Staff Safety & Training Policy – RJC COP 2024
Company Name: Mahavir Bullion & Refinery Private Limited
Policy Title: Staff Safety & Training Policy – RJC COP 2024
Effective Date: 01.04.2025
Approved By: Board of Directors
- 1. Document Control
| Company Name | Mahavir Bullion & Refinery Private Limited | Policy No. | MBR/STP/14 |
| Policy Title | Staff Safety & Training Policy | Revision Date | 01/04/2026 |
| Effective Date | 01/04/2025 | Review Date | 01/04/2027 |
| Approved By | Board of Directors | Approval Date | 01/04/2026 |
| 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) is committed to maintaining a safe and healthy workplace through safety awareness, competency, training, risk control and continuous improvement. Refinery operations may involve chemical, thermal, physical, machinery, electrical and environmental hazards.
This Policy is based on the Company's original Staff Safety & Training Policy and updates its RJC references to the current RJC COP 2024 framework. COP 24 requires appropriate health and safety systems, worker participation, understandable training and information, PPE, first-aid arrangements, emergency preparedness and incident investigation. -
3. Purpose
• Ensure workers are competent, trained and aware of workplace hazards and controls.
• Reduce accidents, injuries, near misses and unsafe behaviors.
• Establish structured induction, job-specific, refresher and emergency-response training.
• Ensure workers and visitors receive safety information in a format and language they understand.
• Provide appropriate PPE free of charge and verify correct use.
• Ensure safety learning from incidents, near misses and risk assessments is converted into corrective action. -
4. Scope
This Policy applies to permanent, temporary, contractual and outsourced employees, supervisors, managers, department heads, contractors, job workers, security/logistics personnel and visitors entering operational areas, across all shifts and refinery/support functions. - 5. RJC COP 2024 Alignment
| RJC Requirement | Policy Response | Evidence |
|---|---|---|
| COP 24.1 – Workplace health and safety | Safety management, hazard controls, safe workplace requirements and responsibilities. | Risk assessments, inspections, SOPs, corrective actions. |
| COP 24.2 – Risk assessment and controls | Training is linked to job hazards and controls identified through risk assessment. | JSA/JHA, risk register, TNA, training matrix. |
| COP 24.3 – Worker participation | Workers can raise health and safety issues through the safety committee and reporting channels. | Committee minutes, safety observations, grievance records. |
| COP 24.4 – Health and safety training | Role-specific training and emergency information are provided in understandable formats/languages; stop-work responsibility is communicated. | Training records, induction, toolbox talks. |
| COP 24.5–24.8 – PPE, first aid, emergencies and incidents | PPE, first aid, drills and incident investigation are addressed. | PPE records, first-aid records, drill reports, incident investigations. |
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6. Safety Policy Statement
• Provide a safe working environment and identify hazards proactively.
• Prevent accidents, injuries and unsafe incidents through effective controls.
• Ensure competency of persons performing safety-critical tasks.
• Reduce chemical, thermal, physical, ergonomic and operational risks.
• Provide safety resources, information and PPE appropriate to assessed risks.
• Promote worker participation, hazard reporting and continuous improvement.v - 7. Safety Responsibilities
| Role | Responsibilities |
|---|---|
| Senior Management | Approve the safety programme; provide adequate resources; review safety and training performance. |
| Safety / EHS Officer | Conduct training-needs assessment; maintain training matrix/records; coordinate safety training; oversee PPE, emergency preparedness and chemical safety; investigate incidents. |
| Department Heads / Supervisors | Conduct toolbox talks; verify PPE and SOP compliance; ensure workers complete required training before safety-critical work; report unsafe conditions. |
| Employees | Follow safety rules/SOPs; use PPE; attend required training; report hazards, near misses and unsafe conditions; exercise stop-work responsibility for uncontrolled hazards. |
| Contractors / Visitors | Complete required orientation, follow site rules and PPE requirements, and immediately report unsafe conditions. |
- 8. Training Programme Structure
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8.1 Induction Training
Mandatory for new joiners before entering high-risk areas. Covers company safety rules, PPE, emergency exits/assembly points/alarms, chemical/thermal/electrical/physical hazards, safety data sheet awareness, first-aid and fire-safety basics, and contractor/visitor safety. -
8.2 Furnace Operators
Molten-metal handling, spill/splash prevention, temperature controls and emergency furnace shutdown. -
8.3 Aqua Regia Operators
Safe acid handling, fume hoods/scrubbers, spill control, reaction control and exothermic hazards. -
8.4 Fire Assay Technicians
Crucibles and fluxes, furnace safety and high-temperature PPE. -
8.5 Maintenance Personnel
Lockout-Tagout, electrical safety and machinery isolation. -
8.6 Chemical Handlers
Correct storage, segregation of incompatible substances, spill kits and disposal procedures. -
8.7 Security & Logistics
Safe handling of precious metals during transport, CCTV/access controls and emergency coordination. -
8.8 Refresher Training
At least annually and additionally after incidents/near misses, process or equipment changes, legal updates or RJC COP updates. -
8.9 Emergency Response Training
Fire preparedness, first aid/CPR, acid-spill response, evacuation, extinguisher use and emergency communications. Mock drills shall be conducted according to the emergency programme and legal/site requirements. -
8.10 Behaviour-Based Safety
Identification of unsafe behaviours, positive reinforcement, peer safety communication and safety-observation reporting. -
8.11 Contractors & Visitors
No entry into operational areas without appropriate safety orientation, PPE briefing, site-hazard awareness and required declaration/acknowledgement.
