General Principles of Code of Business Conduct and Ethics (COBE)¶

Krenovate is driven by a set of values, which are embedded in each of our activities and processes. These are: Quality, Confidentiality, Integrity, Meritocracy and Obligation to Dissent. The COBE sets forth the legal and ethical standards and provides an overview of Krenovate guiding principles and these values. The Code is not intended to be all inclusive and does not cover every conceivable situation an Employee or a Representative may encounter. For that, we place a high degree of reliance on the judgement and discretion of the individual Employee or Representative and it is for him/her to decide what is right, including a decision to obtain guidance from others on the approriate course of conduct.

The COBE is a dynamic document taht will constantly evolve over time as we continue to apply the best practices and principles to the complex and diversified issues/ situations of business conduct and ethics. However, as we change, refine and adapt our best practices, the organisation's commitment to integrity and honesty will always remain consistent.

General Employee Responsibilities¶

All Employees are expected to:

Understand the importance of each Krenovate policy and guideline in relation to his/her job and follow it religiously.
Know that violation of any Krenovate policy and guideline will result in disciplinary action (including immediate termination of employment).
Use good judgement abd demonstrate a high degree of personal integrity and honesty at all times, even in situations that are not specifically addressed by this COBE or by a Krenovate policy.

What Managers Need to Know¶

In most cases, a Krenovate manager will be the first person to be contacted by an Employee whi believes that a Krenovate policy has been, or may be, violated. Thus, managers play a vital role in ensuring compliance with this COBE, Krenovate policies and applicable laws and regulations and they must:

Be familiar with Krenovate policies and guidelines so that they can inform their subordinates about the policies that relate to their jobs and expectations with respect to such policies.
Be perceptive to potential problems or compliance issues that could arise in their area of responsibility.
Learn not to, "look the other way"; if there is a potential or actual problem or issue, report it immediately so that prompt action can be taken, if necessary.

Assistance¶

If an Employee or Representative needs more information or have questions about any Krenovate policy, they may contact the following:

His/her manager
Human Resource Department
Legal Department
Any member of the Executive Team

If you need to report a concern/non-compliance/any incident, you may contact the Whistleblower Committee (Refer to the **Krenovate Whistleblower Policy* for more information*).

Krenovate Commitment¶

Equal Employment Opportunity¶

Krenovate is committed to providing equal employment opportunity to all applicants and Employees. Individuals will be hired and promoted on the basis of their qualifications, performance and abilities. Krenovate employment practicies will comply, in all respects, with applicable laws and regulations. The fundamental employment policy of Krenovate comprises of:

Equal employment opportunity to all persons regardless of race, colour, sex, religion, national origin, disability, veteran status or any othe category protected by law.
All conditions of employment, including but not limited to recruitment, promotion, compensation, benefits, transfers, layoffs, return from layoff, company-sponsored training, education, social and recreational programmes, to be dispensed without regard to race, colour, sex, religion, age, national origin, diability, veteran status or any other category protected by law.

Krenovate managers and Human Resource Department will ensure that all Employee selection activities are carried out in line with prescribed Employee selection guidelines covered by applicable laws.

Freedom from Workplace Harassment¶

Workplace Harassment, whether verbal, written or physical, will not be tolerated. We are determined to provide a workplace free from any type of discrimination and/or harassment.

Workplace Harassment is defined as offensive and/or unwelcome behaviour and/or conduct towards an individual based on diverse human characteristics and/or cultural background (such as age, race, gender, national origin, diability, religion or any other diverse human characteristic) that substantially interferes with an induvidual's employment or creates an intimidating, hostile or offensive work environment for that individual. Workplace Harasssment does not refer to Employees performance-based discussions or other appropriate business-related conversations. Some examples of workplace harassment are continued or repeated verbal abuse; comments and jokes about ethnic backgrounds, race, religion, physical characteristics, racial or ethnic stereotypes; and graphic or degrading comments about an Employee's appearance.

