1. Honesty & Integrity
All directors and senior management shall act their activities, on behalf of the Company and on their personal behalf, with honesty, integrity and fairness. All directors and senior management will act in good faith, responsibility, with due care, competence and diligence, without allowing their independent judgment to be subordinated. Directors will act in the best interests of the Company and fulfill the fiduciary obligations.

2. Conflict of Interest
Directors on the board of the Company and senior management personnel shall not engage in any business, relationship or activity, which may be in conflict of interest of the Company or the group.
Conflicts can arise in many situations. It is not possible to cover every possible conflict situation and at times, it will not be easy to distinguish between proper and improper activity. Set forth, are some of the common circumstances that may lead to a conflict of interest, actual or potential –

a.	They should not engage in any activity / employment that interferes with the performance or responsibility to the company or is otherwise in conflict with or prejudicial to the company.
b.	Directors and senior management and their immediate families should not invest in a company, customer, supplier, developer or competitor and generally refrain from investments that compromise their responsibility to the company.
c.	Directors and Senior Management Personnel should avoid conducing company business with a relative or with a firm / company in which a relative / related party is associated in any significant role.
	If such related party transaction is unavoidable, it must be fully disclosed to the board of the company.

3. Corporate Opportunities
Directors and Senior Management Personnel shall not exploit for their own personal gain, opportunities that are arises through the use of corporate position, information or property unless the same is disclosed in writing to the Board of Directors of the Company.

4. Compliance with Laws, Rules and Regulations
Directors and Senior Management Personnel are required to comply with all applicable laws, rules and regulations, both in letter and spirit. In order to assist the company in promoting lawful and ethical behaviour, directors must report any possible violation of law, rules, regulation or the code of conduct to the compliance officer.

5. Other Directorships
The Company feels that serving on the boards of directors of other companies may raise substantial concerns about potential conflict of interest. And therefore, all directors must report / disclose such relationships to the Board on an annual basis. It is felt that service on the board of a direct competitor is not in the interest of the company.

Senior Management must obtain the approval of the Company before accepting a directorship.

6. Confidentiality of Information
Any information concerning the company’s business, its customers, suppliers etc., which is not in public domain and to which the director or senior management 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 or management personnel shall provide any information either formally or informally, to the press or any other publicity media, unless specially authorized.

7. Insider Trading
The Company has formulated a Code of Conduct for Insider Trading and code of Corporate Disclosure Practices. The Directors and the Management personnel shall comply with the requirements of the code. Any director and senior management personnel of the company shall not derive benefit or assist others to derive benefit by giving investment advice from the access to and possession of information about the company, not in public domain and therefore constitutes insider information. All directors will comply with insider trading guidelines as issued by SEBI.

8. Gifts & Donations
No director or senior management personnel of the company shall receive or offer, directly or indirectly, any gifts, donations, remuneration, hospitality, illegal payments and comparable benefits which are intended (or perceived to be intended) to obtain business (or uncompetitive) favours or influence any business decision for the conduct of business. Nominal gifts of commemorative nature, for special events may be accepted and reported to the Board annually.

9. Protection of Assets
Protection of the Company’s assets is a key responsibility of every person associated with the Company. Directors and senior management personnel must protect the company’s assets, labour and information and may not use these for personal use, unless approved by the Board. Care should be taken to ensure that assets are not misappropriated, loaned to others or sold without appropriate authorization. They are responsible for proper use of Company’s asset and must safeguard such assets against loss, damage, misuse or theft.