Natural Resources Use & Environmental Management Policy
- 1. Document Control
| Company Name | Mahavir Bullion & Refinery Private Limited | Policy No. | MBR/NR-EMP/12 |
| Policy Title | Natural Resources Use & Environmental Management 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”) recognises that responsible use of natural resources is essential to sustainable operations and long-term business continuity. Refinery and bullion operations consume water, energy, fuels and chemicals and may generate wastes, effluents and emissions. Therefore, efficient resource use, pollution prevention and regulatory compliance are integral to the Company’s environmental management approach.
This Policy is based on the Company’s existing Natural Resources Use & Environmental Management Policy and retains its refinery-specific controls, including water, energy, chemical use, emissions, waste, monitoring, supplier expectations and continuous improvement. It has been updated to reflect RJC COP 2024. -
3. Purpose
• Reduce consumption and wastage of natural resources including water, electricity and fuels.
• Promote efficient processes, clean technologies and responsible resource use.
• Reduce emissions, effluents and the environmental footprint of refinery operations.
• Prevent pollution and comply with applicable environmental laws, permits and consent conditions.
• Monitor resource consumption and environmental performance through measurable KPIs.
• Create awareness, accountability and continuous improvement across the workforce. -
4. Scope
• All refinery operations, including melting, aqua regia, fire assay, scrubbing, filtration and dust collection.
• Laboratory operations.
• Office and administrative facilities.
• Utility systems including DG sets, compressors, HVAC and water-purification systems.
• Employees, contractors, suppliers, transporters and visitors, where relevant to environmental controls.
• All significant natural resources, wastes and emissions associated with Company premises and operations. - 5. RJC COP 2024 Requirements Addressed
| RJC Provision | Requirement / Expectation | Company Control |
|---|---|---|
| COP 25 – Environmental Management | Environmental management appropriate to significant risks and impacts. | Environmental policy, legal register, risk assessment, monitoring, responsibilities and improvement actions. |
| COP 27 – Wastes & Emissions | Identify and responsibly manage significant wastes and emissions. | Waste/emission inventory, manifests, monitoring, mitigation hierarchy and records. |
| COP 27.4–27.5 | Work towards renewable energy and annually quantify/document Scope 1 & 2 GHG emissions and material energy consumption by source. | Energy/fuel records, annual GHG calculation and improvement planning. |
| COP 28 – Use of Natural Resources | Manage relevant natural-resource use, including water and natural capital where significant. | Water/energy monitoring, resource-efficiency measures and impact-based controls. |
| COP 2 | Management system, responsibilities, records and review supporting COP implementation. | Board approval, assigned owners, records, training, internal review and corrective action. |
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6. Resource Management Governance
| Role | Responsibility |
|---|---|
| Board of Directors | Provide oversight of environmental and sustainability performance and review material resource-utilisation and improvement plans. |
| Senior Management | Ensure implementation and provide resources/budget for appropriate efficiency initiatives. |
| EHS / Environmental Officer | Monitor resource consumption; maintain environmental records and consent compliance; oversee waste minimisation and pollution-control equipment. |
| Compliance Officer | Monitor compliance evidence, controlled documents, corrective actions and RJC audit readiness. |
| Department Heads | Ensure optimal use of utilities and materials and review department-level resource consumption. |
| Employees | Follow resource-conservation practices and report wastage, leaks, spills or environmental hazards. |
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7. Principles for Natural Resource Use
• Reduce wastage of resources.
• Reuse materials wherever feasible.
• Recycle scrap, waste streams and treated water where feasible and lawful.
• Recover usable materials from waste streams where feasible.
• Replace high-impact materials with efficient alternatives where practical.
• Prioritise prevention and reduction before disposal.
• Use monitoring data to identify improvement opportunities.
- 8. Water Management
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8.1 Water Use in Refinery
• Cooling systems
• Scrubber units
• Cleaning of equipment and floors
• Employee welfare, sanitation and drinking -
8.2 Water Efficiency Measures
• Flow restrictors on taps where appropriate.
• Regular leak inspections and prompt repair.
• Closed-loop water systems in scrubbers where feasible.
• Scheduled cleaning instead of continuous water flow where feasible.
• Monthly water-consumption KPIs and trend review. -
8.3 Water Quality and Discharge
• Monitor relevant effluent parameters such as pH, TDS and heavy metals as required by consent conditions and applicable law.
• Use an ETP where applicable to the operation and consent conditions.
