OCS Corporate Social Responsibility Policy

Short title & Applicability

OCS SERVICES (INDIA) PRIVATE LIMITED (the ‘Company’) has developed its Corporate Social Responsibility Policy (the ‘Policy’) in accordance with section 135 of the Companies Act 2013 and the rules made there under.

This policy encompasses the company’s commitment to create large environmental and societal value as a corporate citizen and lays down the guidelines and mechanism for undertaking socially useful programs for the welfare & sustainable development to the community at large.

The Policy shall apply to all CSR programs of the Company.

CSR Vision Statement

The core vision of the Company’s CSR policy is to create a meaningful and a lasting contribution to the society from which it draws its resources by extending helping hand to the needy and the underprivileged through social projects.

Corporate Social Responsibility is the commitment of business to contribute for economic development that is sustainable, facilitating greater and more inclusive prosperity. It is the contribution of the corporate sector for philanthropic causes like education, health, water, environment and community welfare.

CSR Objectives

The main objective of the CSR Policy is to lay down guidelines for the Company to make CSR as one of the key focus areas to adhere to company’s global interest in environment and society that focuses on making a positive contribution to society through effective impact and sustainable development programs.

This Policy covers the proposed CSR activities to be undertaken by the Company and ensuring that they are in line 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 strategy that defines plans for future CSR activities.

Validity of CSR Policy

The Board may amend the CSR policy as may be required from time to time.

CSR Programme Areas

The Company will focus primarily on the following programs:

• Contributing to projects for eradication of hunger, poverty and malnutrition.
• Undertake projects promoting healthcare including preventive health care and sanitation.
• Promoting education including special education and employment enhancing vocation skills, and livelihood enhancement projects either directly by the company or by funding Non-Government Organizations (NGO’s) / educational institutions / trusts/ organizations involved in promotion of education.
• Ensuring environmental sustainability and ecological balance by contributing to projects relating to protection of environment, agro forestry, conservation of natural resources etc.
• Contribution to the Prime Minister’s National Relief Fund, Prime Minister’s Central assistance and relief in emergency situations Fund (PM CARES Fund) or any other fund set up by the Central Government for socio economic development.

The CSR committee is authorized to consider also other CSR activities which are not included in this list.

CSR Budget

The Board shall ensure that the company spends at least 2% of its average Net Profits calculated as per Sec-198 of the Companies Act, 2013, as its Annual CSR Budget in each Financial Year to be incurred on identified areas.

Allocation of the Annual Budget for CSR activities in any given year shall be as per the provisions of the Companies Act 2013 and rules made thereof as amended from time to time.

Failure to spend the CSR Money

If the Company fails to spend the required amount in a particular financial year, it is the duty of the Committee to 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 Annual Report pertaining to that particular Financial Year. Surplus, if any, arising out of the CSR projects or programs or activities shall not form part of the business profit of the Company.

Implementation Process

• The Company’s projects will be implemented in a time-bound manner with clear objectives, plan, targets and robust monitoring and evaluation mechanisms.
• The Company’s ongoing CSR projects will be aligned to the Policy.
• The mode of implementation of project activities identified under CSR include a combination of direct implementation by the Company under Approved Projects or through specialized agencies, which could include the Trust of the Company, Voluntary Organizations (NGO’s), Recognized Institutes /Academic Institutions, Trusts, Registered Societies, Business Partners, Self Help Groups, Mahila Mandals, Professional Consultancy organization etc.
• For CSR projects, the time-frame and periodic milestones should be finalized at the time of approval of the Project.
• The Company will use services of expert agencies, consultancy firms etc. wherever required for carrying out base line surveys, guidance on project design and implementation, impact assessment surveys etc.
• For CSR projects, the time-frame and periodic milestones should be finalized at the time of approval of the Project.
• The heads of the respective teams managing CSR projects will be authorised to sign memorandum of understanding (MOUs)/ Agreements with the implementing partners after taking approvals.

