Environment Policy

CORPORATE SOCIAL RESPONSIBILITY POLICY

Updated On  – 07 September 2025

PREAMBLE

A Social responsibility organisation cannot, and does not, limit itself to merely increasing its own profits. Neither does it treat corporate social responsibility as a burden to be borne, but instead, believes it to be one of the fundamental duties or an organisation towards society. CSR is way of conducting business, by which a corporate entity visibility contributes to the social good.


At Gumpro Drilling Fluids Private Limited (“GUMPRO”) we are constantly aware of our role in society. Hence, as corporate entity, we at Gumpro strive at every stage to integrate the larger economic, environmental and social objectives with our core operations and growth.

1. SCOPE & APPLICABILITY

This policy, which encompasses the company’s philosophy for delivering its responsibility as a corporate citizen and lays down the guidelines and mechanism for undertaking socially useful programmes for welfare and sustainable development of the community at large, is tilted as the “Gumpro Drilling Fluids CSR Policy”. The provisions related to CSR are incorporated
as per the requirements of the Companies Act, 2013 (hereinafter called as “the Act”) and the Companies (Corporate Social
Responsibility Policy) Amendment Rules, 2021, notified by the Ministry of Corporate Affairs vide Notification dated 22nd
January, 2021.

 

This policy shall apply to all CSR initiatives and activities taken up at the various locations of the Company, for the benefit of
different segments of the society.

 

This policy is applicable to Gumpro and all CSR applicable Group Companies of Gumpro.

2. OBJECTIVE

The objective of this Policy is threefold

  1. Established a guideline for compliance with the provisions of the Act and Rules related to CSR,
  2. Implement CSR initiative in both letter and spirit through appropriate procedures and reporting’s, and
  3. Initiate projects that benefit the community at large.

 

CSR expenditure shall include all expenditure on activities or projects or programs relating to CSR activities approved by the
Board on the recommendation of its CSR Committee.

3. CORPORATE SOCIAL RESPONSIBILITY COMMITTEE

Composition:

The Corporate Social Responsibility Committee shall consist of three (3) Directors.

 

Meeting:
The Committee shall hold meeting as and when required, to discuss various issues on implementation of the CSR Policy of the Company.

 

Role of CSR Committee:
The role of CSR Committee is:

  1. To formulate and recommend to the Board, a Corporate Social Responsibility which shall indicate the activities to be undertaken by the company as specified in Schedule VII of Section 135 of the Companies Act, 2013.
  2. To recommend the amount of expenditure to be incurred on the specified activities in a financial year.
  3. To monitor the Corporate Social Responsibility Policy of the Company from time to time.
  4. To recommend the Board on the guiding principles for selection, implementation and monitoring of CSR activities.
  5. To formulate and recommend to the Board, an Annual CSR Action plan in pursuance of its CSR policy.
  6. To recommend the Board to alter the Annual CSR Action Plan at any time during the financial year based on the reasonable justification to that effect.
  7. Any other matter/thing as may be considered expedient by the members in furtherance of and to comply with the CSR
    Policy of the Company.

 

Role of Board of Directors:

  1. The Board of Directors shall, after considering recommendations made by the CSR committee, approve the CSR
    policy and the Annual CSR Action Plan of the Company.
  2. The Board of Directors shall endeavour that the Company spends 2% average pre-tax net profits of the Company
    made during the 3 immediately preceding financial years in pursuance of its CSR policy.
  3. The Board of Directors of the Company shall disclose the composition of the CSR Committee, and CSR Policy and
    Projects approved by the Board on their website, if any, for public access.
  4. The Board may extend an on-going project(s) beyond one year based on reasonable justification.
  5. The Board shall ensure that the CSR activities are undertaken by the Company itself or through a registered and eligible Implementation Agency.
  6. The Board of the Company shall satisfy itself that the funds so disbursed have been utilized for the purposes and in
    the manner as approved by it and the Chief Financial Officer or the person responsible for financial management shall
    certify to the effect.
  7. In case of ongoing project, the Board of the Company shall monitor the implementation of the project with reference
    to the approved timelines and year wise allocation and shall be competent to make notifications, if any, for smooth
    implementation of the project within the overall permissible time period.
  8. The Board may alter the CSR Annual Action Plan at any time during the financial year, as per the recommendation
    of its CSR Committee, based on reasonable justification to that effect.
  9. The Board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the
    Company for the financial year.
  10. Where the Company spends an amount in excess of requirement, such excess amount may be set off by the Board against the requirement to spend up to immediate succeeding three financial years subject to the condition that –
    • the excess amount available for set off shall not include the surplus arising out of the CSR activities, if any.
    • The Board of the Company shall pass a resolution to that effect.

4. CSR EXPENDITURE

From April 1st, 2014, in line with the new Companies Act 2013 (the Act), Gumpro, contributes at least 2% of the average
net profits of the Company made during the 3 immediately preceding financial years specifically towards CSR initiatives.
For this purpose, the net profit and average net profit shall be calculated in accordance with the provisions of section 198
of the Act read with the Companies (Corporate Social Responsibility Policy) Rules, 2014.

