CSR Policy

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Sustainable Development

Preamble
Lafarge Umiam Mining Private Limited (LUMPL) is a company incorporated in India, hereinafter referred to as “the Company”. LUMPL is a subsidiary of LafargeHolcim Bangladesh PLC. (LHB) in Bangladesh which is in the business of limestone and shale related mining in Meghalaya, India. The mines are captive mines for a cross-border cement manufacturing plant set up by LHB in Bangladesh.

LUMPL from its inception is committed to undertake Corporate Social Responsibility (“CSR”) activities per the provisions of Section 135 of the Indian Companies Act, 2013 (“the Act”) and its related Companies (Corporate Social Responsibility Policy) Rules, 2014 (“CSR Rules”). Notwithstanding the foregoing and in line with the regulatory expectations, the Company hereby puts in place this formal policy as a further guide towards its social commitment going forward, hereafter the “CSR Policy”. The current CSR Policy has been revised in light of the requirements of section 135 of the Indian Companies Act 2013 and Holcim Strategic Social Investment, Sponsorship & Donation Directive. In any case of ambiguity or contradiction, Indian law shall prevail.

Objectives
This CSR Policy reflects the Company’s commitment to sustainable and inclusive development by fostering social, environmental, and economic well-being in the communities it serves—particularly in regions where the Company operates. In alignment with this commitment, the Policy sets out the following key objectives:

To contribute to the company’s CSR focus areas—such as education, healthcare, environmental sustainability, and infrastructure development —by implementing structures that contribute to address community needs and align with the company’s values and regulatory responsibilities.
To ensure that contributions made by LUMPL improve the well-being of the communities and the environment in the countries where LUMPL operates whilst complying with national, international human rights, internal anti-bribery and anti-corruption standards.
To establish and operate a CSR Committee as per the Act to allocate CSR expenditure annually. Establishing a monitoring and reporting mechanism to the CSR Committee and Board.
Implement CSR activities in line with Schedule VII of the Companies Act, 2013 and aligned with Company policies and in line with Holcim’s control framework, policies and procedures.
To ensure approval is taken as per Delegation of Authority through the digital platform of Integrity Gateway tool and to record all documentation of the CSR contribution in the Integrity Gateway tool.

The Beneficiaries
The Beneficiaries of the CSR activities are the communities where the Company operates, where the Company shall give preference to the local area and areas around the Mining operations, for spending as a minimum the amount mandated by law for Corporate Social Responsibility activities. Any projects or programs or activities that only benefit LUMPL, LHB or their employees and families shall not be considered as CSR activities in accordance with section 135 of the Act.

Definition

CSR activities/projects/contribution mean Charitable Sponsorships, Donations to charities, educational institutions and any other organization that contribute to the well-being of communities and the environment. Contributions shall be made in the Focus Areas defined in clause 5 of the CSR Policy.
Holcim Integrity Gateway Tool (IGT) means a digital tool applicable for recording all contribution requests, documentation, reviews and approval for the contributions.
Implementing Partner means an organization or institution or service provider working towards a cause aligned with Schedule VII of the Act or ultimately responsible for execution of the CSR activities on behalf of the Company.
Holcim Policies/ Company policies mean Strategic Social Investment, Charitable Sponsorship & Donation (SSI) Directive, Human Rights & Social Policy, Group Delegated Authorities of Holcim Group, Holcim Procurement Policy and Anti-Bribery & Corruption Policy and Code of Ethics of Holcim Group.

CSR Focus Areas
LUMPL shall undertake CSR projects in the following focus areas, among others permitted under Schedule VII of the Companies Act, 2013. However, as the law has a wider scope for CSR activities, in case any CSR initiatives are allowed under the law and does not fall within the scope of the Policy, that would be considered as exception to the SSI directive and in such case, CSR team shall need to mention this during the approval process. The sub activities under the focus areas are mentioned as indicative and new initiatives and projects may be implemented as per the changing need of the Community under the focused areas.

CSR projects undertaken by LUMPL shall strive to fulfil three key goals:

Driving Sustainable Impact: Initiatives shall prioritize vital activities (e.g., health clinics) or, ideally, generate long-term, sustainable impacts (e.g., water harvesting, scholarships), ensuring that sustainable impact remains at the core of every investment.
Fostering Community Trust: Cultivate and strengthen trust and relationships with communities in and around our operational areas.
Ensuring Strategic Implementation: Projects shall be well-planned, informed by tools like the upcoming Scorecard tool developed by the Holcim Group, thereby avoiding purely reactive responses.

