Wingify Corporate Social Responsibility Policy
Last updated
Version History

12th May 2023
12th May 2023: third version published on the website wingify.com
14th June 2021: second version published on the website wingify.com
31st March 2021: first version published on the website wingify.com

Vision & Mission
Wingify Software Private Limited (hereinafter referred to as ‘Wingify’ or ‘the Company’) is committed
to build a sustainable business with strong social relevance and a commitment to inclusive growthand contribute to society by supporting causes on various concerns including road safety,
healthcare, environmental sustainability, promoting education, promoting sports, Agriculture,
Training Program, Information Technology, etc. and other rural development activities that seek toharness its expertise in technology to create a positive impact on India and influence the society forits sustainable development.
Since our funding is limited in nature, the CSR projects and programmes shall leverage theorganization’s core expertise, partnerships, infrastructure, and other resources to create long termshared value for the community it serves; focussed primarily on inter alia underserved, socially, andeconomically backward groups.

Applicability
The Company’s CSR Policy has been developed in conformity with the provisions of Section 135 of
the Companies Act, 2013 and in accordance with the CSR Rules.
This Policy is revised to conform with the amendments in the Act and the Rules.

Focus Areas
All CSR projects shall be in line with the provisions of the Companies Act, 2013, including the areas
listed in Schedule VII of the Companies Act, 2013.
Therefore, the Company is hereby devoted to directing its CSR resources, to a reasonable extent, for
improving the quality of life of the people by focusing on the social causes, to the following areas:

HUNGER, POVERTY, MALNUTRITION AND HEALTH
Eradicating extreme hunger, poverty, and malnutrition, promoting preventive healthcare andsanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for thepromotion of sanitation and making available safe drinking water.
EDUCATION
Promoting education, including special education and employment-enhancing vocational skills
especially among children, women, elderly, and the differently abled, and livelihood enhancement
projects; monetary contributions to academic institutions for establishing endowment funds, chairs,
laboratories, etc., to assist students in their studies.
RURAL DEVELOPMENT PROJECTSStrengthening rural areas by improving accessibility, housing, drinking water, sanitation, power, andlivelihoods, thereby creating sustainable villages.
GENDER EQUALITY AND EMPOWERMENT OF WOMEN
Promoting gender equality and empowering women; setting up homes, hostels, and daycare centers
for women and orphans; setting up old age homes and such other facilities for senior citizens; andadopting measures for reducing inequalities faced by socially and economically backward groups.
ENVIRONMENTAL SUSTAINABILITY
Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal
welfare, agro-forestry, conservation of natural resources, and maintaining the quality of soil, air, andwater including contribution to the Clean Ganga Fund set-up by the Central Government for
rejuvenation of river Ganga.
PROTECTION OF NATIONAL HERITAGE, ART AND CULTURE
Including restoration of buildings and sites of historical importance and works of art; setting up
public libraries; promotion and development of traditional art and handicrafts.
MEASURES FOR THE BENEFIT OF ARMED FORCES
Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed
Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents
including widows.

PROMOTE RURAL SPORTS
Training to promote rural sports, nationally recognised sports, paralympic sports and olympic
sports.
CONTRIBUTION TO PM FUND
Contribution to the prime minister's national relief fund or Prime Minister’s Citizen Assistance andRelief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the central govt.
for socio economic development and relief and welfare of the schedule caste, tribes, other backward
classes, minorities and women.
RESEARCH AND DEVELELOPMENT(a) Contribution to incubators or research and development projects in the field of science,technology, engineering and medicine, funded by the Central Government or State Government or
Public Sector Undertaking or any agency of the Central Government or State Government; and(b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National
Laboratories and autonomous bodies established under Department of Atomic Energy (DAE);
Department of Biotechnology (DBT); Department of Science and Technology (DST); Department ofPharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy(AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense
Research and Development Organisation (DRDO); Indian Council of Agricultural Research (ICAR);
Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR),
engaged in conducting research in science, technology, engineering and medicine aimed atpromoting Sustainable Development Goals (SDGs).
SLUM AREA DEVELOPMENT
For the purposes of this item, the term `slum area' shall mean any area declared as such by theCentral Government or any State Government or any other competent authority under any law for
the time being in force.
DISASTER MANAGEMENT
Including relief, rehabilitation and reconstruction activities including but not limited to COVID-19
related activities.
The Company will give preference to the local area and areas around it where it operates, forspending the amount earmarked for CSR activities.

