ASM Investor Relationships: Code of Ethics

This code of Conduct (“this Code) shall be called “The Code of Ethics for Directors and Senior Management Personnel” of ASM hereinafter referred to as “the Company”.

The purpose of this code is to bring about an ethical and transparent process in managing the affairs of the Company.

The Code comes into effect from the date of its approval by the Board of Directors of the Company.

The Directors and the Senior Management Personnel shall act within the authority conferred upon them and in the best interest of the Company and observe the following Code of Ethics:

All the Directors and the Senior Management Personnel of the Company shall conduct their activities, on behalf of the Company and on their personal behalf, with the highest standards of honesty, integrity and ethics while pursuing the well accepted professional standards. All the Directors and the Senior Management Personnel shall act in good faith, with responsibility, due care, competence and diligence, without allowing their independent judgment to be subordinated. The Directors, in particular, shall act in the best interests of the Company and fulfill their fiduciary obligations.

The Directors and the Senior Management Personnel shall be scrupulous in their work and shall not engage in any activity or enter into any pecuniary relationship, which might result in conflict of interest, either directly or indirectly with that of the Company. In the case of Senior Management Personnel, each person shall make full disclosure of all facts and circumstances thereof to the Managing Director and a Director in like circumstances shall make adequate disclosures to the Board of Directors.

All the Directors and the Senior Management Personnel shall maintain confidentiality of all the material and non-public information about the Company, its business and affairs. Any information pertaining to business of the company, its customers, suppliers and others connected with its activities, which is not in the public domain and to which the Directors have access or they possesses such information, shall be considered confidential and held in confidence, unless authorized not to do so when such disclosure is authorized or legally mandated. No Director or Senior Management Personnel shall provide any information either formally or informally, to the press or any other publicity media that is detrimental to the interest of the company.

All the Directors and the Senior Management Personnel shall endeavourer compliance with all the applicable laws, rules and regulations applicable to the Company. In order to assist the company in promoting lawful and ethical behavior, the Directors shall report any possible violation noticed thereof or of the Code of Ethics to the Board of Directors.

The Executive Director(s) and the Senior Management Personnel shall be responsible to safeguard and protect the assets and resources of the company. Except as specifically authorized, the assets of the Company, including both tangible and intangible should not be misused or used by them for personal gains.

The Directors and the Senior Management Personnel shall not derive benefit or assist others to derive benefit by giving investment advice from the access to and possession of information about the Company which is not in the public domain and therefore constitute insider information. Both, the Directors and the Senior Management Personnel shall make timely disclosures of (i) trading in the shares of the Company. (ii) Transactions having personal interest and (iii) related party transactions that are required to be made under the laws, rules, regulations and Code for prevention of Insider Trading.

The Directors and the Senior Management Personnel shall neither receive nor offer or make directly/indirectly any donations, which are intended to obtain business or unethical favors, save and except nominal gifts which are customary or commemorative in nature.

Each Director and Senior Management Personnel shall adhere to this Code and affirm compliance on an annual basis. Suspected violations of this Code shall be reported to the Board.

Any waiver of the provisions of the code shall be approved by the Board of Directors of the Company only. The Board of Directors of the Company shall address any question or interpretation under this Code.

Any amendments to the provisions of this code shall also be approved by the Board of Directors and promptly disclosed on the website of the Company and other applicable regulatory filings pursuant to the applicable laws, rules and regulations.