Supply Chain Policy

Philosophy
At Mahavir Bullion and Refinery Private Limited (MBR"), we believe that a responsible and resilient supply chain is fundamental to sustainable business growth and long-term value creation. Our approach to supply chain management is rooted in a strong commitment to ethical conduct, transparency, and accountability, aligned with the highest standards of commercial integrity and compliance with applicable laws, rules, and regulations.

MBR strives to lead by example in the precious metals industry by integrating robust Environmental, Social, and Governance (ESG) principles into every aspect of its sourcing and operational strategy. We aim to minimize adverse environmental impacts, uphold human rights, and contribute positively to society through our value chain. As part of this commitment, MBR has set ambitious goals to ensure that all precious metals are sourced securely, transparently, and traceably, in a manner that is ethical, socially responsible, and environmentally sustainable. We categorically reject materials associated with conflict, human rights violations, child or forced labour, and any form of exploitative or irresponsible practices.

• Record receipt date, refining/processing date, assay and finalisation information as applicable.
• Reconcile documentary information with physical delivery. Material with a material inconsistency shall be controlled, segregated or prevented from normal processing/dispatch until resolved or an approved risk decision is documented.
• Investigate and document complex, unusual, unusually large or suspicious transactions under the AML Policy.
• Maintain internal material controls capable of reconciling material received, processed, in inventory and dispatched.

2. Purpose

Mahavir Bullion & Refinery Private Limited (“Mahavir”, “Company”, “we” or “our”) is committed to sourcing, refining, trading and handling precious metals responsibly. This Policy establishes the Company’s management framework and due-diligence requirements for gold, silver and platinum group metals (PGM) handled within the Company’s RJC certification scope.

The Policy is designed to prevent the Company from causing, contributing to, or being directly linked to serious human-rights abuses, conflict, money laundering, terrorist financing, bribery, fraudulent origin claims and significant environmental or other responsible-sourcing risks. It incorporates the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including Annex II, and follows its five-step framework. For gold, the Company shall implement the OECD Supplement on Gold as applicable to its operations and supply chains.

3. Scope

This Policy applies to all Company activities and facilities within the RJC certification scope that source, purchase, receive, refine, process, trade, sell, transfer or otherwise handle:

• Gold, including mined gold, gold doré, recycled gold and gold scrap.
• Silver, including mined and recycled silver, where handled by the Company.
• Platinum Group Metals (PGM), where handled by the Company.

It applies to relevant suppliers, customers, intermediaries, traders, agents, transporters, service providers and other business partners to the extent relevant to responsible-sourcing due diligence.
Where a material, source, transaction or activity is outside the RJC certification scope, the Company shall document the basis for its treatment and shall not make an RJC-related claim that is unsupported by the certified scope.

4. RJC COP 2024 Alignment

This Policy is a principal control document supporting:

5. Responsible Sourcing Commitments

• The Company shall neither tolerate nor profit from, assist with or facilitate torture, cruel, inhuman or degrading treatment; forced or compulsory labour; illegal or unacceptable forms of child labour; widespread sexual violence; war crimes; crimes against humanity; genocide; or other serious violations of international humanitarian law.
• The Company shall not provide direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals, including support to groups that illegally control mine sites, transportation routes, trading points or upstream actors, or that illegally tax or extort money or minerals.
• The Company shall seek to eliminate direct or indirect support to public or private security forces where such support is associated with unlawful conduct, serious abuses, illegal control, illegal taxation or extortion, and shall assess security arrangements where relevant to risk.
• The Company shall not offer, promise, give, demand or accept bribes or facilitation payments, and shall resist bribery intended to conceal or disguise mineral origin or to misrepresent taxes, fees or royalties due to governments in connection with extraction, trade, handling, transport or export.
• The Company shall not knowingly source material from illegal mining operations.
• As a continuing Company responsible-sourcing commitment, the Company shall not knowingly source mined gold from mining operations located within a designated UNESCO World Heritage Site.
• The Company shall assess money laundering, terrorist financing, sanctions, fraud and other financial-crime risks in accordance with its AML/KYC controls and applicable law.
• The Company shall perform risk-based due diligence before onboarding relevant counterparties and shall conduct ongoing monitoring throughout the business relationship.
• The Company shall assess relevant environmental, biodiversity, hazardous-substance, occupational-safety and sustainability risks in its supply chains and shall implement proportionate responses to identified material risks.
• The Company shall make and receive payments for precious-metal transactions through official banking channels, except where another payment method is expressly permitted by applicable law and approved under documented Company controls.
• The Company shall maintain records sufficient to demonstrate responsible-sourcing due diligence and shall cooperate, subject to applicable law and legitimate confidentiality, with competent authorities and RJC assurance processes.
• The Company shall communicate this Policy to relevant suppliers and use best endeavours to promote responsible sourcing practices consistent with OECD Annex II and applicable RJC requirements throughout its supply chain.

