CODE OF PRACTICE & PROCEDURE FOR FAIR DISCLOSURE

The code aims at prompt public disclosure of Unpublished Price Sensitive Information (UPSI) that would impact price discovery so as to make such information generally available. The disclosure shall be done no sooner than credible and concrete information comes into being.
The code also covers the practices and procedures for fair disclosure of Unpublished Price Sensitive Information.

1. Uniform and universal dissemination of UPSI shall be ensured to avoid selective disclosure. In case of selective dissemination of UPSI inadvertently or otherwise, it shall be ensured promptly to make such information generally available.

2. The Company and Designated Persons” shall maintain the confidentiality of all unpublished price sensitive information (UPSI) shall communicate the same purely on the need to know
basis and shall not communicate to any unauthorized person or on a selective basis.

3. The Company shall promptly disclose UPSI once such credible and concrete information comes into being.

4. The Company shall disclose UPSI by making its prompt disclosure with sufficient and unambiguous details to the stock exchange on which its securities are listed. The company shall also disclose UPSI on its website.

5. In case the company finds that any UPSI has been disclosed selectively, inadvertently or otherwise, it shall promptly disclose and disseminate as soon as the circumstances permit such information to make it uniformly and non-discriminatorily available to the
general public.

6. The Company designates its ‘Company Secretary’ as its Chief Investor Relations Officer and entrusts him with the function of dissemination and disclosure of UPSI. Whenever Company Secretary is not available any Director shall be the Chief Investor Relations
Officer.

7. The Company shall ensure that no UPSI is shared with the analysts and researchers on a selective basis.

8. The Company shall ensure that its conferences with analysts and investors shall be open to participation by all analysts, shareholders and other investors.

9. The Company shall make transcripts or records of proceedings of its meetings with analysts/investor conferences and make the same access to all by uploading them on its website.