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JEHAN NUMA PALACE HOTEL PRIVATE LIMITED
CORPORATE SOCIAL RESPONSIBILITY (CSR) POLICY

Purpose:

This policy sets out the Company's commitment & approach towards Corporate Social Responsibility based on our legacy of 'Giving Back to Society'. The Company is committed to the Purpose of improving the quality of life of the communities we serve through the CSR theme of 'Building Sustainable Livelihoods'. The Company endeavors to facilitate livelihood opportunities & socio-cultural development in areas of its operations.
The Company intends to be a significant contributor to CSR initiatives in India by devising and implementing social improvement projects for the benefit of underprivileged communities, towns and villages.

Focus Area

In accordance with the requirements of the Companies Act, 2013 ("the Act"), the Company's CSR programs shall mainly focus on the following areas:
• Vocational skill development programs
• Partnerships to preserve & promote indigenous heritage, culture, arts and
handicrafts
• Disaster relief and rehabilitation programs
• Income-generation and livelihood enhancement programs
• Education to underprivileged children, women and adults.
• Health Care program and preventive health care measures.
• Environmental and animal welfare.
• Promotion of rural sports
• Promotion of gender equality and empowering women.
• Setting up homes and hostels for women and orphans, Old age homes and day care centers.

However, the Company may choose to undertake additional CSR Activities falling within the purview of Schedule VII of the Act, as may be amended from time to time, based on the recommendations of the CSR Committee and as may be approved by the Board of Directors.

Responsibility of the Board of Directors:

The Board shall be responsible for –
• Approving the CSR policy of the Company as may be recommended by the CSR Committee, subject to necessary changes / modifications as the Board may deem fit.
• Ensuring that in each financial year the Company spends such amounts for CSR activities as may be stipulated in the Act, as amended from time to time. (presently 2% of the average net profits of the Company made during the three immediate preceding financial years)
• Ensuring that the activities as are included in the CSR Policy are undertaken by the Company

CSR Committee:

• The CSR Committee shall comprise three or more directors of which, at least one will be an independent director.
• The CSR Committee of the Company shall be responsible for:
a. Formulating and recommending to the Board the CSR Policy which shall indicate activities to be undertaken in line with Section 135 read with Schedule VII of the Act.
b. Recommending to the Board the CSR expenditure to be incurred.
c. Monitor the implementation of the CSR Policy from time to time

CSR Budget:

The amounts to be spent by the Company shall be as stipulated under the Act, as amended from time to time (presently 2% of the average net profits of the Company for the preceding three financial years) and as approved by the Board. Any surplus arising out of the CSR projects or programs or activities shall not form part of business profits of the Company.
Target Communities & Project Locations: Our target communities shall include rural, less-privileged, school dropout, differently abled, marginalized youth and women; indigenous artisans, disaster victims and other such groups associated with our focus areas. Relevant projects and locations pertaining to the above focus areas and target communities shall be undertaken around our areas of operation as well as other 'identified locations' from time to time.

Implementation & Monitoring Structure:

CSR Programs of the company shall be undertaken through a three tier structure:
• Hotel-level volunteer teams take up implementation of key initiatives, in association with like-minded partners – including Cause Based Organizations.
• Cross-functional CSR committee at Corporate level helps initiate projects and provides support & monitoring.
• CSR committee at Board level provides broad direction for CSR planning and conducts biennial reviews to ensure desired impact.

Project Monitoring –

• The Project Monitoring team will ensure that the CSR Policy is implemented as per the Act and the Rules ensuring that all projects as budgeted are duly carried out.
• All CSR spends will be closely monitored and audited in an accountable and transparent manner
• Project monitoring shall include periodic field visits, comprehensive documentation, and if required interaction with beneficiary communities.
• The CSR Committee shall periodically review the CSR project reports and the same shall be annually presented to the Board.

Stakeholder Communication

We shall ensure relevant updates regarding our key projects and its impact through our Annual Report, web platforms and other relevant mechanisms from time to time.