CODE OF CONDUCT FOR ALL MEMBERS OF THE BOARD OF DIRECTORS AND SENIOR MANAGEMENT OF THE COMPANY

1. GENERAL STANDARDS OF CODE OF CONDUCT

The Company expects all members of the Board and senior management of the Company to act in the best interests of the Company and its stakeholders. They shall adopt the highest standards of personal ethics, integrity, confidentiality and discipline in dealing with all matters relating to the company.

2. BUSINESS INTERESTS:

The Members of the Board and senior management of the Company shall not engage in any business, relationship or activity, which may be in conflict of interest of the Company. They shall not derive any personal benefit or undue advantages by virtue of their position or relationship with the Company.

3. RELATED PARTY TRANSACTIONS:

Every member of the Board of Directors and officers in the senior management of the company shall :
i) adopt total transparency in their dealings with the Company.

ii) disclose full details of any direct / indirect personal interests in
dealings / transactions with the company, at the beginning of the transaction or at the first time after coming to know of the transaction.

4. STATUTORY COMPLIANCES:

All Directors and Officers are expected to have knowledge of legal obligations relating to their duty and accomplish their tasks in conformity with applicable laws, rules and regulations. They shall always adhere and conform to the various statutory and mandatory regulations/guidelines applicable to the operations of the Company avoiding violations and non-conformities.

5. 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/officer has access or possesses such information must be considered confidential and held in confidence. All confidential information must be used to for company's business purposes only. Special care must be taken to handle the confidential information. All Directors will comply with insider trading guidelines as issued by Securities and Exchange Board of India (SEBI) as well as the Company's Code of Conduct formulated under SEBI (Prohibition of Insider Trading) Regulations, 1992.

6. ELECTRONIC USAGE:

All officers shall utitlize electronic communication devices in a legal, ethical and appropriate manner, only for business purposes of the Company. This policy addresses the company's responsibilities and concerns regarding the fair and proper use of all electronic communication devices within the organisation. Posting or discussing information concerning the Company's services or business on the Internet without the prior written consent of the Chairman and Managing Director of the Company is probibited.

7. USE OF COMPANY'S ASSETS & FUNDS:

Company assets and funds must be used only for business purposes of the Company. All officers are prohibited from using Company assets, funds and confidential or proprietary information or position for personal gain.

8. COMPLIANCE WITH CODE OF CONDUCT:

All the Members of the Board and senior management of the Company shall always abide by the above code of conduct and adhere to these rules in carrying out their duties for the Company. The Company will take appropriate action against any officer whose actions are found to violate these policies. Disciplinary action may include immediate termination of employment.