CODE OF CONDUCT FOR SENIOR MANAGEMENT AND EMPLOYEES

POLITICAL AND TRADE AFFILIATIONS

VIL neither supports any specific political party nor it has any particular political affiliations. Accordingly, therefore no contribution can be made, directly or indirectly, to any political party or for any political purpose without the prior approval of the Board of Directors of the Company, and in strict compliance with applicable legislation.

We shall co-operate with the Government, Chambers of Commerce and Trade Associations in matters concerning the industry with a view to promoting,protecting and enhancing our business interests.

Employees are free to contribute or participate in the political process or to a trade association so long as it does not create a conflict of interest situation or impinge upon their work-related commitments.

Employees associated with political parties or the political process or trade associations should ensure that by their participation, they do not give the impression of representing or being the spokesperson of the Company.

We shall not comment on the political process except in those matters that have a bearing on the operations of the Company or of the Vyapar companies.