Anti-Bribery & Anti-Corruption Policy
Company Name: Mahavir Bullion & Refinery Private Limited
Policy Title: Anti-Bribery & Anti-Corruption Policy
Effective Date: 01-09-2025
Approved By: Board of Directors
Policy Title: Anti-Bribery & Anti-Corruption Policy
Effective Date: 01-09-2025
Approved By: Board of Directors
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1. Introduction
Mahavir Bullion & Refinery Private Limited (“MBRPL” or “the Company”) conducts its business with integrity, transparency, and accountability. Bribery and corruption undermine ethical business conduct, distort markets, and expose organisations to significant financial, operational, and legal risks.
This Policy establishes MBRPL’s zero-tolerance approach to bribery, corruption, facilitation payments, kickbacks, and all forms of improper advantages. It aligns with:
• RJC COP 2019 – COP 3: Bribery & Facilitation Payments
• Prevention of Corruption Act, 1988
• Prevention of Money Laundering Act (PMLA), 2002
• FATF recommendations
• OECD Anti-Bribery Convention
• Industry best practices for gold refinement & bullion trade
All directors, employees, suppliers, intermediaries, logistics partners, visitors, and any persons acting on behalf of the Company must comply with this Policy. -
2. Purpose of the Policy
The purpose of this Policy is to:
• Prevent MBRPL from being involved in bribery or corruption directly or indirectly.
• Provide clear expectations on acceptable and unacceptable conduct.
• Establish internal controls, procedures, and reporting mechanisms.
• Ensure compliance with RJC COP and relevant Indian laws.
• Protect the Company from reputational, financial, regulatory, and criminal consequences.
• Promote ethical decision-making and accountability across all operations. -
3. Scope
This Policy applies to:
• All employees of MBRPL (permanent, temporary, contractual, trainee, outsourced)
• Directors, senior management, and department heads
• Agents, brokers, job-workers & contractors
• Security staff, logistics partners, transport agencies
• Third-party intermediaries & consultants
• Suppliers, aggregators, miners, and scrap dealers
• Customers and trading partners
This Policy applies to all business activities, including procurement, refining, logistics, marketing, sales, finance, licensing, documentation, regulatory interactions, and third-party engagement. -
4. Definition of Bribery & Corruption
Bribery is the offering, promising, giving, requesting, agreeing to receive, or accepting anything of value intended to:
• Influence a decision
• Secure an improper advantage
• Obtain or retain business
• Manipulate a regulatory, financial, or commercial outcome
Bribes may include:
• Cash or cash equivalents
• Gifts, hospitality, entertainment
• Discounts, credit, or favourable pricing
• Free services or benefits
• Political contributions
• Personal favours
• Undisclosed commissions or kickbacks
• Over-invoicing or under-invoicing
• Payments disguised as “consultancy fees” or “facilitation charges”
Corruption includes abuse of entrusted authority for private gain. -
5. Policy Statement - Zero Tolerance (COP 3.1)
MBRPL strictly prohibits:
• Offering, paying, or accepting bribes
• Extortion or solicitation
• Undisclosed commissions or kickbacks
• “Speed money” or facilitation payments
• Payments to influence regulators, customs, DGFT, police, BIS, or any public authority
• Manipulating assay results or refinery output figures
• Over/under invoicing to conceal illegal payments
• Bribes disguised as gifts, hospitality, travel, sponsorships
• Engaging intermediaries to perform bribery on behalf of the Company
Violations will result in disciplinary action, termination, and legal reporting. -
6. Prohibition of Facilitation Payment (COP 3.2)
Facilitation payments are small payments made to secure or expedite routine government actions such as:
• Clearing goods at Customs
• Obtaining permits or licenses
• Routine inspections
• Utility connections
MBRPL prohibits all facilitation payments, regardless of local customs or expectations. Exception — Life or Safety Risk
If an employee is compelled to make a payment under threat to personal safety:
• The employee must immediately report the incident to their Manager and Compliance Officer.
• The incident must be documented and investigated. -
7. Gifts, Hospitality & Entertainment
Gifts or hospitality must never be given or accepted:
• To influence a business decision
• During tendering, supplier evaluation, or contract negotiation
• From or to government officials
• If they involve cash or gift cards
Permitted (with restrictions):
• Low-value, culturally appropriate gifts (e.g., sweets during festivals)
• Modest business meals or light refreshments
• Branded company merchandise
Prohibited:
• Expensive gifts
• Travel packages or hotel stays
• Entertainment or events unrelated to business
• Personal services
All gifts received must be declared in the Gift Register maintained by the Compliance Department. -
8. Roles & Responsibilities (COP 36–41)
8.1 Board of Directors
• Oversees the integrity and effectiveness of anti-bribery controls.
• Approves this Policy and reviews annual compliance reports.
8.2 Senior Management
• Implements systems to prevent bribery and corruption.
• Ensures adequate resources and training.
