1. Introduction and Background

Gennova Biopharmaceuticals Limited (Gennova) believes that, we are surrounded by society and environment and we insist on the principle that we should obey the duty to protect and nourish it. The prime duty of any corporate is to give back to the society and environment whatever it derives from. Our Board of Directors, our Management and all of our employees subscribe to the philosophy of compassionate care.
Corporate Social Responsibility (CSR) is about making sure that organizations have a positive impact on the communities around them. CSR is about being community minded, being responsible, and taking positive actions. This includes being responsible towards employees, customers, the environment, partners and the society at large. By adopting socially and environmentally responsible behavior, businesses can make a significant contribution to boosting wealth creation and employment, fostering social justice and protecting the environment.

2. Our CSR Vision

Gennova CSR vision is to actively contribute towards the social and economic development of the communities in which we operate and to nourish the natural environment. In doing so, build a better, sustainable way of life for the society and environment as a whole.

3. Objectives of the Policy

The Objectives of this policy are to-
• Demonstrate commitment to the common good through responsible business practices.
• Set high standards of quality in the delivery of services in the social sector by creating robust processes and replicable models.

4. Applicability

• Gennova (hereby referred to as ‘the Company’) CSR policy has been developed in consonance to Section 135 of the Companies Act, 2013 (“the Act”), on CSR and in accordance with the CSR rules (hereby referred to as the Rules) notified by the Ministry of Corporate Affairs, Government of India in 2014.
• The Policy shall apply to all CSR projects/programs undertaken by the Company in India as per Schedule VII as may be modified from time to time and respective circulars, notifications issued by the Ministry of Corporate Affairs.

5. CSR Budget

• The Company shall ensure that in each financial year, spend at least 2% of the average net profit made during the immediate three preceding financial years on CSR.
• The CSR Committee shall recommend annual budget for CSR expenditure to the Board of Directors for its consideration and approval.
• The programs that the Company intends to implement will not give rise to any surplus. However, in case a surplus is earned, then such surplus arising out of the CSR projects or programs or activities shall not form part of the business profit of the Company.

6. CSR Committee

I. The composition of the CSR committee shall be as per the provisions of the Act and rules made thereunder i.e. three or more directors out of which at least one director shall be an independent director.
II. The CSR committee of the Company will be responsible for:
– formulating the CSR policy in compliance to Section 135 of the Act.
– identifying activities to be undertaken as per Schedule VII of the Act.
– recommending to the Board the CSR budget to be incurred on the activities.
– recommending to Board, modifications to the CSR policy as and when required.
– regularly monitoring the implementation of the CSR policy.
– ensuring that the programs, projects and activities supported through Gennova are aligned with the approved CSR policy of the              Company and schedule VII of the Act.
– reviewing and approving annual budgets with respect to CSR programs.

7. Implementation

The Company shall implement the identified CSR projects by the following means:
• The Company will implement the identified CSR programs presently within the scope of CSR policy.
• The Company may enter into partnerships with the NGO’s, trust, agencies and communities to create multiplier effect of its social projects. The Company will select its partner after appropriate due diligence.
• The Company may collaborate with other companies, including its Group Companies if required, for fulfilling its CSR objectives, under the effective supervision and monitoring by CSR Committees of respective Companies for achievement of CSR objectives.

8. Monitoring and Review

• The person/bodies to which the implementation is assigned will carry out such CSR Programs as determined by the CSR committee within specified budgets and timeframes and report back to the committee on the progress thereon at such frequency as the committee may direct.
• The committee shall review implementation of the CSR programs during regular intervals and issue necessary directions from time to time to ensure orderly and efficient execution of the CSR programs in accordance with this policy.
• The committee shall obtain feedback from the beneficiaries of the programs and the associated NGO’s/agencies.
• The Sustainable Development achieved through CSR activities and CSR policy shall be periodically reviewed and appropriately revised by the CSR Committee. Wherever applicable, the Company shall organize periodic audits at selected sites at random to check performance.

9. Reporting

The Company shall include an annual report of its CSR activities undertaken for the financial year in its Board’s Report as per the format prescribed under the Companies (Corporate Social Responsibility Policy) Rules, 2014.