ANANDRATHI Wealth Management. uncomplicated Anand Rathi Wealth Services Limited Code_of Conduct _for Board Members and Senior Management4 Code of Conduct To ect in accordance withthe highest standard of personal and professional integrity, honesty and ethical conduct inthe discharge of duties and promote professionalism in the Company ‘To observe and guide the Company in maintaining highest degree of Corporate Governance ‘To ensure that by every employee is compliant with the applicable regulations, specially those involved inthe front-end of the Business, since Compliance isthe duty of every employee ofthe Company, in each oftheir respective roles To stay abreast ofthe afftirs of the Company and be kept informed of the Company's compliance with relevant laws, rules and regulations To exercise independent judement on issuss of strategy, performance, policy matters, ae To avoid and disclose actual and apparent conflicts of personal interest withthe interes, ofthe Company and to disclose all contactua interest, whether directly or indirectly, with the Company To inform the Company immediately about emergence of any situation that may Aisqualify hinvher from Directorship ‘To maintain confidentiality of the Company's business ‘To give due importance to whistle-blowers and to look into the matter that has been referred to ‘To observe the Code of Conduct for dealing in Equity Shares and other securities of the ‘Company framed under the SEBI (Prohibition of Insider Trading) Regulation, 2015 [Not to accept any oiler, payment or anything of value fom Company's customers, ‘vendors, consultants, etc. that is pereived as intended, direlly or indirectly, «0 influence any business decision ‘To observe the highest moral and ethical standards wile dealing withthe Company's ‘omen employees and directors and to avoid al actions or nactions leading to any kind ‘of sexual harassment ‘To reat women employees equally nd eliminate any gender discrimination [Not o hold any office or place of profitin the Company by himselfherself or by histher ‘relatives without fll disclosure of information in connection therewith15. Not to divert to hisher own advantage any business opportunity thatthe Company isin pursuit 16 Not to compete, whether diretly or indirectly, with the Company’ 17. Notto charge personal expenses tothe Company IR Notto assign his office Duties of Independent Directors: The Independent Directors shall — |. ndertake appropriate induetion and regularly update and refresh their sil, knowledge and familiarity wi the company; ‘eck appropriate claiication or amplitiation of information and where necessary, take and follow appropriate profesional advice and opinion af ouside experts tthe expense ‘of the companys 3. strive to attend all meetings ofthe Board of Directors and ofthe Boned comminees of ‘which he i a member, 4 participate constructively and atively inthe committes of the Board in which they are (Chairperson or member, 5. strive to attend the general meetings ofthe Company; where they have concerns about the running ofthe company ora proposed action, ensure that these are addressed by the Board and, othe extent that they are nt resolved insist, that their eoncems ae recorded inthe minutes ofthe Board meetings, 7. keep themselves well informed about the compaay’ and the extemal environment in Which it operates: & not to unfinly obstruct the funetioning of an otherwise proper Board or committee of the Boards, 9. pay suficent atenton and ensure hat adequate deliberations ae held before approving Felted party wansactons and assure themssves tha the same ein he nero the Company: 10. ascertain and ensure that the company has an adequate and functional vigil mechanism 1nd to ensure that the interests of a person who uses such mechanism are not prejudicilly affected on account of such use; IL report concerns about unethical behavior, actual or suspected fraud or violation of the ‘company’s code of conduct or ethies policy; 12. to ensue that their disagreement to any decision in which they have expressed the same ‘or the vote, iFany, cast against a decision, is noted;13. scting within his authority, assist in protecting the eptimate interests of the company, sharcholders and its employees: 4 not diselose confidential information, including commercial secrets, technologies, ‘advertising and sales promotion plans, unpublished price sensitive information, unless ‘such dislosute is expressly approved by the Board or required bylaw, Code of Conduet for Senior Management This Code of Conduct is applicable tall Senior Management employees ofthe Company snd the Anand Rathi Group. |. To actin accordance withthe highest standard of personal and professional integrity, ‘honesty and ethical eondct in the diseharge of duties ‘To maintain and help the Company in maintaining highest degree of Corporate Govemance ‘To use reasonable care and skill in the discharge of duties and responsibilities and exercise of povsers forthe benefit and prosperity ofthe Company 4 Tohave a clear understanding ofthe aims and objectives, capabilities and capacity and varios policies ofthe Company 5. Toimpart eaining tothe tam and share knowledge, working towards enhancing the tam knowledge and providing with adequate access tothe requisite information fr effective and efficient performance of the tears 6 Todevote fll attention to the business interests of the Company 1. To comply wit all applicable laws and regulations, both in letter and in spirit, in all territories in which helshe operates 4 Toavoid and disclose actual and apparent conflicts of personal interest with the interest of the Company and to disclose all contractual interest, whether directly or indirectly, with the Company % Toact in accordance with the highest standards of integrity and ethical conduct while dealing with women employees and the female gender in general and to avoid all ations or inaction leading to any kind of sexual harassment 10 To teat women employees equally and eliminate any gender discrimination 11. Not to engage in any activity tha interferes with the performance or responsibilities to the Company 12 Notto accept simultaneous employment directorship with the suppliers, customers or competitors ofthe Company and not takepart in any activity that enhances or supports competitor[Not to accept employment or a postion of responsibility (Such as @ consultant or lireetor) with any ether company or firm, nor provide freelance services to anyone [Not to make investment in any customer, supplier or competitor ofthe Company tht ‘may compromise on hishher responsibilities fo the Company and any such investment shal be with full dislosure to dhe Company ‘To avoid conducting Company business with a relative or witha busines in which 3 relative is associated in any signiicant ole Not to divert to hisyher own advantage any business opportunity that the Company i in pursuit Noto accept any offer, payment, donations, gifs or anything of value fom customers, vendors, consultants, etc. that is perceived as intended, directly or indirectly, 10 influenee any busines decision Not to compete, whether diretly or inizetl, with dhe Company ‘To promote professionalism inthe Company To maintain confidentiality ofthe Company's business To ensure a ll times, the integrity of data or information furnished by hinvher tothe Company "Not to eharge personal expenses fo the Company ‘To observe the Code of Conduct for dealing in Equity Shares and other securities ofthe Company! framed under the SEBI Prohibition of Insider Trading) Regulation, 2015 To prompily report to the Chairman say actual or possible violation ofthe Code or an oe Hainan