CORPORATE SOCIAL RESPONSIBILITY POLICY

SHARP BUSINESS SYSTEMS (INDIA) PRIVATE LIMITED

ISO 9001:2015

Certified Company

Registered Office: First Floor, Plot No 51 Okhla Industrial Area, Phase – 3,

Near Modi Mill New Delhi-110020

CIN No. U74899DL2000PTC104046

SHARP CORPORATE SOCIAL RESPONSIBILITY POLICY

Authorised By: Corporate Social Responsibility Committee

1. Context

SHARP Corporate Social Responsibility policy recognizes that “Businesses cannot be successful when the society around them fails”  SHARP Business Systems (India) Private Limited  has been  undertaking the social/ charitable  activities since its inception in various forms mainly aimed at promoting education for a better society.

In view of the provisions of Section 135 of the Companies Act, 2013 and Companies (Corporate Social Responsibility Policy Rules, 20I4), SHARP Business Systems (India) Private Limited, required to formalize the Corporate Social Responsibility Policy, accordingly a policy named “SHARP CSR Policy” complying with the aforesaid provisions.

• Objectives

The CSR vision of SHARP Business Systems (India) Private Limited is two pronged firstly “Empowerment of generation next through Education & Vocational Training.” “Women Empowerment through self employment and Promotion of both national and rural, sports.”

• Focus Areas

The Company CSR Activities will be in line with the stated vision of the Company and shall be in accordance with the requirements of the Companies Act, 2013.

The three focus areas where special Community Development programmes would be run are :-

• Education and Vocational Training: Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects.

• Gender Equality and Empowerment of Women: Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centers and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups.

• Promotion of Sports : Training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic sports

In addition, the Company has identified the following areas for Community Development interventions as well:-

• Hunger, Poverty, Malnutrition and Health:- Eradicating extreme hunger, poverty and malnutrition, promoting 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.

• Environmental Sustainability : 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.

• National Heritage, Art And Culture : Protection of national heritage, alt and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional and handicrafts.

• Rural & Slum Area Development Projects : Strengthening Rural & Slum areas by improving accessibility, housing, drinking water, sanitation, power and livelihoods, thereby creating sustainable villages

• Undertaking of CSR Activities

SHARP will strive to implement the aforesaid CSR activities on its own to the extent possible. However, the principle implementer of our CSR activities would be through the Company itself or such other entity/organization as approved by CSR Committee. At the same time, we recognize need to work in partnership with other players also. This would include:-

1. under the Companies Act, 2013 or Society or NGOs or any other form of entity incorporated in India that specialise in the aforesaid activities.

• Contribution to various funds which are aligned with our Vision and Mission e.g.

2. Prime Minister’s National Relief Fund
3. Any other fund set up by the Central Government for :
   • socio-economic development and relief.
   • for the welfare of Scheduled Castes, the Scheduled Tribes, other Backward classes, minorities and women.
4. Collaborating or pooling resources with other companies to undertake aforesaid CSR activities.

Accordingly, the Company or such other entity will work closely with and support the Board and the CSR Committee in implementing CSR Activities of the Company. The Company or such other entity will assist the CSR Committee in identifying the CSR Activities, programs and execution of initiatives as per defined guidelines. The Company or such other entity will also assist the Board and CSR Committee in reporting the progress of deployed initiatives and in making appropriate disclosures.

• CSR COMMITTEE

The Corporate Social Responsibility Committee comprises of Mr. Shinji Minatogawa as the Chairman and Mr. Shiv Shankar Jhunjhunwala as Member of the Committee. This Committee will supervise and provide guidance to in-house CSR Team of the Company.

• RESPONSIBILITIES OF THE CSR COMMITTEE

The responsibilities of the CSR Committee includes :-

• Formulating and recommending to the Board Corporate Social Responsibility Policy and the activities to be undertaken by the Company ;

• Recommending the amount of expenditure to be incurred on the activities undertaken;

• Reviewing the performance of the Company in the area of Corporate Social Responsibility ;

• FUNDS

At least two per cent in every financial year, of the average net profits of the company made during the three immediately preceding financial years, or as may be prescribed under the regulatory provisions in this regard, shall form the Funds available for implementation of CSR projects.

The resources arising out of the CSR Activities, projects or programs shall not form part of business profit of the Company and will be ploughed back to CSR Activities.

• MONITORING PROCESS

SHARP’s CSR Committee shall monitor the implementation of the CSR Policy through periodic reviews of the activities of the Company and/or through any other entity. The Head of CSR will present their annual budgets and list of programs, projects, and activities to the CSR Committee for its approval. The Committee will in turn recommend this to the SHARP Board for its final approval. In compliance with the Act and to ensure funds spent on CSR programs are creating the desired impact on the ground a comprehensive Monitoring and Reporting framework will be put in place. The monitoring and reporting mechanism is divided into three distinct areas:

1. Programme Monitoring Mechanism

1. Mechanism will ensure :

• the CSR policy is implemented as per the Act and the Rules.

• the CSR policy is implemented ensuring that all projects/programmes as budgeted are duly carried out.

1. CSR spends will be closely monitored and funds shall be released against verified utilizations as per the approved work plans. This may include monthly field visits, comprehensive documentation, and regular interaction with beneficiary communities.

1. CSR spends will be audited in an accountable and transparent manner.

1. Quarterly reporting and review by the CSR committee and six monthly reviews by the Board.

1. Evaluation

1. A robust MIS monitoring mechanism and evaluation plan will be put in place.

1. Expected outcomes, outputs and inputs will be clearly defined for each programme as per stated timelines.

1. There shall be clarity about the scope of the programme and the need before evaluations are undertaken.

1. Third parties will be engaged to ensure objective assessment across baseline and end line parameters.

• Head of CSR will be authorized to decide whether it will be internal, external or third party evaluation.

1. Documentation and Reporting

The CSR Committee will prepare the annual CSR report to be filed by the Company on approval of the Board. This report will ensure:

• CSR projects and programmes are being properly documented.

• An MIS is maintained on expenditure across sectors and geographies and beneficiaries impacted. The MIS structure will be in alignment with the    prescribed reporting format.

• Accountability is fixed at each level of CSR process and implementation.

• A repository of case studies and good practices is being maintained.

• EFFECTIVE DATE

This Policy is effective from 30^th May, 2019.

1. AMENDMENTS

Further any or all provisions of the CSR Policy would be subject to revision /amendment by the Board of Directors of the Company based on the recommendations of the CSR Committee or else in accordance with the guidelines on the subject as may be issued from time to time.