CORPORATE SOCIAL RESPONSIBILITY POLICY

In pursuant to section 135 of the Companies Act, 2013 (“the Act”) and the Companies (Corporate Social Responsibility Policy) Rules, 2014 (“the Rules”) framed thereunder (including any statutory modification(s), re-enactment thereof, for the time being in force), Circulars, FAQs and Guidelines framed thereunder on this behalf, “Corporate Social Responsibility (CSR)” is a company’s commitment to contribute and operate in an economically, socially and environmentally sustainable manner.

The Policy outlines the Company’s responsibility as a corporate citizen and lays down the guidelines and mechanism for undertaking activities for welfare and sustainable development of the community at large.

Your Company has always adhered to its “Corporate Social Responsibility” (CSR) as one of it’s commitments to the society. “Impacting the community by its actions to save mother nature, supporting social needs, promoting tourism & green living” are idiosyncratically the mantras of MAYFAIR Hotels & Resorts. Towards achieving this, the Company has been a pioneer in setting benchmark standards through its various CSR initiatives which promote its objectives to make the world greener and environmentally friendly. Since, last six years, your company recognized its responsibility to give back to the community and people. The needs of local community are addressed by your company through various welfare activities such as setting up old age homes, promoting healthcare facilities, developing rural infrastructure, planting trees, promoting hygiene and cleanliness etc. Your Company has adopted a CSR Policy indicating the broad philosophy and objectives, which is available on the website of your Company viz www.mayfairhotels.com .

The core element of CSR is the continuing commitment by business to ethical principles, protection of human rights, care for the environment while improving the quality of life of all the stakeholders including the local community and society at large.

It is Company’s conscious strategy to design and implement Social Investments / CSR programs, by enriching value chains that encompass the disadvantaged sections of society, especially those residing in rural India, and to operate by upliftment of the local communities by providing livelihood and other means.

Among the activities covered under the Schedule VII of the Companies Act 2013, which can be considered under the Company’s CSR policies, below are mentioned some of the broad outlines for choosing the Activities. the company is inclined towards Rural Development Projects as one major area for CSR programs. Efforts for improving the lives of rural populations in terms of access to basic facilities like education, healthcare, sanitation, livelihoods, water availability, agricultural improvement etc. are some key focus areas.

a) The Company’s commitment to CSR projects will be by deploying resources into any of the activities broadly mentioned in Schedule-I to this policy.

b) Without prejudice to the scope of activities mentioned in Schedule-I, the following activities may also be carried out by the Company, if it deems fit

- Curative health care, surgery, eye donation camps, skin donation camps, blood donation activities, therapy camps, dental camps, acupressure camps, cataract camps etc.
- To participate in building a healthy community through continuing initiatives in several areas of healthcare, with a focus on mother and child care and HIV/AIDS awareness.
- Literacy/ Awareness programmes and activities in various social and well-being areas.
- Furtherance and promotion of the practice of alternative Indian traditional medical practices such as homoeopathy, ayurvedic, Siddha, naturopathy and yoga therapies, for the benefit of the community at large.
- Disaster management activities and relief to victims of natural calamities.
- Activities relating to irrigation, wells, dams etc. for improving the livelihood of farmers and agriculturists.
- Promotion of nationally recognized sports (not only training).
- Infrastructure activities, essentially for helping the poor and the needy.

c) Following activities will not be included in the list of CSR Activities unless specifically permitted by Regulatory Authority:
- Activities undertaken in pursuance of the normal course of business of the Company.
- Any activity undertaken by the company outside India except for training of Indian sports personnel representing any State or Union territory at national level or India at International level
- Contribution of any amount directly or indirectly to any political party under section 182 of the Act
- Activities benefitting employees of the company as defined in section 2(k) of the Code on Wages, 2019
- Activities supported by the companies on a sponsorship basis for deriving marketing benefits for its products or services
- Activities carried out for the fulfilment of any other statutory obligations under any law in force in India
- Any other activity specifically restricted by relevant Regulatory / Government authorities from time to time.

(a) CSR Committee:

The Company has duly constituted a CSR Committee of the Board consisting of the following Members

a) Mrs. Pooja Ray, Managing Director
b) Mr. Sidhartha Pradhan, Independent Director
c) Mr. Mrutyunjay Mahapatra, Independent Director
d) CA Manoja Kumar Gouda, President & Whole-time Director.

(b) CSR Implementation:

The Company’s CSR projects and programmes will be undertaken by the Company by itself or through –

- A Company established under section 8 of Companies Act, 2013
- A Registered public trust registered under section 12A and 80 G of the Income Tax Act, 1961
- A Registered society registered under section 12A and 80 G of the Income Tax Act, 1961
- 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
- Any entity established under an Act of Parliament or a State legislature
- 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 has an established track record of at least three years in undertaking similar activities
- Either singly or jointly through collaborative efforts of other MAYFAIR Group/ Associate Companies and CSR committees of such company shall report separately on such projects or programmes in accordance with the prescribed CSR Rules.

The company may engage international organizations for designing, monitoring and evaluating of the CSR projects or programmes as well as for capacity building of their own personnel for CSR.

