Gem Spinners follows a strong Code of Business Conduct and Ethics for Directors/Senior management personnel of the company. The Code highlights areas of ethical risk provides guidance to directors/ senior management personnel on ethical issues offers mechanisms to report unethical conduct and helps foster a culture of honesty and accountability.

The Board or any person/committee authorized by the Board is authorized to handle any query or interpretation under the Code as well as waive compliance to it. The Director, Officer or employee seeking waiver of this code shall make full disclosure of the particular circumstances to the Board or the designated person/committee. Each Director/senior management personnel must comply with the letter and spirit of this Code.