Sunbeam Lightweighting Solutions Pvt. Ltd.

CSR Policy

Table Of Contents

Introduction
Objective & Scope
Corporate Social Responsibility (CSR) Committee
CSR Budget/CSR Spend
CSR Initiatives
Publication of CSR Policy & Programs
Policy Review & Future Amendment

1. Introduction

Sunbeam Lightweighting Solutions Pvt. Ltd. (SLSPL) founded in 1986, The business of Sunbeam Lightweighting Solutions Pvt. Ltd is to manufacture Aluminium Die Cast Components which are being supplied to Automotive manufacturers, namely Hero Motocorps Limited, Maruti Suzuki India Limited, Continental, Ford, Bosch. The day to day Management is looking after by Mr. J.K. Menon, who is Executive Chairman, of the Company under the supervision of the Board of Directors.

The company is producing Aluminium Alloy Die Casted Components by Gravity, Low Pressure and High Pressure die casted methods followed in its foundry and has become one of the largest die casting foundry of the country.

Corporate Social Responsibility (CSR) is the business response to the sustainable development challenge and the way in which it manages its processes to produce an overall positive impact on its employees and their families as well as that of the local community and society at large. Our business is people and property. As people in the property business, we strive to be trusted business partners and by being responsible, we help to create that trust.

We believe that the successful long-term future of our business can only be achieved by working collaboratively with our stakeholders and in their interests: clients – whether they are building occupiers, developers or investors – employees, suppliers, NGOs, the media, Government and the wider community.

1.1 CSR in India

CSR provisions put formal and greater responsibility on companies to set out a clear framework and process to ensure strict compliance.
The new Companies Act 2013 (hereinafter referred to as 'the Act'), has introduced the idea of CSR to the forefront and through its “Comply-or-Explain” mandate. It mandates qualifying companies to constitute Corporate Social Responsibility Committee to effectively monitor CSR activities of the Company. Further the Companies (Corporate Social Responsibility Policy) Rules, 2014 (hereinafter referred to as “CSR Rules”) lays down the framework and modalities of carrying out CSR activities which are specified in Schedule VII of the Act.

2. Scope

This Policy covers current as well as proposed CSR activities to be undertaken by the Company and examining their alignment with Schedule VII of the Act as amended from time to time. It covers the CSR activities which are being carried out in India only and includes a strategy that defines plans for future CSR activities.

2.1 Objective

The main objective of the SLSPL CSR policy is

To lay down guidelines to make CSR a key business process for sustainable development of the society.
To directly/indirectly undertake projects/programs which will enhance the quality of life and economic well-being of the communities in and around our plant and society at large?
To generate goodwill and recognition among all stakeholders of the company.

2.2 CSR Support:

CSR activities at Sunbeam Lightweighting Solutions Pvt. Ltd shall be carried out through the following:

1) Sunbeam Corporate Charitable Trust

Sunbeam Corporate Charitable Trust is a non- profit charitable trust promoted and was established by SLSPL in 2014 as a social development arm of the Company. Trust work for the charitable purpose such as to strive for women and girl welfare, to maintain or support or establish Ashram, Dharamshala, guest house etc., to establish, maintain, manage crèches, hospitals, dispensaries, clinic, mobile clinic with latest medical equipment and facilities and to work with rural communities on issues related to Water Resource Management, Agro & Skill based livelihood generation, Health, education, women's empowerment and rural infrastructure.

2) Collaboration with other Companies undertaking projects/ programs in CSR activities.

3) Contribution/donation made to such other Organization/Institutions (Government as well as NGO)/authorities/trust as may be permitted under the applicable laws from time to time.

4) Directly by the Company for fulfilling its responsibilities towards various stakeholders.

2.3 Targeted Sectors

Healthcare
Sanitation
Drinking Water
Education
Rural Development
Vocational Skills
Entrepreneurship Skills
Employment Opportunities
Facilities for Senior Citizens
Medical Aid
Old Aged Homes
Women Hostels
Special Employment Opportunities for Women
Environment Protection
Animal Welfare
Conservation of Natural Resources
Protection of National Heritage
Promoting and development of Art and Culture
Public Libraries
Promotion and development of traditional arts and handicrafts
Measures for the armed forced veterans, war widows and their dependents
Promotion and development of rural sports and National Games
Contribution to funds set by the Central or State Government for the development and welfare of Scheduled Castes, Scheduled Tribes and minorities
Rural Development Projects
Contribution to technology incubators located within academic institutions
Go Green Initiatives
Human Rights
Any other area as may be prescribed by Schedule VII amended from time to time

The Company will review the sectors from time to time and make additions/deletions/clarifications to the above sectors.

3. CSR Committee

3.1 Constitutions
Pursuant to the provisions of Section 135 of the Act, the Board of Directors shall constitute the Corporate Social Responsibility (CSR) Committee. The Members of CSR shall be appointed by the Board of Directors of the Company. The committee shall consist of minimum three Directors; however, in case Board of Directors reduced to two, the Committee shall have two Directors only. In case, resignation, cessation of Committee members, Board of Directors shall have power to appoint members of the Committee.

