SBI Card is committed to simplify the lives of its stakeholders through trust and excellence. Being a responsible corporate citizen, it has integrated Corporate Social Responsibility in the way it conducts its business. It has taken up innovative CSR projects with an aim to create sustainable impact by facilitating access, enhancing collaboration, and building capacity. The cCmpany will undertake CSR projects primarily with underprivileged communities with special focus on women, children, people with disability, people with mental health challenges, elderlies, healthcare, and environmental issues.

CSR Vision and Mission

The Company’s CSR vision is for an inclusive society where everybody has access to opportunities, financial security, and quality of life.

The Company’s CSR mission is to be a significant contributor in India’s growth story, by undertaking innovative, technology driven and impactful CSR programs with underprivileged communities.

The ownership of the policy is with Chief People Officer (CPO). The Policy shall be reviewed annually or at earlier intervals, as and when required. Modifications, if any, required to be made in this Policy, shall be placed before the Corporate Social Responsibility and ESG Committee which will recommend the policy to Board for review and approval. For approval of any recommended modifications, due to change in regulatory / legal requirements, the changes in the policy shall be deemed to be part of policy. However, it shall be placed before the Board in ensuing Board Meeting for ratification/approval.

A “policy exception” means any deviation from the Policy.

Exceptions are generally discouraged; however, policy exceptions, if any, require prior approval from the Board provided however that such exception is permitted in terms of the applicable regulatory framework.

The Company has constituted a Corporate Social Responsibility Committee to be called as Corporate Social Responsibility and ESG Committee as per requirements. The composition / structure of the Corporate Social Responsibility and ESG Committee is described under the section 5.1.2 of this Policy. In addition to Corporate Social Responsibility and ESG Committee, Company has formed a management level Committee – (CSR Management Level Committee) to manage the CSR Activities more efficiently and effectively. Composition/structure of the CSR Management Level Committee are described under 5.1.3. of this policy.

The Board shall, after taking into account the recommendations made by the Corporate Social Responsibility and ESG Committee , approve the Corporate Social Responsibility Policy for the Company and ensure that the activities as are included in Corporate Social Responsibility Policy of the Company are undertaken by the Company.

Roles and Responsibilities

Board of Directors

• The Board shall ensure that the Company spends, in every financial year, at least two per cent of the average net profit of the Company made during the three immediately preceding financial years, in pursuance of its Corporate Social Responsibility Policy. The Board shall form a CSR Committee (Corporate Social Responsibility and ESG Committee) and disclose the composition of the CSR Committee (Corporate Social Responsibility and ESG Committee), and CSR Policy and Projects approved by the Board on Company’s website, if any, for public access.
• The Board of Directors of the Company shall, make Annual Report on CSR activities which forms part of the Board’s Report for every financial year as required in the Companies Act and the Rules framed under the Act from time to time
• The Board shall ensure implementation of the CSR activities and expenditure of requisite amount on CSR every year as per the applicable law and disclose reasons for not spending the amount (if applicable) in the Annual Report on CSR which forms the part of the Board Report of the Company and ensure the treatment of unspent amount as per the provisions of Companies Act 2013 and rules made thereunder.
• The Board shall ensure that CSR activities are undertaken by the Company itself or through implementing partner(s) eligible for the said purpose, as per the requirements laid down under the Companies Act, 2013 and Rules made thereunder including statutory modifications/amendments.
• Ensure that CSR activities should be aligned to CSR Focus Areas/activities permitted in Schedule VII of the Companies Act, 2013 and rules made thereafter. The Board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of the Company for the financial year
• The Board shall satisfy itself that the funds so disbursed have been utilized for the purposes and in the manner as approved by it and the Chief Financial Officer of the Company shall certify to the effect
• The Board shall ensure that any amount which may remain unspent or is spent more than requirement amount out of the CSR budget shall be treated as per the provision of the Companies Act and Rules made thereunder.
• The Board shall monitor the implementation of the Ongoing Projects with reference to the approved timelines and year-wise allocation and may make modifications, if required, for smooth implementation of the project within the overall permissible time.
• Ensure that the activities as are included in Corporate Social Responsibility Policy of the Company are undertaken by the Company
• Board shall review and approve/modify the Annual Action Plan recommended by the Corporate Social Responsibility and ESG Committee

Corporate Social Responsibility and ESG Committee

IIn terms of Section 135(1) of the Companies Act, 2013 and rules made thereunder, the Company has constituted the Corporate Social Responsibility and ESG Committee and it would consist of three or more directors, out of which one shall be an independent director

The Roles and responsibilities of Corporate Social Responsibility and ESG Committee shall include:

CSR Management Level Committee

To manage the CSR Activities more efficiently and effectively, the Company shall have a CSR Management Level Committee which will be a management level committee and shall have composition:

Quorum

The quorum would be MD & CEO or COO (in absence of MD and CEO) & any 2 members. In case of Nonavailability of MD & CEO, COO will be the chairman

CSR Management Level Committee meeting will be held at least once in a quarter and its Roles and responsibilities shall include but not limited to following:

Principle & Overview

The Company will undertake CSR projects in alignment with Schedule VII of the Companies Act, 2013 and has selected the following focus areas for CSR interventions:

The Company will undertake CSR projects primarily with underprivileged communities with special focus on women, children, people with disability, people with mental health challenges, elderly, and terminally ill people.