8.3 Compliance Officer
• Oversees adherence to this Policy.
• Conducts investigations into bribery allegations.
• Maintains registers for gifts, hospitality, and conflict of interest.
8.4 All Employees
• Must not engage in or tolerate bribery.
• Must report suspected violations immediately. -
9. Third-Party Intermediaries (COP 3.3)
Third parties may include:
• Customs brokers
• Consultants
• Logistics agents
• Introducers
• Gold aggregators
• Government liaison personnel
MBRPL conducts Enhanced Due Diligence on third parties, including:
• Business justification
• Beneficial ownership verification
• Conflict of interest checks
• Sanctions/adverse media screening
• Background verification
No third party may be engaged without a written agreement containing anti-bribery clauses. -
10. Procurement & Supplier Controls (COP 7 & 28–30)
Suppliers must:
• Provide complete KYC/KYB documentation
• Sign Responsible Sourcing Declarations
• Agree to audits and assessments
• Maintain transparent pricing and invoicing
• Not engage in bribery, manipulation, forged documentation, or illegal mining
The Company may terminate a supplier relationship if any violation is identified. -
11. Red Flags (COP 3.4 & OECD ANNEX II)
Examples include:
11.1 Transaction Red Flags
• Unusual discounts or inflated prices
• Requests for off-the-books payments
• Payments routed through unrelated third parties
• Assay manipulation requests
• Pressure to expedite payments without documentation
11.2 Behavioural Red Flags
• Supplier unwilling to sign anti-bribery clauses
• Attempts to bypass internal controls
• Excessive hospitality or gifts offered
11.3 Government Interaction Red Flags
• Requests to pay unofficial “fees”
• Redirected payments
• Officials insisting on using a specific agent
Any red flag requires immediate escalation. -
12. Reporting & Whistleblowing (COP 41)
Employees may report concerns through:
• Compliance Officer
• Internal email (designated)
• Confidential written complaint
Whistleblowers are protected against retaliation, harassment, or adverse employment consequences. -
13. INVESTIGATION PROCEDURE
When a bribery allegation is reported:
• Compliance Officer conducts preliminary assessment.
• If credible, a formal investigation is initiated.
• Evidence is collected confidentially.
• Relevant employees or suppliers may be suspended during investigation.
• Findings are reviewed by Senior Management.
• Corrective and disciplinary actions are implemented.
If necessary, matters may be reported to statutory authorities. -
14. Disciplinary Action
May include:
• Written warning
• Suspension
• Demotion
• Termination
• Supplier blacklisting
• Legal prosecution under PMLA or Prevention of Corruption Act -
15. Training & Awareness (COP 38)
Training includes:
• Annual mandatory anti-bribery training
• Role-specific sessions for procurement, logistics, and compliance teams
• Case studies of real bribery scenarios
• Monitoring of training effectiveness
New employees receive induction training on this Policy. -
16. DOCUMENTATION & RECORD KEEPING (COP 40)
Records maintained for 10 years:
• Gifts & hospitality registers
• Conflict of interest declarations
• Supplier due diligence files
• Investigation reports
• Training attendance logs
• Audit reports
• Contractual agreements -
17. AUDIT & REVIEW (COP 39–41)
Internal audits evaluate:
• Effectiveness of anti-bribery controls
• Adequacy of documentation
• Compliance with RJC COP and Indian regulations
• Corrective action implementation
Findings are reported to Senior Management and the Board.
This Policy is upon:
• RJC COP updates
• Regulatory changes
• New operational risks
• Any findings
PURPOSE
The Anti-Bribery Policy (“Policy”) emphasizes Mahavir Bullion & Refinery Private Limited’s (hereinafter referred to as “MBR/Company”) zero-tolerance approach to bribery and corruption. It establishes the principles with respect to applicable anti-bribery and anti-corruption laws. The policy provides information and guidance on how to recognise and deal with bribery and corruption issues. It guides us to act professionally, fairly and with utmost integrity in all our business dealings and relationships, wherever we operate.
POLICY STATEMENT
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
It is our policy to conduct our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in all jurisdictions in which we operate.
It is our policy to conduct our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in all jurisdictions in which we operate.
SCOPE
The principles set forth in this policy are applicable to all directors, officers, employees, consultants, contractors, associates and business partners of the company. It is, therefore, the responsibility of all to follow and adhere to all elements described in the policy. In countries where there are more stringent applicable laws, regulations or industry codes, MBR requires compliance with the most restrictive requirement, and the principles set out in this policy shall be superseded in those specific countries.
