Each of the group's gardens are ISO 9002 compliant and adhere to stringent quality standards. Flourishing under the able guidance of the Groups' stewardship, production has almost doubled.

Talup Tea Estate

Hilika Tea Estate

Hokunguri Tea Estate

Khobong Tea Estate

Hapjan Tea Estate

Budlabeta Tea Estate

Kharjan Tea Estate

Pengaree Tea Estate

Budlapara Tea Estate

The company plans to invest in and explore the needs of the modern tea consumer. Plans for the production of instant, decaffeinated and organic teas are in the pipeline.
Through improved field management, infilling, rejuvenation, interplanting, drainage, better plucking techniques and a host of other state-of-the-art innovations, the company plans to increase production by 10%. Clonal plantations of 1500 hectares have been implemented to facilitate increased production. The focal point of the company in the future is to increase the yield of Organic and environmental friendly teas.

The Company's future objectives could be summed up as given below:

- Improvement of the quality of tea through technological advancements
- Greater realisation of the domestic market through increased per capita consumption
- Augment exports through competitive pricing and superlative quality

One of the largest factories in Assam is situated at the Hokunguri Tea Estate producing around 3 million kgs a year. Great emphasis is also being laid on the development of direct exports. Efforts have already established export links with UK, Germany, Iran, Pakistan and Russia. A tried and tested pioneer, the company plans to participate in the tea industry this century by endeavouring to attain perfection in quality tea making.

Code of Conduct

If we apply knowledge with faith, dedication and deep analysis, our actions become stronger. This will lead to success - Chanakya.

Apeejay Tea expects the highest possible ethical conduct from its Board Members and senior management personnel. ‘Senior Management’ shall mean personnel of the Company who are members of its core management team excluding Board of Directors and shall comprise of all members of management one level below the executive directors, including all functional heads.

This Code contains the policy guidelines and procedures adopted by the Board of Directors of the Company relating to legal and ethical standards for conducting Company’s business. Full compliance with this Code of Conduct by all concerned is mandatory.

The objective of the Code is to promote honest and ethical conduct and to disclose, in a transparent manner, the values in accordance with which the Company’s business will be conducted. Compliance with this Code is a condition of employment and service for Senior Management Personnel, and is meant to supplement the general Code of Conduct for all employees.

Code of Business Conduct and Corporate Governance

Our code has traditionally embodied rules regarding individual and peer responsibilities, as well as responsibilities to our employees, customers, suppliers, shareholders, the public and other stakeholders, and includes:

• Prohibiting conflicts of interest (including protecting corporate opportunities)
• Protecting Apeejay Tea's confidential and proprietary information, including that of our customers' and vendors'
• Treating Apeejay Tea's employees, customers, suppliers and competitors fairly
• Safeguarding and proper usage of company’s assets
• Compliance with laws, rules and regulations
• Encouraging the reporting of any unlawful or unethical behavior

Business Ethics

It is essential that we all keep an eye out for possible infringements of Apeejay Tea's business ethics-whether these infringements occur in dealings with the government or the private sector, and whether they occur because of oversight or intention. Apeejay Tea employees who have knowledge of possible violations should notify the Board. To assist employees in the day-to-day protection of our business ethics, we've compiled a list of some areas where breaches may occur:

Improper or excessive payments of any of the following:

• Questionable payments to agents, consultants, or professionals whose backgrounds haven't been adequately investigated, who have not signed contracts or letters of engagement, or whose association with Apeejay Tea would be embarrassing if exposed.
• Payroll related expenditures, bonuses, awards, and non-cash gifts given to or by Apeejay Tea employees without proper approval and adequate documentation.
• Payments made in cash or cheques drawn to Cash or Bearer or bank accounts/property titles not in Apeejay Tea's name.
• Transfers to or deposits in the bank account of an individual, rather than in the account of the company with which we are doing business.
• Billings made higher or lower than normal prices for fees, at a customer's request.
• Payments made for any purpose other than that described in supporting documents.
• Payments made to employees, customers or agencies that seem to deviate from normal business transactions.
• Any large, abnormal, unexplained, or individually approved contracts, or expenditures made without review of supporting documentation.
• Unusual transactions occurring with nonfunctional, inactive, or shell subsidiaries or undisclosed or unrecorded assets or liabilities.
• Use of unethical or questionable means to obtain information, including information about competitors, information concerning government acquisition plans, or any procurement decision or action.
• An employment, consulting, or business relationship between a Apeejay Tea employee and another company, especially in the same or related business.
• Frequent trading (buying and selling over short intervals) in Apeejay Tea stock or the stock of a company with which we do business.

