National Bulk Handling Corporation Private Limited ("NBHC") is registered under the Companies Act, 2013 having its registered office at 5th Floor, Richa 9, Plot No. 56, Road No. 17, MIDC, Andheri (East), Mumbai – 400 093. NBHC was formed for strengthening the post-harvest infrastructural facilities of the country. The physical delivery system has evolved to include end-to-end solutions in procurement, storage, quality gradation, certification and inspection, commodity care and pest management, disposal and collateral management. The Government is pro-actively encouraging corporate participation in the above sectors and creating favourable conditions for promoting business and investments. Recognizing the immense business potential in the Indian agri-commodities management market, NBHC is at the forefront of creating and offering "Complete Solutions in Commodity Management" to all participants of the ecosystem.

The stakeholders of NBHC desire to participate in Corporate Social Responsibility ("CSR") activities and wish to include CSR strategies as part of their management strategies for creation of a sustainable livelihood in society. This Policy is aimed at implementing welfare measures in the society by addressing the concerns of the marginalized section of the society, as part of their core business areas and to encourage employees to give back to the society. This Policy is made in accordance with the Companies Act, 2013 ("Act") along with Companies (Corporate Social Responsibility) Rules, 2014 ("Rules") and forms part of NBHC's key business process; this Policy has been approved by the Board of Directors of NBHC ("Board") in their meeting held on August 18th, 2014 and Board constituted CSR Committee for implementation of CSR initiatives of NBHC.

NBHC believes in partnership concept and connecting people to markets. Therefore reaching out to unserved communities is part of NBHC's DNA.

CSR PHILOSOPHY AND VISION OF NBHC:

NBHC's CSR Vision is "to actively contribute to the social and economic development of the marginalized section of the society. In doing so; build a better, sustainable way of life for underserved communities and raise the country's human development. This Policy is titled as "NBHC's CSR Policy" and it shall apply to all CSR initiatives and activities taken up by the Company for the benefit of the Society.

CSR COMMITTEE

In accordance with the Act and the Rules, the Board has constituted the Corporate Social Responsibility Committee ("CSR Committee") consisting of 4 (four) members (including the Directors and Non-Executive Directors). The present Members of the CSR Committee are mentioned herein below and such Membership of the CSR Committee shall be subject to review by the Board on a periodical basis:

• Rajagopalan Santhanam, Non-Executive (Nominee Director)
• Vinod Kumar, Managing Director and Chief Executive Officer

The CSR Committee shall, inter alia, perform the following functions:

Formulate and recommend to the Board, a CSR Policy which shall indicate the CSR activities proposed to be undertaken and such projects will be identified based on the proposed thematic areas as provided under the Act and the Rules therein;

1) To recommend the amount of expenditure to be incurred on the CSR activities; and
2) To monitor the implementation of the CSR Policy from time-to-time and take such other action, as it may deem fit in pursuance of the CSR Vision of NBHC.

EXCLUSION:

Following kinds of expenditures or contributions to other parties shall not be construed as expenditure on CSR Activity under this Policy:

1) All Projects, Programs or Activities that benefits only NBHC Employees and their Families.
2) All Projects, Programs or Activities that are being undertaken outside India.
3) All Kinds of Political Contributions whether, directly or indirectly.
4) All Projects, Programs or Activities which are undertaken in pursuance of its normal course of business.

ORGANISATIONAL MECHANISM AND PERFORMANCE:

NBHC will provide the vision under leadership of its Board, CSR Committee and Managing Director. This vision will underline all CSR activities by NBHC and / or its eligible subsidiaries, volunteers along with outside consultants; wherever necessary.

PARTNERSHIPS:

Collaborative Partnerships will be formed with the entire system of stakeholders with the expertise; the influence and the infrastructure to coordinate a fundamental shift, not only in our own operations, but in the way markets operate. This will help widen NBHC's reach and leverage upon the collective expertise, wisdom and experience that these partnerships bring to the table.

SURPLUS OF CSR PROJECTS:

The surplus arising out of the projects or programs or activities shall not form part of the business profit of NBHC and such surplus shall be invested in suitable bank deposits, liquid funds and other instruments offering adequate safety and reliability and any interest income earned on the foregoing shall be utilized for CSR purposes.

INFORMATION DISSEMINATION:

NBHC's CSR projects will be disseminated on its website, annual reports, in-house journals and through the media. NBHC will provide employees, customers and external stakeholders with a significant depth of information about such projects through credible research, white papers, videos, stories, and social media.

MANAGEMENT COMMITMENT:

The Board, our Management and all our Employees subscribe to the philosophy of ethical business. NBHC believes and acts on ethos of transparency, freedom and inclusiveness; characterized by a willingness to build a commodity ecosystem that works for everyone. This is the cornerstone of CSR Policy.

REPORTING:

NBHC shall provide an Annual Report which is to be included in the Board's Report on all CSR activities undertaken as per the format prescribed in the Rules. The internal monitoring group shall prepare such report on behalf of NBHC.