Anti Money Laundering & Counter Terrorist Financing
(AML/CFT) Policy – RJC COP 2024
- 1. Document Control
| Company Name | Mahavir Bullion & Refinery Private Limited | Policy No. | MBR/AML-CTF/02 |
| Policy Title | Anti Money Laundering & Counter Terrorist Financing | 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” or “the Company”) is committed to conducting its business in a lawful, transparent and ethical manner. As a precious-metals refinery and bullion trading entity, the Company recognises that gold, silver and PGM are high-value products that can be vulnerable to money laundering, terrorist financing, fraud, smuggling and other financial crimes.
This Policy establishes the Company’s framework for preventing, identifying, assessing, monitoring, escalating and reporting money-laundering and terrorist-financing risks. It shall be read together with the Company’s Responsible Gold, Silver & PGM Sourcing Policy, KYC/Due Diligence SOP, Risk Mitigation Plan and other applicable controlled documents. -
3. Purpose
• Prevent the Company from being used to launder proceeds of crime or finance terrorism.
• Establish documented KYC procedures for suppliers, customers and other relevant counterparties.
• Apply a risk-based approach to identify higher-risk counterparties, transactions, products and geographies.
• Monitor transactions for unusual or suspicious activity and escalate/report suspicions as required by applicable law.
• Support RJC COP 2024 responsible-sourcing and KYC requirements.
• Ensure employees understand their AML/CFT responsibilities and know how to escalate concerns.
• Protect the Company, employees, counterparties and stakeholders from legal, financial and reputational harm. -
4. Scope
This Policy applies to:
• All MBRPL employees, including full-time, part-time, outsourced and contractual personnel whose roles may expose them to AML/CFT risks.
• All suppliers of gold doré, scrap/recycled precious metals, bullion and other COP RJC Scope Materials or inputs intended to become COP RJC Scope Materials.
• All customers, dealers and trading entities within the Company’s business relationships, subject to the RJC treatment of end consumers.
• Intermediaries, agents, transporters and logistics partners where relevant to the transaction or supply chain.
• Procurement, refining, processing, trading, storage, finance, sales and compliance activities.
• Third-party refining or processing arrangements and consignment arrangements involving COP RJC Scope Materials. - 5. RJC COP 2024 Requirements Addressed
| Provision | Policy control |
|---|---|
| COP 2 | Management systems, implementation and grievance/escalation integration |
| COP 5 | Business-partner controls and expectations |
| COP 7 | Risk-based responsible-sourcing due diligence where AML/CFT risks overlap with supply-chain risks |
| COP 12.1 | Documented KYC procedures for relevant suppliers/customers and other materials intended to become COP RJC Scope Materials |
| COP 12.2 | Enhanced KYC for relevant refining/processing on behalf of third parties and consignment arrangements |
| COP 12.3 | Assignment of senior authority and responsibility |
| COP 12.4 | Training, documentation and regular review of KYC procedures |
| COP 12.5 | Cash/cash-like transaction records and reporting at the applicable threshold |
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6. Legal and Regulatory Framework
The Company shall comply with applicable Indian laws, regulations and directions relating to AML/CFT and financial crime. The existing framework identified by MBRPL includes:
• Prevention of Money Laundering Act, 2002 (PMLA) and applicable rules.
• Applicable FIU-IND requirements and reporting obligations.
• Applicable Customs, DGFT, tax and financial-transparency requirements.
• FATF Recommendations, as an international reference for risk-based AML/CFT controls.
• OECD Due Diligence Guidance where relevant to responsible mineral supply-chain risk.
• Applicable United Nations sanctions and other legally applicable sanctions/restrictions.
• Other applicable regulatory requirements, including those applicable to the Company’s specific activities and counterparties.
Where legal requirements change, the Company shall update this Policy and related procedures. Legal requirements shall prevail where they impose a stricter control. - 7. AML/CFT Governance and Responsibilities
| Role | Responsibility |
|---|---|
| Board of Directors | Approve the Policy; provide oversight and resources; review material AML/CFT issues and compliance performance at least annually. |
| Principal Officer | Be the designated senior person responsible for implementation of the AML programme; receive and analyse suspicious-transaction alerts; make statutory reports where required; maintain confidentiality and prevent tipping-off; ensure appropriate training and internal review. |
| Compliance Officer | Conduct/review due diligence; coordinate KYC/KYB; perform sanctions and adverse-information screening; assign/monitor risk classification; oversee transaction monitoring and escalation. |
| Sourcing & Procurement | Complete required KYC/KYB before onboarding; collect source/origin information; ensure documentation is complete; identify and escalate anomalies. |
| Finance | Use approved banking channels; monitor payment patterns; maintain financial records; escalate unusual payment behaviour. |
| Operations / Refinery / Logistics | Maintain appropriate physical and transaction records; reconcile material and documentation; escalate discrepancies and suspicious circumstances. |
| All Employees | Comply with this Policy; complete required training; immediately report suspicious behaviour or attempted circumvention to the Principal Officer or Compliance Officer. |
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8. Risk-Based Approach
MBRPL shall assess AML/CFT risk using a documented, proportionate and risk-based methodology. Risk shall be assessed before establishing a relationship and monitored throughout the relationship. -
8.1 Counterparty Risk
• Legal and regulatory history.
