CORPORATE SOCIAL RESPONSIBILITY (CSR) POLICY

PREAMBLE

As the Company’s vision and mission is to serve society at large by providing affordable and high quality medicines to the society at large with the more emphasis on providing medicines to the rural areas of India. In the present scenario of challenges in Economic Growth of Nation, Government alone will not be able to get success in improving the lives of the people of the Nation and attaining Sustainable Development Goals. Corporate and Private sector can contribute in Economic Development by applying their creativity, innovation and resources. In furtherance of Company’s mission and vision to serve the people of its Nation, Company has adopted CSR as a strategic tool to serve the society at large for Economic Development and Sustainable Growth. We believe in the trusteeship concept. We believe, we will be a more satisfied corporate when we operate according to the highest ethical standards, address unmet social needs, function with compassion and promote the wellbeing of citizens of this country, their communities and the entire environment. We strongly believe that a responsible corporate should go beyond the Statutory compliances and put something back into the society, which has given so much to the corporate. This entails transcending business interests and doing something for the people who are grappling with the "quality of life" challenges and working towards making a meaningful difference to them.

OUR CSR VISION

"To actively contribute to the social and economic development of the communities in which we operate. In so doing build a better, sustainable way of life for the weaker sections of society and raise the country's human development index".

So far Grecian has actively contributed in the areas of promoting education, sanitation, rural development, healthcare and preventive healthcare, promotion of sports. Grecian’s intiatives have not just transformed the lives of the individuals but society at large.

SCOPE AND COVERGAE

This Policy for CSR applies to formulation, implementation, monitoring, evaluation, documentation, reporting of CSR and sustainability activities taken up by Company anywhere in India. This policy does not cover activities undertaken by the company in its normal course of business and activities exclusively for the benefit of its employees or their family. This policy is intended to be in conformity with the provisions of Companies Act, 2013 and the rules prescribed there under.

CSR COMMITTEE

Keeping in line with Section 135 of the Companies Act, 2013 (hereinafter referred to as ‘the Act’), the Board of Directors of the Company has formed a Corporate Social Responsibility Committee (hereinafter referred to as the ‘CSR Committee’), which includes two executive directors and one independent director. The Board of Directors reserves the right to re-constitute the CSR Committee at any time if warranted by prevailing situations.

The committee inter alia other prescribed operations, shall carry out the following functions:

• formulating the CSR policy in compliance to Section 135 of the Companies Act, 2013
• identifying activities and CSR Projects and programs to be undertaken in areas or subjects as per Schedule VII of the Companies Act 2013.
• recommending to Board the CSR expenditure to be incurred
• recommending to Board, modifications to the CSR policy as and when required
• regularly monitoring the implementation of the CSR policy
• Formulating and Recommending to the Board an Annual Action Plan on CSR.

CSR PROJECTS, PROGRAMS AND ACTIVITIES

In accordance with the specified activities under the Companies Act, 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014, and Schedule VII of the Act, the thrust areas identified under the CSR activities of the Company are as under:

• Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water.
• Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
• Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups.
• 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 4[including contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga.
• 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, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
• Training to promote rural sports, nationally recognized sports, Paralympics sports and Olympic sports
• Contribution to the prime minister’s national relief fund or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the central govt. for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women;
• (a) Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and
  
  (b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense Research and Development Organisation (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).
• Rural development projects
• Slum area development.
  

  For the purposes of this item, the term `slum area' shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force.

• Disaster management, including relief, rehabilitation and reconstruction activities.
• Such other activities as may be recognized by the Committee/Board or as may be required/ permissible under prevailing law(s).”

CSR EXPENDITURE

The Company shall spend in every financial year, at least two percent of the average net profits of the Company made during the three immediately preceding financial years on CSR projects in accordance with the policy. Surplus, if any, arising out of the CSR projects, programs or activities shall not form a part of the business profits of the Company and will be ploughed back into the CSR activities. Surplus, if any, out of CSR activity is prohibited to form part of business profits and has to used back for CSR purpose only or transfer such surplus to fund specified in Schedule VII within 6 months from end of financial year.

CAPACITY BUILDING

The Company may build CSR capacities of its own personnel by training its staff to think strategically about how and where the money is being spent, as well as how to effectively manage other organizations through which or in collaboration with which the Company undertakes/may undertake CSR activities. CSR expenditure including salaries of personnel (if any) who are engaged in CSR activities, spent on capacity building for the CSR team in the Company who have been especially entrusted the assignment to execute CSR projects and expenses incurred on their training etc. cannot be more than the limit imposed by the Companies Act, 2013.

