Responsible Gold Sourcing Policy

Scope

This policy covers the business activities of Mahavir Bullion & Refinery Private Limited (hereinafter referred to as “Company”) for sourcing of Gold Dore from Conflict Free and Ethical compliant gold suppliers and mining companies and Gold Scrap from local Ethical compliant precious metals traders.

RESPONSIBILITY:

• Senior Management to provide accesses to necessary documents, information and resources to fulfill the core objective of ensuring conflict free and ethical sourcing of precious metal (gold).
• Senior Management is responsible to provide all required resources and infrastructure to meet the requirements of Responsible Jewellery Council (“RJC”).
• Senior Management shall appoint a Compliance officer with necessary knowledge and qualification and shall provide required training and awareness about the compliance with this Responsible Gold Sourcing Policy and its Due Diligence requirements.
• The Company shall conduct a periodic review meeting of OECD compliances along with Senior Management of Company.
• Senior Management shall conduct an annual review of Responsible Gold Sourcing Policy and shall endorse the policy document as a token of commitment of Compliance.
• Senior Management shall be overall responsible for review and compliance to this Responsible Gold Sourcing Policy.
• Senior Management shall be responsible to design the risk assessment framework/Risk Mitigation Plan during enrolment of new suppliers and their ongoing risk monitoring.
• Senior Management/Board shall conduct on going monitoring of transactions, KYC (Know your counter party) compliance and its periodic reviews. • Senior Management shall be responsible to maintain the necessary records of due diligence and its annual compliance for review.

PROCEDURE:

• Fighting serious abuses of human rights, avoiding contributing to conflict over its supply chain and complying with high standards of Anti-Money Laundering (AML) and Combating The Financing of Terrorism (CFT) and addressing environmental and sustainability responsibilities are central tenets of the Company’s operating procedures.
• The Company will apply this guidance and comply with the OECD Responsible Gold Guidance for gold handled. The policy covers the five steps framework for risk based due diligence of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
• As part of our Responsible Gold Sourcing Policy, the Company commits to:

Neither tolerate nor contribute to, assist with or facilitate the commission of following:

• Any forms of torture, cruel, inhuman and degrading treatment;
• Any forms of forced or compulsory labor;
• Illegal and/or unacceptable forms of child labor;
• Other human rights violations and abuses such as widespread sexual violence
• War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

OUR ACTIONS ON RED FLAGS

• Immediately suspend or discontinue engagement with counterparty where the Company identifies a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as defined above.
• Support measures to build secure, transparent, fair-trade and verifiable gold supply chains from artisanal miners to market.
• Never source from illegal mining operations
• Not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals who:

- Illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain, and/or
- Illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or
- Illegally tax or extort intermediaries, export to the Company or international traders.

• Immediately suspend or discontinue engagement with upstream suppliers where the Company identify a probable occurrence that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined above.
• Eliminate direct or indirect support to public or private security forces with illegal practices.
• The Company shall not engage offering, promise, give or demand any bribes, and resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of minerals extraction, trade, handling, transport and export.
• Not to source gold from an area designated as a World Heritage Site.
• Perform appropriate due diligence on a risk-based approach over our counterparties before doing any business and ongoing monitoring of the relationship in order to assess the risk of contribution to conflict, money laundering, terrorist financing, serious human rights abuse and non-compliance with environmental and sustainability legal requirements and implement a strategy to respond to identified risk.
• Ensure that appropriate scrutiny and monitoring of transactions is undertaken applying a risk-based approach.
• Maintain adequate records to demonstrate that appropriate and ongoing due diligence have been followed.
• Make and receive payments for gold transactions through official banking channels.
• Take steps to contribute to the effective elimination of money laundering and terrorism financing. In case the Company suspects or have reasonable grounds to suspect that the funds or the gold are the proceeds of a criminal activity, or are related to terrorist financing, the Company shall promptly report such findings to the local financial intelligence unit (FIU).
• Establish long-term relationships with gold suppliers and customers in order to build and support a responsible supply chain.
• Encourage suppliers of gold to take appropriate steps to ensure that the provisions of the Company’s Responsible Gold Sourcing Policy is communicated to their employees and their own supply chain and to urge such suppliers to commit to a gold supply chain policy consistent with Annex II of the OECD Due Diligence Guidance for Responsible Supply Chains.
• Our due diligence includes the following 5 steps:

STEP I: ESTABLISH STRONG MANAGEMENT SYSTEM

• The Senior Management shall review the effectiveness and performance of the due diligence procedures yearly and document the results of these reviews.
• The Senior Management along with sourcing team is responsible for all matters regarding precious metal supply chain/AML-CFT due diligence. In particular, they review due diligence on suppliers, customers and all the persons involved in the supply chain and assesses if the due diligence documentation collected and maintained is adequate to ensure that these parties have not financed conflict, have not participated in abuse of human rights or money laundering nor financed terrorism and have addressed environmental and sustainability practices.
• Senior Management ensures as well that appropriate measures are executed in case of high-risk counterparties and transactions.
• Senior Management is also responsible for the training of the employees with respect to this guidance (participation list to training shall be kept in the Company’s records) and to give proper information to the Management.
• Senior Management is responsible to perform due diligence and continuous monitoring of the business relationship as described in this guidance (OECD Annexure II).
• The Company will maintain a supply chain traceability system that collects and maintains supply chain information for each inbound and outbound shipment, including assigning a unique reference number to each input and output in a manner that tampering or removal will be evident.
• All consignments shall be unsealed and opened only by authorized personnel and records/evidence of the same shall be maintained.
• Adequate records of due diligence documents and traceability system records are required to be maintained for at least 8 (eight) years to demonstrate that appropriate and ongoing due diligence have been performed.
• Management of the Company shall be encouraged to build long term relationship based on trust and mutual recognition with their gold suppliers and customers. Where appropriate, the Company shall promote responsible sourcing practices throughout the supply chain and assist their counterparties or prospects in improving their own responsible supply chain practices.
• Senior Management will ensure continuous improvement of its due diligence practices.
• Company will make and receive payment for gold through official banking channels only.
• Company will cooperate fully and transparently with government authorities and provide full access to records and information as appropriate.
• Senior Management will be responsible to update this guidance and to ensure that this guidance is properly implemented by the subsidiaries,(if any).
• Company have put in place appropriate grievance redressal mechanism wherein any employee, persons involved in supply chain process, or external stakeholder can raise any concerns over the supply chain or newly identified risk.