CODE OF CONDUCT

I. COVERAGE:
This code is applicable to all employees of INOX Air Products Pvt. Ltd including
trainees, retainers and temporary staff. Use of the word 'employee' or 'employees'
in this code refers collectively to all of the above.

II. PURPOSE:
Company is committed to ensure that its business affairs are always conducted in
a fair and transparent manner by adopting the highest professional, ethical and
legal standards which prevail from time to time in the industrial sector. All
employee are expected to strictly adhere to this code of conduct.

Our Code of Conduct gets reflected in our good Corporate Governance,

Employment Terms and Conditions, Whistle blower Policy, Rules and regulations
pertaining to Discipline, Other Policy Guidelines, Procedures and Standards.

The standard set out in our Code of Conduct determine how company will
maintain its relations with customers, suppliers, other businesses and the
environment. All employees shall ensure to be aware of the Code of Conduct, all
policies and procedures applicable to the company and abide by them to the
fullest extent, as a part of employment conditions. However, in case if the local law
in the Country or State at any point in time is stricter than the rules of this code,
follow such local law and seek guidance from the management.

III. ELEMENTS OF THE CODE:

INTEGRITY:
INOX Air Products Pvt. Ltd continues to value utmost commitment to integrity. It is
essential that employees keep the highest standards of integrity during all our
business interactions and safeguard our reputation for transacting business in an
honest manner. We should all deal fairly with the company's customers, suppliers,
competitors, and or colleagues.

ENABLING WORK ENVIRONMENT:

The Company shall continue to build an inclusive, challenging and full of learning
work environment where openness, trust, and respect are integral part of our
corporate culture. The company will continue to support all principles of equal
opportunity in employment.

We will continue to recruit people solely on merit and individual competencies.

We are committed to provide a work environment free of unlawful harassment.
Our Policy on sexual harassment spells out clearly our approach on the same.

ENVIRONMENT, HEALTH AND SAFETY:

The Company is committed to continuous improvement in safety performance so
as to provide a healthy, safe and secure work environment. It is committed to
preservation of environment in accordance with applicable laws. Particular
attention shall continue to be given to training of employees to increase safety
awareness, adoption of safe working methods and personal protective
equipment.

All employees shall comply with the company Environment, Health and Safety
norms as communicated to them from time to time.

Employees shall take care to ensure that none of their acts of commission and
omission while carrying out their duties and responsibilities adversely affect the
environment.

PROTECTION AND USE OF COMPANY PROPERTY:

It is the responsibility of everyone to comply fully with all applicable laws and
regulations, uphold the company policies, procedures and standards .Everyone
shall strive to protect company property. Company equipment, systems,
information, data, goods and services should be used only for company business.

CONFLICT OF INTEREST:
Employees shall avoid any situation that involves a conflict between their
personal interest and the interest of the company. All employees must avoid
circumstances that might cloud his/ her judgement, sense of impartiality or would
result in his/her personal gain/benefits.

Employees shall not engage in any business activity which could be detrimental
to, or in competition with the company's business activity.

All employees shall devote their time and best efforts to the responsibilities
entrusted to them, to promote the company's business and shall not engage,
directly or indirectly, in any other business, employment or vocation for pecuniary
gain. During the currency of the employment with the Company, an employee
shall seek prior approval of management in case he/she requires to serve as an
employee, agent, director, partner or consultant of any other business enterprise.

It is obligatory for an employee to declare that he/she is related to any other

employee of the company in Company Application Form and later; during course
of employment to declare through a written letter/mail to Head-HR.
An employee should not be the final decision maker for any business contract or
arrangement with any organization wherein his relatives are employed in key
positions.

GIFTS, OTHER BENEIFTS AND ENTERTAINMENT:

Exchanging high value gifts or inappropriate entertainment is unethical.
Employees should get the prior approval of the Business/Functional Head to incur
any expenses towards entertainment.

Giving or accepting a bribe, a payoff or any kind of inducement to/from any third
parties, public servant, customer, supplier or business associate of the company
in the conduct of business is unlawful and is strictly prohibited. It can be damaging
to both individual and company's reputation.

Employees shall not accept gifts in kind or cash or enjoy any special privileges
from any business associate (except for complimentary sweets on Festive/New
year occasion, the value of which shall not exceed Rs.2500/-).

DEALING WITH CUSTOMERS, SUPPLIERS AND MARKET:

Employees will ensure that products supplied / services/ provided to customers
are as per the stated quantity, specifications and meet delivery commitments.
Employees will handle customer's queries and complaints promptly and fairly.

Suppliers/ Service Providers will be selected based on merit, price, quality and
performance. Our Company's policy is to select reliable suppliers / service
providers through a competitive bid process.
Employees may not make false or misleading statements regarding its
competitors or its products. Employees will enable Company to comply with all
competition laws.

CONFIDENTIALITY OF INFORMATION:
As a result of employment with the company, employees may be entrusted with
confidential information; with regard to the company and /or its affiliates, its
customers and suppliers.

Employee shall use information received in the course of their business dealings
only for the purpose it is intended or normally used and never for personal gain.
He/ She will not unauthorizedly release or share any confidential data or
information to others and will adhere to the terms and conditions of the
confidentiality clause in employment.

During the tenure of services or even thereafter, an employee shall not disclose,
divulge or make public or shall personally use for his/her gain any of the
materials, processes, accounting transactions, dealings, information etc. which
is/are the intellectual property of the Company, whether the same may be
confined to him/her or known to him/her during the course of his/her services or
otherwise and all such information shall be treated as confidential. The Company
will be at a liberty to initiate any kind of civil and/or criminal proceedings,
whichever it deems fit, in case of any violation of this clause.

Employees must take adequate steps to protect company's assets including

company information/data, which they have in their possession and shall
immediately report any suspected fraud, theft, security breach or improper use of
company's assets by others. The use of company assets including Computer,
Laptop or Internet device for any unlawful, unethical and any purpose other than
employee's official duties is strictly prohibited. Employees are strictly advised not
to share their network or personal passwords, provide sensitive information
/data online or in email or click on links in unverified emails.

All employees must respect confidential information belonging to others.

IV. COMPLIANCE:
It is the policy of our company to ensure proper compliance with all applicable
laws, rules and regulations. No employee in any way will cause the company's
accounts or other records to not clearly describe and properly state the true
nature and timing of business transactions.

If someone observes ambiguity and is unsure of legal requirement or its

understanding, company policies, he must consult Concerned in Legal/Corporate
Audit Dept. /Senior Management. The company values and protects employee if
he/she reports violations in good faith or come forward with his/her suggestions,
concerns or ethical issues.

V. NON- CONFORMANCE OF THE CODE:

Non-observance of this code shall be construed as a misconduct that could
warrant disciplinary action, including dismissal or any other legal action as may be
decided by the Management.

VI. AMENDMENTS:
The company reserves the rights to amend/add/delete any provisions of this code
at any time without assigning any reason whatsoever. The employees are advised
to check for any such change regularly and hereby unconditionally agree to all
such changes in the code.

Approved by :

Date : 28/03/2019