Through our untiring effort to maximize customer satisfaction by delivering products of high quality, the group has gained a special position and preference in domestic and international market. As a result the company has been profit making, growing and also dividend paying since its inception in 1986.

Considering the financial year performance and strength of the company ICRA (one of the reputed rating agencies of India) has assigned LBBB and A+++ rating to the company for its short term and long term debt program.

The Directors and employees shall conduct the Company's business in an efficient and transparent manner in meeting its obligations towards the shareholders and other stakeholders. The Directors and employees shall not be involved in any activity that would have any adverse effect on the objectives of the Company or against national interest. The following elucidates the Company’s position on the manner of conduct of the Company’s business and transactions:

A. CORPORATE CITIZENSHIP & REGULATORY COMPLIANCE

• The company shall be committed to good corporate citizenship, not only in the compliance of all relevant laws and regulations but also by actively assisting in the improvement of quality of life of the people in the communities in which it operates.
• The company shall not treat these activities as optional, but should strive to incorporate them as an integral part of its business plan.
• Employees of the company, in their business conduct, shall comply with all applicable laws and regulations, in letter and spirit, in all the territories in which they operate.

A. CORPORATE CITIZENSHIP & REGULATORY COMPLIANCE

• The company shall provide equal opportunities to all its employees and all qualified applicants for employment without regard to their race, caste, religion, colour, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin or disability.
• Human resource policies shall promote diversity and equality in the workplace, as well as compliance with all local labour laws, encouraging the adoption of best practices.

C. HEALTH SAFETY & ENVOIRNMENT

• The policy of the company is offering to its employees a safe and healthy workplace. The company is against all forms of exploitation of children and believes in abiding by the laws and applicable regulations for prevention of child labour.
• The Company is committed to prevent the wasteful use of natural resources and minimize any hazardous impact of the development, use and disposal of any of the intermediaries or direct materials used in its product and service offerings on the ecological environment.

D. CONFLICT OF INTEREST

• An employee or director of the company shall always act in the interest of the company, and ensure that any business or personal association which he / she may have does not involve a conflict of interest with the operations of the company and his / her role therein.
• In case of an Employee, where such conflict appears at any time or is in existence at the time of the implementation of this policy, such Employee shall forthwith make a disclosure in writing to the Management. Upon reviewed the Employee may be directed to avoid/resolve the conflict or to take such remedial action as is deemed suitable by management.
• A Director shall disclose any potential conflicts of interests to the Board of Directors or any Committee thereof and abstain from participating in the decision making or in influencing the decision on the areas resulting in the potential conflict of interest in accordance with the applicable rules under the Companies Act. In addition, the Director shall provide on a periodic basis, such disclosure as is required by the Board of Directors or any Committee thereof.
• If the management becomes aware of an instance of conflict of interest the management shall take a serious view of the matter and consider suitable disciplinary action against the employee.

E. CONFIDENTIALITY

• Any information concerning the Company’s business, its customers, suppliers, etc. to which the Directors or the employees have access or which is possessed by the Directors and the employees, must be considered privileged and confidential and should be held in confidence at all times, and should not be disclosed to any person, unless
  1. Authorised by the Board; or
  2. The same is part of the public domain at the time of disclosure; or
  3. Is required to be disclosed in accordance with applicable laws.

F. EXCLUSIVITY

• Senior Officers are expected to devote their full attention with integrity and honesty to the business interests of the Company. They are prohibited from engaging in any activity that interferes with his proper discharge of responsibilities of the Company, or is in conflict with or prejudicial to the interests of the Company.

G. INSIDER TRADING

• A Director or the Employees and their relatives shall not derive any benefit or assist others to derive any benefit from the access to and possession of information about the Company, which is not in the public domain and thus constitutes insider information. They shall also ensure compliance with SEBI (Prohibition of Insider Trading) Regulations, 1992 as also other regulations as may become applicable to them from time to time.
• The Company also prohibits its Directors and Employees in undertaking any fraudulent or unfair trade practice in connection with the securities of the Company.

H. PROTECTION OF COMPANIES ASSETS

• The Directors and the Employees shall not use the Company’s tangible assets such as equipment and machinery, systems, facilities, materials etc. or intangible assets such as proprietary information, relationships with customers and suppliers, etc. for their personal benefit or for the benefit of a related party or for any purpose other than of conducting the business of the company.

I. PUBLIC REPRESENTATION

• The company honours the information requirements of the public and its stakeholders. In all its public appearances, with respect to disclosing company and business information to public constituencies such as the media, the financial community, employees, shareholders, agents, franchisees, dealers, distributors and importers, the company shall be represented only by specifically authorised directors and employees. It shall be the sole responsibility of these authorised representatives to disclose information about the company.

J. GIFT & DONATIONS

• The Company, it’s Directors and Employees shall neither receive nor offer or make directly/indirectly any illegal payments, gifts, donations or any benefits which are intended to obtain business or unethical favours. However, the Directors or Employees may receive such nominal gifts which are customary in nature or are associated with festivals.

For any query/grievance the investors may contact with:
Mas Services Limited
Registrar and Transfer Agent
T-34, 2nd Floor, Okhla Industrial Area,
Phase - II,
New Delhi - 110 020
Ph:- 26387281/82/83
Fax:- 26387384
email:- info@masserv.com

Mr. Abhishek Agrawal
Company Secretary
Good Luck House,
II- F, 166-167,
Nehru Nagar, Ambedkar Road,
Ghaziabad- 201001
Ph. 0120 419 6600/6700
Fax: 0120 419 6666
email:- investor@goodlucksteel.com