Non-Discrimination Policy & Standard Operating Procedure
MAHAVIR BULLION & REFINERY PRIVATE LIMITED
POLICY DOCUMENTPeople
1. Document Control
Company Name
Mahavir Bullion & Refinery Private Limited
Policy No.
MBR/SRAMP/02
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
23/03/2026
Policy Owner
Compliance Officer / Senior Management
Classification
Controlled Document
Applicable Standard
RJC COP 2024
Next Review
Annually
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.
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.
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
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.
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
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.
Treat colleagues respectfully, avoid discriminatory conduct, report concerns and cooperate with investigations.
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.
