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Marudhar's Policies

Environment Policy

Introduction

At Marudhar Spg. Mills Private Limited, we are committed to conducting our business operations in a manner that minimizes our environmental impact. As a responsible corporate entity in the textile and spinning industry, we recognize the importance of protecting natural resources, reducing pollution, and fostering sustainable development for the benefit of future generations.

Scope

This policy applies to all employees, contractors, stakeholders, and operations at Marudhar Spg. Mills Private Limited, including manufacturing units, supply chains, and administrative offices.

Policy Objectives

The primary objectives of our Environmental Policy are:
• To comply with all applicable environmental laws, regulations, and standards.
• To integrate sustainability and environmental responsibility into all aspects of our operations.
• To continuously improve environmental performance through innovation and best practices.

Responsibility

The management of Marudhar Spg. Mills Private Limited is responsible for the implementation and enforcement of this policy. Each employee and stakeholder is encouraged to support the company’s environmental objectives and initiatives.

Key Commitments

Resource Efficiency
• Minimize the consumption of raw materials, energy, and water throughout our production processes.
• Promote the use of renewable energy sources and invest in energy-efficient technologies.
• Encourage the recycling and reuse of materials wherever feasible.

Pollution Prevention
• Implement measures to reduce air emissions, wastewater discharge, and solid waste generation.
• Ensure the proper treatment and safe disposal of hazardous and non-hazardous waste.
• Monitor and control noise pollution in compliance with regulatory standards.

Sustainable Practices
• Adopt sustainable sourcing practices by engaging with environmentally responsible suppliers.
• Develop and promote eco-friendly textile products.
• Encourage sustainable packaging and logistics practices to reduce the carbon footprint.

Awareness and Training
• Educate employees and stakeholders on environmental issues and best practices.
• Conduct regular training programs on environmental management systems and compliance.
• Foster a culture of environmental responsibility across all levels of the organization.

Monitoring and Reporting
• Set measurable environmental goals and regularly monitor performance against these objectives.
• Conduct periodic audits to ensure compliance with environmental standards.
• Report environmental performance and achievements transparently to stakeholders.

Compliance and Accountability

Marudhar Spg. Mills Private Limited is committed to adhering to all relevant environmental laws, regulations, and international standards. Any breach of this policy will be taken seriously and addressed promptly through corrective actions.

Continuous Improvement

We will continuously evaluate and enhance our environmental strategies and practices to align with emerging global trends and technologies. Feedback from stakeholders will be considered an essential part of this improvement process.

Communication

This Environmental Policy will be communicated to all employees, stakeholders, and the public through appropriate channels. A copy of this policy will be made available on the company website and in official documentation.

Review and Revision

This policy will be reviewed annually or as required to ensure its relevance and effectiveness. Updates will reflect changes in regulatory requirements, technological advancements, and organizational priorities.

Conclusion

Marudhar Spg. Mills Private Limited is committed to balancing economic growth with environmental stewardship. Through this Environmental Policy, we aim to make a positive contribution to the environment while delivering value to our customers and stakeholders.

Effective Date: 1st April 2024Policy Statement on Sexual Harassment at Workplace

Introduction

Marudhar Spinning Mills Private Limited (hereinafter referred to as “the Company”) is committed to fostering a safe, inclusive, and respectful workplace for all employees. Sexual harassment is a grave violation of human dignity and a form of workplace misconduct that will not be tolerated under any circumstances. This policy is established in compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“POSH Act”), and is applicable to all employees, irrespective of gender, across all levels of the organization.

Scope and Applicability

1. Who is Covered:
• All employees (permanent, temporary, contract, and trainees).
• Visitors, vendors, clients, contractors, and any third party associated with the Company.
2. Where is it Applicable:
• Premises of Marudhar Spinning Mills.
• Any location related to official work, including work-related travel, virtual workplaces, and off-site meetings or events.

Definition of Sexual Harassment

Sexual harassment includes, but is not limited to:
1. Physical Conduct: Unwelcome physical contact or advances.
2. Verbal Conduct: Comments or remarks of a sexual nature, innuendos, or derogatory
statements.
3. Non-Verbal Conduct: Displaying explicit imagery, leering, or suggestive gestures.
4. Quid Pro Quo: Demanding sexual favors in exchange for professional benefits like
promotions, salary hikes, or career growth.
5. Hostile Work Environment: Creating an intimidating, offensive, or uncomfortable work
environment through inappropriate behavior, jokes, or actions of a sexual nature.

