Accuracy of Business Records: Accurate recording and timely reporting of information is extremely important. Investors count on Sawaca Business Machines Limited to provide accurate and timely information. Directors and SMP also must properly record information related to their responsibilities. All financial books, records and accounts must accurately reflect transactions and events, and conform to generally accepted accounting principles. No entry may be made that intentionally hides or disguises the true nature of any transaction.

Recording Business Information: Most of the accounting records are subject to public disclosure. Accounting records are also made available to investors or the media. Directors and SMP should therefore attempt to be as clear, concise, truthful and accurate as possible when recording any information.

Conflict of Interest: Directors and SMP must avoid any conflicts of interest between them and the Company. Any situation that involves, or may reasonably be expected to involve, a conflict of interest with the Company, should be disclosed promptly to the Chairman of the Board. A "conflict of interest" can occur when:

• Personal interest of a Director or SMP is adverse to, or may appear to be adverse to, the interests of the Company as a whole.

Full, fair, accurate, timely and understandable disclosure: The Company is committed to ensuring that all disclosures in reports and documents that the Company files with, or submits to the Stock Exchanges and Government agencies well as other public communications made by the Company are full, fair, accurate, timely and understandable. The Company's Chief Executive and Chief Financial Officer are ultimately responsible for taking all necessary steps to ensure that this occurs. All Directors and SMP shall take appropriate steps within their area of responsibility to ensure the same.

Confidential Information: Directors and SMP must maintain the confidentiality of information, intellectual property and domain knowledge entrusted to them by the Company and any other confidential information about the Company that comes to them, from whatever source, in their capacity as Director or SMP, except when disclosure is authorized or legally mandated. For purposes of this Code, "confidential information" includes all non-public information relating to the Company.

Compliance with Laws, Rules and Regulations: Directors and SMP must comply, with applicable laws, rules and regulations, including insider-trading laws.

Reporting and Questions: Any director or a SMP with a concern or question about applicable provisions of the Code, or about conduct that may violate these provisions, should contact the Chairman of the Board.

Publication of the Code of Conduct: This Code of Conduct will be posted and maintained on the Company's website. All Board Members and Senior Management Personnel shall affirm compliance with the Code on an annual basis. The Annual Report of the Company shall contain a declaration to this effect signed by the Chairman.

   Prevention Of Insider Trading: SEBI has promulgated Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 1992 to protect the interest of the investors in general. In order to have a healthy stock market it is essential that all those who play in stock market are aware of the all price sensitive information of a Company.