Grievance Redressal Policy – RJC COP 2024
- 1. Document Control
| Company Name | Mahavir Bullion & Refinery Private Limited | Policy No. | MBR/SRAMP/02 |
| Policy Title | Grievance Redressal Policy | Revision Date | 01/04/2026 |
| Effective Date | 01/04/2025 | Review Date | 01/04/2027 |
| Approved By | Board of Directors | Approval Date | 23/03/2026 |
| Policy Owner | Compliance Officer / Senior Management | Classification | Controlled Document |
| Applicable Standard | RJC COP 2024 | Next Review | Annually |
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2. Introduction
Mahavir Bullion & Refinery Private Limited (“MBRPL” or the “Company”) is committed to providing a legitimate, accessible and fair mechanism through which employees, workers, customers, suppliers, business partners, contractors, visitors, communities and other relevant stakeholders can raise concerns, complaints, requests for information or grievances connected with the Company’s activities. -
3. Purpose
• Provide a clear and accessible process for raising, receiving, assessing, investigating, resolving and closing grievances.
• Ensure grievances are handled fairly, respectfully, consistently and without retaliation.
• Provide timely acknowledgement, investigation, response and resolution, subject to the nature and complexity of the matter.
• Protect confidentiality and anonymity where requested and reasonably possible.
• Identify root causes and implement corrective actions to prevent recurrence.
• Provide appropriate escalation routes and preserve the right of a complainant to use available external remedies. -
4. Scope
This Policy applies to:
• All permanent, temporary, contractual, trainee and outsourced workers.
• Directors, management and supervisors.
• Customers, suppliers, business partners, contractors, job-workers, agents, service providers and transporters.
• Visitors and other persons interacting with the Company.
• Relevant affected stakeholders and communities where the grievance relates to Company activities. - 5. RJC COP 2024 Requirements Addressed
| RJC Provision | Requirement / Expectation | Policy Control |
|---|---|---|
| COP 2.6 | Legitimate, rights-compatible complaints and grievance mechanism; accessible, communicated, understandable, unbiased, predictable and transparent. | Formal channels, responsible officers, escalation, communication, investigation, resolution and records. |
| COP 2.6(f) | Avoid retaliation; train personnel; timely response/investigation; preserve external remedies; protect confidentiality; review remedies and corrective action. | Non-retaliation, training, case handling, escalation, confidential records and CAPA. |
| COP 2.7a | Monitor and review grievance mechanism performance and implement corrective action where gaps are identified. | Periodic review, trend analysis, effectiveness assessment and CAPA. |
| COP 18.5 | Communicate the mechanism to workers, ensure freedom from penalty/retaliation and allow a workers’ representative if requested. | Worker communication, non-retaliation and representative involvement. |
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6. Grievance Principles
• Accessibility – channels shall be reasonably easy to use and communicated to relevant stakeholders.
• Legitimacy and rights compatibility – the mechanism shall respect applicable human rights and legal requirements.
• Fairness and impartiality – complaints shall be assessed and handled without bias or conflict of interest.
• Confidentiality – information shall be restricted to persons with a legitimate need to know.
• Anonymity – anonymous complaints shall be accepted where reasonably possible and shall be assessed on the information available. • Non-retaliation – no person shall be penalised, threatened, discriminated against or otherwise retaliated against for raising a grievance in good faith or participating in its handling.
• Predictability and transparency – the complainant shall be informed of the process and status as appropriate.
• Timeliness – cases shall be acknowledged, investigated and resolved within reasonable timeframes appropriate to their seriousness and complexity.
• Continuous improvement – trends, root causes, remedies and corrective actions shall be reviewed to reduce recurrence. -
7. Types of Grievances Covered
• Workplace treatment, harassment, discrimination, dignity and respect.
• Employment terms, working conditions, wages, working hours and workplace facilities.
• Health, safety and environmental concerns.
• Human rights concerns, including potential adverse impacts linked to Company operations or business relationships.
• Responsible sourcing, supply-chain due diligence and business-partner concerns.
• Bribery, corruption, fraud, conflicts of interest or other unethical conduct, subject to the Whistleblower / Anti-Bribery channels.
• Customer or stakeholder complaints relating to Company services, products, communication or conduct.
• Security-related concerns and inappropriate treatment by security personnel.
