Code of Business Conduct and Ethics for Directors and Senior Management of Puravankara Projects Limited (“Company”)

Our Company is committed to maintaining the highest standards of ethical and lawful conduct and is proud of its reputation of honesty and integrity. We are committed to these core values and this commitment is shared by our Board of Directors (“Board”), Senior Management Personnel and Employees, and is critical to the Company’s success. Our principles and values require us to persistently maintain and uphold the highest degree of ethical and legal standards in all our business endeavors, and in pursuing our corporate objectives.

All Directors and Senior Management of the Company need to act within the bounds of the authority conferred upon them, inter alia by applicable laws and the Memorandum and Articles of Association of the Company, and with a duty to make and enact informed decisions and policies in the best interests of the Company and its stakeholders. The Directors and Senior Management Personnel of the Company acknowledge and accept the scope and extent of their duties that they are entrusted with, and are responsible for the oversight of the assets and business affairs of the Company. Consistent with these principles, the Company’s Board has adopted this Code of Conduct and Ethics (“Code”) as a guide to the high ethical and legal standards expected of its Directors and Senior Management Personnel and the Directors and Senior Management are expected to adhere to the standards of loyalty, good faith, and the avoidance of conflict of interest that follow.

In performing their duties the Directors and Senior Management Personnel shall:

• Act honestly, fairly, ethically and with integrity;
• Conduct themselves in a professional, courteous and respectful manner and strive towards enhancing and maintaining the reputation of the Company;
• Act in the best interests of, and fulfill their fiduciary obligations to the Company and its stakeholders;
• Help create and maintain a culture of high ethical standards and commitment to compliance of all applicable laws, rules and regulations;
• Act in good faith, responsibly, with due care, competence and diligence, without allowing their independent judgment to be subordinated;
• Not to derive benefit or assist others to derive benefit from information concerning the Company, which is not in the public domain;
• Comply with SEBI (Prohibition of Insider Trading) Regulations, 1992 guidelines with respect to insider information and the Company’s policies and codes as applicable to them with respect to purchase and sale of Company’s securities and shall not use confidential information, including price sensitive information, acquired in the course of their service with the Company for their personal advantage;
• Respect that any information concerning the Company’s business, its customers, suppliers etc., which is not in the public domain and to which the Director and/ or the Senior Management may have access, must be considered confidential and held in confidence, unless authorized or legally required to disclose. No Director or member of Senior Management shall provide any information either formally or informally, to the press or any other publicity media, unless specifically authorized to do so;
• Disclose any potential conflicts of interest that they may have with respect to any matters that may come up before the Board, and abstain from discussion and voting on any matter in which the Director has or may have a conflict of interest;
• Not to use Company’s property, information, position or opportunities for personal gain or for any other purpose outside the Company. Any suspected incident of fraud, mismanagement of Company’s assets or theft should be immediately reported for investigation to the Chairman of the Board or such other person, if any, designated by the Board in this regard;
• Share with fellow Directors and Senior Management Personnel information, as may be appropriate to ensure proper conduct and sound operation of the Company.

Annexure 1