CORPORATE SOCIAL RESPONSIBILITY POLICY

1. INTRODUCTION

Vivaconnect Private Limited ("Company") is committed to conduct its business with highest standards of business ethics and in accordance with applicable laws, rules and regulations. The Company believes in conduct its objectives in a fair and transparent manner by adopting highest standards of professionalism, honesty and integrity.

The Company's Corporate Social Responsibility ("CSR") lays down the guidelines and mechanism for undertaking socially useful programmes for welfare & sustainable development of the underprivileged community.

2. DEFINITIONS

Any term used in this policy but not defined herein shall have same meaning as assigned to them under the Act as applicable to the Company.

3. OBJECTIVE & SCOPE

This is the Corporate Social Responsibility Policy ("CSR Policy") for the Company as required under the Companies Act, 2013 (hereafter referred to as "the Act"), read with the Companies (Corporate Social Responsibility Policy) Rules, 2014 and other directions and clarifications issued by the Ministry of Corporate Affairs from time to time (collectively referred to as the "CSR Regulations"). This policy lays down broad approach for CSR activities to be undertaken by the Company, implementation and monitoring of CSR activities as well as formulation of the Annual Action Plan pursuant to the CSR obligations in the sphere of corporate social responsibility undertaken by the Company.

The Board of Directors of the Company ("Board") shall be responsible for implementing this Policy and shall ensure that the CSR activities are carried out in compliance with this Policy and with the CSR Regulations.

4. CSR ACTIVITIES AND PROJECTS

The Board shall approve the action plan and CSR activities in pursuance of the CSR Regulations and CSR Policy. Such CSR activities may be undertaken directly by the company or in collaboration with other companies or through implementing agencies as may be approved by the Board from time to time.

The Company (either independently or in collaboration with other entities or implementation agency) shall undertake such activities which are broadly related to any of the following:

• Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water;
• Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
• Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups.
• Contribution to the Prime Minister's national relief fund or Prime Minister's Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the central govt. for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women;
• Disaster management, including relief, rehabilitation and reconstruction activities.

The Board of Directors of the Company is also authorised to consider other CSR activities which not included above as part of its CSR activity.

5. CSR SPENDING

The Company shall endeavour to achieve the objectives of CSR policy and allocate every year:

• The 2% of its average net profits made during the three immediately preceding financial years or such sum as may be decided by the Board of Directors for CSR activities.
• Any income or surplus arising out of the CSR activities, projects or programs shall not form part of the business profit of the company and the same shall utilized as per the provisions of CSR Regulations.

Unspent CSR amount, if any, shall be utilized as per the provisions of the CSR regulation as amended from time to time.

6. IMPLEMENTATION AND MONITORING

The company shall implement CSR activities directly or in collaboration with other companies or through implementing agencies. The Board shall monitor the disbursement of funds and utilization of the objects for which the contribution is made.

The Board can make changes in fund utilisation and CSR activities under taken at its discretion.

7. REPORTING

The Board's report shall include an annual report on CSR projects, programs and activities undertaken by the Company pursuant to rule 8 of the CSR rules (as amended from time to time).

The CSR Policy of the Company shall be disclosed in the website of the Company.

8. EFFECTIVE DATE

The policy shall be effective from the date of approval of this policy by the Board of Directors of the Company.

9. POLICY REVIEW & FUTURE AMENDMENT

The Board may subject to compliance with applicable law review, amend or modify the CSR Policy as it deems fit to comply with the statutory obligation of the Company to undertake CSR activities.