CORPORATE SOCIAL RESPONSIBILITY POLICY. Ansal Properties & Infrastructure Limited

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CORPORATE SOCIAL RESPONSIBILITY POLICY Ansal Properties & Infrastructure Limited

BACKGROUND Ansal Properties & Infrastructure Limited {including its subsidiaries, affiliates, associate(s), joint venture(s), group company (ies)} (hereinafter referred as the APIL or Company ) believes in the conduct of its affairs in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behaviour and in complete compliance of laws, as amended from time to time. REQUIREMENT OF CORPORATE SOCIAL RESPONSIBILITY {CSR} Section 135 of the Companies Act, 2013 {in short Act }, read with the Companies {Corporate Social Responsibility Policy} Rules 2014 {In short CSR Rules }, mandates companies meeting specified net worth or turnover or net profit during any financial year to constitute a Corporate Social Responsibility Committee of the Board, formulate a Corporate Social Responsibility Policy {in short CSR Policy} including the activities specified in Schedule VII of the Act and ensure spending in each financial year, at least 2% {two per cent} of their average net profits made during the three immediately preceding financial years in pursuance of their CSR Policy. SHORT TITLE & APPLICABILITY This Policy, which encompasses the Company s philosophy to delineate its responsibility as a corporate citizen and lays down the guidelines and mechanism for undertaking socially useful programmes for welfare & sustainable development of the community at large, is titled as APIL CSR Policy. This shall apply to all CSR activities i.e. projects or programs, activities undertaken or to be undertaken by the Company in terms of Section 135 of the Act and CSR Rules {in short, CSR activities }. These activities shall exclude those undertaken or to be undertaken by the Company in pursuance of its normal course of business. EXISTING CSR ACTIVITIES The Company draws its inspiration for engaging in CSR activities from the legacy of the Ansal API Group. The Company is, thus already engaged in social and philanthropic causes since long. It extends its support towards community service by enhancing the quality of life in the fields of education, healthcare, community welfare, & rural developments, housing for economically weaker section of society, senior citizen home, providing food for the poor and the needy, resource conservation & environment, promotion of literature, as well as religious and spiritual activities. The Company, in this regard, is presently engaged through charitable companies, Trusts, other NGOs, namely, among others, Sushil Ansal Foundation, Kusumanjali Foundation {Section 8 Companies}, Chiranjiv Charitable Trust, Ansal Diya Foundation, Shanti Sahyog, Divya Chaya Trust and Kahma Welfare Committee. (Further particulars appear in attached Annexure -I)

COMPLIANCE The Company shall comply with Section 135 of the Companies Act, 2013 and Companies {Corporate Social Responsibility Policy} Rules 2014, as amended and also various notifications/ clarifications, issued from time to time, and any other applicable provisions of any statute. OVERALL OBJECTIVES To pursue the CSR objectives the Company will endeavour to: Continue to undertake social responsibilities as a dependable corporate citizen functioning in the society. Collaborate with like minded bodies like governments, voluntary organizations and academic institutes in pursuit of its goals. Interact regularly with stakeholders, review and publicise the CSR initiatives. Volunteering by APIL employees is recognized. IMPLEMENTATION & THROUGH EXECUTING AGENCIES The Company is undertaking and shall undertake CSR activities either on its own and/or through charitable company/ies u/s 8 of the Act and/or Trust/s which are already established/ to be established by it or its promoters and/or undertake CSR activities through its subsidiary/ies and/or associate company/ies. The Company will accomplish its CSR objectives either on its own and/or through: a. Community based organizations, whether formal or informal. b. Elected local bodies such as panchayats. c. Voluntary Agencies (NGOs). d. Institutes/ Academic Organizations. e. Missions & Self help Groups. f. Government, Semi Government and autonomous Organizations. g. Subsidiary/ies / associate / group company/ies. h. Any other group, samiti, organization. PERMITTED AREAS OF CSR Pursuant to Schedule VII of the Act and the CSR Rules, the Company shall endeavour, through its CSR Policy, to carry out CSR activities in respect of one or more of the following areas, in India, for:- eradicating hunger, poverty and malnutrition, promoting preventive health care and 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, 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; setting up public libraries; promotion and development of traditional and handicrafts: measures for the benefit of armed forces veterans, war widows and their dependents; training to promote rural sports, nationally recognised sports, paralympic sports and Olympic sports; 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, other backward classes, minorities and women; contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government; rural development projects; slum area development. FORMATION OF CSR COMMITTEE In terms of criteria mentioned in Section 135 of the Act, a Corporate Social Responsibility Committee {in short CSR Committee } consisting of following members has been constituted by the Board of Directors of the Company at their meeting held on 07 th February, 2014: Sr. No. Name of the Members Position (i) Shri Sushil Ansal Chairman (ii) Dr. R.C Vaish Member (iii) Shri P.R Khanna Member (iv) Shri P.S Rana Member AUTHORITY OF CSR COMMITTEE a) formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate the activities to be undertaken by the Company in terms of Schedule VII such as Promotion of Education, Charitable, Philanthropic activities and promotion of Backward classes etc.;

