PHILOSOPHY
Recognizing that business enterprises are economic organs of society and draw on societal resources, it is our belief that a company's performance must be measured by its Triple Bottom Line contribution to building economic, social and environmental capital towards enhancing societal sustainability. We believe that in the strategic context of business, enterprises possess, beyond mere financial resources, the transformational capacity to create game-changing development models by unleashing their power of entrepreneurial vitality, innovation and creativity. In line with this belief, we will continue crafting unique models to generate livelihoods and environmental capital. Such Corporate Social Responsibility ("CSR") projects are far more replicable, scalable and sustainable, with a significant multiplier impact on sustainable livelihood creation and environmental replenishment. These initiatives are independent of the normal conduct of our business. Programs, projects and activities (collectively "CSR Programs") carried out in this regard are the subject matter of this Policy.

CSR POLICY

It is ASTL’s policy:

1. ATSL shall undertake CSR projects in sectors as identified under Schedule VII of the Companies Act, 2013 with special focus on the areas given below, each of which is titled by the objective they seek to achieve:

1. • Arogya (Wellness) - Nutrition, Health and Sanitation and Drinking Water projects.
2. • Ujjwal (Towards a Bright future) – Education initiatives.
3. • Kaushal (Skill) - Livelihood Generation and Skill development initiatives.
4. • Unnati (Progress) - Rural Development.
5. • Sashakt (Empowerment) - Women Empowerment initiatives.
6. • Saksham (Capable) - Care of the elderly and differently abled.
7. • Harit (Green) – Environment Centric Activities.


IMPLEMENTATION
1. CSR programmes will be undertaken by various work centers within the defined ambit of Schedule VII of Companies Act, 2013 with special focus on the heads as listed above.

2. Majority of the CSR programs by value (at least 75%) may be implemented in and around the ‘local areas’ (within a radius of 100 Kms). The balance projects can be taken up anywhere in the country, as per the company requirement/imperatives from time to time.

3. CSR activities shall be undertaken through various agencies including registered trusts/ societies or companies or autonomous bodies/government departments. In case of NGOs/Trust/Pvt. Companies, an established track record of 03 years in undertaking similar projects or programs would be essential.

4. The Board of Directors’ Report shall include a Responsibility Statement of the CSR Committee that the implementation and monitoring of CSR Policy is in compliance with CSR objectives and Policy of the Company.

5. If for some reason, the Company fails to spend 2% of the avg. net profit of the preceding three FYs on CSR, the reasons thereof, shall be furnished in the report of the Board of Directors under Section 134 (3) (o) of the Companies Act, 2013.

GOVERNANCE
1.Every year, the CSR Committee will place for the Board's approval, a CSR Plan delineating the CSR Programs to be carried out during the financial year and the specified budgets thereof. The Board will consider and approve the CSR Plan with any modification that may be deemed necessary.

2.The Board will assign the task of implementation of the CSR Plan within specified budgets and timeframes to such persons or bodies as it may deem fit.

3.The persons/bodies to which the implementation is assigned will carry out such CSR Programs as determined by the Board within the specified budgets and timeframes and report back to the Board on the progress thereon at such frequency as the Board may direct.

4.Once year the Board will provide a status update to the CSR Committee on the progress of implementation of the approved CSR Programs carried out during the year. It shall be the responsibility of the CSR Committee to review such reports and keep the Board apprised of the status of implementation of the same.

5.At the end of every financial year, the CSR Committee will submit its report to the Board.

CSR EXPENDITURE
CSR expenditure will include all expenditure, direct and indirect, incurred by the Company on CSR Programs undertaken in accordance with the approved CSR Plan. Moreover, any surplus arising from any CSR Programs shall be used for CSR. Accordingly, any income arising from CSR Programs will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.

GENERAL PROVISIONS
1. The Company shall execute all CSR activities and programmes in terms of the systems and procedures as detailed in the ‘CSR Policy’ (as maybe notified from time to time) which are aligned/based on the provisions of Section 135 of the Companies Act, 2013, the CSR Rules and the subsequent clarifications and amendments as notified by Ministry of Corporate Affairs.

2. If necessitated, new CSR activities / projects can be taken up during the course of a year, in addition to CSR activities already incorporated in the CSR policy of the Company on annual basis, with the Board’s approval based on the recommendations of the CSR Committee. The same would be treated as amendment to the policy.

3. The surplus arising out of CSR projects or programmes or activities shall not form part of the business profit of the company.

4. No contribution shall be made to any political party through CSR Fund.

5. The CSR projects or programmes or activities that benefit only the employees of the Company and their families shall not be considered as CSR activities in accordance with Section 135 of the Act.

CSR COMMITTEE OF THE BOARD
The CSR Committee of the Board comprises of Mr. Jay Vilas Dubey (Chairman), Mr. Naresh Chand Maheshwari and Shri Deoki Nandan Agarwal as members. All the members of the Committee are eminent personalities from academic and industrial field. The members with the vast experience and multi-functional expertise, provide macro policy level inputs to the CSR Committee and guide Company’s approach towards CSR.