Corporate Social Responsibility Policy

Preamble

It is the Company’s intent to make a positive difference to society. It recognises that it cannot do it all; so that if there are choices to be made, bias will be towards doing fewer projects with greater impact and focusing initiatives on communities in which the Company lives and operates.

As a responsible business, Company takes pride in being socially inclined and focuses on sustained and effective Corporate Social Responsibility (“CSR”) projects. Through sustainable measures, Guavus shall actively contribute to the Social, Economic and Environmental Development of the community in which we operate ensuring participation from the community and thereby create value for the nation. Such CSR projects are far more replicable, scalable and sustainable, with a significant multiplier impact on sustainable livelihood creation and environmental replenishment. These initiatives are independent of the normal conduct of Guavus business.

Our employees are encouraged to volunteer their time and skills and enjoy the experience of giving back to the communities in which they work.

We are committed towards improving the quality of lives of people in the communities in which we operate. We wish to be a Company which is respected by people for its commitment towards social causes.

Policy

It is Guavus policy:

1. To implement CSR programmes primarily in the economic vicinity of the Company’s operations with a view to ensuring the long term sustainability of such interventions.

2. To direct CSR Programmes, inter alia, towards achieving one or more of the following:

i. eradicating hunger, poverty and malnutrition;

ii. enhancing vocation skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects;

iii. ensuring environmental sustainability by cleanlinessinitiatives;

iv. supporting rural development;

v. promoting education including special education and employment enhancing vocation skills among children, women, elderly and differently abled and livelihood enhancement projects;

vi. preserving and promoting sports;

vii. promoting preventive health care and sanitation and making available safe drinking water; and

viii. such other activities as the Board may consider to be appropriate.

The Guavus CSR committee in collaboration with the CSR Action Group (CAG) came out with the following areas identified for conducting the CSR activities at Guavus, which have been duly approved by the Board:

i. promoting education including special education and employment enhancing vocation skills among children, women, elderly and differently abled and livelihood enhancement projects;

ii. promoting preventive health care and sanitation and making available safe drinking water; and Implementation

We will strive to implement the aforesaid CSR activities to the extent possible. To implement the Company’s CSR Programmes through Company personnel or through external implementing agencies. We recognize the need to work in partnership with other players as well.

This would include:

1. Collaborating with organization/s, registered as Trust, or as Society, or NGO’s, non-profit company under Section 8 of the Companies Act, 2013 or any other form of entity incorporated in India that specialise in the aforesaid activities.

2. Contribution to various funds which are aligned with our Vision

a. Prime Minister’s National Relief Fund;

b. Swach Bharat Kosh;

c. Clean Ganga Fund;

d. Any other fund set up by the Central Government.

3. Collaborating or pooling resources with other companies to undertake aforesaid CSR activities.

Governance

(Refer Governance report for complete details)

The Board of Directors Anukool Lakhina, Anupam Lakhina and Pooja Lakhina have constituted a CSR Committee comprising of Louis-Philippe Benoit, Anubhav Srivastav, Rakesh Khanna and Steve Denebeim as Directors. This CSR committee has further approved for the “CSR Action Group” called CAG as abbreviation, working with the NGO’s/schools at the ground level comprising of 14 members who have volunteered for CSR initiatives at Guavus.

1. Every year, the CSR Committee will place for the Board’s approval, a CSR Plan delineating the CSR Programmes to be carried out during the financial year and the specified budgets thereof. The

Board will consider and approve the CSR Plan with any modification that may be deemed necessary.

2. The CSR Committee will assign the task of implementation of the CSR Plan within specified budgets and timeframes to such persons or bodies as it may deem fit.

3. The CSR Committee shall review the implementation of the CSR Programmes once a quarter and issue necessary directions from time to time to ensure orderly and efficient execution of the CSR Programmes in accordance with this Policy.

4. It shall be the responsibility of the CSR Committee to review the progress of implementation of the approved CSR Programmes carried out during the six month period and keep the Board apprised of the status of implementation of the same.

5. At the end of every financial year, the CSR Committee will submit its report to the Board.

CSR Expenditure

The corpus to be spent by Guavus on CSR shall be 2% of the average net profits for preceding three financial years. CSR expenditure will include all expenditure, direct and indirect, incurred by the Company on CSR Programmes undertaken in accordance with the approved CSR Plan.

Moreover, any surplus arising from any CSR Programmes shall not form part of business profits of the Company and shall be used for CSR. Accordingly, any income arising from CSR Programmes will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.

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