• Beneficial ownership and control structure.
• Reputation and adverse media.
• Nature and legitimacy of business activity.
• Government, military or political affiliations where relevant.
• Unusual ownership, unexplained complexity or shell-company indicators.
• Quality and completeness of KYC information.
• AML/CFT controls maintained by the counterparty. -
8.2 Geographic Risk
• Countries identified as higher risk under applicable official sources.
• Conflict-Affected and High-Risk Areas (CAHRA).
• Weak AML/CFT regulatory environments.
• Countries or routes associated with illegal precious-metals movement or sanctions concerns. -
8.3 Product / Material Risk
• Gold doré from higher-risk regions.
• Scrap or recycled material with uncertain origin.
• Mixed or unverified precious-metal sources.
• Material processed or refined on behalf of a third party.
• COP RJC Scope Materials handled on consignment. -
8.4 Transaction Risk
• Large or unusual cash/cash-like payments.
• Structuring or splitting transactions.
• Over- or under-invoicing.
• Rapid turnover without a clear economic rationale.
• Circular or unnecessarily complex transactions.
• Third-party payments inconsistent with the relationship.
• Transactions inconsistent with declared business profile or expected activity.
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9. KYC / KYB Due Diligence
The Company shall document and apply KYC procedures to relevant suppliers and customers of COP RJC Scope Materials, products containing such materials, and other materials intended to be converted into COP RJC Scope Materials. -
9.1 Identity and Legal Existence
• Obtain and verify government-issued identification or reliable government/company records appropriate to the counterparty type.
• Record legal name, registered address, business address, contact information, date/country of incorporation and registration/tax identifiers as applicable.
• Obtain parent-company/subsidiary information and management structure where relevant.
• Understand the counterparty’s core business activity, including its material sources where relevant.
• Obtain financial information proportionate to risk. -
9.2 Beneficial Ownership and Principals
• Identify and record beneficial ownership and principals were triggered by risk assessment or applicable law.
• Verify beneficial ownership using reliable sources such as government/company records, declarations and appropriate third-party checks.
• Escalate unclear, concealed or inconsistent ownership structures for enhanced review. -
9.3 Sanctions and Screening
• Screen relevant counterparties and, where applicable, beneficial owners/principals against legally applicable sanctions and relevant government lists.
• Use appropriate additional screening sources identified in the Company’s KYC SOP, including adverse media and relevant regulatory/debarment information.
• Potential matches shall be investigated before onboarding or further processing where required.
• Confirmed prohibited matches shall be escalated immediately and handled in accordance with applicable law.
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10. Enhanced KYC for Refining, Processing and Consignment
Where MBRPL has mineral-processing or refining operations that extract COP RJC Scope Materials from input substances on behalf of a third party, or where the Company handles COP RJC Scope Materials on consignment, enhanced KYC shall be conducted commensurate with the nature, scale and purpose of the business relationship.
• Establish the identity and legitimacy of the contracting party and relevant upstream/source parties to the extent required by risk.
• Understand the source and nature of the input material and the reason for the third-party processing/refining or consignment arrangement.
• Verify ownership/control and relevant principals where triggered.
• Assess expected volumes, transaction patterns, payment arrangements and destination of output material.
• Obtain additional information where the source, ownership, transaction purpose or material flow cannot be satisfactorily understood.
• Document the enhanced KYC assessment, approval and any conditions imposed. -
11. Ongoing Due Diligence and Monitoring
• Review transaction patterns against the Company’s knowledge of the counterparty and its declared business.
• Monitor changes in ownership, management, business activity, country of origin, routes and expected transaction volumes.
• Check payments for legitimacy and consistency with approved arrangements.
• Investigate discrepancies between declared and actual weights, assay/purity, origin, invoices or other material information.
• Document red flags and escalation decisions.
• High-risk relationships shall undergo enhanced and periodic review at a frequency determined by the risk assessment; the existing practice of quarterly review for high-risk suppliers shall continue unless the KYC SOP establishes a more appropriate documented frequency. -
12. Prohibited / Restricted Transactions
The Company shall not knowingly engage in transactions involving:
• Anonymous or fictitious counterparties.
• Confirmed sanctions/prohibited parties.
• Shell companies without a legitimate business purpose.
• Undeclared or illegal mining or other unlawful material sources.
• Transactions designed to conceal beneficial ownership.
• Materially inconsistent or fraudulent origin documentation.
• Suspicious routing or unexplained intermediaries.
• Cash/cash-like arrangements prohibited by applicable law or Company controls.
