Emergency Evacuation Plan
- 1. Document Control
| Company Name | Mahavir Bullion & Refinery Private Limited | Policy No. | MBR/EEP/10 |
| Policy Title | Emergency Evacuation Plan | 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”) acknowledges its responsibility to protect employees, contractors, visitors, assets and the environment during emergency situations. The refinery operations include hazards such as high-temperature furnaces, chemical processes including Aqua Regia, acid vapours, gas cylinders, electrical panels and valuable inventories.
This Emergency Evacuation Plan establishes structured procedures for responding to foreseeable emergencies quickly, safely and effectively. It is based on the Company’s existing Emergency Evacuation Plan and has been structured for RJC COP 2024 audit readiness. -
3. Purpose
• Establish clear, step-by-step evacuation procedures for foreseeable emergencies.
• Ensure prompt communication and coordination during critical events.
• Protect life, health, property and the environment.
• Provide clear responsibilities for emergency response personnel.
• Ensure employees and other relevant persons are trained to respond calmly and appropriately.
• Provide a basis for emergency drills, incident review and continual improvement. -
4. Scope
This Plan applies to all employees, temporary and contractual workers, contractors, job-workers, visitors, suppliers and transporters present within Company-controlled areas, including:
• Refinery areas including melting, Aqua Regia and assay operations.
• Acid handling and chemical storage areas.
• Furnace areas.
• Electrical and DG rooms.
• Security cabin.
• Offices, administration areas and staircases.
• Storage vaults and production floors. - 5. RJC COP 2024 Requirements Addressed
| RJC Provision | Requirement / Expectation | Company Control |
|---|---|---|
| COP 24.7 | Emergency procedures and evacuation plans for reasonably foreseeable health and safety emergencies; accessible/displayed, regularly tested and periodically updated. | This Plan, displayed emergency procedures, evacuation routes, drills, records and periodic review. |
| COP 24.8 | Investigation of health and safety incidents and use of findings to improve controls. | Post-incident investigation, root-cause review and corrective/preventive actions. |
| COP 2 | Management systems and implementation of applicable COP requirements. | Defined responsibilities, training, records, review and corrective action. |
| COP 25–27 | Environmental, hazardous-substance and waste/emission controls where relevant to emergencies. | Chemical spill, toxic vapour and related emergency procedures are incorporated where applicable. |
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6. Types of Emergencies Covered
• Fire or explosion, including electrical, chemical, furnace, paper/waste and gas-cylinder ignition events.
• Chemical emergencies, including HCl, HNO3 and Aqua Regia spills, toxic vapour release, scrubber malfunction and chemical reaction outburst.
• Medical emergencies, including burns, acid exposure, respiratory distress, cardiac arrest and injury.
• Security-related incidents, including lockdown situations, unauthorised entry, theft attempts during evacuation and bomb threats.
• Natural disasters, including earthquake, flooding and severe storms. -
7. Emergency Response Committee (ERC)
The Emergency Response Committee shall coordinate emergency response and evacuation activities.
• Chief Emergency Controller (CEC) – Plant Head / Senior Manager: makes high-level evacuation decisions, coordinates external emergency services, declares “All Clear” and leads the post-incident review.
• Deputy Emergency Controller (DEC) – EHS / Safety Officer: supports the CEC, activates alarms and announcements, ensures evacuation routes are clear and oversees emergency equipment readiness.
• Floor Wardens: guide employees to exits, check designated areas, ensure no one is left behind and report evacuation/headcount status.
• First-Aid Team: provides medical support, assists injured persons and coordinates transport to hospitals.
• Fire Response Team: responds to fire emergencies within its training and safe operating limits.
• Communication & Security Team: manages communications, gates, assembly areas, emergency vehicle access and crowd control.
• Evacuation Guides: support orderly movement and provide assistance to persons requiring additional support. -
8. Emergency Equipment & Infrastructure
• Fire extinguishers appropriate to identified hazards, including CO2, dry powder, foam and water types as applicable.
• Fire alarm system and smoke detectors.
• Fire hydrant/sprinkler system, where applicable.
• Emergency exit signage and displayed evacuation route maps.
• First-aid kits.
• Chemical spill kits.
• Eye-wash stations and emergency showers.
• PPE for trained emergency responders.
• Public address (PA) system and emergency communication arrangements.
Emergency equipment shall be inspected and maintained at defined intervals and in accordance with applicable statutory requirements.
- 9. Evacuation Procedure
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9.1 Raising the Alarm
1. Any person discovering an emergency shall immediately raise the alarm by shouting the appropriate warning or announcing the hazard.
2. Activate the nearest manual alarm switch, where provided.
3. Inform the Safety Officer or Supervisor.
4. The Safety Officer shall activate the fire/emergency alarm, inform the Chief Emergency Controller and notify affected areas using the PA system or other available communication method. -
9.2 During Evacuation
5. Stop work immediately.
6. Switch off equipment only where it is safe to do so.
7. Do not collect personal belongings.
8. Move calmly to the nearest safe exit.
9. Walk; do not run or push.
10. Assist injured, physically weak or otherwise vulnerable persons in accordance with the emergency plan.
11. Follow the displayed evacuation route maps and instructions of wardens.
Wardens shall guide employees, check designated areas such as washrooms, acid rooms and utility rooms where safe to do so, close doors without locking them where appropriate, and report evacuation status. -
9.3 Assembly Area and Accountability
All evacuees shall gather at the designated external assembly point identified on the site emergency map.