A. Education:

Promoting education, including special education and employment-enhancing vocational skills.
Supporting infrastructure development in schools, transportation of students.
Providing learning aids and others support to the students of the local Communities.
Student felicitation program on merit basis financial assistance for higher education.
Other programs relating to the enhancement of the education of the people of the Community.

B. Healthcare:

Promoting preventive and general healthcare.
Organizing health awareness programs, medical camps, cleaning and sanitation initiatives.
Assistance for supply of safe drinking water to the Community.
A CSR clinic is run by one doctor and staffed with a full-time nurse and helper to support ongoing community health needs. In Shella, temporary clinics are operated in community-designated spaces such as Dorbar halls, schools, or other available venues.
Essential medicines and medical supplies for both Nongtrai and Shella visits are procured under the CSR budget, ensuring continuity of care and access to basic treatment for the local population.
LUMPL has donated two ambulances to support the local communities, enhancing access to hospitals and emergency medical services in the main city.

C. Environment:

Ensuring ecological balance and environmental sustainability.
Projects related to renewable energy, afforestation, water conservation, and waste management.

D. Infrastructural Development:
Supporting community infrastructure such as roads, bridges, sanitation, community centers and other common infrastructures which will benefit the community in general.

E. Other Activities:
As permitted under Schedule VII of the Companies Act, including support during disasters or calamities, women empowerment, livelihood (i.e. relating to earning for the community), cultural activities, sports and any other areas/activities not inconsistent with the Company policies

CSR Committee

6.1. Composition
In terms of section 135 of the Companies Act, 2013 and rules made thereunder the CSR Committee of the LUMPL Board of Directors (“Board”) shall be composed of at least three (3) Directors (hereafter referred as the “CSR Committee”).

6.2. Members of the CSR Committee may be replaced by any other member of the Board.

6.3. Committee meetings
Meetings shall be held four (04) times in a year preferably on a quarterly basis. The minutes of the CSR Committee shall be presented before the Board for review.

In case of any urgent decision required by the Committee whereby a regular meeting is not scheduled, in such cases a circular resolution may be passed to recommend the Board for necessary approval.

6.4. Duties & Responsibilities of the CSR Committee

The CSR Committee shall quarterly review, and recommend changes to Annual CSR Plan, Annual CSR Budget, prepared and submitted by the LUMPL CSR Team to the CSR Committee.
Approve the CSR budget for the full year (succeeding year) and recommend for LUMPL Board approval.
The CSR Committee shall ensure approval of the changes of this CSR policy and to report all the decisions taken by the CSR Committee to the Board of Directors.
The CSR Committee shall formulate a transparent mechanism to carry out the CSR activities and recommend the internal processes to be undertaken by the Company as mandated by the policy and laws.
The CSR Committee shall oversee the CSR activities implementation in compliance with applicable rules, this policy and reporting obligations under the Companies Act, 2013 and related Holcim policies including impact assessment of CSR projects.
The CSR Committee is responsible for reviewing and recommending any budget revision, transfer of unspent budget as per the Act and rules, re-spending earnings from CSR initiatives, and reviewing and setting off any excess expenditure to be adjusted as per the Act and rules without changing the total allocated budget by the Board. CSR Committee shall then place and recommend the amended budget to the Board for approval.
An external auditor may be appointed to independently review CSR expenditures and assess project implementation. The appointment shall be based on the recommendation of the CSR Committee and is subject to the approval of the Board.

