Human Rights Policy
- 1. Document Control
| Company Name | Mahavir Bullion & Refinery Private Limited | Policy No. | MBR/HRP/08 |
| Policy Title | Human Rights 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”) affirms its commitment to respect, uphold and promote internationally recognized human rights across its operations and business relationships. As a precious-metals refinery and bullion business, the Company recognizes that its activities and supply chains may be exposed to risks including child labour, forced labour, discrimination, unsafe working conditions, human trafficking, conflict-related abuses and adverse impacts on communities.
This Policy is based on the Company’s existing Human Rights Policy and retains its core commitments while updating the document for RJC COP 2024. RJC COP 2024 places increased emphasis on human-rights due diligence aligned with the UN Guiding Principles on Business and Human Rights (UNGPs). -
3. Purpose
• Establish a clear, company-wide commitment to respecting human rights.
• Define expectations for employees, contractors, suppliers, counterparties and relevant stakeholders.
• Identify, prevent, mitigate and address actual and potential adverse human-rights impacts connected with the Company’s operations and business relationships.
• Integrate human-rights considerations into sourcing, procurement, refining, operations, employment and decision-making.
• Provide accessible channels for raising concerns and support appropriate remedy where the Company has caused or contributed to an adverse impact.
• Support RJC audit readiness and continuous improvement. -
4. Scope
• All permanent, temporary, outsourced and contractual employees.
• All suppliers and counterparties, including miners, aggregators, refiners, recyclers and scrap dealers, to the extent relevant to due diligence.
• All contractors, visitors, job-workers, transporters and logistics/service providers.
• All operational and support functions including sourcing, procurement, refining, HR, logistics, security, administration, finance, sales and compliance.
• Business decisions relating to procurement, production, labour conditions, health and safety, security, environmental matters and community wellbeing. - 5. RJC COP 2024 Requirements Addressed
| RJC Provision | Requirement / Expectation | Company Control |
|---|---|---|
| COP 6.1 | Respect human rights; consider potential and actual human-rights risks and impacts; implement UNGP-aligned human-rights due diligence appropriate to the business. | Human Rights Policy, HRDD risk assessment, supply-chain due diligence, integration, monitoring and remedy. |
| COP 2 | Policy and management systems supporting implementation of the COP. | Board-approved policy, assigned responsibilities, training, records, review and corrective action. |
| COP 5 | Promote responsible business practices among significant business partners and require relevant compliance at facilities. | Supplier/business-partner expectations and due-diligence controls. |
| COP 7 | Responsible sourcing due diligence, including human-rights risks in supply chains. | Responsible Sourcing Policy, KYC/EDD, CAHRA assessment and risk mitigation. |
| COP 12 | KYC controls relevant to counterparties and business relationships. | AML/KYC framework and enhanced due diligence. |
| COP 18 | Harassment, discipline, grievance procedures and non-retaliation. | Grievance, POSH and Whistleblower mechanisms; non-retaliation. |
| COP 24 | Safe and healthy working conditions. | Health & Safety Risk Assessment Policy and related controls. |
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6. Human Rights Commitment
MBRPL commits to respect human rights in accordance with internationally recognized human-rights principles and applicable law. The Company shall consider potential and actual impacts in its own operations, business relationships and, where relevant, communities connected with its activities. The Company shall not knowingly cause, contribute to or remain directly linked to serious human-rights abuses through its business relationships without taking appropriate action.
• Zero tolerance for torture, cruel, inhuman or degrading treatment.
• Zero tolerance for forced or compulsory labour, human trafficking and unacceptable child labour.
• Zero tolerance for physical or mental abuse, violence, intimidation, coercion and degrading working or living conditions.
• Respect for dignity, equality, freedom of association and lawful collective bargaining.
• Respect for safe and healthy working conditions.
• Respect for workers’ ability to raise concerns without retaliation.
• Respect for affected stakeholders and communities where Company activities may create or contribute to adverse impacts. -
7. Alignment with International Frameworks
• RJC Code of Practices 2024, particularly COP 2, COP 5, COP 6 and related labour, health and safety and responsible-sourcing provisions.
• United Nations Guiding Principles on Business and Human Rights (UNGPs).
• Universal Declaration of Human Rights (UDHR).
• ILO Declaration on Fundamental Principles and Rights at Work and relevant ILO conventions.
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including relevant human-rights risks.
• Applicable Indian labour, safety, anti-trafficking, child-labour and other human-rights-related laws.
RJC’s COP 2024 requires a policy commitment endorsed by top management and a human-rights due-diligence process to identify, prevent, mitigate and account for adverse human-rights impacts, with appropriate remediation where the Company has caused or contributed to impacts. -
8. Prohibition of Child Labour
MBRPL strictly prohibits child labour and shall comply with applicable Indian law. Age verification shall be performed during recruitment and appropriate controls shall be applied to contractors and relevant business partners.