• Other concerns relating to the Company’s policies, practices or impacts. -
8. Grievance Channels
The Company’s existing Policy provides for telephone, email and written complaints. The current contact details include the Company address and a generic email address. These details are retained as placeholders where appropriate for controlled finalisation.
| Channel | Details | Availability / Notes |
|---|---|---|
| Telephone / Helpline | +91-84216 27321 | Available during working hours; grievances are received and handled confidentially by authorized personnel |
| connect@mbrpvt.com | Monitored by authorised personnel | |
| Written complaint | W-154-MIDC, TTC Industrial Area, Thane Belapur Road, Pawane, Opp. Krishana Steel, Navi Mumbai, Thane – 400614 | Written submissions accepted |
| In-person / supervisor route | Employees may raise grievances directly with their immediate Supervisor / Department Head / HR Representative. | Available during working hours; grievances shall be treated confidentially and handled through the grievance redressal process. |
- 9. Grievance Handling Procedure
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9.1 Receipt and Registration
1. Receive the complaint through any approved channel.
2. Record the date, source, subject, relevant persons, location and available supporting information.
3. Assign a unique grievance reference number.
4. Acknowledge receipt to the complainant where contact details are available.
5. Where the complaint is anonymous, record and assess the available information without attempting to identify the complainant unless legally required. -
9.2 Screening and Classification
6. Determine whether the matter falls within this Policy or should be routed to another controlled mechanism.
7. Assess urgency, severity, potential human-rights impact, health and safety risk, legal/regulatory exposure and potential conflicts of interest.
8. Immediately escalate serious matters requiring urgent protection, legal intervention or senior management attention.
9. Where another specialist process applies, such as POSH, AML/CFT, anti-bribery or whistleblowing, transfer or coordinate the case in accordance with the relevant controlled procedure while preserving confidentiality. -
9.3 Investigation
10. Investigations shall be conducted by appropriately authorised and trained personnel.
11. The investigator shall be impartial and shall not handle a matter where there is a material conflict of interest.
12. Relevant documents, records, interviews and other evidence shall be reviewed.
13. Both the complainant and relevant persons shall be treated fairly and respectfully.
14. Information shall be shared only on a need-to-know basis, subject to law and investigation requirements. -
9.4 Response and Resolution
15. The Company shall provide a timely response appropriate to the nature and complexity of the grievance.
16. Where appropriate, the complainant shall be informed of the outcome and relevant remedial action, subject to confidentiality, privacy and legal limitations.
17. Where a grievance is substantiated, appropriate corrective, preventive or remedial action shall be identified, assigned and tracked to closure.
18. Where a grievance cannot be substantiated, the case shall still be documented with the basis for the conclusion. -
9.5 Escalation / Appeal
19. A complainant who is dissatisfied with the response may request review by a designated senior authority.
20. Serious or unresolved matters shall be escalated to Senior Management and, where appropriate, the Board or another authorised governance body.
21. Use of the Company grievance mechanism shall not remove or prevent an individual’s right to use available administrative, judicial or other non-judicial external remedies.
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10. Protection Against Retaliation
The Company shall not tolerate retaliation against any person who raises a grievance in good faith, provides information, participates in an investigation or assists another person in accessing the grievance mechanism. Retaliation may include threats, dismissal, adverse treatment, discrimination, intimidation, harassment or other detrimental action.
Any allegation of retaliation shall itself be treated as a grievance and investigated promptly. -
11. Confidentiality and Anonymity
• Grievance records shall be maintained securely with access restricted to authorised personnel.
• The identity of complainants and witnesses shall be protected to the extent reasonably possible.
• Where anonymity has been requested, information shall be handled in a manner that protects the person’s identity unless disclosure is required by law.
• Confidentiality shall not prevent lawful reporting to competent authorities where required. - 12. Roles and Responsibilities
| Role | Responsibility |
|---|---|
| Board / Senior Management | Approve the mechanism, provide oversight, review significant trends and ensure adequate resources. |
| Compliance Officer / Grievance Owner | Maintain the mechanism, oversee case handling, escalation, records, trend analysis and effectiveness review. |
| HR / Management | Receive and support worker grievances, ensure fair treatment and coordinate investigations where appropriate. |
| Investigators | Conduct impartial, confidential and documented investigations. |
| Supervisors / Managers | Respectfully receive concerns, avoid retaliation and promptly escalate matters. |
| Workers / Stakeholders | Provide information in good faith and cooperate with investigations where appropriate. |
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13. Training and Awareness
• Relevant employees shall receive induction and periodic training on the grievance mechanism.