b) recommend the amount of expenditure to be incurred on the activities referred to in clause (a); and c) monitor the Corporate Social Responsibility Policy of the Company from time to time. New CSR Activities The CSR Committee shall have the authority to recommend to the Board for approval of any other CSR programmes or projects or activities not covered in this policy which are within purview of the Companies Act, 2013, and rules thereunder as amended from time to time. THRUST AREAS OF CSR IN TERMS OF SCHEDULE VII OF THE ACT 1. Promoting Education, literacy & Skill Development 2. Environment sustainability & protection 3. Healthcare/Medical care 4. Housing for Weaker Section of the Society & old age persons 5. Promotion & protection of culture / literature 6. Rural Developments All CSR activities have been and shall be identified in consultation with the relative community which is to benefit/benefitting, in a participatory manner, wherever feasible. GEOGRAPHICAL AREA OF CSR The focus of CSR activities shall be generally in the vicinity of the projects and operations of the Company. APPROVAL CSR activities as identified by the Company shall be required to be put up to the CSR Committee, from time to time for approval and/or confirmation / ratification. FUNDING AND ALLOCATION For achieving its CSR objective, the Company through CSR Committee shall allocate for spending in every financial year, at least 02% of its average net profits made during the three immediately preceding financial years, as its Annual CSR Budget. It shall also decide the modalities of utilization of funds. Moreover mere contribution of funds, unless statutorily permitted, to any entity without the Company undertaking CSR activities through it will not be considered as CSR activities.

DISTRIBUTION OF ANNUAL CSR BUDGET AMONGST THRUST AREAS Sr.No. Thrust Area % allocation 1 Promoting Education, literacy and Skill 20% Development 2 Environment sustainability & protection 10% 3 Healthcare/Medical facility 15% 4 Housing for Weaker Section of the Society & old 05% age persons 5 Promotion & protection of culture/ literature 05% 6 Rural Developments 45% The CSR Committee shall have the authority to review the allocations from time to time, with respect to any financial year/s, and may at its discretion authorise one/more officers to exercise such authority. DETAILS OF THRUST AREAS FOR IMPLEMENTATION The Company has already undertaken and/or shall undertake in terms of this Policy, CSR activities, in one or more areas, as follows:- In Education, the endeavour is to spark the desire for learning and knowledge at every stage through schools graduations higher education underprivileged children s education sponsorship of vocational training programmes generally all types of literacy skill development projects. In Environment the aim is to monitor and conserve water and electricity used across project sites of the Company create awareness towards environment and resources conservation green initiatives projects having integrated environment protection plantation of trees and others. In Health care the goal is to render quality health care facilities {preventive and curative} to people living in the villages and elsewhere, particularly weaker sections of the society, old age persons and women Primary health care centres immunization programmes with a thrust on polio eradication programmes to address malnutrition preventive health care through awareness programmes blood donation camps provision of health facilities to poor people eye camps. In Housing for Economically Weaker Section of the Society {EWS} & old age persons the effort is to allot plots to them in townships of the Company through open public lottery system at highly subsidized rates with easy interest free instalments donation to establish senior citizen s home and providing free technical and engineering support for building construction of roads sanitation facilities. In Promotion & protection of culture/ literature the aim is to encourage literature Hindi and other regional language authors provide opportunity for authors institute annual award to honour and felicitate the authors promote

ethics, principles and the philosophy of spiritualism and religious inclinations in the society donations to temples & spiritual learning centre. In Rural Developments the endeavour is adoption of villages connected to project sites of the Company ensuring healthy and secured childhood for children through quality day care programmes aimed at holistic development creating conducive conditions for women to work at the Company s project sites by providing them the necessary day care support for their children & crèche providing opportunities for basic schooling skills vocational training for women to make them economically self reliant development of road work, sewer line, electrification work creation of awareness & confidence to resist social taboos & instil self help. SCHEDULES OF IMPLEMENTATION OF THRUST AREAS shall be reviewed by the CSR Committee and the Board of the Company, from time to time. MONITORING & REPORTING FRAMEWORK There shall be three levels of monitoring and review to be undertaken for CSR activities:- Level {1}: Identified Local officers, at the project levels, who shall be entrusted with the responsibility of implementation, shall give monthly reporting to Level {2}. Level {2}: Identified Senior Officers at the project levels who shall be entrusted with the responsibility shall review the progress, effectiveness action plans and support. They shall give quarterly reporting to Level {3}. Level {3}: CSR Committee shall review on a half yearly basis and the Board shall review on an annual basis. INFORMATION DISSEMINATION The Company s engagement in this domain shall be disseminated in its website, Annual Reports, internal communications and through the media, wherever required. 11 th February, 2015 Sushil Ansal {Chairman}

