CATMi - CODE OF CONDUCT

The CATMi Code of Conduct is based on the ten principles of the United Nations Global Compact’ - http://www.unglobalcompact.org/aboutthegc/thetenprinciples/index.html in the areas of human rights, labor, the environment, and anti-corruption. The purpose of this Code of Conduct is to communicate our common set of ethical values and business principles to our stakeholders and to provide internal guidance. CATMi encourages members and other business partners within its sphere of influence to adopt the principles in this Code of Conduct.

CATMi’s operations in India are based on high ethical standards promoting fair business practices in accordance with applicable laws and complying with the legislation and regulations of the country in which CATMi operates. Where legislation does not provide guidance, CATMi applies its own standards based on its corporate values and culture. In the event of a conflict between legislation and the principles contained in this Code of Conduct, the legislation shall prevail. It is the responsibility of all members to be aware of relevant legislation or to seek legal advice to ensure compliance.

BUSINESS PRACTICES

SAFEGUARDING CORPORATE ASSETS

Safeguarding CATMi assets, both tangible and intangible (such as intellectual property rights) is vital to the success of CATMi’s goals and objectives. Members have a duty to use CATMi’s assets only for legitimate business purposes and to protect them from loss or unauthorized use. Under no circumstances may CATMi’s assets be used for unlawful or improper purposes.

CONFLICT OF INTEREST

To operate in a fair and open manner, it is important that every corporate member of CATMi avoid any situation or interest which might interfere with their judgment concerning their responsibilities to CATMi and other members. Should such a conflict of interest arise, it must be reported immediately by the person subject to the conflict to the Board of Directors.

ANTI-CORRUPTION

No CATMi member may offer, give or accept, directly or indirectly, any bribe or any other improper inducement for the purpose of wrongfully obtaining or retaining business. Any such offer received by a CATMi member must be reported without delay to the Board of Directors. No gifts or similar benefits may be offered, given or accepted by member of CATMi if they are considered to contravene any legislation or code of local business practice. Gifts or similar benefits may only be offered to, or accepted from, a third party if they are modest in value and if they are consistent with reasonable hospitality given in the ordinary course of business.

POLITICAL INVOLVEMENT

CATMi observes neutrality with respect to political parties and candidates. Neither the CATMi name, nor any resources controlled by CATMi, shall be used to promote the interests of political parties or candidates.

INSIDER TRADING

CATMi expects its members to act in the manner required of insiders, even if they are not in fact registered as insiders. Members must keep all information and secrets that relate to CATMi’s present and future business operations strictly confidential. It is prohibited to misuse or disclose to any third party any information about CATMi’s business operations or information about specific projects.

ACCOUNTING AND REPORTING

All accounting and reporting by CATMi are reported in accordance with generally accepted financial accounting practices, and accounting records give a true and fair view of the financial position. CATMi strives to provide disclosure that is open, fair, relevant, timely and understandable.

HUMAN RIGHTS AND WORKPLACE PRACTICE

HUMAN RIGHTS

CATMi supports and respects the principles set out in the Universal Declaration of Human Rights - http://www.un.org/en/documents/udhr/index.shtml

NON-DISCRIMINATION AND EQUAL OPPORTUNITIES

CATMi treats its members in a manner that does not discriminate with regard to gender, nationality, religion, race, age, disability, sexual orientation, political opinion, union membership, or social or ethnic origin. CATMi promotes the ideal that all members shall be treated with equal respect and dignity.

LABOR

CATMi does not accept child labor nor other forms of compulsory or forced labor. CATMi supports freedom of association, and all members have the right to be a member of a trade union and to bargain collectively.

WORK ENVIRONMENT

A safe and healthy working environment shall be provided for all members. Violence or threats are never acceptable at CATMi and shall be reported to the Board of Directors immediately if such situations should occur.

ENVIRONMENTAL PRACTICE

CATMi supports a precautionary approach to environmental challenges and a responsible way of conducting its own business operations.

RESPONSIBILITY OF BOARD OF DIRECTORS AND MEMBERS

It is the responsibility of CATMi members and Board of Directors to make sure that both the content and the spirit of this document are communicated, understood and acted upon within their organizations and to encourage members to report behavior that may be noncompliant with this Code of Conduct. Explicit or implicit approval of questionable actions will not be tolerated. Reports of violations of this Code of Conduct may be made anonymously and in confidence to the Board of Directors. Persons reporting violations in good faith will not be subject to retaliation. Failure to act in compliance with the Code of Conduct can result in appropriate disciplinary actions.

CATMi seeks continuous improvement in the way it conducts its business and encourages all members to take part in this process. The Code of Conduct is regularly reviewed.

This Code of Conduct has been reviewed by the President and Board of Directors.

Note: Stricter rules in a local guideline or policy will overrule this document where such exists.