BRISTOL-MYERS SQUIBB INDIA PRIVATE LIMITEDBMSI-OCD-3pS1 CORPORATE SOCIAL RESPONSIBILITY STANDARDI.

SHORT TITLE:
This Standard in relation to the Corporate Social Responsibility ("CSR") of Bristol-Myers Squibb India Private Limited is titledas the "CSR Standard" and shall include any alterations, amendments or modifications hereto from time to time.

II.

VISION STATEMENT, OBJECTIVE AND APPLICABILITY
Bristol Myers Squibb India private limited (“Company”) follows the global Company Standard Operating Procedure, BMS-SOP3p, for Grants, Giving and Corporate Sponsorship Support which includes donation/contribution to comply with corporatesocial responsibility of the Company. The company will adhere to BMS-SOP-3p and prevailing local laws/regulations regarding
CSR activities, projects and programmes.

1.

The CSR Standard sets out our commitment to ensuring that our activities extend beyond business and include
initiatives and endeavours for the benefit and development of the community and society. The CSR Standard lays
down the guidelines for undertaking programmes geared towards social welfare activities or initiatives.

2.

This CSR Standard has been framed in accordance with the applicable provisions of the Companies Act, 2013 ("Act")and the rules issued thereunder.

3.

Notwithstanding anything to the contrary contained in this CSR Standard but subject to applicable law, in the eventthat the Company fails to meet the thresholds set out under Section 135(1) of the Act for three consecutive
financial years, it shall not be required to:

(i)
(ii)

Constitute/maintain the CSR Committee; andComply with the provisions of this CSR Standard

till such time as it again meets the criteria specified in Section 135(1) of the Act.

III. DEFINITION AND INTERPRETATION
1.

"Board" means the Board of Directors of the Company.

2.

"Company" means Bristol-Myers Squibb India Private Limited.

3.

"CSR Activities" means such programs and projects as may be approved by the Board in terms of this CSR
Standard.

4.

"CSR Committee" means a committee constituted by the Board of Directors in terms of Section 135 of the Act andthe CSR Rules.

5.

"CSR Rules" means the Companies (Corporate Social Responsibility Standard) Rules, 2014, as amended from time to
time.

6.

"CSR Expenditure" means the amount recommended by the CSR Committee to be incurred on the CSR Activities inIndia in terms of the Act and the CSR Rules as approved by the Board from time to time.

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7.

"Director" means a member of the Board of the Company.

8.

"Implementing Agency" means an implementing agency as defined under paragraph IV(3).

9.

"Implementation Group" means an implementation group as defined under paragraph IV(2).

10.

"Net Profits" means the net profit of the Company as per its financial statement prepared in accordance with theapplicable provisions of the Act, but shall not include (i) any profit arising from any overseas branch or branches of
the Company (whether operated as a separate companyor otherwise); and (ii) any dividend received from othercompanies in India, which are covered under and complying with the provisions of Section 135 of the Act.

11.

"Society" means a society registered under the Societies Registration Act, 1860 or any other applicable law in India.

12.

"Trust" means a public charitable trust registered under the Indian Trusts Act, 1882 or any other applicable law inIndia.

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

IV. IMPLEMENTATION OF THE CSR STANDARD
The Company will adhere to BMS-SOP-3p and prevailing local laws / regulations.

1.

The Board shall be responsible for implementing the mandate of the CSR Standard and shall ensurethat the CSR
Activities are carried out in accordance with the CSR Standard read with the Act and CSR Rules and the annual action
plan formulated and recommended by the CSR Committee.

2.

The CSR Committee shall approve reconstitution of an implementation group for the purposes of implementation of
the CSR Activities approved by the Board from time to time (the "Implementation Group") and submitting report ofthe progress on the CSR Activities to the CSRCommittee, which shall be further laid before the Board.

3.

Mode of Implementation: The CSR Activities may be undertaken by the Company directly throughits Implementation
Group or with the prior approval of the Board, through any of the following entities as “Implementation Agency”
being duly registered with the Central Government and having a unique CSR Registration Number :(i)Company established under section 8 of Indian Companies Act 2013, or Trust, or Society registered under
section 12-A and 80-G of the Income Tax Act 1961, being established by the Company, either singly or alongwith any other company;(ii)

Company established under section 8 of Indian Companies Act 2013, or Trust, or Society, being established by(Indian) Central Government or (Indian) State Government;(iii)

Company established under section 8 of Indian Companies Act 2013, or Trust, or Society registered under
section 12-A and 80-G of the (Indian) Income Tax Act 1961, and having anestablished track record of at least
three years in undertaking similar CSR activities; or(iv)

Any entity established under an act of (Indian) Parliament or a (Indian) State Legislature.

