Health & Safety Risk Assessment Policy
- 1. Document Control
| Company Name | Mahavir Bullion & Refinery Private Limited | Policy No. | MBR/HSRAP/07 |
| Policy Title | Health & Safety Risk Assessment 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” or the “Company”) is committed to providing safe and healthy working conditions for workers and visitors. This Policy establishes a structured approach for identifying hazards, evaluating health and safety risks, implementing controls, documenting assessments and reviewing their effectiveness.
This revised Policy is based on the Company’s existing Health and Safety Risk Assessment Policy. The original policy covers all work areas, processes, equipment and personnel and requires proactive, documented risk assessments, annual review, and additional review following significant changes, incidents, near misses or safety audits. -
3. Objective
• Identify workplace hazards before they result in injury, ill-health, damage or unsafe conditions.
• Evaluate the likelihood and potential consequence of identified hazards.
• Implement effective controls using the hierarchy of controls.
• Assign responsibility and target dates for additional controls.
• Verify that controls remain suitable and effective.
• Promote continuous improvement in occupational health and safety performance. -
4. Scope
This Policy applies to all work areas, processes, equipment and personnel at MBRPL, including:
• Permanent, temporary, contractual and outsourced employees.
• Supervisors, managers and department heads.
• Contractors, job-workers and service providers.
• Visitors entering operational areas.
• All shifts, refinery processes and support functions.
• Routine and non-routine activities. - 5. RJC COP 2024 Requirements Addressed
| RJC Provision | Requirement / Expectation | Company Control |
|---|---|---|
| COP 24.1 | Provide safe and healthy working conditions for workers and visitors in accordance with applicable law and relevant recognized standards. | Health and safety policy, hazard identification, risk assessment and control processes. |
| COP 24.2(c) | Identify hazards, assess workplace risks and implement controls to minimize accidents and injury, considering hazards associated with activities and products. | Formal risk assessment process, risk register, JSA and hierarchy of controls. |
| COP 24.2(d) | Establish occupational health and safety management systems and procedures to eliminate hazards, manage risks, verify controls and demonstrate improvement. | Defined responsibilities, procedures, records, monitoring, incident learning and corrective action. |
| COP 24.2(e) | Conduct documented reviews at least annually to assess suitability, adequacy and control effectiveness and address gaps. | Annual documented review plus trigger-based review after changes, incidents, near misses and audits. |
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6. Policy Statement
• MBRPL is committed to maintaining a safe and healthy working environment by identifying hazards and implementing effective risk control measures.
• Risk assessments shall be carried out proactively, documented and reviewed periodically and whenever significant changes occur.
• Employees and other relevant persons are expected to cooperate with risk-control measures, report hazards and follow safe work procedures.
• Health and safety considerations shall take priority over production or operational convenience where a material safety risk is identified. -
7. Key Definitions
• Hazard: Anything with the potential to cause harm, including chemicals, machinery, energy sources, unsafe conditions or work activities.
• Risk: The combination of the likelihood of harm occurring and the severity/consequence of that harm.
• Risk Assessment: The process of identifying hazards, evaluating associated risks and determining appropriate control measures.
• JSA / Job Safety Assessment: A task-level assessment used to identify hazards and controls before high-risk or non-routine work. -
8. Refinery-Specific Hazard Identification
Risk assessments shall consider hazards relevant to the Company’s actual operations. The existing Company assessment specifically identifies the following areas for consideration:
• Hydrochloric acid, nitric acid and Aqua Regia exposure.
• Toxic fumes and vapors.
• Furnaces, high temperatures and molten metal.
• Electrical systems.
• Machinery and moving equipment.
• Compressed gases.
• Chemical storage and chemical incompatibility.
• Material handling and lifting.
• Fire and explosion.
• Heat stress.
• Work at height.
• Confined spaces.
