Corporate Social Responsibility Policy

CSR VISION

The CSR vision of SBL Specialty Coating Private Limited ("the Company") recognises that an enterprise and the society in which it operates are mutually dependent on each other and the growth of the industry is proportionate to the equitable development of the country, its environment and its people, irrespective of religion, race, caste, creed and gender. The Company also believes that all round development can be brought about by paying attention to regions, groups and people which are backward and have special needs and by helping citizens to acquire useful skills.

To this extent, the Company will devote resources, in the manner recommended by its CSR Committee and approved by its Board of Directors in accordance with the provisions of law for fulfilling the aforesaid objective in the manner laid out in Schedule VII to the Companies Act, 2013, with particular stress on areas around which the Company operates.

SCOPE OF CSR ACTIVITIES

To this extent, the Company will support or undertake measures by established and reputed agencies and Non-Government Organisations, Central and State Governments and other agencies or the Company itself, for: • Eradication of hunger, poverty and malnutrition • Promote health care facilities including preventive health care • Implementation of measures for reducing inequality faced by socially and economically backward groups • Promoting sanitation • Making available safe drinking water • Promoting education including special education and skill development • Promoting employment enhancing vocational skill among citizens including children, women, elderly, differently abled persons • Promoting livelihood enhancement projects • Promoting gender equality and empowerment of women • Promoting setting up of homes for women and orphans, old age homes, day care centres and such other facilities for senior citizens • Ensuring environmental sustainability, environmental balance, protection of flora and fauna, animal welfare, agro-forestry, conservation of natural resources and maintaining quality of soil, air and water • Protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art, promotion and development of traditional arts and handicrafts • Setting up and running of public libraries • Measure for benefit of armed forces veterans, war widows and their dependants • Promotion of rural sports and training for nationally recognised sports, Paralympics sports and Olympic sports • Contribution to the Prime Minister’s National Relief Fund or Prime Minister’s Citizens Assistance and Relief in Emergency Situations Fund (PM Cares Fund) and any other Fund set up by the Central Government for socio economic development and relief and welfare of the scheduled castes, scheduled tribes, other backward classes, minorities and women. • Providing funds to technology incubators located within academic institutions which are approved by the Central Government including contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Electronics and Information Technology and other bodies, namely Defence Research and Development Organisation (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs). • Promotion and setting up of Rural Development Projects • Promotion of slum area development • Promotion of disaster management, including relief, rehabilitation and reconstruction activities • Promotion of sporting activities

While the Company pledges to encourage its employees towards participation in varied CSR activities that the Company undertakes, activities undertaken in the normal course of business of the Company or only for benefit of the employees and their families shall not qualify as CSR under this Policy, except as may be permissible under applicable laws. In this regard, activities benefitting employees of the Company as defined in clause (k) of Section 2 of the Code on Wages 2019 shall also not be considered as CSR under this Policy. However, if employees and their families get benefits by an activity which is largely meant for the outside community or society, then such activity, if otherwise qualified, will count as a CSR activity. It is further clarified that the Company shall also not undertake any activity in fulfilment of any other statutory obligations under any law in force in India, as a CSR activity.

The composition of the CSR Committee, the CSR Policy and CSR Projects approved by the Board of Directors shall be disclosed on the website of the Company for public access.

CSR COMMITTEE AND ITS ROLE

A CSR Committee comprising of 3 (three) or more directors shall work in coordination with directions given by the Board of Directors of the Company. Such CSR Committee may be reconstituted from time to time as per the requirement of applicable laws. Role of the CSR Committee shall include inter alia the following: Formulate and Recommend to the Board, a Corporate Social Responsibility Policy and to conduct CSR activities in the manner as approved by the Board of Directors of the Company and ensure that such CSR activities are in compliance with the provisions of Schedule VII of the Companies Act 2013. To monitor the Corporate Social Responsibility Policy of the company from time to time. In case any of the CSR Activities to be undertaken are anticipated to be long term i.e. an ongoing project being for a term of 3 (three) years excluding the financial year in which it has commenced, then an estimate on implementation schedule or milestones should be submitted by the CSR Committee to the Board of Directors. Formulate and recommend an annual action plan in pursuance of its CSR policy, which shall include: -> the list of approved CSR projects and programmes of the Company that are to be undertaken in areas or subjects specified in Schedule VII of the Act; -> the manner of execution of such projects or programmes; -> the modalities of utilisation of funds and implementation schedules for the projects or programmes; -> monitoring and reporting mechanism for the projects or programmes;

BOARD OF DIRECTORS AND ITS ROLE

The board of directors of the Company shall:– (a) Form a CSR Committee and disclose the composition of the CSR Committee (as set out above). (b) Approve the CSR Policy after taking into account the recommendations made by the CSR Committee. (c) Place the CSR Policy on the Company’s website. (d) Ensure implementation of the activities under CSR Policy. (e) Ensure expenditure of requisite amount on CSR every year as per law. (f) Disclose reasons for not spending the amount (if applicable) in the Annual Report to the shareholders of the Company. (g) Ensure that the funds so disbursed have been utilized for the purposes and in the manner as approved by Board / CSR Committee and the Chief Financial Officer shall certify to the effect. (h) Approve transfer of unspent CSR Amount in accordance with the law, if applicable. (i) In case of an ongoing project, monitor the implementation of the project with reference to the approved timelines and year-wise allocation and to make modifications, if any, for smooth implementation of the project within the overall permissible time period. (j) To make alteration in annul action plan at any time during the financial year, as per the recommendation of its CSR Committee, based on the reasonable justification to that effect. The Board shall also ensure that the CSR activities are undertaken by the Company itself or 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 (43 of 1961), established by the Company, either singly or along with any other company, or - a company established under section 8 of the Act or a registered trust or a registered society, established by the Central Government or State Government; or - any entity established under an Act of Parliament or a State legislature; or - a company established under section 8 of the Act, or a registered public trust or a registered society, not referred to above, registered under section 12A and 80G of the Income Tax Act, 1961, and having an established track record of at least 3 (three) years in undertaking similar activities. Every entity as covered above, who intends to undertake any CSR activity, shall register itself with the Central Government by filing the form CSR-1 electronically with the Registrar (or such other form or document as may be required), for projects or programmes approved, with effect from 1st April 2021. The Company may engage international organisations for designing, monitoring and evaluation of the CSR projects or programmes as per its CSR policy as well as for capacity building of their own personnel for CSR. The Company may also collaborate with other companies for undertaking projects or programmes or CSR activities in such manner as prescribed under the law. The Board shall satisfy itself that the funds so disbursed have been utilised for the purposes and in the manner as approved by it. The Chief Financial Officer of the Company shall certify to this effect.

PARTNERSHIPS AND COLLABORATIONS

Collaborative partnerships shall be formed with the internal as well as external stakeholders which shall include the Government, the village panchayats, NGOs, the District Authorities, international organisations and other likeminded stakeholders. Company may join hands with external experts and organizations with an established track record who have done work or are capable of doing work in the areas identified by the Company as CSR initiatives.

GENERAL

In case of any doubt with regard to any provision or interpretation of the policy or in relation to any matter not covered herein, a reference shall be made to the CSR Committee. In all such matters, the interpretation and decision of the 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 from Government, from time to time.

The Company is committed to continuously reviewing and updating the policies and procedures. Therefore, this policy is subject to modification.

The Board of Directors of the Company reserves the right to modify, add, or amend the CSR Policy from time to time, as it may think fit, based on the recommendation of the CSR Committee. Any changes/ modifications to the CSR Policy shall be immediately updated on the website.