ANTI-BRIBERY AND CORRUPTION STANDARDS
It is prohibited for the company or its directors, officers, employees, consultants, business partners or contractors to:
a) Give, promise to give, or offer a payment, gift or hospitality to a third party or otherwise engage in or permit a bribery offence to occur, with the expectation or hope that an advantage in business will be received, or to reward a business advantage already given.
b) Give, promise to give, or offer a payment, gift, or hospitality to a third party to "facilitate" or expedite a routine procedure.
c) Accept a payment, gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by the company in return.
d) Threaten or retaliate against another employee or worker who has refused to commit a bribery offence or who has raised concerns under this Policy or the company’s whistleblower policy.
e) Engage in any activity that might lead to a breach of this Policy.
a) Give, promise to give, or offer a payment, gift or hospitality to a third party or otherwise engage in or permit a bribery offence to occur, with the expectation or hope that an advantage in business will be received, or to reward a business advantage already given.
b) Give, promise to give, or offer a payment, gift, or hospitality to a third party to "facilitate" or expedite a routine procedure.
c) Accept a payment, gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by the company in return.
d) Threaten or retaliate against another employee or worker who has refused to commit a bribery offence or who has raised concerns under this Policy or the company’s whistleblower policy.
e) Engage in any activity that might lead to a breach of this Policy.
GIFTS, HOSPITALITY AND ENTERTAINMENT
a) MBR acknowledges that exchange of nominal gifts and sharing of entertainment is customary in many parts of the world during national, cultural and religious occasions.
b) The giving or receipt of gifts by Associates is not prohibited, if following requirements are met:
- No quid pro quo – There must always be a legitimate business purpose to support gifts related expenses. Customary gifts, meals, entertainment, travel or lodging may never be given or received in return for a favour/ favourable treatment or to refrain from doing something disadvantaging Company.
- It complies with all applicable Anti-bribery and Anti-corruption laws;
- It does not include cash or a cash equivalent (such as gift certificates or vouchers);
- Considering, the reason and nature of the gift, it is of an appropriate type and value and given at an appropriate time;
- It is given openly, not secretly.
c) MBR appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
b) The giving or receipt of gifts by Associates is not prohibited, if following requirements are met:
- No quid pro quo – There must always be a legitimate business purpose to support gifts related expenses. Customary gifts, meals, entertainment, travel or lodging may never be given or received in return for a favour/ favourable treatment or to refrain from doing something disadvantaging Company.
- It complies with all applicable Anti-bribery and Anti-corruption laws;
- It does not include cash or a cash equivalent (such as gift certificates or vouchers);
- Considering, the reason and nature of the gift, it is of an appropriate type and value and given at an appropriate time;
- It is given openly, not secretly.
c) MBR appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
FACILITATION PAYMENTS AND KICKBACKS
Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low-level officials to obtain a level of service that one would normally be entitled to.
MBR’s strict policy is that facilitation payments must not be paid. MBR recognizes, however, that its employees may be faced with situations where there is a risk to the personal security of an employee or his/her family and where a facilitation payment is unavoidable, in which case the following steps must be taken:
- Keep any amount to the minimum;
- Create a record concerning the payment; and
- Report it to your manager.
In order to achieve our aim of not making any facilitation payments, each business of the company will keep a record of all payments made, which must be reported to the management in order to evaluate the business risk and to develop a strategy to minimize such payments in the future.
MBR’s strict policy is that facilitation payments must not be paid. MBR recognizes, however, that its employees may be faced with situations where there is a risk to the personal security of an employee or his/her family and where a facilitation payment is unavoidable, in which case the following steps must be taken:
- Keep any amount to the minimum;
- Create a record concerning the payment; and
- Report it to your manager.
In order to achieve our aim of not making any facilitation payments, each business of the company will keep a record of all payments made, which must be reported to the management in order to evaluate the business risk and to develop a strategy to minimize such payments in the future.
POLITICAL CONTRIBUTIONS
MBR do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.
CHARITABLE CONTRIBUTIONS
Charitable support and donations are acceptable (and indeed are encouraged), whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. MBR only does charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Management.
RECORD-KEEPING
MBR maintains financial records and has appropriate internal controls in place, which will evidence the business reason for making payments to third parties. MBR maintains a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review. All expense claims relating to hospitality, gifts, or expenses incurred to third parties are submitted in accordance with the company’s expenses policy and specifically record the reason for the expenditure. All accounts, invoices, memoranda, and other documents and records relating to dealings with third parties, such as clients, suppliers, and business contacts, should be prepared and maintained with strict accuracy and completeness. MBR ensures that no accounts are kept "off-book" to facilitate or conceal improper payments.
RAISING A CONCERN AND PROTECTION
a) All MBR associates are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If they are unsure whether a particular act constitutes bribery or corruption, or if they have any other queries, these should be raised with the manager.
b) An associate who refuses to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. MBR aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
c) MBR will ensure that no one will suffer any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
b) An associate who refuses to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. MBR aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
c) MBR will ensure that no one will suffer any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
TRAINING AND COMMUNICATION
Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept conformance to this policy on an annual basis. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, customers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
MONITORING AND REVIEW
The Board of Directors shall monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Board of Directors. This policy does not form part of any employee's contract of employment and it may be amended at any time.