  1. The Annual CSR Budget shall be spent on projects/ activities as laid down in this Policy.
  2. “Administrative Overheads” expenses incurred by the Company will be used for ‘General Management & Administration’ of the Corporate Social Responsibility functions in the Company but shall not include the expenses directly incurred for the designing, implementation, monitoring and evaluation of a particular Corporate Social Responsibility project or programme.
  3. The excess amount arising out of the CSR activities will not be considered as a part of the business profits of the Company and such excess amount may be set-off against the requirement of the CSR Spending u/s 135(5) upto the immediate succeeding 3 financial year subject to the conditions that the Board of Directors shall pass a resolution to that effect.
  4. Any surplus arising out of the CSR activities shall not form part of the business profit of the Company and shall be ploughed back into the same project or shall be transferred to the Unspent CSR Account and spent in pursuance of CSR
    policy and Annual Action Plan of the Company or transfer such surplus amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.
  5. Any unspent amount of not relating to the ongoing project shall be transferred to such a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.

5. CSR ACTIIVITIES/PROGRAMMES/PROJECTS

The Company is committed to support the CSR activities undertaken in any one or more of the following areas/sectors:

  1. Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitisation and making available safe drinking water.
  2. Contribution towards medical aid, promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects;
  3. Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
  4. Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water including contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga;
  5. protection of national heritage and culture including restoration of buildings and sites of historical importance and works of art; Setting up public libraries; promotion and development of traditional and handicrafts:
  6. measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
  7. Training to promote rural sports, nationally recognized sports, Paralympics sports and Olympic sports;
  8. contribution to the Prime Minister’s National Relief Fund or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Caste, the Scheduled Tribes, other backward classes, minorities and women;
  9. contributions or funds provided to technology incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government
  10. Rural development projects;
  11. Slum area development;
  12. Disaster management, including relief, rehabilitation and reconstruction activities.


The Company will prefer to take up projects for spending the amount earmarked for CSR at local areas and areas where the
Company operates.

The Chairman will ensure that the expenses/contribution will be in full compliance of the CSR Policy.

6. IMPLEMENTATING AGENCY

The Board shall ensure that the CSR activities are undertaken by the Company itself or through –

  1. a company established under Section 8 of the Act, or a registered society, registered under section 12A and 80 G of the Income Tax Act, 1961, established by the company, either singly or along with any other company, or
  2. a company established under section 8 of the Act or a registered trust or a registered society, established by the Central
    Government or State Government; or
  3. any entity established under an Act of Parliament or a State legislature: or
  4. a company established under section 8 of the Act, or a registered public trust or a registered society, registered under Section 12A and 80G of the Income Tax, 1961, and having an established track record of at least three years in undertaking similar activities.

 

Every entity who intends to undertake any CSR activity, shall register itself with the Central Government by filing the form CSR-1 electronically with the Registrar.
The Company may also collaborate with other companies to undertake CSR projects, provided the CSR Committee of the respective companies are able to report separately on such projects.

7. IDENTIFICATION OF ACTIVITIES/PROJECTS:

Out of approval CSR activities, the Committee shall decide which activity/project should be given priority for the respective
financial year. While arriving at the decision of the activity to be undertaken for the respective year, the Committee shall
analyse the basic need of the community/area in which the Organisation operates or at a place where its registered office is
situated. The Committee shall record its findings and prioritised the CSR activities.

8. EXCLUSIONS:

Corporate Social Responsibility (CSR) means the activities undertaken by the Company in pursuance of its statutory obligation laid down under section 135 of the Act in accordance with the provisions contained in the CSR Rules, but shall not include the following, namely:

  1. activities undertaken in pursuance of normal course of business of the Company.
  2. Any activity undertaken by the Company outside India except for training of Indian sports personnel representing any State or Union territory at national level or India at international level.
  3. Contribution of any amount directly or indirectly to any political person.
  4. Activities benefitting employees of the Company.
  5. Activities supported by the companies on sponsorship basis for deriving marketing benefits for its products or services.
  6. Activities carried out for fulfilment of any other statutory obligations under any law in force in India.

9. CAPITAL ASSET

The CSR amount may be spent by the Company for creation or acquisition of a capital asset, which shall be held by –

  1. A Company established under Section 8 of the Act, or a Registered Public Trust or Registered Society, having
    charitable objects and CSR Registration Number.
  2. Beneficiaries of the said CSR project, in the form of self-help groups. Collectives, entities; or
  3. A public authority.

Provided that any capital asset created by the Company prior to the commencement of the Companies (Corporate Social
Responsibility Policy) Amendment Rules, 2021, shall within a period of one hundred and eighty days from such commencement comply with this requirement, which may be extended by a further period of not more than ninety days with the approval of the Board on reasonable justification.

10. GENERAL:

In case of any doubt with regards to any provisions of the policy and in respect of matters not covered herein, a reference to be made to CSR Committee. In all such matters, the interpretation & decision of the Committee shall be final.

 

Any or all provisions of the CSR Policy would be subject to revision/amendment in accordance with the guidelines on the subject as may be issued from the Government from time to time.

 

The CSR Committee reserves the right to modify, add or amend of provisions of the Policy subject to approval of Board.

Note: This policy has been approved by the Board of Directors of the Company at their meeting held on 10th March, 2021.

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