Mahavir Bullion & Refinery Private Limited (MBRPL) is committed to maintaining high standards of integrity, ethics, transparency and accountability. The Company provides a protected reporting mechanism through which employees and relevant external stakeholders can raise genuine concerns about misconduct, violations of law, Company policy or responsible-business requirements.
This Policy is based on the Company's original Whistleblower & Ethics Reporting Policy, while updating the RJC references to COP 2024. RJC COP 2024 COP 18.5 requires the complaints and grievance mechanism to be actively communicated to workers, permit workers to raise grievances without penalty or retaliation, and allow a worker to involve a workers' representative if requested.
3. Purpose
• Provide a safe, confidential and accessible channel for reporting genuine concerns. • Encourage good-faith reporting without fear of retaliation. • Enable early identification of fraud, bribery, corruption, human-rights, labour, environmental, safety, sourcing and compliance concerns. • Ensure reports are screened, investigated and resolved fairly and proportionately. • Protect whistleblowers, witnesses and other participants from retaliation. • Support the Company's RJC COP 2024 management and grievance framework.
4. Scope
This Policy applies to permanent, temporary and contractual employees, trainees, apprentices, Board members, senior management, department heads, job workers, consultants, contractors, security personnel, suppliers, service providers, logistics partners and other external stakeholders interacting with the Company, where the reporting channel is made available to them.
5. RJC COP 2024 Alignment
Requirement
Policy Response
Evidence
COP 2 – Policy & Management Systems
Maintains a documented reporting mechanism, responsibilities, records, communication, monitoring and review.
Approved policy, registers, communications and review records.
COP 18.5(a) – Communication
Communicates the complaints/grievance mechanism to workers, including new workers at recruitment.
Allows involvement of a worker representative where requested by the worker.
Case records and procedure.
6. Definitions
Term
Definition
Whistleblower
A person who raises a concern or makes a protected disclosure in good faith.
Protected Disclosure
A communication made in good faith concerning suspected unethical conduct, fraud, misconduct, legal or policy violations, or other reportable matters.
Subject
The person or entity against whom a report is made.
Good Faith
A genuine belief that the information reported raises a legitimate concern, even if the concern is ultimately not substantiated.
Retaliation
Any adverse action or threat of adverse action because a person raised a concern, participated in an investigation or otherwise used the reporting mechanism.
7. Policy Principles
• Confidentiality – information and identity are protected on a need-to-know basis, subject to law. • Non-retaliation – good-faith reporters and participants are protected from adverse treatment. • Impartiality – reports are assessed and investigated objectively. • Accessibility – reporting channels should be practical and understandable to intended users. • Fairness – the subject of a report will be treated fairly and given an opportunity to respond where appropriate. • Proportionality – investigation and corrective action will be appropriate to the allegation and risk. • Documentation – reports, decisions and actions are documented securely. • No automatic presumption of guilt – a report is an allegation until assessed/investigated.
8. Reportable Matters
Category
Examples
Financial Misconduct
Fraud, embezzlement, theft, misuse of funds, over/under-invoicing, falsification of records.
Ethical Misconduct
Bribery, corruption, kickbacks, facilitation payments, conflicts of interest and improper procurement favouritism.
Human Rights & Labour
Child labour, forced labour, discrimination, harassment, unsafe working conditions, suppression of grievances or other human-rights concerns.
Environmental
Illegal waste disposal, pollution, hazardous-chemical misuse or material breach of environmental requirements.
Responsible Sourcing
Misrepresentation of precious-metal origin, illegal sourcing, conflict/high-risk sourcing concerns, or non-compliance with responsible-sourcing requirements.
Regulatory / Compliance
Suspected violation of applicable PMLA, GST, Customs, DGFT, BIS or other applicable requirements, and RJC COP requirements.
Security / Asset Misconduct
Theft, pilferage, misappropriation, tampering, unauthorised access or serious security breaches.
Health, Safety & Workplace Conduct
Serious safety violations, sexual harassment or other workplace violence/harassment. Matters specifically governed by the POSH process shall be routed to the designated POSH mechanism as applicable.
9. Reporting Channels
• Whistleblower E-mail: connect@mbrpvt.com • Sealed written complaint/drop-box: Corporate Office: Mahavir Bullion & Refinery Pvt.Ltd., S.N.K. Plaza 1, 23/25, Nasta Galli, 3rd Agyary Lane, Ground Floor, Office No.1, Mumbai - 400 003. • Direct reporting to the Compliance Officer. • Direct reporting to the Managing Director or designated senior management representative. • Reporting to a designated Whistleblower Committee member. • Anonymous reports may be accepted where sufficient information is provided to permit meaningful assessment/investigation. • Where a concern relates to the Compliance Officer or a Committee member, the report shall be escalated to an independent senior authority/Board-designated person.
The actual email address and physical reporting location must be completed before the Policy is issued as an operative controlled document; the original policy currently contained placeholders for both.
10. Reporting Process
Stage
Requirement
Receipt
Report is received through an approved channel and recorded securely.
Acknowledgement
Where contact details are available, acknowledge receipt within 7 working days.
Preliminary Screening
Determine scope, seriousness, conflicts of interest, immediate protection needs and whether another specialist procedure applies.
Investigation Planning
Define investigator(s), scope, evidence required, confidentiality controls and target timeline.
Investigation
Review relevant documents, records, CCTV/logs where appropriate, transactions and witness/subject statements.
