Corporate Policies

Corporate Social Resonsibility Policy

1. Preamble:At Global Ispaat Private Limited (‘GIPL’), we believe that business growth must go hand-in-hand with social progress and environmental sustainability. Guided by our core values of “Greener – Stronger – Better”, we are committed to integrating social, environmental, and ethical responsibilities into our governance and business practices.This CSR Policy outlines our vision, focus areas, implementation framework, and monitoring mechanisms, in alignment with the provisions of the Companies Act, 2013.

2. Purpose: In compliance with the legal framework on corporate social responsibility contained in Section 135 and Schedule VII of the Companies Act, 2013 (“Act”) along with Companies (Corporate Social Responsibility Policy) Rules 2014 (“Rules), this Policy establishes a consistent Corporate Social Responsibility (CSR) framework for GIPL. The key purposes of this policy are to:

Identify broad areas in which CSR projects will be undertaken
Serve as a guide in defining, executing, monitoring and reporting all CSR projects
Governance Structure, Implementation strategy & Review mechanism
To align our CSR efforts with Schedule VII of the Companies Act, 2013.
To build meaningful partnerships with communities, NGOs, and government
Institutions for impactful CSR delivery.

3. Focus Areas: GIPL will focus on CSR activities under the following heads:

Education & Skill Development

Supporting education for underprivileged children.
Establishing skill development centres, especially for youth in rural and semi-urban areas.
Promoting digital literacy and vocational training.

Environment Sustainability

Promoting renewable energy, energy efficiency, and sustainable practices.
Afforestation and water conservation projects.
Waste reduction, recycling, and awareness campaigns aligned with Magna’s eco-friendly steel initiatives.

Healthcare & Sanitation

Organizing health camps in rural and industrial belt areas.
Supporting maternal and child health programmes.
Building toilets and sanitation facilities in schools and rural areas.

Rural Development

Infrastructure development in villages (roads, lighting, drinking water).
Supporting livelihood generation projects for marginalized communities.

4. CSR Committee: Board of Directors shall constitute a CSR Committee as per Section 135 of the Act. The Committee shall:

Formulate and recommend the CSR Policy to the Board.
Recommend CSR projects and budget allocations.
Monitor the implementation of CSR activities.
Submit periodic reports to the Board.

The Board’s CSR Committee shall delegate auxiliary power to the CSR Working Committee (comprising of such members as may be nominated by the Board of Directors from time to time) for implementing the CSR Policy on its behalf. The CSR working committee will review and report activities, outcomes and impact of the initiatives on a periodic basis to the Committee/Board. This CSR policy document will be reviewed from time to time and any changes, if necessary, will be approved by the CSR Committee of the Board.

Any surplus arising out of the CSR projects/ programs/ activities shall not form part of the business profit of a company.

5. Implementation, Review & Amendments: CSR initiatives may be implemented directly by the Company or through:

A registered trust, society, or not-for-profit company established under Section 8 of the Act.
Collaboration with other companies, provided separate reporting is ensured.
Preference will be given to areas in and around the Company’s operations, while also supporting national causes.
This CSR Policy shall be reviewed annually by the CSR Committee and recommended for modifications, if any, to the Board.
Amendments may be made in line with changes in the Companies Act, 2013, CSR Rules, or business priorities.

Vigil Mehcanism

1. Preamble:Global Ispaat Private Limited (‘GIPL’) believes in ethical, transparent, and responsible conduct of business. In compliance with Section 177(9) & (10) of the Companies Act, 2013, this Vigil Mechanism / Whistleblower Policy (“Policy”) provides a framework to enable directors, employees, and stakeholders to report genuine concerns about unethical behavior, fraud, or violation of laws, policies, or codes of conduct without fear of reprisal.

2. Objectives:

To encourage reporting of unethical conduct, suspected fraud, or violation of Company rules.
To provide adequate safeguards against victimization of whistleblowers.
To ensure proper investigation and timely corrective action.
To reinforce the Company’s commitment to good governance and accountability.

