CORPORATE SOCIAL RESPONSIBILITY (CSR) POLICY

Effective Date: 27th Day of March 2025

SHORT TITLE: This policy in relation to the Corporate Social Responsibility (“CSR”) of
NxtWave Disruptive Technologies Private Limited (“NxtWave”) is titled as the “CSR Policy”
and shall include any alterations, amendments or modifications hereto from time to time.

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1. INTRODUCTION

At NxtWave, we believe in leveraging technology and education to drive positive social
impact. As part of our commitment to CSR, we strive to support initiatives that foster
education, skill development, employability, healthcare and environmental sustainability.

This CSR Policy is formulated in compliance with Section 135 of the Companies Act, 2013
(“Act”), and the Companies (CSR Policy) Rules, 2014, as amended from time to time.

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2. APPLICABILITY

This policy applies to NxtWave, as the company meets the financial thresholds prescribed
under Section 135 of the Companies Act, 2013. In accordance with the provisions of the Act,
any company having a net worth of ₹500 crore or more (or) turnover of ₹1,000 crore or more
(or) net profit of ₹5 crore or more during the immediately preceding financial year is required
to undertake CSR activities. Based on its financial performance, NxtWave falls within this
mandate and is therefore obligated to comply with the applicable CSR requirements.

A Corporate Social Responsibility (CSR) Committee shall be constituted in accordance with
the applicability criteria prescribed under Section 135 of the Companies Act, 2013. In cases
where the constitution of a CSR Committee is not applicable, all CSR initiatives will be
directly overseen by the Board of Directors of NxtWave.

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3. CSR VISION & OBJECTIVES

NxtWave aims to create a meaningful impact through CSR initiatives that:

Promote education, skill development, and employability.
Support environmental sustainability.
Support technological innovations.
Foster healthcare access and community development.

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4. CSR BUDGET & COMPLIANCE

1. CSR Allocation: In accordance with Section 135(2) of the Companies Act, 2013, NxtWave shall allocate and spend at least 2% of the average net profits of the last three financial years on eligible CSR activities. If the company spends an amount in excess of the requirements provided under Section 135 of the Act, it may set off such excess amount against the requirement to spend as may be prescribed by the Act.
2. Treatment of Unspent CSR Funds:
1. Non-Ongoing Projects:
  - 1.1 Any unspent CSR amount not related to an ongoing project shall be transferred directly to a fund specified in Schedule VII of the Act within six months from the end
    of the financial year.
2. Ongoing projects:
  - 2.1 If any amount allocated for a CSR activity classified as an ongoing project remains unspent at the end of the financial year
  - 2.2 The unspent amount shall be transferred to a designated CSR Unspent Account within 30 days from the end of the financial year.
  - 2.3 The funds must be utilized within three financial years from the date of
    transfer for the specified ongoing CSR project.
  - 2.4 If the amount remains unutilized even after three years, it will be
    transferred to a government-specified fund included in Schedule VII of the Companies Act, 2013 within 30 days from the end of the third
    financial year.

5. CSR FOCUS AREAS

CSR activities will be aligned with Schedule VII of the Companies Act, 2013, focusing on
including but not limited to the following key areas:

5.1 Education & Skill Development

Scholarships & Grants: Funding scholarships for economically weaker students.
STEM Education: Supporting Science, Technology, Engineering, and Mathematics
(STEM) learning initiatives.
Vocational Training: Sponsoring technical and vocational training programs to
enhance employability.
Digital Learning: Providing access to online courses and technology-driven education
solutions.

5.2 Environmental Sustainability

Renewable Energy Projects: Supporting clean energy adoption.
Waste Management: Promoting recycling and sustainable waste disposal.
Afforestation & Water Conservation: Initiatives to restore green cover and preserve
water bodies.

5.3 Healthcare & Community Welfare

Public Health Initiatives: Funding medical aid and preventive healthcare programs.
Sanitation & Hygiene: Providing clean drinking water and hygiene awareness
programs.
Disaster Relief Support: Contributing to emergency relief efforts in disaster-affected
areas.

5.4 Technology & Innovation for Social Impact

R&D: Supporting incubators and research projects for social good.
Digital Literacy Campaigns: Empowering underprivileged communities with
technology access.
Collaborations with IITs & Research Institutes: Supporting technological innovations
in various fields including but not limited to education, healthcare, agriculture, space.

6. Implementation & Execution

CSR projects may be implemented through:

Direct execution by NxtWave or through a Trust, or a Society or a company
established by NxtWave or its holding or subsidiary or associate company 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 .
Collaboration with other companies, NGOs, government institutions, industry bodies.
Partnerships with educational and research institutions like IITs.
Contributions to government-notified funds included in Schedule VII of the
Companies Act, 2013.

The company may engage in multi-year projects, ensuring long-term impact and
sustainability.

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7. Monitoring & Reporting

The Board of Directors will oversee CSR spending and implementation.
A CSR Performance Report will be presented annually.
The Annual Board Report will disclose CSR expenditures and progress.
The company will file the MCA Form CSR-2 annually for compliance.

8. CSR Policy Approval & Updates

The CSR Policy and any amendments thereof shall be approved by the Board of
Directors.
The policy will be reviewed annually and updated based on requirements.

Conclusion

This CSR Policy ensures that NxtWave Disruptive Technologies Private Limited complies
with statutory obligations while making a meaningful impact in education, skill development,
technology, healthcare and environmental sustainability. Our commitment to CSR will
enhance social well-being and drive long-term, scalable impact.