Code of Conduct

VADILAL GROUP's commitment to total, unyielding Integrity is set forth in group's compliance handbook, The Spirit & The Letter. The policies set forth in The Spirit & the Letter govern the conduct of all Vadilal Group employees and are supplemented by compliance procedures and guidelines adopted by Vadilal Group business components. All Vadilal Group employees must not only comply with the letter of the Company's compliance policies, but also with their spirit.

The spirit of Vadilal Group's Integrity commitment is set forth in the Vadilal Group Code of Conduct, which each Vadilal Group employee has made a personal commitment to follow:

• Obey the applicable laws and regulations governing our business conduct worldwide.
• Be honest, fair and trustworthy in all of your activities and relationships.
• Avoid all conflicts of interest between work and personal affairs.
• Foster an atmosphere in which fair employment practices extend to every member of the diverse

Vadilal Group community.

• Through leadership at all levels, sustain a culture where ethical conduct is recognized, valued and exemplified by all employees.
• Never compromise on the quality and effort we put into all our products and services
• Using state of the art technology to ensure that our products & services meet the requirements of this ever changing world.

No matter how high the stakes, no matter how great the challenge, Vadilal Group will do business only by lawful and ethical means. When working with customers and Suppliers in every aspect of our business, we will not compromise our commitment to integrity, which is why we are where we are today.