List of activities not included in CSRNORMAL COURSE OF BUSINESS
Activities undertaken in pursuance of the normal course of business of the company.
ACTIVITY OUTSIDE INDIAAny activity undertaken by the company outside the India (except for the training of the Indian sports
personnel representing any State or Union territory at the national level or India at International level).
POLITICAL CONTRIBUTION
Contribution of any amount directly or indirectly to any political party under section 182 of the Act.
BENEFIT OF EMPLOYEES
Activities that significantly benefit the employees of the company as defined in clause (k) of section
2 of the Code on Wages, 2019 (29 of 2019).
BENEFIT TO ITS PRODUCTS
Activities supported by the companies on sponsorship basis for deriving marketing benefits for its
products or services.
OTHER OBLIGATIONS IN LAW
Activities carried out for the fulfilment of any other statutory obligations under any law in force inIndia.

Wingify CSR Committee
Constitution of CSR Committee:
Corporate Social Responsibility Committee (hereinafter referred to as ‘CSR committee’) comprisesof following individuals as per the requirements of the Companies Act, 2013 and the Rules madethereunder:•••

Mr. Anil Chopra, Director at Wingify
Mr. Paras Chopra, Director at Wingify
Mr. Sparsh Gupta, Director at Wingify

Meetings of CSR Committee:
The CSR Committee shall meet at least once in Year. The meeting shall be held either at theregistered office of the company or any other place, as may be decided by the members.
Physical presence of a minimum of two members of the committee shall constitute the quorum.

Responsibilities of CSR Committee
The CSR Committee shall (a) formulate and recommend to the Board, a CSR Policy which shall indicate the activities to beundertaken by the company in areas or subject, specified in Schedule VII;(b) recommend the amount of expenditure to be incurred on the activities referred to in clause (a);(c) monitor the CSR Policy of the company from time to time;(d) formulate and recommend to the Board, an Annual Action Plan in pursuance of its CSR Policy.
(e) Any other matter as may be entrusted to the CSR Committee by the Board from time to time.

Responsibilities of Board of Directors
The Board shall (a) after taking into account the recommendations made by the CSR Committee, approve the CSR
Policy for the company and disclose contents of such Policy in its report and also place it on thecompany's website, and(b) ensure that the activities as are included in CSR Policy of the company are undertaken by thecompany.

Undertaking CSR Activities
Wingify will undertake its CSR activities, as recommended by CSR Committee, through Wingify
Foundation, CSR arm of the Company, or such other entity/organization as approved by the CSR
Committee.

The Board shall specify the reasons for not spending the amount and, unless the unspent amountrelates to any ongoing project, transfer such unspent amount to a Fund specified in Schedule VII,
within a period of six months of the expiry of the financial year.
However, any unspent amount related to any ongoing project undertaken by the company inpursuance of its CSR Policy, shall be transferred to a separate bank account to be called the Unspent
Corporate Social Responsibility Account, and such amount shall be spent in pursuance of its
obligation towards the CSR Policy within a period of three financial years from the date of suchtransfer.
The surplus arising out of the CSR activities, projects, or programmes shall not form part of thebusiness profit of the Company and be ploughed back into the same project or shall be transferredto the Unspent CSR Account and spent in pursuance of CSR policy and annual action plan of thecompany or transfer such surplus amount to a Fund specified in Schedule VII, within a period of six
months of the expiry of the financial year.

Governance
The Company through a registered entity can undertake CSR activities as per the provisions of theCompanies Act, 2013. Accordingly, Wingify Foundation or such other entity will work closely withand support the Board and the CSR Committee in implementing CSR activities of the Company.
Wingify Foundation or such other entity will assist the CSR Committee in identifying the areas of
CSR activities, programmes, and execution of initiatives as per defined guidelines. Wingify
Foundation or such other entity will also assist the Board and the CSR Committee in reporting the
progress of deployed initiatives and in making appropriate disclosures (internal/external)
periodically.
The Board allocates the budget in line with the provisions of Section 135 of Companies Act, 2013
along with the Companies (Corporate Social Responsibility) Rules, 2014 including the amendments
thereafter. The Board would make changes to the projects in pursuance to this Policy as per therecommendation of the CSR Committee.

Project selection criteria
Wingify will receive requests for funding of projects throughout the financial year. The CSR
committee will evaluate proposals received and will be prioritized after satisfying the following
criteria:•••

Focus Area - Covered under Company’s focus area?
Impact - is there a multiplicative and positive impact from our effort?
Technology - does it use and leverage ICT to scale its impact?

