BUSINESS COMPLIANCE AND POLICIES

ETHICAL BUSINESS PRINCIPLES

1. Background

• At JEWELEX GROUP, our philosophy is to measure success by not only the results we achieve, but also how we achieve them.
• This Business Principles document, adopted by JEWELEX GROUP sets forth the basic internal standards to be observed by all Directors, officers and employees of the Company with respect to conducting business in a legal, ethical, professional and accountable manner.
• The Company is required to take appropriate steps to ensure that the same is understood and put into practice by all of its Directors, officers and employees.
• Also appropriate steps are taken to assure adherence to the Business Principles document, including establishing appropriate disciplinary procedures where violations of this document will result in sanctions up to and including discharge.

2. Legislation and Regulations

• JEWELEX GROUP shall operate in compliance with relevant national and international legislations / regulations as applicable in the countries in which they operate.
• All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal Company rules and policies relating to their business activities.
• It is the responsibility of personnel to know and understand legal, regulatory and internal requirements as they apply to their jobs.
• Compliance team maintains the list of applicable legal and regulatory requirements and same is followed for compliance on day to day basis. Necessary records of requirements and its compliance is maintained.

3. Money Laundering, Terrorism Financing, Other Financial Offences

• JEWELEX GROUP recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
• Strict compliance is required at all times, with all applicable national and, where appropriate, international laws / regulations with respect to money laundering, terrorism financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.
• JEWELEX GROUP shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations.
• It is the responsibility of concerned personnel to know and understand the relevant money laundering / financial offences related legal, regulatory and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious activity that appears to be questionable may also be considered as a violation of the Business Principles, depending on the seriousness of the non-conformance.
• Compliance officer ensure all the critical steps such as obtaining KYC, identification of suspicious transaction, reporting to management and record keeping as required by the local act and legislations are complied with.

4. Kimberley Process and System of Warranties

• JEWELEX GROUP is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and World Diamond Council’s (WDC) System of Warranties Declaration.
• The definition of ‘Conflict Diamonds’ as agreed by the Kimberley Process Certification System

“Rough diamonds used by rebel movements or their allies to finance conflict aimed at undermining legitimate Governments, as described in relevant United Nations Security Council (UNSC) resolutions insofar as they remain in effect, or in other similar UNSC resolutions which may be adopted in the future, and as understood and recognized in United Nations General Assembly (UNGA) Resolution 55/56, or in other similar UNGA resolutions which may be adopted in the future.”

• Wherever applicable, the following affirmative statement as recommended by the World Diamond Council’s System of Warranties should be printed on all the invoices:

“The diamonds herein invoiced have been sourced / purchased from legitimate sources not involved in funding conflict, in compliance with United Nations resolutions and corresponding national laws. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WDC SoW Guidelines.”

• Entering into transactions involving ‘conflict diamonds’ or not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, will be considered as a violation of the Business Principles.

5. Anti-Bribery and Facilitation Payment Policy:

• Jewelex Group shall ensure complete prohibition of Bribery and facilitation payment across organization and in all the group entities.
• Company will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.
• The company shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.
• Periodic training and awareness shall be carried out to educate employees about various type and ways of bribery and facilitation payments.

6. Disclosure of Treated Diamonds, Synthetics and Simulant

• The following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and simulant
• Full disclosure i.e. the complete and total release of all available information about a Diamond and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the diamond.
• No misuse of terminology or mis-representations or attempts to disguise the product will be made in the selling, advertising and distribution of treated diamonds, synthetics and simulant.

The word ‘diamond’ will not be used in the case of names of firms, manufacturers or trademarks; in connection with treated diamonds or diamond simulant or synthetic diamonds.

JEWELEX GROUP has adopted the following definitions:

Diamond: A diamond is a natural mineral consisting essentially of pure carbon crystallized with a cubic structure in the isometric system.

Synthetic: A synthetic is any object or object that has been either partially or wholly crystallized or re-crystallized due to artificial human intervention such that, with the exception of being non-natural, the product meets the requirements specified in the definition of the word ‘diamond’ above.

Treated Diamond: A treated diamond is any object or product that meets the requirements specified in the definition of the word’s ‘diamond’ and ‘synthetic’ above, but has been subject to some form of treatment i.e. any process, enhancement changing, interfering with and/or contaminating the natural appearance or composition of a diamond other than historically accepted practices of cutting and polishing.