Though CSR activities of the Company shall be guided by the focus areas as mentioned above, the Company may also engage in other CSR activities mentioned in Schedule VII of the Companies Act, 2013, after prior approval of the Board of Directors of the Company on recommendation of Corporate Social Responsibility and ESG Committee.

The company, in compliance with the Companies Act 2013, will contribute 2% of its average net profits made during the three immediately preceding financial years in pursuance to its CSR Policy. The CSR budget will be allocated/ approved at the start of every financial year. Further, mere disbursal of funds for implementation of a project will not be considered as CSR spent unless the implementing agency utilizes the whole amount.

According to Rule 2(1)(f) of the CSR Rules: “CSR Policy;’ means a statement containing the approach and direction given by the board of a company, taking into account the recommendations of its

Corporate Social Responsibility and ESG Committee, and includes guiding principles for selection, implementation and monitoring of activities as well as formulation of the annual action plan.

Any surplus arising out of the CSR activities shall not form part of the business profit of the company and shall be ploughed back into the same project or shall be transferred to the Unspent CSR Account and spent in pursuance of CSR policy and annual action plan of the company or shall be transferred to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.

Administrative overheads shall not exceed 5% of total CSR expenditure of the company for a financial year. Impact assessment amount booked under CSR shall not exceed five percent of the total CSR expenditure for that financial year or fifty lakh rupees, whichever is less.

Any amount which may remain unspent or is spent excess of requirement amount out of the CSR budget shall be treated as per the provision of the Companies Act and Rules made thereunder

Any amount spent excess of CSR budget of current financial year; such excess amount may be set off in immediate succeeding three financial years subject to the conditions that-

• the excess amount available for set off shall not include the surplus arising out of the CSR activities
• the Board of the company shall pass a resolution to that effect.

The implementing partner organization must register itself with the Central Government by filing form CSR-1 and must fulfill the criteria as per Companies Act, 2013 and CSR Rules 2014 including any amendment/modifications from time to time.

The company may engage international organizations for designing, monitoring and evaluation of the CSR projects or programs as per its CSR policy as well as for capacity building of their own personnel for CSR. The company may also collaborate with other companies for undertaking projects or programs on CSR activities in such a manner that the Corporate Social Responsibility and ESG Committee of respective companies are able to report separately on such projects or programs in accordance with these rules.

The CSR amount may be spent by a company for creation or acquisition of a capital asset, which shall be held by –

Execution Mechanism

• Develop a CSR Strategy – aligned with the CSR Policies of the company
• Operationalizing the institutional mechanism – Corporate Social Responsibility and ESG Committee & team identification and appointment
• Clear identification of CSR Budget and development of annual action plan
• Shortlist Implementing Agencies and conducting due diligence
• Identification, selection, and approval of projects
• Finalizing agreements with the implementing agencies
• Project Implementation
• Documentation
• Monitoring and Evaluation
• Project impact assessment (if required, by an independent third party)
• Preparation of reporting format and placement in public domain

Evaluation Mechanism

Monitoring

The progress of the projects should be tracked and evaluated as defined in MoU/ Addendum.

• Quarterly/ half yearly/ annual progress report (whichever are applicable as per the MoU)
• Fund utilization/ expense report/ certificate (as per the MoU)
• Project monitoring through virtual meetings/field visit to track project progress
• Employee volunteering initiatives; wherever possible. Monitoring of the project by vetting invoices, utilization certificate and project reports

CSR Reporting and Disclosures

• The Board's Report of a Company covered under CSR act and rules pertaining to any financial year shall include an annual report on CSR containing particulars specified in Annexure II of Corporate Social Responsibility Rules, 2014,
• The Company shall ensure the composition of the CSR and ESG Committee, CSR Policy and Projects approved by the Board shall be displayed at the Company website.
• The Company Shall furnish a report on Corporate Social Responsibility in Form CSR-2 every year to the Registrar as an addendum to FORM AOC-4 or AOC-4 XBRL or AOC-4 NBFC, as required.
• The Company shall place impact assessment report before the Board and executive summary of the impact assessment shall be annexed to the annual report along with web-link to access the complete impact assessment reports

Impact Assessment:

The Company shall undertake an impact assessment, through an independent agency, of their CSR projects having outlays of one crore rupees or more, and which have been completed not less than one year before undertaking the impact assessment study.

A Company undertaking impact assessment may book the expenditure towards Corporate Social Responsibility for that financial year, which shall not exceed two percent of the total CSR expenditure for that financial year or fifty lakh rupees, whichever is higher.

The impact assessment reports shall be placed before the Board and executive summary of the impact assessment shall be annexed to the annual report on CSR along with web-link to access the complete impact assessment report.

Unspent CSR Amount:

Any amount remaining unspent under sub-section (5), pursuant to any ongoing project, fulfilling such conditions as may be prescribed, undertaken by a Company in pursuance of its Corporate Social Responsibility Policy, shall be transferred by the Company within a period of thirty days from the end of the financial year 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 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. Further, unspent amount, if any, is transferred to this designated account and shall be used only for meeting the expenses of ongoing projects, and not for other general purposes of the Company. The special account cannot be used by the Company as collaterals or creating a charge or any other business activity.

Any unspent amount pertaining to ‘other than ongoing projects’ at the end of the relevant financial year shall be transferred within six months of the expiry of the financial year to a fund mentioned in Schedule VII of the Companies Act, 2013.