Non-Discrimination Policy & Standard Operating Procedure
- 1. Document Control
| Company Name | Mahavir Bullion & Refinery Private Limited | Policy No. | MBR/NDP-SDP/13 |
| Policy Title | Non-Discrimination Policy & Standard Operating Procedure | 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 a workplace where employees and workers are treated fairly, respectfully and without unlawful discrimination. The Company’s original Non-Discrimination Policy and SOP establishes controls covering recruitment, promotion, working conditions, compensation, disciplinary decisions, harassment and bullying, reasonable accommodation, grievance handling, supplier expectations, training, records and monitoring. This revised version preserves those controls while updating the document to the RJC COP 2024 structure. RJC COP 2024 identifies COP 22 as Non-Discrimination and COP 23 as Diversity, Equity and Inclusivity. RJC defines non-discrimination as employees being judged on their ability to perform a job, without exclusion or preference on other grounds, except distinctions based on inherent job requirements. -
3. Purpose
• Prevent discrimination and unequal treatment in employment and workplace practices.
• Establish clear responsibilities for management, HR and employees.
• Provide fair and transparent recruitment, promotion, development, remuneration and disciplinary processes.
• Prevent harassment, bullying and discriminatory behaviour.
• Provide reasonable accommodation where appropriate.
• Provide accessible reporting, investigation, corrective-action and non-retaliation mechanisms.
• Extend relevant non-discrimination expectations to suppliers and business partners.
• Support RJC COP 2024 compliance and continuous improvement. -
4. Scope
• All permanent, temporary, outsourced and contractual employees and workers.
• Directors, management, supervisors and HR personnel.
• Job applicants and candidates during recruitment and selection.
• Contractors, job-workers and service providers where Company controls or influences relevant working conditions.
• Suppliers and business partners to the extent relevant to the Company’s responsible-business expectations.
• All Company locations, departments, shifts and employment-related processes.
- 5. RJC COP 2024 Requirements Addressed
| RJC Provision | Requirement / Expectation | Company Control |
|---|---|---|
| COP 22 – Non-Discrimination | No discrimination in employment and working conditions; decisions based on ability and legitimate job requirements. | Recruitment, promotion, compensation, training, working-condition and disciplinary controls. |
| COP 23 – Diversity, Equity & Inclusivity | Promote diversity, equity and inclusion and identify relevant barriers or opportunities. | Inclusive workplace practices, reasonable accommodation, awareness and monitoring. |
| COP 18 | Harassment, grievance procedures and non-retaliation. | Reporting channels, investigation, confidentiality, corrective action and non-retaliation. |
| COP 6 | Respect human rights and address adverse human-rights impacts. | Human Rights Policy and related grievance/remedy mechanisms. |
| COP 2 | Policy and management systems. | Board approval, responsibilities, training, records, monitoring and annual review. |
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6. Legal and Regulatory Framework
The original Company document identifies the following frameworks as relevant: Constitution of India, including Articles 14, 15, 16 and 21; Equal Remuneration Act, 1976; Rights of Persons with Disabilities Act, 2016; Sexual Harassment of Women at Workplace Act (POSH), 2013; Factories Act, 1948; applicable Shops & Establishments requirements; ILO Convention C111; and the UN Guiding Principles on Business and Human Rights. The Company shall maintain and periodically update its legal and regulatory register to reflect applicable current law.
This Policy does not replace the Company’s separate POSH Policy or other statutory procedures. Where a matter falls under a specific statutory mechanism, that mechanism shall apply. - 7. Definitions
| Term | Meaning |
|---|---|
| Discrimination | Any distinction, exclusion or preference based on a protected or otherwise impermissible characteristic that impairs equality of opportunity or treatment. |
| Harassment | Unwelcome physical, verbal or non-verbal conduct that demeans, humiliates, intimidates or creates a hostile or offensive working environment. |
| Equal Opportunity | Fairness in employment-related decisions based on legitimate job requirements, skills, qualifications, capability and performance. |
| Reasonable Accommodation | Appropriate adjustments or support that enable a person with a disability or genuine specific need to perform work without undue discrimination. |
| Retaliation | Adverse treatment, threat, penalty or other negative action because a person raised a concern, participated in an investigation or exercised a protected right. |
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8. Non-Discrimination Commitment
• MBRPL shall not tolerate discrimination in recruitment, hiring, promotion, transfer, training, compensation, benefits, working conditions, performance management, discipline or termination.
• Employment decisions shall be based on objective job requirements, qualifications, capability, performance and legitimate business considerations.
• The Company shall promote a workplace based on dignity, respect, fairness and equal opportunity.