Findings
Document allegations, evidence considered, findings and whether allegations are substantiated, partially substantiated or unsubstantiated.
Corrective Action
Where appropriate, implement disciplinary, control, remediation, training, process or other corrective actions.
Closure & Communication
Close the case with appropriate communication to the reporter, subject and management, while protecting confidentiality and legal restrictions.
Monitoring
Track corrective actions to closure and review whether retaliation or recurrence risks remain.
11. Investigation Timelines
The original Company Policy provides the following internal target timelines: acknowledgement within 7 working days, routine investigations within 45 days, and complex or multi-party investigations within 90 days.
• Routine cases – target completion within 45 days. • Complex or multi-party cases – target completion within 90 days. • Where a case cannot reasonably be completed within the target, document the reason, revised target and escalation/communication required. • Statutory or specialist procedures, including POSH, shall follow their applicable legal timelines where those differ.
12. Protection Against Retaliation
Retaliation against a person who raises a concern in good faith, provides information, acts as a witness, participates in an investigation or otherwise uses the reporting mechanism is prohibited. RJC COP 18.5 specifically requires workers to be able to raise grievances without penalty or retaliation.
• Termination or threatened termination • Demotion or denial of legitimate benefits • Unjustified salary/benefit reduction • Harassment, intimidation or threats • Unjustified disadvantageous transfer or work assignment • Coercion or adverse treatment because of participation in an investigation
Alleged retaliation shall itself be treated as a reportable matter and investigated promptly. Persons found responsible may face disciplinary action.
13. Confidentiality & Data Protection
• Identity of the whistleblower shall be protected to the extent reasonably possible and permitted by law. • Information shall be shared only with persons who need it for assessment, investigation, legal compliance or corrective action. • Case files shall be stored securely with controlled access. • Investigators shall avoid unnecessary disclosure of sensitive information. • Confidentiality breaches may result in disciplinary action, subject to applicable law and due process.
14. Fair Treatment of the Subject
• A report shall not be treated as proof of wrongdoing. • The subject shall be given a fair opportunity to respond where appropriate and consistent with investigation integrity. • Investigators shall consider relevant evidence supporting and contradicting the allegation. • Corrective/disciplinary action shall be based on findings and applicable Company procedures.
15. False or Malicious Disclosures
Knowingly false or malicious allegations may result in disciplinary action in accordance with Company policy and applicable law. A good-faith report shall remain protected even where the allegation is ultimately not substantiated.
16. Communication & Training
• Include the reporting mechanism in new-joiner induction. • Provide periodic awareness training on reporting rights, confidentiality and non-retaliation. • Display or communicate reporting channels in accessible locations/formats. • Inform relevant contractors and suppliers of the mechanism where applicable. • Train persons responsible for receiving or investigating reports on confidentiality, impartiality, non-retaliation and investigation procedures. • Communicate any changes to reporting channels promptly.
RJC guidance emphasises that grievance mechanisms should be legitimate, accessible, communicated, rights-compatible, unbiased and equitable.
17. Roles & Responsibilities
Role
Responsibilities
Board / Senior Management
Approve policy; oversee significant matters; ensure independence/resources where required.
Compliance Officer
Administer reporting mechanism, maintain register, coordinate screening/investigations and monitor corrective actions.
Whistleblower Committee / Investigators
Conduct impartial assessments/investigations, protect confidentiality and document findings.
HR
Support employee-related cases, disciplinary processes and protection measures while maintaining confidentiality.
Employees & Stakeholders
Raise genuine concerns in good faith and cooperate honestly with investigations.
Managers
Do not obstruct reporting; escalate concerns received through management channels and prevent retaliation.
18. Interaction with Other Reporting Mechanisms
Concern Type
Primary Mechanism
Note
Ethics, fraud, bribery, compliance, sourcing and serious misconduct
Whistleblower & Ethics Reporting Policy
Use this mechanism where protected disclosure is appropriate.
General workplace grievance
Grievance Redressal Policy
Follow the general grievance process.
Sexual harassment covered by POSH law
POSH / Internal Committee process
Statutory procedure and timelines apply.
Human-rights concerns
Human Rights / Grievance mechanism
Whistleblower route remains available where appropriate.
Immediate safety emergency
Emergency / Security / EHS reporting
Do not wait for the whistleblower investigation process.
19. Records & Retention
• Whistleblower/Protected Disclosure Register • Original complaints and supporting evidence • Acknowledgements and communications • Screening/conflict-of-interest records • Investigation plans and reports • Witness/subject statements where maintained • Corrective and disciplinary action records • Retaliation monitoring records • Training/communication records • Management/Board reporting records
Records shall be retained securely in accordance with applicable law and the Company's controlled-record retention requirements, with access restricted to authorised personnel.
20. Monitoring & Continuous Improvement
• Monitor number and type of reports, acknowledgement/completion times and overdue cases. • Review recurring themes and control weaknesses without compromising confidentiality. • Track corrective actions to closure and effectiveness. • Review whether reporting channels remain accessible and trusted. • Use lessons learned to strengthen policies, controls and training. • Conduct an annual management review of the mechanism.
21. Policy Review
This Policy shall be reviewed at least annually and additionally following changes in law or RJC requirements, significant cases, audit findings, material process changes, changes to reporting channels or other events that may affect the effectiveness of the mechanism.