Responsibilities of the CSR Team

Project planning & budget: The CSR Team shall identify potential projects aligned with the CSR focus areas of this Policy. These projects shall include detailed proposals with financial estimates, implementation plans, and expected outcomes/community impact for the Committee’s review and approval. CSR Team may operate complex CSR projects as per Standard Operating Procedures (SOP) to be recommended by the CSR Committee.
Project execution, Monitoring and evaluation: Monitor the execution and progress of the CSR initiatives either directly or through other external organizations (as permitted by the Act), ensuring regular field visits, status reports, and interactions with stakeholders. The Department shall assess whether the projects are meeting their goals/KPI and share updates with the CSR Committee on a regular/quarterly basis. The CSR team will ensure proper documentation is in place for the initiative and conduct inspections and impact assessments.
Documentation: Ensure that all CSR activities are carried out in accordance with the Companies Act, 2013 and applicable CSR Rules. CSR Team is responsible to maintain proper documentation and support the CSR Committee and statutory auditors during reviews and audits, as per clause 13 of this Policy and other Company Policies.
Holcim Minimum Control Standard (MCS): The CSR Team shall adhere to MCS 32 for payment processing for the CSR all expenditures and shall comply with MCS 62 to ensure reporting and adherence to Holcim Human Rights and Social Policy and the Human Rights Directive.
Implementation Report: The CSR Manager /person(s) responsible for overseeing CSR initiatives shall prepare and submit an implementation report on a quarterly basis to the CSR Committee of the Company. This report shall include updates on the KPI’s such as implementation of the CSR initiatives, reconciliation of approvals against actual expenses from GL against budget, CSR impact assessment, changes in the budget, projected surplus CSR expenditure or projected unspent CSR expenditure or any other challenges of the CSR initiatives.
In case there are any residual earnings from any CSR initiative, the earnings must be reinvested by the CSR Team in the same CSR project, latest within the following 6 (six) months. This is subject to prior approval from the CSR Committee.
The CSR Team shall ensure half yearly reconciliation between the General Ledger and the records maintained in the IGT to verify accuracy of the CSR expenditures and approvals. Discrepancies, if any, must be promptly identified, investigated and resolved in coordination with the Finance and Compliance team.

Roles and responsibilities of affiliated functions
Implementing CSR initiatives within the Company necessitates a coordinated and collaborative approach, engaging key departments such as Finance, Procurement and Legal & Compliance. This cross-functional teamwork ensures that CSR activities are effectively planned, executed, and aligned with both organizational objectives and regulatory requirements. Following are the affiliated roles and responsibilities of the concerned departments:

a. Finance:

The Finance Department shall promptly inform the CSR Committee and the CSR Team regarding the average net profit to be considered for the annual CSR budget calculation, in accordance with Clause 9.1(i) & (v) of the CSR Policy.
The Finance Department shall maintain separate General Ledger (GL) for CSR expenditures.
Before the disbursement of funds, the Finance Department serves as the final checkpoint, ensuring that all disbursement requests have adhered to the approval flow outlined in clause 10 of this Policy.
The Finance shall adhere to clause 9.5 for disbursement of unspent CSR expenditure.

b. Procurement:

Procurement shall ensure that with regards to the engagement of vendor/implementing partner for CSR activities required to be selected as per the Act, CSR Rules and Holcim Policies.
When a vendor is assigned to implement a CSR project, the CSR Team will coordinate with the Procurement team. The Procurement team shall conduct Third Party Due Diligence and necessary screening prior to onboarding and disbursement of fund to the vendor/recipient.
The Company strictly prohibits the splitting of Purchase Order with regards to a single project to circumvent the established thresholds for CSR project approvals.

c. Legal: The CSR team will collaborate with the Legal team to obtain assistance in drafting memorandums of understanding and/or agreements related to the scope of services and other terms. Legal team will also review/verify the Statutory reporting are duly filed before the regulators as per legal requirements

d. The Compliance and Human Rights and Social Impact teams (Holcim Group) is responsible for reviewing project scope, recipient/implementing partners/vendors screening in the IGT. If any screening hits are identified, Compliance will inform the requestor to address and resolve the issue. Compliance will also verify that the request aligns with Company’s policies and that all required documentation has been properly submitted. Before granting approval through the Holcim Integrity Gateway Tool, Compliance may assign tasks to the requestor or request additional supporting documents.

e. Working with Integrity (Conflict of Interest) – All members of the CSR Team including employees of affiliated functions with regards to any potential conflict of interest, which includes but not limited to any personal, financial, or professional connection with vendors, partners, or project beneficiaries, must be promptly disclosed to the Compliance and HR team for evaluation and agree on necessary action plan for remediation of any potential conflict of interest if exist during discharging the CSR activities.

Financials

9.1. Annual CSR Budget-

The Company shall annually allocate and spend at least 2% of the average net profits of the Company made during the three immediately preceding financial years on CSR activities as specified in Schedule VII of the Act (“CSR expenditure”).
The CSR Committee shall be responsible for recommending an annual CSR budget to the Board of Directors. This recommendation shall be made in the 4th quarter of the preceding financial year (based on unaudited accounts) on a provisional CSR budget, ensuring that adequate resources are planned and allocated well in advance.
The CSR budget will be prepared annually and detailed across different expense heads such as Health, Education, Infrastructure, Environment & others.
In case, the budget needs to be revised for a project/project head it is required to be reviewed by the CSR Committee members.
Final CSR budget shall be fixed and approved by the Board based on full year audited accounts and following the calculation matrix including any revision. No expenses shall be made beyond the approved budget of the Board.
The reviewer (i.e. Legal, Compliance and Finance) will review and verify that classifications into expense heads are appropriate and that all assumptions and projections are realistic in compliance with Law and the policies.
Administrative Charges: As per law, administrative overhead must not exceed 5% of the total CSR budget in any financial year. The areas of administrative cost/expenses for CSR projects monitoring and implementation shall be within the scope limited under CSR rule 7 (1).

