Corporate Social Responsibility Policy

1.1 Preamble

Jubilant MotorWorks Private Limited (the “Company”) a company incorporated in the year 2009
is the automobile vertical of the Jubilant Bhartia Group. Since inception JMPL has created one of
the country’s largest and most successful luxury auto retail companies by embracing and
introducing high quality management practices in the auto retail sector. The Company has a huge
presence in Southern and Western India and has chartered a growth plan to becoming India’s
largest and the most admired Auto Retail company through organic growth and acquisitions.
The Company is engaged in various social initiatives across the country. In order to provide
further impetus to the social interventions and make the entire process and activities more
impact driven, it is imperative to outline the guidelines on the Corporate Social Responsibility
into a policy pursuant to the provisions of the Companies Act, 2013 (the “Act”) read with the
Companies (Corporate Social Responsibility Policy) Rules, 2014 (the “CSR Rules”).

1.2 Definitions and Interpretations

“Board” means the Board of Directors of the Company.

“CSR Activities” means such programs and projects as may be approved by the Board in terms
of the CSR Policy, from time to time. The current programs and projects identified by the Board
are listed in Annexure I to this CSR Policy.

“CSR Expenditure Budgeted” means the amount approved by the Board from time to time, to
be incurred on the CSR Activities in India in a financial year in terms of Section 135 of the Act and
the CSR Rules. CSR expenditure will include all expenditure incurred by the Company on CSR
Programmes undertaken in accordance with the approved Annual Action Plan.

“Annual Action Plan” will include the list of CSR projects or programmes that are approved to
be undertaken in areas or subjects specified in Schedule VII to the Act, the manner of execution
of such projects or programmes, modalities of utilisation of the CSR funds and implementation
schedules for the projects or programmes, monitoring and reporting mechanism for the projects
or programmes and details of need and impact assessment for the projects undertaken by the
Company. The Board shall approve the Annual Action Plan including any alteration thereto.

“Ongoing Projects” means projects that have a multi-year implementation focus but not having
timelines exceeding three years excluding the financial year in which it commences. The Board
may also designate some of the existing CSR projects as Ongoing Projects and such Ongoing
Projects shall be selected, implemented, monitored and reported in accordance with the
applicable CSR Provisions.
Any term used but not defined in this CSR Policy shall have the meaning assigned to it under the
Act or the CSR Rules.

1.3 Title and Scope

This Policy:

I. shall be called the “Corporate Social Responsibility Policy” or “CSR Policy” of the Company
which is developed and implemented in accordance with the provisions of Section 135 of
the Act read with the CSR Rules.

II. outlines the Company’s philosophy and responsibility and lays down the guidelines and
mechanism for undertaking socially impactful programs towards welfare and sustainable
development of the community around the area of its operations and other parts of the
country.

III. shall be applicable to all CSR Activities taken up by the Company at various locations in India
for the benefit of different segment of the society at large, specifically the deprived and
underprivileged segment.

Corporate Social Responsibility is the commitment of businesses to contribute to sustainable
economic development by working with the employees, their families, the local community and
the society at large to improve their lives in ways that are good for business and for its
development.

2.1 Vision

To follow global progression in the concept of Corporate Social Responsibility and its
implementations by way of being beneficial to our society and the corporations to which we
render services.
To ensure benefit to society and to the corporation for sustainable development by imparting
measurable values to all stakeholders in every aspect of our operations.
Ensuring Corporate Social Responsibility is adopted through principled implementations that
contribute to our country’s social, cultural, and environmental development and help in
developing awareness on these issues.

2.2 Mission & Purpose

To work on the popularity, adoption, and implementation of the concept of Corporate Social
Responsibility while adding measurable values tothe community and to our corporation along
with managing related processes to the advantage of all concerned in a way that becomes
model for other corporations for replication,to further expand the scope.

