Corporate Social Responsibility (CSR) Policy - JSW Steel Ltd

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CORPORATE SOCIALRESPONSIBILITY (CSR) POLICYJSW Energy LimitedDt.: 01 Apr 2021Ver.: 0.2/Draft

Corporate Social Responsibility PolicyJSW Energy LimitedDocument TitleCorporate Social Responsibility (CSR) PolicyTotal Number Of Pages11 (Eleven) TitleTo provide guidelines for:Purpose CSR activities Applicability & scope of the framework Outlining of the key tenetsApplicable ToJSW Energy Limited & Subsidiaries (the “Company”)Effective Date01 Apr 2021Document No:Date created:Version No:JSW/FN/CSR/00116 Mar 20210.2/DraftRecommended by:Approved by:CSR Committee of JSW Energy LimitedBoard of Directors of JSW Energy LimitedPage 1 of 11CSR Policy DocumentJSW Energy Limited

Table of ContentsPreamble . 3Scope & Applicability of this Document . 3Introduction . 3Vision and Philosophy . 4Vision . 4Mission . 4Guiding Principles . 4Our Approach. 5Key Focus Areas . 6Health & Nutrition . 6Education . 6Water, Environment & Sanitation . 6Agri-Livelihoods . 6Livelihoods . 6Other Initiatives . 6Implementation Strategy . 7Stakeholders Engagement. 7Program Management Framework . 8Monitoring, Evaluation and Learning . 8I.Program design. 8II.Concurrent Monitoring & Reporting . 9Impact Assessment . 9Governance . 9Board . 9Corporate Social Responsibility (CSR) Committee . 10Budget . 11Page 2 of 11CSR Policy DocumentJSW Energy Limited

PreambleScope & Applicability of this DocumentThis policy is applicable to JSW Energy Limited in India. The following are the key elements of thepolicy: Vision, Strategy and Approach towards Corporate Social Responsibility (CSR) Key Focus areas Implementation strategy Monitoring and Evaluation Framework Governance Structure BudgetIntroductionJSW Energy Limited is amongst India’s leading private sector power producing companies thatbelieves in the efficient utilisation of all available resources. From managing operations, enhancingsocial and economic benefits, minimizing environmental impacts and employing cutting-edgeinnovation, JSW Energy has grown steadily and strongly through the years. Today, the Company’spresence extends across several Indian states and includes stakes in natural resource companiesin South Africa.At JSW Energy Limited, we believe better execution is the key to excellence. From our everydayoperations to our strategic expansion programs, our differentiator has always been betterexecution, backed by a strong vision. Be it operating at industry – leading efficiencies or expandingat the least per MW cost, our will to undertake challenges, plan with conviction and execute withpassion have sustained and improved over the years.In line with our group philosophy of BETTER EVERYDAY, we continue to deliver on ourresponsibilities with utmost prudence, across parameters.Page 3 of 11CSR Policy DocumentJSW Energy Limited

Vision and PhilosophyOur vision is governed by the ideology that every life is important and must be given fairopportunities to make the best out of it.VisionEmpower communities with sustainable livelihoods.MissionEmpower citizens with better health, education and employment opportunities, and encouragesustainable development in key areas.Guiding PrinciplesoThe CSR Policy of the Company shall be guided by the regulatory frameworks, internationalstandards & best practices and industry norms, mentioned below: Section 135 of The Companies Act, 2013 of the Government of India (GoI) and relevantnotified rules International Finance Corporation (IFC) Performance Standards UN Global Compact Principles & Guidelines and UN SDGs Global Reporting Initiative (GRI) guidelines State as well as National Laws & statutes related to social development contribution bycorporatesoIn all circumstances the rules as defined by the CSR Rules under Section 135 of the CompaniesAct, 2013 shall prevail over any other rule/ convention/ best practice. The CSR rules asamended by Govt. of India from time to time shall prevail over and above this policy and thesame shall be adhered to by the company.oThe CSR Policy of the Company will be applicable in close coordination with the Company/Group policies on Human Rights, Social Development & Community Involvement and otherSustainability Policies as permissible within the ambit of the CSR Rules under Section 135 ofthe Companies Act, 2013.oThe Board of Directors of the Company shall be reviewing these Guiding Principles from timeto time to incorporate and amend as necessary.Page 4 of 11CSR Policy DocumentJSW Energy Limited

