ETHICAL POLICY

Summary

Shree Shivam Services Pvt Ltd expects that all of its business is conducted in compliance with high ethical standards of business practice. We apply these standards to all dealings with employees, customers, suppliers and other stakeholders

The Ethics Policy, which has been approved by the Board of Shree Shivam Services Pvt Ltd, is set out below. Our Ethics Policy has been developed to ensure that our business is conducted in adherence with high ethical and legal principles and sets standards of professionalism and integrity for all employees and operations worldwide.

The following is a summary:

•  All employees have the right to expect and the responsibility to ensure that Shree Shivam Services Pvt Ltd’s
   business is conducted with high ethical standards and legal principles;

•  Our policy is to operate within applicable law;
•  Discrimination or harassment of any kind will not be tolerated;
•  As a matter of policy, we do not make political donations;
•  No bribes shall be given or received;
•  Conflicts of interest must be avoided;
•  We aim to be a responsible partner within our local communities;
•  Employees are encouraged and supported to report, in confidence, any suspected wrong doing.

Our internal control process includes the review of appropriate ethical behavior.

Introduction

This summary is not intended to address every instance in which we are called upon to observe and practice sound business ethics. However, it is meant to remind us that if we each strive to live and abide by basic ethical principles in the day-to-day conduct of our business, we will foster an environment of mutual trust and respect, and continue to build on our reputation for integrity, which is the foundation of the company.

Shree Shivam Services Pvt Ltd believes that trust fosters long-term relationships which are built through honesty, openness and fair play. All aspects of our business must be based on the highest ethical standards. Our employees are key to our success and we're all part of the Shree Shivam Services Pvt Ltd team, so we all must take responsibility for our own actions and conduct. In addition, since managers are responsible for directing the actions of others and for setting an example for other employees, they should be familiar with this Business Ethics Policy and how it applies to them and to those under their supervision. It should be remembered that no one has authority to require or influence another employee to violate this code of conduct, and any attempt to do so may result in immediate disciplinary action, up to and including termination of employment.

Good judgment is a fundamental basis of everything Shree Shivam Services Pvt Ltd does as a company and understanding our ethical and legal parameters can only strengthen that judgment. We have a responsibility to follow applicable laws and regulations in all locations where we do business. Instances where law does not explicitly address an ethical matter requires us to use good judgment, adhering to the spirit of the law, and following the principles of honesty, integrity, and common sense. To be clear, if local law is stricter than the Business Ethics Policy, and then we should follow local law. If the Business Ethics Policy is stricter than local law, then we should follow the Policy.

This Shree Shivam Services Pvt Ltd Ethics Policy is supported by the whole Board of Shree Shivam Services Pvt Ltd and shall be reviewed from time to time. The policy applies to every employee of the company

Employment, Discrimination and Harassment

Taking into account local practice and the operational requirements of the business, it is our goal to offer unambiguous and fair terms of employment and to provide employees with appropriate opportunities to develop their skills and progress in their careers. It is our intention to honor all applicable terms and conditions of employment.

The Company recognizes its duty and the benefits of providing working conditions which promote good health, safety and environmental practices – copies of Company guidelines in respect of these matters are available from local management. Employees are encouraged to report immediately any health, safety or environmental concerns to their line manager in order to protect the welfare of themselves and colleagues.

Employees are encouraged to recognize their duty to act in a responsible manner in the workplace, having due regard for the health, safety and general welfare of their colleagues.

It is our policy to respect the human rights of all employees, including:

•  ensuring employees have the freedom to associate or to collectively bargain without fear of discrimination against
   the exercise of such freedoms;

•  a prohibition on using forced or child labor; and
•  appropriate restrictions on the access and use of personal employee information to respect rights of privacy.

Conduct and Behavior Standards

All employees are expected to contribute to the success of Shree Shivam Services Pvt Ltd by performing their jobs as required and conducting themselves in a professional manner consistent with the company's business philosophy, values and standards of business conduct.

Employee honesty and integrity are essential to ethical business practices. Employees are required to prepare all reports, including expense reports and time cards accurately and truthfully. Unacceptable conduct that is considered detrimental to the company's best interests may result in immediate disciplinary action, up to and including termination of employment.

Misuse of Shree Shivam Services Pvt Ltd property, including the company's equipment, supplies, e-mail, intranet, and computer and voicemail systems can constitute unethical conduct. These tools and resources are intended to assist employees in conducting legitimate company business, and any other use of such property is discouraged.

Compliance with the Law

At all times, it is our policy to stay within the laws, rules and regulations of the countries, states or other jurisdictions in which we operate. It is our policy to co-operate fully with relevant public authorities and regulatory bodies as appropriate.

The senior management team of each operating unit or subsidiary is responsible for ensuring that legislation is complied with and that requirements are appropriately communicated to their staff. All employees have the right and the responsibility to resolve doubts or uncertainties about ethical questions or compliance with the law. To resolve any ethical or legal issue, an employee should first contact his or her immediate manager or supervisor for guidance prior to taking any action. We also strongly encourage an 'open door' policy to bring any such queries, if necessary, to a higher level of management.

Political Contributions

Shree Shivam Services Pvt Ltd’s policy is that it does not use corporate funds, whether in cash, goods, services, equipment, etc., to make contributions to political candidates, political parties or committees, or political entities.

Bribes or Other Payment to Influence Business Transactions

The giving or receiving of any such payment is indefensible. No bribes of any sort may be paid to or accepted from customers, politicians, government representatives, advisors or representatives. It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions (slush funds).

Violation of governing laws leads to significant risk that could result in fines, penalties and damaged reputation. Although laws vary, the following general guidelines should be followed when dealing with any governmental agency:

•  NEVER discuss or offer employment or business opportunities to contracting officers or governmental officials who
   may influence an official act or decision affecting Shree Shivam Services Pvt Ltd or its business.

•  NEVER offer or give bribes or other questionable or irregular payments (whether in the form of cash, goods or other
   property) if you know, or have reason to believe, that such payments will be used to influence their representatives to
   facilitate official acts or decisions involving Shree Shivam Services Pvt Ltd. This rule applies even if such payments
   are considered customary or legal in the law of land.