4.

The Company shall conduct due diligence prior to selection of an entity as its implementation agency, to inter alia
verify the credentials and ensure that the proposed implementation agency iseligible and capable to be appointed as
such.

5.

The Company may engage international organizations for designing, monitoring and evaluation ofthe CSR projects orprogrammes as per its CSR Standard as well as for capacity building of their own personnel for CSR.

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The Company may also collaborate with other companies for undertaking projects or programmes or CSR activities
in such a manner that the CSR committees of respective companies are in a position to report separately on suchprojects or programmes in accordance with these rules.
The Company may collaborate with the group companies / affiliates in consultation with the CSR committee, toidentify, conduct due diligence and contribute to CSR projects. As part of such collaboration, any one of the BristolMyers collaborating group companies / affiliates may engage with Implementation Agencies (including executionof the appropriate memorandum of understanding or any other documents as approved by the CSR Committee) on
behalf of the Company.

V.

6.

The Board shall empower the Implementation Group to finalize, approve and execute various agreements, deeds,
writings, confirmations, undertakings or other documents, as may be necessary, under the Common Seal of theCompany or otherwise, with any party including Implementing Agencies and/or others for the purposes of the CSR
Standard and accept modifications, changes and amendments to any such documents/ agreements as it may deem fit.

7.

In case of failure to ensure the minimum CSR Expenditure i.e. 2% (two percent) of average Net Profits of the Company
made during the three immediately preceding financial years, detailed reasons for the same should be submitted by
the Implementation Group to the CSR Committee and the Board. Further the Board shall duly include such explanationin their annual board of directors’ report.

CSR COMMITTEE
1.

The CSR Committee shall be responsible for providing recommendations to the Board with respect to CSR Activities
that may be undertaken by the Company in accordance with the CSR Standard as well as the Act and the CSR
Rules.

2.

Without prejudice to the generality of the foregoing, the CSR Committee shall be responsible for the following
activities:

(i)
(ii)
(iii)
(iv)

Formulating and recommending CSR activities to the board of directors;
Recommend amount of expenditure;
Monitor CSR Standard of the company; andFormulate annual action plan in pursuance of the CSR Standard in accordance with the applicablelaw, and inclusive of the following items:(a)the list of CSR projects or programmes that are approved to be undertaken in areas orsubjects specified
in Schedule VII of the Act;(b)

the manner of execution of such projects or programmes;(c)the modalities of utilisation of funds and implementation schedules for the projects or programmes;(d)monitoring and reporting mechanism for the projects or programmes; and(e)details of need and impact assessment, if any, for the projects undertaken by the company.

3.

The CSR Committee shall consist of at least two directors of the Company. The number of members of the CSR
Committee and their powers and functions can be specified, varied, altered or modified from time to time by the
Board, subject to the provisions of the applicable law.

4.

The CSR Committee shall hold meetings which shall be attended by minimum of two members of the Committee.
The meetings shall be held at the registered office or at any other place as may be agreed by the members of theCommittee.

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5.

All questions of interpretation or discrepancies which shall arise under, or as a result of, or pursuant to, or inconnection with the implementation of the CSR Standard or any initiative or activities undertaken by the Company interms of the CSR Standard, shall be referred to the CSR Committee for their inputs and the final
decision/determination/ interpretation shall rest with the Board.

6.

No member of the CSR Committee shall be personally liable for any decision or action taken in good faith withrespect to the CSR Standard.

VI. CSR EXPENDITURE
1.

The Company shall spend at least 2% (two percent) of average Net Profits of the Company made during thethree immediately preceding financial years in accordance with the Act and the Rules and the CSR Standard.

2.

The CSR Committee shall recommend the manner in which the CSR Expenditure shall be incurred in a year, in
accordance with the Act and the Rules and the CSR Standard.

3.

The Board shall be responsible for sanctioning the CSR Expenditure and along with the CSR Committee responsible fortaking steps to ensure that the amount for the CSR Expenditure is available to the Implementation Group for
application towards the CSR Activities.

4.

Any surplus arising out of the CSR Activities shall not form part of the business profit of the Company and may only
be re-allocated to the CSR Activities being undertaken in terms of this CSR Standard and the annual action plan for
the financial year in which such surplus has arisen.

5.