Preventive Measures

1. Awareness Programs:
Regular training sessions and workshops to sensitize employees about sexual harassment and the POSH Act.
2. Display of Policy:
This policy will be prominently displayed across all work premises and accessible via the Company intranet.
3. Prohibition of Retaliation:
Retaliation against a complainant, witness, or anyone assisting in an inquiry is strictly prohibited.

Internal Complaints Committee (ICC)

1. Constitution:
An ICC will be constituted in line with the POSH Act. It will include a Presiding Officer (a senior female employee), at least two employee members, and an external member familiar with issues related to sexual harassment.
2. Responsibilities of the ICC:
• Address complaints promptly and maintain confidentiality.
• Conduct fair and unbiased inquiries.
• Recommend corrective actions, including penalties and preventive measures, as required.

Complaint Mechanism

1. Filing a Complaint:
• Complaints should be made in writing to the ICC within three months of the incident.
• The ICC may extend this period under reasonable circumstances.
2. Confidentiality:
• The identity of the complainant, respondent, and witnesses will be kept confidential throughout the process.
3. Inquiry Process:
• The ICC will conduct a detailed inquiry in accordance with principles of natural justice.
• Both the complainant and respondent will have an equal opportunity to present their case.
4. Resolution and Action:
• Based on the inquiry findings, the ICC may recommend disciplinary actions, including warnings, suspension, termination, or other corrective measures.
• If the complaint is found to be false or malicious, appropriate action will be taken against the complainant as per Company policies.

Support for Complainants

1. Counseling services or external support will be provided if necessary.
2. Transfers or temporary adjustments may be arranged to ensure the complainant’s comfort and safety.

Accountability and Review

1. Monitoring: The Company will regularly monitor the effectiveness of this policy and compliance with legal requirements.
2. Annual Report: The ICC will submit an annual report as mandated by the POSH Act, outlining the number of cases received, resolved, and pending.
3. Policy Review: This policy will be reviewed annually or as required to incorporate changes in legislation or feedback.

Communication

This Environmental Policy will be communicated to all employees, stakeholders, and the public through appropriate channels. A copy of this policy will be made available on the company website and in official documentation.

Conclusion

Marudhar Spinning Mills Private Limited is committed to maintaining a workplace where every individual feels respected and safe. Any violation of this policy will be addressed with the utmost seriousness.

For further assistance or to report an incident, please contact the Internal Complaints Committee at contact@marudharmills.com

Human Rights & Employment Policy

The Board of Directors of Marudhar Spinning Mills Private Limited (‘Marudhar’ or ‘We’) has determined that, on the recommendation of the members, Marudhar should formalise its policy on compliance with the Social Laws and employment laws of India, and thus has formulated this policy called “Human Rights & Employment Policy”.

Overview

Human rights are fundamental rights, freedoms, and standards of treatment to which all people are entitled. Respect for human rights is rooted in our values and applies wherever we do business. Marudhar Spinning Mills Private Limited’s Human Rights and Employment Policy (the “policy”) is intended to succinctly express Marudhar’s communication to respect human rights on a worldwide basis. It embodies common principles reflected in the United Nations (UN) Global Compact, the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the Organization for Economic Co-operation and Development Guidelines for Multinational Enterprises, Social Accountability 8000 Standards, Responsible Business Alliance Guidance, and the laws of the countries in which we operate.

Scope

The scope of the policy applies to all employees, subsidiaries, partners, suppliers, and contractors of Marudhar

