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CODE OF CONDUCT FOR BOARD MEMBERS AND SENIOR MANAGEMENT

This Code of Conduct shall be applicable to all Board Members and also to Senior Management Staff immediately one level below the Board Members of Tradingo powered by Swastika Investmart Limited. The code shall come into force with effect from the 31st day of October, 2005.

This Code of Conduct shall be applicable to all Board Members and also to Senior Management Staff immediately one level below the Board Members of Tradingo powered by Swastika Investmart Limited. The code shall come into force with effect from the 31st day of October, 2005.

The Board Members and the Senior Management team shall comply with the Code of Internal Procedures and conduct for prevention of Insider Trading in dealing with securities of the Company.

The Board Members and the Senior Management team shall protect the Company’s assets including physical assets, information and intellectual rights and shall not use the same for personal gain.

The Board Members and the Senior Management team shall conduct the Company’s business in an efficient and transparent manner and in meeting its obligations to shareholders and other stakeholders. The Board Members and the Senior Management team shall not be involved in any activity that would have any adverse effect on the objectives of the Company or against national interest. The corporate objectives to be pursued shall be to sustain the competitive edge of the company and not to indulge in any activity which is detrimental to the society at large.

The Directors and the Senior Management team shall immediately bring to the notice of the Board about any unethical behavior, actual or suspected fraud or violation of company’s policies.

As required by Regulation 46 of the Securities Exchange Board of India(Listing Obligations And disclosure Requirements) Regulations, 2015 this code and any amendments thereto shall be posted on the website of the Company.

Mrs. Anita Nyati, Whole time Director shall be the Compliance Officer for the purpose of this code.

All the board members and the senior management team shall furnish to the compliance officer, their acknowledgement of the receipt of the code in the format prescribed under Appendix I to this code and shall within 30 days of close of every financial year affirm compliance with the code in the format prescribed under Appendix II to this code.

Any violations of this code shall be promptly brought to the notice of (a) the Board of Directors in case any such violation is on the part of a board member and (b) the Chairman & Managing Director of the company in case the violation is on part of any senior management personnel, by the Compliance officer. The Board of Directors or the Chairman & Managing Director of the company, as the case may be shall upon receipt of report of any violation, take such action as is deemed appropriate in the interests of the company.

Any amendment or waiver of any provision of this code can be made only by the Board of Directors and shall promptly be disclosed on the company’s website and in applicable regulatory filings pursuant to applicable laws and regulations, together with details about the nature of the amendment or waiver.

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