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2. Introduction
Mahavir Bullion & Refinery Private Limited (“MBRPL” or “the Company”) is committed to conducting its business in a lawful, transparent and ethical manner. Bribery and corruption undermine ethical business conduct, distort commercial and regulatory decisions and expose the Company to financial, legal, operational and reputational risks.
This Policy establishes the Company’s framework for preventing, identifying, assessing, monitoring, escalating and responding to bribery and corruption risks. It is based on the Company’s existing Anti-Bribery & Anti-Corruption Policy and has been updated to align with RJC Code of Practices 2024, particularly COP 11 – Bribery and Facilitation Payments.
The Policy shall be read together with the Company’s Supply Chain Policy, AML/CFT Policy, KYC/Due Diligence SOP, Risk Mitigation Plan, Whistleblower Policy, Grievance Redressal Policy and other applicable controlled documents. -
3. Purpose
• Prevent the Company from being involved in bribery or corruption directly or indirectly.
• Establish clear expectations on acceptable and unacceptable conduct.
• Identify and manage bribery risks in the Company’s activities and business relationships.
• Provide controls for gifts, hospitality, third parties, reporting, investigation and sanctions.
• Protect workers and other affected persons who raise concerns in good faith or refuse to participate in bribery.
• Support compliance with RJC COP 2024 and applicable Indian laws and regulatory requirements.
• Protect the Company, employees, counterparties and stakeholders from legal, financial and reputational harm. -
4. Scope
This Policy applies to:
• All MBRPL employees, including full-time, part-time, outsourced and contractual personnel.
• Directors, senior management and department heads.
• Agents, brokers, job-workers, contractors, consultants and other third-party intermediaries.
• Security staff, logistics partners and transport agencies.
• Suppliers, aggregators, miners, scrap dealers and other business partners.
• Customers and trading partners to the extent relevant to the Company’s anti-bribery controls.
• All business activities including procurement, refining, logistics, marketing, sales, finance, licensing, documentation, regulatory interactions and third-party engagement. -
5. RJC COP 2024 Requirements Addressed
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8. Bribery Risk-Based Approach
MBRPL shall assess bribery risk using a documented, proportionate and risk-based methodology. Risk shall be assessed before relevant relationships or activities are established and monitored throughout the relationship. -
8.1 Counterparty / Third-Party Risk
• Ownership and beneficial ownership where relevant.
• Nature and legitimacy of business activity.
• Reputation, adverse information and prior misconduct.
• Government or public-official interaction.
• Use of agents, consultants, brokers or intermediaries.
• Unusual commission structures or unexplained fees. -
8.2 Geographic / Regulatory Risk
• Higher-risk jurisdictions or routes.
• Countries with elevated corruption risk under relevant official or reputable sources.
• Locations involving significant customs, licensing or regulatory interaction.
• Jurisdictions with weak enforcement or transparency controls. -
8.3 Business Activity Risk
• Procurement and sourcing of precious metals.
• Customs, licensing, regulatory and government interactions.
• Refining, assay, valuation or documentation activities where improper influence could create benefit.
• Use of third-party intermediaries, logistics providers or introducers.
• Marketing, sales, sponsorships, donations, gifts and hospitality. -
8.4 Transaction Risk
• Unusual discounts, commissions or fees.
• Off-book, cash or unexplained payments.
• Payments routed through unrelated parties.
• Over- or under-invoicing.
• Urgent requests to bypass normal approvals.
• Transactions inconsistent with legitimate business purpose.
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9. Definition of Bribery and Corruption
Bribery is the offering, promising, giving, requesting, agreeing to receive or accepting anything of value intended to influence a decision or secure an improper advantage.
Anything of value may include:
• Cash or cash equivalents.
• Gifts, hospitality or entertainment.
• Discounts, credit or favourable pricing.
• Free services or benefits.
• Political or charitable contributions where intended to secure an improper advantage.
• Personal favours.
• Undisclosed commissions or kickbacks.
• Over-invoicing or under-invoicing.
• Payments disguised as consultancy, facilitation or other legitimate fees.
Corruption includes abuse of entrusted authority for private or improper gain. -
10. Prohibition of Bribery and Improper Advantages
• Offering, promising, giving, requesting or accepting bribes.
• Undisclosed commissions or kickbacks.
• Payments intended to improperly influence regulators, customs, police, licensing authorities or other public officials.
• Bribes disguised as gifts, hospitality, travel, sponsorships, consultancy fees or facilitation charges.
• Manipulation of assay results, refinery output figures, invoices or records to conceal an improper payment or advantage.
• Using a third party to perform an act that the Company or its personnel could not lawfully or ethically perform themselves.
• Extortion or solicitation where the underlying conduct involves an improper advantage, subject to immediate safety considerations. -
11. Facilitation Payments
MBRPL prohibits facilitation payments as a Company policy.
Examples include unofficial payments to expedite routine government or administrative actions such as:
• Customs clearance.
• Permits or licences.
• Routine inspections.
• Utility connections or similar routine services.
If an employee is compelled to make a payment because of an immediate and credible threat to personal safety, the employee must prioritise safety, promptly report the circumstances to their Manager and Compliance Officer, and ensure the incident is documented and investigated.
