1. PREAMBLE

This policy encompasses the company’s philosophy for giving back to society as corporate citizens, and lays down the guidelines and mechanism for undertaking socially useful programmes for the welfare and sustainable development of the community at large, is titled as the ‘SAN CSR POLICY’.

This policy shall apply to all CSR initiatives and activities taken up by the company directly or through other social and welfare organizations on behalf of the company for the benefit of the society.

2. CSR VISION STATEMENT & OBJECTIVES

The core theme of the Company CSR policy is giving back to the society from which it draws its resources and extends helping hand to the needy and the underprivileged.

Corporate Social Responsibility is the commitment of business to contribute for sustainable economic development by working with the employees, local community and society at large to improve their lives in ways that are good for business and development. It is the contribution of the corporate sector for philanthropic causes like education, health, environment and community welfare at large.

In alignment with the vision of the company, through its CSR initiatives, SAN will contribute to enhance the value creation in the society, through its services, conduct and initiatives, so as to promote sustained growth of the society in fulfillment of its role as a Socially Responsible Corporate, with environmental concern.

3. OBJECTIVES

The objectives of SAN CSR Policy are:

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

To directly or indirectly take up porgrammes that benefits the communities over a period of time, and in enhancing the quality of life and economic well-being of the local populace. The Company and the employees are to actively involve and participate voluntarily in social welfare projects.

The business principles prescribe that everyone at SAN needs to follow and support our approach to governance, corporate social responsibility and continuous improvement.

4. SCOPE AND THE ACTIVITIES

The scope of CSR shall be the following activities as prescribed in Schedule VII of Companies Act 2013:

• Eradicating hunger, Poverty and malnutrition, promoting health care;
• Promoting education, special education and employment enhancing vocational skills;
• Promoting gender equality, empowering women and assisting the centers for aged & senior citizens and taking measures for reducing inequalities faced by socially and economically back word groups.
• Ensuring environmental sustainability, ecological balance, protection of flora & fauna and conservation of natural resources.
• Protection of natural heritage, art and culture and promoting & development of traditional arts and handicrafts
• Measures for the benefit of armed forces veterans, war widows and their dependents;
• Training to promote rural sports, nationally recognized sports, Para Olympic sports and Olympic sports
• Contribution to the Prime Ministers National Relief Fund / Chief ministers Relied Fund or any other fund set up by the Central / State Government for socio-economic development and relief and welfare of Scheduled Casts, the Scheduled Tribes, other backward classes, minorities and women,
• Contribution or funds provided to technology incubators located within academic institutions which are approved by the Central Government
• Rural and community development projects.

The above list is illustrative and not exhaustive. The CSR committee of Board of Directors of the Company is authorized to consider CSR activities which are not included in this list. All activities under the CSR activities shall be environment friendly and socially acceptable to the local people. Emphasis shall be given for local area development on the basis on need assessed for the people.

5. RESOURCES

Funding and Allocation

For achieving its CSR objects through implementation of meaningful and sustainable CSR programme, SAN shall allocate 2% of its average Net Profits calculated as per Sec 135 of the Companies Act 2013 as its annual CSR budget in each Financial Year.

From the annual CSR Budget allocation, a provision will be made towards the expenditure to be incurred on identified areas, for undertaking CSR activities on a year on year basis.

Allocation of the Annual Budget for CSR activities in any given year shall be as per the provisions of Companies Act 2013 and rules made thereof as amended from time to time. Any unspent / unutilized CSR allocation of a particular year will be carried forward to the next year and the CSR budget will be non-lapsable in nature.

6. IMPLEMENTATION

CSR programmes shall be undertaken by the company to the best possible extent within the defined ambit of identified thrust areas. Project activities identified under CSR are to be implemented by the company or through specialized agencies, which could include Trust of the Company, Voluntary Organizations, NGO’s, Recognized Institutes / Academic Institutions, Welfare Trusts, Self Help Groups, Mahila Mandals, Professional Consultancy Organizations etc.

CSR activities could be of Short term or Long term in nature:

Short term programmes:
These programmes shall be of period less than one year including one time assistance / contribution for the specific need.

In the case of short term project, the CSR committee shall fix a general budget and the company shall spend CSR amount within these budgets and shall submit periodically reports of these outflows.

Long term project: projects of over one year period
While identifying and selecting long term projects efforts shall be made to the extent possible to define the following:

• Programme objectives
• Study of the need and possible outcome of the programme
• Implementation schedule and milestones
• Responsibility and authorities
• Major results expected.

The time period / duration over which a particular programme will be spread, will depend on its nature, extent of coverage and the intended impact of the programme.

Programmes which involve considerable financial commitment are undertaken on a time frame of 2 – 5 years, and will be considered as special projects.

For all long term CSR projects, the time-frame and periodic milestones should be finalized at the time of approval of projects. CSR programmes as identified by the Company shall be put up to the CSR committee of the Board for its approval.

7. CRIETERIA FOR IDENTIFYING EXECUTING AGENCY

In case of long term programmes executed by NGO/s Voluntary organizations / Trust/ Section 8 Company, the following shall be minimum criteria need to be ensured:

• The NGPO / Agency / Trust / Company registered under Sec 8 of Companies Act shall have a permanent office / address in India
• The agencies shall have necessary registration as applicable.
• Possesses a valid Income Tax Exemption Certificate;
• The antecedents of NGO / Agency / Trust / Companies registered under Sec 8 of Companies Act 2013 are verifiable / subject to confirmation
• Experience of the Trust / NGO’s / Agency

For all long term CSR programmes once the same is approved by CSR Committee of the Board of Directors, the Company shall have an agreement / MOU with each of the executing implementing agency.

8. MONITORING AND FEEDBACK

To ensure effective implementation of the CSR programmes undertaken by the company, a monitoring mechanism will be put in place by the company. The progress of implementation of CSR programme under implementation will be reported to CSR committee on quarterly basis.

CSR initiatives of the Company will also be reported in the Annual Report of the Company in terms of Companies Act, 2013.

9. GENERAL

The provisions of CSR Policy would be subject to revision / amendment from time to time.

The Board shall review the CSR policy from time to time based on the changing needs and in accordance with the guidelines as may be issued by the Government in this regard. Suitable modifications in CSR policies shall be made as may be necessary.

The decision of the CSR Committee shall be final in interpretation of the provision of CSR policy.