Note: Necessary declaration is provided on invoice in case of CZ are used in jewellery and same is communicated verbally prior to execution of sale.

7. Gold Sourcing Policy:

Our company is concerned about the environment and social impacts of irresponsible mining.

We at Jewelex India Pvt. Ltd. shall ensure that all our gold suppliers’ comply with gold sourcing guidelines.

Further we are committed to ensure that sourcing of gold and precious metals products and articles are under the highest social, Human rights and environmental standard of trade.

8. Supply Chain Management / Best Endeavours

• The management of JEWELEX GROUP is committed to taking appropriate action to use best endeavours to ensure the commitment of Tier 2 & Tier 3 entities to comply with the Best Practice Principles.

9. Conflict Minerals Policy Statement (Diamond & Gem Stone) as per OECD

JEWELEX GROUP is committed to trade in conflict free supply chain and as a part of its compliance strategy majority of our upstream supplies are coming from Primary (Mine suppliers) and Secondary suppliers (auctions purchase and sale from Tier -1 rough suppliers) where origin of diamonds is known and easily established that it is conflict free.

• OECD sourcing policy has been published on company website
• Sourcing policy has been communicated to all the suppliers and vendor questions to Tier-2 suppliers have been circulated to seek information for their upstream supply chain.
• Ongoing monitoring by compliance officer is carried out to ensure compliance of these sourcing policy.
• 90 % plus products are sourced directly or indirectly from mine on a long-term contract
• We have necessary infrastructure and testing facility for polish purchase, records of testing and screenings are maintained.

10. Employment

• Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.
• The Company shall not require workers to work for more than the national limit of working hours.
• The Company shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of workers and provide some discretionary income.
• It is the responsibility of concerned personnel to know and understand the relevant employment and labour related legal, regulatory and internal requirements as they apply to their jobs.
• When required, due recognition will be given to the existence, membership and lawful activities of worker representative bodies, and worker representatives will be given access to carry out their responsibilities / functions.
• The procedures detailed in the Employee Manual should be followed for dismissal of employees, in case the need for the same arises and arbitrary dismissal procedures should be avoided.
• Information regarding applicable employment policies and working practices should be communicated in a transparent manner to all employees.

11. Health and Safety

JEWELEX GROUP recognizes the need to provide safe and healthy working conditions to all its employees.:

• Any adverse impact of our business processes on those who carry it out shall be identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.
• This review will use appropriate standards as required by prevailing laws, expert opinion and our knowledge of best practices.
• The review will lead to formulation of clearly described work practices and drills.
• All our staff will be trained in the manner required to adhere to these work practices and drills.
• The health of our staff, exposed to certain hazardous processes, will be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
• Workers shall not be under the influence of or abusing, drugs, alcohol and/ or other illegal substances.
• We will seek to substitute the use of material, which are known to cause an adverse impact on the health of workers or health of consumers in the course of its manufacture or use.
• All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable.
• Wherever requires and applicable, individual entities will nominate a Health, Safety and Environment Committee, headed by a senior management representative, which will have its fullest support in executing operational changes required to carry out these policies.

12. Non Discrimination, Disciplinary Practices

• Discrimination can mean distinction, exclusion or preference.
• Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by the Company and any such reported incidents will be viewed as a serious violation of this Business Principles.
• JEWELEX GROUP will ensure that employees who have certain life threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.
• JEWELEX GROUP shall at no time condone the use of corporal punishment or other forms of mental or physical coercion
• JEWELEX GROUP encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, Company operation or practice is or will likely be in violation of any law, regulation or internal Company rule or policy, including this Business Principles. JEWELEX GROUP shall assure all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully.

13. Child Labour

• No form of child labour should be employed at any of the facilities of JEWELEX GROUP.
• Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).
• For authorized adolescents (persons below 18 years of age but above 15 years), the Company management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
• As per our company policy no child labour or adolescent child labour will be employed.
• Company will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

14. Forced Labour

• The management of JEWELEX GROUP is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of this Business Principles.