• Maintain documented age and identity verification for employees.
• No hiring of persons below the legally permitted age.
• No persons below 18 years shall be assigned to hazardous refinery activities such as chemical handling, furnace operations or heavy machinery.
• Supplier and contractor due diligence shall consider child-labour risks.
• If credible child-labour concerns are identified in a business relationship, the Company shall investigate, implement appropriate corrective action and suspend or disengage where risks cannot be adequately mitigated. -
9. Prohibition of Forced Labour and Human Trafficking
• Prohibition of bonded, indentured, trafficked, forced or compulsory labour.
• No confiscation or retention of workers’ identity documents as a means of coercion.
• No withholding of wages as coercion.
• No threats, intimidation, violence or restrictions on lawful freedom of movement.
• Employment terms shall be transparent and voluntary.
• Overtime shall not be used as a coercive practice and shall be managed in accordance with applicable law and Company procedures.
• Human-trafficking and forced-labour indicators shall be considered in relevant supplier and contractor due diligence. -
10. Non-Discrimination and Equal Opportunity
MBRPL does not tolerate discrimination in recruitment, employment, training, promotion, compensation, benefits or working conditions. The Company’s separate Non-Discrimination Policy shall be read together with this Policy.
• Gender, caste, religion, ethnicity or social background.
• Marital status, age or disability.
• Sexual orientation or pregnancy.
• Language or other legally protected characteristics.
• Political affiliation or other status where protected by applicable law. -
11. Freedom of Association and Collective Bargaining
• Respect workers’ rights to form or join lawful associations and trade unions.
• Respect lawful collective bargaining rights.
• Workers may raise concerns through the Company’s grievance mechanisms without retaliation.
• Where a union is not present, accessible grievance and worker-representation mechanisms shall be maintained. -
12. Employment Terms, Working Hours and Remuneration
• Employees shall receive clear employment terms appropriate to their employment relationship.
• Working hours, rest periods and overtime shall comply with applicable law and Company procedures.
• Wages shall meet or exceed applicable statutory requirements.
• Overtime shall be managed lawfully and compensated as required.
• Employment records, attendance and payroll records shall be maintained as required. -
13. Health, Safety and Environmental Rights
Workers have the right to a safe and healthy workplace. MBRPL shall identify workplace hazards, assess risks and implement appropriate controls through its Health & Safety Risk Assessment Policy and related procedures.
• Appropriate PPE and safety training.
• Access to drinking water, sanitation and welfare facilities.
• Emergency preparedness and evacuation arrangements.
• Controls for hazardous substances and refinery chemicals.
• Ventilation, fire safety and first-aid arrangements.
• Hazard identification, risk assessment, incident investigation and corrective action. -
14. Human Rights Due Diligence
MBRPL shall maintain a risk-based human-rights due-diligence process covering its own operations and relevant business relationships. The process shall be proportionate to the Company’s size, activities, operating context and potential severity of impacts.
| HRDD Step | Company Approach |
|---|---|
| 1. Identify and assess | Identify actual and potential human-rights impacts through operational risk assessments, supplier/business-partner due diligence, worker feedback, grievances, incidents, audits, adverse information and responsible-sourcing assessments. |
| 2. Integrate and act | Assign responsibility, implement controls, risk mitigation and corrective actions, and integrate findings into procurement, operations, HR and management decisions. |
| 3. Track effectiveness | Monitor controls and corrective actions through audits, inspections, reviews, grievance trends, supplier reviews and incident/near-miss information. |
| 4. Communicate | Provide appropriate information to relevant stakeholders on human-rights due-diligence efforts and material issues, subject to confidentiality and legal requirements. |
| 5. Remedy | Where the Company causes or contributes to an adverse impact, provide for or cooperate in legitimate remediation processes. Where directly linked through a business relationship, use leverage and appropriate risk-response measures. |
- The UNGP-aligned approach is continuous and focuses on risks to people, not only risks to the Company.
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15. Supply Chain Human Rights Due Diligence
• KYC/KYB and beneficial-ownership checks for relevant counterparties.
• Assessment of supplier business activity, location, source and nature of materials.
• Screening for sanctions, PEPs, adverse information and relevant human-rights concerns.
• Assessment of labour practices and serious human-rights risks where relevant.
• CAHRA and responsible-sourcing assessment for higher-risk supply chains.
• Verification of origin, traceability and transaction documentation where required.
• Enhanced due diligence for higher-risk suppliers or transactions.
• Documented risk mitigation, monitoring, suspension or disengagement decisions.
