V. Honest and ethical conduct:
All Officers shall act in accordance with the highest standards of personal and professional integrity, honesty and ethical conduct while working not only on company’s premises and offsite but also at company sponsored business, social events as well as any places. They shall act ethically and conduct free from fraud and deception. Their conduct shall conform to the best accepted professional standards of conduct. Ethical conduct includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.

VI. Insider Trading:

The company has adopted a Code of Conduct for Prevention of Insider Trading which all Board Member and Senior Management Personnel should observe with respect to the purchase and sale of the Company’s securities.

Board Member and Senior Management Personnel should direct questions regarding the application or interpretation of these guidelines to the Compliance Officer.

VII. Fair Dealing:
All Officers should deal fairly with the customers, suppliers, competitors and employees of group companies. They should not take unfair advantage of anyone through manipulation, concealment, abuse of confidential, proprietary or trade secret information, misrepresentation of material facts or any other unfair dealing practices.

VIII. Protection and proper use of Company’s Assets:
All Officers have a responsibility to protect the Company’s assets and property, ensure its efficient use at all times for the growth of the Company and report and record all transactions. Theft, damage, loss, carelessness and waste of the Company’s assets and property have a direct impact on the Company’s profitability. Officers who have access to the Company’s assets, property and confidential information must take every precaution to protect such assets, property and information. Company’s assets should be used only for legitimate business purposes Every Officer must protect the reputation of the Company, its employees and its products.

IX. Compliance with Laws, Rules and Regulations:
Officers must comply with all applicable governmental laws, rules, regulations and notifications at all times. Officers shall acquire appropriate knowledge of the legal requirements relating to their duties and responsibilities sufficient to enable them to recognize potential dangers and to know when to seek advice from the Board of Directors or any person / Committee designated for this purpose. Any Officer who is unfamiliar or uncertain about the legal rules/requirements involved should consult the legal department of the Company before taking any action that may jeopardize the Company or that individual.

Transactions, directly or indirectly, involving securities of the Company should not be undertaken without pre clearance from the Company’s Compliance officer, who is the Company Secretary. Any violations of applicable laws, rules, regulations and notifications may subject Officers to individual criminal or civil liability as well as disciplinary action by the Company.

X. Privacy and Confidentiality:
“Confidential information” includes all trade related information, trade secrets, confidential and privileged information, buyer / customer information, employee related information, strategies, commercial, administration, technical, legal, scientific and research information that are provided to or made available to the Officer of the Company or that the Officer is able to know or has obtained access by virtue of his employment or position with the Company. All Officers shall maintain the confidentiality of confidential information of the Company or that of any customer, supplier or business associate of the Company to which Company has a duty to maintain confidentiality, except when disclosure is authorized or legally mandated. The use of confidential information for his /her own advantage or profit is strictly prohibited.

XI. Compliance with Code of Conduct:
All Officers of the Company must comply with this Code in letter and spirit. Any Officer, who knows of or suspects of a violation of applicable laws, rules or regulations or this code of conduct, must immediately report the same to the Board of Directors or any designated person/committee thereof. Such person should as far as possible provide the details of suspected violations with all known particulars relating to the issue. The Company recognizes that resolving such problems or concerns will advance the overall interests of the Company that will help to safeguard the Company’s assets, financial integrity and reputation. Violations of this code of Ethics will result in appropriate disciplinary action, which may even include termination of services of the employee. The Company’s Board or any Committee / person designated by the Board for this purpose shall determine appropriate action in response to violations of this code of Ethics.