Designated Assembly Point: Inside Main Entrance Gate, Adjacent to Security Office
• Conduct headcount using department attendance registers or another controlled personnel list.
• Identify and report missing persons to the Emergency Response Committee.
• Provide or coordinate first aid for injured persons.
• Await the “All Clear” from the authorised emergency controller.
• No person shall re-enter the affected area unless authorised.
- 10. Special Procedures for Refinery Operations
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10.1 Fire in Furnace / Melting Area
• Cut power supply where this can be done safely.
• Use the appropriate fire extinguisher for the identified fire type and only by trained personnel.
• Evacuate the furnace aisle/affected area.
• Maintain a safe distance and await emergency response instructions. -
10.2 Acid Spill – HCl, HNO3 or Aqua Regia
• Move employees away from the spill and isolate the affected area.
• Activate emergency ventilation where safe and appropriate.
• Use acid-resistant PPE and spill-response equipment as trained.
• Use appropriate neutralising/spill-control material where available and authorised by the emergency procedure.
• Do not apply water directly to an acid spill unless the approved chemical emergency procedure specifically requires it.
• Evacuate the affected area if vapours spread or conditions become unsafe. -
10.3 Toxic Vapour Release
• Trigger the alarm and notify the Emergency Response Committee.
• Move away from the affected area and, where practicable, move upwind or to the designated safe location.
• Shut down or isolate relevant systems only where safe to do so.
• Contact external emergency responders where required. -
10.4 Gas Cylinder Leak
• Do not operate electrical switches or equipment where this could create an ignition risk.
• Close the cylinder valve only if it is safe to do so.
• Remove ignition sources where safe.
• Raise the alarm and evacuate/isolated the affected area as instructed.
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11. Emergency Communication
• Emergency alarms
• Phone/message systems
• Radio/walkie-talkie communication
External communication shall be made by the responsible officer, as applicable, with:
• Local Fire Brigade
• Police Department
• Ambulance / hospital services
• Pollution Control Board for relevant chemical/environmental incidents
• Corporate Management
Emergency contact numbers shall be displayed prominently and kept current.
| Emergency Service / Contact | Contact Person / Number | Location |
|---|---|---|
| Fire Brigade | Chief Fire Officer / Duty Station Officer 022-27681313 / 022-27612211 (or 101) | MIDC Fire Station, Pawane / Mahape |
| Police | [Senior Police Inspector (Sr. PI) 022-27670110 / 022-27670138 (or 100) | Turbhe MIDC Police Station |
| Ambulance / Hospital | Chief Medical Officer / ER In-Charge 022-39666666 (or 108) | Reliance Hospital, Kopar Khairane |
| Pollution Control Board | Sub-Regional Officer 022-27576034 | Raigad Bhavan, CBD Belapur |
| Corporate Management / CEC | Mahavir Refinery, Pawane Plant |
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12. Training, Testing and Mock Drills
The Company shall communicate this Plan to relevant workers and conduct emergency preparedness activities. The existing Plan provides for:
• Fire drill – every 6 months.
• Chemical spill drill – annually.
• Evacuation drill – every 6 months.
• First-aid training – annually.
• PPE usage training – during induction and quarterly.
RJC COP 24.7 guidance states that evacuation drills should be conducted every six months and records should include the time taken to evacuate.
Records of drills shall include date, scenario, participants/attendance, evacuation time where applicable, findings, lessons learned and corrective/improvement actions. -
13. Disability-Inclusive Evacuation
• Assign evacuation buddies or other appropriate assistance arrangements where required.
• Provide suitable evacuation assistance/equipment where needed.
• Ensure ramps, handrails and accessible routes are maintained.
• Prioritise appropriate support for persons with disabilities or other evacuation needs. -
14. Post-Evacuation and Incident Review
1. Confirm headcount and identify missing persons.
2. Assist injured persons and coordinate medical response.
3. Control secondary hazards where safe to do so.
4. Evaluate damage and operational impacts.
5. Prepare an incident investigation report where required.
6. Identify contributing/root causes and lessons learned.
7. Implement corrective and preventive actions and track them to closure.
Health and safety incidents and near-misses shall be reviewed so that relevant hazard controls can be improved and recurrence prevented. -
15. Documentation and Record Keeping
• Emergency drill reports and evacuation drill records.
• Training attendance and training records.
• Incident and near-miss records.
• Fire/emergency equipment inspection and maintenance records.
• Relevant Safety Data Sheets (SDS/MSDS).
• Current emergency response and evacuation plans.
• Headcount/attendance records for drills.
• Corrective action and improvement records.
Records shall be retained in accordance with the Company’s document-control and legal retention requirements. The original Plan specified a minimum eight-year retention period; this requirement is retained unless a longer applicable legal or Company requirement applies. -
16. Policy Review and Continual Improvement
This Plan shall be reviewed at least once every 12 months and additionally:
• After any major incident or significant near-miss.
• Following significant changes to processes, plant, equipment, chemicals or site layout.
• Upon changes in applicable legal or regulatory requirements.
• Following emergency drills where findings indicate that changes are required.
• Following RJC audit recommendations or significant changes to RJC requirements.
Changes shall be documented through the Company’s document-control process and approved by the authorised approving authority. -
17. Related Controlled Documents
• Staff Safety & Training Policy.
• Security Risk Assessment Policy.
• Natural Resource Use Policy.
• Hazardous Substance / Chemical Safety procedures, where applicable.
• Incident Investigation / Corrective Action records.
• Emergency Contact Register.
• Site Emergency Maps and Fire Safety Records. - 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.