• Chief Executive Officer of the Company
• All General Managers and Heads of the Departments of the Company
• Such other employees as may be determined by the Board of Directors/ Managing Director/Executive Director of the Company from time to time.

1. PRESERVATION OF “PRICE SENSITIVE INFORMATION”
   
   Directors/designated employees shall maintain the confidentiality of all Price Sensitive Information. Directors/ designated shall not pass on such information to any person directly or indirectly by way of making a recommendation for the purchase or sale of securities.
   
   
   Price Sensitive Information is to be handled on a “need to know” basis, i.e., Price Sensitive Information should be disclosed only to those within the Company who need the information to discharge their duty.
   
   
   Files containing confidential information shall be kept secure. Computer files must have adequate security of login and pass word etc.
   
   
2. PROHIBITION TO BUY / SELL EQUITY SHARES OF THE COMPANY
   Directors/designated employees, when in possession of any unpublished price sensitive information, as defined in the Regulations, pertaining to the Company, shall not:
   
   
   Buy / sell securities of the Company, either on their own behalf or on behalf of any other person.
   
   
   Communicate, counsel or procure any unpublished price sensitive information to / from any person.
   
   
   
3. PREVENTION OF MISUSE OF “PRICE SENSITIVE INFORMATION”
   All directors/designated employees of the Company shall be subject to trading restrictions as enumerated below:-
   
   Trading window
   The Company has specified trading period, called "Trading Window", for trading in the Company’s securities. The trading window shall be closed during the time the information referred to in para 4 is un-published.
   
   When the trading window is closed, the Directors/designated employees shall not trade in the company's securities during such period.
   
   
4. RESTRICTION TO BUY / SELL SECURITIES
   1. “Trading Window” shall, inter alia be closed during the following periods:
      
      Commencing from seven days prior to the date of the Board Meeting in which the last quarter financial results are proposed to be placed for approval, upto twenty-four hours after the announcement of such results.
      
      
      Commencing from seven days prior to the date of the Board Meeting in which the first quarter financial results are proposed to be placed for approval, upto twenty-four hours after the announcement of such results.
      
      
      Commencing from seven days prior to the date of the Board Meeting in which the second quarter and half-yearly financial results are proposed to be placed, for approval upto twenty-four hours after the announcement of such results.
      
      
      Commencing from seven days prior to the date of the Board Meeting in which the third quarter financial results are proposed to be placed for approval, upto twenty-four hours after the announcement of such results.
      
      
      Commencing from seven days prior to the date of the Board Meeting in which the annual financial results are proposed to be placed for approval, upto twenty-four hours after the announcement of such results.
      
      
   2. The trading window shall also be closed at the time of:-
      
      1. Declaration of dividends (interim and final)
         
      2. Issue of securities by way of public/ rights/bonus etc.
         
      3. Any major expansion plans or execution of new projects.
         
      4. Amalgamation, mergers, takeovers and buy-back of shares.
         
      5. Disposal of whole or substantially whole of the undertaking.
         
      6. Any changes in policies, plans or operations of the company.(
      
      The closure of the Trading Window for these events will be advised by the Compliance Officer.
      
      
   3. The Trading Window shall open 24 hours after conclusion of the Board Meeting at which decisions in respect of the above events are taken and the information regarding the same is made public.
      
      
   4. Pre-Clearance of Trades
      
      All Directors/designated employees of the Company who intend to deal in the securities of the Company (above a minimum threshold limited as specified in this code) should pre-clear the transactions as per the pre-dealing procedures as described hereunder:
      
      
      Directors/designated employees shall make an application for prior clearance from the Compliance Officer in respect of purchase / sale of equity shares in the Company, exceeding 25,000 shares or Rs 5 lac in value of such shares or 1% of the total shareholding or voting rights in the Company, whichever is lower in a month (either in one transaction or in a series of transactions). Such purchase / sale of securities by the Compliance Officer shall require prior clearance from the Chairman or Managing Director or Executive Director.
      
      
      An undertaking in such form as the Company may require shall be executed in favour of the Company by such Directors/designated employees.
      
      
      Purchase / sale transactions, for which prior clearance has been obtained, shall be executed within seven days of such clearance.
      
      
      Directors /designated employees shall hold the equity shares in the Company for a minimum period of 30 days from the date of purchase ('Minimum Holding Period').
      
      
      In case of personal emergency, the prior approval of the Compliance Officer shall be taken for relaxation in the Minimum Holding Period. In respect of the Compliance Officer, such relaxation shall require prior approval of the Chairman or Managing Director or Executive Director.
   
   
   
5. DISCLOSURES
   Directors/designated employees shall make the following disclosures of shares and other securities held in the Company by them and their dependant family members, to the Compliance Officer:
   
   
   Annual disclosure of number of shares and other securities held as on 31st March, including details of purchase / sale of shares and other securities during the financial year. This disclosure shall be made within 30 days from the close of each financial year, in the prescribed form.
   
   
   Changes in shareholding, when such change exceeds Rs 5 lacs in value or 25,000 shares or 1% of total shareholding or voting rights, whichever is lower. This disclosure shall be made within 4 working days of such change in the prescribed form.
   
   
   Disclosure shall also be made of the number of shares and other securities held, upon becoming a designated employee, at any point of time. This disclosure shall be made within 4 working days of becoming a designated employee, in the prescribed from.
   
   
   
6. PENALTIES FOR CONTRAVENTION
   Violation of this Code will invite disciplinary action. Such disciplinary action as may be decided by the Board of Directors/Managing Director/Executive Director in consultation with the Compliance Officer, will be irrespective of action that may be taken by SEBI under the Regulations.

I Details of Shares held by Directors / Designated Employees:

II Details of Shares held by Relative/s:

Regulation 13(1) – Details of acquisition of 5% or more shares in a listed company

for
Director

Regulation 13 (2) – Details of shares held by Director or officer of a Listed company

Regulation 13(3) – Details of change in shareholding in respect of persons holding more than 5% shares in a listed company

Regulation 13(4) – Details of change in shareholding of Director or Officer of a Listed Company