7. OECD Step 1 – Establish a Strong Management System

• Maintain this written Supply Chain & Responsible Sourcing Policy, approved at the highest appropriate level, make it publicly available, and communicate it to relevant suppliers and other applicable business partners.
• Assign competent personnel and sufficient financial, human and technical resources for responsible-sourcing due diligence.
• For gold, implement the OECD Due Diligence Guidance Supplement on Gold, as applicable to the Company’s operations and supply chains.
• Maintain procedures for supplier onboarding, KYC, beneficial ownership, origin determination, CAHRA assessment, risk rating, enhanced due diligence, transaction monitoring, escalation, mitigation and disengagement.
• Maintain a supplier/business-partner approval process and do not commence a new high-risk relationship until required due diligence and approvals are completed.
• Use best endeavours to establish durable, transparent relationships with suppliers and customers, communicate responsible-sourcing expectations, and support counterparties in improving their due-diligence practices where appropriate and proportionate to risk.
• Where the Company has subsidiaries within the applicable RJC certification scope, Senior Management shall ensure that this Policy and supporting due-diligence controls are implemented consistently across those entities.
• Make and receive payments for precious-metal transactions through official banking channels, subject only to documented legal and Company-approved exceptions.
• Provide role-appropriate training to procurement, sourcing, compliance, AML/KYC, refining, security, logistics and sales personnel and retain training records.
• Maintain an accessible grievance mechanism for employees, supply-chain participants and external stakeholders.
• Maintain due-diligence, traceability, risk, decision, mitigation, monitoring and reporting records for the period required by law and Company controls. The existing eight-year retention practice shall continue unless formally revised.
• Review effectiveness at least annually and additionally after material legal, regulatory, business, supply-chain, incident or RJC-standard changes.

8. Supply Chain Mapping and Information Requirements

• Identify the immediate counterparty and its legal status, ownership and management.
• Identify beneficial owners and persons acting on behalf of the counterparty, subject to applicable legal exceptions.
• Identify known upstream actors and, where relevant, mine/source, recycler/collector, exporter, transporter and other intermediaries.
• Obtain information sufficient to understand origin, route and circumstances of extraction, collection, recycling, trade and transportation.
• For mined material, determine country and, where required by risk and available information, mine or source of origin.
• For recycled material, determine the point at which the material re-enters the precious-metals supply chain and, where reasonably possible, information on earlier origin and collector/recycler chain.
• For each inbound and outbound shipment or material movement, maintain a unique traceability reference linking the physical material to the relevant supplier/customer, transaction, assay, weight, source/origin and due-diligence records. Identification, seal and custody controls shall be designed so that unauthorised tampering or removal can be detected where applicable.

9. Know Your Counterparty and Enhanced KYC

The Company shall apply its AML Policy and KYC/Due Diligence SOP together with this Policy. KYC shall be risk-based and proportionate to the nature, scale and purpose of the relationship.

• Verify identity and legal existence using reliable, independent documentation and sources.
• Identify beneficial owners and persons exercising control using the threshold and methodology established in the Company AML/KYC framework.
• Understand purpose and expected nature of the relationship, business activity, transaction profile, expected volume/frequency and source of funds/wealth where relevant.
• Screen counterparties, beneficial owners and relevant parties against applicable sanctions, PEP and adverse-information sources.
• Assess the counterparty’s AML/CFT controls, regulatory environment and responsible-sourcing controls where relevant to risk.
• For refining/mineral-processing activities performed on behalf of a third party, or where RJC Scope Material is handled on consignment, apply enhanced KYC commensurate with the nature, scale and purpose of the relationship.
• Do not maintain anonymous counterparties or shell banks. Suspicious circumstances shall be escalated under the AML/CFT Policy and applicable law. Where a reporting obligation applies, the AML/Principal Officer shall ensure reporting to FIU-IND or another competent authority, as applicable, within the legally prescribed framework and timeframe.

10. OECD Step 2 – Identify and Assess Supply-Chain Risk

The Company shall identify and assess risks using a documented, risk-based methodology consistent with the OECD Guidance and the Company Risk Mitigation Plan. The assessment shall consider country/region, supplier, material, route, transaction and known upstream actors.