In order to count towards CSR Expenditure, CSR Activities must be undertaken in compliance withthe applicable laws
and shall not include the following:

(i)

(ii)
(iii)
(iv)
(v)
6.

activities undertaken in pursuance of normal course of business of the company any activity undertaken by thecompany outside India except for training of Indian sports personnel representing any State or Union territory
at national level or India at international level;
contribution of any amount directly or indirectly to any political party under Section 182 of the Act;
activities benefitting employees of the company as defined in clause (k) of Section 2 of the Code on Wages,
2019 (29 of 2019);
activities supported by the companies on sponsorship basis for deriving marketing benefits for its products orservices; andactivities carried out for fulfilment of any other statutory obligations under any law in force in India.

The Board shall ensure that the administrative overheads shall not exceed five percent of total CSR expenditure of
the Company for the financial year.

VII. CSR ACTIVITIES1.

The Board shall ensure that the CSR Activities that are undertaken by the Company should be within the scope of thefollowing activities:

(i)

(ii)

BMSI-OCD-3pS1.v2

Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care andsanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for thepromotion of sanitation and making available safe drinking water;
Promoting education, including special education and employment enhancing vocation skills especially amongchildren, woman, elderly, and the differently abled and livelihood enhancement projects;

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(iii)

(iv)

(v)

(vi)
(vii)
(viii)

(ix)

(x)
(xi)

(xii)
(xiii)

Promoting gender equality, empowering women, setting up homes and hostels for women and orphans,setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing
inequalities faced by socially and economically back ward groups;
Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro
forestry, conversation of natural resources and maintaining quality of soil, air and water 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 historicalimportance and works of art; setting up public libraries; promotion and development of traditional arts andhandicrafts;
Measures for the benefit of armed forces veterans, war windows and their dependents, Central Armed Police
Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
Training to promote rural sports, nationally recognized sports, paralympic sports and Olympic sports;
Contribution to the Prime Minister's National Relief Fund or Prime Minister’s Citizen Assistance and Relief inEmergency Situations Fund (PM CARES Fund) or any other fund set up by the Central Government for socialeconomic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward
classes, minorities and women;
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 contributions to public funded
Universities; Indian Institute of Technology(IITs); National Laboratories and autonomous bodies establishedunder Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science andTechnology (DST); Department of Pharmaceuticals; 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 at promoting
Sustainable Development Goals (SDGs).
Rural development projects;
Slum area development
Explanation - For the purpose of this item, the item ‘slum area’ shall mean any area declared as such by theCentral Government or any State Government or any other competent authority under law for the time
being in force;
Disaster management including relief, rehabilitation and reconstruction activities; andAny other project as may be specified under Schedule VII of the Companies Act, 2013, from time to time.

2.

The CSR Activities will be carried out in a manner that the preference is to undertake the CSR Activities in and aroundthe local areas where the Company operates.

3.

Based on the scope of activities set out in paragraph VII I. above, the CSR Committee shall provide recommendations to
the Board with respect to specific CSR Activities that may be undertaken by theCompany.

4.

The Board shall ensure that appropriate designated staff or personnel provide adequate assistance (viz. data collection,
survey, quotations and costs involved etc.) to the CSR Committee to enableit to make necessary recommendations
to the Board. For this purpose, the CSR Committee may also approach external consultants for necessary assistanceas it may deem fit at such costs asmay be approved by the Board.

5.

Any CSR Activities to be undertaken by the Company shall be presented to the Board by the CSR Committee alongwith its recommendations:6.

In case any of the CSR Activities to be undertaken are anticipated to be long term i.e. an ongoingproject being of aterm of 3 (three) years excluding the financial year in which it was commenced, then a detailed estimate on
implementation schedule or milestones should be submitted by the CSR Committee to the Board.

7.

Based on the recommendations of the CSR Committee, the Board shall approve the CSR activities of the Company for a

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given financial year.

VIII. MONITORING PROCESS
1.

To ensure that the objectives of CSR Standard are being met in an efficient and effective manner, the utilisation of theamount sanctioned towards CSR Activities should be reported in such manner as the CSR Committee may direct.

2.

In the event any of the CSR Activities are undertaken through an Implementing Agency, the Implementation Groupshould obtain relevant information from the Implementing Agency and ensure that the progress on such CSR Activity
is submitted on a timely basis in such manner as the CSR Committee may direct.

3.

For the purposes of monitoring, the Implementation Group may visit the Implementation Agency site to review CSR
project and carry out inspections as recommended by the CSR Committee from time to time.

4.

Upon receipt of such progress report by the Implementation Group, the CSR Committee may review and deliberate
upon such reports and provide such inputs or recommendations, as it may deem necessary, to the Board.

5.

Notwithstanding anything to the contrary, the Board shall not be obliged to comply with the recommendations of the
CSR Committee.

IX. REPORTING AND RECORD KEEPING
1.

The CSR Committee shall maintain proper minutes of all its meetings.

2.

