CODE OF CONDUCT FOR BOARD MEMBERS AND SENIOR MANAGEMENT

As per Clause 49 of the Listing Agreement, the Code of Conduct is applicable to the -

- Board members (hereinafter referred as Directors)

- Senior Management of the company defined as Senior Management means personnels of the company, who are member of core management team excluding Board of Directors and one level below the Executive Directors including all functional heads (hereinafter referred as Senior Management).

The said codes are required to be posted on the website of the company. All Board Membera and Senior Management shall affirm compliance with the code on annual basis.

The following are comprehensive codes which are applicable to all Directors / Senior Management. However, the provisions shall apply to Executive and Non Executive Directors including Independent Directors only to such extent as may be applicable depending on their respective roles and responsibilities.

1. Directors / Senior Management are accepted to comply with all applicable laws, rules and regulations and all applicable policies and procedures adopted by the company.

2. Directors / Senior Management shall not engage in any business, relationship or activities, which may be in conflict in interest of the company.

3. Any information concerning the company’s business, its customer, suppliers etc., which is not in the public domain and to which the Directors / Senior Management has exceess must be considered confidential and held in confidence, unless authorised to do so and when disclosure is required as a matter of law.

4. Directors / Senior Management should abide by SEBI (Prohibition of Insider Trading) Regulation 1992.

5. Directors / Senior Management are responsible for effective control and appropriate use of all company’s resources entrusted to them in the official discharge of their duties.

6. Intellectual Property Rights (IPR) broadly covers patented or potentially petenable inventions, trade mark, service marks, copy writable subject matter and trade secrets.

Directors / Senior Management shall make their best efforts to protect all such intellectual properties related to the company, as it is critical to the company’s overall success.

7. Any amendment or waiver of any provision of this code should be approved by the Company’s Board of Directors.