10.1 CAHRA and Red-Flag Indicators

• Material originates from, transits through or is transported via a Conflict-Affected and High-Risk Area (CAHRA).
• Known upstream actors are associated with serious human-rights abuses, conflict, direct or indirect support to non-state armed groups, unlawful conduct by public/private security forces, illegal control, illegal taxation or extortion.
• Credible concerns regarding bribery, fraud or misrepresentation of origin.
• Credible concerns regarding non-payment or fraudulent misrepresentation of taxes, fees or royalties related to extraction, trade or export.
• Elevated money-laundering or terrorist-financing risk.
• Origin or supply-chain route is inconsistent with known production, reserves, capacity or commercial circumstances.
• Unexplained or unusually complex ownership, shell structures or unexplained changes in business activity.
• PEP status or higher-risk business/activity requiring enhanced review.
• Significant environmental, biodiversity, unsafe-working-condition, hazardous-substance or other sustainability risks.
• For mined gold, credible information that the mining operation is located within a designated UNESCO World Heritage Site, contrary to the Company’s sourcing commitment.
• Material associated with mercury or cyanide use where relevant to source and risk assessment.
• Unusually large, complex or unexplained transactions.
• Incomplete, contradictory, unverifiable or materially inconsistent information.

10.2 Risk Assessment by Material Type

• Mined Gold/Silver/PGM: obtain origin, mine/source information where applicable, licences/authorisations, import/export documentation, production/capacity information where available, and relevant environmental, human-rights and community information.
• Gold Doré: link each delivery to supplier, source/mine information, assay/weight, transport documentation and due-diligence file.
• Recycled/Post-Consumer Material: identify recycler/collector and point of re-entry into the precious-metals supply chain and assess illicit-material, theft, AML and hazardous-working-condition risks.
• Material from ASM: where directly sourced, apply COP 8 requirements, including unsafe working conditions, uncontrolled mercury/cyanide, significant environmental impacts and community-development considerations.
• Material from Informal Recyclers: where directly sourced, apply COP 9 requirements, including unsafe working conditions, toxic chemical/metal exposure and significant environmental impacts.

10.3 Enhanced Due Diligence for High-Risk Supply Chains

• Obtain proportionate KYC for relevant parties from source/mine or recycler through to the Company.
• Obtain and verify additional origin, ownership, transaction, route and control information.
• Assess security arrangements and risks of links to armed groups or unlawful security forces where relevant.
• Assess taxes, fees and royalties where relevant to the supply chain.
• Obtain evidence concerning serious human-rights abuses and other material adverse impacts where relevant.
• Conduct or commission an on-site assessment where appropriate to substantiate documentary due diligence and document scope, timing, competence and findings.
• Document the risk assessment, decision, mitigation requirements and management approval.

11. Transaction Monitoring and Traceability

• Monitor transactions throughout the relationship using a risk-based approach.
• Assign each inbound shipment a unique internal reference linked to supplier, material type, physical description, weight, assay, source/origin information, transport documents and due-diligence file; maintain corresponding traceability for outbound material sufficient to reconcile inputs, processing, inventory and dispatch.
• For mined material, retain mine/source information where applicable, licence/equivalent evidence where relevant, import/export and transport documentation.
• For recycled material, retain recycler/collector identity, material type and relevant origin information available from the supply chain.
• Record receipt date, refining/processing date, assay and finalisation information as applicable.
• Reconcile documentary information with physical delivery. Material with a material inconsistency shall be controlled, segregated or prevented from normal processing/dispatch until resolved or an approved risk decision is documented.
• All precious-metal consignments shall be received, unsealed/opened, handled and released only by authorised personnel in accordance with security and operations controls, with appropriate records or evidence retained.
• Investigate and document complex, unusual, unusually large or suspicious transactions under the AML Policy.
• Maintain internal material controls capable of reconciling material received, processed, in inventory and dispatched.

12. OECD Step 3 – Strategy to Respond to Identified Risks

Depending on the nature and severity of the risk, the Company may continue with mitigation, suspend new transactions while additional information is obtained, continue under defined corrective controls, or disengage where the risk cannot be adequately mitigated.

12.1 Escalation and Decision-Making

• The Compliance Officer shall document red flags/adverse findings and obtain additional information where appropriate.
• Material findings shall be escalated to Senior Management and, where required by severity, to the Board.
• Where there is a serious risk of human-rights abuse, conflict financing, terrorist financing, money laundering, fraudulent origin information or other prohibited conduct, transactions shall be stopped or suspended as appropriate and reports to competent authorities shall be made where legally required.
• Risk mitigation plans shall contain actions, responsible persons, target dates, measurable indicators, monitoring and escalation criteria.
• Initial risk-response timelines in the Company Risk Mitigation Plan shall apply according to risk rating. A longer improvement programme shall not delay urgent controls.
• Risk mitigation effectiveness shall be reviewed periodically and reported to Senior Management/Board as appropriate.

