CODE OF CONDUCT FOR SENIOR MANAGEMENT AND EMPLOYEES

EMPLOYEES

VIL recognizes that the success of its operations is dependent to a large extent on the commitment and support of its workforce.

We are an equal opportunities employer. Employment decisions are to be made with no reference to religion, caste, sex or any non-job related handicap. Discrimination and harassment of any kind will be dealt within the most severe manner. Terms and conditions of employment will be competitive.

Employees will display the highest level of ethics and integrity in every sphere of activity and will abide by the rules and regulations of the organization. Every employee will be given an assignment that best suits the employee’s capabilities and will be sufficiently empowered to function at an optimal level.

Adequate opportunities will be provided to our workforce to upgrade their skills. Every employee is entitled to equal consideration for any open job opportunity within the Company and due importance will be given to Succession Planning. Innovation and well-reasoned risk taking shall be supported, but performance will be demanded. Employees shall have no rights or lien over any inventions that arise in the course of employment.

Suggestions from the workforce for the betterment of processes and practices will always be welcomed. Employees are expected to devote their full time attention to the business of the Company and not take on any competing assignments either directly or indirectly without proper authorizations.

Company property – equipment and intellectual property rights such as patents, trademarks, copyrights, designs, strategies, plans, trade secrets and similar items that are not in the public domain – should be used only in the course of and for Company business, with proper care and safeguards.

Insider trading in securities of the Company is not permitted. The Code of Conduct prescribed by the Board of the Company for the prevention of insider trading in securities of the Company will have to be strictly adhered to and requisite disclosures made.

Solicitation or acceptance of gifts is strictly forbidden except in cases where items are gifted with no expectation of business or personal gain. The payment or receipt of bribes is prohibited.

Employees must avoid any form of activity that would result in a conflict of interest situation or a potential conflict of interest situation, such that the ability of the employee to perform objectivity or impartially could get impaired.

We will comply with all labour related legislations of the Central and the State Governments, and, in particular, will neither employ nor advocate the employment of child labour or forced labour. Employees will be encouraged to align their interest with those of the Company through participation in applicable Stock Option Plans, if any. Employees will be provided with a safe and healthy work environment.

Employees will be expected to maintain cordial relations with and respect one another, and will conduct themselves in a manner that would be benefiting the organization. We value individual dignity, uphold the right to express disagreement and respect the time and efforts of our workforce.