ENCOURAGING THE REPORTING OF

ILLEGAL OR UNETHICAL BEHAVIOUR

High standards are more than a slogan or catch phrase - they represent the way
we do business. Maintaining high standards means conducting business ethically
and legally. Every employee shares in the responsibility for promoting a
positive workplace and making a commitment to Doing What's Right.
Therefore-
1. Employees have to report violation of laws, rules, regulations or the Company's
Code of Conduct to appropriate head.
2. Employee can make a protected disclosure addressed to the President HR of
the actual or possible violation of the 'Code' with a reasonable evidence to
conclude that a violation is possible or has taken place with a covering letter
which shall bear the identity of the reporting employee
3. Self-reporting is encouraged. Anyone who self-reports their own wrongdoing or
violation of law will be given due consideration in potential mitigation of any
disciplinary action that may be taken
4. Assure Employees that the Company will not allow retaliation for reports made
in good faith.
5. A Committee compromising the Chief Operating Officer, the President -
Finance and the President HR will investigate the matter and place a Report
before the next Audit Committee meeting for appropriate action.

INSIDER TRADING
The Code of Ethics and Insider Trading Policies and Procedures are designed to
protect the public from abusive trading practices and to maintain ethical
standards for access persons when dealing with the public.  Insider Trading is
prohibited by both Law as well as by the Company's policy.

POLICY - Directors and their relatives as also Employees of the

Company and their 'immediate family' shall not derive any benefit or
assist others to derive any benefit from the access to and possession of
information about the Company, which is not in the public domain and
thus constitute insider information. "Price sensitive information" is an
information, which relates directly or indirectly to a Company and
which, if published, is likely to materially affect the price of Securities
of a Company.
This insider trading policy is being adopted with the goal of helping:
1. Prevent inadvertent violations of the insider trading laws.
2. Protect the reputation of the Company, its Directors and its employees.
3. Protect the Company from controlling person liability