2.3 Objectives

The CSR Policy is laid down by the Company to ensure that the:

• CSR agenda is integrated with the business.
• Focussed efforts are made in the identified community development areas to achieve the
expected outcomes.
• Support in nation building and bringing inclusive growth through our CSR programs.

2.4 Governance

The Board monitors and reviews the performance and impact of the CSR programmes, provides input
and course corrections if required and satisfies itself that the CSR funds so disbursed have been
utilized for the purposes and in the manner as approved by it. The CFO or a person responsible for
financial management shall certify to the fact that CSR funds so disbursed have been utilised for the
purposes and in the manner approved by the Board.

3.1 Our CSR is to have

• Respect for all stakeholders
• Devotion to work ethics
• Data and document discretion
• Honesty in the flow of information
• Continuity relations based on customer satisfaction

3.2 The CSR Activities may relate to one or more activities listed in Schedule VII to the Act. This is
subject to the amendment of the Act and/or Rules from time to time.

3.3 The CSR Activities to be undertaken by the Company during each financial year along with the
particulars of projects, planned expenditure and implementation schedule are outlined in
Annexure I to this CSR Policy.

Our Promises

Our Values drives our actions….

At Jubilant we have embraced a three-dimensional path to sustainability

4.1 FOCUS AREA OF INTERVENTION

(i) The Company has identified the following focus areas of intervention:

• Improving health indices through innovative services and promoting health seeking
behavior;
• Universalizing elementary education and improving quality parameters for primary
education through community involvement;
• Enhancing employability through vocational training; and
• Supporting the community infrastructure as and when identified in the project area.

(ii) The Company shall implement the CSR Activities stipulated in Annexure I to this CSR Policy.
The said annexure shall be re-drawn every financial year in relation to the CSR Activities
proposed to be undertaken in that financial year.

4.2 PROGRAMME IMPLEMENTATION APPROACH AND PROCESS

The Company shall implement all CSR Activities in the project mode in compliance with the
provisions of Section 135 of the Act read with the CSR Rules.

While implementing such projects, all possible efforts shall be made to define the following:

(i) Programme Objective
(ii) Need Assessment/ Baseline Survey – It would give the basis on which the outcome of
the programme would be measured
(iii) Duration of the programme
(iv) Funds allocated to the programme
(v) Implementation schedule
(vi) Responsibilities and authorities
(vii) Major results expected and measurable outcome
(viii) Effective monitoring and evaluation
(ix) Programme Documentation

4.3 MODE OF IMPLEMENTATION

A. The CSR Activities shall be executed through one or more of the following modes:
(a) directly by the Company; or
(b) by Jubilant Bhartia Foundation (“JBF”), a social wing of Jubilant Bhartia group
established in 2007 and a non-profit organization (incorporated under Section 25
under the Companies Act, 1956).

B. CSR programmes may be implemented with the active participation of the concerned local
stakeholders. These interventions may also be synergized with the initiatives undertaken
by the State Government, District Administration as well as Departments.

C. The Company will identify the projects recommended by JBF which are falling within the
purview of Schedule VII to the Act and provide funds to JBF. The funds will be utilized by
JBF for the identified projects. JBF will maintain a separate account for each project at each
location and ensure to provide the details of expenditure / reports for each project, in a
manner as may be desired by the Company from time to time.

D. The Board may amend Annexure I to the CSR Policy on an annual basis at the end of each
financial year.

4.4 LOCATION OF CSR PROJECTS / PROGRAMMES / ACTIVITIES

The CSR Activities, whether undertaken by the Company itself or through JBF, shall be carried
out in and around the areas of the Company’s manufacturing locations / offices.
However, the Board may identify other areas for CSR Activities, from time to time.

4.5 PROGRAMME DURATION
The time period of implementation of the programme will depend on its nature, extent of
coverage and the impact of the programme.
The Company will follow a project based accountability approach to stress on the long-term
sustainability of its CSR projects. Based on the tenure of the identified projects, they will be
qualified as:
i. Short Term – upto 1 year
ii. Long term / Ongoing Project

5.1 In the beginning of every financial year, the Board shall determine whether the provisions of
Section 135 of the Act for mandatory CSR spend are applicable to the Company and accordingly,
determine the CSR Expenditure Budgeted for the financial year and approve the same.

