CORPORATE SOCIAL RESPONSIBILITY

We are committed towards achieving a greener & greater India. We follow strict policies to ensure a better way of life for all in various structures of the society namely education, healthcare, environment, climate change and believe in respecting universal human rights.

CORPORATE SOCIAL RESPONSIBILITY (CSR) POLICY

Enabling lives, living and livelihood for a stronger and inclusive India

DAGA GROUP

DAGA TRADING COMPANY PRIVATE LIMITED

Introduction:

Corporate Social Responsibility (hereinafter referred to as CSR) is strongly connected with the principles of Sustainability (i.e., an organization should make decisions based not only on financial factors and business outcomes, but also on the social and environmental consequences). M/s Daga Trading Company Private Limited (hereinafter referred to as the Company) wishes to contribute to harmonious and sustainable development of society and the Earth through its business activities. This Policy sets forth the Company’s goals in complying with all the CSR-related provisions of the Companies Act, 2013.

Objectives of the policy:

To behave ethically and contribute to sustainable development.
To contribute to Society through the Company’s Business.
To comply with the provisions of Companies Act, 2013 and rules made thereunder.
To act with utmost respect for human rights and pursue a high sense of corporate ethics.
To promote social contribution activities as a good corporate citizen in order to make a better society.
To build a bond and sense of harmony with the environment.

To play an effective role in addressing issues such as access to education, health care and livelihood opportunities.

Applicability:

The CSR policy is formulated in accordance with the provisions of section 135 of the Companies Act, 2013 and rules made thereunder and other applicable laws to the Company. Section 135 of the Companies Act, 2013 is applicable to the Company with net worth of INR 500 Crore or more, or a turnover of INR 1000 Crore or more, or a net profit of INR 5 Crore or more during any of the three preceding financial years. Under this section of the Companies Act, 2013, in every financial year, such company must allocate at least 2% of its average net profits made during the three immediately preceding financial years.

Effective Date:

This policy shall be effective from 01-04-2018.

Any modification/amendment in the CSR policy shall be carried out by the Board of Directors of the Company.

Definitions:

“Act” shall mean the Companies Act, 2013, including any modifications, amendments or re-enactments thereof.

“Approved Budget” shall mean the total budget as approved by the Board of Directors.

“CSR Rules” means the Companies (Corporate Social Responsibility Policy) Rules, 2014 as amended from time to time.

“Board” shall mean the Board of Directors of the Company.

“CSR Annual Plan” shall mean the annual plan detailing the CSR expenditure for the relevant year.

“CSR Policy” shall mean the present Corporate Social Responsibility Policy of the Company, which covers the activities to be undertaken by the Company as specified in Schedule VII to the Act and the CSR Expenditure thereon.

“CSR Projects” or “Projects” means Corporate Social Responsibility projects/activities/programs/initiatives, instituted in India, either new or ongoing.

“Financial Year” shall mean the period beginning from 01st April of every year to 31st March of the succeeding year.

“Net Profit” shall mean the net profit as per the Act and Rules based on which the specific percentage for CSR expenditure has to be calculated.

Activities To Be Undertaken:

The Company is committed towards environmental and social safety and protection. In compliance of the Schedule VII of the Companies Act, 2013 and the Company’s Policy any of the below mentioned activities shall be carried out by the Company to contribute towards CSR:

Eradicating hunger, poverty and malnutrition, promoting health care including preventive healthcare and sanitation including contribution to the Swachh 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 centers 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, agroforestry, conservation of natural resources and maintaining quality of soil, air and water and water 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 historic 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, paralympic sports and Olympic sports.

Rural development projects.

Development of area declared as “slum area” by the Government or competent authority.

Disaster management, including relief, rehabilitation and reconstruction activities.

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 caste, tribes, other backward classes, minorities and women.

Contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government.

Slum area development.

CSR Committee:

With Companies (Corporate Social Responsibility Policy) Amendment Rules, 2021, CSR Committee is not required, if the amount to be spent by a company does not exceed fifty lakh rupees. In such cases the Board shall discharge all functions of the CSR Committee.

Allocation For CSR:

The Company shall contribute for CSR activities in every financial year (after the adoption of this Policy) at least two percent (2%) of its average net profit earned during three immediately preceding financial years.

Based on the profits earned the Board of Directors may allocate for CSR activities more than two percent of the net profit earned during three immediately preceding financial years but shall not exceed 5 percent (5%).

In case, if the Company does not fall under Section 135 of the Companies Act, 2013 in any financial year, the Company may not allocate funds for CSR purpose in such financial year.

CSR Expenditure:

The board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the company for the financial year.

Any surplus arising out of the CSR activities shall not form part of the business profit of a company and shall be ploughed back into the same project or shall be transferred to the Unspent CSR Account and spent in pursuance of CSR policy and annual action plan of the company or transfer such surplus amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.

Where a company spends an amount in excess of requirement provided under sub-section (5) of section 135, such excess amount may be set off against the requirement to spend under sub-section (5) of section 135 up to immediate succeeding three financial years subject to the conditions that – (i) the excess amount available for set off shall not include the surplus arising out of the CSR activities, if any, in pursuance of sub-rule (2) of this rule. (ii) The Board of the company shall pass a resolution to that effect.

