi Government and autonomous Organizations.
• Mahila Mandals/Samitis and the like
• Professional consultancy organizations

MONITORING AND FEEDBACK

a) To ensure effective implementation of the CSR programmes approved and undertaken by the company, progress on the CSR activities shall be reported to the CSR Committee on a quarterly basis.

b) CSR initiatives of the company will also be reported in the Annual Report as per the requirement of CSR Rules.

The Board of Directors of the Company shall mandatorily disclose the composition of the CSR Committee, and CSR Policy and Projects approved by the Board on their website, if any, for public access.