Business Policies - Rinfra

1. What is Inside Information?

Employees usually have 'non-public' information about Reliance Infrastructure or about a company with which Reliance Infrastructure does business. Such information is termed 'inside information'.

Inside information includes, but is not limited to, 'unpublished price sensitive information'.

Such inside information may include information about:

• new products or processes;
• mergers, acquisitions or dispositions of businesses or securities;
• problems being faced by the company;
• sales;
• profitability;
• negotiations relating to significant contracts or
• business relationships with others;
• significant litigation; or
• other financial, technical, commercial, legal information;
• pricing policies;
• Customer negotiation details;
• Business policies;
• Operational discussions and decisions;
• Viewpoints of individual manager that may surface in a discussion;

2. What is "unpublished price sensitive" information?

Please refer to The Policy on Insider Trading for details.

3. What are the general principles of the Company policy about Inside Information?

It is important to understand that any Reliance Infrastructure employee may hold inside information and be subject to the restrictions contained in this policy.

Employees should not give or release, without proper authority, to anyone not employed by the company, or to another employee who has no need or does not have the appropriate authority to receive inside information.

Careful control of and restriction of access to sensitive inside information can significantly inhibit improper use of such information.

Employees should not use inside information obtained which in company employment (including information about customers, suppliers or competitors) for the direct or indirect personal gain of the employee or anyone else.

This includes, but is not limited to, taking advantage of such information by:

• Trading or providing information for others to trade in securities or
• Acquiring an interest of any kind of property, including but not limited to plant or office sites or adjacent properties or
• Advising or assisting or informing a customer, contractor, supplier, consultant, advisor, agents, intermediary, contractor, broker, and representative of the company in a manner which leads to direct or indirect personal gain of the employee or anyone else.

Data transmitted or stored electronically are the assets of the Company requiring protection. Each data user throughout the company is responsible for compliance with the standards and related procedures with reference to safe guarding such data.

Employees who handle particularly sensitive inside information, and who may not have the background to understand the legal and corporate implications of the misuse of such information, should periodically discuss with the Ethics Office the implications of this policy.

If during the course of employment in Reliance Infrastructure employees have developed any patent, know how, invention, or process or if they have been entrusted in preparation of any market/other research report, the same is prohibited from being used outside the company.

Employees should also refer to the Insider Trading Policy contained in this policy document to further understand the company's policy on this issue.

Employees found violating the requirements of the Policy on Insider Information would be subject to disciplinary action.

1. What is our commitment?

We are committed to the maintenance of accurate and complete corporate records.

2. What is expected of employees?

Transactions between Reliance Infrastructure and outside individuals and organizations must be promptly and accurately entered in our books and systems in accordance with generally accepted accounting practices and principles.

3. What actions on the part of employees are considered unacceptable?

Rationalizing or even considering misrepresentation of facts or falsification of records is completely unacceptable. It is illegal, will not be tolerated, and will result in disciplinary action.

4. What is the specific policy to ensure financial and accounting integrity?

All accounts and records shall be documented in a manner that:

• Clearly describes and identifies the true nature of business transactions, assets, liability, income and expenditure.
• Properly and timely classifies and records entries on the books of account in conformity with generally accepted accounting practices and principles.
• >No record or entry or document shall be false, distorted, misleading, misdirected, and deliberately left incomplete or suppressed.

There is no room for:

• Improper or fraudulent accounting;
• Documentation or financial reporting contrary to company's policies and
• Intentional wrong accounting / misclassifications and miscalculations.

The company has established internal control standards and procedures to ensure that assets are protected and properly used and that financial records and reports are accurate and reliable.

Employees share the responsibility for maintaining and complying with required internal controls. Improper accounting and documentation and fraudulent financial reporting are not only contrary to Company policy but also may be in violation of laws and regulations.

What are the principles for external communication?

We are committed to be truthful in all our actions. We strive to be honest and forthright with one another and with all our stakeholders.

Reliance Infrastructure seeks to form a constructive and productive relationship with all aspects of media. Reliance Infrastructure recognizes that open communication is essential. Reliance Infrastructure has a comprehensive corporate information programme and provides full relevant information about its activities to legitimately interested parties, subject to any overriding considerations of business confidentiality and cost.

Only employees, authorised by Reliance Infrastructure's Corporate Communications Department, are permitted to give an interview/or publish an article written by him/her, in various sections of media/radio/T.V. shows, etc.

The above does not apply to non- Reliance Infrastructure topics. However, it will be preferred if the employee clears the same prior to the said interview/press article, radio talk or TV show with the Corporate Communications Department.