Roles and responsibilities

The Board:

The Board of Directors of the Company will be responsible for:

• Approval of the CSR Policy of the Company.
• Disclosing the content of the Policy in its report and place the Policy on the Company’s website in such a manner as prescribed under Section 135 of the Companies Act 2013 read with the CSR Rules.
• Ensuring that the social projects included in the Policy are undertaken by the Company.
• Ensuring that the Company spends, in every financial year, at least 2% of the average net profits of the Company made during the three immediately preceding financial years in pursuance of the Policy.
• Ensuring that it specifies the reasons in its report for not spending the earmarked amount in case the Company fails to spend such amount.

CSR Committee:

Composition of the CSR committee:

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 which must consist of at least two or more Directors. Accordingly, the composition of the CSR Committee of the Board is as under:

1. Mr. Uday Gurunath, Director
2. Mr. Hitesh Reshamwala, Director

The Board shall have the power to make any change(s) in the constitution of the Committee.

CSR Committee Meeting:

For smooth functioning of the Committee, the members shall meet as below to discuss such matters and to take such decisions as may be necessary;

• The CSR Committee shall hold meetings as and when required.
• The members of the Committee may mutually agree between them regarding time and place for the said meetings.
• The quorum for the CSR Committee Meeting shall be one-third of its total strength (any fraction contained in that one-third be rounded off as one) or two members, whichever is higher.
• The Members of the Committee may participate in the meeting either in person or through video conferencing or other audio visual means as may be convenient.

CSR Contribution Guidelines:

The Committee shall review and recommend for approval to the Board of Directors the eligible projects basis the following broad guidelines with respect to budget allocation:

1. Contributing to projects for eradication of hunger, poverty and malnutrition – 50%
2. Promoting education including special education and employment enhancing vocation skills – 30%
3. Ensuring environmental sustainability and ecological balance – 10%
4. Projects promoting healthcare including preventive health care and sanitation – 10%

However, based on the recommendations of the Committee, the Board may vary the allocation percentage and type of projects and the Committee shall accordingly execute the same

Responsibility of CSR Committee:

• Formulate and recommend the CSR Policy to the Board for approval. The Committee shall indicate the projects to be undertaken by the Company as specified in Schedule VII.
• Monitor the Policy from time to time and recommend changes to the Board.
• Recommend the amount of expenditure to be incurred on CSR projects.
• Institute a transparent monitoring mechanism for ensuring implementation of the social projects undertaken by the Company.
• To monitor the execution of the approved CSR projects in timely manner and in compliance of law.
• Any CSR expenditure incurred prior to approval of the Board shall be promptly notified to the Board for ratification along with reasons.

Monitoring and Reporting

Project monitoring

The Company will institute a well-defined monitoring and evaluation mechanism to ensure that each social project has:

• Clear objectives developed out of the societal needs that are determined through baseline studies and research.
• Clear targets, time lines and measureable parameters wherever possible.
• A progress monitoring and reporting framework that is aligned with the requirements of section 135 of the Companies Act and the CSR Rules.

The CSR progress monitoring authorities and the frequency of review is given below.

Budget monitoring:

The Company will establish an accounting system to ensure project wise accounting of CSR spends.

Reporting framework:

• The Company will monitor progress on CSR projects and CSR spend and report to the CSR Committee of the Board of Directors quarterly.
• The Company will report CSR performance in its annual report as per the structure and format prescribed in the notified CSR Rules.

Conclusion

The CSR Committee of the Board of Directors is the sole authority to review and recommend to the Board on the CSR projects to be undertaken and the expenditure. The management team of the Company, including business and function heads, should not approve and/or incur any expenditure in relation to CSR projects prior to proposing such projects to the CSR Committee of the Board of Directors and obtaining their approval.

In case of any doubt with regard to any provision(s) of the policy, a reference can be made to CSR Committee of Board of Directors. In all such matters, the interpretation & decision of the CSR committee of the Board of Directors shall be final.

Any or all provisions of the CSR Policy would be subject to revision/amendment in accordance with the guidelines as may be issued by Government, from time to time.

The Board will review the policy from time to time based on changing needs and aspirations of the target beneficiaries and make suitable modifications, as may be necessary.

Adopted in the Board Meeting dated August 18, 2025.

Composition of OCS Services (India) Private Limited CSR Committee:

OCS Services (India) Private Limited

CSR Projects Approved by the Board in F.Y. 2025-26