Introduction
The Board of Directors and Senior management personnel of the Company are committed to maintain the highest standards of ethical conduct. This code of conduct hereinafter called as “code”) reflects the business principles that support this commitment. The Board of Directors are responsible for setting the code and for updating and revision, if required, to reflect legal and regulatory developments. It is expected that every director and senior management personnel of the company to read and understand this code and its application to the performance of their duties.

The Board has designated Mr.S.K.Loyalka, Managing Director of the company to administer the code. Directors, employees may make any report or complaint to the Chairman of the Board or to Mr.S.K.Loyalka for submission to the Board of Directors.

Fair Dealing
Board of Directors and Senior Management Personnel will discharge their duties in accordance with their good faith, business judgement and in the best interests of the company and its stakeholders. They are expected to use their best endeavors and organize the resources for advancing company’s Mission, Aspiration, Values and Leadership Attributes. They are expected to act diligently, openly, honestly and in good faith. 

Compliance with Laws
They must abide by all laws, rules and regulations of the country applicable to the company and company’s insider trading norms. 

Conflict of Interest
A “conflict of interest” may arise when the interests of a corporate leader conflict in any way (or even appear to conflict) with the interests of a corporate entity. Any situation that creates or appears to create a conflict of interest must be avoided. They shall disclose conflicts of interest, if any, to affected parties including but not limited to Board of Directors when they exist. 

Corporate Opportunity
Except as may be approved by the Board of Directors, they are prohibited from :- 

(a) taking for themselves personally any opportunities that belong to company or are discovered through the use of corporate property, information or position ;

(b) using corporate property, information or position for personal gain ; and 

(c) competing with company. 

Confidentiality of information
They must maintain the confidentiality of all material non-public information entrusted to them by company, except when the company authorizes disclosures or required by laws, regulations or legal proceedings. 

Protection and proper use of assets
They shall ensure protection and efficient use of company’s assets. Company resources should be used only to conduct company’s business.

Reporting of illegal or unethical behaviour
They and all the employees are encouraged to report to the Chairman of the Board about any illegal or unethical behaviours of any employee, officer or director. 

Public Disclosure
They may be asked to provide information so that company’s public disclosure requirements should be full, fair, accurate, timely and understandable.

Compliance with code and violation
All the persons to whom such code is applicable shall agree to support a mechanism for the prompt and fair adjudication of alleged violations of this code.

Amendment and Modification
This code may be amended, modified by the Board subject to the provisions of applicable laws, rules and regulations of the country.