It is recognized that integrating social, environmental and ethical responsibilities into the governance of businesses ensures the long-term success, competitiveness and sustainability.

Further, CSR makes a business sense as companies with effective CSR, have image of socially responsible companies, achieve sustainable growth in their operations in the long run and their products and services are preferred by customers.

The main objective of CSR policy is to make CSR a key business process for sustainable development of the society. Thermo Group will act as a good corporate citizen and aims at supplementing the role of Government in enhancing the welfare measures of the society within the framework of its policy.

As per the requirements under the Companies Act 2013, the CSR activities of the Thermo Cables Pvt Ltd would include, but not limited to

• Promotion of Health care especially preventive health care and sanitation
• Promotion of Education especially employment enhancing vocation skills, and
• livelihood enhancement Projects
• Rural Development Projects
• Promotion of gender equality, empowering women, and measures for reducing
• Inequalities faced by socially and economically backward groups
• Promotion and training for Sports
• Corporate Social Responsibility Policy
• Slum area development in areas designated by competent Authorities
• Disaster Management including for relief, rehabilitation, and reconstruction

The CSR activities will be focused in the geographic areas with presence of the Thermo Group Offices, or in proximity to manufacturing units of the Thermo Group. This is intended to enable not only the engagement of the employees but also to embrace responsibility for the Company’s actions and encourage positive impact.

Beyond this, the CSR Committee would, from time to time, decide the location of the Projects based on the community needs, developmental issues needing attention, availability of credible local partners and so on.

The CSR activities may be undertaken through a registered trust or a registered society or a company established by the company or its holding or subsidiary or associate company pursuant to Section 135 of the Companies Act, 2013 and rules made there-under.

Accordingly, the Sri Ram Charitable Trust (TS/2018/0215965- Darpan Registration) would be the main implementation agency. Additionally, partnerships with government, local stakeholders, NGOs, like – minded individuals and other organizations which similar objectives would help in extended outreach and coverage in terms of not only geography but also, diversity of expertise.

The CSR activities shall be undertaken by Thermo Cables Pvt Ltd as stated in this Policy, as projects or programs or activities (either new or ongoing), excluding activities undertaken in pursuance of its normal course of business.

The CSR activities which are exclusively for the benefit of Thermo Cables Pvt Ltd employees or their family members shall not be considered as CSR activity.

The CSR Committee is composed of –

1. Uma Ghurka (Chairperson)

2. NK Ghurka (Member)

• To formulate and recommend to the Board, a CSR Policy which would indicate the activities to be undertaken as specified in Schedule VII of the Act.
• To recommend the amount of the expenditure to be incurred on the activities undertaken in pursuance of the on policy.
• To Institute a transparent monitoring mechanism for implementation of the CSR projects or programs or activities undertaken by the company.
• To monitor the CSR policy of the company from time to time.

The Board of the company would, after taking into account the recommendations made by the CSR Committee, approve the policy for the company and disclose contents of such Policy in its report and also place it on the company’s website and ensure that the activities as are included in the CSR Policy of the company are undertaken by the company.

Thermo Cables Pvt Ltd, would predominantly undertake implementation through the SRCT, as well as continue to receive requests for financial assistance for implementation by other like- minded individuals, local stakeholders like Panchayats, Self- Help Groups, , NGOs etc. Employee contributions would be matched by the Thermo Cables Pvt Ltd, as much as partner with other Organizations to solicit traditional & new avenues of funding for maximizing the impact.

A specific budget is allocated for CSR activities and spending on CSR activities shall be 2% of the average net profits of the Company made during the three immediately preceding financial years, in pursuance of this policy.

In case Company fails to spend such amount, the Board shall specify the reasons for not spending the amount.

Approving authority for the CSR amount to be spent would be any one Director or the Managing Director or VP (F)/Chief Financial Officer of the Company after due recommendation of CSR Committee and approval of the Board of Directors of the Company.

The CSR Policy mandates that the surplus arising out of the CSR projects or programs or activities shall not form part of the business profit of a company.

The CSR projects or programs or activities undertaken in India only shall amount to CSR expenditure.

CSR expenditure shall include all expenditure including contribution to corpus, for projects or programs relating to CSR activities approved by the Board on the recommendation of the CSR Committee, but does not include any expenditure on any item not in conformity or not in line with activities which fall within the purview of Schedule VII of the Companies Act 2013.

Prior to the commencement of CSR activities/projects, a situational analysis / study of the proposed area may be conducted as appropriate.

The study encompasses various parameters such as – health indicators, literacy levels, sustainable livelihood processes, and population data – below the poverty line and above the poverty line, state of infrastructure, among others.

From the data generated, a 1-year plan and a 5-year rolling plan may be developed.

To measure the impact of the work done, appropriate methodologies like satisfaction surveys, audits, community feedback systems etc may be carried out.

All activities/projects of CSR would be assessed under the agreed strategy, and are monitored every quarter/year, measured against targets and budgets. Wherever necessary, midcourse corrections would be made.

The Company’s engagement in this domain is disseminated on the website, annual reports and its house journals as and when deem fit.