Y-ACCESS MANUFACTURING PRIVATE LIMITED

PREAMBLE

Y-Access Manufacturing Private Limited (the "Company") is committed to discharging its Corporate Social Responsibility ("CSR") obligations in accordance with Section 135 of the Companies Act, 2013, and the Companies (CSR Policy) Rules, 2014, as amended from time to time.

This Policy provides the framework for the identification, approval, implementation, monitoring, and reporting of CSR activities undertaken by the Company.

CSR VISION

To contribute towards Safety, Healthcare, Skill Development, and Sustainable Community Development, ensuring measurable positive social impact across India.

CSR FOCUS AREAS

The Company shall undertake CSR activities in accordance with Schedule VII of the Companies Act, 2013, including the following focus areas:

Safety, Health & Workplace Risk Prevention

• Safety awareness and capability enhancement
• Providing PPE and safety equipment
• Accident and injury prevention measures

Skill Development & Education

• Technical training for employment enhancement
• Supporting vocational and skill-development institutions
• Initiatives aimed at improving employability and technical capabilities

Healthcare & Hygiene

• Medical support and healthcare initiatives
• Health awareness programmes
• Sanitation and hygiene initiatives

Environmental Sustainability

• Waste management initiatives
• Green initiatives and environmental conservation
• Activities supporting sustainable development

Supporting Government Relief Funds

• Contributions to PM CARES Fund or other funds specified under Schedule VII of the Companies Act, 2013, as applicable.

Note: CSR activities shall not include activities undertaken in the normal course of the Company's business.

GEOGRAPHIC COVERAGE

CSR projects may be implemented PAN India, with preference given to communities connected to or located around the Company's operations.

CSR GOVERNANCE

Since the Company's CSR expenditure requirement is ₹50 lakh or below, the Company is not required to constitute a separate CSR Committee, as applicable under the provisions of Section 135 of the Companies Act, 2013.

Accordingly, the Board of Directors shall directly perform all functions specified under Section 135(9) of the Act.

BOARD RESPONSIBILITIES

The Board of Directors shall be responsible for:

• Formulating, approving, reviewing, and updating the CSR Policy
• Approving the annual CSR budget
• Overseeing CSR project implementation and monitoring
• Ensuring appropriate CSR reporting and disclosures
• Ensuring compliance with applicable provisions relating to unspent CSR amounts
• Reviewing the overall social impact and effectiveness of CSR initiatives

CSR EXPENDITURE

The Company shall ensure that:

• A minimum of 2% of the average net profits of the preceding three financial years shall be spent on CSR activities, as applicable under Section 135 of the Companies Act, 2013.
• Administrative overheads shall be maintained within the statutory limits prescribed under applicable CSR laws and rules.
• Any unspent CSR amount shall be dealt with in accordance with Section 135(6) of the Companies Act, 2013 and applicable rules.

MODE OF IMPLEMENTATION

CSR activities may be undertaken through the following modes:

Direct Implementation

The Company may undertake CSR activities directly through its own resources and personnel.

Implementation Through Eligible Agencies

The Company may undertake CSR activities through implementing agencies eligible under the Companies (CSR Policy) Rules, 2014, including:

• Registered Trusts
• Registered Societies
• Section 8 Companies having valid CSR-1 registration
• Government entities permitted under applicable CSR Rules

Appropriate due diligence shall be undertaken, and necessary agreements and documentation shall be executed prior to the release of CSR funds.

MONITORING & REPORTING

The Company shall establish appropriate mechanisms for monitoring and reporting CSR activities.

The following shall be undertaken, as applicable:

• Periodic review of CSR projects by the Board
• Monitoring of utilisation of CSR funds
• Assessment of project progress and outcomes
• Impact assessment where the applicable statutory thresholds are met
• Reinvestment of any surplus arising from CSR activities into CSR activities in accordance with applicable law
• Annual disclosure of CSR activities in the Board's Report
• Filing of CSR-2 with the Ministry of Corporate Affairs (MCA), as applicable

DISCLOSURE

This CSR Policy shall be disclosed through:

• The Company's Board's Report
• The Company's website, where required under applicable law
• Other statutory records and disclosures as may be prescribed from time to time

VALIDITY & AMENDMENTS

This CSR Policy shall remain effective until amended or replaced by the Board of Directors.

The Board may amend, modify, or revise this Policy:

• Based on recommendations of the CSR Committee, where applicable; or
• To ensure compliance with changes in applicable laws, rules, regulations, or statutory requirements.

CONCLUSION

Through this CSR Policy, Y-Access Manufacturing Private Limited reinforces its commitment to contributing towards social development, skill enhancement, healthcare, environmental sustainability, and a safer working environment across India.

For Y-Access Manufacturing Private Limited (formerly Youngman Manufacturing India Private Limited) Policy dated 22-04-2025

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