Our ApproachThe Company’s CSR interventions are oriented towards achieving better outcomes in local contextby adopting the SAMMS approach:S StrategicA AlignedM Multi-stakeholderM MeasurableS SustainableOur larger focus is sustainable developmentwhere community leads and owns initiatives inthe long term.The Company shall initiatedemonstrable models for replication which arealigned and linked to business case. During this journey, the Company will adopt multistakeholder approach and work closely with all stakeholders (Community, Government, othercompanies, National/International organizations).Alignment to SDGsThe Company takes conscious steps to design its CSR programs in such a way that the programsare aligned to the mandate of at least one of the SDGs. The SDG progress is constantly monitoredthroughout the implementation phase. The Company has identified areas of intervention and theiralignment to SDGs. Examples are in the figure below.Page 5 of 11CSR Policy DocumentJSW Energy Limited

Key Focus AreasThe Company follows a holistic and integrated approach that is community-led and managed.Key focus areas of our interventions include strengthening rural education, provisioning ofsecondary & tertiary healthcare and strengthening of public health system, helping communitiesto access basic sanitation & promoting hygiene, contributing towards water and environmentconservation, facilitating women-centric livelihoods and, promoting agribusiness approach.Health & NutritionoImproving access to affordable primary and secondary careoImproving awareness and health-seeking behaviour amongst communityEducationoImproving access to quality education for enhancing learning outcomes and life skillsincluding support for need-based infrastructure.oCreating enabling environment for access to higher educationWater, Environment & SanitationoConserving and augmenting water, promoting biodiversity, sanitary living conditions &sustainable livelihoods.oEnsure zero dumping by promoting waste management practices amongst communityAgri-LivelihoodsoImprove the economic well-being of farmers through appropriate interventions in farm valuechainsoFocus on sustainable agriculture to make it a preferred rural livelihood optionLivelihoodsoSkills enhancement of youth for improving employabilityoEnhancing women workforce participation by creating livelihood optionsOther InitiativesoTo undertake other need based community development initiatives in compliance withSchedule VII of the Companies Act, 2013Page 6 of 11CSR Policy DocumentJSW Energy Limited

Implementation StrategyThe Company is committed towards holistic inclusive development and implements its CSRinitiatives largely through JSW Foundation1. JSW Foundation is a not-for-profit entity registeredas a Public Charitable Trust spearheading development agenda of the JSW Group.JSWFoundation will engage partners, and build alliances and collaboration for executing CSRinitiatives of the Company. JSW Foundation’s core model of engagement is as follows:oFocus on local needs, community ownership and long term sustainabilityoPartnerships with National/International organizations for technical and implementationsupportoLeveraging technology for development solutionsoSupport development and incubation of social enterprise to nurture an ecosystem to scaleup innovation and connect it to grassroot level needs with need based partnersStakeholders EngagementThe Company involves all stakeholders at every stageof the CSR journey thereby building a robust institutionwhere community owns and leads the developmentagenda.While our larger focus is sustainabledevelopment, the Company also initiates need basedinterventions subsequently driving the process withparticipation from community and collaborating d on the basis of need assessment from thecommunity. Right from conceptualization to planning,designing, and execution, stakeholders’ inputs form akey basis for the formulation of the strategy. Various modes of dialogue deployed include:oOne-on-one meetings with Local self-governance bodies, district and state officials,academic institutionsoParticipating in Existing Platforms to apprise the stakeholders of the progress and to andseek their support wherever requiredJSW Foundation (www.jsw.in/foundation), established in 1988, is a development organization having a long and richlegacy. The Foundation has completed its journey of more than three decades, working towards empowerment ofcommunities and enriching their lives in various ways, fulfilling basic needs of health and education to skill developmentand also building up a common understanding and shared pride of the rich cultural heritage of the country and itsdiversity.1Page 7 of 11CSR Policy DocumentJSW Energy Limited

oEngaging with peers: Participation at forums created by apex industry bodies/esteemededucational institutions with an aim to facilitate knowledge sharing and learning among thepeersProgram Management FrameworkThe CSR programs implemented by JSW Foundation shall beProgramIdentificationgoverned by a robust program management framework. Theprograms shall be designed and executed following alifecycle approach with the following stages:1. Conceptualization of program: The need for a programProgram Designto be identified through a need assessment with an aimto identify the community needs on the ground.2. Inception of the program: After the interventional needis identified a program design shall be in placementioning objectives, key performance indicators,ProgramExecutiontimeline and execution model.3. Execution & monitoring of the program: Programimplementation shall be monitored through robustprogram management system to help keep track of theMonitoring &Evaluationprogrammatic deliverables.4. Culmination of the program: As the program nears itsexit, an end-line assessment shall be conducted throughthird-party agency.ImpactAssessmentMonitoring, Evaluation and LearningFollowing enablers shall guide and facilitate the process of monitoring and evaluation throughthe stages of the program:I.Program designa. KPI (Key Performance Indicators) Matrix: Standard set of sector-wise output,outcome, and impact indicators to be devised to define the measurement matrix forPage 8 of 11CSR Policy DocumentJSW Energy Limited