For further details, reference may be made to the detailed internal guidelines issued by Corporate Communications by writing at corporate.communication@relianceada.com.

1. Why do we need a policy on Work Ethics?

Success in implementing a Code of Ethics is not likely to be fully achieved in a large organization like Reliance Infrastructure without a positive work environment. Inter-personal relations based on the values of respect, harmony and mutual development are keys in this effort.

Managers need to take effort to maintain high standards of interpersonal behaviour to ensure continuing employee development and high levels of morale within the organization.

To that end, a defined code of work ethics can give managers a clearer direction on these issues.

2. What are the issues that are relevant to promote better work ethics ? And what are our policies ?

Business confidentiality

• Employees are expected to maintain business secrecy and confidentiality by ensuring that inside information policy is implemented. For instance, employees should not share with others any information that they may come to acquire during the process of closed-door discussions with other employees/outsiders.

Favoritism in the workplace

• All Departmental / Business Heads must treat each and every employee in their department equally.
• It is but natural for a manager to trust, respect and depend upon one employee most than another a result of experience, common interests, goals or backgrounds.

The underlying principles is that each one of us, regardless of our position within Reliance Infrastructure, are expected to work to create an environment where people are valued as individuals and treated with respect, dignity, fairness and equality, thus leaving no room for displays of favoritism.

Avoid behavior and actions that can result in a Conflict of Interest.

• For a conflict of interest to exist, direct benefit to the employee may or may not be feasible. Conflict of interest may also arise when an emotional attachment to a person by way of relation or allied interests can affect or affects the decisions made by the employee.

The employee should conduct himself and arrange his affairs in way that ensures he is not involved in any arrangement or circumstance, including relations or other personal relationships that might dissuade him from acting in the best interest of the company.

• An employee should not use directly or indirectly his influence within the company on an officer of the company, or other executives, or on any outside party, that may benefit an employee and/or his family and/or his relations and/or any persons covered above.

Avoiding Intellectual Dishonesty

• Employees should perform their actions with sincere diligence and honesty. They should strive to attain high levels of intellectual integrity and honesty. Employees should strive to be true to themselves while performing their duties. A typical example of intellectual dishonesty would be when an employee decides to present an inaccurate picture of his work/performance to his superiors even when he is consciously aware of the inaccuracy. Such behavior should be avoided.
• Intellectual integrity fosters leadership qualities in employees. Managers should strive to instill, encourage, and appreciate intellectual integrity in their colleagues.

Gossiping at Work

• There is no place for malicious rumors and gossip, both of which attack the spirit of the individual and attempt to divide us into groups.
• At Reliance Infrastructure's workplace, all employees should not gossip. Of course, it is only natural that we communicate with other employees, but our office is no place for rumors / gossip.
• Whenever you are communicating / passing information (casually or not), do so in a manner that ensures that the message heard by those listening, is as accurate as possible.
• Insinuations, half-truths, malicious rumors must be avoided.
• Reliance Infrastructure's ethical work place is based on trust, honesty, candor and teamwork.

Other related standards

The following guidelines are suggested

• To tidy up work areas.
• To organize all files, papers and documents.
• To punch in the Time-o-log attendance system each time an employee leaves / returns to office.
• Refrain from using office assets and properties for personal work.
• Maintain company property and assets with appropriate care.

Other office behavioral standards

The cost of these activities is high, especially in the areas of motivation, morale and stress, quality, turnover, productivity, pride as well as customer satisfaction all the areas that we want to emphasize in a highly ethical company.

• Refrain from "scapegoating" blaming others for missed commitments, bad decisions or poor results.
• Allowing the boss/ colleagues to fail by withholding information or by not pointing out risks.
• Over-promising a customer/ colleague.
• Turf-guarding / protecting yourself from losing control or power.
• Withholding / purposely delaying information required by another department/colleague.
• Risk aversion not doing what is needed to succeed because you fear the consequences of failure more than you value the reward of success.
• Not delivering on commitments due to the fact that the other person's priorities are not important to you or because you look good by looking better than someone else.
• Misuse of time : Time is an asset and the misuse of that asset is just as wrong as the misuse of any of our assets here at Reliance Infrastructure.

Examples of misusing time

• Taking personal time off and not reporting it.
• Long lunches and breaks.
• Wasting time at work on computer games, personal business or reading magazines.
• Time spent on telephone on personal matters or working during office hours on personal projects.
• Calling outsiders at the work place and conducting personal/ other business appointments.