• The Company shall not tolerate discriminatory language, behaviour, intimidation, exclusion or targeted unfair treatment.
• Employees shall be able to raise concerns without fear of retaliation. -
9. Protected Characteristics and Fair Treatment
• Gender, caste, religion, ethnicity or social background.
• Marital status or age.
• Disability.
• Sexual orientation.
• Pregnancy.
• Language.
• Political affiliation or other status where protected by applicable law.
• Any other characteristic protected by applicable law.
The Company’s objective is not merely to avoid overt discrimination but to ensure that employment decisions and workplace practices do not create unjustified barriers or unequal treatment.
- 10. Non-Discrimination in Employment Practices
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10.1 Recruitment & Hiring
• Job requirements shall be based on skills, qualifications and legitimate experience requirements.
• No discriminatory bias based on appearance, gender, caste, religion, age or social background.
• Shortlisting criteria shall be consistent and transparent.
• Interviewers/panels shall be appropriately briefed to avoid discriminatory or biased decision-making.
• Recruitment records shall be maintained as required. -
10.2 Promotions, Transfers & Development
• Decisions shall be based on performance, capability, qualifications and legitimate business requirements.
• Employees shall have fair access to training and career development.
• Performance reviews shall be applied consistently and monitored for potential bias. -
10.3 Working Conditions
• Equal access to welfare facilities, PPE, canteen, rest areas and relevant workplace benefits.
• Modified duties or ergonomic support shall be considered where appropriate.
• Cultural and religious practices shall be respected subject to safety, legal and operational requirements. -
10.4 Compensation & Benefits
• Equal pay for equal or comparable work, subject to applicable law and legitimate factors.
• No discriminatory differentiation based on gender, caste or other protected characteristics.
• Compensation structures and criteria should be transparent and consistently applied. -
10.5 Termination & Disciplinary Action
• Decisions shall be based on documented conduct, performance or legitimate business grounds.
• Termination and disciplinary decisions shall be documented.
• The Company shall apply safeguards against discriminatory dismissal or disciplinary treatment.
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11. Prevention of Harassment and Bullying
• Derogatory remarks or discriminatory comments.
• Mocking a person’s dialect, accent, appearance or background.
• Unwelcome jokes, pranks or innuendos.
• Physical intimidation or threatening behaviour.
• Social exclusion intended to demean or disadvantage a person.
• Targeted unfair treatment or repeated hostile behaviour.
Employees are encouraged to report such behaviour through the applicable grievance, Whistleblower or POSH mechanism. Sexual-harassment complaints shall be handled through the statutory POSH process and the Company’s POSH Policy. -
12. Reasonable Accommodation
MBRPL shall consider reasonable adjustments for persons with disabilities and other genuine workplace needs, subject to applicable law, operational feasibility and safety requirements.
• Persons with disabilities.
• Pregnant women and nursing mothers.
• Employees with medical restrictions where supported by appropriate documentation, where required.
• Employees requiring flexible schedules for genuine needs, where reasonably practicable.
Examples may include modified workstations, adjusted duties, additional breaks, accessible facilities, support equipment or other suitable adjustments. -
13. Grievance and Reporting Mechanism
Employees may report discrimination through the HR Manager, Compliance Officer, Department Head, Grievance Redressal Mechanism, Whistleblower channel or other applicable reporting channel. Reports may be verbal or written and shall be handled confidentially to the extent reasonably possible.
• Reports shall be acknowledged and appropriately screened.
• A suitably independent and competent investigator shall be appointed, considering conflicts of interest.
• Relevant statements, documents and other evidence shall be collected.
• Interviews shall be conducted where necessary.
• Findings shall be documented objectively.
• Corrective actions shall be recommended and tracked.
• The complainant shall be informed of the outcome to the extent appropriate and lawful.
• No retaliation shall be permitted against a person who raises a concern in good faith or participates in an investigation.