• Apply a zero-discharge approach where feasible and legally/technically appropriate.
• Maintain records of water quality testing, treatment performance and lawful discharge/disposal.
- 9. Energy Management
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9.1 Energy Consumption Areas
• Furnaces and melting units
• Fume-extraction systems
• HVAC systems
• Compressors and pumps
• Lighting and other electrical equipment -
9.2 Energy Efficiency Measures
• Use high-efficiency motors and equipment where feasible.
• Preventive maintenance of furnaces and utilities.
• LED lighting and efficient electrical systems.
• Insulation of hot surfaces where appropriate.
• Shutdown of idle equipment.
• Maintain energy/electricity logs and review trends. -
9.3 Fuel Use
• Monitor DG-set fuel consumption monthly.
• Maintain DG-set operating and maintenance records.
• Use fuel efficiently and investigate abnormal consumption.
• Maintain applicable emission and compliance records. -
9.4 Greenhouse Gas and Energy Reporting
• Quantify and document annual Scope 1 and Scope 2 greenhouse-gas emissions using a documented methodology.
• Record material energy consumption by source.
• Identify opportunities for energy efficiency and renewable-energy use.
• Where additional RJC requirements apply to the Company, maintain the relevant plan, verification and reporting evidence.
- 10. Chemical Resource Management
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10.1 Key Chemicals Used
• Hydrochloric acid
• Nitric acid
• Aqua regia
• Fluxes, reagents and laboratory chemicals -
10.2 Minimisation and Substitution
• Optimise acid mixtures and process quantities to reduce unnecessary consumption.
• Recover or control nitric fumes through appropriate scrubber systems.
• Use sealed/appropriate chemical storage to minimise evaporation and leakage.
• Maintain chemical inventory and FIFO controls where appropriate.
• Evaluate safer or lower-impact alternatives where technically feasible. -
10.3 Safe Handling
• Maintain current SDS/MSDS and make them accessible in relevant work areas.
• Use acid-resistant PPE and other controls required by the risk assessment.
• Provide secondary containment for relevant chemical storage.
• Control spills through established spill-response procedures.
• Maintain chemical inventories and inspection records.
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11. Waste Management
• Identify and classify hazardous and non-hazardous wastes generated by refinery and support activities.
• Segregate wastes at source and prevent incompatible waste mixing.
• Apply the waste hierarchy: reduce, reuse, recycle and recover where feasible before disposal.
• Use authorised vendors/transporters for regulated waste disposal.
• Maintain manifests, disposal receipts and other evidence required by applicable law.
• Monitor waste quantities and investigate opportunities for reduction.
- 12. Emissions and Air Quality Management
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12.1 Air Emission Sources
• Furnace fumes
• Acid vapours from aqua regia
• DG-set emissions
• Dust from relevant processing areas -
12.2 Control Measures
• Wet scrubbers for acid vapours where applicable.
• Regular monitoring of relevant air-emission parameters as required by consent conditions.
• Stack monitoring as applicable under MPCB requirements.
• DG-set emission compliance records where applicable.
• Maintenance of pollution-control equipment. -
12.3 Indoor Air Quality
• Adequate ventilation.
• Fume hoods in chemical areas where required.
• Dust-collection systems in filing/grinding areas where applicable.
• Prompt investigation of abnormal fumes, odours or air-quality concerns.
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13. Noise, Odour and Nuisance Control
• Acoustic enclosures or equivalent controls for DG sets where required.
• Hearing protection in designated high-noise areas.
• Preventive maintenance of scrubbers and pollution-control equipment to control odour.
• Investigate complaints or abnormal nuisance conditions and implement corrective actions. -
14. Natural Capital, Land and Soil
For activities within Company premises, MBRPL shall consider whether operations create significant adverse impacts on land, soil or related natural capital. Where significant impacts are identified, the Company shall establish appropriate controls, monitoring and corrective actions.
• Identify risks of soil or land contamination from chemicals, fuels, waste and spills.
• Maintain suitable chemical and waste storage controls and secondary containment.
• Investigate significant spills or contamination and implement corrective action.
• Consider relevant land users, neighbouring stakeholders and regulatory authorities where an impact may affect them.
• Maintain records of incidents, remediation and monitoring where applicable. -
15. Environmental Emergency Preparedness
• Maintain spill-response and environmental-emergency procedures appropriate to refinery hazards.
• Maintain suitable spill kits, containment materials and emergency equipment.
