Preamble
Conducting business in full compliance with the applicable provisions of law shall continue to be a matter of fundamental faith shared by the Directors, Senior Management and other employees of the Company. The core value expressed in the code should be shared values within the Company.

All Directors and Senior Management must act within the bounds of the authority conferred upon them and with a duty to make informed decisions and policies in the best interests of the Company and its shareholders/stakeholders.

With a view to maintaining the high standards that the Company requires, the following code of conduct should be observed in all activities. The Company will appoint the Company Secretary as the Compliance Officer.

Honesty & Integrity
All Directors shall conduct their activities, on behalf of the Company and on their personal behalf, with honesty, integrity and fairness. All Directors will act in good faith, responsibly, with due care, competence and diligence, without allowing their independent judgement to be subordinated.   Directors will act in the best interests of the Company and fulfil their fiduciary obligations.

Compliance
Directors are required to comply with all applicable laws, rules and regulations, both in letter and in spirit.   In order to assist the Company in promoting lawful and ethical behavior, Directors must report any possible violation of law, rules, regulation or the code of conduct to the Company Secretary. The Board shall determine appropriate action to be taken in the event of violation of this code. Any question on interpretation under this code will be handled by the Board of Directors or a Committee thereof and also the Board has the authority to waive compliance with this code by any Director or Employee of the Company.

Other Directorships
The Company feels that serving on the Board of Directors of other companies may raise substantial concerns about potential conflict of interest.   Therefore, all Directors must report / disclose such relationships to the Board on an annual basis.

Confidentiality of Information
Any information concerning the Company’s business, its customers, suppliers etc., which is not in the public domain and to which the Director has access or possesses such information, must be considered confidential and held in confidence, unless authorized to do so and when disclosure is required as a matter of law. No Director shall provide any information either formally or informally, to the press or any other publicity media, unless specially authorized.

Prevention of Insider Trading
No Director of the Company shall derive benefit or assist others to derive benefit by giving investment advice from access to and possession of information about the Company, not in public domain and therefore constituting insider information. All Directors will comply with the prevention of insider trading guidelines as issued by SEBI

Gifts & Donations
No Director of the Company or Senior Management Personnel shall receive or offer, directly or indirectly, any gifts, donations, remuneration, hospitality, illegal payments and comparable benefits which are intended to obtain business favors or decisions for the conduct of business.   Nominal gifts of commemorative nature for special events may be accepted and reported to the Board.

Protection of Assets
Directors and Senior Management Personnel must protect the Company’s assets and information and may not use these for personal use unless approved by the Board.

Periodic Review
Once every year or upon revision of this code, every Director and Senior Management Personnel shall affirm compliance with the code on an annual basis.   New Directors will sign such a deed at the time when their Directorship begins. The code of conduct should be reviewed at regular intervals to ensure that it reflects changes in the law / regulatory environment and gives appropriate emphasis to current issues of concern.