Corporate Social Responsibility
This Corporate Social Responsibility Policy
                                                (“Policy”)
                                                is framed
                                                by the CSR Committee (as defined below) constituted by the Board of
                                                Directors of
                                                Trinity Mobility Private Limited (“Company” or “Trinity”) in terms of
                                                the
                                                Companies
                                                Act, 2013 (“Act”) read with the Companies (Corporate Social
                                                Responsibility
                                                Policy)
                                                Rules, 2014 (“CSR Rules”), as amended from time to time, and approved by
                                                the
                                                Board
                                                of Directors of the Company on 01.06.2018.
                                                The CSR Committee of the Board had revised the CSR Policy, which was
                                                approved by the
                                                Board at its meeting held on 16.07.2021. The amended is effective from
                                                16.07.2021.
                                            
About Trinity and Its Corporate Social Responsibility Initiatives
Trinity is committed to improving the world we live in by creating, supporting, and nurturing programs and initiatives that serve local communities. Together with leading public and non-profit institutions, Trinity has developed powerful programs to address needs in the communities it serves. The cities, towns and villages where Trinity has operations and where our employees live and raise their families are not just addresses to us – they’re our hometowns. By applying the same rigor and business tools we use in the workplace, Trinity builds programs that deliver results we can quantify: one community, one home, one teacher, and one student at a time. The Policy, as a part of the Company’s corporate citizenship initiative, provides the Company a deep and wide experience and understanding of corporate social responsibility work that has real, measurable, and sustainable positive impact on the communities Trinity serves.
Vision
Trinity is committed to building a world that’s safer and more secure, more comfortable and energy efficient, more innovative, and productive. Accordingly, the Company believes in identifying corporate social responsibility projects that have optimal and sustainable impact on local communities, in the areas where the Company can leverage its strengths. Whilst the Company will continue to support activities as per Schedule VII of the Act listed below, the Company will focus its efforts on the areas of vital importance, i.e., environmental sustainability, education, rural development, disaster relief and other activities. Trinity may join hands with leading public and non-profit institutions to develop powerful programs to address the needs of the communities it serves. This Policy encompasses the Company’s philosophy setting out the Company’s role as a responsible corporate citizen and lays down guidelines for undertaking programs for public good.
Composition of CSR Committee
The CSR Committee shall consist of 2 (Two) or more members and such number of other members as may be decided by the Board of Directors from time to time, in accordance with the provisions of the Act and the charter documents of the Company. The present members of the CSR Committee constituted by the Board of Directors are as follows:
| S.No | Name | Designation | 
|---|---|---|
| 1 | Mr. Ashok Kumar Munusamy | Chairman | 
| 2 | Mr.Radhakrishan Nambiar | Member | 
| 3 | Mr.Ashish Kumar Modi | Member | 
| 4 | Mr.Manish Kumar Sharma | Member | 
| 5 | Mr.Rajesh R Pillai | Member | 
Our Focus Areas
We combine CSR strategy and community outreach with both financial support and volunteerism to address core community needs in areas where we have unique expertise. In terms of the CSR Rules, the Company will be focusing on undertaking the project /programs /activities listed below, as specified in Schedule VII to the Act excluding activities undertaken in pursuance of normal course of business of a Company.
- 
                                                                    
Environmental Sustainability:
Promoting awareness about environmental issues.
Promoting awareness about environmental issues. - 
                                                                    
Education
Promoting Education in all forms, including special education and Employment enhancing vocational skills especially among children, women, elderly and differently abled, who are in need and financially backward. Provide financial support to academic institutions for providing infrastructure facilities with the objective of assisting students in their studies.
Improving quality of education in existing schools and promoting the other cultural activities. - 
                                                                    
Rural Development
To development of Rural Area and identified the registered Trusts who engaged in the work of rural Development. - 
                                                                    
Disaster Relief
Contribution money for adopting the relief measures during the time of Natural Disaster, anywhere in the Country.
Contribution money for development of standard of living of peoples who suffered any natural disaster in the Country. - 
                                                                    