The Board's report of the Company shall include an annual report on CSR containing the particulars set out inAnnexure A to this CSR Standard and such other details as may be prescribed from time to time under the Act and the
CSR Rules.

3.

In respect of the reporting, the Board will be responsible to ensure that:

(i)
(ii)
(iii)
(iv)

X.

The report of the Board includes the annual report on CSR Activities of the Company and sets out therequisite information in terms of the Act and the Rules;
The contents of the latest and updated version of the CSR Standard is included in the report of the Board;
The contents of the CSR Standard along with composition of the CSR committee, and projects approved by
the Board are also made available on the website (if any) of the Company.
In case of failure to ensure the minimum CSR Expenditure, detailed reasons for the same are adequately
disclosed in the Board Report.

AMENDMENT1.

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

REFERENCES
BMS-SOP-3p, Grants, Giving and Corporate Sponsorship Support
BMSI-TMP-3pS1, Annexure A Format for the Annual Report on CSR Activities

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DOCUMENT HISTORY
Effective Date
See Signature
Manifestation page

Version Number

Description

2

CSR Standard updated based on the amended statutory requirements to include
principles pertaining to spending, monitoring, reporting and other points asprescribed in the Act and Rules

Author(s): Narendra Mundra

Approvers Sanjay Sharma
and Titles:(General Manager, India)

Raghavendra Agarwal(Finance Director, Finance India)
25 March 20191

Author(s): Narendra MundraFirst version
Approvers Jitendra Tyagi
and Titles:(Managing Director)

Raghavendra Agarwal(Finance Director)

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“ANNEXURE -VI
FORMAT FOR THE ANNUAL REPORT ON CSR ACTIVITIESTO BE INCLUDED IN THE BOARD’S REPORT FOR FINANCIAL
YEAR COMMENCING ON OR AFTER 1ST DAY OF APRIL, 2020
1. Brief outline on CSR Policy of the Company.
2. Composition of CSR Committee:
Sl. No.

Name ofDirector

Designation/Nature of
Directorship

Number of Meetingsof CSR held during
the year

Number of meetings of
CSR Committee attended
during the year

3. Provide the web-link where Composition of CSR committee, CSR Policy and CSR projects approved by the board are disclosed on the website of the company.
4. Provide the details of Impact assessment of CSR projects carried out in pursuance of sub-rule (3) of rule 8 of the Companies (Corporate Social responsibility Policy) Rules, 2014, if applicable (attach the report).
5. Details of the amount available for set off in pursuance of sub-rule (3) of rule 7 of the Companies (Corporate Social responsibility Policy) Rules, 2014 and amount required for set off for the financial year, if any
Sl. No.

Financial Year

Amount Available for set off
from preceding Financial
Years (in Rs.)

Amount Required to be set off
for the Financial year, if any(in Rs.)6. Average net profit of the company as per section 135(5). –7. (a) Two percent of average net profit of the company as per section 135(5) –(b) Surplus arising out of the CSR projects or programmes or activities of the previous financial years. –(c) Amount required to be set off for the financial year, if any –(d) Total CSR obligation for the financial year (7a+7b- 7c). –8. (a) CSR amount spent or unspent for the financial year:
Total Amount
Spent for the
Financial Year. (inRs.)

Amount Unspent (in Rs.)
Total Amount transferred to Unspent
CSR Account as per section 135(6).
AmountDate of transfer.

Amount transferred to any fund specified under Schedule VIIas per second proviso to section 135(5).
Name of theFund

Amount.

Date of transfer.

8.(b) Details of CSR amount spent against ongoing projects for the financial year:
(1)
Sl.
No.

(2)
(3)
Name ofItem
the Project from thelist ofactivities in
Schedule VII
to the
Act

(4)
Local
area
(Yes
/No).

(5)
Location of the
project.

State

1.
Total

District(6)
Project
durat-ion.

(7)
Amountallocated
for theproject (in
Rs.).

(8)
Amountspent in thecurrent
fina-ncial
Year (inRs.).

(9)
Amounttransferred to
Unspent CSR
Account for the
project as per
Section 135(6)(in Rs.).

(10)Mode of
ImplementationDirect (Yes
/No).

(11)
Mode of Implemen
tation – ThroughImple-menting
AgencyName

CSR
Registrationnumbe

8. (c) Details of CSR amount spent against other than ongoing projects for the financial year:(1)
Sl. No(2)Name of the
Project(3)
Item from the list ofactivities in schedule
VII to the Act.

(4)
Local
area
(Yes/No).

(5)
Location of the project.

State

(6)
Amount spent
for the project(in Rs.).