The Company’s broader Grievance Redressal Policy governs the general grievance mechanism, while the POSH Policy and Whistleblower Policy apply to matters within their specific scope. The RJC COP 2024 framework places grievance procedures and non-retaliation under COP 18. - 14. SOP – Handling a Discrimination Complaint
| Step | Procedure | Responsible Person / Function |
|---|---|---|
| 1. Receive | Receive verbal or written complaint through an approved channel; record the basic facts and date received. | HR / Compliance / Designated recipient |
| 2. Acknowledge | Acknowledge receipt and explain the applicable process and confidentiality limitations. | HR / Compliance |
| 3. Screen | Determine whether the complaint concerns discrimination, harassment, POSH, whistleblowing or another process and assess urgency/safety. | HR / Compliance |
| 4. Conflict Check | Confirm the investigator has no actual or perceived conflict of interest. | HR / Senior Management |
| 5. Investigate | Collect statements, documents, relevant HR records and other evidence; interview relevant persons where necessary. | Assigned Investigator |
| 6. Assess | Assess evidence objectively against applicable policy, law and employment requirements. | Assigned Investigator / HR |
| 7. Findings | Prepare a documented findings report and recommended actions. | Assigned Investigator |
| 8. Corrective Action | Implement proportionate corrective/preventive action, including training, counselling, process changes or disciplinary action where justified. | Management / HR |
| 9. Communicate | Communicate appropriate outcome information to the complainant without breaching confidentiality of other persons. | HR / Compliance |
| 10. Close & Monitor | Close the case, retain records securely and monitor agreed corrective actions for effectiveness. | HR / Compliance |
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15. Supplier Non-Discrimination Expectations
• Suppliers are expected to uphold non-discrimination in recruitment and operations.
• Relevant suppliers may be required to provide declarations or evidence of compliance.
• The Company may assess labour practices through due diligence, documentation review or other appropriate assessment.
• Suppliers shall address material findings related to discrimination.
• Failure to address significant non-compliance may result in a Corrective Action Plan, temporary suspension or termination of the relationship, subject to risk assessment and contractual arrangements.
These expectations are consistent with the original Company SOP’s supplier controls. -
16. Training and Awareness
• Anti-discrimination training at least annually for relevant employees.
• Induction training for new employees.
• Sensitivity and inclusion awareness.
• Unconscious-bias awareness for relevant recruitment/management personnel.
• Gender equality and respect in the workplace.
• Reporting channels and non-retaliation.
• Role-specific training for HR, managers, supervisors and investigators.
Training attendance and completion records shall be maintained. -
17. Monitoring and Continuous Improvement
• Annual workplace culture or employee-feedback surveys where implemented.
• Review recruitment and promotion trends for potential inequity or recurring concerns.
• HR data analysis for relevant equity patterns, subject to privacy and confidentiality requirements.
• Supplier compliance checks where relevant.
• Review of complaints, findings and corrective actions for recurring issues.
• Periodic review of policies and employment practices.
Material trends or repeated concerns shall be escalated to Senior Management and corrective action shall be tracked. -
18. Records and Document Retention
• Complaint registers.
• Investigation reports and evidence records, subject to confidentiality.
• Corrective and preventive actions.
• Training attendance and completion records.
• Supplier non-discrimination declarations and due-diligence evidence.
• Workplace assessment or survey reports.
• Policy review and monitoring records.
The original SOP specifies a minimum 10-year retention period for these records. This period shall be followed where legally and operationally applicable, unless a longer period is required. Confidential records shall be access-controlled. -
19. Policy Breach and Disciplinary Action
• Counselling, corrective instruction or written warning, where appropriate.
• Suspension or other disciplinary action in accordance with Company rules and applicable law.
• Reduction or reassignment of responsibilities where justified.
• Termination of employment for serious or substantiated misconduct, in accordance with applicable law and Company procedure.
• Legal or regulatory reporting where required.
• For suppliers: Corrective Action enforcement, removal from the approved supplier list, suspension or termination where justified. - 20. Responsibilities
| Role | Responsibility |
|---|---|
| Board of Directors | Approve the Policy and provide oversight of material workforce and human-rights risks. |
| Senior Management | Provide resources, enforce implementation and review significant concerns and trends. |
| HR | Implement fair employment practices, maintain employee records, receive complaints and coordinate investigations. |
| Compliance Officer | Monitor policy implementation, support investigations, maintain audit evidence and escalate material issues. |
| Managers / Supervisors | Apply fair workplace practices, prevent discriminatory behaviour and escalate concerns promptly. |
| Employees / Workers | Treat colleagues respectfully, avoid discriminatory conduct, report concerns and cooperate with investigations. |
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21. Policy Review
• This Policy and SOP shall be reviewed at least annually.
• Additional review shall occur following significant incidents, material complaints, RJC audit findings, changes in applicable law, organisational changes or identified gaps in effectiveness.
• Changes shall be approved through the Company’s document-control and governance process. -
22. Related Controlled Documents
• Human Rights Policy
• Grievance Redressal Policy
• Whistleblower Policy
• POSH Policy
• Staff Safety & Training Policy
• Responsible Gold, Silver & PGM Sourcing Policy
• Employee Handbook / HR Rules - 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.