CONFLICT OF INTEREST
The policies and procedures under this code require that the Directors, Managers, Officers, and Associates of the Company shall avoid any activity or association that creates or appears to create a conflict between the personal interest of the Directors, Managers, Officers, and Associates and the company's business interests.

a) Related Parties: The policies and procedures of the company expect that the Directors, Managers, Officers, and Associates avoid conduct of business of the company with their relatives or their significantly associated companies, firms and other businesses.
b) The company discourages the employment of relatives in positions or assignments within the same department and prohibits the employment of such individuals in positions that have a financial dependence or influences (eg. an auditing or control relationship, or a supervisor/subordinate relationship). Wilfull withholding of information regarding a prohibited relationship/reporting arrangement may be subject to corrective/penal action as may be deemed fit by the company.
c) Every employee who is required to make a disclosure as mentioned above shall do so, in writing, to the HR Department who shall forward the information along with comments to place it before the MD/CEO and/or the - Board of Directors, Managers, Officers/Executive Committee appointed by the Board and, upon a decision being taken in the matter. The employee concerned will be required to take necessary action as advised to resolve/avoid the conflict.
d) If an employee fails to make a disclosure as required herein, and the management of its own accord becomes aware of the instance of conflict of interest that ought to have been disclosed by the employee, the management shall take a serious view of the matter and consider suitable disciplinary action against the employee.
e) Gifts: The Directors, Managers, Officers, and Associates of the company shall not accept any personal gifts because of their value or the time at which they are offered, could be interpreted to adversely affect business decisions or likely to compromise their personal or professional integrity. The Directors, Managers, Officers, and Associates of the Company shall also avoid offering of gifts or payments or authorisation of payments by way of gifts. Gifts on account of celebrations, memorial in nature, business meals, and gift received because of attending widely held gatherings as panelist/speaker and other customary gifts, which are not improper and do not in any way influence the business decisions, are allowed under this policy.
f) Protection and proper use of the Company's Assets: The Directors, Managers, Officers, and Associates shall protect the company's assets and ensure their efficient use. All Company assets should be used for legitimate business purposes. Company's assets should not be used for other than business requirements of the Company.
g) Confidentiality of information: The Directors, Managers, Officers, and Associates must maintain the confidentiality of information relating to the affairs of the Company acquired in the course of their service as Directors, Managers, Officers, or Associates, until and unless authorised or legally required to disclose such information; and shall not use confidential information and other corporate opportunities for their personal advantage.
h) Others: The conflicts of interest that may arise in any other form which at this point of time may not be practicable to enumerate. In case, any act, transaction or situation raise doubts or questions, the Directors, Managers, Officers, or Associates must consult the company's HR Head or Compliance Officer.