CSR Policy

KARAMCHAND REALTECH PRIVATE LIMITED

CORPORATE SOCIAL RESONSIBILITY POLICY

INTRODUCTION

Karamchand Realtech Private Limited (the “Company”) is in the business to acquire, purchase, sell, subdivide, develop any type of land and transfer the same. The Company is also into development of residential, commercial and retail properties.

This CSR Policy aims to define and establish the Company’s Policy framework towards CSR.

OBJECTIVES

This policy aims to contribute towards sustainable development of the society and environment to make planet a better place for future generations. The philosophy of CSR is imbibed in our business activities and social initiatives taken in the area mentioned in Scheduled VII to the Act.

The CSR Policy shall be implemented in accordance with the provisions of Section 135 of the Companies Act, 2013 and the rules made thereunder. It shall apply to all the CSR Activities undertaken by the Company in India as per Schedule VII of the Act and any amendments or modifications thereto.

The CSR activities shall not include activities undertaken by the Company in pursuance of the normal course of its business. Further, projects, programs or activities that solely benefit the employees of the Company and their families shall not be considered as CSR Activities under this CSR Policy.

CSR COMMITTEE

In compliance of the requirement of Section 135 of the Companies Act, 2013 and relevant rules made thereunder(“Regulations”), the Company has constituted CSR committee consisting of :

Mr. Bimal Arya

Mr. Anil Arya

Mr. Naveen Arya

Mr. Vivek Chaturvedi

Mr. Sanjay Shrivastava

FUNCTIONS OF CSR COMMITTEE

CSR Committee was constituted with following functions assigned:

  • To formulate and recommend a CSR Policy indicating the activities to be undertaken by the company in areas or subject specified in Schedule VII to the Act;
  • To recommend the amount of expenditure to be incurred on the activities referred to in clause (a);
  • To formulate and recommend an annual action plan in pursuance of CSR Policy covering the following aspects:
    • the list of approved CSR projects or programs to be undertaken in areas or subjects specified in Schedule VII to the Act;
    • the manner of execution of such projects or programs as specified in rule 4(1) of CSR Rules;
  • the modalities of utilisation of funds and implementation schedules for the projects or programs;
    • monitoring and reporting mechanism for the projects orprograms; and
    • details of need and impact assessment, if any, for the projects undertaken by the company;
  • Recommend changes to the Board, if any, needed in the annual action plan with reasonable justification to that effect.
  • To monitor the CSR Policy as approved by the Board from time to time.

The CSR Committee should recommend the approach and direction of CSR activities to be undertaken by the company and also provide guiding principles for :

  • Selection of CSR projects / programmes / activities
    • Implementation of CSR projects / programmes / activities
    • Monitoring of CSR projects / programmes / activities
    • Formulation of the annual action plan

CSR ACTIVITIES

The Policy recognizes that corporate social responsibility is not merely compliance; it is a commitment to support one or more of the following focus areas as notified under Section 135 of the Companies Act, 2013 read with the Companies (Corporate Social Responsibility Policy) Rules, 2014 as amended fromtime to time:

  • Eradicating hunger, poverty and malnutrition, [‘‘promoting health care including preventinve 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

CSR SPENDING

The Company would strive to spend at least 2% (two percent) of the average Net Profits of the Company made during the three immediately preceding financial years.

The amount to be spent on CSR activities shall be calculated in accordance with the provisions of the Act and Rules made thereunder.

Amount spent on CSR projects or programs or activities undertaken in India only shall amount to CSR expenditure.

The surplus arising out of the CSR activity/projects shall not form part of the business profits of the Company.

Expenses incurred for the fulfillment of any act / statute of regulations (such as Labour Law, Land Acquisition Act etc.) would not count as CSR expenditure under the Companies Act.

It includes all expenditure including contribution to corpus, for projects/programs relating to CSR activities approved by the Board, but does not include any expenditure on an item not in conformity or not in line with activities which fall within the purview of Schedule VII of the Companies Act, 2013.

IMPLEMENTATION OF CSR ACTIVITIES

The Company may undertake CSR activities through registered trust or a registered society or a company established by the Company or its subsidiary or associate company under Section 8 of the Act or otherwise.

The Company can carry out the CSR activities through any other trust or society or company which is not established by the Company or its holding or subsidiary or associate company provided that it shall have an established track record of three years in undertaking the similar programs or projects and the Company has specified the projects or programs to be undertaken by these entities, modalities of utilization of funds on such projects and programs and the monitoring and reporting mechanism.

The Company may collaborate with other companies for undertaking the CSR activities subject to fulfillment of separate reporting requirements as prescribed, in the Regulations.

The CSR activities shall not include any activities undertaken by the Company in pursuance of normal course of business of the Company.

Any amount directly or indirectly contributed to any political party shall not be considered as CSR activities.

MONITORING MECHANISM

The Board will ensure a transparent monitoring mechanism for ensuring effective implementation of the CSR Activities proposed to be undertaken by the Company.

The Board will ensure that the CSR Activities are undertaken in compliance with this CSR Policy and in a project or programme with clearly defined project deliverables, implementation schedules, processes and budgets as given in the Annual Action Plan.

The Board will monitor the projects and programmes to ensure that they are being carried out in compliance with this CSR Policy and the Companies Act. The Board shall also monitor the progress of CSR Project/programmes/activities including expenditure incurred till the allocated budget is fully utilised.

REPORTING

The Company will make following disclosures in its Board Report: Composition of CSR Committee.

Contents of CSR policy and placing it on website of the company. Reason for not spending the CSR amount.

CSR activities/projects undertaken by the Company and amount spent.

Annual report on CSR containing particulars as per annexure as specified in theCompanies (Corporate Social Responsibility Policy) Rules, 2014.

A responsibility statement by the Board that the implementation and monitoring of CSR policy, is in compliance with CSR objective and policy of the Company, will be included in the Annual Report on CSR Activities.

AMENDMENT

The Board may review and amend this policy from time to time subject to the recommendations of Corporate Social Responsibility Committee (“CSR Committee”).