CODE OF CONDUCT FOR DIRECTORS AND SENIOR MANAGMEMENT

The Board of Directors (the “Board”) and the Key Managerial Personnel (the “Senior Management”) of Cheviot Company Limited (CCL) agree to the following Code of Conduct adopted by the Board:-

• To take utmost care and diligence in exercising the powers attached to the office in performance of the duties;

• To act in accordance with the highest standards of personal and professional integrity & maintain honesty and ethical conduct in the best interests of CCL;

• To ensure that personal interest do not conflict with interest of CCL;

• To ensure not to provide any information to the press and any other publicity media unless specifically authorized to do so;

• To remain independent in judgement and actions in respect of all decisions taken by the Board;

• To ensure that confidential information acquired in the course of work is disclosed only if permitted by the Company or in accordance with requirements of law.