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Code of Conduct


Code of conduct for Landforce supplier:
The Landforce expects all of its employees to comply with the law and act ethically in all matters. We have the same expectations of our suppliers. Our Code of Business Conduct sets the basic standards for employee conduct. This Code of Business Conduct for Suppliers establishes related requirements for our suppliers. By Working together, we can achieve great success by doing the right thing.

Note: This Code contains general requirements applicable to all suppliers to Landforce. Particular supplier contracts may contain more specific provisions addressing some of these same issues. Nothing in this Code is meant to supersede any more specific provision in a particular contract, and to the extent there is any inconsistency between this Code and any other provision of a particular contract, the other provision will control.

Conflicts of Interest
Employees of Landforce should act in the best interest of the Company. Accordingly, employees should have no relationship, financial or otherwise, with any supplier that might conflict, or appear to conflict, with the employee's obligation to act in the best interest of  Landforce. For example, suppliers should not employ or otherwise make payments to any employee of The Landforce during the course of any transaction between the supplier and the Company. Friendships outside of the course of business are inevitable and acceptable, but suppliers should take care that any personal relationship is not used to influence The Landforce employee's business judgment. If a supplier employee is a family relation (spouse, parent, sibling, grandparent, child, grandchild, mother- or father-in-law, or same or opposite sex domestic partner) to an employee of Landforce, or if a supplier has any other relationship with an employee of Landforce that might represent a conflict of interest, the supplier should disclose this fact to Landforce or ensure that the Landforce employee does so.

Gifts, Meals and Entertainment
Employees of Landforce are prohibited from accepting anything more than modest gifts, meals and entertainment from suppliers. Ordinary business meals and small tokens of appreciation such as gift baskets at holiday time generally are fine, but suppliers should avoid offering Landforce employees travel, frequent meals or expensive gifts. Gifts of cash or cash equivalents, such as gift cards, are never allowed.

Business and Financial Records
Both the supplier and Landforce must keep accurate records of all matters related to the supplier's business with Landforce. This includes the proper recording of all expenses and payments. If Landforce is being charged for a supplier employee's time, time records must be complete and accurate. Suppliers should not delay sending an invoice or otherwise enable the shifting of an expense to a different accounting period.

Bribery
Suppliers acting on behalf of Landforce must comply with the India Government Act, as well as all local laws dealing with bribery of government officials. In connection with any transaction as a supplier to Landforce, or that otherwise involves The Landforce, the supplier must not transfer anything of value, directly or indirectly, to any government official, employee of a government-controlled company, or political party, in order to obtain any improper benefit or advantage. Suppliers must keep a written accounting of all payments (including any gifts, meals, entertainment or anything else of value) made on behalf of Landforce, or out of funds provided by Landforce. Suppliers must furnish a copy of this accounting to Landforce upon request.

Protecting Information
Suppliers should protect the confidential information of Landforce. Suppliers who have been given access to confidential information as part of the business relationship should not share this information with anyone unless authorized to do so by Landforce. Suppliers should not trade in securities, or encourage others to do so, based on confidential information received from Landforce. If a supplier believes it has been given access to Landforce's confidential information in error, the supplier should immediately notify its contact at the Company and refrain from further distribution of the information.

Similarly, a supplier should not share with anyone at Landforce information related to any other company if the supplier is under a contractual or legal obligation not to share the information.

Reporting Potential Misconduct
Suppliers who believe that an employee of The Landforce, or anyone acting on behalf of
Landforce, has engaged in illegal or otherwise improper conduct, should report the matter to the Company. A supplier's relationship with The Landforce will not be affected by an honest report of potential misconduct.


* This document is applicable to suppliers of Landforce and its majority-owned subsidiaries. Use of the terms " Landforce" and "the Company" in this document refers to Landforce or one or more of its subsidiaries, whichever is relevant to the particular supplier relationship.