These are examples of possible infringements that Apeejay Tea employees need to avoid. Employees should feel free to discuss any concerns about this policy with their managers or Company Secretary.

Good work environment

The Company’s vision is based on inspiring and unleashing creative potential in human assets of the Company. This is possible in an environment where we all respect the rights of those around us. In this direction, we endeavour to treat individuals in all aspects of employment solely on the basis of their abilities and qualifications irrespective of race, caste, creed, religion, age, disability, gender, sexual orientation, marital status or political affiliations.

Conflicts Of Interest

All concerned are expected to make or participate in business decisions and actions in the best interests of the company and not based on personal relationships or benefits. Conflicts of interest can compromise employees' business ethics. Each one of us is expected to apply sound judgment to avoid conflicts of interest that could negatively affect Apeejay Tea or its business. At Apeejay Tea, a conflict of interest is any activity that is inconsistent with or opposed to Apeejay Tea's interests, or gives the appearance of impropriety. All are expected to disclose to the Board any situations that may involve inappropriate or improper conflicts of interests affecting them personally or affecting other employees or those with whom company does business. Waivers of conflicts of interest involving executive officers require the approval of the Board of Directors or an appropriate committee. Members of the Board of Directors have a special responsibility because they are prominent individuals with substantial other responsibilities. To avoid conflicts of interest, Directors are expected to disclose to their fellow Directors any personal interest they may have in a transaction upon which the Board passes and to recluse themselves from participation in any decision in which there is a conflict between their personal interests and the interest of Apeejay Tea.

Interest in Other Businesses

All Directors and senior management personnel need the written consent of the Board of Directors before they engage in any other business activity, whether or not they benefit financially from them. The same approval is necessary where such a person wishes to have a financial interest in any business activity other than in a quoted or listed company. If he / she has already involved in such an activity or if he / she already has such a financial interest when he / she joins the Group, he / she will still need the same approval. Where such written approval has been given the employee is responsible for confirming that one copy is placed on their personnel file and that a second copy is deposited centrally with the designated company officer, that is, the Company Secretary.

Safety, Health and Environment

The Company’s vision envisages no compromise in its commitment to safety, health and responsible care for the environment. Health and safety of the people in and around our tea estates are of paramount importance to the Company. The Company is committed to environment protection, pollution control and maintenance of ecological balance. The Company shall maintain high standards of pollution control, environment protection and safety.

Company Facilities

No director, senior management and employee shall misuse Company’s facilities, except where such facilities have been provided for personal use either by policy or by specific permission. Even in their use for Company purposes, care shall be exercised to ensure that costs are reasonable and there is no wastage. Ostentation in Company’s expenditure shall be avoided.

Special Ethics Obligations

It is of critical importance that the Apeejay Tea's filings with all Regulatory Authorities be accurate and timely. Depending on their position with Apeejay Tea, employees may be called upon to provide information to assure that the Company's public reports are complete, fair and understandable. Apeejay Tea expects all of its personnel to take this responsibility very seriously and to provide prompt and accurate answers to inquiries related to the Company's public disclosure requirements. The Finance Department bears a special responsibility for promoting integrity throughout the organization, with responsibilities to stakeholders both inside and outside of the Apeejay Tea. The Chief Financial Controller and Finance Department personnel have a special role both to adhere to these principles themselves and also to ensure that a culture exists throughout the company as a whole that ensures fair and timely reporting of Apeejay Tea's financial results and condition.

The Chief Financial Controller, all members of Apeejay Tea's Finance Department, all members of Secretarial & Legal Department, Marketing Department, Purchase Department including members in all other areas of operation are bound by the following Code of Ethics, and by accepting the Code of Business Conduct, each agrees that he or she will:

• Act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships.
• Provide information that is accurate, complete, objective, relevant, timely and understandable to ensure full, fair, accurate, timely, and understandable disclosure in reports and documents that Apeejay Tea files with, or submits to, government agencies and in other public communications.
• Comply with rules and regulations of federal, state, provincial and local governments, and other appropriate private and public regulatory agencies.
• Act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing one's independent judgment to be subordinated.
• Respect the confidentiality of information acquired in the course of one's work except when authorized or otherwise legally obligated to disclose. Confidential information acquired in the course of one's work will not be used for personal advantage.
• Share knowledge and maintain skills important and relevant to stakeholder's needs.
• Proactively promote and be an example of ethical behavior as a responsible partner among peers, in the work environment and the community.
• Achieve responsible use of and control over all assets and resources employed or entrusted.
• Promptly report to the Manager of Internal Compliance and/or the Chairman of the Audit Committee any conduct that the individual believes to be a violation of law or business ethics or of any provision of the Code of Conduct, including any transaction or relationship that reasonably could be expected to give rise to such a conflict.
• Violations of this Code of Ethics, including failures to report potential violations by others, will be viewed as a severe disciplinary matter that may result in personnel action, including termination of employment.

