1. Title and applicability

a) The document describes the corporate social responsibility policy (csr policy) of entire park group including all group companies, business divisions and business units (the group). It includes groups vision, mission and other relevant attributes of corporate social responsibility.

b) The csr policy shall be guided by groups corporate philosophy of respect for the individual and the society at large.

c) The csr policy has been formulated in accordance with section 135 of the companies act, 2013 and the csr amendment rules, 2021.

d) The csr policy shall apply to all csr programs of the group.

2. Vision and mission

Park group is committed to build a sustainable business with strong social relevance and a commitment to inclusive growth and contribute to the society by supporting causes on various concerns including road safety, healthcare, environmental sustainability, promoting education, promoting sports and other rural development activities.

In pursuance of our vision that we desire to be a group which society wants to exist, we are dedicated towards fulfilling the social objectives through various csr activities. We shall make it our endeavour to positively impact and influence the society for its sustainable development.

3. Purpose

The companies act, 2013 has brought greater emphasis on csr with rules that provide guidance on minimum csr spend, focus areas, implementation mechanism and reporting to the shareholders of each of the group companies.

Csr policy has been designed keeping in view the park groups business vision, its csr vision and long-term social objectives that the companies wants to achieve. Park groups csr policy has been created with the purpose to outline its csr focus areas, review mechanism, execution process and reporting mechanism.

4. Responsibility of the board of directors

The responsibility of the board of directors shall be as under:

a) To approve the csr policy & disclose the contents of such policy in its report and also place it on the website of the group companies;

b) To ensure that the activities proposed in the csr policy are undertaken;

c) To ensure that the companies spend, in every financial year, at least 2% of average net profits of the company made during the 3 immediately preceding financial years, as required under section 135 of the companies act, 2013 & rules made thereunder;

d) If companies fail to spend the sum as mentioned above, then the board shall, in its report specify the reasons for not spending the amount.

5. Csr committee

i. Constitution of csr committee

A corporate social responsibility committee (the csr committee) has been constituted by the board of directors to oversee the csr agenda of the each of the group company. The committee has been formed as per the requirements of section 135 of the companies act, 2013 and companies (corporate social responsibility policy) amendment rules, 2021.

The board of directors shall be empowered to take decision for making or effecting changes in the constitution of the csr committee.

The composition of csr committee shall be disclosed in the board of directors report.

ii. Responsibilities of the csr committee

a) To formulate & recommend to the board of directors, a csr policy indicating the activities to be undertaken as specified in schedule vii of the companies act, 2013 and modify / amend the same as required;

b) To review and approve annual action plan with respect to csr programs;

c) To develop and institutionalize a csr reporting mechanism in light with section 135, rule 8 of the companies act 2013;

d) To ensure that park groups corporate website displays the approved csr policy of the group;

e) To monitor the csr policy, projects and programs from time to time.

iii. Meetings of csr committee

The csr committee shall meet at least once in six months. The meeting shall be held either at the registered office of the company or any other place, as may be decided by the members.

Physical presence of a minimum of two members of the committee shall constitute the quorum.

iv. Notice of meeting

At least seven days advance notice of every meeting, specifying the day, place and timing of meeting and the general nature of the business to be transacted there at shall be given to the members. In urgency, a meeting may be convened by shorter notice.

6. Areas of csr activities

The park group is hereby devoted to direct its csr resources, to a reasonable extent, for improving the quality of life of the people by focusing on the social causes, including but not limited to the following areas:

a) Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care 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;

b) Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects;

c) 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;

d) 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 set-up by the central government for rejuvenation of river ganga;

e) 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;

f) Measures for the benefit of armed forces veterans, war widows and their dependents;

g) Training to promote rural sports, nationally recognized sports, paralympic sports and olympic sports;

h) 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, and other backward classes, minorities and women;

i)Contributions or funds provided to technology incubators located within academic institutions which are approved by the central government;

j) Rural development projects;

k) Slum area development and

l) Activities related to promotion of road safety.

