ORRA’s purpose of Corporate Social Responsibility (CSR) is to give back to the community, take part in philanthropic causes, and provide positive social value. It is ORRA’s "sense of responsibility" towards the community and surroundings in which it operates. ORRA Fine Jewellery Private Limited in India is committed to undertake CSR activities in accordance with the provisions of Section 135 of the Indian Companies Act, 2013 and related Rules.

ORRA believes that business enterprises are economic organs of the community and it is required to be a truly value-adding organization. ORRA should not only operate ethically and diligently but also directly nurture the the community and its environment in a scale that is appropriate to its economics. Corporate Social Responsibility (CSR) plays an important role in an organization’s existence and sustained growth. In line with this belief, ORRA carries out CSR activities to build a better, sustainable way of life for the weaker sections of the community. Programmes, projects, and activities (collectively known as “CSR Programmes") are independent of the normal business activities of ORRA.

• "Act" means The Companies Act, 2013
• "Board" means the Board of Directors of the Company.
• "Company" means ORRA Fine Jewellery Private Limited.
• "CSR Activities" means such programs and projects as may be approved by the Board in terms of this CSR Policy.
• "CSR Committee" means a committee constituted by the Board of Directors in terms of Section 135 of the Act and the CSR Rules as amended from time to time.
• "CSR Rules" means the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended from time to time.
• "CSR Expenditure" means the amount recommended by the CSR Committee to be incurred on the CSR Activities in India in terms of the Act and the CSR Rules as approved by the Board from time to time.
• "Director" means a member of the Board of the Company.
• "Implementing Agency" means an implementing agency as defined under paragraph 9.
• "Net Profits" means the net profit of the Company as per its financial statement prepared in accordance with the provisions of section 198 of the Act and will also be exclusive of the items given under rule 2(1)(h) of the Companies (CSR Policy) Rules, 2014.
• "Society" means a society registered under the Societies Registration Act, 1860 or any other applicable law in India.
• "Trust" means a public charitable trust registered under the Indian Trusts Act, 1882 or any other applicable law in India.

Any term not defined above, shall have the meaning assigned to it under the Act or the CSR Rules.

• To develop a long – term vision and mission strategy for ORRA’s CSR objectives.
• To serve the community.
• Establish relevance of potential CSR activities to ORRA’s core business and create an overview of activities to be undertaken, in line with Schedule VII of the Companies Act, 2013.

• The total budget for the CSR projects will be recommended by the CSR Committee in accordance with applicable provisions of the Act read with Rules prescribed thereunder. The Board shall approve the said amount and ensure that the amount sanctioned for the CSR Expenditure is available for application and utilized towards the CSR Activities.
• The Board shall ensure that the relevant financial data and such other necessary details are shared with the CSR Committee to enable the Committee to recommend the amount of CSR Expenditure to the Board.
• The Board shall ensure that the CSR Expenditure in a financial year is at least at two per cent of the average Net Profits of the Company made during the three immediately preceding financial years and any surplus arising out of the CSR Activities shall only be re-allocated to the CSR Activities being undertaken in terms of this CSR Policy.
• Any amounts expended while undertaking activities in pursuance of normal course of business of a Company or on an item not in conformity or in line with activities set out in Schedule VII of the Act, will not form a part of CSR Expenditure.
• The Board shall ensure that expenditure, if any incurred towards any capacity building exercise internally or of Implementing Agencies through institutions with established track record of atleast three financial years, as the case may be, shall not exceed five percent of the CSR Expenditure in one financial year.

ORRA’s key areas of expenditure for the target communities are focused in the following areas:

• Education (Including Financial & Digital Literacy)
• Employability & Employment (Skilling for Livelihoods)
• Rural and urban infrastructures

Besides it will also undertake expenditure in the areas of sports, disaster relief, environment and ethnicity etc. (Refer Annexure A), all aimed at improving the quality of life of the communities.

ORRA follows a structured governance procedures to monitor CSR activities. Our CSR Policy is governed by the Board of Directors of the Company. The Board has constituted a CSR Committee comprising of three directors who shall monitor the Policy and the programmes from time to time. The Board monitors and reviews the performance and impact of the CSR programmes, provides input and course corrections if required and satisfies itself that the CSR funds so disbursed are aligned to the CSR Policy of the Company and have been utilized for the purposes and in the manner as approved by it. The CSR committee shall also institute appropriate governance systems to ensure that there is adequate oversight and checks and balance in the processes to ensure desired outcomes.

• Mr. Dipu Mehta, Chairman & Managing Director
• Mr. Russell Mehta, Director
• Mr. Amar Kothari, Director

• formulate and recommend the CSR policy to the Board;
• recommend the amount of expenditure to be incurred on CSR activities;
• monitor the implementation of the CSR expenditure or projects
• monitor the CSR policy of the company from time to time; and
• formulate and recommend to the Board, an annual action plan in pursuance of its CSR policy, which shall include the items as mentioned in rule 5(2) of the Companies (CSR Policy) Rules, 2014.

Mode of Implementation: The CSR Activities may be undertaken by the Company by directly implementing any project approved by CSR committee/Board or through the following Implementation Group:

• Through a Trust, or a Society or a Company established either singly or its holding or subsidiary or associate company or alongwith any other company or holding or subsidiary or associate company of such other company, or under Section 8 of the Act or otherwise; and/ or
• Through a Trust, or a Society or a company established under section 8 of the Act with an established track record of three years in undertaking similar programs or projects; and/ or
• In collaboration with other companies/ industry Body coordinating such activities or NGOs
• Contribution to PM Relief Fund or any other fund as may be notified by Govt

The Board of the Company may, subject to compliance with applicable law, review the policy and at any time alter, amend or modify the CSR Policy as it deems fit to comply with the statutory obligation of the Company to undertake the CSR Activities.