Sexual Harassment is a specific form of Workplace Harassment and Krenovate strictly prohibits any such kind of harassment. (Refer to the **Krenovate Anti-Sexual Harassment Policy* for more information*).

Employee Privacy¶

Krenovate respects the personal information of its Employees. Krenovate and its authorised entities/individuals collect and maintain personal information about Employees, such as employment, medical, educational and other personal history details. Krenovate maintains the confidentiality of such information about its former and existing Employees and access to such information is restricted to people who need to know that information. Employees who have access to personal information have an added responsibility to ensure the confidentiality of all such information and the disclosure of such information is only to be made in accordance with Krenovate's policy where there is genuine business, legal or a reasonable requirement to do so. However, this privacy protection does not apply to the Employees's own personal information that is stored by him/her on Krenovate equipment or in office files. Krenovate also has the right to monitor Employee's use of his/her equipment and systems- telephones, e-mails, internet, computers, fax machines, etc. This applies to all Krenovate-owned equipment in te owrkplace and other locations.

Employee Conduct¶

Alcohol, Substance Abuse and Other Prohibitions¶

We are determined to provide a workplace free from any type of alcohol and substance abuse.

Krenovate has a strict policy on substance abuse, which includes alcohol abuse and use of illegal drugs and controlled substances. Employees and Representatives are not permitted to report to work or conduct Krenovate business on Company premises or operate Company vehicles while under the influence of alcohol, drugs and/or controlled substances. This also applies to any other work site or any other premises/ location where Employees and Representatives are assigned during work hours or are representing Krenovate in a professional capacity.

Krenovate policy forbids consumption, purchase, sale, manufacture, trafficking, possession and/or distribution of these substances. Serving alcoholic beverages to clients, guests or Krenovate Employees at Krenovate premises is not allowed and us strictily prohibited. The only exception to the above consumption of alcoholic beverages is on Krenovate events where such consumption has been specifically permitted. Even during such events, intoxication or excessive use or abuse of alcohol is prohibited and Krenovate expects that the Employees will exercise propriety and ethical conduct at such events.

To create a safe working environment, Krenovate has zero tolerance against workplace violence. Workplace violence includes any coercive, unethical activities that create an environment of fear and has the potential to create a risk to health, safety and wellbeing of the Employees. In furtherance to this, Krenovate strictly prohibits possession of firearms or other weapons, on Company property.

Protection of Krenovate Assets¶

All Employees and Representatives should protect Krenovate assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on our profitability. All Krenovate assets are to be used for legitimate business purposes only. Any suspected incident of fraud, misuse or theft should be immediately reported for investigation. Krenovate assetsshould not be used for personal benefit.

Physical Assets: Krenovate assets include physical assets, such as facilities, systems, equipment and materials, corporate charge cards. All Employees must adhere to the following guidelines for judiciously using Krenovate assets and protecting them from loss, theft and misuse:

Use Krenovate assets appropriately and protect them when not in use.
Do not give or lend these assets to anyone without qpproval.
Display your Krenovate identification badge while on Krenovate premises.
Use electronic access control cards that provide access to Krenovate facilities and systems.
Do not admit unauthorised individuals into Krenovate facilities.
Be aware of and understand Krenovate's security policies and procedures. Employees should also be alert and be aware of situations or incidents that could lead to the loss, misuse or theft of Company property.
Notify the Administration Department immediately if any asset is lost, misused, or stolen.
Notify the Whistleblower Committee if you suspect any fradulent activity.

