CSR Policy

Background

KIMS Al Shifa Healthcare Private Limited (KAS) is a corporate entity committed to serve
the people by providing hospitality services. Our strategic CSR initiatives are based on social
and environmental consequences but at the same time due consideration is given to the interests
of its stakeholders including shareholders, customers, employees, suppliers, business partners,
local communities and other organizations.

Main Objectives

CSR Policy of KAS is framed around our ethical business practices and values we have wovenover a period of time. Like our business which is strongly dependent on customer satisfaction,we have created our framework of CSR activities around people with humanity and personcentric approach. We aim to address social, environmental and economic needs of themarginalized/underprivileged sections of the society. Through this policy, we align our CSRstrategy with the company’s vision and goals. We adopt an approach that integrates solutions toproblems to benefit the communities at large and create social and environmental impact.

Applicability

The Policy shall be applicable to all CSR activities of the company whether carried by it or
through any implementation agency with effect from December 14, 2022.

CSR Key Focus Areas

KAS’s approach towards social responsibility and sustainability would be on the following key areas and the detailed activities are listed in Annexure A:

 Healthcare including preventive & community healthcare

 Safe Drinking Water/Sanitation

 Education& Livelihood Enhancement

 Gender Equality/Women Empowerment

 Environment

 Sports

 Rural Development

 Disaster Management

Governance & Management

The Company is not required to constitute CSR Committee as per the provision of the SubSection (9) of Section 135 of the Companies Act, 2013. CSR activities of the Company will begoverned by the Board of Directors. The Board will recommend the Annual Business Plan forCSR. CSR activities shall be those mentioned under key focus areas or other activities as perSchedule VII of the Companies Act, 2013. Once CSR committee became applicable as perSection 135(1) of the Companies Act, 2013, the Company shall constitute CSR Committee. The CSR Committee will do a quarterly review of the activities and monitor achievementsagainst targets set at the beginning of the year followed by reporting to the Board from time totime. The operational responsibility of the CSR program resides with the Company’s SeniorManagement and the CSR lead. The responsibilities of the CSR Committee include:

A. Board of Directors

•  Constitution of the CSR Committee
• Approval of the CSR Policy considering recommendations of CSRCommittee
• Ensure that the activities as included in CSR Policy are undertakenbytheCompany
• Support the CSR Policy implementation

B. CSR Committee

• Formulation and recommendation to the Board the CSRPolicy
• Recommendation of CSR activities/ programs to be undertakenbytheCompanyunder the policy including selection/ appointment of implementation agencies
• Ascertaining location of CSR activities
• Approval and review of the Annual Budget thereon
• Monitoring the execution and adherence to the CSRPolicy andannual plansonacontinuous basis
• Implement a transparent monitoring mechanismfor implementationoftheCSRprojects/ activities undertaken by the company
• To carry such other functions as may be delegated by the BoardrelatedtoCSRactivities from time to time

C. Senior Management

• Propose the annual budgets (long term and short term);
• Report to CSR Committee the spends as per the approved schedule
• Create CSR reports to be presented to the Board

D. CSR Lead

• Formulate and propose the strategy for Corporate Social Responsibilityactivitiesasper the company’s philosophy (in alignment with statute) and otherwise
• Design and propose CSR Programs
• Ensure execution of Corporate Social Responsibility projects/programsaspertheapproved plan
• Identify, build and leverage external partnerships towards commonobjectivesinthearena of CSR
• Liaison with eligible agencies for smooth implementation of initiatives
• Supervise and manage the CSR teams and inter‐dependencies in the area of CSR
• Reporting progress to the CSR Committee
• Create project application and reporting formats
• Create visibility of the policy and implemented initiatives

Reporting & Disclosures

Reporting & Disclosures

• Composition of the CSR Committee shall be disclosed in the Board Report
• The Board Report shall include an annual report on CSR activities in prescribedformatasper Companies Act 2013 containing specific details
• The Corporate Social Responsibility (CSR) Policy shall be displayedonthecompany’swebsite.
• A comprehensive annual CSR Report detailing the initiatives with relevant annexuresandphotographs along with account statement shall be created and communicated for internalcompany records.

CSR Activities in Partnership

The company may undertake programs in collaboration with other companies only in caseswhere such programs are separately reportable in the CSR report of participating companies.

CSR Expenditure

The Administrative overheads shall not exceed Five percent of total CSR expenditure of theCompany for the Financial Year. Any amount that remains unspent on ongoing projects will be transferred to a separate accountas per Rules.

Surplus arising out of CSR

Surplus arising out of any CSR project or program or activities shall not form part of thebusiness profit of the company, and can be utilized as permitted under the Rules.

Amendment of the Policy

The CSR policy of the company may be amended at any time by the board of the company onthe recommendation of the CSR committee.

Note:

Since the company is not required to constitute CSR committee as per the provision ofSection 135(9) of the Companies Act, 2013, the activities/ roles and responsibilities of theCommittee mentioned in the policy will be vested with the Board of Directors of the Company.