Corporate Social Responsibility Policy

Introduction

Gulshan Polyols Limited (“GPL”) was incorporated under the Companies Act, 1956 on 20th October, 2000.

Short Title

This policy in relation to the Corporate Social Responsibility ("CSR") of Gulshan Polyols Limited (“GPL”) is titled as the "GPL CSR Policy" and shall include any alterations, amendments or modifications hereto from time to time.

Vision Statement, Objective and Applicability

GPL has a vision to “Enhance Stakeholder value while adhering to the code of ‘Responsible Care’ and ethical values”.

To actualize this vision, GPL has set the following mission before itself through innovations, constantly endeavor to bring better products and processes that create greater value for the society and thereby ensuring:-

Effective contribution to the society
Value addition to the Stakeholders
Growth and Development of its employees

This CSR Policy has been framed in accordance with the applicable provisions of the Companies Act, 2013 ("Act") and the rules issued thereunder.

The CSR policy aims to achieve following Objectives:

Enhance the quality of life of the people in areas surrounding the plant and offices;
Create a positive impact by making sustainable developments in the society and promote good environmental practices;
Be responsible and responsive corporate citizen through endeavors to create a safe, harmonious and ecologically balanced environment for its members and the community at large.
Maintain commitment to quality, health and safety in every aspect of the business and people;

Further, GPL endeavors to ensure increased commitment at all levels in the organization, to operate its business in an economically, socially and environmentally sustainable manner, while recognizing the interest of all its stakeholders.

Definition

Unless the context so requires, the terms used herein shall have meaning assigned herein:

“Act” means Companies Act, 2013.
“Average Net Profit” shall have the same meaning as prescribed in Section135 of the Act read with the Rules.
“Board” shall mean Board of Directors of GPL.
“CSR activities” shall mean the projects or programs or activities undertaken / to be undertaken by GPL as prescribed in Schedule-I of this policy.
“CSR Committee” shall mean a Committee duly constituted by the Board of Directors pursuant to provisions of Section 135 of the Act and the CSR Rules.
“CSR Policy” shall mean Corporate Social Responsibility Policy of GPL.
“GPL” or “Company” shall mean GULSHN POLYOLS LIMITED.
“CSR Rules” means Companies (Corporate Social Responsibility Policy) Rules, 2014 as may be amended from time to time.
"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.

Any term not defined above, shall have the meaning assigned to it under the Act, CSR Rules or any other prevailing law.

Scope

The CSR Policy applies to the formulation, execution, monitoring, evaluation, and documentation of CSR activities in the target locations, in and around Company’s offices and plants.

Members and Meeting of CSR Committee

The Committee shall meet as often as necessary subject to the minimum number and frequency stipulated by the Board or as prescribed by any law or authority, time to time.

The following are the members of Corporate Social Responsibility (CSR) Committee:

Name	Designation
Ms. Archana Jain	Chairperson
Ms. Arushi Jain	Member
Ms. Aditi Pasari	Member

CSR Approach and Guiding Principles

As a corporate citizen of India, the Company aims to work towards inclusive and sustainable development of the community in and around its areas of operations and other parts of the country. The objective of the CSR projects / programmes of the Company is to improve the quality of life of people and build lasting social capital through interventions in social initiatives for the benefit of the community.

The guiding principles for selection, implementation and monitoring of CSR activities of the Company as well as formulation of the annual action plan shall be as follows:

i. Selection of CSR Projects and Programmes

While CSR projects / programmes of the Company may be carried out in any part of India, the Company shall give preference to the local areas around its manufacturing facilities/units.
The Company shall not discriminate against the beneficiaries of the CSR projects / programmes, on any grounds including caste, creed, gender, race, religion, disability or sexual orientation but it may focus its CSR projects / programmes to benefit the economically or socially weaker or marginalised sections of the society.
The Company may select the CSR projects /programmes based on need assessment, consultation with local bodies / government authorities or any other process as may be deemed appropriate considering the nature of activity including the emergent requirements arising out of natural calamity / disaster, pandemic, etc.
d.While selecting the CSR projects / programmes having implementation schedule of more than one year or outlay of Rs. one crore or more, the Company shall endeavor to define the following:
1. Project / Programme objectives.
2. Implementation schedules - Timelines for milestones of the project / programme.
3. Major results expected and measurable outcome.
The CSR programmes, projects or activities to be undertaken by the Company shall relate to one or more areas or subjects specified in Schedule VII to the Companies Act, 2013, as amended from time to time.
f.The CSR activities to be undertaken by the Company pursuant to this policy are outlined in Schedule I attached hereto.

ii. Implementation of CSR Projects and Programmes

The time period for implementation of a particular project or programme will depend on its nature, extent of coverage and the intended impact thereof.
b.GPL will follow a project / programme wise accountability approach to stress on the long term sustainability of its CSR projects / programmes. The CSR projects / programmes will be classified as under:
1. Ongoing Project - Multi-year CSR project/programme having timelines not exceeding three years excluding the financial year in which it is commenced and shall include CSR project /programme which was initially not approved as multi-year project/ programme but whose duration has been extended beyond one year by the Board of Directors of the Company based on reasonable justification; and
2. Other Projects – CSR projects/programmes which are not Ongoing Projects will be treated as other projects / programmes.
CSR projects/ programmes shall be implemented with participation of local community, wherever possible, and in consultation with local administration at village, block and district levels, wherever applicable. In order to make the desired impact on the society at large, the Company may synergize its CSR projects/ programmes with the initiatives undertaken by the Central / State Government, District Administration and Local Administration, as the case may be.
The CSR projects / programmes shall be executed by the Company itself and/ or through Mridul Literacy Society and / or any other implementing entities which fulfil the criteria and meet the requirements, as prescribed under Rule 4 of CSR Rules.
The target beneficiaries, the local authorities, professionals and institutions etc. involved in similar activities if need, may be consulted/ associated in the process of planning and implementation of the CSR activities.
Agency will hire professionals on need basis wherever considered necessary to plan and implement various projects