• Other significant operational hazards identified through site assessment. - 9. Responsibilities
| Role | Responsibility |
|---|---|
| Senior Management | Ensure adequate resources, review significant risks and support implementation of corrective actions. |
| Management | Ensure risk assessments are conducted, implemented and acted upon. |
| EHS / Safety Officer | Coordinate the risk assessment programme, maintain the master register, support assessors, monitor controls and track corrective actions. |
| Supervisors / Line Managers | Lead or participate in area-specific assessments, maintain records, ensure team compliance and communicate controls. |
| Employees | Follow controls and safe work procedures and report hazards, unsafe conditions and near misses. |
| Contractors / Job-workers | Comply with applicable site risk controls and report hazards or unsafe conditions. |
- 10. Risk Assessment Process
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10.1 Step 1 – Hazard Identification
1. Inspect work areas, equipment, materials and tasks.
2. Consider routine and non-routine activities.
3. Consider foreseeable abnormal and emergency situations where relevant.
4. Consult workers and supervisors who understand the task and work conditions.
5. Consider previous incidents, near misses, audit findings and reported unsafe conditions. -
10.2 Step 2 – Risk Evaluation
The Company’s existing policy uses likelihood and consequence of harm and a Low / Medium / High risk approach. Site-specific risk criteria and scoring shall be defined in the approved Risk Assessment Form / Risk Matrix before assessments are conducted.
• Likelihood – how probable the hazardous event or exposure is.
• Severity / Consequence – the potential seriousness of injury, ill-health or other harm.
• Overall risk level – determined using the approved Company risk matrix. -
10.3 Step 3 – Control Measures
Controls shall be selected using the hierarchy of controls:
• Elimination – remove the hazard where reasonably practicable.
• Substitution – replace the hazard with a less hazardous alternative.
• Engineering Controls – isolate people from the hazard through physical or technical measures.
• Administrative Controls – procedures, training, supervision, permits, signage and scheduling.
• Personal Protective Equipment (PPE) – use appropriate PPE where residual risk remains.
PPE shall not be treated as the preferred control where a higher-level control is reasonably practicable. -
10.4 Step 4 – Documentation
6. Record findings in the approved Risk Assessment Form / Risk Assessment Register.
7. Record existing controls and the assessed risk level.
8. Identify additional controls required.
9. Assign a responsible person for each action.
10. Set a target completion date.
11. Record the status and evidence of completion. -
10.5 Step 5 – Verification and Review
12. Verify that implemented controls are actually in place and functioning.
13. Review residual risk after additional controls are implemented.
14. Document findings and outstanding actions.
15. Escalate overdue or significant unresolved risks to appropriate management.
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11. Risk Assessment Register
The following minimum fields shall be used for site-specific or department-wise risk registers, based on the Company’s existing format:
| Hazard / Task | Risk Description | Existing Controls | Risk Level | Additional Controls | Responsible Person |
|---|---|---|---|---|---|
| Melting / Refining Furnace | Burns, heat exposure, molten metal splash, fire | PPE, trained operators, furnace guarding, SOPs, emergency arrangements | High | Verify furnace interlocks, heat-resistant PPE, periodic competency training, emergency drills | Production / EHS Manager |
| Acid / Chemical Handling | Chemical burns, inhalation exposure, toxic fumes, chemical spills | Chemical PPE, labelled containers, SDS, ventilation/fume extraction | High | Emergency eyewash/shower, spill kits, chemical handling training, periodic ventilation inspection | EHS / Refinery Manager |
| Nitric / Hydrochloric Acid Use | Corrosive exposure and hazardous fumes during refining | Fume extraction, PPE, chemical storage and handling procedures | High | Verify LEV performance, chemical compatibility of storage, exposure monitoring where required | EHS Manager |
| Gas Cylinders / Argon / LPG | Fire, explosion, cylinder damage, gas leakage or asphyxiation | Secured cylinders, designated storage, regulators, trained personnel | High | Leak testing, cylinder inspection, segregation, emergency isolation procedure | Maintenance / EHS |
| Electrical Equipment | Electric shock, short circuit, electrical fire | Earthing, electrical panels, authorised maintenance personnel | High | Periodic electrical inspection, ELCB/RCCB testing, thermography where applicable | Maintenance Manager |
| Chemical Storage | Spill, incompatible chemical reaction, exposure | Labelled storage, SDS, restricted access | High | Compatibility-based segregation and periodic storage inspection | EHS / Stores |
| Laboratory / Assay Operations | Chemical exposure, glass breakage, fumes, burns | Laboratory PPE, SOPs, ventilation, trained analysts | Medium/High | Review laboratory risk assessments and emergency procedures | Laboratory Manager |
| Material Handling / Lifting | Musculoskeletal injury, dropped material, crushing injury | Handling procedures, lifting aids, PPE | Medium | Manual-handling training and lifting-equipment inspection | Operations Manager |
| Forklift / Vehicle Movement | Collision, struck-by injury, material damage | Defined routes, trained operators, speed controls | High | Pedestrian segregation, warning signs, periodic competency checks | Operations / EHS |
| Fire Emergency | Injury, smoke exposure, property damage | Fire extinguishers, alarms, emergency exits, evacuation plan | High | Periodic fire drills, equipment inspection and emergency response training | EHS / Fire Safety Team |
| Emergency Evacuation | Delayed evacuation, missing personnel | Emergency plan and designated assembly point | High | Periodic evacuation drills and headcount verification | EHS / Emergency Response Team |
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12. Frequency of Risk Assessments
• At least annually for all operations.
