POLICY DISCLOSURE

Corporate Social Responsibility Policy

Chhotaria Securities Private Limited is committed to social and environmental responsibility, contributing positively to communities and sustainable growth.

PREAMBLE

Chhotaria Securities Private Limited (“Chhotaria”, “Company”) understands the responsibility it has against its stakeholders, society and the public. The Company recognizes that integrating social, environmental and ethical responsibilities into the governance of businesses ensures long-term success, competitiveness and sustainability.

Through Corporate Social Responsibility (“CSR”), the Company engages in impactful welfare-driven activities in India contributing towards the betterment of life in communities where the Company has presence.

PURPOSE

This CSR Policy establishes the scope, funding priorities and processes associated with the CSR goals of the Company for the purposes of Section 135 of the Companies Act, 2013, the Companies (CSR Policy) Rules, 2014, and other applicable laws and regulations.

DEFINITIONS

• “Act” – Companies Act, 2013, as amended.

• “Board” – Board of Directors of Chhotaria Securities Private Limited.

• “CSR Activities” – Projects or programs undertaken pursuant to statutory obligations under Section 135, excluding activities in normal course of business, political contributions, exclusive employee benefits, or sponsorship marketing.

• “CSR Committee” – Committee of the Board constituted to implement, supervise and manage CSR initiatives.

• “CSR Corpus” – Corpus accumulated pursuant to this Policy for conducting CSR activities.

• “Ongoing Project” – Multi-year project having timelines not exceeding three years excluding the financial year of commencement.

SELECTION OF
PROJECTS

The Company plans to undertake CSR projects pursuant to Schedule VII of the Companies Act, 2013:

(i) Eradicating hunger, poverty & malnutrition: healthcare, sanitation, Swachh Bharat Kosh, safe drinking water.

(ii) Promoting education: special education, employment enhancing vocational skills for children, women, elderly.

(iii) Gender equality & women empowerment: setting up hostels, old age homes, day care centres.

(iv) Environmental sustainability: ecological balance, animal welfare, conservation of natural resources, Clean Ganga Fund.

(v) National heritage, art & culture: restoration of historical sites, traditional art and handicrafts.

(vi) Armed forces welfare: measures for veterans, war widows and their dependents (including CAPF/CPMF).

(vii) Sports promotion: rural, nationally recognised, paralympic and olympic sports.

(viii) PM CARES / Relief Funds: socio-economic development and welfare funds.

(ix) R&D and Academic Contributions: research in science, technology, medicine aimed at Sustainable Development Goals.

(x) Rural & slum area development: infrastructure and community betterment.

(xi) Disaster management: relief, rehabilitation, and reconstruction activities.

COMPOSITION OF
CSR COMMITTEE

• Implemented, managed and supervised by the CSR Committee of the Company.

• Comprises 2 (two) or more directors. Strength may be varied by Board resolution.

• Committee may invite non-voting participants from time to time to assist in implementation.

• Transparent monitoring mechanism instituted for all CSR projects.

DECISIONS BY THE
CSR COMMITTEE

Decisions are arrived at by consensus or majority consent (ratified by the Board). Preference is given to local areas around Company operations for CSR expenditure.

Committee Constitution:

Name	Designation
Mr. Neelansh Kaabra	Director
Mr. Kishor Kumar Gajpal	Director

The Committee formulates and recommends an annual action plan (projects, execution manner, fund modalities, monitoring, and impact assessment) to the Board.

COMMITTEE MEETINGS

• Meets as frequently as necessary, but not less than once in a year.

• Maintains minutes in relation to each meeting.

• Reviews proposals and recommends project approvals to the Board. Final decision rests with the Board.

CSR CORPUS

• Composition: 2% of average Net Profits of the Company for the last 3 financial years, plus surplus arising out of CSR activities (if any).

• CSR surplus does not form part of business profits.

• Up to 5% of total CSR expenditure may be spent on administrative overheads.

• Excess expenditure in a financial year may be set off against requirements of the immediately succeeding three financial years with Board approval.

MANNER OF
IMPLEMENTATION

CSR activities are undertaken directly by the Company or through eligible registered implementation agencies (Section 8 companies, registered public trusts/societies with 12A/80G registrations and track records, or statutory entities).

The Company may also collaborate with other companies for joint CSR initiatives subject to independent reporting.

MONITORING
MECHANISM

Transparent monitoring mechanisms are devised for all CSR activities. Committee members certify fund utilisation in accordance with approved mandates and obtain feedback from beneficiaries. Ongoing multi-year projects are tracked against approved annual milestones.

REPORTING
MECHANISM

The CSR Committee prepares an annual CSR report containing details prescribed under the Act and Rules, which is annexed to the Board's Report and financial statements.

WEBSITE PUBLICATION
& AMENDMENTS

• The approved CSR Policy is published on the Company website for public access.

• Any exceptions require prior written approval of the Chairman of the CSR Committee and the Board.

• The Board retains power to revise, modify, or amend this Policy based on CSR Committee recommendations.