CODE OF CONDUCT FOR SENIOR MANAGEMENT AND EMPLOYEES

BUSINESS PARTNERS AND JOINT VENTURES

A proper choice of business partners is vital for the success of the Company and of the Vyapar companies.

Associations shall be encouraged, in India or abroad, with such entities as are able to add value to the Company’s products or services, or help fulfill the strategic growth plans of the Company.

Only such persons shall be selected to be our business partners where there is a complete match in the partners’ manner of conduct of business, core values and other business principles and processes.

We shall maintain mutually lasting and beneficial relationships with all our suppliers, customers and other business partners, including Joint Ventures.

We shall respect the interest of all our business partners and in our dealings with them, shall act with fairness, integrity and transparency.

Business partners shall not be expected, directly or through employees, or vice versa, to do anything in the course of their dealings with the Company that is not permitted under this Code.