The following definitions will be applicable:

• The Universal Declaration of Human Rights that states that ‘No one shall be held in slavery or servitude’
• ILO Convention 29, which defines forced or compulsory labour as “all work or service which is extracted from any person under the menace of any penalty, and for which the said person has not offered himself voluntarily”

15. Human Rights

• All employees in the Company’s facilities will be treated with equality, respect and dignity.
• JEWELEX GROUP will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation
• The Company strongly discourages any form of sexually coercive, threatening, abusive or exploitative behaviour.
• Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company.
• Grievance Committee & Anti sexual harassment committees are formed and committee shall review the compliance at regular intervals.

16. Environment Protection

JEWELEX GROUP is committed to effective environmental management as one of its important corporate priorities, and will focus on the following initiatives:

• Compliance with all applicable environmental laws and regulations
• The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards and reviewed periodically to mitigate or eliminate such impact.
• Disposal procedures for waste generated will be clearly defined and practiced in line with standards that are set by law and best practices of the industry.
• Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.
• Measurement of environmental performance through auditing with employee accountability and reporting to senior management.
• Commitment to a continual improvement process in environmental management.

17. Product Security

JEWELEX GROUP is committed to secure its product throughout its supply chain by following precaution as mentioned below:

• Each and every stage of product processing it is covered through blanket insurance
• Suitable safe guarding and storage is ensured at all stage with the help of safes
• All the manufacturing, sales and retailing units are guarded by security agency and monitored by close circuit cameras.
• All the concerned persons are trained on relevant safety and security procedures to be followed at all time.
• Organization has developed emergency plan, which includes procedure in case of emergency (include emergency scenario such as theft, robbery, etc.)
• Product purity, quality and other parameters are monitored at each stage to avoid switching of the product.

18. Environment Responsibility

JEWELEX GROUP is committed to comply with environment regulations and shall ensure all its facility have adequate arrangement for reduction, reuse and recycling of process wastes.

• Compliance with all applicable environmental laws and regulations.
• Effective communication of environment requirements and its compliance procedure to all the concerned employees on regular basis.
• All the entities of the organization will identify the manufacturing processes being carried out in the premises. Once the activities are identified than it will be reviewed for environmental hazards associated with each of the activities.
• Environmental hazards will be evaluated in terms of probability of occurrence of an activity and associated risks to environment. This will be further classified in to high, medium and low risk.

19. Lab Grown Diamonds

JEWELEX GROUP is committed to fight against undisclosed LGDs. Following methodology has to be adopted for ensuring compliance to undisclosed LGDs.

• Access to effective detection system
• Buying from trusted suppliers
• Factory controls in place and safety measure are to be implemented to control switchover of diamonds.
• Reporting of un-disclosed synthetics to supplier and interested parties whenever detected.
• Record the incidents of contamination reported and implement suitable corrective and preventive measures for effective controls.
• Tabulate the flow of business processes and identify the potential areas of contaminations
• Classify contamination of points into different category (High, Medium & Low)
• Identify the policy, procedure and test mechanism to implement testing procedures in the organization.

Public Grievances

Keeping in view the increasing importance to redress public grievances, company has introduced the common grievance cell to look in to the matter of reporting noncompliance of any of the company policy or raising red flag against any of its business entity or individual involved in activities that are against the company policy and which will bring industry in to disrepute. Any such matter can be communicated to below mentioned members.

JEWELEX GROUP
ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR THE YEAR 2023-24

DATED: 23rd May, 2024

Like the multiple facets of a diamond, Jewelex goes beyond the value chain by providing superior products, customer care and services that are acknowledged within the global jewelry industry. We are among the world's leading vertically integrated diamond and jewelry companies known for integrity, innovation and trust. Being in the gems and jewelry business for over half a century, Jewelex has obtained a strong reputation. This is reflected by our wide range of product lines, strong global presence, and deep manufacturing expertise earned over the years. Jewelex India Private Limited is a Sightholder of De Beers Group. We are also a member of the Responsible Jewellery Council. We are recognized for consistency, excellent customer service and transparency in our operations. Integrated business model, cutting-edge technology, and skilled human resources have ensured Jewelex to be the supplier of choice for leading jewelry brands. Continuous innovation, unrelenting desire for excellence, care towards all stakeholders and working with complete integrity are the spirits which drive Jewelex.

