Title and Applicability

• Sua Explosives and Accessories Private Limited (‘Company’) has developed its Corporate Social Responsibility Policy (‘Policy’) in accordance with section 135 of the Companies Law 2013 and the rules made there under.
• The Policy shall apply to all CSR programmes of the Company.

CSR activities will primarily be in the areas of art & culture, education,health and upliftment of economic and social conditions of people.

The Company’s CSR projects will be implemented like any other business activity, in a time-bound manner with clear objectives, plan, targets and robust monitoring and evaluation parameters.

• The CSR will focus on supporting projects and programs for the protection of national heritage, art, culture, including restoration of buildings and sites of historical importance and work of art, setting up of public libraries, promotion and development of arts and heritage.
• In order to bring about development, enabling access to education for the underprivileged sections of the society and enhancing employability of under-served remains a prime area of the company’s CSR focus.
• While access to healthcare remains an important indicator of development, lack of access to proper medical facilities plagues many parts of rural and urban India. The Company seeks to promote healthcare through its CSR projects.
• The Company will undertake relevant and effective social projects to have a positive and meaningful impact on the lives of communities around it. The Company intends to aid Projects and Programmes for social advancement and livelihood help for women, senior citizens, children, widows, and differently abled persons.

The Company will focus on CSR initiatives that promote the areas identified in this policy. The Company will implement the chosen programs via two channels:

• Directly by Sua Explosives and Accessories Private Limited.
• Through Tasveer Foundation.

The Board may amend the CSR policy as may be required from time to time.

This policy is effective from 26.05.2014.

Company’s CSR will primarily focus on programs as stated below:

• Art & Culture.
• Education.
• Health.
• Upliftment of economic and social conditions of people.

However, the CSR Committee (defined below) may take up initiatives outside this scope based on specific circumstances.

The Company’s ongoing CSR projects will be aligned to the Policy. This Policy builds on the learning and good practices of the CSR projects initiated by the Company.

The mode of implementation will include a combination of direct implementation and implementation through trust/foundation/society/section 8 companies etc. set up by the Company or otherwise and partners such as NGOs, business partners,registered societies etc. The Company will select its partners after appropriate due diligence.

Composition of the CSR committee: The composition of the CSR Committee of the Board is as under

• Formulate and recommend the CSR Policy to the Board for approval. The Committee shall indicate the projects to be undertaken by the Company as specified in Schedule VII of the Companies Act 2013.
• Monitor the Policy from time to time and recommend changes to the Board.
• Recommend the amount of expenditure to be incurred on CSR projects.
• Institute a transparent monitoring mechanism for ensuring implementation of the social projects undertaken by the Company.

• The Board of Company shall ensure that in each financial year, the Company spends at least 2% of the average net profit made during the immediate three preceding financial years.
• The unutilized CSR budget from the 2% of the average net profit will be parked in a CSR Fund (Corpus) created by the Company. This Fund would also include any income arising there from and any surplus arising out of CSR activities.
• In case of any surplus arising out of CSR projects the same shall not form part of business profits of the Company.
• The Company may collaborate or pool resources with other companies (its subsidiary companies) to undertake CSR activities.

The Company will institute a well-defined monitoring and evaluation mechanism ensure that each social project has:

• Clear objectives developed out of the societal needs.
• Clear targets, time lines and measureable parameters wherever possible.
• A progress monitoring and reporting framework that is aligned with the requirements of the section 135 of the Companies Act and the CSR Rules.

• The Company will monitor progress on CSR projects and CSR spend and report to the top management quarterly and the CSR Committee half yearly.
• The Company will report CSR performance in its annual report as per the structure and format prescribed in the notified CSR Rules.
• The Company will share its CSR performance with its various stakeholders through its annual Sustainability Report, media, conferences, brochures, short films etc.