1. CONTEXT:

We, Ruchi Malls Private Limited ('The Company""). believe that better communities are built when people lead better lives.

Better lives are built around basic needs and necessities. Education. Health. Spotts. A1is & Culture and the Environment around us are integral to building and leading better lives. In these dimensions. we focus on the individual and the community alike.

2. APPLICABILITY:

The Corporate Social Responsibility Policy (CSR Policy) has been developed in consonance to Section 135 of the Companies Act, 2013 and in accordance with the Rules made there under.

The Policy shall apply to all CSR activities undertaken by the Company in India as per Schedule VII of the Companies Act, 2013.

3. DEFINATIONS

''Company" shall mean Ruchi Malls Private Limited.
"Board" shall mean the Board of Directors of the Company.
"Act" means the Companies Act, 2013 including any modifications, amendments or re-enactment thereof "CSR" mean Corporate Social Responsibility
"CSR Policy" means the policy approved by the board as the Corporate Social Responsibility policy of the company as amended f rom time to time.
"CSR Rules or Rules" means Companies (Corporate Social Responsibility Policy) Rules 2014 including any modifications, amendments or re-enactments thereof
"Board" means the Board of Directors of the Company.
"CSR Activities" means such programs or projects as may be approved by the Board in tenns of the CSR Policy.
"CSR Committee" means the committee constituted by the Board of Directors in terms of Section 135 of the Act and CSR Rules.
"Net Profits" shall mean the net profits of the Company as defined under the Act and the Rules based on which a specific percentage for CSR expenditure has to be calculated.
"CSR Expenditure" means the amount recommended by the CSR Committee to be incurred on the CSR activities in India in terms of the Companies Act, , 2013 and the CSR Rules as approved by the Board from time to time.

4. COMPOSITION OF CORPORATE SOCIAL RESPONSIBILITY (CSR} COMMITTEE:

A private Company having two Directors on its Board shall constitute its CSR Committee with two such Directors.

The CSR Committee should be governed by the Companies Act, 2013 and the CSR Regulations, rules, etc. by whatever name called. The CSR Committee would consist of such members or as prescribed by the specified legislation.

The members of the CSR Committee may elect a Chainnan / Chairperson amongst themselves.

Changes to the membership of the CSR Committee, and any modification or variation to the powers and the functions of the CSR Committee will require the approval of the Board,

The Quorum for a meeting of the CSR Committee would be two [2] members. The meetings shall be held at the registered office of the Company or at such place as may be agreed to b) the members of the Committee.

5. CORPORATE SOCIAL RESPONSIBILITY (CSR) EXPENDITURE:

The CSR Committee shall recommend the amount of CSR Expenditure in a year to be in accordance with the Companies Act, 2013 and the CSR Rules. For this purpose the Board shall ensure that a designated officer of the Company provides the relevant finance data and such other necessary details to the CSR Committee.

The Board shall be responsible for sanctioning the CSR Expenditure and to ensure that the amount of CSR expenditure is available for implementing the CSR Policy.

The CSR Expenditure shall, in every financial year be, at least 2% of average Net Profits made during the three immediately preceding financial years in accordance with the Companies Act and CSR Rules from time to time.

Surplus arising out of the CSR Activities shall not from part of the business profits of the Company. Any activity undertaken in the normal course of business activities wi II be excluded.

6. RESPONSIBILITIES OF THE COMMITTEE:

The Responsibilities of the CSR Committee include:

7. FOCUS AREAS:

In accordance with the requirements under the Companies Act, 2013. the CSR activities, amongst others, will focus on:

8. IMPLEMENTATION, MONITORING AND REVIEW:

The Company has constituted a CSR committee to oversee the implementation of the Policy and formulate a CSR strategy.

The CSR Committee comprises of the Directors of the Company to approve and monitor the CSR activities /programmes.

The CSR Committee shall be responsible for overseeing the programs / projects and it shall prepare the budget which will be reviewed and approved by the Board of Directors of the company.

A Company may also collaborate with other companies or any other external agency for undertaking projects/ programmes or CSR activities in such a manner as the CSR Committee deems fit. Besides implementation, the Committee will ensure regular monitoring and evaluation.

The management of the Company will review the various provisions of the CSR policy at regular intervals and make such changes as per recommendations of different stakeholders and guidelines introduced by regulatory bodies from time to time.

All necessary changes must be brought to the notice of the Board of Directors of the company and be duly approved in the Board Meeting. The revised policy document may be prepared as and when such revisions are approved by the Board of Directors.

9. EFFECTIVE DATE:

The Policy is effective from 17th November 2015