CORPORATE SOCIAL RESPONSIBILITY POLICY

EASY TRIP PLANNERS LIMITED

(CIN – L63090DL2008PLC179041)
Regd. Office: 223 FIE Patparganj Industrial Area, Delhi - 110092

Last amended by the Board of Directors on 14th August, 2021)

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 EASY TRIP PLANNERS LIMITED
Corporate Social Responsibility Policy
(CSR Policy)

TABLE OF CONTENTS
Sl. No. Contents Page
No.
1. Introduction 3
2. Objectives 3-4
3. Definitions 5-8
4. CSR Committee 8-9
5. CSR Organisation 9-10
6. CSR Allocation 10-12
7. CSR Budget 12
8. CSR Activities 12-15
9. Implementation of CSR Activities 15
10. Monitoring Mechanism 15-16
11. Role of implementing agencies 16-17
12. Capacity Building 17
13. Impact Assessment 17
14. Disclosures 18
15. Amendments 18
16. General 18

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 EASY TRIP PLANNERS LIMITED

CORPORATE SOCIAL RESPONSIBILITY POLICY

[IN TERMS OF SECTION 135 OF THE COMPANIES ACT, 2013 READ WITH CORPORATE
SOCIAL RESPONSIBILITY POLICY RULES, 2014, AS AMENDED]

1. INTRODUCTION

Easy Trip Planners Limited is a Listed Company engaged in the business

of tourism and travel agents in India or abroad to facilitate tourism and
travelling of all kinds by way of issuance of rail/air/sea tickets, hotels,
restaurants and lodging accommodation guides.

This CSR Policy [as defined in clause 3(g)] aims to define and establish
the Company’s Policy framework towards CSR [as defined in clause
3(e)].

2. OBJECTIVES

The Company recognizes and is committed towards creating common

good for all. The Company shall implement its CSR activities to integrate
economic, environmental and social objectives with its operations and
growth for common good. CSR projects/ programmes/ activities should
be beneficial to the society at large and in compliance with the
applicable laws. The Company is committed towards making visible and
tangible contribution to communities and environment.

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The Company shall identify projects/ programmes/ activities both in
urban/ rural areas that will improve quality of life.

The broad objectives of this CSR Policy is to:

(i) elucidate and inform to all Shareholders about the Company’s

CSR Policy;
(ii) demonstrate commitment to the common good through
responsible business practices and good governance;
(iii) actively support the country’s development agenda to ensure
sustainable change;
(iv) set high standards of quality in the delivery of services in the
social sector by creating robust processes and replicable
models; and
(v) engender a sense of empathy and equity among employees
of the Company to motivate them to give back to the society.

The CSR Policy shall be implemented in accordance with the provisions

of Section 135 of the Act and the Rules made thereunder. It shall apply
to all the Corporate Social Responsibilities activities undertaken by the
Company in India as per Schedule VII to the Act and any amendments
or modifications made thereto.

The Corporate Social Responsibilities activities shall not include activities

undertaken by the Company in pursuance of the normal course of its
business. Further, projects, programmes or activities that solely benefit
the employees of the Company and their families shall not be
considered as Corporate Social Responsibilities under this CSR Policy.

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3. DEFINITIONS

Definitions of some of the key terms used in this policy are given below:

a) ‘Act’ means Companies Act, 2013 read with rules made

thereunder, as amended from time to time.

b) ‘Administrative Overheads’ means the expenses incurred by the

Company for ‘general management and administration’ of
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;

c) ‘Annual Action Plan’ means a plan formulated by the CSR

Committee and recommend to the Board, in pursuance of the
CSR Policy, which shall include the following:

(i) the list of CSR projects or programmes that are approved to

be undertaken in areas or subjects specified in Schedule VII
to the Act;
(ii) the manner of execution of such projects or programmes as
specified in the Rules;
(iii) the modalities of utilisation of funds and implementation
schedules for the projects or programmes;
(iv) monitoring and reporting mechanism for the projects or
programmes; and
(v) details of need and impact assessment, if any, for the
projects undertaken by the Company.
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d) ‘Board’ means Board of Directors of the Company.