7. Exclusions

Following activities shall be excluded from the csr expenditure of the companies.

a) Activities which are exclusively for the benefit of employees of the companies or their family members;

b) Activities undertaken in pursuance of normal course of business of the companies;

c) Direct or indirect contribution to political parties;

d) Activities outside india, except training of sports personnel representing any state, union territory at national level or india at international level;

e) Activities for statutory obligations.

8. Csr expenditure

a) Every year the companies shall spend atleast 2% of its average net profit as defined under the rules (csr obligation) during the three immediately preceding financial years, on the csr activities as per approved annual action plan.

b) The companies shall not consider any administrative expenses, except the cost of impact assessment, in meeting its csr obligation, provided that such costs shall not exceed the cap (5% of csr expenditure) for such impact assessments, prescribed under applicable laws.

c)Any amount remaining unspent at the end of the financial year, if any, except in case of an ongoing project, shall be transferred to a fund to be specified in schedule vii for this purpose, within a period of six months of the expiry of the relevant financial year.

d) In case the companies undertake any ongoing project, any amount remaining unspent and earmarked for the ongoing project, shall be transferred within a period of thirty days from the end of the financial year to a special account to be opened for that financial year in any scheduled bank to be called the unspent corporate social responsibility account, and such amount shall be spent within a period of three financial years from the date of such transfer, failing which, the unspent

Amount shall be transferred to the fund to specified in schedule vii for this purpose, within a period of thirty days from the date of completion of the third financial year.

e) In case the companies spend an amount in excess of the requirements of its csr obligations in a financial year, such excess amount may be set-off against the requirement of the csr spending under sub-section (5) of section 135 upto the immediate succeeding 3 financial years subject to the fulfilment of conditions as specified under the companies (corporate social responsibility policy)amendment rules, 2021, the board shall pass the resolution to that effect.

f) Any surplus arising out of csr projects, programmes or activities shall not form part of the business profits of the companies and shall be utilized towards the eligible csr activities / addressed in accordance with applicable laws.

9. Approval of csr activities

a) The csr activities to be undertaken by the park group under the policy shall be approved by way of annual action plan by the board on the recommendation of the csr committee.

b) The annual action plan shall, inter alia, contain the following information with respect to the csr activity proposed to be undertaken by the companies:

i. List of csr activities to be undertaken in the relevant financial year;

ii. Local area where the csr activities are to be undertaken;

iii. Manner of execution;

iv. Modalities of utilisation of funds;

v. Implementation schedule;

vi. Monitoring and reporting mechanism; and

vii. Details of need and impact assessment, if any.

c) The board on the recommendation of the csr committee shall be the absolute authority to update, alter, modify, amend, withdraw and replace the annual action plan for justified reasons.

10. Geographies and beneficiaries

a. Geographies

The park group will give preference to the local areas around its operations for spending the amount earmarked for csr activities. Park groups operations are mainly concentrated in the following areas:

i. Nct of delhi;

ii. State of haryana;

iii. Companies may undertake csr activities in any other area in india as may be decided, from time to time.

B. Beneficiaries

The beneficiaries of park groups csr programs are the following categories of people:

i. Children/students.

ii. Women.

iii. Weaker sections of the society.

iv. Others society at large.

11. Implementation mechanism

The park group may conduct / implement csr programs by itself and/or through registered trusts, societies and / or section 8 companies with an established track record of at least three years in carrying on activities in the related area/s or as suggested by ministry of corporate affairs vide circulars/notifications.

The park group may collaborate or pool resources with other companies to undertake csr activities and any expenditure incurred on such collaborative efforts would qualify for computing the csr spending.

The progress will be reported to the csr committee during the committee meetings.

The progress on csr programs undertaken by the companies will also be reported in the annual report in the format prescribed by the csr amendment rules, 2021.

12. Monitoring of csr programs

The park groups csr team shall be responsible for day to day management of csr related activities of the companies. The team shall periodically report to the csr committee regarding the financial and programmatic progress of csr projects.

All projects undertaken by the park group shall be monitored on a regular basis. On- site monitoring would also be undertaken at least once a year to ensure on-track implementation.

13. Amendments to the csr policy

The csr policy may be updated to align it with the changing requirement or changes in the legal and regulatory framework. Any revision in the policy shall be approved by the board of directors.