The Code Applies To:

• All Directors, executives, officers and employees of ZIL Limited, and
• People, whether or not employees, acting as agents, affiliates, contractors or representatives of ZIL Limited, within all sectors, regions, areas and functions.

Board’s Responsibilities

This Code has been developed and approved by the Board of Directors of ZIL (the “Board”). The Board shall periodically review the adequacy and appropriateness of – and compliance with – the Code. The Board shall also implement any change it believes is necessary or desirable in order to achieve Code’s purposes.

Management’s Responsibilities

The Chief Executive Officer of ZIL is responsible for ensuring that ZIL conducts its business in accordance with this Code. The Chief Executive Officer shall communicate the strong support of senior management for this Code and shall endeavor to foster a strong “culture of compliance.”

• Relationships amongst employees, at all levels, must be truthful, trustworthy and honest.
• Compliance with the relevant laws, regulations, statutory provisions and company’s policies & procedures is a constant commitment and duty of every employee of ZIL.
• The Company’s business and activities have to be carried out in a transparent, honest and fair manner. Any discrimination based on race, color, religion, gender, age, nationality, marital status or physical disability is unacceptable.
• Employees must be committed to customer satisfaction and strive to provide quality in all business dealings.
• Employees must avoid any investment, arrangement or other association – whether on their own or through an immediate family or household member – which can interfere with the independent exercise of sound business judgment in the best interest of the Company, or otherwise represents a real or apparent conflict of interest between the interests of the employee and those of the Company.