FOR DIRECTORS AND SENIOR MANAGEMENT The Board of Directors (the “Board”) and the senior management of Ajanta Pharma Limited all over the world in all areas, regions and functions, subscribe to the following Code of Conduct adopted by the Board. They would 1. Use due care and diligence in performing their duties of office and in exercising their powers attached to that office; 2. Act honestly and use their powers of office, in good faith and in the best interests of Ajanta Pharma Limited as a whole; 3. Not make improper use of information nor take improper advantage of their position  as a Director; 4. Not allow personal interests to conflict with the interests of Ajanta Pharma Limited; 5. Not engage in any business relationship or activity which may be in conflict of interest of Ajanta Pharma Limited; 6. Recognise that their primary responsibility is to Ajanta Pharma Limited shareholders as a whole but they should (where appropriate) have regard for the interests of all stakeholders of Ajanta Pharma Limited; 7. Comply with all applicable laws, rules and regulations both in letter and spirit; 8. Not engage in conduct likely to bring discredit upon Ajanta Pharma Limited; and 9. Be independent in judgement and actions, and to take all reasonable steps to be satisfied as to the soundness of all decisions taken by the Board of Directors; 10. Comply with Code of Conduct for prevention of Insider Trading; 11. Ensure the confidentiality of information they receive whilst being in office of  Director and is only disclosed if authorised by the company, or the person from whom the information is provided, or as required by law; 12. Not accept gifts from persons or entities who deal with the Company; 13. Protect the Company’s assets, labour and information and shall not use them for personal use unless approved by the Board.