CORPORATE SOCIAL RESPONSIBILITY POLICY

Preamble

The Board of Directors (the “Board”) of Glass Wall Systems (India) Private Limited (the “Company” or “GWSIPL”), are committed to operate and grow its business in a socially responsible manner. Objective of this policy is to articulate the philosophy/values of the company towards social responsibility and to define areas chosen by the company to impact the society with its efforts towards Corporate Social Responsibility (“CSR”) and to define the governance and monitoring framework for ensuring effectiveness of the policy.

Regulatory Framework

The Companies Act, 2013 (“the Act”) read with the Companies (Corporate Social Responsibility Policy) Rules, 2014 (“the Rules”) and Schedule VII to the Act provides a framework for the companies falling within the purview of the Act, to undertake any one or more of the activities as laid down there under and to the discharge their responsibility towards the society in general. Further, the Act also provides instructions/ agencies eligible for the implementation of CSR activities, through which companies may spend their funds assigned for CSR.

Our Approach Towards Implementation

We will strive to implement the aforesaid CSR activities on our own to the extent possible. However, the implementation of our CSR activities would continue to be in association with Sanyam Life Foundation and various organization which are registered as a Trust or a section 8 company under the Companies Act, 2013 or Society or NGOs or any other form of entity incorporated in India that specialize in the aforesaid activities.
However, these entities shall have an established track record of 3 years of undertaking such or similar projects/programs.

Exclusion from CSR

The following activity shall not form part of the CSR activities of the Company:-

5.1 The activities undertaken in pursuance of normal course of business of a company.

5.2 CSR projects/programs or activities that benefit only the employees of the Company and their families.

5.3 Any contribution directly/indirectly to political party or any funds directed towards political parties or political causes.

5.4 Any CSR projects/programs or activities undertaken outside India.

CSR Funds

The corpus for the purpose of carrying on the aforesaid activities would include the followings:

6.1 2% of the average Net Profit made by the Company during immediately preceding three Financial Years.

6.2 Any income arising there from.

6.3 Surplus arising out of CSR activities carried out by the company and such surplus will not be part of business profit of the company.

Monitoring and Reporting

The CSR Committee will provide regular progress report to the Board. This report would indicate:

7.1 Achievement since last progress report / during the last quarter in terms of coverage compared to the target and reasons for variance.

7.2 Achievement of the year-to-date in terms of coverage compared to the target, plans to overcome shortfalls if any and support required from the Board to overcome the shortfalls.

7.3 Actual year-to-date spends compared to the budget and reasons for variance.

7.4 In respect of activities undertaken through outside Trust/Society/NGO's etc. there will be mechanism of monthly reporting of progress on each such activities and the amount incurred thereon.

7.5 The Board shall seek a short progress report from the CSR Committee on a quarterly basis.

7.6 Additionally, the Committee may empower the Chief Financial Officer to spend such amount as they think appropriate for some other strategic CSR contingencies that may arise during any financial year. The amount spent as above shall be put up for ratification of the Committee at its next meeting and shall report to the Board accordingly.

General

The CSR Policy would be subject to revision/amendment in accordance with the guidelines as may be issued by the Ministry of the Corporate Affairs from time to time, on the subject matter.
In any case, the CSR Committee shall review the Policy every year once for making suitable amendments for the better implementation of the Policy. The Company reserves its rights to alter, modify, add, delete or amend any of the provisions of this Policy.
The power to interpret and administer the Policy shall rest with the Chairman of the CSR Committee whose decision be final and binding. The Chairman is also empowered to make any supplementary rules/orders to ensure effective implementation of the Policy. These will, however, be reported to or tabled before the Board, from time to time, to ensure Board’s oversight on these issues.

Disclosures

The Annual Report of the Company include a section on CSR outlining the CSR Policy, CSR committee, CSR initiatives undertaken by Company, the CSR spend during the financial year and other information as required by the prevailing law.