The Company’s Responsible Gold, Silver & PGM Sourcing Policy is the principal controlled document for responsible-sourcing due diligence. It already incorporates human-rights risks, CAHRA assessment, KYC/EDD and supply-chain monitoring. -
16. Security and Human Rights
• Security personnel shall perform duties lawfully, proportionately and respectfully.
• Security controls shall not involve intimidation, unnecessary force, degrading treatment or unlawful restriction of movement.
• Relevant security providers shall be subject to appropriate due diligence and contractual expectations.
• Human-rights concerns associated with security activities shall be reported, investigated and addressed. -
17. Grievance, Reporting and Non-Retaliation
Employees, workers, suppliers, contractors, business partners and other relevant stakeholders may raise human-rights concerns through the Company’s Grievance Redressal Policy, Whistleblower Policy, POSH mechanism or other applicable reporting channel.
• Channels shall be accessible and communicated to relevant workers and stakeholders.
• Good-faith reporting shall not result in retaliation, threats, discrimination, penalty or adverse treatment.
• Confidentiality shall be protected on a need-to-know basis and anonymous concerns shall be considered where reasonably possible.
• Complaints shall be assessed, investigated and resolved in a fair and timely manner appropriate to their seriousness and complexity.
• Corrective action and remediation shall be documented where required.
The Company’s Grievance Redressal Policy is the broader mechanism for workplace, human-rights and stakeholder concerns, while POSH and Whistleblower mechanisms apply to matters within their specific scope. -
18. Remediation and Corrective Action
• Where MBRPL causes or contributes to an adverse human-rights impact, the Company shall take appropriate steps to stop or prevent the impact and provide or cooperate in legitimate remediation.
• Where MBRPL is directly linked to an impact through a business relationship, the Company shall use appropriate leverage and risk-response measures.
• Corrective actions shall have assigned owners and target dates where appropriate.
• Material or repeated issues shall be escalated to Senior Management and/or the Board as appropriate.
• Supplier suspension, corrective-action plans or disengagement may be applied where risks cannot be adequately mitigated. - 19. Governance and Responsibilities
| Role | Responsibility |
|---|---|
| Board of Directors | Approve the Policy; provide oversight; review significant human-rights risks and material escalations. |
| Senior Management | Provide resources; integrate human-rights controls into business processes; review performance and corrective actions. |
| Compliance Officer | Maintain the Policy; coordinate human-rights due diligence; review risk assessments; monitor grievances and escalations; maintain audit evidence. |
| HR | Maintain recruitment, age verification, employment, remuneration, working-hours, training and worker-welfare controls. |
| Procurement / Sourcing | Apply supplier due diligence; identify human-rights risks; obtain supporting documentation; escalate red flags. |
| EHS / Operations | Identify and control workplace hazards; maintain safety controls and incident records. |
| Security | Implement lawful, proportionate security practices and report human-rights concerns. |
| Employees / Contractors | Follow Company policies; complete training; report concerns and cooperate with investigations without retaliation. |
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20. Training and Awareness
• Relevant employees shall receive training on this Policy and their human-rights responsibilities.
• Training shall cover child labour, forced labour, discrimination, harassment, human trafficking, freedom of association, health and safety, grievance reporting and non-retaliation as relevant to the role.
• Procurement, sourcing, HR, security, compliance and management personnel shall receive role-specific awareness.
• Training records shall be maintained. -
21. Records and Evidence
• Human-rights risk assessments and reviews.
• Supplier/business-partner due-diligence records relevant to human-rights risk.
• Age-verification and employment records, where applicable.
• Training and awareness records.
• Grievance, investigation, corrective-action and remediation records, subject to confidentiality.
• Audit, inspection and monitoring records.
• Management review and policy review records.
Records supporting applicable RJC COP requirements shall be retained in accordance with the Company’s document-retention controls and applicable law; RJC COP 2024 COP 2.5 requires records to be retained for at least five years unless a longer period is required. -
22. Monitoring, Review and Continuous Improvement
• Human-rights risks and the effectiveness of controls shall be monitored periodically.
• Material incidents, grievances, audit findings, supplier concerns and regulatory changes shall be reviewed and used to improve controls.
• This Policy shall be reviewed at least annually.
• Additional review shall be performed following material changes to operations, significant incidents or allegations, major changes in supply chains, legal/regulatory changes, audit findings or other relevant triggers.
• Changes shall be approved through the Company’s document-control and governance process. -
23. Related Controlled Documents
• Supply Chain Policy
• AML/CFT Policy
• KYC / Due Diligence SOP
• Risk Mitigation Plan
• Non-Discrimination Policy
• POSH Policy
• Whistleblower Policy
• Grievance Redressal Policy
• Health & Safety Risk Assessment Policy
• Staff Safety & Training Policy
• Security Risk Assessment Policy - 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.