Transparency

• What is Reliance Infrastructure's policy on Transparency? Reliance Infrastructure and all its employees undertake to conduct all the business transactions and take all decisions which are relevant to their function, in a transparent and reasoned manner keeping in mind, the established norms of confidentiality and secrecy which are necessary to protect the business and competitive interests of Reliance Infrastructure.
• The employees shall conduct all their actions in a manner complying with all laws and requisite disclosures there under.
• The employees shall endeavor to create an internal communication network in their spheres of operation and activity, which is transparent and unhindered by levels in organizational hierarchy.

Protection and use of Assets

What is the company's policy on protection and use of assets?

It is the primary responsibility of each employee to protect and properly utilize the Company's assets, including proprietary information. Employees must safeguard company's physical property and other assets against unauthorized use or removal, as well as against loss by criminal act or breach of trust.

1. What are employees expected to do?

Reliance Infrastructure employees are expected to ensure that their conduct at all times, in official as well as personal capacity is such that Reliance Infrastructure s reputation is upheld.

They must remember that one is judged by how he or she acts and the company he or she keeps. Our reputation will be upheld if we act with integrity in all our dealings, even at a personal level, and we always do what we think is right at all times.

In official as well as personal capacity, employees at no times should indulge in any action / behavior that -

• Violates any law; or
• Is indicative of personal indiscretion; or
• Is socially unacceptable.

3. What is the essence of this policy on conduct at home?

When judging the relevance of any personal indiscretion or socially unacceptable behavior by an employee, whether at work or elsewhere, consideration of following questions may be helpful:

• Could the employee's conduct leave him or her vulnerable to special pressures from others in a way that might affect his or her work?
• Could the employee's conduct prejudice Reliance Infrastructure's good name?

4. What are some common actions that can be considered as improper conduct?

• Exercise of sound judgment and common sense will equip every employee to judge as to whether his / her actions can be construed as improper conduct. The key question that employees need to ask themselves at all times is whether this conduct befits a cultured, mature, and socially responsible adult?
• It also must be kept in mind that while major lapses of law and social behavior are usually prevented very often seemingly minor mistakes can and do result in improper conduct. Even such actions need to be avoided.

Indicative examples are:

Violation of law

• Possession of liquor in excess of permissible limits is a violation of the excise laws.
• Possession of foreign exchange in excess of defined limits is in violation of forex laws.
• Holding undeclared or undisclosed assets.

Acts of personal indiscretion or socially unacceptable behavior are:

• Getting drunk in a party or a social function or misbehaving in public.
• To be under the influence of liquor, narcotics or any other form of intoxication while representing Reliance Infrastructure or reporting to work at the Reliance Infrastructure premises or at a customer's / supplier's premises.
• Using abusive expletive infested language.
• Inflicting verbal abuse on anyone (including employees).
• Loud and irresponsible behavior in public, which causes discomfort and embarrassment to surrounding people.
• Manhandling or physical assault on any one.
• Unreasonable criticism.
• Undue show of authority.
• Reporting to work in an inappropriate dress or presenting oneself in a shabby manner.

The range of possibilities covered by this policy is too wide for any pre-defined guidelines. Respect for the self as well as for others has to be the guiding principle for personal conduct. However, it is imperative that employees remember to exercise sound judgments and demonstrate a serious sense of responsibility and maturity all times and in official as well as personal capacities.

What is Reliance Infrastructure's policy on Health Safety and Environment?

"Safety of person overrides all the Production Targets" is the Health, Safety and Environment Policy of Reliance Infrastructure.

To attain this, the Health Safety and Environment in the plants are safeguarded by the provision of:-

• Properly designed plants.
• Effective use of safe working procedures and practices.
• Meeting in all respects the applicable statutory requirements.
• Clearly defined procedures for inspection, operation and emergency shut down and their updating.
• Imparting relevant training and strict validation of employees after training.
• Continuous, systematic and micro level auditing internal as well as external of work procedures and practices.
• Continuous and systematic education of Company's Contractors' and Transporters' personnel for observing safe work practices.
• A detailed investigation of all incidents including the minor ones and near-miss incidents followed by recommendations to avoid recurrence.
• Analyze the findings of investigations of accidents in similar industry and take steps to prevent such accidents in the plants.
• Keep abreast with the latest international codes, standards and practices.
• Continuous monitoring of plant and ambient environment as well as of various effluents liquid, gas and solid to maintain a clean and safe environment in and around the plants.
• Pre-employment and periodic medical check-ups of employees for early identification of occupational health hazards.

What is Reliance Infrastructure policy on Quality?

We at Reliance Infrastructure are committed to total customer satisfaction in terms of quality and services for the entire range of our products.

Our continued commitment to excellence and innovative efforts help us stay ahead as market leaders.