Following entities covered in this report: Companies fall under Midstream Tier 1

• Jewelex India Pvt. Ltd.
• Jewelex Antwerp NV
• Jewelex Europe N.V.
• Jewelex Australia Pty Ltd
• Jewelex HK Ltd
• Jewelex Japan Ltd.
• Jewelex Middle East DMCC
• Jewelex New York Ltd

Section B: Financial compliance of the JEWELEX GROUP:

2.1 Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

• JEWELEX GROUP recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
• Strict compliance is ensured at all the entities and compliance officer has been appointed who in turn reports to JEWELEX GROUP Management on compliance status on annual basis.
• Know Your Counter Party and other compliance of Due Diligence is followed in line with OECD guidance.
• Ongoing monitoring is carried out along with all stakeholders.

Area of concern & Remedial Measures

• Nil As on Date.

2.2 Kimberley Process and System of Warranties

• JEWELEX GROUP is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme of World Diamond Council’s (WDC) System of Warranties Declaration.
• Day to day monitoring and compliance of SOW is done by compliance officer.
• JEWELEX GROUP is committed towards conflict free sourcing and zero tolerance policy is followed at JEWELEX GROUP level.

Area of concern & Remedial Measures

• Nil As on Date.

2.3 Anti-Bribery and Facilitation Payment Policy:

• The JEWELEX GROUP shall ensure complete prohibition Bribery and facilitation payment across organization and in all the entities.
• JEWELEX GROUP has published compliance team contact details on website to receive any grievance or complaints.

Area of concern & Remedial Measures

• Nil As on Date.

2.4 Ethical Sourcing of Loose Diamonds Policy:

• Our company is concerned about the environment and social impacts of irresponsible mining.
• JEWELEX GROUP has identified the risk of supply chain with respect to Conflict Affected High Risk Area.
• JEWELEX GROUP ensure all its supplies are screened for conflict free supplies.
• We have published the OECD based ethical sourcing policy and we are communicating our policies to all the supply chain partners and pushing them to adopt the same.

Area of concern & Remedial Measures

• Current concern is lack of awareness about OECD regulation and requirements of sourcing.
• We have started creating awareness about our Ethical sourcing requirements for our supply chain.
• We started Engagement with our global supply chain for obtaining the further supply chain information to ensure ethical and conflict free sourcing in metal business.

2.5 Social Compliance

• We ensure full compliance with all applicable national and, where appropriate, international laws / regulations with respect to employment and labour codes in all our establishment.
• We respect all regulation for child labour, forced labour, non-discrimination, non-retaliation etc.
• All work man rights are respected and adhere to freedom of association and collective bargaining regulations.

Area of concern & Remedial Measures

• No point has been reported in the social compliance of the JEWELEX GROUP where remedial measures at JEWELEX GROUP level is required.
• Entity level remedial measures are taken based on internal and external audits conducted by reputed agencies.

2.6 Health and Safety

• We at JEWELEX GROUP are concern about the health and safety of employees and are constantly studding about any adverse impact of our business processes and the same are identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.
• This review will use appropriate standards as required by prevailing laws, expert opinion, and our knowledge of best practices.
• All our staff are trained in the manner required to adhere to these work practices and drills.
• The health of our employees who are exposed to certain hazardous processes, is being monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
• All workplaces are constructed in such a manner so as to meet safety standards with local regulations and applicable standards.

Area of concern & Remedial Measures

• Nil as on date, no accidents are reported in last one year.
• Organization has been blessed and we did not have any fire or any other incidents leading to dangerous circumstances.

2.7 Human Rights

• JEWELEX GROUP is not and will not interfere in the rights of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation.
• The Company strongly discourages any form of sexually coercive, threatening, abusive or exploitative behaviour.
• Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company.
• JEWELEX GROUP ensures that none of its suppliers and stake holder have engaged in any activity which can violate the Human Right Principles.
• We have carried out the Human Right Due Diligence of suppliers and other Stake holders & based on risk assessment where necessary.

Area of concern & Remedial Measures

• No Area of concern & Remedial Measures has been raised in the Human right for any of our operating units.
• Supplier’s further upstream compliance with respect to Human Right compliance for conflict free sourcing is a new development, where company is heading and would require more focus on the same.

2.8 Environment Protection

• JEWELEX GROUP is Complying with all applicable environmental laws and regulations.
• Improvement is seen employee’s environmental awareness and performance with the help of detailed policies and procedures, training, and recognition of excellence.