Code of Ethics

Aaditi Group has adopted this Code of Ethics (this “Code”) to:

• encourage honest and ethical conduct, including fair dealing and the ethical handling of conflicts of interest;

• encourage full, fair, accurate, timely and understandable disclosure;

• encourage compliance with applicable laws and governmental rules and regulations;

• ensure the protection of the Company’s legitimate business interests, including corporate opportunities, assets and confidential information; and

• deter wrongdoing.

All directors, officers and employees of the Company are expected to be familiar with the Code and to adhere to those principles and procedures set forth in the Code.

The Group’s more detailed policies and procedures set forth in Aaditi Group Code of Business Conduct or other corporate codes or policies are separate requirements and are not part of this Code.