13. OECD Step 4 – Independent Assurance and Ongoing Reassessment

• Responsible-sourcing due diligence shall be subject to independent RJC certification audit and any other assurance required by applicable frameworks or Company commitments.
• Provide auditors and competent authorities with relevant records, subject to lawful confidentiality and data-protection controls.
• Reassess risks when supplier ownership, source, country, route, material, transaction pattern, legal environment, adverse event, allegation, sanctions status or other relevant circumstances change.
• Completion of initial KYC shall not be treated as sufficient where ongoing monitoring identifies new or changed risks.

14. OECD Step 5 – Reporting and Transparency

• Maintain responsible-sourcing due-diligence records and management reporting in accordance with applicable RJC requirements.
• As a gold refiner, maintain information necessary to identify the origin of mined and recycled gold and submit the information required by RJC under COP 7.2 in the required format and timeframe.
• Maintain evidence supporting the methodology used to determine origin and risk level, including transaction records and risk assessments.
• Ensure public or customer-facing responsible-sourcing information is accurate, approved and consistent with actual practices and RJC certification scope.
• Protect confidential commercial information while meeting applicable reporting and audit requirements.

15. Grievance and Non-Retaliation

• Maintain an accessible mechanism through which employees, suppliers, business partners, affected stakeholders and other relevant parties can raise responsible-sourcing, human-rights, financial-crime, environmental, fraud or origin concerns.
• Complaints shall be logged, acknowledged where appropriate, assessed and investigated according to nature and severity.
• Confidentiality shall be respected to the extent legally and operationally possible.
• No person shall suffer retaliation for raising a concern in good faith or participating in an investigation.
• Complaints and outcomes shall be retained and used, where appropriate, to improve controls.
• Official contact details shall be completed before publication: Email: Connect@mbrpvt.com , telephone: +91-8421627321; website: https://www.mahavirrefinery.com/

16. Records and Document Retention

• Supplier and counterparty KYC files
• Beneficial ownership records
• Sanctions/PEP/adverse-media screening records
• Supplier approval and risk-rating records
• Supply-chain maps and origin information
• Mine/source/recycler information
• Import/export and transportation documents
• Assay, weight, receipt and refining records
• CAHRA assessments and external-source checks
• Enhanced due-diligence and on-site assessment reports
• Risk mitigation plans and monitoring reports
• Suspension/disengagement decisions
• Grievance records and investigation outcomes
• Training records
• RJC origin reporting submissions and supporting data

Records shall be protected against unauthorised alteration or destruction and retained for the period required by applicable law, RJC requirements and the Company’s record-retention procedure.

17. Training and Awareness

Relevant employees shall receive induction and periodic refresher training appropriate to their role. Training shall cover, as applicable, responsible-sourcing commitments, red flags, KYC, CAHRA identification, human rights, AML/CFT, bribery, origin/traceability, grievance channels, escalation and non-retaliation. Attendance and training content shall be documented.

18. Exceptions and Escalation

No employee may waive or bypass mandatory due-diligence, sanctions, AML/CFT or legal controls without a documented and authorised basis. Exceptions or unresolved conflicts between procedures shall be escalated to the Compliance Officer and Senior Management. Legal requirements shall prevail where they impose a stricter standard.

19. Review, Approval and Continuous Improvement

This Policy and the effectiveness of the supporting responsible-sourcing management system shall be reviewed at least annually by Senior Management and, where appropriate, the Board, and additionally upon changes to applicable law, RJC standards, OECD requirements, material scope, sourcing countries, supply-chain structure, significant incidents, material grievances, audit findings or Company operations. Review results, decisions and required actions shall be documented. Revisions shall be approved through the Company’s document-control and governance process before taking effect.

20. Related Controlled Documents

• AML & CFT Policy
• KYC / Due Diligence SOP
• Risk Mitigation Plan
• Anti-Bribery & Anti-Corruption Policy
• Human Rights Policy
• Grievance Redressal Policy
• Whistleblower Policy
• Security Risk Assessment Policy
• Natural Resources / Environmental Policy
• Health & Safety Risk Assessment Policy
• Staff Safety & Training Policy
• Emergency Evacuation / Emergency Response Plan
• Non-Discrimination and POSH Policies
• Board / CTC Approval of Policies
• External reference: RJC Code of Practices 2024 and applicable RJC COP 2024 Guidance.
• External reference: OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including Annex II and the Supplement on Gold.