The company shall ensure that the administrative overheads shall not exceed 5% (five percent) of the total CSR expenditure of the company for the financial year. Further, the expenditure for impact assessment, where impact assessment is mandatory, shall not exceed 5% (five percent) of the total CSR expenditure or Rs. 50,00,000 (Indian Rupees Fifty lakh), whichever is less, for the financial year in which such impact assessment is undertaken.

In case the unspent amount pertains to an ongoing project, such amount shall be transferred to the Unspent CSR Account of company within 30 (thirty) days from the end of the financial year, further such amount remaining unspent for a period of 3 (three) years, shall be transferred to the funds specific in Schedule VII within 30 (thirty) days from the end of the third financial year, and; in case the unspent amount does not pertain to an ongoing project, such amount shall be transferred to the funds specific in Schedule VII within 6 (six) months from the end of the financial year.

Identification Of Activities/Projects:

Out of approved CSR activities, the Board shall decide which activity/project should be given priority for the respective financial year. While arriving at the decision of the activity to be undertaken for the respective year, the Board shall analyze the basic need of the community/ area in which the Organisation operates or at the place where its registered office is situated. The Board shall record its findings and prioritize the CSR activities.

Implementation Process

After prioritizing the activity the Board shall finalize the detailed implementation project/programme, including planning for expenses against the total budget allocated for CSR activities.

Management Commitment

Our Board of Directors, our Management and all of our employees subscribe to the philosophy of compassionate care. We believe and act on an ethos of generosity and compassion, characterized by a willingness to build a society that works for everyone. This is the cornerstone of our CSR policy. Our Corporate Social Responsibility policy conforms to the relevant section of the Corporate Social Responsibility, Rules made under Companies Act, 2013 and amendment(s) to be made thereto in future.

CSR Monitoring:

The Board will undertake a routine monitoring and analysis of the CSR projects through various steps including impact assessment, progress of the project vis-à-vis the prescribed timelines / budget etc. The monitoring mechanism may include visits, meetings, and progress / status reports etc.

CSR Reporting:

The Board’s Report of a company covered under these rules pertaining to any financial year shall include an annual report on CSR containing particulars specified or in any other manner as specified under the Companies Act, 2013.

The Board will annually report on the CSR projects as a part of the Director’s report.

Review/Amendment:

The Board may amend, abrogate, modify or revise any or all clauses of this policy, on recommendation of the CSR Committee and in accordance with the Act.

NORTHERN STEEL AND GENERAL MILLS PRIVATE LIMITED

R/o: 6A, FIRST FLOOR, HIMALAYA HOUSE, 23 KASTURBA GANDHI MARG

DELHI-110001

About the Company:

NORTHERN STEEL AND GENERAL MILLS PRIVATE LIMITED is engaged in the business of sale, purchase, import, export, manufacture of all types of iron and steel and other related products, by-products and allied goods and to provide all types of services relating to these products.

The Company is incorporated on 20/07/2009.

Purpose:

The Corporate Social Responsibility Policy (“CSR Policy”) of M/s Northern Steel and General Mills Private Limited has been formulated by the Board of Directors of the company and approved at its meeting held on 01-04-2016.

This policy aims to contribute towards sustainable development of society and environment to make planet a better place for future generations. The philosophy of CSR is imbibed in our business activities and social initiatives taken in the area of social welfare, health and education sector etc.

Applicability:

Effective Date

This policy shall be effective from the 01-04-2018.

Any modification/amendment in the CSR policy shall be carried out by the Board of Directors of the Company.

Definitions

“Act” shall mean the Companies Act, 2013, including any modifications, amendments or re-enactments thereof.
“Approved Budget” shall mean the total budget as approved by the Board of Directors.
“CSR Rules” means the Companies (Corporate Social Responsibility Policy) Rules, 2014 as amended from time to time.
“Board” shall mean the Board of Directors of the Company.
“CSR Annual Plan” shall mean the annual plan detailing the CSR expenditure for the relevant year.
“CSR Policy” shall mean the present Corporate Social Responsibility Policy of the Company, which covers the activities to be undertaken by the Company as specified in Schedule VII to the Act and the CSR Expenditure thereon.
“CSR Projects” or “Projects” means Corporate Social Responsibility projects/activities/programs/initiatives, instituted in India, either new or ongoing.
“Financial Year” shall mean the period beginning from 01st April of every year to 31st March of the succeeding year.
“Net Profit” shall mean the net profit as per the Act and Rules based on which the specific percentage for CSR expenditure has to be calculated.

