Introduction

This Code of Conduct / Ethics has been adopted by the Board of Directors of Subros Limited in their meeting held on 29th October’ 2005. Based on globally accepted corporate practices, the Company has believed in the Creed of Trusteeship and had laid down foundation of Corporate Governance in the conduct of its business operation and transparency, full disclosure, fairness, consistent and effective adherence has remained the focus in the process of its implementation.

The company has now laid down specific Code of Conduct for the members of the Board of Directors and Senior Management officers to further strengthen Corporate Governance practices as required under clause 49 of the Listing Agreement with Stock Exchanges.

A Special Code of Conduct for dealing in equity shares of the company for the Directors and employees of the company has also been framed.

The objective of this Code of Conduct (The “Code”) is to conduct the operation of the company in accordance with applicable laws, regulations, rules supported with the highest standards of ethics and values which are of utmost importance to the company, shareholders and other stakeholders.

This code shall come into force with immediate effect.

Every person defined herein below shall be duty bound to follow the provisions of this code in letter and spirit.

Accordingly, the Directors/Senior Management officers, as defined herein below, are expected to read and understand this Code, adopt the same and uphold these standards.