2. VISION STATEMENT, OBJECTIVE AND APPLICABILITY

Company CSR Policy intends to:

• Strive for economic development that positively impacts the society at large with minimal resource footprint.
• Embrace responsibility for the Company’s actions and encourage a positive impact through its activities on hunger, poverty, malnutrition, education, environment, communities, stakeholders and the society.
• Demonstrate commitment to the common good through responsible business practices and good governance

3. DEFINITIONS

• “Board” means the board of Directors of the Company and wherever the context requires, shall signify the Company acting through its Board.
• “Company” means Girnar Insurance Brokers Private Limited.
• “Companies Act” means the Companies Act, 2013 read with the rules made thereunder and includes any statutory modifications or reenactments thereof.
• “CSR Activities” means such programs and projects as may be approved by the Board in terms of this CSR Policy.
• “CSR Committee” means a committee constituted by the Board of Directors in terms of Section 135 of the Act and the CSR Rules.
• “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 herein and in Schedule VII to the Act and the CSR Expenditure thereon.
• “CSR Rules” means the Companies (Corporate Social Responsibility Policy) Rules, 2014 including any re-enactment, modifications or amendments thereof.
• “CSR Expenditure” means the amount recommended by the CSR Committee to be incurred on the CSR Activities in India in terms of the Act and the CSR Rules as approved by the Board from time to time.
• “Director” means a member of the Board of the Company.
• “Implementing Agency” means an implementing agency as defined under paragraph 5 (c).
• “Implementation Group” means an Implementation Group as defined under paragraph 5(b).
• “Society” means a society registered under the Societies Registration Act, 1860 or any other applicable law in India.
• “Trust” means a trust registered under the Indian Trusts Act, 1882 or any other applicable law in India.

Words and expressions used and not defined in the Policy shall have the same meanings respectively assigned to them in the Companies Act and/or CSR Rules.

4. FOCUS AREA

Company seeks to contribution to the society through its distinct value proposition that meets the needs of millions of people, enhancing their lives through healthcare, improving quality of living by providing education and enabling livelihoods by creating employment opportunities through the following:

• For the business - value created for the society through business (including employment generation, market growth, creating opportunities etc.)
• By the business - value created through CSR initiatives across different operating facilities with appropriate linkages to local communities in which they operate.
• Beyond business - value created through interventions for the communities in diverse geographies across India.

In accordance with the requirements under the Companies Act, 2013, Company’s CSR activities, amongst others, will focus on:

• Hunger, poverty, malnutrition and health: Eradicating extreme hunger, poverty and malnutrition, promoting preventive healthcare and sanitation and making available safe drinking water.
• Education: Promoting education, including special education and employment-enhancing vocational skills especially among children, women, elderly and the differently abled and livelihood enhancement projects, monetary contributions to academic institutions for establishing endowment funds, chairs, laboratories, etc., with the objective of assisting students in their studies.
• Gender equality and empowerment of women: Promoting gender equality and empowering women, setting up homes, hostels and day care centers for women and orphans, setting up old age homes and such other facilities for senior citizens and adopting measures for reducing inequalities faced by socially and economically backward groups.
• Environmental sustainability: Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro-forestry, conservation of natural resources and maintaining the quality of soil, air and water.

However, the Company may, subject to the approval of the CSR Committee, undertake any CSR project specified in Schedule VII of the Companies Act, 2013 from time to time.

5. IMPLEMENTATION OF CSR ACTIVITIES

• a. The Board shall be responsible for implementing the mandate of the CSR Policy and shall ensure that the CSR Activities are carried out in accordance with the CSR Policy read with the Act and CSR Rules.
• b. The Board shall constitute an implementation group for the purposes of implementation of the CSR Activities approved by the Board from time to time (the “Implementation Group”) and submitting report of the progress on the CSR Activities to the Board as well as the CSR Committee.
• c. Mode of Implementation: The CSR Activities may be undertaken by the Company directly through the Implementation Group with the prior approval of the Board:
  • Through a Trust, or a Society or a company established by the Company or its holding or subsidiary or associate company under Section 8 of the Act or otherwise;
  • Through a Trust, or a Society or a company established under section 8 of the Act with a established track record of three (3) years in undertaking similar programs or projects;
  • In collaboration with other companies or NGOs
  • In collaboration with any Industry Body coordinating such activities
  • Direct contribution/ implementation of any project approved by CSR committee/ Board
  • Contribution to Prime Minister Relief Fund or any other fund as may be notified by Govt.

