Conflict of Interest
The Directors and senior management personnel are expected to avoid and disclose any activity or association that creates or
appears to create a conflict between the personal interests and the Company's business interests. A Conflict of interest
exists where the interests or benefits of one person or entity conflict with the interests or benefits of the Company.
Relationships with prospective or existing suppliers, contractors, customers, competitors or regulators must not affect
the independent and sound judgment on behalf of the Company. Directors & the Senior Management personnel are required to
disclose to the Board any situation that may be, or appear to be, a conflict of interest. When in doubt, Disclosure is the
best way out.
It is the general obligation of the Directors to conduct the business and operations of the Company in accordance with the
laws, rules, regulations, agreements, guidelines; standards including Accounting Standards governing its operations in the
geographies where the Company operates. The Directors and Senior Management personnel shall acquire appropriate knowledge of
the legal requirements relating to their duties sufficient to enable them to perform their obligations diligently.
The Directors and Senior Management personnel shall also comply with the internal polices and procedures of the Company to
the extent applicable to them including but not limited to compliance with Prohibition of Insider Trading policy of the
Confidential Information and Corporate Disclosure Policy
The Directors and Senior Management personnel must maintain the confidentiality of information relating to the affairs of the
Company until and unless authorized or legally required to disclose such information; and shall not use confidential
information for their personal advantage. The Directors and Senior Management are obliged to ensure continuous, timely and
adequate disclosure of necessary information to the Company at regular intervals in respect of declarations required to be
made under Applicable Laws, including the Companies Act, 1956 as amended, details of related parties and details of any
material financial and commercial transactions where a conflict of interest is likely.
Fair Dealing, Use and Protection of Company's Assets
The Directors and Senior Management personnel are obligated to deal fairly and honestly with each other, the Company's
associates and with the Company's customers, suppliers, competitors and other third parties. Directors and Senior Management
personnel shall not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information,
misrepresentation or any other unfair dealing or practice. The Directors and Senior Management are required to protect the
Company's assets and properties, records and systems, including intellectual property and ensure their efficient use. The
assets of the Company shall be used for legitimate business purposes and shall not be used for personal purposes. Incidental
personal use, if reasonable, does not amount to violation of the code.
Compliance and Violation of Code of Conduct
It is the duty and obligation of every Director and Senior Management person to comply with this code of conduct and he/she
shall acknowledge and affirm ongoing compliance with the code on an annual basis. This code of conduct shall be posted on the
website of the Company. Any violations of this code shall be promptly reported to the Chairman of the Board or any other
person appointed for this purpose. The Company will take appropriate action against any Director member or the Senior
Management whose actions are found to violate the Code, after giving him/her a reasonable opportunity of being heard.
Waivers and Amendments of the Code
We are committed to continuously review and update our policies and procedures. Therefore, this Code is subject to
modifications. Any amendment / inclusion or wavier of any provision of this Code must be approved by the Company's Board of
Directors and promptly disclosed, if required pursuant to Applicable Laws.
Each of the Directors and members of the Senior Management and every other person to whom this Code is made applicable, shall
file with the Company Secretary of the Company, or any other person appointed for this purpose, a certificate addressed to the
Chairman, by the 1st of April of every year, confirming his/her compliance with the provisions of this Code.