Where facilitation payments are legally permitted by applicable law, the Company shall seek to eliminate them or reduce their size and frequency over time. Any permitted payment must be limited in nature and scope, approved by the responsible manager, fully recorded and accounted for, monitored and publicly disclosed where required by RJC COP 11.3. -
12. Gifts, Hospitality and Entertainment
The Company shall establish criteria and approval procedures for offering and accepting gifts and hospitality.
• Gifts or hospitality must never be used to influence a decision or secure an improper advantage.
• Cash or cash equivalents, including gift cards, are prohibited as business gifts.
• Gifts or hospitality must not be offered or accepted during tendering, supplier evaluation or contract negotiation where they could influence the process.
• Gifts or hospitality intended to improperly influence public officials are prohibited.
• Low-value, culturally appropriate gifts and modest business meals/refreshments may be permitted when lawful, reasonable and approved under Company procedures.
• Expensive gifts, travel packages, hotel stays, personal services or unrelated entertainment are prohibited unless clearly legitimate and approved under documented criteria.
• Relevant gifts received or given shall be recorded in the Gift & Hospitality Register. -
13. Third-Party Intermediaries and Supplier Controls
Third parties may include customs brokers, consultants, logistics agents, introducers, government liaison personnel, aggregators and other intermediaries.
• Establish a legitimate business justification before engagement.
• Conduct risk-based KYC/KYB and beneficial ownership checks where relevant.
• Conduct conflict-of-interest checks and sanctions/adverse-information screening where appropriate.
• Obtain background or reputation information proportionate to risk.
• Use written agreements containing appropriate anti-bribery obligations where applicable.
• Do not use a third party to circumvent this Policy.
• Suppliers and intermediaries may be suspended or terminated where a confirmed or material violation is identified. -
14. Procurement and Payment Controls
• Pricing, invoices, commissions and payment instructions shall be supported by legitimate documentation.
• Payments shall use approved channels and authorised approval workflows.
• Unusual discounts, inflated prices, unexplained commissions or unrelated third-party payments shall be escalated.
• Employees shall not bypass procurement, approval or payment controls to complete a transaction.
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16. Reporting, Whistleblowing and Non-Retaliation
• Employees and other affected persons may report suspected bribery through the Compliance Officer, designated internal reporting channel or confidential written complaint mechanism.
• Reporting channels shall be communicated to relevant workers and, where appropriate, other affected persons.
• The Company shall protect workers from retaliation, harassment or adverse consequences for raising concerns in good faith, refusing to participate in bribery or refusing a prohibited facilitation payment.
• Actual reporting contact details shall be inserted into the controlled policy before issue. -
17. Investigation and Escalation
1. Receive and record the allegation or concern.
2. Conduct a preliminary assessment and determine the appropriate investigation route.
3. Preserve and review relevant evidence confidentially.
4. Interview relevant persons and assess transactions, approvals, contracts and records as appropriate.
5. Escalate significant findings to Senior Management and/or the Board.
6. Implement corrective, disciplinary and contractual actions as appropriate.
7. Report to competent authorities where required by applicable law. -
18. Disciplinary Action and Sanctions
Depending on the facts, applicable law and Company procedures, sanctions may include:
• Written warning or other disciplinary action.
• Suspension, demotion or termination, as applicable.
• Suspension or termination of supplier/intermediary relationship.
• Recovery or remediation of improper benefits where lawful.
• Legal or regulatory reporting and prosecution where appropriate. -
19. Training and Awareness
• Induction anti-bribery training for relevant new employees.
• At least annual refresher training for relevant personnel.
• Role-specific training for sourcing, procurement, logistics, finance, compliance and other exposed functions.
• Training on red flags, gifts and hospitality, facilitation payments, reporting and non-retaliation.
• Training records shall be maintained in the applicable controlled training register. -
20. Record Keeping
The Company shall maintain adequate anti-bribery records in accordance with applicable law and its document-retention requirements. The existing Company practice of retaining relevant anti-bribery records for 10 years shall continue unless a longer legal or contractual requirement applies.
• Gift & Hospitality Register.
• Conflict-of-interest declarations.
• Third-party due-diligence files.
• Contracts and anti-bribery undertakings.
• Investigation and incident records.
• Training attendance and effectiveness records.
• Internal audit/review reports.
• Facilitation payment records and public disclosures, where applicable. -
21. Internal Review and Assurance
• The Company shall conduct periodic internal anti-bribery reviews to evaluate the effectiveness of risk identification, third-party controls, gifts and hospitality controls, reporting, investigations, sanctions, recordkeeping and training.
• Review findings shall be reported to Senior Management and significant findings shall be escalated to the Board.
• Corrective actions shall have responsible owners and target dates and shall be tracked to closure.
• RJC audit evidence shall be maintained and made available to the auditor as appropriate. -
22. Policy Review and Approval
This Policy shall be reviewed at least once every 12 months and additionally when there are changes in law, regulation, RJC requirements, material business activities, bribery-risk exposure, audit findings, significant incidents or material changes to the Company’s anti-bribery programme.
Changes shall be documented through the Company’s document-control process and approved by the Board or other authorised approving body. -
23. Related Controlled Documents
• AML/CFT Policy.
• Supply Chain Policy
• KYC / Due Diligence SOP.
• Risk Mitigation Plan.
• Human Rights Policy.
• Grievance Redressal Policy.
• Whistleblower Policy.
• Security Risk Assessment Policy.
• Supplier / Business Partner Code, when approved.
• Product Integrity / Claims & Disclosure Policy, when approved. -
For Mahavir Bullion & Refinery Private Limited
