Investors Handbook

Code of practices and procedures for fair disclosure of unpublished price sensitive information (UPSI)

Familiarisation Programme for Independent Directors

Listing Information

The company is listed on Bombay Stock Exchange Limited

R&T Agent

Mr. Shrawan Mangla
General Manager
MAS Services Limited
T-34, II Floor, Okhla Industrial Area,
Phase-II,
New Delhi- 110020

Code of Conduct

Introduction

This Code of conduct has been framed in compliance with the provisions of Clause 49 of the listing agreement with the stock exchanges. The purpose of this code is to help ensure that the members of the Board, the Senior Management and the employees conduct the business with the highest standards of integrity, honesty, ethics, conduct and governance and also to ensure that they act in an efficient and transparent manner in the conduct of the day to day activities of the organization.

Applicability

  • All the directors of the company.
  • Members of the senior management of the company (i.e., one level below the executive directors).
  • Functional heads and the employees in the company.

The Code

The members of the Board, senior management and the employees of the company must observe and abide with the following code of conduct:

  • To act honestly, diligently and in good faith and integrity in all their dealings with the company.
  • To exercise authority and power with due care and diligence whilst discharging their responsibility of office.
  • Comply with all applicable laws and regulations.
  • To observe confidentiality of information acquired in the course of their duties.
  • Deal fairly with customers, suppliers, employees and other business partners.
  • Supply products and services of the highest quality standard.
  • To make proper records of all financial transactions.
  • To always act in the best interests of the company and its stakeholders.

Whistle Blower Policy Model (Vigil Mechanism)

The Company believes in the conduct of the affairs of its constituents in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behavior. Towards this end, the Company has adopted the Superior Code of Conduct (“the Code”), which lays down the principles and standards that should govern the actions of the Company and its employees. The company shall ensure protection to the whistleblower and any attempts to intimidate him/her would be treated as a violation of the Code.

This Policy is an extension of the Superior Code of Conduct as published on the Website of the Company. The Whistleblower’s role is that of a reporting party with reliable information. They are not required or expected to act as investigators or finders of facts, nor would they determine the appropriate corrective or remedial action that may be warranted in a given case.

All Protected Disclosures concerning financial/accounting matters should be addressed to the Chairman of the Audit Committee of the Company for investigation.

The contact details of the Chairman of the Audit Committee are as under:

Mr. Vijay Kumar Gupta

162-B, Pocket-C, Sidharth Extn.

New Delhi-110014, Delhi, India

Contact : 9810708187

The identity of the Whistleblower shall be kept confidential to the extent possible and permitted under law.

Code of Internal Procedures and Conduct for Regulating, Monitoring and reporting of Trading by Insiders

Nomination, Remuneration & Evaluation Policy

Related Party Tranasaction Policy

Policy for determining Material Subsidiaries

Policy determining materiality

Archival Management Policy

Policy on Preservation of Documents