For the purpose of this Code, the term ‘senior management’ shall mean:

• Executives who are in the grade of Manager and above;
• All executives directly reporting to the Managing Director; and
• Company Secretary

In performing their functions, the directors, senior management and all other employees of the Company shall : Act honestly, diligently and in good faith and integrity in all their dealings with and for the Company.

Not use any confidential information obtained by them in the course of their official duty, whether from the Company or otherwise, for personal gain, or use/allow the use of such information for the financial benefit for any other person.

Not engage in any business, relationship or activity, which might detrimentally conflict with the interest of the Company.

Maintain the principal of need to know and also confidentiality of all material non-public information about the Company, its business and affairs.

Abide by all applicable laws and regulations including the Company’s Prohibition of Insider Trading code.

Not use their status to seek or accept any personal gains or favors from those doing or seeking to do business with the Company or from other employees of the Company.

Not share any information regarding the Company, its business and/or affairs with media without the prior approval of the Corporate Disclosure Officer/Compliance Officer.

In addition, in performing their Board and Board Committee functions, the directors shall :

• Not hold position of Director/Advisor with a competitor Company.
• Inform the Chairman of changes in their interest that may interfere with their ability to perform their duties, and in the case of ‘independent directors’ impact their independence as a Board member.
• This code embodies the belief that acting always with the company’s legitimate interest in mind and being aware of the Company’s responsibility towards its stakeholders is an essential element of the company’s long term excellence.