Responsible Business Supply Chain Policy

1. BRPL is committed to the principle of  responsible sourcing  throughout the supply chain. BRPL understand that there are risks of associated with extracting, trading, handling and exporting minerals from conflict-affected and high-risk areas, and we recognize that we have the responsibility to respect human rights and not contribute to conflict, and protect the environment.It will implement these principles by :
   1. Establishing processes to prevent use of its organization in money laundering operation or crimnal activities. These would be based on the guidelines set forth by the Organisation for Economic Co-operation and Development(OECD) Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Area, third edition.
   2. Ensuring that minerals originating from notified  regions that are    mined to  benefit armed groups or to finance conflict‚ are not used in its products. This includes illegal financial support got by armed groups (non government/ private)  through the extraction, transport, trade or export of mineral. 
   3. Our endeavour is to ensure that the actors in the supply chain are  not involved in violation of international humanitarian law, human rights abuse in any forms of torture, cruel, inhuman and degrading treatment, forced or compulsory labour, child labour, and sexual violence. 
   4. Additional steps will be taken to ensure that the miners have paid the taxes, fees and royalties due to government and has not fraudulent misrepresentation of the origin of minerals. Steps will be taken to ensure that the miners and other actors are not involved in bribery related to the metals.
   5. Including measures to assess and mitigate the risk of financing terrorism within the supply chain, ensuring compliance with relevant regulations and standards.
   6. Suspending or discontinuing engagement with any counterparty where a reasonable risk is identified to indicate that they have sourced gold from, or linked to, any party committing serious abuses as defined above.
2. Further BRPL is committed to support measures to create a  Gold Supply chain from   mines to market that will be   responsible,  secure, transparent and verifiable by  establishing  long-term relationships with precious metals suppliers and customers.It will implement the management system that :
   1. Encompasses strict risk based due diligence process before entering into new commercial relationships
   2. Provide training to employees and suppliers on responsible sourcing practices and risk management.
   3. Widely disseminate the principles across the organization and supply chain. Will also incorporate in contracts and/or agreements, with suppliers the following policy on responsible sourcing of minerals from conflict-affected and high-risk areas.
   4. Maintain adequate records to demonstrate that appropriate and ongoing due diligence have been followed. Including the origin, transportation, and processing of gold.
   5. Continuous monitoring of transactions on a risk based approach.
3. BRPL will perform appropriate due diligence and risk assessment of our counterparties before conducting  any business with them.   When necessary, carry out on-the-ground assessments to verify supplier practices.
4. BRPL will periodically monitor and assessment of the supply chain in order to assess the risk of contribution to conflict, money laundering and serious human rights abuse and implement a strategy to respond to identified risk. Develop a risk management plan to respond to identified risks.
5. BRPL will encourage and assist  it’s suppliers to be part of the Larger Global supply chain for responsible gold. If some suppliers are found to have  minor infractions, steps will  be taken to help   them correct the same. If  it's not feasible  then such business  relationships will be terminated.
6. Conduct audits at regular intervals, of the supply chain to verify compliance with this policy and the OECD Guidance.
7. Publicly report on our due diligence activities, including risk assessments, mitigation strategies, and audit results. Use the findings from audits and reports to continuously improve our sourcing practices.
8. Any action required to be undertaken under this  Policy shall be taken by the Compliance Officer in accordance with this Policy. The Compliance Officer shall have a functional reporting to the Designated Director. Aggravated cases of breach of this AML Policy shall be escalated to the Board of Directors of our Company through the Designated Director. Please  send an  email to umesh@bangalorerefinery.com for any query regarding this policy.

 NOTE: The above policy is implemented with effect from 22 July 2023.