Corporate Social Responsibility Policy

Vision Statement

Western Fintrade Private Limited believes that responsible business growth must be aligned with social progress, financial inclusion, education, entrepreneurship, sustainability, and community development.

The Company aims to create measurable social impact through transparent, sustainable, and compliant CSR initiatives.

Objectives

The objectives of this CSR Policy are:

• To comply with the provisions of Section 135 of the Companies Act, 2013.
• To promote financial literacy, education, entrepreneurship, and livelihood enhancement.
• To support socially and economically weaker sections of society.
• To contribute towards environmental sustainability and community welfare.
• To create long-term positive impact in communities where the Company operates.

Subject to applicability of CSR provisions under law, the Company shall spend:

• At least 2% of the average net profits of the Company made during the three immediately preceding financial years, calculated in accordance with Section 198 of the Companies Act, 2013.
• The annual CSR budget shall be approved by the Board based on:
• Profitability
• Regulatory applicability
• Business sustainability
• Approved annual action plan
• Any unspent amount shall be dealt with in accordance with applicable law.

Role of the Board

The Board of Directors of Western Fintrade Private Limited shall:

• Approve the CSR Policy.
• Constitute the CSR Committee (where applicable).
• Approve annual CSR action plans.
• Ensure spending as per statutory requirements.
• Review utilization of CSR funds.
• Disclose CSR activities in the Board’s Report and on the Company website.

Role of CSR Committee

The CSR Committee shall:

• Formulate and recommend CSR policy.
• Recommend projects, programs, and annual budgets.
• Monitor implementation of CSR projects.
• Review project outcomes and utilization of funds.
• Recommend modifications, if required.

CSR implementation shall follow:

Step 1:

Identification of community needs and project opportunities.

Step 2:

Selection of implementation agencies or direct execution.

Step 3:

Budget approval and project commencement.

Step 4:

Monitoring, evaluation, and reporting.

CSR activities shall be undertaken in line with Schedule VII of the Companies Act, 2013, including:

A. Education & Skill Development

Scholarships for students

Financial literacy programs

Skill development for youth

Employability and entrepreneurship training

Digital education initiatives

B. Women Empowerment

Skill development for women entrepreneurs

Microfinance awareness

Women-led livelihood initiatives

C. Healthcare

Preventive healthcare camps

Health awareness programs

Support for medical assistance initiatives

D. Environment

Tree plantation

Water conservation

Waste management

Renewable energy awareness

E. Rural Development

Village development programs

Community infrastructure

Sanitation initiatives

F. Entrepreneurship & Financial Inclusion

As an NBFC, priority may be given to:

• Financial literacy campaigns
• MSME awareness programs
• Credit awareness workshops
• Start-up and entrepreneurship support programs

G. Disaster Relief

Emergency relief

Rehabilitation support

Contributions to approved government funds

For Western Fintrade Private Limited, priority may be given to:

6.1 Education Finance Awareness

Rural student awareness programs

Overseas education funding awareness

Scholarship support

6.2 MSME Development

Small business financing awareness

Business documentation training

Credit discipline programs

6.3 Financial Inclusion

Banking awareness

Credit score awareness

Fraud prevention education

CSR activities may be undertaken across India, with preference to:

• Areas where the Company operates
• Underserved communities
• Aspirational districts
• Educational clusters

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The Company may implement CSR activities through:

• Registered trusts
• Registered societies
• Section 8 companies
• NGOs with proven track record
• Educational institutions
• Government bodies
• Direct implementation by the Company
• All implementing agencies must comply with applicable CSR registration requirements.

The Company shall establish monitoring mechanisms including:

• Quarterly progress review
• Utilization certificates
• Field visits (where applicable)
• Outcome measurement
• Impact assessment (if required under law)
• Funds shall be released based on project milestones and verified utilization.

Administrative overheads relating to CSR implementation shall remain within limits prescribed under applicable law.

The Company shall disclose:

• CSR Policy
• Approved projects
• CSR expenditure
• Impact reports (where applicable)
• in:
• Board’s Report
• Financial statements
• Official website of Western Fintrade Private Limited

The Managing Director / Whole-Time Director, as authorized by the Board or CSR Committee, may approve:

• Selection of implementation agencies
• Project execution
• Budget deployment
• Mid-course project corrections
• subject to approved CSR limits.

This Policy shall be reviewed annually or earlier if required by law or business needs.