Jaisal Securities Ltd. (the ‘Company’) is committed to conducting its business in accordance with the applicable laws, rules and regulations and with highest standards of business ethics. This code is intended to provide guidance and help in recognizing and dealing with ethical issues, provide mechanisms to report unethical conduct, and to help foster a culture of honesty and accountability. Each Director and senior officer is expected to comply with the letter and spirit of this code.

The directors and senior officers of the Company must not only comply with applicable laws, rules and regulations but should also promote honest and ethical conduct of the business. They must abide by the policies and procedures that govern the conduct of the Company’s business. Their responsibilities include helping to create and maintain a culture of high ethical standards and commitment to compliance and to maintain a work environment that encourages the stakeholders to raise concerns to the attention of the management.

This code does not attempt to describe all potential problem areas that could develop, but some of the more common problems are described below:

a. When a director/senior officer takes action or has interests that may make it difficult to     perform his or her work objectively and effectively;

b. The receipt of improper personal benefits by a member of his or her family as a result      of one’s position in the Company;

c. Any outside business activity that detracts an individual’s ability to devote appropriate     time and attention to his or her responsibilities;

d.The receipt of gifts or excessive entertainment from any person/company with which     the Company has current or prospective business dealings;

e. Any significant ownership interest in any supplier, customer or competitor of the     Company;

f. Any employment relationship with any supplier, customer, business associate or    competitor of the Company.

The directors and senior officers should be scrupulous in avoiding ‘conflicts of interest’ with the Company. In case there is likely to be a conflict of interest, he/she should make full disclosure of all facts and circumstances thereof to the Board of directors or any Committee / officer nominated for this purpose by the Board and a prior written approval
should be obtained.

The Directors and senior officers shall act in accordance with the highest standards of personal and professional integrity, honesty and ethical conduct not only on Company’s premises but also at company sponsored business, social events as well as any place. Their conduct shall conform to the best-accepted professional standards of conduct.

Each director and senior officer, should deal fairly with customers, suppliers, ompetitors, and employees of group companies. They should not take unfair advantage of anyone through manipulation, concealment, abuse of confidential, proprietary or trade secret information, misrepresentation of material facts, or any other unfair dealing practices.

All directors and senior officers should protect Company’s assets and property and ensure efficient use. Theft, carelessness and waste of Company’s assets and property have a direct impact on the Company’s profitability. Company’s assets should be used only for legitimate business purposes.

The Directors and officers shall comply with all applicable laws, rules, and regulations. Transactions involving securities of the Company should not be undertaken without pre-clearance from the Company’s compliance officer. Any director, officer or employee who is unfamiliar or uncertain about the legal rules involving Company business conducted by him/her should consult the Secretarial department of the Company before taking any action that may jeopardize the Company or that individual.

If any director or senior officer who knows of or suspects of a violation of applicable laws, rules or regulations or this Code of conduct, he/she must immediately report the same to the Board of Directors or any designated person/committee thereof. Such person should as far as possible provide the details of suspected violations with all known particulars relating to the issue. The Company recognizes that resolving such problems or concerns will advance the overall interests of the Company that will help to safeguard the Company’s assets, financial integrity and reputation.

Violations of this Code of Ethics will result in disciplinary action, which may even include termination of services of the employee. The company’s Board or any Committee/person designated by the Board for this purpose shall determine appropriate action in response to violations of this Code.

Any question or interpretation under this Code of Ethics and Business Conduct will be handled by the Board or any person/committee authorized by the Board of the Company. The Board of Directors or any designated person/committee has the authority to waive compliance with this Code of business conduct for any director or senior officer of the Company. The person-seeking waiver of this Code shall make full disclosure of the particular circumstances to the Board or the designated person/committee.

Honesty, integrity and sound judgment of the senior officers is fundamental for the success and reputation of Jaisal Securities Ltd. The professional and ethical conduct of the senior officers is essential to the proper functioning of the Company. The senior officers of the Company shall be bound by the following code of ethics:

a. Act with honesty and integrity, including the ethical handling of actual or apparent     conflicts of interest between personal, financial and professional relationships,

b. Make full and accurate disclosure in reports and documents that the Company files     with or submits or makes periodically to the shareholders, government authorities and     to the public,

c. Comply with governmental laws, rules, notifications and regulations.

d. Disclosure to the Board or any committee/officer designated by the Board for this purpose, any material transaction or relationship that reasonably could be expected to     give rise to any violation of the code including actual or apparent conflicts with the     interests of the company,

e. Respect the confidentiality of information acquired in the course of employment     unless legally obliged to disclose and ensure that no such confidential information is     used for personal advantage,

f. Refrain from any inappropriate or undue influence of any kind in all dealings with independent auditors and avoid any actual or apparent conflicts with analysts,

g. Achieve responsible use of and control over all assets and resources employed or entrusted to them

h. Promote ethical and honest behavior within the Company,

All senior officers should adhere to both the code of business conduct and the code of ethics of the Company. Violation of the code of ethics will lead to appropriate disciplinary action including dismissal from the services of the Company.

Any deviation/waiver from this code can only be effected on the sole and absolute discretionary authority of the Board or any person/committee designated by the Board for this purpose.