CORPORATE SOCIAL RESPONSIBILITY POLICY

Introduction

Corporate Social Responsibility is strongly connected with the principles of sustainability; an organization should make decisions based not only on financial factors, but also considering the social and environmental consequences. As a Corporate Citizen receiving various benefits out of society, it is our co-extensive responsibility to pay back in return to the society in terms of helping needy people by providing foods, clothes, etc., keeping the environment clean and safe for the society by adhering to the best industrial practices and adopting best technologies, and so on. It is the Company’s intent to make a positive contribution to the society in which the Company operates.

Short Title & Applicability

Corporate Social Responsibility (CSR) can be defined as the commitment of a company to set apart resources to support activities aimed at enhancing socio–economic development. Typically it constitutes an effort to improve living conditions of the local area in which the Company operates and to benefit society at large. The idea is to expend resources in order to create a positive impact in the community and on society, without seeking any commensurate monetary benefit.

MANA PROJECTS PRIVATE LIMITED (the Company) has framed its Corporate Social Responsibility Policy in accordance with the provisions of Section 135 of the Companies Act, 2013 read with Corporate Social Responsibility (CSR) Rules, 2014 together with Schedule VII of the Companies Act, 2013.

Policy Objectives

Corporate Social Responsibility is a form of corporate self-regulation integrated into a business model. Therefore, the policy will function as a built-in, self-regulating mechanism whereby the business will monitor and ensure its active compliance with the spirit of law, ethical standards and international norms.

The main objective of this Policy is to set a guiding principles for carrying out CSR activities by the Company and also to set up process of execution, implementation and monitoring of the CSR activities to be undertaken by the Company

CSR Committee

Composition The Corporate Social Responsibility Committee (CSR Committee) shall consist of three or more Directors out of which atleast one shall be an Independent Director. In case the total No. of Directors in the company is two, the CSR Committee should consist of two Directors.

Frequency of Meeting The Committee shall hold meetings as and when required, to discuss various issues on implementation of the CSR Policy of the Company.

Role The Committee, referred above, shall

• Formulate and recommend to the Board the CSR Policy and any amendments thereof which shall indicate the activities to be undertaken by the Company as specified in Schedule VII of the Companies Act 2013;
• Recommend the amount of expenditure to be incurred on the activities, as per CSR Policy:
• Be responsible for implementation and monitoring of CSR projects or programs or activities of the Company.
• Any other matter/thing as may be considered expedient by the members in furtherance of and to comply with the CSR Policy of the Company.

Quorum Quorum of meeting of CSR Committee shall be one third of the total strength or two Directors, whichever is higher.
The CSR Committee may invite Executives, Advisors, representatives of Social Organizations, Auditors of the Company and such other person (s) as it may consider necessary to attend the meeting

CSR Budget

The company shall ensure that it spends, in every Financial year 2% of its average net profits made during the 3 immediately preceding Financial years in pursuance of its Corporate Social Responsibility and subject to section 135 of the Companies Act, 2013 and Rules made thereunder.

“Administrative Overheads” expenses, if any, incurred by the Company will be used for ‘General Management & Administration’ of the Corporate Social Responsibility functions in the Company but shall not include the expenses directly incurred for the designing, implementation, monitoring, and evaluation of a particular Corporate Social Responsibility project or program.

Any surplus arising out of the CSR activities shall not form part of the business profit of the Company and shall be ploughed back into the same project or shall be transferred to the Unspent CSR Account and spent in pursuance of CSR Policy and Annual Action Plan of the Company or transfer such surplus amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.

Transfer of unspent CSR amount. - Until a separate fund is specified by the Government, the unspent CSR amount, if any, shall be transferred by the Company to a fund specified in Schedule VII of the Act.

CSR Activities

The Company shall undertake any of the following Activities/Projects or such other activities/ projects as may be notified by the Ministry of Corporate Affairs from time to time as a part of the Corporate Social Responsibility (“CSR”):

1. Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation and making available safe drinking water,
2. Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects;
3. Promoting gender equality, empowering women, setting up homes and hostels for women and orphans, setting up old age homes, day care centers and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
4. Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro forestry, conservation of natural resources and maintaining quality of soil, air and water;
5. Protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries;
6. Promotion and development of traditional arts and handicrafts;
7. Measures for the benefit of armed forces veterans, war widows and their dependents;
8. Training to promote rural sports, nationally recognized sports, Paralympics and Olympic sports;
9. 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;
10. Contribution or funds provided to technology incubators located within academic institution which are approved by the Central Government;
11. Rural development projects;
12. Any other activities in relation of the above and all other activities which forms part of CSR as per Schedule VII of the Act, 2013 (the “Act”) as amended from time to time. (Collectively hereinafter referred to as “CSR Activities")
    The CSR Activities shall be undertaken only in India for the benefit of the public and not only for the employees of the Company and their family. Provided that the preference shall be given to the local areas and areas where the Company operates for undertaking the CSR Activities.

“Administrative Overheads” expenses, if any, incurred by the Company will be used for ‘General Management & Administration’ of the Corporate Social Responsibility functions in the Company but shall not include the expenses directly incurred for the designing, implementation, monitoring, and evaluation of a particular Corporate Social Responsibility project or program.

Implementation of CSR Activities

The company shall undertake its CSR activities (being projects / programs / other permitted activities), approved by the CSR Committee either directly or through such other eligible entity / organization as approved by the CSR Committee.

The CSR Committee shall decide on the locations for CSR activities and formulate and recommend to the Board for approval a CSR annual action plan, which shall contain all matters which are required under Applicable Law and any other matters as the CSR Committee may deem fit from time to time. The Board may modify the annual action plan as per the recommendations of the CSR Committee at any time during the financial year, based on reasonable justification.

Exclusions

Corporate Social Responsibility (CSR) means the activities undertaken by the Company in pursuance of its statutory obligation laid down in Section 135 of the Act in accordance with the provisions contained in the CSR Rules, but shall not include the following, namely: -

1. Activities undertaken in pursuance of normal course of business of the Company.
2. Any activity undertaken by the Company outside India except for training of Indian sports personnel representing any State or Union territory at national level or India at international level.
3. Contribution of any amount directly or indirectly to any political party.
4. Activities benefitting employees of the Company.
5. Activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services.
6. Activities carried out for fulfilment of any other statutory obligations under any law in force in India