CORPORATE SOCIAL RESPONSIBILITY POLICY

The Board of Directors (the “Board”) of DCM Engineering Limited (the ‘Company’ or ‘DCM Engineering’) acting upon the recommendation of its Corporate Social Responsibility Committee (‘CSR Committee’), has adopted the following policy with regard to the Company’s Social Responsibility:

SHORT TITLE & APPLICABILITY

This policy, which encompasses Company’s philosophy for delineating its responsibility as a corporate citizen and lays down the guidelines and mechanism for undertaking socially useful programmes for welfare & sustainable development of the community at large, is termed as the “DCM Engineering Limited CSR Policy”. This policy shall apply to all CSR initiatives and activities taken up preferably in the local area and around various workplace(s)/ factory(ies)/project site(s)and location(s) of Company for spending the amount earmarked for CSR.

CSR VISION STATEMENT

In alignment with the vision of the Company, DCM Engineering, through its CSR initiatives, strives to create value in the society and in the community in which it operates, through its services, conduct & initiatives, so as to promote sustained growth for the society and community.

OBJECTIVE

The main objective of the DCM Engineering Limited CSR Policy is to establish and lay down the basic principles and the general framework of action for Company to undertake and fulfill its corporate social responsibility.

CSR COMMITTEE

In compliance with Section 135 of the Companies Act, 2013 and the relevant Rules, the Board of Directors has constituted a CSR committee of the Board.

LIST OF ACTIVITIES/PROJECTS

The Company may undertake any one or more of the following activities, as mentioned in the Schedule VII of the Companies Act, 2013 and Rules thereunder, as may be recommended by the CSR Committee of the Board and as approved by the Board of Directors from time to time depending on the resources and opportunities available:

• i. 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 promotion of sanitation and making available safe drinking water;
• ii. Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects;
• iii. 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;
• iv. 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 including contribution to the clean Ganga Fund setup by the Central Government for rejuvenation of river Ganga;
• v. 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 arts and handicrafts:
• vi. Measures for the benefit of armed forces veterans, war widows and their dependents;
• vi. Training to promote rural sports, nationally recognised sports, Paralympic and Olympic sports;
• vii. 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;
• ix. Contribution or funds provided to technology incubators located within academic institution which are approved by the Central Government;
• x. Rural development projects;
• xi. Slum area development;
  Explanation : For the purpose of this team, the term ‘slum area’ shall mean any area declared as such by Central/State Govt. Or any other competent authority under any law from time to time being in force
• xii. Any other activities, which may be included Schedule VII from time to time.

QUANTUM OF AMOUNT TO BE SPENT ON CSR ACTIVITIES

• i. The Company shall strive to spend in every financial year at least 2% (two percent) of the average net profits of the Company made during the three immediately preceding financial years. The average net profits shall be calculated in accordance with section 198 of the Companies Act, 2013.
• ii. Any surplus arising and/or additional revenue generated out of CSR Activities undertaken by the Company shall not form part of the business profit of the Company and same shall be spent for undertaking CSR Activities only.
• iii. Any amount remained upspent, if any, or spent in excess of the mandatory requirement in any financial year, will be adjusted in the subsequent year with the approval of the CSR Committee.

EXCLUSIONS

• i. The activities undertaken by Company in pursuance of its normal course of business shall not be considered as CSR activities.
• ii. Any Contribution of any amount directly or indirectly to any political party under Section 182 of the Act, by Company shall not be considered as CSR activity.
• iii. The CSR projects or programs or activities that benefit only the employees of Company and their families shall not be considered as CSR activities.
• iv. CSR projects or programs or activities undertaken outside India shall not be considered as CSR activities.

IMPLEMENTATION

Projects will be undertaken either-in-house or through trust or Company formed by the Company for this purpose or in partnership with the recognized NGO’s, trusts or other accredited agencies.

POWERS FOR APPROVAL

CSR programmes as may be identified will be required to be put up to the CSR Committee of the Board from time to time.

MONITORING OF PROJECTS

All projects will be assessed under an agreed strategy and monitored & measured against the targets and budgets periodically. Wherever required, projects will be reoriented depending upon the need.

CORPUS AND BUDGET

The Board shall ensure that the Company spends or earmarks at least 2% of its average net profit during the preceding three financial years arrived at as per Section 198 of the Companies Act, 2013 and any income arising therefrom.

The Company’s CSR Policy conforms to the Corporate Social responsibility as stipulated under the Companies Act, 2013 and the Rules framed thereunder. This Policy is subject to review by the CSR Committee/Board of Directors, as and when need arises or is required.

GENERAL

In case of any doubt with regard to any provision of the CSR Policy and also in respect of matters not covered herein, a reference to be made to CSR Committee. In all such matters, the interpretation & decision of the CSR Committee shall be final.

Any or all provisions of the CSR Policy would be subject to revision/amendment in accordance with the guidelines on the subject as may be issued by the Government, from time to time.

Words and expressions used and not defined in this Policy shall have the same meanings respectively assigned to them in the Companies Act, 2013 and Rules issued there under.

DCM Engineering reserves the right to modify, add, or amend CSR Policy and any of these Policy Rules/Guidelines.