Whistleblower & Ethics Reporting Policy
- 1. Document Control
| Company Name | Mahavir Bullion & Refinery Private Limited | Policy No. | MBR/WERP/09 |
| Policy Title | Whistleblower & Ethics Reporting 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) is committed to maintaining high standards of integrity, ethics, transparency and accountability. The Company provides a protected reporting mechanism through which employees and relevant external stakeholders can raise genuine concerns about misconduct, violations of law, Company policy or responsible-business requirements.
This Policy is based on the Company's original Whistleblower & Ethics Reporting Policy, while updating the RJC references to COP 2024. RJC COP 2024 COP 18.5 requires the complaints and grievance mechanism to be actively communicated to workers, permit workers to raise grievances without penalty or retaliation, and allow a worker to involve a workers' representative if requested. -
3. Purpose
• Provide a safe, confidential and accessible channel for reporting genuine concerns.
• Encourage good-faith reporting without fear of retaliation.
• Enable early identification of fraud, bribery, corruption, human-rights, labour, environmental, safety, sourcing and compliance concerns.
• Ensure reports are screened, investigated and resolved fairly and proportionately.
• Protect whistleblowers, witnesses and other participants from retaliation.
• Support the Company's RJC COP 2024 management and grievance framework. -
4. Scope
This Policy applies to permanent, temporary and contractual employees, trainees, apprentices, Board members, senior management, department heads, job workers, consultants, contractors, security personnel, suppliers, service providers, logistics partners and other external stakeholders interacting with the Company, where the reporting channel is made available to them. - 5. RJC COP 2024 Alignment
| Requirement | Policy Response | Evidence |
|---|---|---|
| COP 2 – Policy & Management Systems | Maintains a documented reporting mechanism, responsibilities, records, communication, monitoring and review. | Approved policy, registers, communications and review records. |
| COP 18.5(a) – Communication | Communicates the complaints/grievance mechanism to workers, including new workers at recruitment. | Induction, notices, training, policy acknowledgement. |
| COP 18.5(b) – Non-retaliation | Workers may submit grievances without penalty or retaliation. | Non-retaliation commitment, investigation records, corrective action. |
| Requirement | Policy Response | Evidence |
|---|---|---|
| COP 2 – Policy & Management Systems | Documented reporting mechanism, responsibilities, records, communication, monitoring and review. | Approved policy, registers, communications and review records. |
| COP 18.5(a) – Communication | Communicates the complaints/grievance mechanism to workers, including new workers at recruitment. | Induction, notices, training, policy acknowledgement. |
| COP 18.5(b) – Non-retaliation | Workers may submit grievances without penalty or retaliation. | Non-retaliation commitment, investigation records, corrective action. |
| COP 18.5(c) – Worker representative | Allows involvement of a worker representative where requested by the worker. | Case records and procedure. |
- 6. Definitions
| Term | Definition |
|---|---|
| Whistleblower | A person who raises a concern or makes a protected disclosure in good faith. |
| Protected Disclosure | A communication made in good faith concerning suspected unethical conduct, fraud, misconduct, legal or policy violations, or other reportable matters. |
| Subject | The person or entity against whom a report is made. |
| Good Faith | A genuine belief that the information reported raises a legitimate concern, even if the concern is ultimately not substantiated. |
| Retaliation | Any adverse action or threat of adverse action because a person raised a concern, participated in an investigation or otherwise used the reporting mechanism. |
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7. Policy Principles
• Confidentiality – information and identity are protected on a need-to-know basis, subject to law.
• Non-retaliation – good-faith reporters and participants are protected from adverse treatment.
• Impartiality – reports are assessed and investigated objectively.
• Accessibility – reporting channels should be practical and understandable to intended users.
• Fairness – the subject of a report will be treated fairly and given an opportunity to respond where appropriate.
• Proportionality – investigation and corrective action will be appropriate to the allegation and risk.
• Documentation – reports, decisions and actions are documented securely.