Our Principles

1. Diversity and anti-discrimination
The makeup of our staff is large and diversified. We respect the diversity of our Board of Directors, workforce, and the versatility of our value chain. We do not tolerate discrimination and strictly forbid any discrimination against any employee based on ethnicity, nationality, region or social origin, social background, social class, lineage, religion, disability, gender, sexual orientation, family responsibilities, marital status, group membership, political affiliation, age, or other status protected by the local laws or laws of other countries.
2. Working hours, wages and benefits
All employment must be in full compliance with all applicable laws and apply international standards where laws are less stringent, including working hours, overtime hours, minimum wage, overtime pay, and legally mandated benefits. Employees shall be allowed at least one day off for each seven working days.
3. Freely Chosen Employment
Employees have the right to leave the workplace after the completion of standard working hours. Employees are free to terminate their employment contract after a reasonable notice period. All work should be done voluntarily. Employees have the right to terminate the employment contract in accordance with local laws or the reasonable notice period as agreed upon in the contract.
4. Prevention of forced labor and human trafficking. We require ourselves, third party employment agencies, suppliers and our business partners to ensure that all work is freely chosen. As an employer and global corporate citizen, we do not accept any type of forced labor, slavery, or human trafficking. These include the transportation, transfer, harboring, recruitment, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to anyone for the purpose of control.
5. Child Labor and Underage Workers
We prohibit the employment of child labor. We support the elimination of improper and illegal business transactions related to child labor and operate in accordance with relevant legal requirements and ethics. If underage workers are employed, their work safety must be guaranteed. They must not engage in work that could endanger their health and safety and must be managed properly.
6. Humane treatment
We are committed to treating our employees humanely and do not allow any form of violence or harassment in the workplace. This includes sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, verbal abuse of workers, or threat of any such treatment.
7. Freedom of association
We recognize that all employees in many of our operation locations have lawful rights to associate with others, form, and join, or refrain from joining organizations of their choice, and bargain collectively. We support freedom of expression and are committed to creating an environment where employees can share their concerns or suggestions freely without interference, discrimination, retaliation, or harassment.
8. Workplace health and safety
We are dedicated to providing all workers with a clean, healthy and safe working environment. We maintain an occupational health and safety management system to achieve greater protection, where appropriate. It is our policy to comply with applicable regulatory requirements, reduce health and safety risks, and strive to achieve zero injury and incidents.
9. Ethics
We request that all Marudhar members should uphold the highest standards of business ethics, including, but not limited to, maintaining business integrity, using no improper advantage, anti-corruption, avoiding conflicts of interest, protecting intellectual property rights, anti-trust, and assuring conflict minerals in products are from responsible sources.
10. Value chain responsibility
We expect all suppliers to uphold these same values and comply with our supplier code of conduct, and conflict mineral requirements (Supplier CSR Policy, Supplier Code of Conduct, Declaration of Compliance with RBA Code of Conduct, Metal Origins and Declaration of Conflict Metal Free). All suppliers shall follow up on the above request and implement practices under an effective mechanism. Suppliers shall pursue actions to identify, monitor, and mitigate any adverse impact along the value chain.

Policy Compliance

The Marudhar Human Right Policy is governed by a procedure that demands full compliance. Compliance with this policy will be reported to the Board of Directors annually. Daily practices and regular monitoring are implemented by each site through various modes. Grievance and remedy processes will take place on a continuous basis. Concerns from employees, partners, suppliers, and contractors can be communicated through various channels anonymously. Appropriate documents and records should be maintained to ensure compliance. To ensure the effectiveness of the policy, principles are reviewed annually and updated as needed. Training will be provided accordingly to employees and relevant stakeholders .

Grievance and Remedy Processes

We have put in place a formal grievance channel to enable anyone, including employees, Marudhar’s suppliers, and other external stakeholders, to report human rights concerns. We will promptly investigate allegations and pursue action to mitigate any adverse human rights impact. Marudhar does not tolerate retaliation against anyone who in good faith reports possible violations of laws, the Marudhar Code of Conduct, or other company policies or procedures.

Anti-Bribery & Corruption Policy

Introduction

The Board of Directors of Marudhar Spinning Mills Private Limited (‘Marudhar’ or ‘We’) has determined that, on the recommendation of the members, Marudhar should formalise its policy on compliance with the anti-corruption laws of India.

This Anti-Bribery & Corruption Policy (the "Policy") will supersede any other existing Marudhar policies relating to bribery and corruption.

The Compliance Officer is the General Manager (GM).

Policy Statement

It is Marudhar's policy to conduct all of its business in an honest and ethical manner. Marudhar takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships. It is the goal of Marudhar to avoid acts which might reflect adversely upon the integrity and reputation of the Company.

Individuals involved in corrupt activity may be fined or sentenced to imprisonment. Further, if Marudhar or any of its employees or associated persons (e.g. contractors, agents or subsidiaries) is found to have taken part in corruption, Marudhar could face an unlimited fine, and it could face serious damage to its reputation both in the public markets and in the countries in which it operates. Marudhar therefore takes its legal responsibilities very seriously.

