Human Rights Policy

2. Introduction

Mahavir Bullion & Refinery Private Limited (“MBRPL” or the “Company”) affirms its commitment to respect, uphold and promote internationally recognized human rights across its operations and business relationships. As a precious-metals refinery and bullion business, the Company recognizes that its activities and supply chains may be exposed to risks including child labour, forced labour, discrimination, unsafe working conditions, human trafficking, conflict-related abuses and adverse impacts on communities.

This Policy is based on the Company’s existing Human Rights Policy and retains its core commitments while updating the document for RJC COP 2024. RJC COP 2024 places increased emphasis on human-rights due diligence aligned with the UN Guiding Principles on Business and Human Rights (UNGPs).

3. Purpose

• Establish a clear, company-wide commitment to respecting human rights.
• Define expectations for employees, contractors, suppliers, counterparties and relevant stakeholders.
• Identify, prevent, mitigate and address actual and potential adverse human-rights impacts connected with the Company’s operations and business relationships.
• Integrate human-rights considerations into sourcing, procurement, refining, operations, employment and decision-making.
• Provide accessible channels for raising concerns and support appropriate remedy where the Company has caused or contributed to an adverse impact.
• Support RJC audit readiness and continuous improvement.

4. Scope

• All permanent, temporary, outsourced and contractual employees.
• All suppliers and counterparties, including miners, aggregators, refiners, recyclers and scrap dealers, to the extent relevant to due diligence.
• All contractors, visitors, job-workers, transporters and logistics/service providers.
• All operational and support functions including sourcing, procurement, refining, HR, logistics, security, administration, finance, sales and compliance.
• Business decisions relating to procurement, production, labour conditions, health and safety, security, environmental matters and community wellbeing.

6. Human Rights Commitment

MBRPL commits to respect human rights in accordance with internationally recognized human-rights principles and applicable law. The Company shall consider potential and actual impacts in its own operations, business relationships and, where relevant, communities connected with its activities. The Company shall not knowingly cause, contribute to or remain directly linked to serious human-rights abuses through its business relationships without taking appropriate action.

• Zero tolerance for torture, cruel, inhuman or degrading treatment.
• Zero tolerance for forced or compulsory labour, human trafficking and unacceptable child labour.
• Zero tolerance for physical or mental abuse, violence, intimidation, coercion and degrading working or living conditions.
• Respect for dignity, equality, freedom of association and lawful collective bargaining.
• Respect for safe and healthy working conditions.
• Respect for workers’ ability to raise concerns without retaliation.
• Respect for affected stakeholders and communities where Company activities may create or contribute to adverse impacts.

7. Alignment with International Frameworks

• RJC Code of Practices 2024, particularly COP 2, COP 5, COP 6 and related labour, health and safety and responsible-sourcing provisions.
• United Nations Guiding Principles on Business and Human Rights (UNGPs).
• Universal Declaration of Human Rights (UDHR).
• ILO Declaration on Fundamental Principles and Rights at Work and relevant ILO conventions.
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including relevant human-rights risks.
• Applicable Indian labour, safety, anti-trafficking, child-labour and other human-rights-related laws.

RJC’s COP 2024 requires a policy commitment endorsed by top management and a human-rights due-diligence process to identify, prevent, mitigate and account for adverse human-rights impacts, with appropriate remediation where the Company has caused or contributed to impacts.

8. Prohibition of Child Labour

MBRPL strictly prohibits child labour and shall comply with applicable Indian law. Age verification shall be performed during recruitment and appropriate controls shall be applied to contractors and relevant business partners.

• Maintain documented age and identity verification for employees.
• No hiring of persons below the legally permitted age.
• No persons below 18 years shall be assigned to hazardous refinery activities such as chemical handling, furnace operations or heavy machinery.
• Supplier and contractor due diligence shall consider child-labour risks.
• If credible child-labour concerns are identified in a business relationship, the Company shall investigate, implement appropriate corrective action and suspend or disengage where risks cannot be adequately mitigated.

9. Prohibition of Forced Labour and Human Trafficking

• Prohibition of bonded, indentured, trafficked, forced or compulsory labour.
• No confiscation or retention of workers’ identity documents as a means of coercion.
• No withholding of wages as coercion.
• No threats, intimidation, violence or restrictions on lawful freedom of movement.
• Employment terms shall be transparent and voluntary.
• Overtime shall not be used as a coercive practice and shall be managed in accordance with applicable law and Company procedures.
• Human-trafficking and forced-labour indicators shall be considered in relevant supplier and contractor due diligence.

10. Non-Discrimination and Equal Opportunity

MBRPL does not tolerate discrimination in recruitment, employment, training, promotion, compensation, benefits or working conditions. The Company’s separate Non-Discrimination Policy shall be read together with this Policy.

• Gender, caste, religion, ethnicity or social background.
• Marital status, age or disability.
• Sexual orientation or pregnancy.
• Language or other legally protected characteristics.
• Political affiliation or other status where protected by applicable law.

11. Freedom of Association and Collective Bargaining

• Respect workers’ rights to form or join lawful associations and trade unions.
• Respect lawful collective bargaining rights.
• Workers may raise concerns through the Company’s grievance mechanisms without retaliation.
• Where a union is not present, accessible grievance and worker-representation mechanisms shall be maintained.

12. Employment Terms, Working Hours and Remuneration

• Employees shall receive clear employment terms appropriate to their employment relationship.
• Working hours, rest periods and overtime shall comply with applicable law and Company procedures.
• Wages shall meet or exceed applicable statutory requirements.
• Overtime shall be managed lawfully and compensated as required.
• Employment records, attendance and payroll records shall be maintained as required.