• No automatic presumption of guilt – a report is an allegation until assessed/investigated. - 8. Reportable Matters
| Category | Examples |
|---|---|
| Financial Misconduct | Fraud, embezzlement, theft, misuse of funds, over/under-invoicing, falsification of records. |
| Ethical Misconduct | Bribery, corruption, kickbacks, facilitation payments, conflicts of interest and improper procurement favouritism. |
| Human Rights & Labour | Child labour, forced labour, discrimination, harassment, unsafe working conditions, suppression of grievances or other human-rights concerns. |
| Environmental | Illegal waste disposal, pollution, hazardous-chemical misuse or material breach of environmental requirements. |
| Responsible Sourcing | Misrepresentation of precious-metal origin, illegal sourcing, conflict/high-risk sourcing concerns, or non-compliance with responsible-sourcing requirements. |
| Regulatory / Compliance | Suspected violation of applicable PMLA, GST, Customs, DGFT, BIS or other applicable requirements, and RJC COP requirements. |
| Security / Asset Misconduct | Theft, pilferage, misappropriation, tampering, unauthorised access or serious security breaches. |
| Health, Safety & Workplace Conduct | Serious 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. |
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9. Reporting Channels
• Whistleblower email: [TO BE COMPLETED – official corporate email].
• Sealed written complaint/drop-box: [TO BE COMPLETED – actual location].
• Direct reporting to the Compliance Officer.
• Direct reporting to the Managing Director or designated senior management representative.
• Reporting to a designated Whistleblower Committee member.
• Anonymous reports may be accepted where sufficient information is provided to permit meaningful assessment/investigation.
• Where a concern relates to the Compliance Officer or a Committee member, the report shall be escalated to an independent senior authority/Board-designated person.
The actual email address and physical reporting location must be completed before the Policy is issued as an operative controlled document; the original policy currently contained placeholders for both. - 10. Reporting Process
| Stage | Requirement |
|---|---|
| Receipt | Report is received through an approved channel and recorded securely. |
| Acknowledgement | Where contact details are available, acknowledge receipt within 7 working days. |
| Preliminary Screening | Determine scope, seriousness, conflicts of interest, immediate protection needs and whether another specialist procedure applies. |
| Investigation Planning | Define investigator(s), scope, evidence required, confidentiality controls and target timeline. |
| Investigation | Review relevant documents, records, CCTV/logs where appropriate, transactions and witness/subject statements. |
| Findings | Document allegations, evidence considered, findings and whether allegations are substantiated, partially substantiated or unsubstantiated. |
| Corrective Action | Where appropriate, implement disciplinary, control, remediation, training, process or other corrective actions. |
| Closure & Communication | Close the case with appropriate communication to the reporter, subject and management, while protecting confidentiality and legal restrictions. |
| Monitoring | Track corrective actions to closure and review whether retaliation or recurrence risks remain. |
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11. Investigation Timelines
The original Company Policy provides the following internal target timelines: acknowledgement within 7 working days, routine investigations within 45 days, and complex or multi-party investigations within 90 days.
• Routine cases – target completion within 45 days.
• Complex or multi-party cases – target completion within 90 days.
• Where a case cannot reasonably be completed within the target, document the reason, revised target and escalation/communication required.
• Statutory or specialist procedures, including POSH, shall follow their applicable legal timelines where those differ. -
12. Protection Against Retaliation
Retaliation against a person who raises a concern in good faith, provides information, acts as a witness, participates in an investigation or otherwise uses the reporting mechanism is prohibited. RJC COP 18.5 specifically requires workers to be able to raise grievances without penalty or retaliation.
• Termination or threatened termination
• Demotion or denial of legitimate benefits
• Unjustified salary/benefit reduction
• Harassment, intimidation or threats
• Unjustified disadvantageous transfer or work assignment
• Coercion or adverse treatment because of participation in an investigation
Alleged retaliation shall itself be treated as a reportable matter and investigated promptly. Persons found responsible may face disciplinary action. -
13. Confidentiality & Data Protection
• Identity of the whistleblower shall be protected to the extent reasonably possible and permitted by law.
• Information shall be shared only with persons who need it for assessment, investigation, legal compliance or corrective action.
• Case files shall be stored securely with controlled access.
• Investigators shall avoid unnecessary disclosure of sensitive information.
