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Confidentiality

Any information concerning the Company's business, its customers, suppliers etc. shall be considered as confidential.

No Director and Senior Management Executives shall provide any information concerning the Company or its business or its customers, suppliers, etc. either formally or informally, to any person including press or publicity media, unless such information is -

• in public domain at he time of disclosure; or
• authorized or required to be disclosed pursuant to a decision of the Board/Committee thereof; or
• required to be disclosed in accordance with applicable laws or requirement of any government authority.

Amendments

The Board may amend the provisions of this Code from time to time.

Unless otherwise specified, such amendments shall be effective from the date of the Board meeting at which such amendments are approved.

Affirmation

All the Directors and Senior Management Executives shall affirm compliance with the Code on annual basis within 30 days of close of every financial year ending on 31st March.

The Annual Affirmation (as per format specified) shall be forwarded to the Company Secretary of the Company within the said period of 30 days.

Waiver

The Board has, at its absolute discretion, the power to waive compliance with any or al of the provisions of the Code.

Enforcement

The Board has the power to investigate, in such manner as it may deem fit, any breach or violation or alleged breach or violation of the Code.

The Board also has the absolute power to determine penalty for the same as it may consider appropriate under the circumstances.

Such penalty may be in addition to the penalty levied under any law for the time being in force for such breach or violation.

No Rights Created

This Code is neither intended to nor does it create any right in favour of any Director, Senior Management Executives, clients, suppliers, customers or shareholders of the Company or any other persons or entity, whatsoever.

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