1. CSR Policy:

The CSR Policy of the Company will be operative within the overall ambit of CSR provisions in the Companies Act 2013, Companies (CSR Policy) Rules 2014 & Schedule-VII to the Companies Act 2013 and amendments thereof from time to time.

CSR Committee of the Board:

The Board of the Company will constitute a CSR Committee of the Board consisting of at least three directors.

Expenditure and Coverage under CSR Policy

The expenditure on account of CSR will be made with a view to build goodwill of the company and to be a part of National programme, no matter how minuscule the same may be.

The CSR Policy of the company will include the following:

Geographical Coverage:

The Company would undertake CSR activities primarily in the geographical areas where it has business activities and interest viz.:

• Purba Midnapore District of West, Bengal;
• Thiruvallur District of Tamil Nadu;
• Kolkata and South & North 24 Parganas;
• Tehsil - Vikas Nagar, Deharun, Uttar Khand.
• All Plants where company is having O&M Contracts (Presently at Bathinda, Banka, Goindwal and Baitalpur).
• All the locations of the company where company is entering into packed marketing business.

In addition, the Company may contribute or be a part of projects/ schemes of national importance.

CSR Projects/Programme

Schedule VII of the Act deals with the activities that may be considered as CSR initiatives. However, the following initiatives will be adopted as CSR focal points of the Company:

Activities which may be included by companies in their Corporate Social Responsibility Policies Activities relating to:

• 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 the promotion of sanitation] and making available safe drinking water.
• Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
• 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.
• Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, 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.
• 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 art and handicrafts;
• Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
• Training to promote rural sports, nationally recognised sports, paralympic sports and olympic sports
• Contribution to the prime minister's national relief fund or Prime Minister's Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the central govt. for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women;
• (a) Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and
• (b) 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 Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense 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).
• Rural development projects
• Slum area development.
• Disaster management, including relief, rehabilitation and reconstruction activities.

Procedure for selection and obtaining in-principle approval:

• In-charge of the geographical areas as identified above will put forward detailed proposal to CEO every year.
• The proposal will be examined by a committee to be constituted by CEO and put up recommendation through proper channel for obtaining in-principle approval from the committee.
• Base-line study/survey of all the short-listed projects should be done to establish the requirement of the project before placing the same for the administrative approval.
• Projects should be chosen carefully with the ultimate objective of the benefit of the society. Projects involving one-time expenditure should be considered for CSR activity and any project involving recurring nature of expenditure should be avoided.
• Emphasis should always be given to enhance the goodwill of the Company through CSR activities and to get the image of the Company uplifted at every opportunity. The name and logo of the Company should be on display at all the projects undertaken by the Company.
• While selecting the project/scheme, emphasis would be given on the project/scheme which are easily implementable.

Monitoring process of such projects:

CEO will nominate Officer (s) to execute, monitor and report the progress of the projects approved by Board.

Amount to be spent for CSR:

• At least 2% of the average net profit (before tax and after adjustment under section 198) of the company made during the three immediately preceding financial years will be spent for every financial year commencing from 1st April 2014.
• Based on the provisions of the Companies Act, the overall amount to be spent for CSR in a financial year will be arrived at and provided in the budget for approval of the Board.
• CEO is empowered to spend up to Rs.10 lakh per project and the CSR Committee is empowered to spend up to Rs.50 lakh per project on CSR projects / scheme within the purview of Schedule VII of the Companies Act 2013 subject to quarterly reporting of the same to the Board. Projects /scheme exceeding Rs.50 lakhs to be approved by Board on recommendation of CSR Committee.
• Surplus arising out of CSR projects or programme or activity will not form part of the business profit of the company.

Implementation of CSR activities in IPPL:

The Board will ensure that the CSR activities will be 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 80G 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, registered under section 12A and 80G of the Income Tax Act, 1961, and having an established track record of at least three years in undertaking similar activities.

