DOLPHIN HOTELS PVT LIMITED

CORPORATE SOCIAL RESPONSIBILITY POLICY (CSR POLICY)

1.Introduction

DOLPHIN HOTELS PRIVATE LIMITED (DHPL) is committed to good Corporate Citizenship and has a firm belief that businesses are key organs of the society, which have an underlying responsibility towards empowering people and ensuring sustainable development in the overall interest of the Society and the eco system in which we operate.

2.Applicability

This Corporate Social Responsibility Policy (“CSR Policy”) has been adopted by the Company in consonance with Section 135 of the Companies Act 2013 (“Act”), the Companies (Corporate Social Responsibility Policy) Rules 2014 (“CSR Rules”), and subsequent amendments / notifications/circulars issued by the Ministry of Corporate Affairs, Government of India, from time to time.

The Policy shall apply to all CSR projects/programmes undertaken by the Company in India as per Schedule VII of the Act.

3.CSR Budget

4.Scope

It is the endeavour of the Company to focus on the following broad activities.

The Company may take up such other activities which are broadly covered under Schedule VII of the Act (capturing the essence of the subjects enumerated therein, with liberal interpretation) and any additions which may be made hereafter. Relief and rehabilitation works in case of any natural calamities and major disasters, will also be taken up under CSR.

5.CSR Committee

Composition of the CSR committee: The CSR Committee consists three board of directors.

The CSR committee will be responsible for:

6.IMPLEMENTATION

The investment and duration of programme will depend on its nature, extent of coverage and intended impact of the programme. It may be ensured that majority of the CSR activities are undertaken in both Andhra Pradesh and Telangana.

Implementation may be taken up through designated teams of the company or at corporate level under the programs as approved by the CSR Committee and the Board of the company. The company may also implement the CSR schemes in collaboration with its associate companies or other companies, wherever feasible. Company may also appoint an Implementation Agency in the form of a Registered Trust to carry out the approved CSR Projects and make contributions to the Corpus of the Trust from time to time.

Execution of Programmes:

Project activities identified under CSR are to be implemented by employees, selected volunteers, specialized agencies, which include Voluntary Organisations (NGOs), Elected local bodies such as Panchayats, Institutes / Academic Organisations, Trusts, Missions, Self Help Groups, Govt./Semi Govt. / Autonomous Organisations, MahilaMandals/ Samitis, Professional Consultancy Organization etc.,

Initiatives of State Governments, District administration, Local Administration as well as Central Government Departments/ Agencies, Self-Help Groups etc., would be dovetailed / synergized with the initiatives taken by the Company.

Activities shall, as far as possible, be implemented in a project mode. For easy implementation, long-term CSR projects shall be broken down into medium-term and short-term plans. Each plan shall specify the CSR activities planned to be undertaken for each year. Accordingly, the budget shall be allocated for the implementation of these activities and achievement of targets set for each successive year, till the final completion of the project.

All the CSR activities shall be monitored regularly by Chairman and the CSR Committee.

7.Roles and Responsibilities

The Board of the Company will be responsible for:

As per Section 135 of the Act, the reasons for under spending of the allocated CSR budget shall be specified in the Board’s Report.

The surplus arising out of the CSR activities, if any, will not be considered as a part of the business profits of the company.

8.General

CSR PROJECTS

The Company is implementing the CSR activities under collaboration with eligible Group Companies through a Registered Trust Ramoji Foundation, the Implementation Agency.