Computers and Other Information Systems: Krenovate maintains a wide spectrum of technology (including electronic communications technology) for legitimate business activities to be conducted by authorized individuals, in support for its business needs. Krenovate expects that Employees will responsibly use all the information assets including computers, laptops, printers, fax machines, scanners, telephones, voicemail and software. Krenovate's connection to the internet and its intranet systems is solely for business purposes. Employees who misuse information systems may lose access privileges and depending on the severity of the situation, may also be subject to strict disciplinary action including dismissal. The policy prohibits the following activities, using Company's assets:

Any illegal activity, such as pornography, pyramid schemes, gambling and/or software piracy.
Commercial or political uses, such as running a personal business, and/or promoting a political candidate.
Chain e-mail, emailsof lewd nature and/or virus hoaxes and/or actual viruses or downloading unauthorised software or materials.
Harassing and/or threatening communications including defamatory, libelous or slanderous comments.
Intentional concealment of one's identity or misrepresentation.
Any form of pronography and/or offensive materials, in tangible or intangible form.
Using the systems in any other way that interferes with any Employee's productivity and/or that of others.
"Hacking" or attempting to "hack" or obtain unauthorised access of/to any computer or computer network of Krenovate.
Not to make copies, lend, resell or transfer software, install personal software or install software that is lewd or obnoxious in nature.
Damage, circumvent and/or harm the security controls designed to protect Krenovate information systems or equipments.

Other general guidelines that an Employee must follow are:

Do not store sensitive client or personal information on your Krenovate computer.
Promptly report any suspected violations and/or virus attack.
Use of Licensed/Legally Authorized Software: The software used at Krenovate may be owned by other companies and protected by copyright law and/or license restrictions. Before acquiring or using any such software, Employees are required to contact the IT Department and/or Legal Department to ensure that all third party intellectual property rights related to such software use are fully complied with.

(Refer to the **Krenovate End User Computing Policy* for more information*)

Proprietary Information: Properietary Information is any information owned by and related to Krenovate, such as information on Krenovate's databases, Krenovate's business clients/customers details, personnel details, medical and salary records, copyrighted materials, Krenovate's technical or scientific information relating to current and future products, services or research; business or marketing plans or projections; earnings, credit and other financial data; executive and organizational change, software and othe confidential information relating to the Company. All Krenovate properietary information is confidential in nature unless specifically classified otherwise. This information may also be subject to copyright, patent and other intellectual property and legal rights.

Authority to Make Business Commitments¶

The authority to make business and/or financial commitments on behalf of Krenovate has been clearly defined by way of clear delegation of authority, and all Employees and Representatives are expected to work in accordance with the same. Employees and Representatives should not make any oral or written commitments, arrangements or promises of business that create a new agreement or modify abn existing agreement with a third party without proper approval. Such commitments should be made by those having defined authority, and acting within the limits of the said authority. Any and all forms of misrepresentation, fraud, dishonesty and deception are to be avoided by Employees and Representatives.

Conflict of Interest¶

Employees must avoid any relationships which create a perceived or actual conflict between their obligation to Krenovate and personal self-interest. An Employee's financial, business or other non-work related activities must be lawful and free of conflicts with the Employees's responsibilities to Krenovate. Employees and Representatives must not, as part of engaging in any outside activities, misuse Krenovate resources, discredit its name and reputation or affect its business in any way. Employees and Representatives should not participate in any business or personal relationships, activities, or dealing that might adversely affect Krenovate.

Although it is not possible to provide a comprehensive list of every possible situation that may lead to a conflict of interest, given below are a few illustrations or possible conflicts of interest:

You (or your family member) have a significant financial interest in a company (clients/suppliers) that has dealing with Krenovate, and you are in a position to influence those dealings or if you have access to non-public information about that company.
You (or your family member) have a significant financial interest in a company that competes with Krenovate.
A family member is a Director, officer, employee or consultant in a company (clients/suppliers) that has business dealings with Krenovate or competes with Krenovate.
Your participation as a Director, officer, employee, consultant or promoter in an outside business prevents you from devoting full time to your job at Krenovate.
Receipt of gifts from suppliers, clients or competitors.
Potential conflict resulting from a family member or close friend working for or owning a supplier of Krenovate.
Any outside activity or relationship which could reasonably be interpreted as being in conflict with the interests of Krenovate.
Providing assistance to an organisation that markets products and services in competition with Krenovate's current or potential products or servcie offerings.