CSR Process of IPPL:

1. Developing a CSR strategy + And policy
2. operationalizing the institutional mechanism
3. Selection of the project recommended by location-in-charge by committee appointed by CEO.
4. Due diligence of the project development Implementation partner (In case applicable)
5. Obtaining in-principle approval of CSR committee.
6. Project approval + Finalizing the arrangement with the implementing agency
7. Project Implementation signing of agreement with implementing partner (where applicable) / finalizing terms/ stage for direct expenditure, approval to be taken as per DOA. for expenditure within empowerment of CEO, comprehensive proposal to be put up and CEO's approval taken and implemented as per DOA.
8. Progress monitoring and reporting
9. Impact measurement + Report consolidation and communication

In case of CSR activities done by any entity, it is to be ensured that they are registered with the Central Government by filing the form CSR-I and have submitted CSR Registration Number.

• Activities undertaken in pursuance of normal course of business of IPPL.
• Any activity undertaken by IPPL outside India.
• Contribution of any amount directly or indirectly to any political party under section 182 of the Act.
• Activities benefitting employees of IPPL as defined in clause (k) of section 2 of the Code on Wages, 2019(29 of 2019).
• Activities supported by IPPL on sponsorship basis for deriving marketing benefits for its products or services.
• Activities carried out for fulfilment of any other statutory obligations under any law in force in India.

CSR Expenditure:

• CSR expenditure will include all expenditure including contribution to corpus, projects or programmes related to CSR activities approved by the Board on the recommendation of the CSR Committee, but does not include any expenditure on an item not inconformity or not in line with the activities which fall within the purview of Schedule VII of the Act.
• "Administrative Overheads" means the expenses incurred by the company for 'general management and administration' of Corporate Social Responsibility functions in the company but will not include expenses directly incurred for the designing, implementation, monitoring, and evaluation of a particular Corporate Social Responsibility project or programme.
• The Board will ensure that the Administrative Overheads will not exceed 5% (Five Percent) of total CSR expenditure of the company for the financial year.

CSR Reporting:

• The Board's Report of a company covered under these rules pertaining to any financial year will include an annual report on CSR containing particulars specified in Annexure I or Annexure II, as applicable.
• (i) Whenever IPPL is having average CSR obligation of Ten Crore Rupees or more in pursuance of sub-section (5) of section 135 of the Act, in three immediately preceding financial years, shall undertake impact assessment, through an independent agency, of their CSR projects having outlays of One Crore Rupees or more, and which have been completed not less than one year before undertaking the impact study.
• The impact assessment reports will be placed before the Board and will be annexed to the annual report on CSR.
• When IPPL undertaking impact assessment may book the expenditure towards Corporate Social Responsibility for that financial year, which will not exceed Five Percent of the Total CSR expenditure for the financial year or Fifty Lakh Rupees, whichever is less.

Amount of Ongoing Projects & Transfer of Unspent Amount:

• "Ongoing Project" means a multi-year project undertaken by a Company in fulfilment of its CSR obligation having timelines not exceeding Three Years excluding the financial year in which it was commenced and will include such project that was initially not approved as a multi-year project but whose duration has been extended beyond one year by the board based on reasonable justification.
• Any surplus arising out of the CSR activities will not form part of the business profit of IPPL 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 a period of Six Months of the expiry of the financial year.
• Where IPPL spends an amount in excess of requirement provided under sub-section (5) of section 135, such excess amount may be set off against the requirement provided under sub-section (5) of section 135 up to immediate succeeding three financial years subject to the conditions that -
• The excess amount available for set off will not include the surplus arising out of the CSR activities, if any, in pursuance of sub-rule (2) of this rule.
• The Board of IPPL should pass a resolution to that effect.
• Transfer of unspent CSR amount - Until a fund is specified in Schedule VII for the purposes of sub-section (5) and (6) of section 135 of the Act, the unspent CSR amount, if any, will be transferred by the company to any fund included in schedule VII of the Act.

Annual Action Plan

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

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

Display of CSR activities on IPPL website:

The Board of Directors of IPPL will mandatorily disclose the composition of the CSR committee, and CSR policy and Projects approved by the Board on their website, if any, for public access.