(the entities referred to under sub-clause (i) and (ii) above, are hereinafter referred to as “Implementing Agencies” ).

6. CSR Committee & its Responsibilities

The Board of Directors of the Company shall constitute / re-constitute the CSR Committee from time to time in compliance with statutory requirements. The CSR Committee shall comprise of a minimum of two Directors. The responsibilities of the Committee will be as follows:

• To formulate and recommend to the Board, a CSR policy that shall indicate the activities to be undertaken by the Company as per the Companies Act, 2013;
• To review and recommend the amount of expenditure to be incurred on the activities to be undertaken by the Company.
• To institute a transparent monitoring mechanism for the implementation of the CSR projects, programs and activities undertaken by the Company;
• To monitor the CSR policy of the Company from time to time;
• Any other matter as the CSR Committee may deem appropriate after approval of the Board of Directors or as may be directed by the Board of Directors from time to time.

7. Selection and Implementation of CSR Activities and Projects

The CSR Committee shall consider CSR proposals from the Company or any other eligible entity/ foundation. In order to be considered by the CSR Committee, such proposals must inter-alia contain details of projects/ programs to be undertaken, proposed amount, timelines and a confirmation that such projects/ programs are eligible under the Companies Act, 2013 and rules made thereunder.

The CSR Committee will evaluate the projects/ programs and may, at its sole discretion, approve certain projects/ programs for implementation. While approving projects / programs, the Committee shall ensure that those are covered under the ambit of activities listed in Clause 3 above.

The CSR Committee may also decide to contribute towards the Corpus Fund, as permitted under the law.

8. SURPLUS

The surplus arising out of the CSR projects or programs or activities shall not form part of the business profit of a company.

9. CSR BUDGET

The Board shall approve overall limits for CSR Activities to be undertaken by the Company. Within the overall limits approved by the Board, the CSR Committee shall approve individual projects/programs including contributions towards the Corpus Fund, ensuring all expenditures are in accordance with applicable laws.

10. LOCATION OF CSR EFFORTS

All CSR projects/programs under this policy shall be undertaken in India. The CSR Committee shall decide on locations for implementation of the CSR projects/programs.

11. EMPLOYEE VOLUNTEERISM

The Company provides opportunities to its employees to participate in projects and programs undertaken in the social development sector. Participation in CSR initiatives by employees is voluntary and employees may choose activities they wish to participate in. The Company also encourages family and friends of the employees to participate in CSR activities. Apart from this, employees are encouraged to identify the social development area, and the CSR Committee can take the recommendations ahead as per the process and in consonance with statutory norms.

12. MONITORING AND DISCLOSURE

• The CSR Committee shall endeavor to:

Devise a robust monitoring mechanism to ensure that the CSR projects/ programs are undertaken effectively in accordance with the approval granted and are fully in compliance with applicable laws, rules, and regulations. Monitoring of CSR activities could be done through:

• Ø Periodic third-party assessment of key projects
• Ø Impact assessment with key indicators in our areas of operations
• Ø Regular review by CSR committee

• Ensure that appropriate disclosures are made in the Company’s annual reports.

13. VALIDITY OF CSR POLICY

This policy is effective from 20 March 2025 and may be amended by the Board as required from time to time.

14. AMENDMENTS

The CSR committee will review the Policy from time to time based on the changing needs and aspirations of the target beneficiaries and recommend suitable modifications/ amendments to the Board of Directors for their approval.

15. GENERAL

Any or all provisions of this CSR Policy would be subject to revision/amendment in accordance with the guidelines on the subject as may be issued by the Government of India, from time to time. Any amendment in the list of CSR activities under Schedule VII of the Companies Act, 2013 shall apply automatically to this policy without any further amendment to the policy.

16. INFORMATION DISSEMINATION

The Company’s continuous activities and information relating to the same is disseminated on its website, www.insurancedekho.com, in its Annual Report under ‘Corporate Social Responsibility’.