1. CSR Policy: Objective

1.1 Objective

The Objective of the policy is to be define VKC's Corporate Social Responsibility approach in alignment with Section 135 of the Companies Act,2013 read with applicable rules.

VKC's endeavours to reach out to underprivileged and underserved communities to address fundamental challenges of our society. We shall focus on the following areas which are aligned to Schedule VII to the Companies Act, 2013:

• Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation and making available safe drinking water;
• Promoting education, including special education and employment enhancing vocation skills especially among children, women, and elderly and other livelihood enhancement projects;
• Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; is setting up old age homes, day care centers and such other facilities.
• Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro forestry, conservation of natural resources and maintaining quality of soil, air and water;
• 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 art and handicrafts;
• Measures for the benefit of armed forces veterans, war widows and their dependents;
• Training to promote rural sports, nationally recognized sports, Paralympics and Olympic sports;
• Contribution to the Prime Minister's National Relief Fund or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women;
• Contributions or funds provided to technology incubators located within academic institutions, which are approved by the central govt.
• Rural development projects;
• Any other measures with the approval of Board of Directors on the recommendation of CSR Committee subject to the provisions of Section 135 of Companies Act, 2013 and rules made there-under.

2. Undertaking CSR Activities

VKC's will undertake its CSR Activities, approved by the CSR Committee, through such entity/organization as approved by the CSR Committee.

The Surplus arising out of the CSR Activities, projects or programs shall not form part of the business profit of the Company.

3. CSR Policy Governance Structure & Approach

3.1 Board Of Directors

In line with the provisions of Section 135 of the Act, VKC's Board of Directors will be responsible for the following:

• Constitute a CSR committee and approve the CSR policy;
• Make sure the company spends, in every financial year, at least 2% of its average net profit during the three preceding financial years, in pursuance of this policy
• Approve the CSR action plan and budget as proposed by the CSR committee in accordance with Schedule VII of the Companies Act, 2013
• Make disclosures in the Board report as per clause (o) of sub-section (3) of section 134 including particulars specified in Annexures to the CSR rules. If the company fails to spend the amount, reasons for not spending to be specified in the above report.

3.2 CSR Constitution

Pursuant to the provisions of Section 135 of the Act, the Board of Directors shall constitute the Corporate Social Responsibility (CSR) Committee. The Members of CSR shall be appointed by the Board of Directors of the Company which must consist of two or more Directors. Accordingly, the constitution of CSR Committee formed by VKC NUTS are as follows:

Sr. No.	Name of Member	Designation in Committee	Designation in VKC Nuts
1	Vijay Kumar Jain	Chairman	Director
2	Gagan Jain	Member	Director
3	Gunjan Jain	Member	Director

3.3 Roles and Powers of The Committee

• Formulate CSR policy and seek approval from the Board of Directors of the company. Review the policy on a yearly basis.
• Formulate and share the CSR action plan with budget for the year with the Board of Directors and seek approval. Implement the activities either through the Implementation Partner or directly through its own team.
• Spend the allocated amount on CSR activities once approved by the Board of Directors and create a transparent monitoring mechanism of CSR initiatives.
• Submit periodic reports to the Board for the activities undertaken.

4. CSR Budget

• The Board shall ensure that in each financial year, VKC spends at least 2 per cent of the average net profit made during the three immediately preceding financial years.
• The computation of average net profits will be carried out in accordance with the provisions of Section 198 of the Companies Act, 2013.
• The unutilized CSR budget from the 2 per cent of the average net profit will be put back into CSR activities of the succeeding year.
• The surplus arising, if any, out of the CSR projects or programs or activities shall not form part of the business profit of a company.

5. Measurement of CSR Performance

Our goal is to maintain high quality standards on CSR reporting. In order to meet this goal, we will institutionalisea transparent measurement system. This will help us measure our performance against the set key performance indicators (KPIs) and best practices. The measurement process will also help set out future action plans.

6. Disclosure: Publishing a CSR report

Reporting will constitute an integral part of our CSR initiatives, as we at VKC, remain committed to being transparent and accountable to our stakeholders. The objective of reporting is not only to update our stakeholders, but also to receive their feedback, and incorporate their suggestions into our future CSR strategies.

As per the CSR Rules, the contents of the CSR Policy shall be included in the Directors' Report and the same shall be displayed on the Company's website.