Ethical Redressal Policy
Company Name: Mahavir Bullion & Refinery Private Limited
Policy Title: RESPONSIBLE GOLD SOURCING POLICY
Effective Date: 01.09.2025
Approved By: Board of Directors
Policy Title: RESPONSIBLE GOLD SOURCING POLICY
Effective Date: 01.09.2025
Approved By: Board of Directors
-
Scope
This policy covers the business activities of Mahavir Bullion & Refinery Private Limited (hereinafter referred to as “Company”) for sourcing of Gold Dore from Conflict Free and Ethical compliant gold suppliers and mining companies and Gold Scrap from local Ethical compliant precious metals traders. -
RESPONSIBILITY:
• Senior Management to provide accesses to necessary documents, information and resources to fulfill the core objective of ensuring conflict free and ethical sourcing of precious metal (gold).
• Senior Management is responsible to provide all required resources and infrastructure to meet the requirements of Responsible Jewellery Council (“RJC”).
• Senior Management shall appoint a Compliance officer with necessary knowledge and qualification and shall provide required training and awareness about the compliance with this Responsible Gold Sourcing Policy and its Due Diligence requirements.
• The Company shall conduct a periodic review meeting of OECD compliances along with Senior Management of Company.
• Senior Management shall conduct an annual review of Responsible Gold Sourcing Policy and shall endorse the policy document as a token of commitment of Compliance.
• Senior Management shall be overall responsible for review and compliance to this Responsible Gold Sourcing Policy.
• Senior Management shall be responsible to design the risk assessment framework/Risk Mitigation Plan during enrolment of new suppliers and their ongoing risk monitoring.
• Senior Management/Board shall conduct on going monitoring of transactions, KYC (Know your counter party) compliance and its periodic reviews. • Senior Management shall be responsible to maintain the necessary records of due diligence and its annual compliance for review. -
PROCEDURE:
• Fighting serious abuses of human rights, avoiding contributing to conflict over its supply chain and complying with high standards of Anti-Money Laundering (AML) and Combating The Financing of Terrorism (CFT) and addressing environmental and sustainability responsibilities are central tenets of the Company’s operating procedures.
• The Company will apply this guidance and comply with the OECD Responsible Gold Guidance for gold handled. The policy covers the five steps framework for risk based due diligence of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
• As part of our Responsible Gold Sourcing Policy, the Company commits to:
Neither tolerate nor contribute to, assist with or facilitate the commission of following:
• Any forms of torture, cruel, inhuman and degrading treatment;
• Any forms of forced or compulsory labor;
• Illegal and/or unacceptable forms of child labor;
• Other human rights violations and abuses such as widespread sexual violence
• War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide. -
OUR ACTIONS ON RED FLAGS
• Immediately suspend or discontinue engagement with counterparty where the Company identifies a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as defined above.
• Support measures to build secure, transparent, fair-trade and verifiable gold supply chains from artisanal miners to market.
• Never source from illegal mining operations
• Not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals who:
- Illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain, and/or
- Illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or
- Illegally tax or extort intermediaries, export to the Company or international traders.
• Immediately suspend or discontinue engagement with upstream suppliers where the Company identify a probable occurrence that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined above.
• Eliminate direct or indirect support to public or private security forces with illegal practices.
• The Company shall not engage offering, promise, give or demand any bribes, and resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of minerals extraction, trade, handling, transport and export.
• Not to source gold from an area designated as a World Heritage Site.
• Perform appropriate due diligence on a risk-based approach over our counterparties before doing any business and ongoing monitoring of the relationship in order to assess the risk of contribution to conflict, money laundering, terrorist financing, serious human rights abuse and non-compliance with environmental and sustainability legal requirements and implement a strategy to respond to identified risk.
• Ensure that appropriate scrutiny and monitoring of transactions is undertaken applying a risk-based approach.
• Maintain adequate records to demonstrate that appropriate and ongoing due diligence have been followed.
• Make and receive payments for gold transactions through official banking channels.
• Take steps to contribute to the effective elimination of money laundering and terrorism financing. In case the Company suspects or have reasonable grounds to suspect that the funds or the gold are the proceeds of a criminal activity, or are related to terrorist financing, the Company shall promptly report such findings to the local financial intelligence unit (FIU).
• Establish long-term relationships with gold suppliers and customers in order to build and support a responsible supply chain.
• Encourage suppliers of gold to take appropriate steps to ensure that the provisions of the Company’s Responsible Gold Sourcing Policy is communicated to their employees and their own supply chain and to urge such suppliers to commit to a gold supply chain policy consistent with Annex II of the OECD Due Diligence Guidance for Responsible Supply Chains.
• Our due diligence includes the following 5 steps: -
STEP I: ESTABLISH STRONG MANAGEMENT SYSTEM
• The Senior Management shall review the effectiveness and performance of the due diligence procedures yearly and document the results of these reviews.
• The Senior Management along with sourcing team is responsible for all matters regarding precious metal supply chain/AML-CFT due diligence. In particular, they review due diligence on suppliers, customers and all the persons involved in the supply chain and assesses if the due diligence documentation collected and maintained is adequate to ensure that these parties have not financed conflict, have not participated in abuse of human rights or money laundering nor financed terrorism and have addressed environmental and sustainability practices.
• Senior Management ensures as well that appropriate measures are executed in case of high-risk counterparties and transactions.
• Senior Management is also responsible for the training of the employees with respect to this guidance (participation list to training shall be kept in the Company’s records) and to give proper information to the Management.
• Senior Management is responsible to perform due diligence and continuous monitoring of the business relationship as described in this guidance (OECD Annexure II).
• The Company will maintain a supply chain traceability system that collects and maintains supply chain information for each inbound and outbound shipment, including assigning a unique reference number to each input and output in a manner that tampering or removal will be evident.
• All consignments shall be unsealed and opened only by authorized personnel and records/evidence of the same shall be maintained.
• Adequate records of due diligence documents and traceability system records are required to be maintained for at least 8 (eight) years to demonstrate that appropriate and ongoing due diligence have been performed.
• Management of the Company shall be encouraged to build long term relationship based on trust and mutual recognition with their gold suppliers and customers. Where appropriate, the Company shall promote responsible sourcing practices throughout the supply chain and assist their counterparties or prospects in improving their own responsible supply chain practices.
• Senior Management will ensure continuous improvement of its due diligence practices.
• Company will make and receive payment for gold through official banking channels only.
• Company will cooperate fully and transparently with government authorities and provide full access to records and information as appropriate.
• Senior Management will be responsible to update this guidance and to ensure that this guidance is properly implemented by the subsidiaries,(if any).
• Company have put in place appropriate grievance redressal mechanism wherein any employee, persons involved in supply chain process, or external stakeholder can raise any concerns over the supply chain or newly identified risk.
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.
