CODE OF CONDUCT FOR SENIOR MANAGEMENT AND EMPLOYEES

BUSINESS ETHICS

VIL is committed to seeking long term success with no compromise on ethical business standards.

The highest standards of integrity, impartiality, equity and objectivity shall be observed in every activity that encompasses the business, so as to uphold and enhance the reputation of the “VYAPAR” trade name.

The businesses shall be conducted in keeping with the exacting standards that are contained in this Code. Our Management employees shall diligently comply with the requirements of this section, and the regulations applicable to the country in which they transact business.

Management and Employees are expected to remain independent in any decision that they may be required to take and should disclose any interest – personal, professional, academic or business – which may arise directly or indirectly through their relatives, that may conflict with their responsibilities.

Business decisions shall be taken in a manner that supports full and open competition and secures for the Company the best products and services at the most competitive price.

The Company does not espouse the payment or receipt of gifts or bribes for business or financial gain. As a corollary, no employee or representative of the Company should do anything that could give an impression that the Company could be influenced in this manner.

It might be customary, at times, to give or exchange unsolicited gifts during the traditional festive seasons or during certain corporate events. These should be restricted to promotional or advertising material or such items that are customary or considered to be prudent or of a symbolic nature of the management, having regard to the nature of the business, the type of markets in which the Company is operating and the event being observed. It would however be unethical and incorrect to gift items where there is an intention to derive any benefit in return. An exceptionally stringent view will be taken of anyone who violates this policy.