Other Activities
Other CSR Activities in line with Schedule VII of the Act and approved by the CSR Committee. 
Implementation
Trinity is committed to building a world that’s safer and more secure, more comfortable and energy efficient, more innovative, and productive. Accordingly, the Company believes in identifying corporate social responsibility projects that have optimal and sustainable impact on local communities, in the areas where the Company can leverage its strengths. Whilst the Company will continue to support activities as per Schedule VII of the Act listed below, the Company will focus its efforts on the areas of vital importance, i.e., environmental sustainability, education, rural development, disaster relief and other activities. Trinity may join hands with leading public and non-profit institutions to develop powerful programs to address the needs of the communities it serves. This Policy encompasses the Company’s philosophy setting out the Company’s role as a responsible corporate citizen and lays down guidelines for undertaking programs for public good.
Monitoring
The CSR Committee and the Board will review, monitor and provide strategic direction to the Company's CSR and sustainability practices towards fulfilling its objectives under this Policy, and review the effectiveness of the programs implemented under this Policy. The programs and activities will be identified and approved by the Board.
Budget
A specific budget calculated in accordance with the provision of Section 135 of the Act is allocated for activities to be undertaken in pursuance of this Policy. For achieving corporate social responsibility objectives, the Company will initially allocate funds earmarked for such activities for implementation of programs either independently or jointly with third party organizations that meet the requisite expertise and credentials for the project(s).
Annual Action Plan
The Corporate Social
                                                                                Responsibility
                                                                                Committee
                                                                                shall formulate and recommend to the
                                                                                Board,
                                                                                an
                                                                                Annual
                                                                                CSR
                                                                                Action
                                                                                Plan in pursuance of this CSR Policy,
                                                                                which
                                                                                shall
                                                                                include
                                                                                the
                                                                                following, namely:
                                                                                the list of CSR projects or programs
                                                                                that
                                                                                are
                                                                                approved
                                                                                to be
                                                                                undertaken in areas or subjects
                                                                                specified in
                                                                                Schedule
                                                                                VII of
                                                                                the
                                                                                Act;
                                                                                the manner of execution of such projects
                                                                                or
                                                                                programs
                                                                                as
                                                                                specified in
                                                                                Rules;
                                                                                the modalities of utilization of funds
                                                                                and
                                                                                implementation
                                                                                schedules
                                                                                for the projects or program;
                                                                                monitoring and reporting mechanism for
                                                                                the
                                                                                projects
                                                                                or
                                                                                programs;
                                                                                and
                                                                                details of need and impact assessment,
                                                                                if
                                                                                any,
                                                                                for
                                                                                the
                                                                                projects
                                                                                undertaken by the Company.
                                                                                The Board will consider and approve the
                                                                                CSR
                                                                                Plan
                                                                                with
                                                                                such
                                                                                modification that may be deemed
                                                                                necessary.
                                                                                The Board may also alter the Annual
                                                                                Action
                                                                                Plan
                                                                                at
                                                                                any
                                                                                time
                                                                                during
                                                                                the financial year, as per the
                                                                                recommendation of
                                                                                its
                                                                                CSR
                                                                                Committee,
                                                                                based on the reasonable justification to
                                                                                that
                                                                                effect.
                                                                            