Granularly, the selection of a project to undertake shall go through following filtering process
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How many people benefit, and by how much? - Are we saving lives or improving lives. If so,
how many. Should be a large numbers, directly or indirectly, so that cost per beneficiary is
low.
‘Is this the most effective work our money can achieve? – We shall look at opportunity costfor various options that compete for our funds. If spending the same amount of money andtime achieve better on one project achieve better vis-à-vis others, that project shall be taken.
We’ll be asking, is the project area neglected? - Villages or Cities, Migrant workers .
underprivilege in Delhi or Delhi citizens. Small or large farmers, Govt schools or private
schools. first option in all examples is most preferred.
We'll also ask what would have happened otherwise if we had not funded a project? - Thisway we'll get to know that what matters is not whose outcome been done good but whether
good is done or not; and also the measure of how much good we can achieve is the difference
between what happens as a result of our actions and what would have happened anyway.
We shall ask ourselves about the chances of success, and how good would success be andhow it will look like? This is to calculate the expected value from the project. To calculate theexpected value of each activity, we will look at all the possible outcomes of that activity. For
each outcome, we take the monetary gain or loss and multiply it by the probability of theoutcome. Maximizing expected value shall be the best strategy for our decisions. Simply puthigh value and high probability gives best results.

The Foundation will then forward its recommendations to the CSR Committee. The CSR Committee
will deliberate on the proposals and recommend to the Board for approval.

Implementation
The implementation of the CSR programmes in the given focus areas would be done through Wingify
Foundation or any other NGO/partners with impeccable track record in their respective domains andthe highest sense of ethics and integrity. The CSR committee may appoint officials to manage,
oversee and monitor the execution of the interventions in accordance with the strategy approved by
the CSR Committee.
The interventions are undertaken in a project mode with specific targets, outcome, activities,
milestones and responsibilities of each party written down and signed off by each, as part of the
MOU. The deliverables are mutually agreed by the parties. As a practice, Wingify establishes longterm multi-year partnerships, so as to provide ample time for creating an impact.

CSR Expenditure

CSR expenditure shall include all expenditure including contribution to corpus for projects orprograms relating to CSR activities approved by the Board on the recommendation of its CSR
Committee, but does not include any expenditure on an item not in conformity or not in line withactivities which fall within the purview of Schedule VII of the Act.

Monitoring and Evaluation of CSR Projects
Monitoring is done through regular interactions and site visits are conducted by the officials
authorised by CSR committee members to assess the progress of the project and extend support,
in terms expertise, to the partner. Third party impact assessment is incorporated in the design ofthe project. The projects are apprised annually by such officials, to assess efficacy basis which
addendums are signed for the consequent year and disbursals are sanctioned. Wingify shall beempowered to appoint an external third party to monitor / review / audit the progress (financial andprogrammatic) of the CSR projects.

CSR Reportinga. The Board's Report of a company covered under these rules pertaining to a financial year
commencing on or after the 1st day of April 2014 shall include an annual report on CSR
containing particulars specified in Annexure.
b. Report on Corporate Social Responsibility under CSR-2 -Every company covered under theprovisions of sub-section (I) to section 135 shall furnish a report on Corporate Social
Responsibility in Form CSR-2, with the Ministry of Corporate Affairs for every financial year
as an Addendum to Form AOC-4.
c. Display of CSR activities on its website - The Company shall disclose contents of CSR policy
in its report and the same shall be displayed on the company's website.

Formulation of Annual Action Plan
The CSR Committee shall formulate and recommend to the Board of Directors Annual Action Plan,in pursuance of this Policy, which shall include focus areas for the year, the list of projects to beundertaken, manner of execution, fund utilization, monitoring mechanism, etc.
The Board of Directors may approve the Annual Action Plan with such further conditions as it deems
fit and further alteration of Annual Action Plan at any time during the financial year, should be as per
the recommendation of the CSR Committee, based on the reasonable justification to that effect.

Amendments to the CSR Policy

The provisions of the CSR Policy would be subject to revision/amendment in accordance with thenotifications/circulars/guidelines issued by the Ministry of Corporate Affairs from time to time. The
Company reserves the right to modify, cancel, add, or amend any of the provisions of this Policy, anyrevision shall be subject to the approval of the Board of Directors of the Company.