9.2. Fund disbursement and utilization

The CSR Team will verify that the budget aligns with both the Company’s strategic objectives and available CSR funds derived from the applicable statutory requirements.
No payment shall be made to any individuals.
All CSR projects must be approved in their entirety to ensure adherence to the prescribed approval and budgetary controls.
All disbursements shall be monitored and tracked against approved budgets.
All CSR expenditures must be made through traceable, non-cash transactions. Cash payments are strictly prohibited.

9.3. Reporting financials to CSR Committee

The CSR Team shall maintain proper records of the CSR expenditures, prepare quarterly utilization reports, and present the same to the CSR Committee. The Committee shall review the financial status of CSR initiatives and ensure that expenditures are in line with the approved budget and objectives. The Company shall maintain separate records for CSR spending and ensure that all CSR financials are subject to internal review and disclosed in the Company’s annual report in the manner prescribed under the Act.

9.4. Change in CSR budget Surplus CSR expenditure

At any point of time, if the Company requires an additional budget for CSR activities, due to an urgent Community need, then the additional budget requires CSR Committee and Board approval.
In any case, the CSR Committee/Board approves, and the Company spends an amount in excess of the annual CSR budget, the Company can set off such excess amount up to immediately succeeding three financial years, and the Board shall pass a resolution to that effect. [Rule 7(3) of CSR Rules].
CSR Team must notify and seek approval of the CSR Committee when a project expenditure exceeds the allocated budget than anticipated.
In the event of any excess expenditure arising after a project’s approval in the IGT, the CSR team shall initiate a revised approval request reflecting the total projected cost. This request must be accompanied by the CSR Committee members’ comments and formal approval, along with a clear explanation outlining the reasons for the additional expenditure, with information of the previously approved request. Although the revised request will be for the total expenditure, in principle, the approval and review will be for the additional/surplus amount only.

9.5. Unspent CSR expenditure

a. Identification of Unspent Amount:
At the end of each financial year, the Finance and CSR teams shall jointly review the status of all approved CSR projects and identify any unspent CSR amount. This may arise due to delays in implementation, pending approvals, or partial completion of multi-year projects.

b. Categorization of Unspent Amount:

Ongoing Projects: If the unspent amount pertains to an “ongoing project” as defined under Rule 2(1)(i) of the Companies (CSR Policy) Rules, 2014, it shall be transferred to a special account named ‘Unspent CSR Account’ within 30 days from the end of the financial year.
Other than Ongoing Projects: If the unspent amount is not related to an ongoing project, it shall be transferred to a fund specified under Schedule VII (e.g., Prime Minister’s CARES Fund) within 6 months from the end of the financial year.

c. Approval Process for unspent amount:

The CSR team shall prepare a detailed note justifying the categorization of the unspent amount and the proposed course of action.
The CSR Committee shall evaluate the note and recommend the proposed transfer (either to the ‘Unspent CSR Account’ or a Schedule VII fund).
The final approval shall be placed before the Board of Directors for resolution in a duly convened meeting.

d. Fund Transfer Mechanism:

Upon Board approval, the Finance Department shall process the fund transfer within the timelines prescribed under the law.
In case of transfer to the ‘Unspent CSR Account’, the account shall be opened with a scheduled bank and shall be used only for the purpose of CSR in accordance with the CSR policy.
In case of transfer to a Schedule VII fund, the Finance team shall ensure proper documentation and acknowledgment of the transfer from the beneficiary fund.
Details of unspent amounts and transfers shall be disclosed in the Board’s Report and CSR Annual Report in the prescribed format (Annexure II of CSR Rules).

e. Integrity Gateway Tool and approval flow
There are two layers of approval process, one as per statutory compliance of the Act and second as per the compliance with the Company policies.