• Train relevant employees on chemical spills, releases, fire and other environmental emergencies.
• Investigate significant environmental incidents and implement corrective/preventive actions.
• Coordinate environmental emergency arrangements with the Emergency Evacuation Plan and Health & Safety Risk Assessment Policy. -
16. Training and Awareness
• Efficient use of water and energy.
• Waste minimisation and segregation.
• Chemical handling and spill response.
• Environmental emergency preparedness.
• Applicable MPCB/environmental compliance requirements.
• Resource-conservation and pollution-prevention practices.
• Role-specific environmental responsibilities.
Training records shall identify the training topic, date, participants and trainer/competent person, as applicable. - 17. Monitoring and Measurement
| Indicator / Record | Frequency / Control |
|---|---|
| Water consumption | Monthly monitoring and trend review |
| Electricity / energy consumption | Monthly monitoring and annual consolidation |
| DG-set fuel consumption | Monthly log / operational record |
| Waste generation | As generated, with periodic trend review |
| Emission test / stack reports | As required by consent and applicable requirements |
| Scrubber performance | Routine inspection / maintenance records |
| ETP performance, if applicable | As required by process, consent and applicable law |
| Scope 1 & Scope 2 GHG emissions | Annual quantification and documented methodology |
- Environmental performance results shall be reviewed by responsible management and significant deviations shall result in investigation and corrective action.
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18. Supplier and Contractor Expectations
• Provide environmentally appropriate materials and comply with applicable requirements.
• Provide current SDS/MSDS for relevant chemicals.
• Comply with hazardous-waste handling and disposal requirements.
• Use authorised waste-management and transport arrangements where required.
• Transporters and service providers shall comply with applicable environmental and safety requirements.
• Material environmental non-compliance may result in corrective action, suspension or disengagement subject to the applicable contract and Company procedure. -
19. Legal and Regulatory Compliance
The Company shall maintain a current legal and regulatory compliance register covering applicable environmental requirements, permits, consent conditions and authorisations. The original Policy identifies the Environmental Protection Act, 1986; Water (Prevention & Control of Pollution) Act, 1974; Air (Prevention & Control of Pollution) Act, 1981; Hazardous Waste requirements; and MPCB Consent to Operate/authorisation conditions as relevant frameworks. The Company shall update its legal register when applicable legislation or consent conditions change. -
20. Records and Document Retention
• MPCB consents, authorisations and compliance submissions.
• Water and energy usage logs.
• Fuel records.
• Calibration and monitoring records.
• Hazardous-waste manifests and disposal receipts.
• Air, water and effluent test reports.
• Chemical inventory and SDS/MSDS records.
• Scrubber and pollution-control equipment records.
• Environmental training records.
• Environmental audit and inspection reports.
• GHG calculations and energy-consumption records.
• Corrective-action and incident records.
Records shall be retained in accordance with applicable law and the Company’s document-retention controls. -
21. Policy Breach and Corrective Action
• Warning, corrective instruction or retraining for appropriate cases.
• Corrective and preventive action with assigned responsibility and target dates.
• Suspension from specific operations where necessary to control risk.
• Supplier or contractor corrective action, suspension or disengagement where appropriate.
• Escalation to regulatory authorities where legally required.
• Management review of significant or repeated non-compliance. -
22. Continuous Improvement
• Set annual environmental and resource-efficiency objectives where appropriate.
• Review water, energy, waste, emissions and GHG performance indicators.
• Conduct internal reviews and support external audits/assessments.
• Evaluate initiatives such as solar/renewable energy, recycling, rainwater harvesting and process-efficiency improvements where feasible.
• Encourage employee suggestions for conservation and pollution prevention.
• Use monitoring, incidents, complaints and audit findings to improve controls. -
23. Policy Review and Approval
• This Policy shall be reviewed at least annually.
• Additional review shall occur when operations, processes, equipment or significant resource use changes; environmental incidents occur; applicable laws/consent conditions change; RJC requirements change; audit findings identify gaps; or other material environmental risks arise.
• Changes shall be approved through the Company’s document-control and governance process. -
24. Related Controlled Documents
• Health & Safety Risk Assessment Policy
• Staff Safety & Training Policy
• Emergency Evacuation Plan
• Risk Mitigation Plan
• Responsible Gold, Silver & PGM Sourcing Policy
• Chemical / Hazardous Substance procedures
• Waste Management / Hazardous Waste procedures - 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.