POLICY FOR CORPORATE SOCIAL RESPONSIBILITY

I. TITLE: This Policy in relation to the Corporate Social Responsibility (“CSR”) of Shantinath Detergents Private Limited (SDPL) is titled as the “CSR Policy” and shall include any alterations, amendments, and or modification hereto from time to time.

II. VISION STATEMENT, OBJECTIVE, AND APPLICABILITY:

1. The CSR Policy sets out our commitment to ensuring that our activities extend beyond business and includes initiatives and endeavours for the holistic benefit and development of the community we operate in and the society we serve (preference to the local area and areas around it where we operate shall always be given). The CSR policy lays down the guidelines for undertaking programs directed towards social welfare activities and plans.
2. This Policy has been framed in accordance with the applicable provisions of the Companies Act, 2013 (“Act”) and the guidelines issued thereunder.

III. DEFINITIONS:

1. “Act” – Mean Companies Act 2013, including any alterations, amendments, and or modification hereto from time to time.
2. “Board” – The Board of Directors of the Company.
3. “Company” – Shantinath Detergents Private Limited.
4. “CSR Activities” – Means such programs and projects as may be approved by the Board in terms of this policy.
5. “CSR Committee” – Shall mean the Corporate Social Responsibilities Committee constituted by the Board of the Company in accordance with the Act and Policy.
6. “CSR Expenditure” – Means the amount recommended by the CSR Committee to be incurred on the CSR Activities in India in terms of the Act and the CSR rules as approved by the Board from time to time.
7. “Implementation Group” – Means constitution of group of members approved for the purpose of Implementation of the CSR Activities approved by Board and submitting report on the progress on the Activities to the CSR Committee, which shall be laid further before the Board.
8. “Implementation Agency” – Entity duly registered with the Central Government and having a unique CSR Registration Number (as of now w.e.f 1st April 2021).
9. “Financial Year” – Shall mean the period beginning from 1st April of every year to 31st March of the succeeding year.
10. “Net Profit” – Means the profit of the Company as per its financial statement prepared in accordance with the applicable provisions of the Act, but shall not include (a) any profit arising from any overseas branch or branches of the Company (whether operated as a separate company or otherwise); and (b) any dividend received from other companies in India, which are covered under and complying with the provisions of Section 135 of the Act.

IV. IMPLEMENTATION OF THE CSR POLICY:

1. The Board shall be responsible for implementing the mandate of the CSR Policy and shall ensure that the CSR Activities are carried out in accordance with this Policy and the annual action plan already approved by the CSR committees.
2. The CSR Committee shall approve reconstitution of an implementation group for the purposes of implementation of the CSR Activities approved by the Board from time to time.
3. The CSR Activities may be undertaken by the Company directly through its implementation group or with the prior approval of the Board, through any Implementation Agency duly registered with the Central Government and having a unique CSR Registration Number.
4. The Company may also collaborate with group companies for undertaking projects or programs or CSR activities in such a manner that the CSR Committees of respective companies are in position to report separately on such projects or programs in accordance with the rules.
5. In case of failure to ensure the minimum CSR expenditure i.e. 2% (two percent) of average Net Profits of the Company made during the three immediate preceding financial years, detailed reasons for the same should be submitted by the Implementation Group to the CSR Committee and the Board. Further the Board shall duly include such explanation in their annual board of director’s report.

V. CSR COMMITTEE:

1. Formulate CSR Policy and recommend to the Board for approval.
2. The CSR committee is responsible for providing recommendations to the Board with respect to CSR activities that has been planned in accordance with the plan.
3. Shall be responsible for the following activities:

a. Provision for CSR Budget and approve budget for respective CSR activities.
b. Monitor CSR policy and guidelines on behalf of Board of the company.
c. Design annual action plan in line to the CSR Policy and applicable law.
              • List of CSR activities or projects.
              • Mode and manner of execution of such projects or programs.
              • Framework of utilization of funds and implementation schedules for specific projects and programs.
              • Reporting mechanisms of the projects.
              • Assess the need to the benefiter and impact of the CSR activities.
d. To carry such other functions as may be delegated to it by the Board relating to CSR activities of the company.
4. The CSR committee shall consist of at least two or more directors.

The first CSR committee at Shantinath Detergents Private Limited shall comprise of the following Directors:

Name of the Members Nature of Directorship Designation of Members in CSR Committee

Name of the Members

Nature of Directorship

Designation of Members in CSR Committee

Vinod Kumar Jain

Director

Chairman

Ritum Jain

Director

Member

5. CSR Expenditure : Shantinath Detergents Private Limited shall spend at least 2% (two percent) of average Net Profits of the Company made during three immediately preceding financial years in accordance with the provisions the Companies Act, 2013 and Rules made thereunder.

6. CSR Committee meeting frequency: Shall meet at least twice in a Financial Year.

7. Reporting and Record Keeping: The CSR committee shall maintain or get maintained proper minutes of all its meetings. Annual report on the CSR programme along with expenses and allied certificates shall be recorded and reported.

VI. CSR ACTIVITIES:

As a part of its CSR initiatives, Shantinath Detergents Private Limited undertook to donate to the a) Indian Institute of Technology (IIT), Kharagpur for quality education & skill development through infrastructure development which overall contributed towards promoting Sustainable Development Goals, b) Bidya Health Plus and Diagonistic Centre (Pvt) Ltd which strives to provide towards high quality, cost effective preventive health care to its patients irrespective of their paying ability and c) Care Netram LLP whose primary objective is to provide vision care and telemedicine services at the door step of rural poor in India.

Company’s CSR projects and programmes, to be undertaken shall include activities falling within the purview of Schedule VII of the Companies Act, 2013, however our focus will be on the broader themes like Health and education through which we will strive to promote sustained growth in our surrounding environment.

VII. AMENDMENT: The Board of the Company may, subject to compliance with applicable law, at any time alter, amend, or modify the CSR Policy as it fit to comply with the statutory obligation of the Company to undertake the CSR Activities.

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