Firstly, CSR Committee and the Board will annually approve the annual CSR Budget for the year.
Secondly, once the budget is approved, prior to execution of the CSR initiative or CSR project, a requestor or the CSR Team will raise a request for approval in the IGT. All employees of LUMPL must use the Holcim Integrity Gateway to record any request for contributions and adhere to designated process flow requirements.
Contributions can only be made after all approvals have been obtained. Contributions should always be requested and approved in a single event, and requesters must refrain from splitting initiatives into smaller requests with the intention to bypass approvers, expedite the process, and alleviate the evidence to provide, etc.
The table below illustrates the threshold for approval and Delegation of Authority for Corporate Social Responsibility contributions:

Recipient	Amount	Pre-assessment	Sustainability function	Compliance Function	Management approval
Private Entity	A ≤ 500 CHF	Country CSR coordinator	N/A	N/A	Country request: Country CEO
Private Entity	500 < A ≤10K	Country CSR coordinator	N/A	Country Compliance	Country request: Country CEO
Public Authority	0 < A ≤10K	Country CSR coordinator	N/A	Area Compliance Officer	Country request: Country CEO
				or
				Regional Compliance Officer*
Private Entity & Public Authority	10K < A ≤50K	Country CSR coordinator	Group Human Rights/CSR	Regional Compliance Officer	Country request: Country CEO and Head of Region


Private Entity & Public Authority	50K < A	Country CSR coordinator	Group Human Rights/CSR	Regional Compliance Officer	Country request: Country CEO and Head of Region and Chief Compliance Officer and Chief Sustainability Officer

Implementing CSR activities

The implementation and execution of the CSR activities/projects shall be carried out through the Company’s CSR Team.
Affiliated departments (CSR, Finance and Procurement or any other) shall receive training to implement this Policy and Holcim Policies by the Legal & Compliance Team: attendance sheet and meeting invites shall be preserved as evidence.
Engagement through external organisation: The Board of the Company may, in the future, decide to undertake and implement its CSR activities through a registered trust or registered society or a Section 8 company (Non-profit entity) established by the Company under Section 8 of the Act. In that case, the CSR Team must monitor and documentation the activities and report to the CSR Committee accordingly as per Company Policies.
Holcim Supplier Code of Conduct for external engagement:

a. All external engagements (NGOs, partner organizations, etc.) will undergo thorough due diligence as per the Holcim Supplier Code of Business Conduct and Holcim Procurement Policy and Holcim Procurement Policy.

b. Performance metrics and compliance criteria will be monitored quarterly by the CSR Committee to ensure adherence to CSR objectives.

Documentation and Record Keeping

All Contributions must be appropriately documented according to the requirements in the Holcim Integrity Gateway and SSI Directive, financial process requirements and best practices.
A contribution request must contain a request letter from any of the recipients/beneficiaries/facilitators of the contribution.
Every request must be supported with any underlying information and documentation (such as a presentation about the project with a detailed project plan, and its impact, the implementation partner, a memorandum of understanding/agreement or any other reasonable proof of receipt or contribution made.
Request for Infrastructure: Any request for infrastructure support must be accompanied by a report detailing the current condition of the existing facilities (if any) and the proposed layout or design. The report should clearly outline the specific issue the proposed infrastructure aims to address. The report must contain the breakdown of the cost from the vendor, the procurement process is to be followed.
Post approval/ for record keeping, Holcim Integrity Gateway is a unique repository of all documents and evidence supporting each Contribution. This may include photographs, acknowledgement of receipt, documents substantiating project activities and implementation and any other documentation requested by the compliance department.

Reporting Framework

i. Quarterly Reporting
CSR Team will prepare comprehensive reports detailing progress on all CSR projects and expenditure are to be prepared and presented to the CSR Committee at quarterly meetings. This reporting may include explanations for any significant variances and corrective actions to be implemented, if any.

ii. Impact Assessment
The CSR Team shall present a quarterly impact assessment to the CSR Committee of the CSR initiatives that has been undertaken to evaluate not only financial performance but also qualitative outcomes and community benefits.

iii. Directors’ Report
On an annual basis, the Directors’ Report of the Company will include a section on CSR reporting as specified in the Companies (Corporate Social Responsibility Policy) Rules, 2014 as amended from time to time.

Website display
The Company shall display on its website (www.lumpl.com) the contents of its CSR Policy and other information as may be required to be displayed pursuant to the applicable provisions of the Companies Act, 2013.

Amendments
This Policy may be reviewed and amended from time to time with approval from the CSR Committee and Board of Directors.