e) ‘Corporate Social Responsibility’ or ‘CSR’ means the activities

undertaken by a Company in pursuance of its statutory obligation
laid down in Section 135 of the Act but shall not include the
following:
(i) activities undertaken in pursuance of normal course of
business of the Company;
(ii) 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;
(iii) contribution of any amount directly or indirectly to any
political party under Section 182 of the Act;
(iv) activities benefitting employees of the Company as
defined in Section 2(k) of the Code on Wages, 2019;
(v) activities supported by the Company on sponsorship basis
for deriving marketing benefits for its products or services;
and
(vi) activities carried out for fulfilment of any other statutory
obligations under any law in force in India.

f) ‘CSR Committee’ means CSR Committee of the Board.

g) ‘CSR Policy’ means a statement containing the approach and

direction given by the Board, taking into account the
recommendations of the CSR Committee, and includes guiding
principles for selection, implementation and monitoring of

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 activities as well as formulation of the annual action plan.

h) ‘International Organisation’ means an organisation notified by

the Central Government as an international organisation
under Section 3 of the United Nations (Privileges and
Immunities) Act, 1947, to which the provisions of the Schedule
to the said Act apply.

i) ‘Net Profit’ means Net Profit as defined in the Rules.

j) ‘Ongoing Project’ means a multi-year project undertaken by

the Company in fulfilment of its CSR obligation having
timelines not exceeding three years excluding the financial
year in which it was commenced, and shall include such
project that was initially not approved as a multi-year project
but whose duration has been extended beyond one year by
the Board based on reasonable justification.

k) ‘Public Authority’ means Public Authority as defined in the Rules

l) ‘Rules’ mean the Companies (Corporate Social Responsibility

Policy) Rules, 2014, as amended from time to time.

Words and expressions not defined in this Policy shall have the same
meaning as contained in the Act read with the Rules.

4. CSR COMMITTEE

In compliance with the requirements of Section 135 (1) of the Act, a

CSR Committee has been constituted by the Board. The CSR
Committee at all times shall comprise a minimum of 3 directors as
members. Subject to the requirements of the Act, the Board may
increase or decrease the size of the CSR Committee by passing a
resolution.
 The Committee may invite such other executive(s)/employees of
the Company, professionals, experts and outsiders with relevant
experience, as it may consider appropriate in its sole discretion,
whether on permanent basis or temporarily, to advise the
Committee on the various CSR activities being undertaken/ to be
undertaken by the Company.

The CSR Committee shall institute transparent monitoring mechanism

for implementation of the CSR activities undertaken by the
Company.

4.1 TERMS OF REFERENCE OF THE CSR COMMITTEE

The CSR Committee shall be responsible for—

(i) Formulate, recommend and modify/ alter whenever necessary,
Corporate Social Responsibility Policy which shall indicate the
projects/ programmes/ activities to be undertaken by the
Company,as specified in Schedule VII to the Act;
(ii) Recommend the amount of expenditure to be incurred on the
projects/ programmes/ activities referred to in clause (i) above;
(iii) Institutionalize transparent monitoring mechanism for
ensuring implementation of the CSR projects/ programmes/
activities; and
(iv) Any other activity(ies)/functions, as may be assigned by the
Board.

5. CSR ORGANISATION

The CSR activities shall be undertaken/ executed/ implemented

either by the Company itself or through any 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 Act, 1961, established by the Company, either singly or
along with its holding company/ fellow subsidiary(ies) or other
 company(ies).

In the event, the Company implements its Corporate Social

Responsibilities activities through any other trust(s), society(ies),
company(ies) that is not established by the Company/ its holding
company/ fellow subsidiary(ies)/, such trust(s), society(ies),
company(ies) shall have (a) registration under Section 12A and 80G
of the Income-tax Act, 1961; and (b) an established track record of
at least three years in undertaking similar activities and the Company
will clearly specify the projects or programmes to be undertaken
through these entities, the modalities of utilization of funds on such
projects and programmes and the monitoring and reporting
mechanism.

The Company will ensure that implementing agency(ies), who

agreed to undertake any CSR activity(ies) of the Company, shall
have registered itself/ themselves with the Ministry of Corporate
Affairs by filing requisite form w.e.f. 1st April, 2021.

6. CSR ALLOCATION

The CSR Allocation for a financial year shall include – (a) at least 2%
of the average Net Profits of the Company made during three
immediately preceding financial years; (b) any income arising there
from; (c) surplus arising out of Corporate Social Responsibilities
activities; and (d) any contribution specifically received for
Corporate Social Responsibilities activities. Further, it is clarified that
any surplus arising out of Corporate Social Responsibilities activities
shall not form part of the business profits.

