This code of conduct and ethics shall apply to the Directors and Members of the Senior Management of Bhairavnath Sugar Works Limited.

The Company is committed to be a good corporate citizen. The Directors, officers and employees of the Company must not only comply with applicable laws, rules and regulations but should also strive to promote honesty in conducting business.

Conflicts of interest

The Directors, officers and employees should avoid 'conflicts of interest' with the Company. In case there is likely to be a conflict of interest, they should disclose all facts and circumstances thereof to the Board of Directors or any officer nominated for this purpose by the Board and a prior written approval should be obtained.

Protecting Company assets

Protecting the Company's assets is a key responsibility of every employee, agent and contractor. The Company's assets have been employed only for the purpose of conducting the business for which they are authorised. Care should be taken to ensure that assets are not misappropriated, loaned to others, or sold or donated, without appropriate authorisation.

Integrity and honesty

The Directors, officers and employees shall act in accordance with the highest standards of personal and professional integrity, honesty and ethical conduct within the Company's premises. They act in a manner that will protect the Company’s reputation.

Health, safety, environment and social responsibility

The safety of people at the workplace is a primary concern of the Company. We maintain compliance with all local laws to help maintain secure and healthy work surroundings.

Confidentiality

The Directors, officers and employees shall maintain the confidentiality of information. The use of confidential information for personal advantage or profit is also prohibited.

Compliances

It is the Company's policy to comply fully with all applicable laws and regulations governing contact and dealings with government employees and public officials and to adhere to high ethical, moral and legal standards of business conduct. This policy includes strict compliance with all local, state, Central and other applicable laws, rules and regulations.

Insider trading

In the normal course of business, officers, Directors, employees, agents, contractors and consultants of the Company may come into possession of significant and sensitive information. This information is the property of the Company you have been entrusted with it. The purpose of this policy is both to inform you of your legal responsibilities and to make clear to you that the misuse of sensitive information is contrary to the Company policy and applicable Indian securities laws.

Disciplinary actions

All officers should adhere to the code of conduct and ethics of the Company. Violations of this code of ethics will result in a disciplinary action, which may even include termination of services of the employee. The Board of Directors or any person designated by the Board for this purpose shall determine appropriate action in response to violations of this code of ethics.