Development and Protection of Intellectual Property¶

Krenovate vigorously protects all of its confidential information and intellectual property (IP), whether in the form of patents, trade secrets, copyrights or trademarks, and expects its Employees and Representatives to do the same. It is critical that Krenovate maintains its reputation as a leader of creation and implementation of best practices to protect all IP that is developed by or disclosed to Krenovate.

Krenovate accepts, as a professional responsibility, to respect and not knowingly violate third party intellectual property rights and copyrighted materials and to abide by all relevant copyright legislations. Employees are expected to abide by this and to accept it as their own personal responsibility. Most of Krenovate's work that is created is subject to copyright protecction and all such works should be accordingly identified to ensure that recipients of such work have knowledge of the same. Such work can include white papers and presentations, any source code that is developed and shared outside Krenovate, reports and articles submitted by Employees, training materials and manuals and other documentation, software programs and databases, etc. Copyright protection applies not only to printed materials but also to visual and electronic media. Copyright lawas protect all works of authorship even if they fo not carry the copyright symbol (C). Krenovate's policy prohibits the unauthorised reproduction of documents, portions of documents, images, reports and data and analysis created by any third party without giving due credit to the author or obtaining permission from the author.

Trademarks (such as name, logo, combination of the name and logo) serve to identify products and services in the market and are distinctive in nature. Krenovate expects its Employees to properly acknowledge and use Krenovate's trademarks and trademarks of other companies at all times. Employees should ensure that (a) the trademark is spelt correctly and written the way the owner of the trademark writes it, (b) they do not use or copy or allow others to use or copy Krenovate trademark or a thrid party trademark without permission, © they do not make commercial use of the name, likeness or distinctive personality traits of a trademark without first having obtained permission to do so, (d) they do not use Krenovate name or trademark, owned or associated with Krenovate, on any letterhead stationery and/or for any personal purpose without proper authorisation.

Krenovate's trade secrets are essential and need to be protected by secrecy since we use considerable efforts to keep and maintain their confidentiality. Some examples of our trade secrets are: details of our clients, our pricing, number of our Employees, our proprietary methods of conducting research or providing other services to our clients and other similar types of information that are not known outside Krenovate or are only known to our clients with a need to know. Employees have the resposnsibility to keep all Krenovate information confidential and to disclose such information only to other Krenovate Employees with a need to know. Information identified as trade secret should also be subject to additional restrictions including limited access to the information (even among Krenovate Employees) and storage of information in segregated areas (or drives, if in an electronic medium) that can be accessed only by authorised personnel.

When an Employee joins Krenovate, he/she is required to sign, at the time of employment, a non-disclosure agreement that restricts disclosure of proprietary, trade secret, and certain other information about Krenovate. During the employment of Krenovate, any ideas, inventions, discoveries, processes, formulas, business methods, concepts, designs, whitepapers, research notes, compilations, articles, publications, software, hardware, improvements, computer programs and documents that are developed, formulated, conceived or planned, using Krenovate time, material or resources and that relate to it's actual or anticipated business, research or development or that are suggested by, or result from work or tasks that an Employee acrries out for Krenovate, are the property of Krenovate and all intellectual property rights vest in Krenovate. Subject to the relevant legislations, this applies no matter where or when- at work or after hours- such information (in tangible or intangible form) is created and is irrespective of the capacity in which the Employee created such work- be it managerial, technical, scientific or professional. All proprietary assets and confidential information of Krenovate must be returned on cessation of employment. The duty to keep all Krenovate confidential and proprietary information in confidence extends beyond the cessation of employment of an Employee.

In certain cases, Krenovate may procure the services of third parties (such as contract engineers, designers, software developers, web designers, outside development houses etc.). The hiring request in this regards should be referred to the Talent Acquisition team of the HR Department. The HR Compliance Team must review all such contractual arrangements, in consultation with the appropriate operations department, to ensure proper treatment of IP rights. While such individuals are hired because of their experience in various technical areas, Krenovate does not employ people as means of gaining access to trade secrets and sensitive information of others.

