CORPORATE SOCIAL RESPONSIBILITY POLICY

For: Goldman Sachs Services Private Limited

Effective Date: [March 8, 2023]
Revision History, page 1

1. INTRODUCTION

The Goldman Sachs Group, Inc. is a leading global investment banking, securities and
investment management firm that provides a wide range of financial services to a
substantial and diversified client base that includes corporations, financial institutions,
governments and individuals. Founded in 1869, the firm is headquartered in New York
and maintains offices in all major financial centers around the world.

Goldman Sachs Services Private Limited (hereinafter referred to as the “Company")

is a company incorporated in Bengaluru, India and is an indirect wholly owned
subsidiary of The Goldman Sachs Group, Inc.

2. OBJECTIVE & SCOPE

This is the Corporate Social Responsibility Policy (“CSR Policy”) for the Company as
required under the Companies Act, 2013 (hereafter referred to as “the Act”), read
with the Companies (Corporate Social Responsibility Policy) Rules, 2014 and other
directions and clarifications issued by the Ministry of Corporate Affairs from time to
time (collectively referred to as the “CSR Regulations”). This policy lays down broad
approach for CSR activities to be undertaken by the Company and direction for
selection, implementation and monitoring of CSR activities as well as formulation of
the annual action plan pursuant to the CSR obligations in the sphere of corporate
social responsibility undertaken by the Company.

The Board of Directors of the Company (“Board”) shall be responsible for implementing
this Policy and shall ensure that the CSR activities are carried out in accordance with
this Policy read with CSR Regulations.

3. CSR COMMITTEE OF THE COMPANY

3.1. Constitution

The Board shall constitute the Corporate Social Responsibility (“CSR”)

committee as a sub-committee of the Board, as required and in compliance with
CSR Regulations.

3.2. Role, Objective and Powers of the Committee

The CSR committee shall assist the Board in implementing the CSR Regulations
and the CSR Policy, and shall also:

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(i) Formulate and recommend to the Board an Annual Action Plan (“Action
Plan”) in pursuance of the CSR policy, which shall include provisions
specified in the applicable CSR Regulations and recommend to the board
any alterations that may be required to such plan during a financial year in
accordance with applicable CSR Regulations.
(ii) Formulate and revise the CSR Policy and recommend the same to the
Board for approval and adoption;
(iii) Recommend CSR activities to the Board as stated under Schedule VII of
the Act;
(iv) Recommend the CSR budget to the Board;
(v) Create a transparent monitoring mechanism for implementation of CSR
initiatives in India;

3.3. CSR COMMITTEE CHARTER

The terms of reference of the CSR committee including frequency of the

committee meeting, quorum, agenda, minutes of the meeting, powers of the
Committee, etc. have been stipulated in the CSR committee charter, which was
approved by the Board in their meeting held on September 1, 2014.

4. CSR ACTIVITIES

The CSR committee shall recommend to the Board for its approval the Action Plan
and CSR activities in pursuance of the CSR Regulations and this CSR policy. Such
CSR activities may be undertaken directly by the Company or in collaboration with
other companies or through implementing agencies as may be recommended by the
CSR committee and approved by the Board from time to time. Subject to the approval
of the Board, the CSR committee is authorized to approve any modification to the
existing Action Plan and or CSR activities or to propose any new activity.

5. GUIDING PRINCIPLES FOR SELECTION, IMPLEMENTATION OF CSR

ACTIVITIES AND MONITORING MECHANISM

5.1 Selection:

• CSR activities to be identified and planned for approval by the CSR committee and
Board with respect to the following focus areas:
➢ Gender Equality and Empowerment of Women: promoting gender equality and
women’s economic empowerment, entrepreneurship and access to capital.
➢ Promotion of education and social innovation: promoting education and skill
enhancement especially among girl children
➢ Health: promoting health care including preventive health care and mental
health care
➢ Environmental Sustainability and betterment.
➢ Disaster Relief and Rehabilitation: managing and responding to disasters
➢ Improvements to immediate local communities or such other causes/initiatives
as approved by the CSR Committee and Board pursuant to Schedule VII of the
Companies Act, 2013.

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 Corporate Social Responsibility Policy

• Company shall ensure that in identifying its CSR activities, preference shall be
given to the local area and areas around which the Company operates. However,
the Company may pursue CSR activities in other areas as well.
• The internal team responsible for CSR will identify and select CSR projects in line
with the Action Plan and present it to the CSR committee for its review. The
committee will review, approve and recommend the projects classified either as
ongoing or otherwise to the Company’s Board for its approval.

5.2 Implementation

Once approved by the Board, the Company will implement its CSR activities directly or in
collaboration with other companies or through Implementing agencies. In case an
implementing agency is engaged, the Company will enter into grant agreements detailing
the objectives and scope of the project, grant disbursement summary, utilization, duration,
reporting and monitoring framework.

5.3 Monitoring mechanism

To ensure compliance with CSR Regulations, the CSR Policy and the Action Plan, the
CSR committee will monitor the projects undertaken by itself or in collaboration with other
companies or through implementing agencies, including assessment of the projects for
the intended purpose and update the Board regarding such monitoring:

Reporting – The Company will ensure that it receives periodic progress reports during the
course of the project and a final report on completion of the project, along with appropriate
documents/records/certificates detailing the grant utilization towards the project.

Monitoring and Evaluation - The project reports and utilization reports received will be
evaluated by the relevant internal teams and reported to the CSR committee. The CSR
committee basis aforesaid reports will recommend any action/course correction, if any to
be taken/made by the Company or implementation agencies, as the case may be.

6. POLICY REVIEW & FUTURE AMENDMENT

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

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Revision History

• As approved by the Board on March 8, 2023 (current; To incorporate minor and

clarificatory language changes)
• As approved by the Board on December 14, 2022 (revised; to align the focus
areas)
• As approved by the Board on March 30, 2022 (revised; to align the Policy to include
implementation of CSR projects by the Company directly or in collaboration with
other companies).
• As approved by the Board on March 31, 2021 (revised; to align the Policy with
Rules of the Companies (Corporate Social Responsibility Policy) Rules, 2014 and
other changes).
• As approved by the Board on March 22, 2021 (revised to align the Policy with
Rules of the Companies (Corporate Social Responsibility Policy) Rules, 2014 and
other changes).
• As approved by the Board on March 25, 2019 (revised to align the Policy with
Rule 5 of the Companies (Corporate Social Responsibility Policy) Rules, 2014
and other changes).
• September 1, 2014 (original)

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