• Before introducing new processes, equipment, chemicals, materials or significant changes.
• Following any incident or significant near miss.
• Following significant safety audit findings.
• Following changes that could alter existing hazards or risk levels.
• Pre-task Job Safety Assessments for high-risk or non-routine work.
These requirements preserve the frequency specified in the Company’s existing policy while expanding the documented triggers needed for effective COP 24 implementation. -
13. High-Risk / Non-Routine Work
• High-risk or non-routine activities shall undergo task-level assessment before work begins.
• Where required, work shall be controlled through appropriate permits, isolation/lockout arrangements, competent supervision and specified PPE.
• Workers shall be briefed on identified hazards and controls before commencing the task.
• Changes in task conditions shall trigger reassessment. -
14. Worker Consultation and Hazard Reporting
• Workers shall be encouraged to report hazards, unsafe conditions and near misses without fear of retaliation.
• Workers performing the task should be involved or consulted where appropriate during risk assessment.
• Reported hazards shall be assessed and controlled according to their risk.
• Corrective actions shall be communicated to relevant workers. -
15. Incident and Near-Miss Learning
• Health and safety incidents shall be investigated to identify contributing and root causes.
• Near misses shall be reviewed where their potential consequences could have been serious.
• Relevant risk assessments shall be revised following significant findings.
• Corrective and preventive actions shall be assigned, tracked and verified.
RJC COP 24.8 requires members to investigate health and safety incidents and feed the results into reviews of relevant hazard controls to prevent recurrence. -
16. Training and Awareness
• Employees shall receive training on hazard identification techniques.
• Employees shall understand the purpose and importance of control measures.
• Employees shall be trained on reporting unsafe conditions and incidents.
• Assessors and supervisors shall receive appropriate role-specific training on conducting and documenting risk assessments.
• Training and attendance records shall be maintained. -
17. Monitoring and Effectiveness
• EHS / Safety personnel shall periodically monitor implementation of identified controls.
• Open corrective actions shall be tracked to closure.
• Risk assessments shall be sampled to verify quality, completeness and control effectiveness.
• Trends in incidents, near misses, hazard reports and risk assessment findings shall be reviewed.
• Management shall take corrective action where the risk assessment process or controls are not effective. -
18. Records and Document Retention
• Risk Assessment Register.
• Area / department risk assessments.
• Job Safety Assessments (JSA).
• Corrective action records.
• Incident and near-miss investigation records.
• Training and competency records.
• Risk assessment review and approval records.
• Evidence of implementation and verification of controls.
Records shall be retained in accordance with the Company’s document-control system and applicable legal requirements. RJC COP 2.5 requires records covering applicable COP requirements to be retained for at least five years or longer where national legislation requires. -
19. Policy Review and Approval
This Policy shall be reviewed at least once every 12 months and additionally when there are significant changes in processes, equipment, chemicals, workplace conditions, applicable law or RJC requirements, or following incidents, near misses, audits or identified weaknesses in the risk-control system.
RJC COP 24.2(e) requires documented reviews at least annually to assess the ongoing suitability and adequacy of the occupational health and safety management system, verify control effectiveness and implement improvements.
Changes shall be documented through the Company’s document-control process and approved by the Board or other authorised approving body. -
20. Related Controlled Documents
• Emergency Evacuation Plan.
• Staff Safety & Training Policy.
• Security Risk Assessment Policy.
• Natural Resource Use Policy.
• Grievance Redressal Policy.
• Incident Investigation / Corrective Action records.
• Emergency Response procedures.
• Chemical Safety / SDS records, where applicable. - 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.