During interactions with the investor community, the Company will ensure that no UPSI is disclosed selectively to any one or group of research analysts or investors to the disadvantage of other stakeholders. In the unlikely event of any UPSI being disclosed selectively, inadvertently or otherwise, at a meeting with analysts or at any investor relations conference, such UPSI would be promptly communicated to the Stock Exchanges where the Company’s securities are listed.

Material content of communication shared with analysts and at investor relations conferences will be put up on the Company’s corporate website either in the form of FAQs or in any other appropriate manner for general dissemination.

The Company will ensure that handling of all UPSI is on a need-to-know basis. UPSI may however be disclosed to persons who need such information for furtherance of legitimate purposes, performance of duties or discharge of legal obligations in relation to the Company.

The Chief Financial Officer of the Company shall act as the Chief Investor Relations Officer for the purpose of dealing with dissemination of information and disclosure of UPSI relating to the Company to the investors, analysts, press and electronic / social media.

The Code will be posted on the Company’s corporate website www.nclind.com

The Code is subject to review by the Board of Directors as and when deemed necessary.

A separate Code of Practices for regulating and monitoring the trading transactions by insiders who may possess Unpublished Price Sensitive Information titled “NCL Code of Practices in respect of Insider Trading” is available as an Annexure to, and forms an integral part of this Code.