Whistleblower & Ethics Reporting Policy

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Whistleblower & Ethics Reporting Policy

Company NameMahavir Bullion & Refinery Private LimitedPolicy No.MBR/WERP/09
Policy TitleWhistleblower & Ethics Reporting PolicyRevision Date01/04/2026
Effective Date01/04/2025Review Date01/04/2027
Approved ByBoard of DirectorsApproval Date01/04/2026
Policy OwnerCompliance Officer / Senior ManagementClassificationControlled Document
Applicable StandardRJC COP 2024Next ReviewAnnually
RequirementPolicy ResponseEvidence
COP 2 – Policy & Management SystemsMaintains a documented reporting mechanism, responsibilities, records, communication, monitoring and review.Approved policy, registers, communications and review records.
COP 18.5(a) – CommunicationCommunicates the complaints/grievance mechanism to workers, including new workers at recruitment.Induction, notices, training, policy acknowledgement.
COP 18.5(b) – Non-retaliationWorkers may submit grievances without penalty or retaliation.Non-retaliation commitment, investigation records, corrective action.
RequirementPolicy ResponseEvidence
COP 2 – Policy & Management SystemsDocumented reporting mechanism, responsibilities, records, communication, monitoring and review.Approved policy, registers, communications and review records.
COP 18.5(a) – CommunicationCommunicates the complaints/grievance mechanism to workers, including new workers at recruitment.Induction, notices, training, policy acknowledgement.
COP 18.5(b) – Non-retaliationWorkers may submit grievances without penalty or retaliation.Non-retaliation commitment, investigation records, corrective action.
COP 18.5(c) – Worker representativeAllows involvement of a worker representative where requested by the worker.Case records and procedure.
TermDefinition
WhistleblowerA person who raises a concern or makes a protected disclosure in good faith.
Protected DisclosureA communication made in good faith concerning suspected unethical conduct, fraud, misconduct, legal or policy violations, or other reportable matters.
SubjectThe person or entity against whom a report is made.
Good FaithA genuine belief that the information reported raises a legitimate concern, even if the concern is ultimately not substantiated.
RetaliationAny adverse action or threat of adverse action because a person raised a concern, participated in an investigation or otherwise used the reporting mechanism.
CategoryExamples
Financial MisconductFraud, embezzlement, theft, misuse of funds, over/under-invoicing, falsification of records.
Ethical MisconductBribery, corruption, kickbacks, facilitation payments, conflicts of interest and improper procurement favouritism.
Human Rights & LabourChild labour, forced labour, discrimination, harassment, unsafe working conditions, suppression of grievances or other human-rights concerns.
EnvironmentalIllegal waste disposal, pollution, hazardous-chemical misuse or material breach of environmental requirements.
Responsible SourcingMisrepresentation of precious-metal origin, illegal sourcing, conflict/high-risk sourcing concerns, or non-compliance with responsible-sourcing requirements.
Regulatory / ComplianceSuspected violation of applicable PMLA, GST, Customs, DGFT, BIS or other applicable requirements, and RJC COP requirements.
Security / Asset MisconductTheft, pilferage, misappropriation, tampering, unauthorised access or serious security breaches.
Health, Safety & Workplace ConductSerious safety violations, sexual harassment or other workplace violence/harassment. Matters specifically governed by the POSH process shall be routed to the designated POSH mechanism as applicable.
StageRequirement
ReceiptReport is received through an approved channel and recorded securely.
AcknowledgementWhere contact details are available, acknowledge receipt within 7 working days.
Preliminary ScreeningDetermine scope, seriousness, conflicts of interest, immediate protection needs and whether another specialist procedure applies.
Investigation PlanningDefine investigator(s), scope, evidence required, confidentiality controls and target timeline.
InvestigationReview relevant documents, records, CCTV/logs where appropriate, transactions and witness/subject statements.
FindingsDocument allegations, evidence considered, findings and whether allegations are substantiated, partially substantiated or unsubstantiated.
Corrective ActionWhere appropriate, implement disciplinary, control, remediation, training, process or other corrective actions.
Closure & CommunicationClose the case with appropriate communication to the reporter, subject and management, while protecting confidentiality and legal restrictions.
MonitoringTrack corrective actions to closure and review whether retaliation or recurrence risks remain.
RoleResponsibilities
Board / Senior ManagementApprove policy; oversee significant matters; ensure independence/resources where required.
Compliance OfficerAdminister reporting mechanism, maintain register, coordinate screening/investigations and monitor corrective actions.
Whistleblower Committee / InvestigatorsConduct impartial assessments/investigations, protect confidentiality and document findings.
HRSupport employee-related cases, disciplinary processes and protection measures while maintaining confidentiality.
Employees & StakeholdersRaise genuine concerns in good faith and cooperate honestly with investigations.
ManagersDo not obstruct reporting; escalate concerns received through management channels and prevent retaliation.
Concern TypePrimary MechanismNote
Ethics, fraud, bribery, compliance, sourcing and serious misconductWhistleblower & Ethics Reporting PolicyUse this mechanism where protected disclosure is appropriate.
General workplace grievanceGrievance Redressal PolicyFollow the general grievance process.
Sexual harassment covered by POSH lawPOSH / Internal Committee processStatutory procedure and timelines apply.
Human-rights concernsHuman Rights / Grievance mechanismWhistleblower route remains available where appropriate.
Immediate safety emergencyEmergency / Security / EHS reportingDo not wait for the whistleblower investigation process.
Prepared ByReviewed & Approved By
Compliance OfficerDirector
Rushikesh Rajendra DeshmukhJitendra Panditrao Deshmukh
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