Title And Applicability
This CSR Policy lays down the principles and mechanisms for undertaking various programs in accordance with the requirements under the Companies Act, 2013 and the rules / regulations framed therein, and circulars / clarifications issued thereunder (collectively, “Applicable Law”). The Policy shall apply to all the CSR projects, programs and activities undertaken by the Company at various locations in India for the benefit of diverse sections of the society.

Objective
The objective is to support people from low-income households achieve their true potential through the social benefits provided by various initiatives under this policy. The Company is committed to ensure that interventions are need-based, community-oriented and sustainable thereby impacting headline human development indicators favourably.

Focus Areas
Blue Pencil expects to make investments for improving the quality of life of people by focusing on social causes. The specific programs/ activities under these focus areas are finalised in due course of the year and submitted for approval to the Board.
In accordance with the requirements under the Companies Act, 2013 and the rules / regulations framed there under, and circulars / clarifications issued thereunder (collectively, “Applicable Law”), Blue Pencil CSR activities, amongst others, will focus on:
• Promoting education, including special education and employment enhancing vocational skills especially among children, youth, women, the elderly and differently abled, and livelihood enhancement projects.
• Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water.
• Protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional art and handicrafts
• Training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic sports.
• Contribution to the Prime Minister’s National Relief Fund or any other fund set up by the Government of India such as PMCARES, or any fund set up by any government of a State or UT of the Union of India for socio economic development and for relief and welfare of its citizens.
• Contributions provided for programs of or collaborations with educational institutions, and skilling bodies approved by the Government of India or any government of a State or UT of the Union of India and eligible as implementing partners as per CSR Rules.
• Promoting healthcare including preventive healthcare and sanitation, including making available safe drinking water and aid for differently abled persons.
• Rural development projects
• Disaster relief(s) discovered at any time in perpetuity.

Implementation
• Focus of CSR activities of Blue Pencil will be pan-India.
• Blue Pencil expects to invest into CSR activities through a combination of financial grants, technology, and other initiatives, which may include employee volunteering and expertise sharing.
• It will work with non-governmental organizations (NGOs) and local administrations to achieve community development goals. Implement directly or partner with NGOs to support projects related to development and improvement of infrastructure and essential amenities, livelihood and skilling initiatives, training and education, and rehabilitating disaster affected victims in rural areas.
• The Company may use the services of internal teams, expert agencies, consultancy firms, etc,. wherever required for implementation of programs.
• The Company will encourage its employees to volunteer for community service.

Budgets
• Blue Pencil has undertaken to spend at least two (02) per cent of the average net profit made during the three (03) immediately preceding financial years on specific CSR projects and programs in compliance to The Companies Act, 2013
• The Board shall make disclosures in the Annual Report as per clause (o) of sub-section (3) of section 134 including particulars specified in annexures to the CSR Rules.
• In the event of the company failing to spend the allocated annual budget, reasons for not spending will be provided in the Company’s Annual Report.
• The unutilized CSR budget if any, will be transferred to a separate bank account within 30 days from the end of financial year.
• Surplus arising out of CSR projects, programs or activities shall not form part of the business profits of the Company. Instead, the same will be further deployed for future CSR projects only.

Governance Structure
The CSR Committee will periodically review, monitor and update the Board about ongoing and any new CSR projects or programs, and the Board will ensure that the activities are included in this Policy are undertaken as per this Policy and in compliance with the CSR Rules.
Roles & Responsibility of the CSR Committee
• Issue notices in advance for any Board meetings related to CSR.
• Formulate the CSR Policy and seek approval of the Board.
• Review the Policy on a yearly basis and make necessary changes from time to time, as required.
• Formulate and share the CSR action plan with budget for the year with the Board and seek approval.
• Implement the activities either through the implementation organisation or directly through its internal team.
• Spend the allocated amount on CSR activities once approved by the Board and create a transparent monitoring mechanism of the initiative.
• Hold periodic meetings and have their decisions approved/ratified by the Board from time to time.

Composition of the CSR Committee
The CSR Committee shall be comprised in accordance with the requirements of Applicable Law.

Monitoring and Reporting Framework
• The Company will receive requests for funding of projects throughout the calendar year.
• The committee will evaluate proposals received under the focus areas mentioned and projects will be prioritized by assessing their potential impact.
• The CSR Committee will deliberate on the proposals and recommend to the Board for approving proposals.
• The CSR Committee will collaborate with stakeholders to monitor the status of each project and will report its findings periodically to enable the Board and the Management of the Company to meet their reporting, monitoring and other legal obligations.
Impact assessments shall be undertaken by the Company or by recipient or by implementing agency as required by and in the manner set out under Applicable Law, and the impact assessment report(s) shall be placed before the CSR Committee and the Board; and shall be disclosed as legally required.
• In any year, where the Company has spent in excess of its CSR obligation, such excess spending shall be available for set off against the Company’s CSR obligations for up to the next three financial years in accordance with Applicable Law, and the Board shall be competent to pass a resolution in this regard.

Compliance Requirements
In compliance with the Legal Provisions, the Company will disclose the contents of this Policy in its Annual Report and publish it on the Company’s website.