Governance
The Board shall
                                                                                    satisfy
                                                                                    itself
                                                                                    that
                                                                                    the
                                                                                    funds disbursed have been utilised
                                                                                    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.
                                                                                    The Board of Directors of the
                                                                                    Company
                                                                                    shall
                                                                                    ensure
                                                                                    that
                                                                                    the
                                                                                    administrative overheads shall not
                                                                                    exceed
                                                                                    the
                                                                                    threshold
                                                                                    limit
                                                                                    for the financial year per the Act
                                                                                    and
                                                                                    the
                                                                                    Rules.
                                                                                    The Board of Directors’ Report of
                                                                                    the
                                                                                    Company
                                                                                    shall
                                                                                    include an
                                                                                    annual report on CSR containing
                                                                                    particulars,
                                                                                    as
                                                                                    applicable and
                                                                                    as mentioned in the Rules.
                                                                                    The Company shall undertake an
                                                                                    impact
                                                                                    assessment,
                                                                                    through an
                                                                                    independent agency, of its CSR
                                                                                    projects
                                                                                    per
                                                                                    the
                                                                                    requirement
                                                                                    under the Act and the Rules.
                                                                                    Any amount remaining unspent, if
                                                                                    any,
                                                                                    under
                                                                                    sub-section
                                                                                    (5) of
                                                                                    Section 135 of the Act, pursuant to
                                                                                    any
                                                                                    ongoing
                                                                                    project,
                                                                                    fulfilling such conditions as may be
                                                                                    prescribed,
                                                                                    undertaken by
                                                                                    the Company in pursuance of the
                                                                                    Policy,
                                                                                    shall be
                                                                                    transferred by
                                                                                    the Company to a special account to
                                                                                    be
                                                                                    opened by
                                                                                    the
                                                                                    Company in
                                                                                    that behalf 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 Policy
                                                                                    within
                                                                                    the
                                                                                    period
                                                                                    specified
                                                                                    under the Act and Rules, failing
                                                                                    which,
                                                                                    the
                                                                                    Company
                                                                                    shall
                                                                                    transfer the same to a Fund
                                                                                    specified in
                                                                                    Schedule
                                                                                    VII.
                                                                                    The
                                                                                    Company shall transfer the unspent
                                                                                    amount
                                                                                    within
                                                                                    the
                                                                                    time
                                                                                    provided under the Act and
                                                                                    Rules.
                                                                                    This Policy is in conformity with
                                                                                    the
                                                                                    requirements
                                                                                    laid
                                                                                    down
                                                                                    under the Act
Review of Policy
The Corporate Social Responsibility Committee of the and the Board of Directors of the Company will review the Policy at regular intervals as deemed appropriate.
Amendments
Any or all the provisions of this Policy are subject to revision/modification by the Committee, as may be required. The CSR Policy of the Company may be amended at any time by the Board of Directors on the recommendation of the CSR Committee.
Definitions
For
                                                                                                purposes
                                                                                                of
                                                                                                this
                                                                                                Policy, the
                                                                                                following terms shall
                                                                                                have
                                                                                                the
                                                                                                following
                                                                                                meaning:
                                                                                                Act shall mean the
                                                                                                Companies
                                                                                                Act,
                                                                                                2013
                                                                                                (to
                                                                                                the
                                                                                                extent that such
                                                                                                enactment
                                                                                                is in
                                                                                                force
                                                                                                and
                                                                                                applicable to the
                                                                                                context in
                                                                                                which
                                                                                                such
                                                                                                term
                                                                                                is used
                                                                                                herein) and shall
                                                                                                include
                                                                                                all
                                                                                                amendments,
                                                                                                modifications and
                                                                                                re-enactments
                                                                                                of
                                                                                                the
                                                                                                foregoing.
                                                                                                Annual Action Plan shall
                                                                                                mean
                                                                                                the
                                                                                                annual
                                                                                                action plan
                                                                                                formulated by the
                                                                                                Committee
                                                                                                and
                                                                                                approved
                                                                                                by
                                                                                                the
                                                                                                Board of Directors in
                                                                                                accordance
                                                                                                with
                                                                                                Rule
                                                                                                5(2) of
                                                                                                the Rules.
                                                                                                Board shall mean the
                                                                                                Board
                                                                                                of
                                                                                                Directors
                                                                                                of
                                                                                                the
                                                                                                Company.
                                                                                                CSR Committee shall mean
                                                                                                the
                                                                                                committee
                                                                                                constituted
                                                                                                by the Board of
                                                                                                Directors
                                                                                                under
                                                                                                Sec.135
                                                                                                of
                                                                                                the
                                                                                                Act.
                                                                                                Rules means Companies
                                                                                                (Corporate
                                                                                                Social
                                                                                                Responsibility Policy)
                                                                                                Rules,
                                                                                                2014,
                                                                                                or
                                                                                                any
                                                                                                other
                                                                                                rules prescribed under
                                                                                                Sec.
                                                                                                135
                                                                                                of
                                                                                                the
                                                                                                Act
                                                                                                and
                                                                                                pertaining to corporate
                                                                                                social
                                                                                                responsibility, as
                                                                                                may be amended, and
                                                                                                prescribed,
                                                                                                from
                                                                                                time to
                                                                                                time.
                                                                                            
For enquiries related to this Policy or Trinity’s CSR initiatives, please contact:
                                                                                                    Name:
                                                                                                    Manisha
                                                                                                    Agarwal
                                                                                                    Contact:
                                                                                                    legal@trinitymobility.com
                                                                                                    Amended and
                                                                                                    effective
                                                                                                    July
                                                                                                    16,2021
                                                                                                