5.2 CSR Expenditure Budgeted shall include all expenditure including contribution to corpus or on
projects/programmes relating to the CSR Activities. For achieving the CSR objectives through
implementation of meaningful and sustainable CSR programmes, the Company shall allocate the
following as its annual CSR

Expenditure Budgeted:

(i) 2% of its average net profits made during the three immediately preceding financial years,
as prescribed under the Act and the CSR Rules from time to time;
(ii) Any income arising there from;
(iii) Surplus arising out of CSR Activities; and
(iv) Such other amount as may be determined by the Company from time to time

5.3 Any surplus arising out of CSR Activities shall not form part of the business profits of the
Company and the same shall be spent on CSR activities.

5.4 Likewise, any excess amount spent on CSR activities may be set off against CSR expenditure to
be incurred in the succeeding financial years in accordance with the applicable CSR Provisions.

5.5 Unspent amount, if any, on the CSR Activities shall be dealt with in accordance with the
provisions of Section 135 of the Act and CSR Rules framed thereunder.

6.1 The Board shall monitor all CSR Activities, including utilization of funds to ensure their effective
implementation in accordance with the CSR Rules read with Section 135 of the Act.

6.2 The progress of CSR programmes under implementation will be reported to the Board at half
yearly intervals.

6.3 Broadly, the following procedure will be adopted by the Board for implementing and monitoring
the CSR Activities:

a. The CSR Annual Action Plan

• The list of CSR projects or programmes that are approved to be undertaken in areas
  or subjects specified in Schedule VII of the Act,
• the manner of execution of such projects or programmes,
  o the modalities of utilisation of funds and implementation schedules for the projects
  or programmes,
• monitoring and reporting mechanism for the projects or programmes and
•  Details of need and impact assessment, if any, for the projects undertaken by the
  company.

b. Monthly review of each CSR Project based on indicators by CSR Head of the Company

c. Quarterly review of the CSR Projects by CEO of the Company, based on

• Budget vs actual expenditure
• Target vs Achievement 

d. Half yearly review by Board members

6.4 The Company may conduct impact assessment on a periodic basis, either on its own or through
an independent professional or professional institutions, especially on the flagship programmes.

6.5 The Board may be presented with the cost incurred on CSR Activities annually and also the
impact assessment thereof as appropriate.

7.1 The CSR Policy shall be displayed on the Company’s website

www.jubilantmotorworks.com

7.2 An annual report on Corporate Social Responsibility shall form part of the Board’s report.

The Board may amend, abrogate, modify or revise any or all clauses of this Policy in accordance with
the Act and the CSR Rules.

In case any provision(s) of this policy is contrary to or inconsistent with the provisions of the Act,
Rules framed thereunder and CSR Rules etc. (“Statutory Provisions”), the Statutory Provisions shall
prevail. Further, amendments in the Statutory Provisions shall be binding even if not incorporated in
this Policy.

The revised CSR Policy has been approved by the Board on September 20, 2023, and is effective from
April 1, 2023.

CSR ANNUAL ACTION PLAN FOR FY 2023-24

1. Funds for undertaking CSR Activities shall be disbursed on a quarterly basis to the Implementing
Agency, Jubilant Bhartia Foundation for implementing the CSR projects as per the Implementation
Schedule.
2. Monitoring and reporting of the CSR projects shall be undertaken as per the process mentioned in
Clause 6.3 of the CSR Policy.
3. Since the overall limit of CSR expenditure is less than Rs. 10 Crore, Impact Assessment by an external
agency is not applicable. The Company shall conduct an internal assessment of the CSR Projects to
understand the impact based on SROI (Social Return on investment) principal.

CSR ACTIVITIES AND BUDGET FOR FY 2023-24