• Training shall cover available channels, confidentiality, non-retaliation, respectful handling, escalation and the role of workers’ representatives.
• Managers and personnel responsible for receiving or investigating grievances shall receive role-appropriate training.
• Records of training and attendance shall be maintained. -
14. Records and Record Retention
• Grievance register / case log.
• Complaint or grievance received and supporting documents.
• Acknowledgement and communication records.
• Investigation notes, evidence and findings.
• Outcome / resolution and remedial action records.
• Corrective and preventive action tracking.
• Appeal / escalation records.
• Training and awareness records.
RJC COP 2.5 requires records covering applicable COP requirements to be retained for at least five years or longer where national legislation requires. -
15. Monitoring, Effectiveness and Corrective Action
• The Company shall periodically review grievance volumes, categories, response times, outcomes, recurring issues and corrective actions.
• Management shall assess whether the grievance mechanism is accessible, trusted and effective.
• Where gaps are identified, corrective actions shall be assigned, monitored and tracked to closure.
• Significant trends and unresolved high-risk matters shall be escalated to Senior Management and, where appropriate, the Board. -
16. Cross-Reference with Other Reporting Mechanisms
To avoid confusion between reporting channels, the following routing shall apply:
| Concern Type | Primary Mechanism | Cross-Reference |
|---|---|---|
| Sexual harassment | POSH Policy / Internal Committee | POSH Policy |
| Bribery / corruption / prohibited facilitation payments | Anti-Bribery & Anti-Corruption Policy / Whistleblower mechanism | Anti-Bribery Policy; Whistleblower Policy |
| AML/CFT suspicious activity | AML/CFT escalation and reporting process | AML/CFT Policy |
| Responsible sourcing / supply-chain concerns | Responsible Gold, Silver & PGM Sourcing Policy / grievance route | Responsible Sourcing Policy |
| Human rights concerns | Grievance Redressal Policy / Human Rights Policy | Human Rights Policy |
| General workplace or stakeholder grievance | Grievance Redressal Policy | This Policy |
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17. Policy Communication
• This Policy shall be communicated to relevant employees and workers, including new workers at recruitment/induction.
• Relevant external stakeholders shall be informed of the available grievance channels where appropriate.
• The Policy and appropriate grievance contact information shall be made accessible to relevant stakeholders, including through workplace displays and the Company website where applicable.
• Information shall be communicated in a language and format reasonably understandable to the intended users. -
18. Policy Review and Approval
This Policy shall be reviewed at least once every 12 months and additionally when there are changes in law, RJC requirements, business activities, stakeholder expectations, grievance trends, significant incidents, audit findings or identified weaknesses in the mechanism. RJC COP 2.7a requires monitoring and review of grievance mechanism performance and corrective action where gaps are identified, while COP 2.7b requires top management review at least annually.
Changes shall be documented through the Company’s document-control process and approved by the Board or other authorised approving body. -
19. Related Controlled Documents
• Human Rights Policy.
• Whistleblower Policy.
• Anti-Bribery & Anti-Corruption Policy.
• AML/CFT Policy.
• Supply Chain Policy.
• Non-Discrimination Policy.
• POSH Policy.
• Health & Safety Risk Assessment Policy.
• Risk Mitigation Plan. - For Mahavir Bullion & Refinery Private Limited
| Prepared By | Reviewed & Approved By |
|---|---|
| Compliance Officer | Director |
| Rushikesh Rajendra Deshmukh | Jitendra Panditrao Deshmukh |
Grievance Redressal Policy
Company Name: Mahavir Bullion & Refinery Private Limited
Policy Title: Anti-Money Laundering & Counter-Terrorist Financing Policy
Effective Date: 01-09-2025
Approved By: Board of Directors
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1. Introduction
Mahavir Bullion & Refinery Private Limited (hereinafter referred to as “Company”) believes that providing prompt and efficient customer service is essential to retaining existing relationships as well as a key factor in sustaining business growth. Addressing customer complaints is a cornerstone of good customer service. Our endeavor is to minimize complaints and grievances through regular review of the instances and proactive redressal of the same. This policy details complaint handling through a structured grievance redressal framework including a review mechanism to minimize such issues in future. -
2. Key Commitments
The purpose of this Policy is to ensure that:
• all customers / stakeholders are treated fairly and in a courteous manner at all times;
• all complaints raised by customers / stakeholders are handled promptly and effectively in the promised timeline;
• There are clear and well-established channels to escalate complaints, concerns and grievances and customers / stakeholders have the right to utilize this escalation channel if they are not satisfied with the resolution of their complaints;
• all employees act in good faith, without prejudice to the interest of the customers / stakeholders and within the policies of the Company; and
• customers / stakeholders are fully informed about the different channels to escalate their grievances.