• Confidentiality breaches may result in disciplinary action, subject to applicable law and due process. -
14. Fair Treatment of the Subject
• A report shall not be treated as proof of wrongdoing.
• The subject shall be given a fair opportunity to respond where appropriate and consistent with investigation integrity.
• Investigators shall consider relevant evidence supporting and contradicting the allegation.
• Corrective/disciplinary action shall be based on findings and applicable Company procedures. -
15. False or Malicious Disclosures
Knowingly false or malicious allegations may result in disciplinary action in accordance with Company policy and applicable law. A good-faith report shall remain protected even where the allegation is ultimately not substantiated. -
16. Communication & Training
• Include the reporting mechanism in new-joiner induction.
• Provide periodic awareness training on reporting rights, confidentiality and non-retaliation.
• Display or communicate reporting channels in accessible locations/formats.
• Inform relevant contractors and suppliers of the mechanism where applicable.
• Train persons responsible for receiving or investigating reports on confidentiality, impartiality, non-retaliation and investigation procedures.
• Communicate any changes to reporting channels promptly.
RJC guidance emphasises that grievance mechanisms should be legitimate, accessible, communicated, rights-compatible, unbiased and equitable. - 17. Roles & Responsibilities
| Role | Responsibilities |
|---|---|
| Board / Senior Management | Approve policy; oversee significant matters; ensure independence/resources where required. |
| Compliance Officer | Administer reporting mechanism, maintain register, coordinate screening/investigations and monitor corrective actions. |
| Whistleblower Committee / Investigators | Conduct impartial assessments/investigations, protect confidentiality and document findings. |
| HR | Support employee-related cases, disciplinary processes and protection measures while maintaining confidentiality. |
| Employees & Stakeholders | Raise genuine concerns in good faith and cooperate honestly with investigations. |
| Managers | Do not obstruct reporting; escalate concerns received through management channels and prevent retaliation. |
- 18. Interaction with Other Reporting Mechanisms
| Concern Type | Primary Mechanism | Note |
|---|---|---|
| Ethics, fraud, bribery, compliance, sourcing and serious misconduct | Whistleblower & Ethics Reporting Policy | Use this mechanism where protected disclosure is appropriate. |
| General workplace grievance | Grievance Redressal Policy | Follow the general grievance process. |
| Sexual harassment covered by POSH law | POSH / Internal Committee process | Statutory procedure and timelines apply. |
| Human-rights concerns | Human Rights / Grievance mechanism | Whistleblower route remains available where appropriate. |
| Immediate safety emergency | Emergency / Security / EHS reporting | Do not wait for the whistleblower investigation process. |
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19. Records & Retention
• Whistleblower/Protected Disclosure Register
• Original complaints and supporting evidence
• Acknowledgements and communications
• Screening/conflict-of-interest records
• Investigation plans and reports
• Witness/subject statements where maintained
• Corrective and disciplinary action records
• Retaliation monitoring records
• Training/communication records
• Management/Board reporting records
Records shall be retained securely in accordance with applicable law and the Company's controlled-record retention requirements, with access restricted to authorised personnel. -
20. Monitoring & Continuous Improvement
• Monitor number and type of reports, acknowledgement/completion times and overdue cases.
• Review recurring themes and control weaknesses without compromising confidentiality.
• Track corrective actions to closure and effectiveness.
• Review whether reporting channels remain accessible and trusted.
• Use lessons learned to strengthen policies, controls and training.
• Conduct an annual management review of the mechanism. -
21. Policy Review
This Policy shall be reviewed at least annually and additionally following changes in law or RJC requirements, significant cases, audit findings, material process changes, changes to reporting channels or other events that may affect the effectiveness of the mechanism. -
22. Related Controlled Documents
• Grievance Redressal Policy – RJC COP 2024
• Anti-Bribery & Anti-Corruption Policy – RJC COP 2024
• Human Rights Policy – RJC COP 2024
• Non-Discrimination Policy & SOP – RJC COP 2024
• POSH Policy – RJC COP 2024
• AML/CFT Policy – RJC COP 2024
• Supply Chain Policy – RJC COP 2024
• Risk Mitigation Plan – RJC COP 2024 - 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.