MONITORING AND REVIEW MECHANISM

The CSR Committee shall monitor the implementation of the CSR Policy through periodic reviews of the activities undertaken by the Company under this policy. In compliance with the Act and to ensure funds spent on CSR programs are creating the desired impact on the ground, a comprehensive Monitoring and Reporting framework will be put in place, wherein the expenditure heads, geography covered, periodicity and distribution of expenditure over various heads will be monitored on regular basis.

GUIDING PRINCIPLES FOR SELECTION, IMPLEMENTATION AND MONITORING OF ACTIVITIES

The Company shall follow the following guiding principles for selection, implementation and monitoring of CSR Activities as well as formulation of the Annual Action Plan:

a. Guiding principles for selection of CSR initiatives:-

• CSR Committee shall recommend to the Board, the activities to be undertaken by the Company.
• The power to approve CSR activities shall vest with the Board of Directors of Grecian Healthcare Limited
• All activities will be identified in an objective manner keeping in mind the ultimate beneficiaries and gauging their basic needs. Consultation with the locals like village panchayats and influential people of the area will also be resorted to, wherever necessary to sense the most critical needs of the area concerned.
• CSR initiatives to supplementing the Central/State Govt. Schemes
• Preference shall be given to local area where the Company has its operations or has its offices or branches;
• The Company shall undertake CSR Activities only in pursuance of its CSR policy and which are listed in Schedule VII of the Companies Act, 2013 as may be amended from time to time. The CSR Committee, from time to time shall choose activities out of the list to be undertaken under this policy
• CSR Projects or programs or activities undertaken in India only shall be accounted as CSR Expenditure
• The Company shall not discriminate on any grounds whatsoever, including race, gender, age, ethnicity, caste, religion, domicile in implementation of its CSR activities but it may focus its CSR Activities to benefit the economically or socially weaker, or marginalized sections, of the society.
• The Company shall endeavor to maintain transparency in selection, implementation, monitoring and reporting of CSR Activities.

b. Guiding principles for implementation of CSR initiatives:-

• The Company shall ensure that all CSR Activities undertaken directly or indirectly, meet applicable standards of quality followed by Company and/or are the market standard for such activities.
• The activities which can be implemented by Grecian either directly or by engaging Contractors for infrastructural development shall be taken up by Grecian
• The activities which cannot be taken up directly by Grecian because of its nature, size and other limitations, shall be considered for implementation through implementing agencies, provided that the implementing agency conforms to the eligibility criteria as specified in the Companies (Corporate Social Responsibility Policy) Rules and have relevant experience and good credentials. Grecian may also collaborate with internationally/nationally reputed Foundations / Organizations.
• The Company shall ensure that all the CSR Activities are implemented as per the Annual Action Plan approved by the Board.

C. Guiding principles for monitoring of CSR initiatives:-

• Monitoring of CSR projects shall go concurrently with implementation, to assess if the progress is on expected lines and as per budgeted
• Like implementation, monitoring too shall be done in project mode with continuous feedback mechanism, for mid-course correction in implementation, whenever required
• Monitoring shall be performed by CSR Committee, which can designate a team of Grecian officials for this task to help mid-course correction, if required.
• In compliance with the Act and to ensure that funds spent on CSR programs are creating the desired impact on the ground, a comprehensive Monitoring and Reporting framework will be put in place, wherein the expenditure heads, geography covered, periodicity and distribution of expenditure over various heads will be monitored on regular basis.
• Any surplus arising out of the CSR activities shall not form part of the business profit of a company

d. Guiding principles for formulation of the Annual Action Plan

Every year, the CSR Committee of the Company shall formulate and recommend to the Board an Annual Action Plan in pursuance of its CSR policy, which shall include the following, namely: -

• the list of CSR projects or programs that are approved to be undertaken in areas or subjects specified in Schedule VII of the Act;
• the manner of execution of such projects or programs as specified in sub-rule (1) of rule 4;
• the modalities of utilization of funds and implementation schedules for the projects or programs;
• monitoring and reporting mechanism for the projects or programs; and
• details of need and impact assessment, if any, for the projects undertaken by the company: Provided that Board may alter such plan at any time during the financial year, as per the recommendation of its CSR Committee, based on the reasonable justification to that effect.

The contents of the CSR policy as amended from time to time shall be disclosed in the Board’s Report and shall also be placed on the company’s websit: www.grecian.in.