3.2 Powers of the Committee

Following are the Powers of the CSR Committee:

Formulate CSR Policy and recommend the same to the Board of Directors of the Company for approval
Recommend CSR activities as stated under Schedule VII of the Act
Approve to undertake CSR activities in collaboration with other Companies/firms/NGOs, etc. and to separately report the same in accordance with the CSR Rules
Recommend the CSR Budget
Spend the allocated CSR amount on the CSR activities once it is approved by the Board of Directors of the Company in accordance with the Act and the CSR Rules
Create transparent monitoring mechanism for implementation of CSR Initiatives in India
Submit the Reports to the Board in respect of the CSR activities undertaken by the Company
Monitor CSR Policy from time to time
Monitor activities of Monitoring Committee (MC) who are authorized to ensure that the CSR activities of the Company are implemented effectively
Authorize executives of the Company to attend the CSR Committee Meetings

3.3 Frequency of the Meetings of the CSR Committee

The CSR Committee shall meet at least once in a quarter. Members of the CSR Committee can agree upon mutually regarding the time and place for the said meetings. Quorum for the meeting should be two. The Members of the Committee may participate in the meeting either in person or through video conferencing or other audio visual means in accordance with the provisions of the Companies Act, 2013 and rules made thereunder from time to time. Minutes of the CSR Committee shall be placed before the Board for noting.

4. CSR Budget/CSR Spend

The Act mandates companies meeting the qualification criteria as mentioned in section 135, shall every year spend at least 2% of its average net profit of 3 (three) immediately preceding financial years in pursuance of its CSR Policy on CSR activities that fall under purview of Schedule VII of the Act.

4.1 CSR Expenditure:

Net profit means profit more fully described under Rule 2 (f) of the CSR Rules. The CSR expenditure shall include all expenditure including contribution to the corpus or on projects or programs relating to CSR activities approved by the Board of Directors on the recommendation of its CSR Committee but does not include any expenditure on an item not in conformity or not in line with activities stated under Schedule VII of the Act.

4.2 Expenditure on CSR capabilities

The Company may build CSR capabilities of their own personnel as well as of their Implementing Agencies and such expenditure shall not exceed 5% of the total CSR spend of the Company as stated in the Rules from time to time. Determination of whether a particular expenses fall within this 5% cap can be decided in consultation of the Vice President (Finance) of the Company based on the clarification available from time to time in this regard.

4.3 Failure to spend the CSR Money

In case the Company fails to spend the above targeted amount in that particular financial year, the Committee shall submit a report in writing to the Board of Directors specifying the reasons for not spending the amount which in turn shall be reported by the Board of Directors in their Directors' Report for that particular Financial Year. Surplus arising out of the CSR initiatives shall not form part of the business profits of the Company.

5. CSR Initiatives

In line with Schedule VII of the Act and the CSR Rules, the Company shall undertake CSR activities included in its Annual CSR Plan, as recommended by the CSR Committee at the beginning of each year. The Committee is authorized to approve any modification to the existing Annual CSR Plan or to propose any new program during the financial year under review.

5.1 Annual CSR Plan

The Annual CSR Plan is a yearly plan of CSR activities that would be placed before the Board of Directors of the Company based on the recommendation of its CSR Committee which outlines the following aspects of CSR initiatives of the Company:

Tailor-made CSR projects depending upon allocated spend and geographical presence
Partnering agencies/companies/firms
Process Owners
Project Proposals
Targeted Beneficiaries & their key needs
Alignment with Schedule VII
Project Goals and milestones
Activities and Timelines, including expected closure dates
CSR Budget with projections
Monitoring mechanism
Progress reporting and frequency of reports
Risks and mitigation strategies
Any other information as may be required by the CSR Committee

5.2 Collaboration

The Company may collaborate with other Companies/institutions/ Authrities (Government & NGO)/trust as may be approved by CSR Committee vi's-à-vis the Board of Directors to implement CSR activities and the same shall form a part of the Annual CSR Plan. The Company may form trusts or society on its own to carry out CSR activities in accordance with the CSR Rules and to administer its CSR activities, the Company may jointly along with other Company form Trusts to administer the CSR activities.

5.3 Exclusion from CSR

The following activity shall not form part of the CSR activities of the Company:-

The activities undertaken in pursuance of the normal course of business of a company.
CSR projects/programs or activities that benefit only the employees of the Company and their families.
Any contribution directly/indirectly to a political party or any funds directed towards political parties or political causes.
Any CSR projects/programs or activities undertaken outside Indi5.4 Monitoring Mechanism:

5.4 Monitoring Mechanism:

The CSR Committee shall form a committee to be called as Monitoring Committee (“MC”). The composition of the MC will comprises of employees of the Company and representatives of entities with which the Company decides to collaborate for fulfilling its CSR obligations. The members of the MC will be appointed on a rotational basis. The MC will be created to ensure effective implementation and monitoring of the projects approved by the CSR Committee. The MC will submit periodic reports to the CSR Committee of the Company on the progress of the various projects approved by the Committee and entrusted to the MC for implementation and monitoring.

The CSR Committee has the powers to:

Seek monitoring and implementation report from the organizations receiving funds.
Delegate a designated company official to co-ordinate with the organization receiving funds to inspect the activities undertaken and ensure information in a timely manner.

The Committee Members will receive in a prescribed format; a quarterly report of CSR spends to ensure effective implementation and monitoring of the projects approved by the CSR Committee

A presentation on the progress of the CSR projects / activities will be made to the Committee by the MC at the Committee meetings held from time to time.

: S.no CSR Project or Activity Identified A sector which the project is covered Project or Programs 1) Local Areas, 2) Specify the state and district where projects or programs was undertaken Budget ( Project or Program Amount spent on Project or Program

a) Direct Expenditure
b) overheads Cumulative Expenditure Amount Spent Direct or through Agency Target Date & Status

5.5 Publication of the CSR Policy

As per the CSR Rules, the contents of the CSR Policy shall be included in the Directors’ Report and the same shall be displayed on the Company’s website, if any.

6. Policy Review & Future Amendment

The Committee shall annually review its CSR Policy from time to time and make suitable changes as may be required and submit the same for the approval of the Board.

J.K. Menon
Executive Chairman