Prevention of Sexual Harassment (POSH)

2. Introduction

Mahavir Bullion & Refinery Private Limited (“MBRPL” or “the Company”) is committed to providing a safe, respectful, productive and professional workplace. The Company adopts a zero-tolerance approach to sexual harassment and conduct that violates the dignity, safety or personal boundaries of individuals.

This Policy is framed in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the applicable Rules, and the Responsible Jewellery Council (RJC) Code of Practices 2024. It is intended to support the Company's commitment to dignity, non-discrimination, effective grievance mechanisms and protection against retaliation.

3. Purpose

• Prevent sexual harassment at the workplace.
• Define prohibited and unacceptable conduct.
• Provide accessible and trusted reporting channels.
• Ensure fair, impartial and confidential handling of complaints.
• Establish and maintain the Internal Committee (IC/ICC) as required by law.
• Protect complainants, respondents, witnesses and Committee members from retaliation.
• Provide appropriate corrective, disciplinary and remedial action.
• Demonstrate compliance with applicable Indian law and RJC COP 2024.

4. Scope

This Policy applies to all persons working at or interacting with MBRPL, including permanent, temporary, contractual, probationary and trainee employees; apprentices, interns, outsourced personnel, job-workers and consultants; directors and management; and visitors, customers, suppliers, transporters and service providers while interacting with Company personnel.

The workplace includes office premises, refinery and production areas, laboratories, storage and control rooms, Company vehicles, work-related travel, meetings, training, events, accommodation arranged for work, remote work and electronic/digital communications connected with work.

6. Legal and Regulatory Framework

• Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
• Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013.
• Applicable labour, employment, criminal and other legal requirements, as amended from time to time.
• RJC Code of Practices 2024 and applicable related requirements.

Where legal requirements change, the Company shall review and update this Policy and related procedures. Applicable law shall prevail where it imposes a stricter requirement.

7. Definitions and Prohibited Conduct

Sexual harassment includes unwelcome acts or behaviour of a sexual nature, including physical contact and advances, a demand or request for sexual favours, sexually coloured remarks, showing pornography or sexually explicit material, and other unwelcome physical, verbal, non-verbal, written or electronic conduct of a sexual nature.

• Unwelcome physical contact or advances.
• Demand or request for sexual favours.
• Sexually coloured remarks, jokes or comments.
• Showing pornography or sexually explicit material.
• Unwelcome sexual messages, images, gestures or electronic communications.
• Stalking, leering, whistling or other unwelcome conduct of a sexual nature.
• Repeated unwelcome requests for dates or intimacy.
• Any conduct that creates an intimidating, hostile, humiliating or offensive work environment.

Sexual harassment may occur between persons of any gender and may involve supervisors, co-workers, subordinates, contract labour, visitors or other third parties.

8. Internal Committee (IC/ICC)

Where required by the POSH Act, MBRPL shall constitute an Internal Committee through a formal written order and maintain evidence of its composition and appointment.

• Presiding Officer: a senior woman employee, as required by law.
• Employee members with appropriate experience, commitment or knowledge relevant to the Committee's functions.
• External member meeting the statutory eligibility requirements.
• Committee members shall serve for the statutory term, subject to applicable law and earlier replacement where required.

The Committee shall receive complaints, maintain confidentiality, conduct inquiries fairly, provide recommendations, support prevention and awareness, protect against retaliation, and maintain statutory records.

9. Reporting and Complaint Mechanism

A complaint falling within the statutory POSH mechanism shall be submitted to the Internal Committee in accordance with the POSH Act and Rules. Where a complainant is unable to make a written complaint, the Committee shall provide reasonable assistance in reducing the complaint to writing.

• Internal Committee member(s).
• HR / Compliance.
• Confidential written complaint.
• Company Grievance Redressal / Whistle Blower mechanism, where appropriate.

As a general statutory rule, a complaint should be made within three months from the incident or, in the case of a series of incidents, within three months from the last incident. The Committee may extend the period by up to a further three months for reasons recorded in writing, where permitted by law.

11. Recommendations and Corrective Action

• Written warning or reprimand.
• Counselling or mandatory training.
• Transfer or other workplace measures where appropriate.
• Suspension or termination, where warranted and lawful.
• Other corrective or remedial action permitted by law and Company procedures.

A complaint that is not substantiated shall not automatically be treated as false or malicious. Action for a malicious complaint shall be considered only where deliberate falsehood or malicious intent is established through the applicable process.

12. Protection Against Retaliation

MBRPL prohibits retaliation, victimisation, intimidation or adverse employment action against a person who raises a concern in good faith, participates in an inquiry, provides evidence or supports the complaint process. Any suspected retaliation shall be reported immediately and will be treated as a separate workplace violation.

• Complainants, witnesses and Committee members shall be protected from victimisation.
• No adverse job consequence shall be imposed for making a good-faith complaint or participating in the process.
• Confidentiality shall be maintained to the extent required by law.

13. Confidentiality

Complaint details, identities of parties and witnesses, evidence, inquiry proceedings, recommendations and related records shall be kept confidential and shall not be disclosed except as permitted or required by law. Unauthorised disclosure may result in disciplinary and/or legal consequences.

14. Training and Awareness

• POSH awareness training shall be provided periodically and at least annually as part of the Company's compliance programme.
• New employees shall receive POSH awareness during induction or within a defined period after joining.
• Managers and supervisors shall receive role-specific awareness on prevention, escalation and non-retaliation.
• Internal Committee members shall receive appropriate training/capacity building.
• Policy and Committee contact information shall be displayed/communicated as required by law.
• Training attendance and completion records shall be maintained.

15. Supplier, Contractor and Visitor Expectations

Suppliers, contractors, transporters, visitors and other third parties are expected to respect this Policy while interacting with MBRPL personnel. Serious or repeated violations may result in appropriate contractual, access-control or commercial action, subject to applicable law and contractual terms.

16. Responsibilities

Board / Senior Management: Approve the Policy, provide resources and oversight, and support implementation and non-retaliation.
HR: Coordinate awareness, employee communication, records and support to the Internal Committee.
Compliance: Monitor applicable legal/RJC requirements and support assurance and corrective action.
Internal Committee: Handle statutory POSH complaints, inquiries, confidentiality, reporting and recommendations.
Managers / Supervisors: Prevent inappropriate conduct, escalate concerns and cooperate with inquiries.
Employees / Workers: Maintain respectful conduct, use reporting channels in good faith and cooperate with lawful inquiries.

17. Documentation and Record Keeping

• Internal Committee appointment/constitution records.
• Complaint and acknowledgement records.
• Inquiry notices, statements, evidence and reports.
• Recommendations and action-implementation records.
• Training and awareness records.
• Statutory annual reports/filings, where applicable.
• Policy communication/display evidence.
• Records shall be retained securely for the period required by applicable law and the Company's document-retention schedule.

18. Monitoring, Review and Assurance

• HR / Compliance shall periodically verify that reporting channels are functional and Committee appointments remain valid.
• Required training and awareness shall be monitored.
• Statutory reporting obligations shall be tracked.
• Internal or external audit findings shall be documented and corrective actions tracked to closure.
• The Policy shall be reviewed at least annually and additionally after legal changes, significant incidents, audit findings, organisational changes or material changes in risk.

19. Related Controlled Documents

• Human Rights Policy – RJC COP 2024
• Non-Discrimination Policy and SOP – RJC COP 2024
• Grievance Redressal Policy – RJC COP 2024
• Whistle Blower Policy
• Staff Safety and Training Policy