Corporate Social Responsibility

The key purpose of this Policy is to :

• 1. Outline the development areas in which the Company shall get involved in.
• 2. Define governance structure for CSR management within the Company.
• 3. Serve as a guiding document aiding in identification, execution and monitoring the CSR projects.
• 4. Describe the treatment of surpluses from CSR activities.
• 5. Define the approach and direction given by the Board of the Company, taking into account the recommendations of the CSR Committee.
• 6. Provide guiding principles for selection, implementation and monitoring of activities.
• 7. Formulate an Annual Action Plan every year as per applicable rules.

We believe to drive our CSR policy with the same values which directs Alutech Packaging Pvt. Ltd. Hence, this CSR Policy absorbs Alutech Packaging Pvt. Ltd. core values and is aligned in the following manner to its CSR strategy :

• 1. Being Accountable for what we do : Alutech Packaging Pvt. Ltd. considers itself accountable for contributing back in a meaningful way to the society / Nation.
• 2. Embrace Diversity : Alutech Packaging Pvt. Ltd. believes in embracing diverse views and opinions which lead to a better solution. Accordingly, for execution of its CSR objectives Alutech Packaging Pvt. Ltd. plans to partner, where necessary, with NGOs / other charitable organizations to meet the CSR objectives.
• 3. Collaborate to Win : Collaborating with other NGOs / charitable organizations, with footprint / expertise in areas selected, is a key aspect of Alutech Packaging Pvt. Ltd.’s strategy to make a positive impact in its CSR activities.

CSR Policy is applicable to Alutech Packaging Pvt. Ltd. Solutions Private Limited and its Indian subsidiaries (collectively referred to as “Alutech Packaging Pvt. Ltd.”) which are mandated with the CSR expenditure obligations as per Section 135 of the Companies Act, 2013 (‘the Act’) read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended from time to time.

This Policy applies to all CSR projects that will be undertaken by Alutech Packaging Pvt. Ltd. and shall fulfil all the requirements of Section 135 of the Companies Act, 2013 and rules made thereunder. Alutech Packaging Pvt. Ltd. shall ensure all these activities are over and above the normal course of business and are in line with Schedule VII of the Companies Act, 2013. This Policy will be periodically reviewed and updated in line with the relevant codes of legislation and best practices that can be adopted by Alutech Packaging Pvt. Ltd..

Alutech Packaging Pvt. Ltd. has broadly selected four areas of focus under its CSR activities, as under :

1.) Eradicating Hunger, Poverty

We have started a Project named “Help for Hunger”, due to which needy people got food. We started this project at COVID-19-first wave, at that time we distributed many food items to the people, try to help those needy people who are leaving the City to reach to their home. Main area of this project is to feed elders, children’s and helpless women’s.

2.) Medical and other Welfare

We have started another project named “ Health is Wealth”, In continuation of that we Provide medical relief and rehabilitation to communities who either don’t have access to quality health care or cannot afford it

3.) Other Areas

• Eradicating hunger, poverty and malnutrition, promoting health care, preventive health care and sanitation and making available safe drinking water
• 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
• Measures for the benefit of armed forces veterans, war widows and their dependents
• Training to promote rural sports, nationally recognized sports, Paralympics sports 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 Government
• Rural development projects
• Slum area development

4.) Emergencies and Natural Calamities

Alutech Packaging Pvt. Ltd. shall provide relief, support, rehabilitation, reconstruction activities etc. for disaster management in case of natural calamities or emergencies etc.

In addition to the Areas to Emphasize specified above, the Company may select any area/ sector/ activity or head of activities, as may be specified in Schedule VII to the Companies Act, 2013 including any amendments or modifications as may be introduced from time to time.

Alutech Packaging Pvt. Ltd. will undertake CSR activities either in partnership with 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 or such other entities prescribed under the Act, who are engaged in activities or programs which fall within the purview of Alutech Packaging Pvt. Ltd.’s CSR Policy and areas of focus, or directly through 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, that may be established by Alutech Packaging Pvt. Ltd., either singly or along with any other company, for the purpose or both.

A governance structure at Alutech Packaging Pvt. Ltd. is responsible for implementing and administering CSR Policy, in compliance with the requirements of Section 135 of the Companies Act, 2013 and rules made thereunder. The Board of Directors of both the Companies who are ultimately accountable for the CSR projects undertaken by Alutech.

Alutech Packaging Pvt. Ltd. has constituted a CSR Committee at the Board level. The CSR Committee is supported by the CSR Team, comprised of representatives from both these companies.