13. Health, Safety and Environmental Rights

Workers have the right to a safe and healthy workplace. MBRPL shall identify workplace hazards, assess risks and implement appropriate controls through its Health & Safety Risk Assessment Policy and related procedures.

• Appropriate PPE and safety training.
• Access to drinking water, sanitation and welfare facilities.
• Emergency preparedness and evacuation arrangements.
• Controls for hazardous substances and refinery chemicals.
• Ventilation, fire safety and first-aid arrangements.
• Hazard identification, risk assessment, incident investigation and corrective action.

14. Human Rights Due Diligence

MBRPL shall maintain a risk-based human-rights due-diligence process covering its own operations and relevant business relationships. The process shall be proportionate to the Company’s size, activities, operating context and potential severity of impacts.

The UNGP-aligned approach is continuous and focuses on risks to people, not only risks to the Company.

15. Supply Chain Human Rights Due Diligence

• KYC/KYB and beneficial-ownership checks for relevant counterparties.
• Assessment of supplier business activity, location, source and nature of materials.
• Screening for sanctions, PEPs, adverse information and relevant human-rights concerns.
• Assessment of labour practices and serious human-rights risks where relevant.
• CAHRA and responsible-sourcing assessment for higher-risk supply chains.
• Verification of origin, traceability and transaction documentation where required.
• Enhanced due diligence for higher-risk suppliers or transactions.
• Documented risk mitigation, monitoring, suspension or disengagement decisions.

The Company’s Responsible Gold, Silver & PGM Sourcing Policy is the principal controlled document for responsible-sourcing due diligence. It already incorporates human-rights risks, CAHRA assessment, KYC/EDD and supply-chain monitoring.

16. Security and Human Rights

• Security personnel shall perform duties lawfully, proportionately and respectfully.
• Security controls shall not involve intimidation, unnecessary force, degrading treatment or unlawful restriction of movement.
• Relevant security providers shall be subject to appropriate due diligence and contractual expectations.
• Human-rights concerns associated with security activities shall be reported, investigated and addressed.

17. Grievance, Reporting and Non-Retaliation

Employees, workers, suppliers, contractors, business partners and other relevant stakeholders may raise human-rights concerns through the Company’s Grievance Redressal Policy, Whistleblower Policy, POSH mechanism or other applicable reporting channel.

• Channels shall be accessible and communicated to relevant workers and stakeholders.
• Good-faith reporting shall not result in retaliation, threats, discrimination, penalty or adverse treatment.
• Confidentiality shall be protected on a need-to-know basis and anonymous concerns shall be considered where reasonably possible.
• Complaints shall be assessed, investigated and resolved in a fair and timely manner appropriate to their seriousness and complexity.
• Corrective action and remediation shall be documented where required.

The Company’s Grievance Redressal Policy is the broader mechanism for workplace, human-rights and stakeholder concerns, while POSH and Whistleblower mechanisms apply to matters within their specific scope.

18. Remediation and Corrective Action

• Where MBRPL causes or contributes to an adverse human-rights impact, the Company shall take appropriate steps to stop or prevent the impact and provide or cooperate in legitimate remediation.
• Where MBRPL is directly linked to an impact through a business relationship, the Company shall use appropriate leverage and risk-response measures.
• Corrective actions shall have assigned owners and target dates where appropriate.
• Material or repeated issues shall be escalated to Senior Management and/or the Board as appropriate.
• Supplier suspension, corrective-action plans or disengagement may be applied where risks cannot be adequately mitigated.

20. Training and Awareness

• Relevant employees shall receive training on this Policy and their human-rights responsibilities.
• Training shall cover child labour, forced labour, discrimination, harassment, human trafficking, freedom of association, health and safety, grievance reporting and non-retaliation as relevant to the role.
• Procurement, sourcing, HR, security, compliance and management personnel shall receive role-specific awareness.
• Training records shall be maintained.

21. Records and Evidence

• Human-rights risk assessments and reviews.
• Supplier/business-partner due-diligence records relevant to human-rights risk.
• Age-verification and employment records, where applicable.
• Training and awareness records.
• Grievance, investigation, corrective-action and remediation records, subject to confidentiality.
• Audit, inspection and monitoring records.
• Management review and policy review records.

Records supporting applicable RJC COP requirements shall be retained in accordance with the Company’s document-retention controls and applicable law; RJC COP 2024 COP 2.5 requires records to be retained for at least five years unless a longer period is required.

22. Monitoring, Review and Continuous Improvement

• Human-rights risks and the effectiveness of controls shall be monitored periodically.
• Material incidents, grievances, audit findings, supplier concerns and regulatory changes shall be reviewed and used to improve controls.
• This Policy shall be reviewed at least annually.
• Additional review shall be performed following material changes to operations, significant incidents or allegations, major changes in supply chains, legal/regulatory changes, audit findings or other relevant triggers.
• Changes shall be approved through the Company’s document-control and governance process.

23. Related Controlled Documents

• Supply Chain Policy
• AML/CFT Policy
• KYC / Due Diligence SOP
• Risk Mitigation Plan
• Non-Discrimination Policy
• POSH Policy
• Whistleblower Policy
• Grievance Redressal Policy
• Health & Safety Risk Assessment Policy
• Staff Safety & Training Policy
• Security Risk Assessment Policy