Corporate Social Responsibility Policy

Introduction & Objective

The Corporate Social Responsibility Policy (“the CSR Policy”) outlines the developmental areas in which Judge India Solutions Private Limited (“the Company/Judge India Solutions/we/us/our”) shall get involved through its CSR activities. The policy defines governance structure for CSR implementation and serves as a guiding document aiding in the identification, execution, and monitoring the CSR projects and will be applicable as per the provisions of the Companies Act 2013.

Scope

This Policy has been framed by Judge India Solutions and applies to all CSR projects that will be undertaken by Judge India Solutions and shall fulfill the requirements of the provisions of Section 135 of the Companies Act, 2013 (“the Act”) and Companies (Corporate Social Responsibility Policy) Rules, 2014 (“CSR rules”) including any notifications, circulars, amendments, order issued by concerned authority or statutory modifications or reenactment(s) thereof for the time being in force. Judge India Solutions shall ensure all these activities are in line with Schedule VII of the Companies Act, 2013. This Policy will be periodically reviewed and updated in line with the relevant codes of legislation and best practices that can be adopted. Unless the context otherwise requires, the definitions mentioned in the notification dated February 27, 2014, and such other notifications, circulars, amendments, and orders issued by the Ministry of Corporate Affairs in this regard and Companies Act 2013, shall apply to this CSR Policy. Judge India Solutions is guided by its core values that is adopted at The Judge Group level. The CSR Policy is in alignment with its core values and is central to its CSR strategy. Being accountable for what we do, implies the company strongly believes that it is accountable for contributing back in a meaningful way to society. For the execution of its CSR objectives and to make a positive impact with its CSR activities, Judge India Solutions desires to involve its employees to create a sense of involvement and bring about social responsibility amongst them. Wherever necessary, the company will partner and collaborate with NGOs / other similar organizations that have experience, knowledge, and a wider reach to meet its CSR objectives.

Areas of Focus:

Under to Schedule VII of the Companies Act, 2013, the board of directors “(board”), in compliance with sub-section (9) of Section 135, has reviewed and approved the following activities as “CSR Activities” to be undertaken under the CSR policy of the Company. Without prejudice to the generality of the aforesaid, the Company may from time to time undertake any project, program and activity in one or more of the following areas:

1. Education: Promoting education, including special education and employment enhancing vocation skills especially, among lower strata or poorer sections of the society or the differently abled adults or eligible children towards their livelihood enhancement projects.
2. Environmental Sustainability: Ensuring environmental sustainability ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining the quality of soil, air, and water.
3. Gender Equality: Promoting gender equality and empowering women.
4. Health and Welfare.
   • Eradicating hunger, poverty, and malnutrition, promoting preventive health care and sanitation, and making available safe drinking water.
   • Training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic sports.
   • Organizing Health camps.
5. Communities: Recognizing our responsibility to the communities in which the company makes an impact, we will identify programs where we can effectively give back to people and invest in the long-term support of wider disadvantaged parts of society. This could mean providing financial support to community investment programs, capacity building or volunteering work through our employees.

Governance Structure & CSR Committee:

A governance structure at Judge India Solutions is responsible for implementing and monitoring CSR Policy. Under the provisions of Section 135 of the Companies Act, 2013 and the rules made thereunder, the Board of Directors is ultimately accountable for the CSR projects undertaken by the Organization. Subject to provisions of the Act and rules made thereunder, a CSR committee will be formed if required. The board will discharge all the functions required to be discharged by the Corporate Social Responsibility Committee. Below is the composition of Board of Director ("Board"): The Board of Judge India Solutions shall have, inter alia, the following roles, powers, and responsibility:

• Formulation of CSR Policy.
• Approve various CSR projects, programs, and activities to be undertaken from time to time either directly by the Company or through other entities.
• Authorize and approve CSR expenditures from time to time.
• Monitor implementation of CSR Policy.
• Modifications to CSR Policy as and when required.
• Review of CSR activities in the Company.
• Appraise to the Board the CSR expenditure done during the year.
• Carry out all such acts, deeds, matters and things as may be required in connection with aforesaid matters and generally for any matter connected with the CSR policy of the Company.

CSR Team:

A dedicated CSR team would be constituted from among the employees at Judge India Solutions, for implementing the CSR Policy and shall work under the guidance of the CSR Committee or Board, as may be applicable and will be mainly responsible for:

• Execution of CSR Policy.
• Identify and develop projects and key initiatives pursuant to CSR Policy in the CSR Annual Plan.
• Facilitating allocation of funds to the projects as identified for CSR activities.
• Monitoring CSR Projects to establish effectiveness of CSR efforts and appraise the same to the CSR Committee or Board, as may be applicable.
• Compilation of information & preparation of Annual Reports on CSR activities and presenting the same to the CSR Committee or Board, as may be applicable.
• Any other activity necessary to ensure achievement of CSR objectives.

CSR Budget:

The total budget for the CSR projects in each financial year will be decided by the CSR Committee or Board, as may be applicable in accordance with applicable provisions of the Act i.e., at least 2% of the average net profit made during the immediate three preceding financial years and the CSR Rules. The CSR Committee or Board, as may be applicable shall propose to distribute the budget among the Areas to Focus or such of them as the Board may deem fit in each financial year, in such proportion and in a manner that meets the objectives of the CSR Policy. For any reason, if the Company is not able to follow the allocation agreed on in any of the areas to focus described above, the same shall be utilized in such other areas to focus as the CSR team may recommend with the reasons therefore, and the Board may approve. Any surplus arising out of CSR activities will be utilized only for CSR purposes. Any amount exceeding the earmarked budget/fund of CSR or any unspent amount which the Company fails to spend the earmarked funds on its CSR activities shall be accounted for, transferred, set-off or treated as per the provisions of the Act.

CSR Monitoring:

Milestones will be decided for every project/activity undertaken, and the progress will be evaluated against the milestones defined in the implementation plan for each project/activity. The Board will monitor the implementation and progress of the approved projects through appropriate mechanisms such as site visits, review meetings and progress reports etc. Judge India Solutions will establish mechanisms to track data and monitor projects so that the CSR projects undertaken are implemented transparently and efficiently.

CSR Reporting:

The Board, based on reports of CSR Projects will annually publish report on the CSR projects as a part of the Director’s report. The report will disclose information in the format as prescribed by the Act. The Board shall also submit a responsibility statement that the implementation and monitoring of the CSR Policy is in compliance with the approved Corporate Social Responsibility Policy. The approved CSR Policy shall remain displayed on the website of Judge India Solutions and any modifications carried out from time to time shall also be updated on the website.