iii. Monitoring of CSR Activities

The monitoring and reporting mechanism for CSR Projects / Programmes shall be indicated in the annual action plan approved by the Board of Directors of the Company.
The CSR programmes / projects to be monitored using appropriate monitoring tools that may include field visit(s), self-assessment report(s), feedback survey(s), impact assessment(s) (if applicable), periodical review(s) or any other appropriate mechanism.
The Company shall undertake impact assessment, through an independent agency, of its CSR projects / programmes having outlays of rupees one crore or more, if applicable as perthe requirements of CSR Rules.
Corporate Social Responsibility Committee (“CSR Committee”) of the Board of Directors shall periodically monitor the progress of the CSR projects / programmes or by the person(s) authorize by the Committee/ Board.
The Board of Directors of the Company shall be periodically apprised about the progress of CSR projects / programmes. In case of Ongoing Project(s), the Board of Directors of the Company shall monitor the implementation thereof with reference to the approved timeline and year-wise allocation.

iv. Formulation of Annual Action Plan

Depending upon the timeline of implementation of a particular CSR Project / Programme, it shall be identified as an Ongoing Project or Other Project as per the parameters given above.
The CSR annual action plan shall include the following:
1. The list of CSR projects or programmes that are approved to be undertaken in areas or subjects specified in Schedule VII of the Companies Act, 2013;
2. The manner of execution of such projects or programmes as specified in sub-rule of rule 4 of CSR Rules;
3. The modalities of utilisation of funds and implementation schedules for the projects or programmes;
4. Monitoring and reporting mechanism for the projects or programmes; and
5. Details of need and impact assessment, if any, for the projects undertaken by theCompany.
6. The annual action plan would include the budget / outlay approved against the CSR projects / programmes to be undertaken.

CSR Activities Schedule

The Board shall ensure that the CSR Activities that are undertaken by the Company should be within the scope of the following activities:
1. 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;
2. Promoting education, including special education and employment enhancing vocation skills especially among children, woman, 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 centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically back ward groups;
4. Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro forestry, conversation 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;
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; promotion and development of traditional arts and handicrafts;
6. Measures for the benefit of armed forces veterans, war windows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
7. Training to promote rural sports, nationally recognized sports, paralympic sports and Olympic sports;
8. 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 Government for social-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women;
9. 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
10. 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 atpromoting Sustainable Development Goals (SDGs).
11. Rural development projects;
12. Slum area development Explanation - For the purpose of this item, the item ‘slum area’ shall mean any area declared as such by the Central Government or any State Government or any other competent authority under law for the time being in force;
13. Disaster management including relief, rehabilitation and reconstruction activities; and
14. Any other project as may be specified under Schedule VII of the Companies Act, 2013, from time to time.
The CSR Activities will be carried out in a manner that the preference is to undertake the CSR Activities in and around the local areas where the Company operates. CSR activities may also be taken up in urban, rural and tribal communities, wherein social engagement by GPL is warranted as per needs assessment.
Based on the scope of activities set out in paragraph 8(a) above, the CSR Committee shall provide recommendations to the Board with respect to specific CSR Activities that may be undertaken by the Company.

Budget/Approval of CSR Projects/Programmes For CSR Activities

CSR Committee shall recommend to the Board of Directors of the Company, the expenditure to be incurred on various CSR projects, programmes and activities and the annual action plan for a financial year and in case of an Ongoing Project, the total amount to be spent on the said project / programme over the years.
The Board of Directors shall, after taking into account the recommendations made by the CSR Committee, approve the amount of expenditure to be incurred on CSR projects, programmes and activities and the annual action plan for a financial year and in case of an Ongoing Project, the total expenditure to be incurred on the said project / programme over the years, as it may consider appropriate.
The Board or CSR Committee may delegate/sub delegate requisite powers for execution and implementation of this policy which may include powers for meeting any unforeseen and / or urgent requirements.
The amount of such expenditure shall not be less than 2% of the Average Net Profits of GPL made during the three immediately preceding financial years.
GPL may build CSR capacities of its own personnel as well as those of their implementing agencies but the Board shall ensure that such administrative overheads shall not exceed five percent of total CSR expenditure of the Company for the financial year
All administrative expenses including expenditure on wages and salaries, tours and travels, training and development of personnel deputed on CSR activities would be included in the amount of expenditure to be incurred on CSR activities.
The expenditure on CSR activities shall include all the expenses incurred by the company for ‘general management and administration’ of 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 programme
h.Based on the total approved Budget, Managing Director of GPL would be authorized to allocate funds for different projects on the basis of identified CSR plans on yearly basis, under different budget heads for undertaking CSR activities.

Reporting

A yearly report on activities / projects identified / implemented shall be submitted to CSR Committee.
The report of the Board includes the annual report on CSR Activities of the Company and sets out the requisite information in terms of the Act and the Rules.
The contents of the CSR Policy along with composition of the CSR committee, and projects approved by the Board are also made available on the website (if any) of the Company.
In case of failure to ensure the minimum CSR Expenditure, detailed reasons for the same are adequately disclosed in the Board Report

General

The surplus arising out of CSR projects or programs shall not form part of the business profits of GPL.
Any amendment or modification to the CSR Policy shall be approved by the Board on the recommendation of CSR Committee.
The contents of the latest and updated version of the CSR Policy is included in the report ofthe Board.