Annexure -I Existing CSR Activities Ansal API group through its various trusts and foundations, is already engaged in social and philanthropic causes since long. Particulars of existing CSR activities are as follows: Healthcare Health Centre in Kalkaji, Delhi this centre provides free preventive and curative health care to more than 1000 poor families living in vicinity. Vocational Training centre for teaching income generating skills to women such as tailoring, designing and embroidery etc. Hansraj Government Hospital, Kahma Village, Punjab providing medical support to residents of all nearby villages alongwith organizing specialized eye camps on periodic basis. Community Welfare Ansal API strongly believes in contributing to and investing in communities in and around its project sites. Under this endeavour, several initiatives have made a lasting impact on the economic, environmental and social conditions of local people. Some such initiatives are: Community Development In association with Humana People to People India we have implemented programs like forming and training women self help groups, conducting literacy enhancement workshops, health checkup camps, Sports Events and skill development training. Rural Development Infrastructure related works like Road Work, Water Supply, Sewer Line & Drainage, Hand Pumps, Primary School Development and Electrification work etc. done in 11 villages in Lucknow. Chiranjiv Karam Bhoomi A home for senior citizens in Palam Vihar, Gurgaon. Education Adult Literacy Centre operated at labour camps near Lodhi Colony and Sewa Nagar. Chiranjiv Bharti Schools K-12 Schools operating in Palam Vihar and Sushant Lok, Gurgaon.Several new schools are under planning stage. (Schools are operational under Chiranjiv Charitable Trust)

Ansal University, Gurgaon - offering undergraduate and postgraduate courses in various disciplines like Management, Engineering & Technology, Art & Architecture, Design, Law etc. Ansal Institute of Technology & Management, Lucknow affiliated to Gautam Buddh Technical University; It is one of premier institution in field of technical and management education. (It is operational under Sushil Ansal Foundation) Promotion of Indian languages and Literacy activities Kusumanjali Sahitya Samaan Two awards are given every year to creative works in genres of literature comprising fiction, short story, poetry and drama. Kusumanjali Fellowship Scheme for creative Writers in Hindi to promote, support and facilitate the writing of good literary works. Samvaad This is a platform for creative writers of all Indian languages where literary works are discussed, analyzed and expressed. Religious Activities Ansal API group has built portion of Chattarpur Temple in New Delhi and Sheetla Mata Mandir in Gurgaon. Donated five acre land to ISKCON at Lucknow where a spiritual learning centre and temple is under construction. Ansal Diya Foundation Serve various philanthropic and charitable activities in the field of education, healthcare, diagnostics, medical, spiritual centre, scientific research, housing and providing food for the poor etc. to benefit the downtrodden and poor people of the country. Currently APIL group is supporting DIYA Foundation for promoting education, literacy and skill development. Resources Conservation Ansal API group recognizes the correlation of business sustainability with resources management and is committed to monitor and conserve the amount of water and electricity used across its project sites at the time of construction. In order to create awareness amongst employees towards environment and resources conservation, your Company organises various camps and has been anchoring green initiatives on a regular basis. The projects of your Company have integrated environment protection, up gradation, conservation, water harvesting, etc. and plantation of trees etc. as a part of the sustainable development.

Housing for Economically Weaker Sections (EWS) of the Society More than three thousand plots for Economically Weaker Sections of the society, in townships of the Company, in the process of development. The plots were allotted through open public lottery system at highly subsidized rates with easy interest free instalments. More than 3000 affordable homes are being developed in the projects in Uttar Pradesh and Rajasthan and it is also proposed to further add to above tally of dwelling units in the affordable housing category in the next few years. Senior Citizen Home A plot of 1000 sq. m. has long since been donated to establish a Senior Citizen s Home in Palam Vihar, Gurgaon. Free technical and engineering support was provided to build this home called Chiranjiv Karam Bhoomi. Several senior citizens have been and are staying in this home which is being run by Divya Chaya Trust comprising Smt. Kusum Ansal and other members of the Trust.