(7)Mode of implementation –Direct (Yes/No).

District

2.
3.
4.

(d) Amount spent in Administrative Overheads –(e) Amount spent on Impact Assessment, if applicable (f) Total amount spent for the Financial Year (8b+8c+8d+8e) 8. (g) Excess amount for set off, if any
ParticularTwo percent of average net profit of the company as per section 135(5)

(ii)
(iii)

Total amount spent for the Financial Year
Excess amount spent for the financial year [(ii)-(i)]Mode of implementation –Through implementing
agency.

Name.

1.

Sl. No.
(i)(8)

Amount (in Rs.)

CSR registration number.

(iv)Surplus arising out of the CSR projects or programmes or activities of the previous
financial years, if any(v)

Amount available for set off in succeeding financial years [(iii)-(iv)]

9. (a) Details of Unspent CSR amount for the preceding three financial years:
Sl. No.

PrecedingFinancialYear.

Amount transferred to
Unspent CSR Accountunder section 135 (6)(in Rs.)Amount spent in the Amount transferred to any fund specified under Schedule VII asreporting Financial per section 135(6), if any.
Year (in Rs.).
Nameof theFundAmount (in Rs)

Date of transfer(7)
Amount spent on
the project in
the reporting
Financial Year
(in
Rs).

(8)
Cumulative amountspent at the end ofreporting Financial
Year. (in Rs.)

Amount rema-ining
to be spent insuccee-dingfinancial years. (in
Rs.)

Total
9. (b) Details of CSR amount spent in the financial year for ongoing projects of the preceding financial year(s):(1)
Sl. No.

(2)
Project ID.

Total

(3)
Name of the
Project.

(4)
Financial Year inwhich the project wascommenced(5)
Project duration.

(6)
Total amountallocated for the
project (in Rs.).

(9)
Status of the project-Completed/Ongoing.

10. In case of creation or acquisition of capital asset, furnish the details relating to the asset so created or acquired through CSR spent in the financial year (asset-wise details). –(a) Date of creation or acquisition of the capital asset(s).
(b) Amount of CSR spent for creation or acquisition of capital asset.
(c) Details of the entity or public authority or beneficiary under whose name such capital asset is registered, their address etc.
(d) Provide details of the capital asset(s) created or acquired (including complete address and location of the capital asset).
11. Specify the reason(s), if the company has failed to spend two per cent of the average net profit as per section 135(5).

Sd/(Chief Executive Officer orManaging Director or
Director).

Sd/(Chairman CSR Committee).

Sd/[Person specified under clause(d) of sub-section (1) ofsection 380 of the Act]
(Wherever applicable).

BRISTOL-MYERS SQUIBB INDIA PRIVATE LIMITEDCSR ANNUAL ACTION PLAN FOR THE FINANCIAL YEAR 2023-24
A. CSR Activity Plan:
Sr.
No

Names of CSR
Projects/
Programmes

1

Implementation ofExperiential
Learning Centres
in Telangana
through Janyaa
Lab in a Box
Program

ActiviManner ofty
Execution
under(Direct/
Sched
Throughule
Implementing
VII
Agency)VII
Implementing(ii)
AgencyAllocated
Budgets(INR)

Implementation
Schedules

Modalities ofutilization of funds
in the financial year2023-24

Details ofneed and
ImpactAssessment, if
applicable

21,70,000

During the
FinancialYear

Project amount will Not applicablebeutilizedtoimplement Janyaa
Lab in a Box
Program in around
10
TTWREIS(Telangana Tribal
Welfare Residential
Educational
Institutions
Society) and around
10
TSWREIS(Telangana Social
Welfare Residential
Educational
Institutions
Society) institutionsin Telangana.
The
expenditure
will
be
made
through“JanyaaFoundation”.

2.

Transfer ofamount to United
way of Mumbai
for project
POSHAN andparticipating in
Tata Mumbai
Marathon

VII
(i) &
VII
(ii)

Implementing
Agency5,67,000

During the
FinancialYear

Project amount will Not applicablebe utilized towards
Project Poshan withthe aim to reduceincidencesofmalnutrition in thechildren and tobenefitapproximately 150
students

Note: The allocated budgets for each of the projects are tentative based on the projections, the actual spends mayvary and will be subject to approval of the Board.

*Annual Action Plan was revised vide Circular resolution dated ____of the Board of Directors
The Board may make alterations to the annual action plan, subject to the recommendation of the Corporate Social
Responsibility Committee of the Company as and when future projects are identified by the Company.
B. Monitoring and Reporting Mechanism: Trust/Institute(s) shall provide proof / receipts of utilization of monies towards the activities pursuant to theProject.
**************