All queries in this regard should be referred to the HR Compliance Team.

Maintaining Confidentiality¶

Krenovate Employees are required to keep all Krenovate confidential information, which is received or accessible during and subsequent to employment, in strictest confidence and protect them from unauthorised disclosure. Confidential information includes all information thta is not available in the public domain, such as IP; trade secrets; business; marketing and service plans; databases and records; login details; salary information; customer and supplier lists; major contracts and any unpublished financial data and reports. Employees must maintain the confidentiality of all information entrusted to them by Krenovate and/or its clients and/or suppliers. Krenovate's policy requires that all disclosures of confidential information are done only after the party, to whom the information is to be disclosed, has signed a non-disclosure agreement with Krenovate.

Employees should not disclose, publish, communicate, described directly or indirectly, in any form or manner any confidential information to any third party without a valid business purpose and proper authorisation from Executive Team and the Legal Department. Employees are also required not to disclose confidential information (even within Krenovate) to anyone who does not need to have such confidential information.

Employees need to have safeguards against not only intentional and wilful disclosures but also against inadvertent disclosures. Krenovate strongly urges its Employees to be aware and alert of such circumstances or situations where there is a chance of an unintentional disclosure of confidential information. Examples of such circumstances can be: discussing client related information or other confidential information with a colleague in a crowded elevator or during lunch hour sitting in the cafeteria where Employees from other teams are also seated. Krenovate Employees are strictly prohibited from discussing Krenovate confidential information with their family members or friends, who might innocently or unintentionally pass such information on to someone else. Not only are Employees required to maintain the confidentiality of the information but they should only use it for Krenovate business and not for any personal benefit or reasons. Employees are urged to be aware of social engineering techniques deployed for extracting confidential information.

With regard to Information owned by/about other parties, Krenovate strongly urges its Employees to:

Not exercise improper/illegal means for obtaining information about Krenovate competitors.
Not attempt or solicit or obtain competitive intelligence through improper means or through means which could be disparaging to Krenovate reputation.
Treat information of all third parties (including Krenovate's suppliers, vendors, clients) with utmost care and confidentiality and respect the privacy rights of such parties.
Treat any proprietary information of another party that is received, with caution to prevent any accusations that Krenovate misappropriated or misused such information.
Only disclose confidential information about Krenovate's suppliers, vendors, clients to those Employees who need to know such information to transact business with such suppliers, vendors or clients.
Exercise extra caution while dealing with clients personnel about whom there may be reasonable ground of belief that, due to change in client's organisation internal dynamics, such personnel may become unauthorised to receive/access any confidential information.
Regard all information received as Confidential, if it is not known that such information is confidential or not, and to exercise all due care with regard to maintaining confidentiality of such information.

All queries in this regard should be referred to the Legal Department.

Compliance with Laws¶

Krenovate ensures that it complies with ail the relevant legislations and that we conduct our business within the framework of applicable laws and regulations. Violations of laws, regulations, rules and orders may subject the violator to individual criminal or civil liability, as well as to disciplinary action by Krenovate.

Compliance with Competition Laws¶

Krenovate's belief is that fair competition is fundamental to free enterprise and it is committed to ensure compliance with the competition laws of various countries as may be applicable to Krenovate business operations. These laws, known under various names such as antitrust, monopoly, fair trade etc, are designed to protect the market competitive process and to ensure that it is fair and healthy. These laws prohibit illegal agreements; collusion among competitors; formal or informal agreements with competitors that harm competition or customers; bid rigging, price fixing and allocations of clients, territories or contracts; the acquisition or nnaintenance of a monopoly or attempted monopoly through anti-competitive conduct etc.

