This Code of Conduct is applicable to the:

1. Members of Board of directors of the Company.

2. Senior management which means

         a) Executives who are in the grade of general manager and above;

         b) Company Secretary.

Aravali commitment to ethical and lawful business conduct is a fundamental shared value of the Board of directors and the senior management.

Consistent with its values and beliefs, Aravali has formulated the following Code of Conduct as a guide. The Code does not attempt to be comprehensive or cover all possible situations. It encourages the Aravali team to take positive actions, which are not only commensurate with the values and beliefs, but are also perceived to be so. Aravali expects its Board members and senior management to implement the Code in its true spirit and in case of any doubt or confusion, to consult his immediate superior or the executive director.

In performing their functions, the directors and senior management of the company shall:

• act honestly, diligently and in good faith and integrity in all their dealings with and for the Company and are prohibited from engaging in any activity that interferes with their proper discharge of responsibilities of the company or is in conflict with or prejudicial to the interests of the Company.
• act in a manner to enhance and maintain the reputation of the Company.
• not use any confidential information obtained by them in the course of their official duty, whether from the company or otherwise, for personal gain, or use/allow the use of such information for the financial benefit for any other person or in a manner that would be detrimental to company’s interest.
• abide by all applicable laws and regulations including the company’s prevention of Insider Trading code.
• not to accept gifts in cash or kind in their capacity as member of Board of directors or senior management. However, an exception to this may be made for non-cash gifts that can be reciprocated such as tickets to events, business meals etc.
• not share any information regarding the company, its business and/or affairs with media without the prior approval of the executive director.
• not hold position of director/advisor with a competitor company/entity.

In addition, in performing their Board and Board Committee functions, the directors shall:

disclose any personal interest in any person/entity and keep informing any changes in their interests that may interfere with their ability to perform their duties or which may influence decisions of Board, and in the case of Independent Directors, impact their independence as a Board member.

This code embodies the belief that acting always with the company’s legitimate interest in mind and being aware of the company’s responsibility towards its stakeholders is an essential element of the company’s long term excellence.