3. Definitions:

Whistleblower: A director, employee, or stakeholder who makes a Protected Disclosure in good faith.
Protected Disclosure: A concern raised in writing, relating to unethical practices, misconduct, fraud, corruption, misuse of Company resources, or breach of laws/policies.
Subject: The person against or in relation to whom a Protected Disclosure has been made.
Vigilance Officer: A senior officer or director designated by the Board to receive, review, and investigate Protected Disclosures.

4. Scope:

This Policy covers malpractices such as Abuse of authority, Financial irregularities, fraud, misappropriation of funds/assets, Violation of Company Code of Conduct, policies, or applicable laws, Harassment, discrimination, or workplace misconduct and Deliberate concealment of facts or misrepresentation.
Excluded matters: employee grievances relating to appraisal, promotion, or personal disputes (unless involving fraud/harassment).

5. Reporting Mechanism :Whistleblowers may report concerns in writing or by email to the Vigilance Officer. If the disclosure relates to the Vigilance Officer, the complaint may be made directly to the Chairman of the Board. Anonymous complaints may be considered if supported with evidence. All disclosures should contain specific details, evidence, names, and factual background.

6. Protection to Whistle-blower :The Company assures protection against retaliation, harassment, demotion, or termination for disclosures made in good faith. The identity of the whistleblower shall be kept confidential, except where disclosure is required by law. No unfair treatment will be meted out to a Whistle Blower by virtue of his/her having reported a Protected Disclosure under this Policy. The Company, as a policy, condemns any kind of discrimination, harassment, retaliation victimization or any other unfair employment practice being adopted against Whistle Blower. Complete protection will, therefore, be given to Whistle Blower against any unfair practice. Malicious, frivolous, or false disclosures may invite disciplinary action.

7. Manner of receipt and disposal of Protected Disclosures

- Protected Disclosures should be reported in writing by the complainant as soon as possible after the whistle blower becomes aware of the same so as to ensure a clear understanding of the issues raised. The Protected Disclosure should be factual and neither speculative nor in the nature of a conclusion and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern.
- The Vigilance Officer will make a preliminary review and, if necessary, initiate a detailed investigation. Investigations shall be fact-based, unbiased, and documented. The Subject shall be given an opportunity to be heard. Findings will be reported to the Board of Directors for appropriate action.
- All Protected Disclosures should be addressed to the Vigilance Officer as under:

Mr. Kushal Agarwal
E-Mail: kushal@magnasteel.in
In other exception cases Protected Disclosure may also be made to the Board of Directors as under:
E-Mail: globalispat@gmail.com
Or by letter marked “Private and Confidential” addressed as under:

Board of Directors,
Global Ispaat Private Limited, Plot M-18 & 19, Cuncolim Industrial Estate,
Cuncolim, Salcete, Goa, India – 403 703

Whistle Blower must put his/her name to Protected Disclosure. Anonymous/Pseudonymous Protected Disclosures shall be entertained at the discretion of the Board of Directors of the Company.

8. Secrecy & Confidentiality :

All disclosures, evidence, investigation reports, and proceedings will be kept strictly confidential. Information shall only be shared on a need-to-know basis. The Whistle Blower, the Subject, the Compliance Officer and everyone involved in the process shall:

maintain complete and strict confidentiality/secrecy of the matter;
not discuss the matter with any other person other than one required for enquiry/investigation into the matter;
discuss only to the extent required for the purpose of completing the process and investigations;
not keep the papers unattended anywhere at any time; and keep the electronic mails/files under password.

9. Reporting to the Board :The Vigilance Officer shall place before the Board a summary of complaints received, investigated, and resolved.

10. Amendments :This Policy shall be reviewed periodically and may be amended by the Board of Directors to align with applicable laws and evolving business practices.