• Transactions where required KYC cannot be satisfactorily completed.
Potentially prohibited transactions shall be escalated to the Principal Officer/Compliance Officer and, where appropriate, Senior Management. No employee shall bypass the approval or escalation process to complete a transaction.
- 13. Red Flag Indicators
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13.1 Documentation Red Flags
• Incomplete or inconsistent KYC.
• Frequent name changes or unclear ownership.
• Falsified invoices, certificates or declarations.
• Conflicting assay or purity reports.
• Inconsistent source/origin information. -
13.2 Transaction Red Flags
• Unusually large or rapid transactions.
• Over- or under-invoicing.
• Circular trading.
• Payments from unrelated third parties.
• Unexplained cash/cash-like activity.
• Transactions inconsistent with expected business profile. -
13.3 Behavioural Red Flags
• Reluctance to provide information.
• Attempts to bypass KYC or approval controls.
• Pressure to expedite onboarding.
• Unusual concern about reporting or recordkeeping. -
13.4 Geographic Red Flags
• CAHRA exposure.
• Routing through higher-risk jurisdictions without clear commercial rationale.
• Use of transporters/intermediaries whose identity or credentials cannot be satisfactorily verified.
Red flags are indicators for investigation and do not automatically establish criminal conduct. The Company shall document the assessment and rationale for the resulting decision.
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14. Suspicious Transaction Reporting and Escalation
• Employees shall immediately escalate suspicious activity to the Principal Officer or Compliance Officer.
• The Principal Officer shall analyse alerts, document findings and rationale, and determine whether a statutory report is required.
• Where required, Suspicious Transaction Reports or other reports shall be filed with the relevant designated authority in accordance with applicable law and prescribed procedures.
• Confidentiality shall be maintained and no employee shall disclose information in a manner that constitutes prohibited tipping-off.
• Internal records shall document the alert, investigation, decision, reporting status and follow-up, subject to legal confidentiality requirements. -
15. Cash and Cash-Like Transactions
The Company shall maintain records of all single or apparently linked cash or cash-like transactions at or above EUR 10,000/USD 10,000 or the threshold defined by applicable law, whichever is lower, and shall report such transactions to the relevant designated authority where required by law. The Company shall also comply with any stricter applicable legal restrictions on cash transactions.
The Finance and Compliance functions shall ensure that transaction aggregation and linked transactions are considered where required. -
16. Record Keeping
The Company shall maintain adequate KYC and AML/CFT records. RJC COP 12.1 requires records for at least five years or as long as required by national legislation, whichever is longer. MBRPL’s existing control is eight-year retention; this shall continue unless a longer legal or contractual requirement applies.
• KYC/KYB files.
• Beneficial ownership and principals’ records.
• Sanctions and screening results.
• Risk classifications and EDD records.
• Transaction and payment records.
• STR/SAR and other statutory reporting records.
• Internal alerts, investigations and decisions.
• Training attendance and content.
• Internal audit/review reports.
• Corrective-action and risk-mitigation records. -
17. Training and Awareness
• Induction AML/CFT training for relevant new employees.
• At least annual AML/CFT refresher training for relevant personnel.
• Role-specific training for sourcing, procurement, operations, finance, compliance and other exposed functions.
• Training on red flags, escalation, reporting obligations, confidentiality and tipping-off.
• Training records shall be maintained in the AML Training Register or equivalent controlled record. -
18. Internal Review and Assurance
• The Company shall conduct periodic internal AML/CFT reviews to evaluate effectiveness of KYC, screening, transaction monitoring, escalation, recordkeeping and training.
• Review findings shall be reported to Senior Management and significant findings shall be escalated to the Board.
• Corrective actions shall have responsible owners and target dates and shall be tracked to closure.
• RJC audit evidence shall be maintained and made available to the auditor as appropriate. -
19. Disciplinary Action and Non-Retaliation
Employees who deliberately violate AML/CFT requirements, ignore known red flags, fail to escalate suspicious activity or attempt to circumvent controls may be subject to disciplinary action, up to and including termination, and reporting to authorities where required.
The Company shall not retaliate against a person who raises an AML/CFT concern in good faith or participates in an investigation. -
20. Policy Review and Approval
This Policy shall be reviewed at least once every 12 months and additionally when there are changes in law, regulation, RJC requirements, material business activities, risk exposure, audit findings, significant incidents or material changes to the Company’s KYC/AML programme.
Changes shall be documented through the Company’s document-control process and approved by the Board or other authorized approving body. -
21. Related Controlled Documents
• Supply Chain Policy
• KYC / Due Diligence SOP
• Risk Mitigation Plan
• Anti-Bribery & Anti-Corruption Policy
• Human Rights Policy
• Grievance Redressal Policy
• Whistleblower Policy
• Security Risk Assessment Policy
• Supplier / Business Partner Code, when approved
• Product Integrity / Claims & Disclosure Policy, when approved - 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.