CODE OF CONDUCT
FOR
DIRECTORS AND SENIOR MANAGEMENT EXECUTIVES

PHILOSOPHY

It is the long pursued policy and commitment of Bala Techno Industries Limited:

(a) To adhere to highest standards of integrity – professional and financial – and business ethics in operation of its business. 
(b) To make full, fair, accurate, sensible, timely and meaningful disclosure in the periodic reports required to be filed by the Company with government and regulatory agencies.
(c) To Comply with applicable laws, rules and regulations.
(d) To address misuse, misapplication or misappropriation of the Company’s assets and resources.
(e) To maintain highest level of confidentiality and fair dealing within and outside the Company.

We believe that the honour of managing this organization has been handed to us by the various stakeholders who have reposed "trust" in us and we as professional managers are the "trustees" of those stakeholders. It is therefore our responsibility to ensure that the organization is managed in a manner that protects and furthers the interests of our stakeholders. We recognize society as an important stakeholder in this enterprise and therefore it is part of our responsibility to practice good corporate citizenship

The Board of Directors of the Company wishes to document a Code of Conduct for all directors and as well as for all senior management executives.


APPROPRIATE AUTHORITY

For employees of the Company, ‘Appropriate Authority’ shall mean the designated reporting authority of the executive concerned, or the Managing Director/Whole Time Director of the Company. In case of members of the Board, the appropriate authority shall be the Board of Directors.


APPLICABILITY

The Code of Conduct shall apply to:
1) All Directors of the Company, whether executive or non-executive including nominee directors (in case of independent directors, as provided below); 
2) All senior executives of the Company.
3) All executives of the Company, having direct reporting to the Chairman/Managing Director/Wholetime Director of the Company.

So much of this Code as relates to the regular business, workings, day-to-day management or supervision of the business of the company on a regular basis shall not be applicable to independent directors. Independent directors are responsible for their conduct during the board meetings.