<DOCUMENT>
<TYPE>EX-99.3
<SEQUENCE>5
<FILENAME>f90667orexv99w3.txt
<DESCRIPTION>EXHIBIT 99.3
<TEXT>
<PAGE>
                                                                    EXHIBIT 99.3

CODE OF ETHICS FOR PRINCIPAL AND FINANCE OFFICERS:

1.    PREAMBLE:

Wipro's Promise:

"With utmost respect to HUMAN VALUES, we promise to serve our customer with
INTEGRITY, through INNOVATIVE, VALUE FOR MONEY Solutions, by APPLYING THOUGHT,
day after day."

Our promise is at the core of Corporate Governance Practice in Wipro. In the
Information Age, Information is the Key asset. As custodians of Information and
assets, the Code of Ethics for Principal Officer and Finance Professionals is
codified as under.

2.    APPLICABILITY:

The Code of Ethics applies to the Principal Officer and all the employees in
Finance Function in Wipro. The Principal Officer and all the employees in the
Finance Function are expected to abide by this code as well as other applicable
Wipro policies or guidelines. Any violation of Wipro Code of Ethics may result
in disciplinary action, up to and including immediate termination.

3.    WIPRO'S CODE OF ETHICS FOR PRINCIPAL OFFICER AND FINANCE PROFESSIONALS:

I. Principle of Professional & Personal Integrity:

      -     Act with honesty and integrity, avoiding actual or apparent
            conflicts of interest in personal and professional relationships.

      -     Confidential information acquired in the course of one's work will
            not be used for personal advantage.

      -     Achieve responsible use of and control over all assets and resources
            employed or entrusted.

II. Principle of Propriety & Relevance of Information:

      -     Provide all stakeholders with information that is accurate,
            complete, objective, relevant, timely and understandable.

      -     Respect the confidentiality of information acquired in the course of
            one's work except when authorized or otherwise legally obligated to
            disclose.

                                       1

<PAGE>
III. Principle of Compliance:

      -     Comply with rules and regulations of all Public Authorities in all
            the geographies in which Wipro operates.

IV. Principle of Role models of Highest Standards of Corporate Governance:

      -     Act in good faith, responsibly, with due care, competence and
            diligence, without misrepresenting material facts or allowing one's
            independent judgment to be subordinated.

      -     Share knowledge and maintain skills important and relevant to
            stakeholders' needs.

      -     Proactively promote and be an example of ethical behavior as a
            responsible partner among peers, in the work environment and the
            community.

                                       2

</TEXT>
</DOCUMENT>