Marudhar is committed to upholding all laws relevant to countering bribery and corruption in each of the jurisdictions in which it operates. As the anti-corruption laws of the UK, US and Canada have extraterritorial application, Marudhar, its employees and associated persons will be bound by the most stringent requirements of these laws in respect of its conduct in all jurisdictions they operate, even if such conduct would otherwise be permitted by the local law of a particular jurisdiction.

The purpose of this Policy is to:
• set out the responsibilities of Marudhar, and all individuals who work for Marudhar, in observing and upholding the Company's position on bribery and corruption; and
• provide information and guidance to those individuals working for Marudhar on how to recognise and deal with bribery and corruption issues.

In this Policy, 'third party' means any individual or organisation with whom you may come into contact during the course of your work for Marudhar, and includes actual and potential customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

Application of the Policy

The Policy applies to all directors, officers, employees, family members, consultants and contractors of Marudhar. Compliance with this Policy constitutes terms of service for each director, conditions of employment for each officer and employee, and conditions of providing services to Marudhar for each consultant and contractor. Each such person agrees to be bound by the provisions of this Policy upon notification of the most recent copy being given to them or upon notification that an updated version has been placed on Marudhar's website for review.

This Policy extends across all of the Company's business dealings and in all countries and territories in which the Company operates. All persons covered by this Policy, in discharging their duties on behalf of Marudhar, are required to comply with the laws, rules and regulations applicable in the location in which Marudhar is performing business activities, and in particular with respect to anti-bribery and corruption laws, rules and regulations. Where uncertainty or ambiguity exists, please contact the Compliance Officer who may seek further legal advice.

Forms of Bribery & Corruption

For purposes of this Policy, each of the examples given below is referred to as a 'bribery offence'

Bribes:
a) A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or business or personal advantage.
b) An inducement is something which helps to bring about an action or desired result.
c) A business advantage means that Marudhar is placed in a better position (financially, economically, or reputationally, or in any other way which is beneficial) either than its competitors or than it would otherwise have been had the bribery or corruption not taken place.

Kickbacks are payment of any portion of a contract made to employees of another contracting party or the utilisation of other techniques, such as subcontracts, purchase orders or consulting agreements, to channel payment to public officials, political parties, party officials or political candidates, to employees of another contracting party, or their relatives or business associates.

Extortion means to directly or indirectly demand or accept a bribe, facilitation payment or kickback.

Anti-Bribery & Corruption Standards

It is prohibited for Marudhar or its directors, officers, employees, consultants or contractors to:
a) give, promise to give, or offer, a payment, gift or hospitality to a third party or otherwise engage in or permit a bribery offence to occur, with the expectation or hope that an advantage in business will be received, or to reward a business advantage already given.
b) give, promise to give, or offer, a payment, gift or hospitality to a third party to "facilitate" or expedite a routine procedure.
c) accept a payment, gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by the Company in return.
d) threaten or retaliate against another employee or worker who has refused to commit a bribery offence or who has raised concerns under this Policy or Marudhar's Whistle Blowing Policy
e) engage in any activity that might lead to a breach of this Policy

Non-compliance with the Policy may result criminal or civil penalties which will vary according to the offence. An employee acting in contravention of the Policy will also face disciplinary action up to and including summary dismissal.

Gifts & Hospitality

This Policy does not prohibit normal and appropriate hospitality (given or received, in accordance with Marudhar's Gifts & Hospitality Policy) to or from third parties.

Marudhar's Gifts & Hospitality Policy sets out when it is, and is not, appropriate for you to make or receive gifts and / or hospitality from a third party. Please refer to the Gifts & Hospitality Policy for further details. In the event of inconsistency, this Policy supersedes the Gifts & Hospitality Policy.

Red Flags

The following is a list of 'red flags' that may indicate the possible existence of corrupt practices and should be kept in mind by all those subject to this Policy:
(a) Use of an agent with a poor reputation or with links to a foreign government.
(b) Unusually large commission payments or commission payments where the agent does not appear to have provided significant services.
(c) Cash payments, or payments made without a paper trail or without compliance with normal internal controls.
(d) Unusual bonuses to foreign personnel for which there is little supporting documentation.
(e) Payments to be made through third party countries or to offshore accounts.
(f) Private meetings requested by public contractors or companies hoping to tender for contracts.
(g) Not following Marudhar policies or procedures – abusing the decision-making process.
(h) Invoices rendered or paid in excess of contractual amounts.

This list is not exhaustive and you should be alert to other indicators that may raise a suspicion of corrupt activity.