To ensure compliance with the various competition laws and in line with Krenovate policy, Krenovate strongly advocates that the following are strictly adhered to:

Avoiding reciprocal dealing — avoidance of any kind of understanding with a client or supplier, which conditions sales or purchases of Krenovate products on reciprocal sales or purchases of the client's/supplier's products.
Participation in meetings where competitors are present: No Employee or Representative should attend or remain present at any meeting where there is a discussion by competitors on any subject which the Employee or Representative would be otherwise precluded from discussing with the competitor. Additionally, no Employee or Representative should attend or remain present at any informal trade association meeting of competitor members held for the purpose of discussing business matters, without observing the formal procedural requirements established by the trade association for its business meetings. Employees and Representatives should be aware that participation in standard development and product certification activities that impact competitors or suppliers may raise antitrust concerns. Therefore, before participating Employees and Representatives should consult with tha Legal Department.
Discussions with competitors — No Employee or Representative shall enter into any understanding or agreement, whether express or implied, formal or informal, written or oral with a competitor limiting or restricting in any of the following: prices, costs, profits, product or service offerings, terms or conditions of sale, production or sales volumes, production facilities or capacity, market share, decisions to quote or not quote certain business, sales territories, clients, distribution methods etc. Employees and Representatives who do have contact with competitors should be ever mindful of not placing themselves in positions which might create the "appearance of impropriety." As a result, no Employee or Representative should discuss with or accept information from a competitor or any other third party acting for a competitor, on any subject as to which an understanding with the competitor would be prohibited.

Antitrust laws impose severe penalties, including criminal penalties, for certain types of violations. All Employees and Representatives who have periodic contact with competitors of Krenovate need to be ever mindful of these laws and strive to avoid placing themselves in situations that might create even the appearance of impropriety. Employees in managerial positions will be responsible for taking appropriate measures in their respective areas to achieve strict legal compliance, both by themselves and by their subordinates.

When a situation is unclear, seek advice from the Legal Department.

Compliance with International Trade Controls¶

All Employees and Representatives must understand and follow applicable international trade control and customs laws and regulations, including those relating to licensing, shipping and import documentation and other such requirements. They should be aware that the trade control laws of various countries might be applicable to Krenovate because these laws apply to business operations and import-export transactions from and to such countries. Such laws govern not only the sale and purchase of goods or products but also cover wide amplitude of technology and information transfer/re-transfer shipment etc.

Employees are required to screen all transactions in accordance with applicable export/import requirements/laws. They are charged with the duty know the client to whom an item/information is being exported or information is being transferred (be it information embedded in software or via email), the end use of the item/information and its final destination.

Krenovate's general policy is not to undertake work or service which will be used directly for any military/defence/security product or service. An exception to this may be obtained with explicit authorisation from the Executive Team, in consultation with the Legal Department.

Compliance with Anti-boycott laws and Embargoes¶

Krenovate's policy is not to participate in boycotts, embargoes or other restrictive trade practices prohibited or penalized under applicable local laws of the countries in which business is conducted, unless sanctioned by the Government. Thus, Krenovate strongly advocates that its Employees and Representatives are aware of all such laws and consults the Legal Department in case of doubts.

Fair Dealings¶

Krenovate is committed to fair and unprejudiced dealing with all persons and companies with whom it has business relationships, including its clients, partners and suppliers (hereinafter referred to as "Business Associates"). In deaiing with Krenovate's Business Associates, Employees and Representatives are expected to consider the best interests of Krenovate and should not show any favour or preference to any person, entity or business. Krenovate strongly advocates that all of its Employees should have business dealings that are impartial and are not influenced by their personal or family interests. An Employee or Representative should not:

Own any substantial amount of stock or other financial interest in, or participate in the business of, an actual or potential client or supplier of goods or services to Krenovate, if that Employee or Representative is directly or indirectly involved in Krenovate's business with the client or supplier. The definition of what constitutes a "substantial" amount of stock or other financial interest will depend on the particular facts and circumstances in any given case. For queries in this regard, contact the Legal Department.
Not seek or accept loans from any supplier or client or any person or entity seeking to do business with Krenovate, except in the case of loans made by financial institutions in the normal course of business.
Not purchase items for personal use on a discounted or wholesale basis from actual or potential suppliers of goods and services to Krenovate, unless the personal purchases are made pursuant to an approved supplier discount program.