Scope

As a responsible corporate citizen, the company is committed to sustainable development and inclusive growth and has been focusing on issues relating to social welfare, health and education sector etc. Whilst the Company will continue to support activities in accordance with schedule VII of the Act, as listed below, the company will focus its efforts on key areas as mentioned above. The specific projects and activities under these pillars are being worked on and more specifies will be finalized in due course. In terms of the CSR rules issued by the MCA the Company will be focusing on undertaking the project/ programs/ activities listed below, as specified in Schedule VII to the Act excluding activities undertaken in pursuance of normal course of business of a company:

Eradicating hunger, poverty and malnutrition, promoting health care including preventive healthcare and sanitation including contribution to the Swachh 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, agroforestry, conservation of natural resources and maintaining quality of soil, air and water and water 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 historic 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, paralympic sports and Olympic sports.
Rural development projects.
Development of area declared as “slum area” by the Government or competent authority.
Disaster management, including relief, rehabilitation and reconstruction activities.
Contribution to 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 schedule caste, tribes, other backward classes, minorities and women.
Contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government.

CSR committee of the Board

With Companies (Corporate Social Responsibility Policy) Amendment Rules, 2021, CSR Committee is not required, if amount to be spent by a company does not exceed fifty lakh rupees. In such cases Board shall discharge all functions of CSR Committee.

Responsibilities of Board

Formulate CSR Policy.
Recommend CSR activities as stated under Schedule VII of the Act.
Approve to undertake CSR activities in collaboration with other Companies/ firms/ NGOs etc. and to separately report the same in accordance with the CSR Rules.
Recommend the CSR Budget.
Spend the allocated CSR amount on the CSR activities in accordance with the Act and the CSR Rules.
Create transparent monitoring mechanism for implementation of CSR activities in India.
Submit the Reports to the Board in respect of the CSR activities undertaken by the Company.
Monitor CSR Policy from time to time.

CSR Expenditure

(1) The board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the company for the financial year.

(2) Any surplus arising out of the CSR activities shall not form part of the business profit of a company and shall be ploughed back into the same project or shall be transferred to the Unspent CSR Account and spent in pursuance of CSR policy and annual action plan of the company or transfer such surplus amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.

(3) Where a company spends an amount in excess of requirement provided under sub-section (5) of section 135, such excess amount may be set off against the requirement to spend under sub-section (5) of section 135 up to immediate succeeding three financial years subject to the conditions that – (i) the excess amount available for set off shall not include the surplus arising out of the CSR activities, if any, in pursuance of sub-rule (2) of this rule. (ii) The Board of the company shall pass a resolution to that effect.

(4) The company shall ensure that the administrative overheads shall not exceed 5% (five percent) of the total CSR expenditure of company for the financial year. Further, the expenditure for impact assessment, where impact assessment is mandatory, shall not exceed 5% (five percent) of the total CSR expenditure or Rs. 50,00,000 (Indian Rupees Fifty lakh), whichever is less, for the financial year in which such impact assessment is undertaken.

(5) In case the unspent amount pertains to an ongoing project, such amount shall be transferred to the Unspent CSR Account of company within 30 (thirty) days from the end of the financial year, further such amount remaining unspent for a period of 3 (three) years, shall be transferred to the funds specific in Schedule VII within 30 (thirty) days from the end of the third financial year, and; in case the unspent amount does not pertain to an ongoing project, such amount shall be transferred to the funds specific in Schedule VII within 6 (six) months from the end of the financial year.

Approval Process

A list of CSR projects/programs which the Company plans to undertake during the implementation year will be laid down and approved by the Board at the beginning of each year, specifying modalities of execution in the areas /sectors chosen and implementation schedules for the same. Once a project is identified, the final project proposal will be discussed by the Board.
The Board will review the project application and will have the right to approve/reject the proposal or ask for more information/amendments in the proposal.
Appropriate documentation and amendments of the CSR Policy, annual CSR activities, reports on execution by CSR partner(s) and expenditures will be undertaken on a regular basis.

CSR Implementation

(1) The Board shall ensure that the CSR activities are undertaken by the company itself or through – (a) a company established under section 8 of the Act, or a registered public trust or a registered society, registered under section 12A and 80 G of the Income Tax Act, 1961 (43 of 1961), established by the company, either singly or along with any other company, or (b) a company established under section 8 of the Act or a registered trust or a registered society, established by the Central Government or State Government; or (c) any entity established under an Act of Parliament or a State legislature; or (d) a company established under section 8 of the Act, or a registered public trust or a registered society, registered under section 12A and 80G of the Income Tax Act, 1961, and having an established track record of at least three years in undertaking similar activities.

(2) In case of ongoing project, the Board of a Company shall monitor the implementation of the project with reference to the approved timelines and year-wise allocation and shall be competent to make modifications, if any, for smooth implementation of the project within the overall permissible time period”.

CSR Monitoring

(i) The Board will undertake a routine monitoring and analysis of the CSR projects through various steps including impact assessment, progress of the project vis-à-vis the prescribed timelines / budget etc. The monitoring mechanism may include visits, meetings, and progress / status reports etc.

CSR Reporting

(1) The Board’s Report of a company covered under these rules pertaining to any financial year shall include an annual report on CSR containing particulars specified or in any other manner as specified under the Companies Act, 2013.

(2) The Board will annually report on the CSR projects as a part of the Director’s report.

Review/Amendment

The Board may amend, abrogate, modify or revise any or all clauses of this policy, on recommendation of the CSR Committee and in accordance with the Act.