The CSR amount may be spent by the Company for creation or

acquisition of a capital asset, which shall be held by (a) a company
established under Section 8 of the Act, or a Registered Public Trust
or Registered Society, having charitable objects and CSR
Registration Number under the Rule; or (b) beneficiaries of the said
CSR project, in the form of self-help groups, collectives, entities; or (c)
a public authority.

The Board shall ensure that the Administrative Overheads shall not
exceed 5% of total CSR expenditure of the Company for the
financial year.

In case, the Company spends an amount in excess of requirement

provided Section 135(5) of the Act, such excess amount may be set-
off against the requirement to spend Section 135(5) of the Act up to
an immediate succeeding three financial years provided the same
has been approved by the Board and passed a resolution to that
effect and the excess amount available for set-off shall not include
the surplus arising out of the CSR activities.

In case, the Company fails to spend the prescribed CSR amount in

any financial year, the Board shall, in its report under Section
134(3)(o), specify the reasons for not spending the amount and,
unless the unspent amount relates to any Ongoing Project, transfer
such unspent amount to a Fund specified in Schedule VII to the Act,
within a period ofsix months of the expiry of the financial year.

Further, any amount remaining unspent under Section 135(5) of the

Act, pursuant to any Ongoing Project of the Company, fulfilling such
conditions as may be prescribed, shall be transferred by the
Company within a period of thirty days from the end of the financial
year to a special account for that financial year in any scheduled
bank to be called the Unspent Corporate Social Responsibility
Account, and such amount shall be spent by the Company in
pursuance of its obligation towards the Corporate Social
Responsibility Policy within a period of three financial years from the
date of such transfer, failing which, the Company shall transfer the
same to a Fund specified in Schedule VII, within a period of thirty
days from the date of completion of the third financial year.
 Until a fund is specified in Schedule VII, the unspent CSR amount, if
any, shall be transferred by the Company to any fund included in
Schedule VII to the Act.

7. CSR BUDGET

The overall amount to be committed towards CSR will be approved

by the Board upon the recommendation of the CSR Committee.

8. CSR ACTIVITIES

The Company will undertake its CSR activities in the following areas:
1. Eradicating hunger, poverty and malnutrition, promoting health
care including preventive health care and sanitation including
contribution to the Swach Bharat Kosh set-up by the Central
Government for the promotion of sanitation and making
available safe drinking water;
2. 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
setup bythe Central Government for rejuvenation of river Ganga;
5. protection of national heritage, art and culture including
 restoration of buildings and sites of historical importance and works
of art; setting up public libraries; promotion and development of
traditional art andhandicrafts;
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 includingwidows;
7. training to promote rural sports, nationally recognised sports,
paralympic sports and olympic sports;
8. contribution to the prime minister's national relief fund or Prime
Minister’s Citizen Assistance and Relief in Emergency Situations
Fund (PM CARES Fund) or any other fund set up by the Central
Government for socio economic development and relief and
welfare of the schedule caste, tribes, other backward classes,
minorities and women;
9. Contribution to 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; and contributions to
public funded Universities; Indian Institute of Technology (IITs);
National Laboratories and autonomous bodies established under
Department of Atomic Energy (DAE); Department of
Biotechnology (DBT); Department of Science and Technology
(DST); Department of Pharmaceuticals; Ministry of Ayurveda,
Yoga and Naturopathy, Unani, Siddha and Homoeopathy
(AYUSH); Ministry of Electronics and Information Technology and
other bodies, namely Defense Research and Development
Organisation (DRDO); Indian Council of Agricultural Research
(ICAR); Indian Council of Medical Research (ICMR) and Council
of Scientific and Industrial Research (CSIR), engaged in
conducting research in science, technology, engineering and
medicine aimed at promoting Sustainable Development Goals
(SDGs).
10. Rural development projects including community/ social/
 infrastructure creation intended for the general well being of
societyat large;
11. Slum area development including social infrastructure projects in
urban areas aimed at improving the well being and safety of the
general public in such urban areas; and
12. disaster management, including relief, rehabilitation and
reconstruction activities.

The CSR Committee shall formulate and recommend to the Board,

an Annual Action Plan. The details of each of the CSR activities/
programmes undertaken during a financial year shall be set-out in
the Annual Action Plan. The Board may alter the Annual Action Plan
at any time during a financial year, as per the recommendation of
the CSR Committee, based on the reasonable justification to that
effect.

The Company shall give preference to the local area and areas
around it where it operates, for undertaking/ implementing/
executing/ collaborating for CSR activities.