Regardless of the reason behind the grievance our stakeholders have complete authority to file complaint/ share feedback if they are disappointed with their experience with the Company. They can give their complaint/ feedback in writing or via email.
If a grievance is not resolved within the given time or if the solution is not satisfactory, our customers / stakeholders can approach our tiered redressal system with their complaint. -
3. Grievance redressal mechanism
a) Registration of complaints:
Customers / stakeholders who wish to register their complaints or provide feedback may use either of the following channels:
• Call Centre: Call the Customer Service Helpline at 8421627321 from 9:30 am and 18:00 Monday – Friday, except on public holidays.
• Electronic mail: E-mail the Company at mahavirbullion18@gmail.com
• Write to address below: W-154-MIDC, TTC Industrial Area, Thane Belapur Road, Pawane, Opp. Krishana Steel, Navi Mumbai, Thane – 400614
b) Addressing of Complaints:
In case the complaint is not resolved or if the customer / stakeholder is not satisfied with the resolution provided by the Company, the customer / stakeholder can contact the Grievance Redressal Officer. The name and contact number of the Grievance Redressal Officer are as follows:
Name: Mr. rushikesh rajendra deshmukh
Contact No.: +91 9960794011
Email id: connect@mbrpvt.com -
4. Employee Training & Awareness
On an ongoing basis, the Company will conduct training programs for staff on customer service best practices with a focus on minimizing grievances. Included in this training will be a review of past customer complaints, resolutions to those complaints and an open discussion on how to best prevent such complaints in the future. Top reasons behind the consumer queries are analysed and worked upon in a way which aims at removal of these reasons from the root. -
5. Communication
Company shall communicate the Policy to all its customers / stakeholders and employees. The Policy shall also be hosted on the website of the Company. The Company shall as and when required update the policy and communicate the same to all its customers and employees. -
6. Policy review
The Board of Directors shall periodically review the policy or on a need-basis i.e., in the event of change in regulatory framework or for business or operational need. Such updates / changes to the policy will be communicated to the relevant staff / relevant stakeholders.
शिकायत निवारण नीति
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1. परिचय
महावीर बुलियन एंड रिफाइनरी प्राइवेट लिमिटेड (जिसे आगे "कंपनी" के रूप में संदर्भित किया जाएगा) का मानना है कि मौजूदा संबंधों को बनाए रखने के साथ-साथ व्यवसाय विकास को बनाए रखने के लिए त्वरित और कुशल ग्राहक सेवा प्रदान करना आवश्यक है। ग्राहक शिकायतों का समाधान करना अच्छी ग्राहक सेवा की आधारशिला है। हमारा प्रयास मामलों की नियमित समीक्षा और उनके सक्रिय निवारण के माध्यम से शिकायतों और शिकायतों को कम करना है। यह नीति भविष्य में ऐसे मुद्दों को कम करने के लिए समीक्षा तंत्र सहित संरचित शिकायत निवारण ढांचे के माध्यम से शिकायत से निपटने का विवरण देती है। -
