Preamble:

Anupam Rasayan India Limited (“Company”) constituted a CSR Committee which in exercise of its authority and discharge of its responsibility formulated the Corporate Social Responsibility Policy (“Policy”) in consonance with Section 135, Companies Act, 2013, as amended (the “Act”) on CSR and in accordance with the Companies (Corporate Social Responsibility) Rules, 2014, as amended (“Rules”). It shall apply to all CSR Projects/ Programmes undertaken by the Company as per liberal interpretation of activities listed in Schedule VII of the Act, within the geographical limits of India, preferably towards the benefits of marginalised, disadvantaged, poor and deprived sections of the community and the sustainable environment. Capitalized terms used in this Policy and not defined herein shall have the meaning as ascribed to them under the Act.

The CSR activities which may be undertaken shall be as per the Schedule VII of the Act as may be amended, modified from time to time and all other provisions in respect of the budget and compliances shall be as per the Act as may be amended, modified from time to time.

Vision Statement & Objectives:

• The Company aspires to be a responsible corporate citizen, by contributing to nation building through CSR Projects/ Programmes, in true letter and spirit, as enshrined in the Act.
• The Policy, which has been formulated in alignment with the vision of the Company, lays down guidelines and mechanisms to be adopted by the Company in order to carry out CSR Projects/ Programmes, as the Company intends to dedicate a percentage of the Company’s profit to social projects.
• All CSR interventions will be conceived and implemented through a focused approach towards target beneficiaries for generating maximum impact.
• CSR initiatives of the Company will be carried out in partnership with credible implementing agencies and by the Company itself too.
• Setting up appropriate procedure and reporting mechanisms to ensure implementation of CSR initiatives.

CSR Budget

The Board of the Company will ensure that in each financial Year (FY), at least two percent (2%) of the average net profits of the Company (calculated as per prescribed guidelines under the Act) accrued during the three immediately preceding FYs is spent on CSR projects/ programmes.

In the event that the amount indicated above is not spent in its entirety in that FY, the reasons thereof will be outlined as is required under the Act.

Projects/ Programmes will be identified and budgets will be allocated for such projects/ programmes through a process incorporating identification of suitable implementation agencies, need assessment (as and where required) and clear outlining of the desired outcomes from the projects.

An illustrative list of activities and projects under Schedule VII of the Act for investing/expending in CSR initiatives to be undertaken by the Company are as below. Additionally, the Company may also undertake any other projects as may be provided in Schedule VII amended from time to time.

• Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water;
• 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 centres 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 including contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga;
• 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 art and handicrafts;
• Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
• Training to promote rural sports, nationally recognised sports, Paralympic sports and Olympic sports;
• Contribution to the prime minister’s national relief fund or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the central govt. for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women;
• 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 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 Organisation (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).
• Rural development projects;
• Slum area development;
  Explanation- For the purposes of this item, the term `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.
• Disaster management, including relief, rehabilitation and reconstruction activities.
• Any other projects or activities approved by the Central Government pursuant to Section 135 of the Act, from time to time. Keeping in view of the spread of the novel COVID-2019 in India, spending of CSR funds for various activities related to COVID-2019 is an eligible CSR activity.

Further, the Company shall give preference to the local area and areas around it where it operates, for spending the amount earmarked for CSR activities

In the event where the Company makes any surplus or profit from pursuing its CSR projects/ programmes, these will not form part of the business profit (but will, instead, be carried forward to the following year/s as part of either the CSR corpus or as a supplement to the CSR budget.)

For all contributions received from other companies/sources towards the CSR Corpus/Budget, the Company will claim CSR expenditure only for funds that are provided from its own resources.

Planning and Implementation:

The operations of the CSR activities of the Company and the Policy shall be overseen by the CSR Committee.

The CSR activities shall be in the form of Projects/ Programmes, which will as far as possible, entail the following components:

• Need Based Assessment/ Baseline Survey/ Study where considered necessary/ feasible
• Identification of specific & measurable objectives/ goals in identified sectors and geographies
• Identification of timelines
• Annual financial allocation wherever possible
• Identification of beneficiaries
• Identification of milestones for complete duration of the project if possible
• Preparation and signing of agreement with implementing agencies
• Periodic reviews and monitoring
• Evaluation & assessment

Opportunities for complementing/ supplementing Government Initiatives/ programmes will be explored.

The Company would assign priority to projects/ programmes of medium (1-3 years) or longer duration (more than 3 years) in order to ensure emphasis on long term outcomes/ impacts.

The Company will lay emphasis on the sustainability of its projects/ programmes to ensure they remain relevant and viable even upon disengagement at the end of the project period.

The Company will explore possibilities for collaborating/ co-operating with other Corporates/ National/ Multi-National/ Bi-lateral International Agencies in order to synergies its efforts and increase both financial resources as well as outcomes and impact.

The Company may also consider participating in larger Projects/ Programmes where more than one Corporate/ National/ Multi-lateral/ Bi-lateral/ International Agency is involved.

The Company will endeavour at all the times to build and develop the skills of its CSR team and enhance levels of CSR awareness within the organisation.

The Company will also endeavour to build and develop the skills of the implementing agency that it engages whenever necessary.

Monitoring and Evaluation

A comprehensive Monitoring and Evaluation mechanism will be devised by the Company to ensure that the CSR process functions as mandated by the Act and the Rules, ensuring that all Projects/ Programmes are duly implemented as budgeted. This will be done on the basis of the following:

• Allocation of a separate budget for setting up and running the monitoring system;
• Installation of human architecture that can work together to ensure a firm check on speeds and the actual implementation of activities as planned;
• Release of funds only against valid utilisations.

The CSR Committee will be responsible for monitoring approved projects/ programmes.

The monitoring system devised by the Company will include:

• Regular field visits to Projects/ Programme site by designated teams;
• Comprehensive documentation/ compilation of Field Reports;
• Regular interaction with beneficiary communities to obtain feedback;
• Monitoring of timely fund utilisation to ensure that Projects/ Programmes as budgeted are actually carried out and/ or
• Any other activity that the CSR Committee may deem necessary in the larger interest of its CSR initiatives.

Impact Assessment/ Evaluation of CSR

In order to assess the impact of its CSR Projects and Programmes, maximise outcomes and build-in sustainability, scalability and replicability, the Company shall ensure that the projects/ Programmes undergo concurrent and final evaluation.

Documentation

Meticulous documentation of projects/ programmes is the only way to ensure that progress is continuously tracked, course corrections are provided, lessons learnt and objective feedback received.

Comprehensive documentation would include – printed material, audio recordings, video recordings etc. if any. This would also be of great value to the Company in brand building, market positioning, enhancing its competitive advantage and embedding CSR values within the organisation.

Accounting & Auditing

The Company will follow the Accounting and Auditing Guidance Note/ Standards duly approved by the Ministry of Corporate Affairs, Government of India.

Disclosure

The Company shall comply with Sections 135 (2), 135(4)(1) and 134 (3) (o) of the Act thereby ensuring that it makes a full disclosure of its CSR Policy, Strategy, Projects/ Programmes, Activities, monitoring mechanism, Implementing Agencies, Expenditure details as well as the composition of the CSR Committee of the Board, as required under the Act.

Review Mechanism

The Policy shall be renewed As and when required by the CSR committee subject to the approval of board of directors but will, at all times be subject to the applicable laws. The policy has been last reviewed on 30th November, 2020.

Interpretation

In case of any conflict between the provisions of this Policy and provisions of any applicable law, the provisions of the applicable law shall prevail over this Policy. Any subsequent amendments/modifications in the provisions of applicable law shall automatically apply to this Policy