Laws, Regulations And Government Related Activities

As an Indian company, Apeejay Tea is subject to laws and regulations in India. Violation of governing laws and regulations is both unethical and subjects Apeejay Tea to significant risk in the form of fines, penalties and damaged reputation. It is expected that each employee will comply with all applicable laws, regulations and corporate policies.

Insider Trading

If any member of the Board or an employee has any material, non-public information relating to Apeejay Tea or its business, it is Apeejay Tea's policy that such member or employee, or their family members, or any entities controlled by them or his/her family members, may not buy or sell the securities of Apeejay Tea or engage in any other action to take advantage of, or pass on to others, that information. Transactions that may be necessary or justifiable for independent reasons, including emergency expenditures and transactions planned before the employee learned the material information, are not exceptions. Even the appearance of an improper transaction must be avoided to prevent any potential prosecution of Apeejay Tea or the individual trader. Besides the obligation to refrain from trading while in possession of material, non-public information, employees are also prohibited from "tipping" others. The concept of unlawful tipping includes passing on information to friends or family members under circumstances that suggest that employees were trying to help them make a profit or avoid a loss. Besides being considered a form of insider trading, of course, tipping is also a serious breach of corporate confidentiality. For this reason, we should be careful and avoid discussing sensitive information in any place (for instance, at lunch, on public transportation, in elevators) where others may hear such information.Government Business

Apeejay Tea employees should understand that special requirements might apply when contracting with any government body (including national, state, provincial, municipal, or other similar government divisions in local jurisdictions). Because government officials are obligated to follow specific codes of conduct and laws, special care must be taken in government procurement. Some key requirements for doing business with a government are:

• Accurately representing which Apeejay Tea products are covered by government contracts.
• Not offering or accepting kickbacks, bribes, gifts, gratuities or anything else of value with the intent of obtaining favorable treatment from the recipient (a gift that is customary in the business sector may be perceived as a bribe by a government official).
• Not improperly soliciting or obtaining confidential information.

Political Contributions

No Apeejay Tea assets including employees' work time, use of premises, equipments, or direct monetary payments may be contributed to any political candidate, political actions committees, party, or ballot measure without the permission of the Board. Of course, Apeejay Tea employees may participate in any political activities of their choice on an individual basis, with their own money and on their own time.

Using Third-Party Copyrighted Material

Employees may sometimes need to use third-party copyrighted material to perform their jobs. Before such third-party material may be used, appropriate authorization from the copyright holder must be obtained, with the exception of material for which Apeejay Tea holds the copyright. The need for such permission may exist whether or not the end product containing third-party material is for personal use, for Apeejay Tea internal or other use. It is against Apeejay Tea’s policy and it may be unlawful for any employee to copy, reproduce, scan, digitize, broadcast, or modify third party copyrighted material when developing its products, promotional materials or written communications (such as manuals, presentations, etc.) or software unless prior written permission from the concerned has been obtained. Improper use could subject both Apeejay Tea and the individuals involved to possible civil and criminal actions for copyright infringement.

Confidentiality

Information about the Group, which is not publicly available, must be handled with discretion and must not be given to others unless they are employees who need to know it in order to do their job or are third parties who are authorised to receive it. Except for our professional advisers, confidential information should normally only be disclosed where an agreement is in place under which the recipient agrees to preserve the confidentiality of the information. Among other things, any unauthorised disclosure could place the Company at an actual or potential commercial disadvantage, may result in the summary dismissal or other disciplining of the individual concerned and could constitute a serious breach of the criminal law.

Amendments and waivers to the Code

The Board may, from time to time, amend or waive certain provisions of this Code depending on the legal and other requirements or for a bona fide purpose. Every member of the Board and Senior Management, including the new recruits will be required to confirm their compliance of with this Code in writing on an annual basis. A copy of the Code will be posted on the website of the Company. This code may, from time to time be extended to other senior officers of the company, as the Board may think fit.