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9. Training Needs Assessment (TNA)
The Safety / EHS Officer shall conduct a documented TNA based on:
• Job role and responsibilities
• Hazard exposure and risk level
• Required competency for safety-critical tasks
• Past incident and near-miss data
• Risk assessments/JSA/JHA
• Audit findings and corrective actions
• Legal requirements and applicable RJC COP requirements
• Changes in equipment, process, chemicals or work methods
Training modules shall be reviewed at least annually and updated when risks, processes, legal requirements or RJC requirements change. -
10. Training Matrix and Competency
MBRPL shall maintain a role-based training matrix identifying mandatory training, frequency, responsible trainer and completion status. Safety-critical work shall not be assigned to personnel who have not completed the required training or demonstrated the required competency. -
11. Safety Communication & Awareness
• Toolbox talks and shift safety briefings.
• Safety posters, signs and hazard markings.
• Chemical hazard labels and safety information.
• Safety alerts following incidents or identified hazards.
• Sharing lessons learned and best practices.
• Safety bulletins or other periodic communications as appropriate.
• Communication of workers' right and responsibility to stop or refuse work where hazards are uncontrolled and to immediately raise the concern to those at risk and management, consistent with COP 24.4. -
12. PPE Management
Appropriate PPE shall be provided to workers and visitors free of charge where required by the risk assessment and site rules. RJC COP 24.5 requires PPE to be appropriate, current and correctly worn/used.
• Acid-resistant gloves
• Face shields
• Safety shoes
• Goggles
• Respirators
• Heat-resistant aprons
• Helmets
• Hearing protection
Supervisors shall verify correct use, condition and replacement of PPE. PPE issuance/inspection records shall be maintained. -
13. First Aid & Medical Preparedness
• Maintain appropriate first-aid provisions and trained first-aid personnel.
• Ensure first-aid arrangements are accessible and clearly identified.
• Maintain procedures for transportation to appropriate medical facilities in a medical emergency.
• Record first-aid treatment and work-related injuries as required by law and company procedure.
• Review first-aid arrangements following incidents, workplace changes or risk assessments. -
14. Emergency Preparedness & Drills
Emergency procedures and evacuation plans shall cover reasonably foreseeable health and safety emergencies and shall be accessible/displayed, regularly tested and periodically updated in accordance with COP 24.7.
• Fire/explosion
• Chemical or acid spill and toxic vapour release
• Gas cylinder or utility emergency
• Medical emergency
• Serious equipment/process emergency
• Security-related emergency where worker safety is affected
• Other emergencies identified through the site's risk assessment
Drill results shall be documented, including scenario, date, participants, observations, response time where measured, deficiencies and corrective actions. -
15. Incident, Near-Miss & Unsafe-Condition Reporting
All injuries, near misses, unsafe conditions, chemical spills and relevant equipment malfunctions shall be reported promptly.
1. Immediate notification to the responsible supervisor/Safety Officer.
2. Entry into the Incident/Observation Register.
3. Investigation proportionate to the event, with contributing/root causes identified.
4. Corrective and preventive actions assigned with responsible persons and target dates.
5. Verification of action effectiveness.
6. Lessons learned communicated to affected workers and reflected in training/risk controls where appropriate.
COP 24.8 requires health and safety incidents to be investigated and the results used to review relevant hazard controls and prevent recurrence. -
16. Safety Committee & Worker Participation
Where established, the Safety Committee shall include appropriate management and worker representation and provide a mechanism for workers to raise and discuss health and safety issues and participate in risk assessments and controls, consistent with COP 24.3.
• Review incidents, near misses and safety trends.
• Review workplace inspection findings.
• Discuss worker safety concerns.
• Participate in hazard identification and control improvement.
• Track safety actions to closure. -
17. Monitoring & Review
• Conduct planned workplace safety inspections.
• Track relevant KPIs such as injuries, near misses, training completion and PPE compliance.
• Review training effectiveness and competency gaps.
• Issue corrective/non-compliance notices where appropriate.
• Verify closure and effectiveness of corrective actions.
• Conduct management review at least annually. -
18. Records & Retention
• Training attendance and competency records
• Induction records/certificates
• Training Needs Assessments and training matrix
• Toolbox talk records
• Safety Committee minutes
• Incident/near-miss investigation reports
• JSA/JHA and risk assessment records
• PPE issuance/inspection records
• Emergency drill records
• Corrective-action records
Retention shall follow applicable law and the Company's controlled-record retention requirements. Any period stated in an individual legal or contractual requirement shall be followed where longer. -
19. Policy Violations & Disciplinary Action
Failure to comply with safety requirements may result in corrective action, retraining, removal from safety-critical tasks, suspension or other disciplinary action consistent with company policy, employment terms and applicable law. Serious intentional or reckless violations may be escalated for legal action where appropriate. -
20. Policy Review & Continuous Improvement
This Policy shall be reviewed at least annually and additionally following changes in law, significant new risks, incidents, process/equipment changes, RJC updates or internal/external audit findings.
The Company shall use worker feedback, training performance, incidents, near misses, inspections, risk assessments and audit findings to improve the effectiveness of the safety and training programme. -
21. Related Controlled Documents
• Health & Safety Risk Assessment Policy – RJC COP 2024
• Emergency Evacuation Plan – RJC COP 2024
• Natural Resources Use & Environmental Management Policy – RJC COP 2024
• Security Risk Assessment & Management Policy – RJC COP 2024
• Grievance Redressal Policy – RJC COP 2024
• Human Rights Policy – RJC COP 2024
• Applicable safety SOPs, JSAs/JHAs, training matrix and emergency procedures - For Mahavir Bullion & Refinery Private Limited
| Prepared By | Reviewed & Approved By |
|---|---|
| Compliance Officer | Director |
| Rushikesh Rajendra Deshmukh | Jitendra Panditrao Deshmukh |
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.