The philosophy of Hindustan Platinum Private Limited (HPPL - "the Company") is to maintain the highest standards of business conduct and ethics by commercial practice or applicable laws, rules or regulations and to set up the mechanism to monitor the functioning of the policy along with the applicability.
As one of the London Good Delivery Refiners, HPPL conducts its business with highest level of ethical, moral and social responsibility standards. We require all our employees to comply with high integrity and honesty.
Our entire business cycle, from sourcing to delivery of the finished products is monitored for all the associated risks.
Applicability and Scope:
The policy shall apply for refining of Silver. This policy shall be effective April 01, 2018 and shall apply to all employees. Any changes / amendments to the policy shall be effective post approval from the Board of Directors.
HPPL ensures that the scope of the policy revolves around the following parameters:
1) Establish strong company management systems.
2) Identify and access risk in the supply chain.
3) Design and implement a management strategy to respond to identified risks.
4) All transactions are monitored for compliance with the policy and appropriate records are kept to an auditable standard to ensure compliance is demonstrated.
5) Arrange for an independent third party audit of the supply chain due diligence as required by LBMA/LPPM.
6) Report on supply chain due diligence.
For the smooth functioning of this policy, the Board shall be responsible to:
a) Approve the objectives and the policy framework.
b) Approve any changes to the policy.
c) Delegate the monitoring responsibility to any person authorized as such.
The Compliance Officer shall:
a) Ensure that the activities are managed according to the objectives of this policy.
b) Review the activities undertaken by various business teams.
c) Review various risks for the counterparties or processes.
d) Oversee, review and ensure control mechanism for effective functioning of the policy.
e) Reporting the risks/activities to the Board of Directors.
f) Inform any changes in the market regulations, governing law and rules to all the relevant stakeholders.
g) Monitor and propose changes to the Policy.
With reference to the sourcing of precious metals, HPPL commits that:
1) All employees shall be treated fairly, with dignity and respect. We shall not tolerate our counterparties with any forms of violations to human rights and laws.
2) Not to enter in to any dealing with counterparties who do not have adequate procedures for compliance and remedial of human rights violations.
3) We shall not tolerate any forms of forced, compulsory labour or any form of child labour, discrimination in hiring and employment practices. Discrimination includes but is not limited to ethnicity, caste, national or social origin, religion, age, disability, gender, marital status, political opinion.
4) To ensure a safe and healthy working environment, including physical and psychosocial health.
5) To observe neutrality or be transparent regarding support to political parties and political representatives.
6) Not to procure/source precious metals from illegal sources or from sources which do not comply with rules and regulations related to human rights, child labour, anti money laundering, terrorist financing. We expect our suppliers to follow the same.
7) To ensure that all dealings are routed through official banking channels as required by law.
8) As a policy, the Company shall not procure from High Risk Areas or Sanctioned Areas or Artisanal mining or Dore materials. In an event the Company enters into transactions with such entities then the Company shall get into deep and enhanced due diligence.
9) Immediately suspend or discontinue engagement with our counterparty where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as defined above.
HPPL ensures that the policy is strictly followed by the employees. Dealings with all counterparties shall be reviewed on a periodic basis with reference to the policy guidelines and risks associated with the transactions.
Any non-compliance to the policy should be reported by an email to email@example.com. The employees are free to raise their concerns either to their reporting managers or to the Compliance Officer.Non-compliance with this Code may have negative impact on the business relationship between counterparties and HPPL.
The Board of Directors shall review the said non compliance and reserves the right to terminate any contract or terminate business relationship.