9. IMPLEMENTATION OF CSR ACTIVITIES

The CSR activities identified by the CSR Committee and approved

by the Board shall be implemented in a project mode through
implementing agency(ies), which will entail charting the stages of
execution through planned processes, measurable targets,
mobilization and allocation of budgets and prescribed timelines. It
also involves assigning of responsibility and accountability. Suitable
documents/ agreements, if required, shall be entered into with the
implementing agencies for the purposes of implementation of the
CSR projects. The conditions of grant of amounts for all CSR activities
and the break-up of the allocations shall be set-out and evaluated
from time to time.
 The Company may engage international organisations for
designing, monitoring and evaluation of the CSR activities as per the
CSR policy as well as for capacity building of its own personnel for
CSR, if required.

10. MONITORING MECHANISM

The CSR Committee will ensure a transparent monitoring

mechanism for ensuring effective implementation of the CSR
activities proposed to be undertaken by the Company.

The CSR Committee will ensure that the CSR activities are
undertaken in compliance with this CSR Policy and in a project or
programme mode with clearly defined project deliverables,
implementation schedules, processes and budgets as given in the
Annual Action Plan.

The CSR Committee will monitor the projects and programmes to

ensure that they are being carried out in compliance with this CSR
Policy and the Act. The CSR Committee shall also apprise to the
Board of Directors about the progress of CSR project/ programmes/
activities including expenditure incurred by the implementing
agency(ies) till the allocatedbudget is fully utilised.

In case of the Ongoing Project(s), the Board shall monitor the

implementation of the project with reference to the approved
timelines and year-wise allocation and shall be competent to make
modifications, if any, for smooth implementation of the project
within the overall permissible time period.

The Board shall satisfy itself that the funds so disbursed have been
utilised for the purposes and in the manner as approved by it and
the Chief Financial Officer shall certify to the effect.
 11. ROLE OF THE IMPLEMENTING AGENCIES

The implementing agencies shall be responsible for:

(i) Determining the modalities of execution including targets and

timelines in consultation with the CSR Committee;
(ii) Ensuring that implementation of all CSR activities is being carried
on in accordance with the above;

(iii) Supervising the implementation of the CSR activities and ensuring

that the CSR activities are undertaken in compliance with this
CSR Policy with clearly defined project deliverables,
implementation schedules, processes and budgets;

(iv) Undertaking impact assessment of the CSR activities, as may

be required;
(v) Maintaining documents and accounts pertaining to all CSR
activitiesof the Company;
(vi) Keep the CSR Committee updated on Implementation progress
ofCSR activities; and
(vii) Assisting the CSR Committee in monitoring of CSR activities and
preparation of the annual report on CSR.

12. CAPACITY BUILDING

The Company may build CSR capacities by providing suitable

training to its own personnel as well as those of implementing
agencies throughinstitutions.

13. IMPACT ASSESMENT

In case, the Company has average CSR obligation of ` ten crore or

more in pursuance of Section 135(5) of the Act, in the three
immediately preceding financial years, it shall undertake impact
assessment, through an independent agency, of its CSR projects
having outlays of ` one crore or more, and which have been
completed not less than one year before undertaking the impact
study.
 The impact assessment reports shall be placed before the Board
and shall be annexed to the annual report on CSR.

In order to undertake impact assessment, the Company may incur

an amount up to 5% of the total CSR expenditure for that financial
year or
` fifty lakh, whichever is less and the same shall be considered as
CSR expenditure for that financial year.

14. DISCLOSURES

The CSR Committee shall prepare an annual report on CSR, in the format
prescribed under the Act and such report shall be included in the
Board’s report annexed to the financial statements. The report shall be
signed by the Chairman of the CSR Committee and Managing Director/
Director of the Company.

The Company shall host the contents of the CSR Policy on its website, if
any, in such manner as may be prescribed.

15. AMENDMENTS

The CSR Committee is empowered to recommend amendments or

modifications to the CSR Policy including Annual Action Plan and such
changes shall be placed before the Board for approval.
Where the CSR Policy including Annual Action Plan is in variance with
the requirements of the Act, the provisions of the Act shall prevail.

16. GENERAL

In case of any doubt with regard to any provisions of the CSR Policy
and also in respect of matters not covered herein, a reference to be
made to the CSR Committee or to the Chairman of the CSR
Committee. In all such matters, the interpretation and decision of the
Chairman of the CSR Committee shall be final.