 8.1 – CSR Committee

Alutech Packaging Pvt. Ltd. has constituted Corporate Social Responsibility Committee (the “CSR Committee”) in line with Section 135 of the Companies Act, 2013 (the “Act”). The CSR Committee consists of following members of the Board :

• Mr. Anil Kumar Mittal
• Mr. Rakesh Goel
• Mr. Hakumat Rai Mittal

The CSR Committee of the Board shall be responsible for :

• Review of CSR activities in the Company.
• Formulation of CSR Policy.
• Monitoring of implementation of CSR Policy.
• Recommend to the Board, modifications to CSR Policy as and when required.
• Appraise to the Board the CSR expenditure done during the year.

8.2 – CSR Team

Dedicated CSR team shall be constituted from among the employees at Alutech Packaging Pvt. Ltd., for implementing the CSR Policy and shall work under the guidance of CSR Committee and will be mainly responsible for :

• Execution of the CSR Policy.
• Identify projects and key initiatives pursuant to CSR Policy.
• Facilitating allocation of funds to the projects as identified for CSR activities.
• Monitoring CSR Projects to establish effectiveness of CSR efforts and appraise the same to CSR Committee.
• Compilation of information & preparation of Annual Reports on CSR activities and presenting the same to CSR Committee.
• Any other activity necessary to ensure achievement of CSR objectives.

The total budget for the CSR projects in each financial year will be decided by the CSR Committee in accordance with applicable provisions of the Act and the CSR Rules and the CSR Committee will recommend the amount of expenditure to be incurred on the activities to the Board for its approval. The CSR Committee shall propose to distribute the budget among the Areas to Emphasize or such of them as the CSR Committee may deem fit in each financial year, in such proportion and in a manner that meets the objectives of the CSR Policy.
For any reason if the CSR team is not able to follow the allocation agreed on in any of the Areas to Emphasize described above, the same shall be utilized in such other Areas to Emphasize as the CSR team may recommend with the reasons therefor, and the CSR Committee may approve.

10.1 – CSR Contributions

The Company will endeavour to contribute and spend at least 2% of the average net profits of the Company made during the three immediately preceding financial years or such amount as may be recommended by the CSR Committee from time to time in pursuance of this Policy.

10.2 – Compliance, Monitoring and Reporting

10.2.1 – Compliance

The CSR Team will formulate implementation plans for the projects specifying the following :

• Activities to be undertaken.
• Budgets proposed.
• Time frame for implementation.
• Responsibilities and authorities for implementation.
• Results expected to be achieved post implementation.

10.2.2 – Monitoring

The CSR Team will monitor the implementation and progress of the approved projects through appropriate mechanisms such as site visits, review meetings and progress reports etc. Mechanisms to track data and monitor projects will be established to ensure the transparency and efficiency of the implementation process. The projects will be evaluated against the milestones defined in the implementation plan of the project.

The Board of the Company shall satisfy itself that the CSR funds disbursed have been utilised for the purposes and in the manner as approved by it and the Chief Financial Officer or the person responsible for financial management shall certify to the effect as per applicable rules inthisregard.

10.2.3 – Reporting

The CSR Committee of the Board, based on reports presented by the CSR Team, will annually publish report on the CSR projects as a part of the Director’s report. The report will disclose information in the format as prescribed by the Section 135 of the Companies Act 2013 and rules made thereunder. The CSR Committee shall also submit a responsibility statement to the Board.The CSR Policy on being approved by the Board shall be displayed on the website of the Company and any modifications carried out from time to time shall also be updated on the website.

Any surplus arising out of the CSR activities shall not form part of the business profit of the 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 such period and with such terms and conditions as may be prescribed under Section 135 of the Act.

The CSR Committee shall formulate and recommend to the Board, an Annual Action Plan in pursuance of the CSR policy, which shall include the following :

• 1. The list of CSR projects or programmes that are approved to be undertaken in areas or subjects specified in Schedule VII of the Act
• 2. The manner of execution of such projects or programmes
• 3. The modalities of utilisation of funds and implementation schedules for the projects or programmes
• 4. Monitoring and reporting mechanism for the projects or programmes
• 5. Details of need and impact assessment, if any, for the projects undertaken by the company

The Board may alter such plan at any time during the financial year, per the recommendation of the CSR Committee, based on the reasonable justification to that effect.

If the Company spends an amount in excess of the requirements provided under the Act, then the Company may set off such excess amount against the requirement to spend under sub-section 5 of Section 135 for such number of succeeding financial years and in such manner, as may be prescribed under the Act and rules made thereunder.
This CSR Policy is subject to such changes and amendments as may be notified by the Ministry of Corporate Affairs under Section 135 of the Companies Act, 2013 and rules made thereunder and the same shall be read in line with the provisions of the Act applicable to the Company from time to time.