each CSR program undertaken by the Foundation. The KPIs shall be used to monitorthe program’s progress concurrently and the change brought about over time.b. Program Design: A standard template shall be designed wherein every program hasto be defined following the results-based management framework. The template shallprovide all relevant information about the program, i.e., rationale, objective, KPIs,detailed budget break-up, activities, and timelines.II.Concurrent Monitoring & Reportingc. Field level Monitoring Mechanism: Specific mechanisms shall be put in place toensure rigorous monitoring and field level supervision of the programs:i.Supervision/ Monitoring Checklist: To facilitate the program monitoring teamto capture details of field level execution and provide meaningful input to helpkeep the program aligned to the agreed plan.ii.Geo-tagging of community assets shall be undertaken. This shall facilitatemaintaining the inventory of community assets and cater to the maintenanceneeds arising from time to time.d. Program Management System (PMS): The cloud-based PMS shall take care of centraldata storage and reporting on the progress of each program through automateddashboards.Impact AssessmentThe Company strives to capture the impact (social/economic and developmental) of its variousinitiatives through multiple mediums.The Company shall undertake Impact assessment ofprograms wherever applicable The impact assessment studies shall be conducted throughcredible third party agencies. The reports of Impact assessments shall be put up for review to theCSR Committee of the CompanyGovernanceBoardoThe Board of the Company shall constitute a Corporate Social Responsibility (CSR) CommitteeoThe Board shall approve the CSR Policy of the Company recommended by the CSR CommitteeoThe Board shall ensure that the administrative overheads shall not exceed five percent of totalCSR expenditure of the Company for the financial year.Page 9 of 11CSR Policy DocumentJSW Energy Limited

oThe Board of the Company shall satisfy itself that the funds so disbursed have been utilizedfor the purposes and in the manner as approved by it and the Chief Financial Officer of thecompany or the person responsible for financial management shall certify to the effect.Corporate Social Responsibility (CSR) CommitteeoThe Company’s Board of Directors shall form a CSR Committee2. This Committee, along withthe CSR team, shall be responsible for the decision making with respect to the Company’sCSR policyoCSR Committee shall recommend the policy to the Company’s Board of Directors, and Boardof Directors shall approve the policyoThe CSR Committee shall formulate and recommend to the Board, an annual action planconsisting the following:a. The list of CSR programs that are approved to be undertaken in areas or subjectsspecified in Schedule VII of the Act;b. The manner of execution of such programs;c. The modalities of utilization of funds and implementation schedules for the programs;d. Monitoring and reporting mechanism for the programs; &e. Details of need and impact assessment, if any, for the programs undertaken by theCompany.oThe CSR Committee shall meet regularly to review the implementation of CSR programs/programs and give suitable directionIn case of an ongoing program, the Board of the Company shall monitor the implementation ofthe program with reference to the approved timelines and year-wise allocation and shall becompetent to make modifications, if any, for smooth implementation of the program within theoverall permissible time period. “Ongoing Program” here means a multi-year program undertakenby the Company in fulfilment of its CSR obligation having timelines not exceeding three yearsexcluding the financial year in which it was commenced, and shall include such program that wasinitially not approved as a multi-year program but whose duration has been extended beyondone year by the board based on reasonable justification.2CSR Committee of the Company is already constituted in compliance with The Companies Act 2013Page 10 of 11CSR Policy DocumentJSW Energy Limited

BudgetoThe Board of Directors of the Company shall ensure that a minimum of 2% of average netprofit before taxes of the immediately preceding 3 (three) financial years is spent on CSRinitiatives undertaken by the CompanyoAll expenditure towards the programs shall be diligently documentedoAny surplus arising out of the CSR activities shall not form part of the business profit of theCompany and shall be ploughed back into the same/similar program and spent in pursuanceof CSR Policy and annual action plan of the CompanyPage 11 of 11CSR Policy DocumentJSW Energy Limited

o The Board of the Company shall constitute a Corporate Social Responsibility (CSR) Committee o The Board shall approve the CSR Policy of the Company recommended by the CSR Committee o The Board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the Company for the financial year.

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