If any donation/ contribution is to be given to any other entity as specified above for CSR activity, preference will be given to such entities having a track record in undertaking similar programs or projects.

Further, in such case, the Company will take prior approval of the CSR Committee by specifying the project or programme to be undertaken through these entities, the modalities of utilization of funds on such projects or programs, the monitoring & reporting mechanism and such other information that the Committee may require.

As required by the Companies Act 2013 and applicable rules, any CSR project taken up through any entity and not directly shall only be through entities registered with the Ministry of Corporate Affairs, Government of India for undertaking CSR activities, unless specifically exempted or otherwise.

(c) Annual Action Plan

The CSR Committee shall formulate and recommend to the Board, an annual action plan in pursuance of this policy, which shall include the following, namely List of CSR Projects approved to be undertaken

- Manner of execution of such projects or programmes
- Modalities of utilisation of funds and implementation schedules
- Monitoring and reporting mechanism for the projects or programmes
- Details of need and impact assessment, if any, for the projects undertaken by the company

The Board can alter the annual action plan at any time during the financial year as per the recommendation of the CSR committee, based on the reasonable justification to that effect.

(a) Release of funds for CSR Project / Programme

The amount sanctioned for a CSR project or programme shall be released in stages or instalments as per progress, as may be determined by the CSR Committee. CSR Committee may design the procedure/ guidelines applicable from time to time and release of funds to any project in a year shall be as per the Annual Action Plan.

Every financial year, with the approval of the Board of Directors, Company will make a budgetary allocation for CSR activities/projects for that financial year. The budgetary allocation will be based on the net profit of the company, which shall not be less than 2% of the average net profits of the last three Financial Years before tax of the company (CSR Budget).

Any surplus arising out of the CSR Activities shall not form part of business profit and shall be ploughed back into the Project.

Surplus funds shall be utilized for the same project or shall be transferred to the Unspent CSR Account and spent in pursuance to CSR policy/ annual action plan or transfer to fund specified in Schedule VII within 6 months from the end of FY.

Administrative expense shall not exceed 5% of the total CSR expenditure of the company for every financial year.

(b) Unspent CSR Amount

The Company Shall transfer the Unspent CSR Amount which does not relate to any ongoing project to a Fund notified under Schedule VII within 6 months from the end of the Financial Year and also disclose the reasons for not fully utilizing the budget allocated for CSR activities planned each financial year and shall comply with the other provisions of Companies Act, 2013 as may be applicable with regards to the unspent amount of CSR budget.

Unspent CSR Amounts relating to any ongoing project shall be transferred to a special account “Unspent CSR Account” opened with any Scheduled Bank within 30 days from the end of the Financial Year. Such amount shall be spent within three Financial Years from the date of such transfer. If not, the company shall transfer it within 30 days from the date of completion of the Third FY to the National Unspent CSR Fund/created by the Central Government for activities specified in Schedule VII or any fund as specified in schedule VII of the Act.

d) Capital Assets

CSR Amount may be spent by the company for creation or acquisition of capital assets. The CSR asset to be held by a Section 8 Company, or Registered Public Trust, or registered society with charitable objects, having CSR registration number or beneficiaries of the said CSR project, in the form of self-help groups, collectives, entities or a public authority

(e) CSR Reporting

Boards Report of a company shall include an annual report on CSR in the prescribed format required by the Companies Act 2013 and applicable rules.

In case, if company is having the obligation of spending average CSR amount of Rs 10 Crores or more in the three immediately preceding financial years in pursuance of Section 135(5) of the Act, then Board shall be provided with impact assessment report done by an independent agency.

Impact assessment to be done in respect of 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 shall be placed before the Board and shall be annexed to the annual report on CSR.

Impact assessment expenditure for a financial year shall not exceed five percent of the total CSR expenditure for that financial year or fifty lakh rupees, whichever is less.

Website Disclosure

The Company shall disclose the information related to Composition of the CSR Committee, CSR policy and Projects approved by the Board on their website

The CSR Policy referred to above is to be read in conjunction with Companies Act, 2013 and Companies (Corporate Social Responsibility Policy) Rules, 2014 as amended from time to time.

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 the Government from time to time or as decided by the Board of Directors of the Company.

The above Policy Guidelines are subject to review / revision at suitable intervals.

In the event of any conflict between the provisions of this policy and the applicable laws, the later shall prevail.

Schedule I to CSR Policy

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 recognized sports, Paralympic sports and Olympic sports

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 Defence Research and Development Organisation (DRDO);

- Indian Council of Agricultural Research (ICAR);

- Indian Council of Medical Research (ICMR)

- 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

Disaster management, including relief, rehabilitation and reconstruction activities.

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;

Slum area development, Slum area shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force

Contribution made to State Disaster Management Authority to combat COVID-19

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;

Any other activity which is relatable to and captures the essence of the subject enumerated in the Schedule VII of the Companies Act, 2013

Any other Activity which is specifically included / allowed under Schedule VII of the Companies Act, 2013 or any other applicable statutory provisions by way of amendment / statutory modification(s) / re-enactment from time to time.

This policy was amended and approved by the Board of Directors of the Company on November 13, 2021