Each Employee and Representative should endeavour to respect the rights of and deal fairly with all clients, suppliers, competitors and Employees. No Employee or Representative should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other illegal trade practice, All Employees and Representatives are responsible for avoiding activities which could damage the Company's reputation or its relationships with its actual and potential suppliers or clients.

Gifting and Entertainment¶

It is against Krenovate policy to give or receive anything of value to gain an unreasonable competitive advantage.

No Employee and Representative shall, solicit or accept gifts, favours, loans or preferential treatment from any person or entity that does business or seeks to do business with Krenovate.
Employees and Representatives are prohibited from offering bribes, kickbacks, illegal political contributions or other improper payments to any client, government official or third party that may fall outside the parameters of applicable laws and evoke any adverse action against Krenovate and creates the impression of seeking an improper advantage.
No Employee and Representative shall, in violation of any applicable law, make or offer to make directly or indirectly, through any other person or firm, any payment of anything of value (money, gift, contribution, etc.), significant gifts or provide any extravagant entertaintnent to a client or supplier without approval.

Krenovate shall endeavour to employ only reputable, qualified individuals and firms who agree to be bound by and act in accordance with the provisions of this policy, to act as employees, consultants, partners, agents or sales representatives.

Insider Trading and Stock Tipping¶

Employees and Representatives, who have access to inside information (also known as material non— public/unpubiished price sensitive information), are not permitted to use or share such information for any purpose other than to conduct Krenovate business. All non-public information about Krenovate, or companies/clients with whom Krenovate does business, is considered confidential information. To misuse material non-public information in connection with buying or selling securities, including tipping others who might make an investment decision on the basis of this information, is illegal and is strictly prohibited by Krenovate.

In order to avoid vioiating laws related to insider trading and tipping, each Employee or Representative who has inside information about Krenovate, or about another company that he or she has obtained by virtue of his or her position with Krenovate, is expected to abide by the following guidelines:

Never buy, sell or suggest to someone else (including family members) that they should buy or sell stock or other securities of any company while you are aware of material non-public information about that company. Material non-public information is the information which is unavailable to the public and that which an ordinary investor would consider as important while making an investment decision.
Donot pass on or disclose material non-public information unless necessary far the conduct of Krenovate business — and never pass on or disclose such information if you are not authorised to do so and suspect that the information will be used for an improper trading purpose.
Do not evade these guidelines by acting through anyone else or by giving material non-public information to others for their use even if you will not financially benefit from it directly.

All queries in this regard should be referred to the Legal Department.

Financial Controls, Records and Auditing¶

Krenovate is required by law to keep and preserve all corporate and businesses records accurately and honestly and report any financial irregularity. The integrity of our records and public disclosure depends upon the validity, accuracy and completeness of the information supporting the entries in our books of account. Financial statements and reports are prepared in accordance with the generally accepted accounting principles, standards, laws and regulations for accounting and financial reporting of transactions, estimates and forecasts. Making of false or misleading entries is strictly prohibited. Financial statements and accounting records are also relied upon to produce reports for our Executive Team, stockholders and creditors, as well as for various governmental/statutory bodies. Employees, who collect, provide or analyze information for or otherwise contribute in any way in preparing or verifying the financial reports should strive to ensure that our financial disclosure is accurate and transparent.

In furtherance of this policy, all Employees and Representatives shall:

Follow all accounting and reporting procedures.
Be accurate, timely and complete in preparing and maintaining all required records and reports.
Obtain all required approvals before releasing any financial information outside Krenovate.
Ensure that all financial records and reports, whether in hard copy or electronic/computer-based format, are securely maintained.
Grant Krenovate's internal and external auditors and other authorised individuals access to all appropriate Krenovate records and provide them with accurate and complete information as they may from time to time require.
Promptly report any concerns about possible violations of this policy to the Whistleblower Committee (For more information please refer to the Krenovate's Whistleblower Policy).