2. प्रमुख प्रतिबद्धताएँ
इस नीति का उद्देश्य यह सुनिश्चित करना है कि:
• सभी ग्राहकों / हितधारकों के साथ हर समय निष्पक्ष और विनम्र तरीके से व्यवहार किया जाए;
• ग्राहकों / हितधारकों द्वारा उठाई गई सभी शिकायतों को वादा किए गए समय-सीमा में तुरंत और प्रभावी ढंग से निपटाया जाए;
• शिकायतों, चिंताओं और शिकायतों को आगे बढ़ाने के लिए स्पष्ट और सुस्थापित चैनल हैं और ग्राहकों/हितधारकों को इस वृद्धि चैनल का उपयोग करने का अधिकार है यदि वे अपनी शिकायतों के समाधान से संतुष्ट नहीं हैं;
• सभी कर्मचारी ग्राहकों/हितधारकों के हितों के प्रति पूर्वाग्रह के बिना और कंपनी की नीतियों के भीतर सद्भावनापूर्वक कार्य करते हैं; और
• ग्राहकों/हितधारकों को उनकी शिकायतों को आगे बढ़ाने के लिए विभिन्न चैनलों के बारे में पूरी जानकारी है।
शिकायत के पीछे का कारण चाहे जो भी हो, हमारे हितधारकों को कंपनी के साथ अपने अनुभव से निराश होने पर शिकायत दर्ज करने/प्रतिक्रिया साझा करने का पूरा अधिकार है। वे अपनी शिकायत/प्रतिक्रिया लिखित रूप में या ईमेल के माध्यम से दे सकते हैं।
यदि किसी शिकायत का समाधान दिए गए समय के भीतर नहीं होता है या यदि समाधान संतोषजनक नहीं है, तो हमारे ग्राहक/हितधारक अपनी शिकायत के साथ हमारी स्तरीय निवारण प्रणाली से संपर्क कर सकते हैं। -
3. शिकायतों का पंजीकरण
a) शिकायतों का पंजीकरण:
ग्राहक/हितधारक जो अपनी शिकायतें दर्ज करना चाहते हैं या प्रतिक्रिया देना चाहते हैं, वे निम्नलिखित में से किसी भी चैनल का उपयोग कर सकते हैं:
• कॉल सेंटर: सार्वजनिक छुट्टियों को छोड़कर, सोमवार से शुक्रवार सुबह 9:30 बजे और शाम 6:00 बजे 8421627321 पर ग्राहक सेवा हेल्पलाइन पर कॉल करें।
• इलेक्ट्रॉनिक मेल: कंपनी को mahavirbullion18@gmail.com पर ईमेल करें
• नीचे दिए गए पते पर लिखें: W-154-MIDC, TTC औद्योगिक क्षेत्र, ठाणे बेलापुर रोड, पवने, कृष्णा स्टील के सामने, नवी मुंबई, ठाणे - 400614
b) शिकायतों का समाधान:
यदि शिकायत का समाधान नहीं होता है या यदि ग्राहक/हितधारक कंपनी द्वारा प्रदान किए गए समाधान से संतुष्ट नहीं है, तो ग्राहक/हितधारक शिकायत निवारण अधिकारी से संपर्क कर सकता है। शिकायत निवारण अधिकारी का नाम और संपर्क नंबर इस प्रकार है:
नाम: श्री. ऋषिकेश राजेंद्र देशमुख
संपर्क नंबर: +91 9960794011
ईमेल आईडी: connect@mbrpvt.com -
4. कर्मचारी प्रशिक्षण और जागरूकता:
कंपनी निरंतर आधार पर शिकायतों को कम करने पर ध्यान केंद्रित करते हुए ग्राहक सेवा सर्वोत्तम प्रथाओं पर कर्मचारियों के लिए प्रशिक्षण कार्यक्रम आयोजित करेगी। इस प्रशिक्षण में पिछली ग्राहक शिकायतों की समीक्षा, उन शिकायतों के समाधान और भविष्य में ऐसी शिकायतों को रोकने के सर्वोत्तम तरीकों पर खुली चर्चा शामिल होगी। उपभोक्ता प्रश्नों के पीछे के मुख्य कारणों का विश्लेषण किया जाता है और उन पर इस तरह से काम किया जाता है जिसका उद्देश्य इन कारणों को जड़ से खत्म करना है। -
6. संचार
कंपनी अपने सभी ग्राहकों / हितधारकों और कर्मचारियों को नीति के बारे में बताएगी। नीति को कंपनी की वेबसाइट पर भी होस्ट किया जाएगा। कंपनी आवश्यकतानुसार नीति को अपडेट करेगी और अपने सभी ग्राहकों और कर्मचारियों को इसके बारे में बताएगी। -
7. नीति समीक्षा
निदेशक मंडल समय-समय पर नीति की समीक्षा करेगा या आवश्यकता के आधार पर, अर्थात विनियामक ढांचे में परिवर्तन की स्थिति में या व्यवसाय या परिचालन आवश्यकता के लिए। नीति में ऐसे अपडेट/परिवर्तनों को संबंधित कर्मचारियों/संबंधित हितधारकों को सूचित किया जाएगा।
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.