Auditing: Krenovate is committed to providing accurate information to external and internal auditors in a timely, orderly and consistent manner. Employees are prohibited from directly or indirectiy taking any action to manipulate, mislead or fraudulently influence the external and internal auditors. Prohibited actions include:

To issue or reissue a report on the Company's financial statements that is not warranted in the circumstances (due to material violations of generally accepted accounting principles, generally accepted auditing standards or other professional or regulatory standards);
Not to perform audit, review or other procedures required by generally accepted auditing standards or other professional standards;
Not to withdraw an issued report; or
Not to communicate matters to the Audit Committee.

Commitment to Society¶

Environment, Health and Safety¶

Krenovate strives to connply with all relevant environmental, health and safety laws and regulations and to provide each Employee and Representative with a safe and healthy work environment. Each Employee has the responsibility of maintaining a safe and healthy workplace for all Employees and Representatives by following environnnental, safety and health rules, practices and reporting accidents, injuries and unsafe equipment, practices or conditions.

All Employees and Representatives are expected to:

Refrain from any acts that may pollute the environment
Refrain from any acts that violates any environmental, health and safety laws and regulations
Maintain a clean end healthy workspace that does not present any hazard to any one
Report circumstances, that might lead to health and safety risks for Employees or the general public, for timely corrective action

Media Communication Guidelines of Krenovate¶

Krenovate is committed to providing accurate information to the public in a timely, orderly and consistent manner. Krenovate will comply with applicable laws and regulations regarding the required mandatory legal disclosures. The Executive Team members are the designated spokespersons for Krenovate and they may from time to time designate other persons (via a written approval) to speak on behalf of Krenovate with respect to a specific issue or to respond to specific inquiries from the investment community or the media.

Specifically, Krenovate prohibits the disclosure of non-public corporate material information to media, securities market, investors and potential investors, unless the communication is made:

To a person who owes a duty of trust or confidence to Krenovate
To a person who has signed a confidentiality agreement
To a rating agency, for the sole purpose of developing a credit rating that will be publicly available

Information is "material" if there is a substantial likelihood that a person/entity would consider it important in making an investment decision.

"Non-public" information is any information that has not been disseminated in a manner reasonably designed to make it generally available to public.

Any Employee or Representative who receives an inquiry from the investors or the media must immediately refer the inquirer to an Executive Team Member.

All Employees and Representatives are required to adhere to the guidelines and protocol which may be connunicated to them from time to time.

Reporting Violations of Code¶

Every Employee and Representative has a duty to adhere to this Code and all existing policies and procedures of Krenovate and to report any suspected violations in accordance with the procedure stated in the Whistleblower Policy. Employees and Representatives must adhere to the letter and spirit of the Code. It is reiterated that this Code is not intended to be totally comprehensive and Krenovate therefore relies on its Employees and Representatives to exercise discretion and engage in ethical conduct consistent with this Code.

Violations/Non-compliance of this Code may subject the violator to individual criminal or civil liability (inciuding penalties, fines etc.), as well as to strict disciplinary action by Krenovate (including dismissal). Disciplinary action may also be taken for: authorising or participating in a violation, knowingly failing to report a violation or suspected violation, refusing to cooperate with the investigation of a suspected violation, retaliating against an individual who reported a suspected violation in good faith.

Any complaint/concern/incident/violation/non-compliance should be reported in to the Krenovate Whistleblower Committee (Refer to the **Krenovate Whistleblower Policy* for more information*).

Changes and Waivers¶

Any waiver of this Code can be made only by express approval of the Board of Directors and to the extent permitted by relevant laws and regulations and will be promptly disclosed as required by a law or a regulation.

Acknowledgement of this policy is annexed as Annexure A¶

Last update: July 27, 2020