Section A: General Information about the Company:

Like the multiple facets of a diamond, Zenstar Jewelry LLC 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 industry’s leading jewelry trading companies known for integrity, innovation and trust. Being in the gems and jewelry business, Zenstar Jewelry LLC has obtained a strong reputation. This is reflected by our wide range of product lines and strong global presence. We are recognized for consistency, excellent customer service and transparency in our operations. Continuous innovation, unrelenting desire for excellence, care towards all stakeholders and working with complete integrity are the spirits which drive Zenstar.

Section B: Financial compliance:

2.1 Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

• Zenstar Jewelry LLC 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 and compliance officer has been appointed who in turn reports to Management of ZENSTAR JEWELRY LLC 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

• ZENSTAR JEWELRY LLC 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.
• ZENSTAR JEWELRY LLC is committed towards conflict free sourcing and zero tolerance policy is followed.

Area of concern & Remedial Measures

• Nil As on Date.

2.3 Anti-Bribery and Facilitation Payment Policy:

• ZENSTAR JEWELRY LLC shall ensure complete prohibition of Bribery and facilitation payment
• ZENSTAR JEWELRY LLC has published compliance officer’s contact details on website to receive any grievance or complaints.

Area of concern & Remedial Measures

• Nil As on Date.

2.4 Ethical Sourcing of Diamonds Policy:

• Our company is concerned about the environment and social impacts of irresponsible mining.
• ZENSTAR JEWELRY LLC has identified the risk of supply chain with respect to Conflict Affected High Risk Area.
• ZENSTAR JEWELRY LLC 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.

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.
• We respect all regulation for child labour, forced labour, non-discrimination, non-retaliation etc.
• Policies are developed for work man rights and adhere to freedom of association and collective bargaining regulations.

Area of concern & Remedial Measures

• Currently company does not have any employees and day to day business operations are handled by Partners. However, polices are in place.

2.6 Health and Safety

• We at ZENSTAR JEWELRY LLC 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 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.

2.7 Human Rights

• ZENSTAR JEWELRY LLC 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.
• ZENSTAR JEWELRY LLC ensures that none of its suppliers and stake holder aree engaged in any activity which can violate the Human Right Principles.
• We have carried out the Human Right Due Diligence of suppliers.

Area of concern & Remedial Measures

• No Area of concern & Remedial Measures has been raised for Human rights violations.

2.8 Environment Protection

• ZENSTAR JEWELRY LLC is Complying with all applicable environmental laws and regulations.

Area of concern & Remedial Measures

• Nil

ANNUAL REPORTING TEMPLATE (RJC TOOL KIT VERSION 5.0)

Company Name:	Zenstar Jewelry LLC
Date:	20th January, 2025
Reporting Period:	Calendar Year 2024
Step 1: Establish strong company management systems
1.A. Adopt and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas	We have published the policy at company level for easy access to our stakeholders. OECD and Best Practice communication has been sent annually to all the active suppliers. Awareness presentation on Ethical sourcing based on OECD guidelines has been circulated. Detailed policy and procedure has been established based on risk of CAHRA’s.
1.B. Structure internal management systems to support supply chain due diligence.	Additional responsibility has been assigned to Compliance officer to look over the compliance of Ethical sourcing policy. All key employees involved in sourcing and procurement of precious metals have been trained on our Ethical precious metal sourcing policy. List of Suppliers has been maintained along with status of their social and ethical compliance. Ongoing monitoring of associated suppliers is carried out with the help of tools such as digital media, web search, review of supply documents, declaration and market intelligence etc.
1.C. Establish a system of controls and transparency over the minerals supply chain.	Supplier upstream information collection process has been started to obtain CAHRA’s information and Ethical sourcing compliance at supplier level. Currently 99% of supply is from low-risk suppliers and balance 1% is from non-regular suppliers.
1.D. Strengthen company engagement with suppliers.	As mentioned above, supplier questionnaire has been circulated, and we are in the process of following up with them to obtain the relevant information from them. Further, we also obtain vital information about suppliers from social platforms and social compliance registration such as BPP & RJC, etc.
1.E. Establish A Company-Level, or Industry-Wide, Grievance Mechanism as an early warning Risk-Awareness System.	We have established the grievance handling policy and procedure at company level, contact details of compliance head provided in our Group Social and Ethical policy on our Website.
Step 2: Identify And Assess Risk In The Supply Chain
Identify and assess risks in the supply chain and assess risks of adverse impacts.	We have established the detailed policy and procedure for identification of risk. Compliance officer oversees the financial and ethical sourcing compliances. We primarily deal with associated suppliers only.
Step 3: Design And Implement A Strategy To Respond To Identified Risks (If Applicable)
Report findings of the supply chain risk assessment to the designated senior management of the company.	Ongoing monitoring of each supplier is done by compliance officer to confirm that they are free from Conflict. Compliance officer shall report all unanswered red flags to management. In worst situations where information is incomplete or not satisfactory, management starts engagement practice and begins discussion and dialogue with suppliers to ensure full information is received in further business.
Devise and adopt a Risk Management Plan.	We have formulated the risk management plans considering entity’s position in the supply chain and position of supplier in the supply chain. Compliance officer carries out monitoring of each and every business transaction and where required Red Flags are raised and further steps are followed as mentioned above.
Implement the risk management plan and monitor performance of risk mitigation efforts.	Currently no red flags identified. Compliance officer provides periodic status reports of OECD compliance to the management.
Internal Training	Company provides periodic training to all the concerned employees involved in buying and selling and compliance monitoring team.
Communications	Business principle has been published on the website covering all the COP-wise policies. Annual communication on Business policy and Awareness on various best practices and expectations from business partners is communicated.
OPTIONAL INFORMATION ON Step 4: Carry Out Independent Third-Party Audit
RJC COP Audit	Initial RJC audit is scheduled.
Grievances And Remediation	No grievance of whatsoever has been reported till date.

1. Background

• At ZENSTAR JEWELRY LLC 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 ZENSTAR JEWELRY LLC sets forth the basic internal standards to be observed by all Partners, 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 Partners, officers and employees.
• Also appropriate steps are taken to assure adherence to this 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

• ZENSTAR JEWELRY LLC shall operate in compliance with relevant national and international legislations / regulations as applicable in the country in which it operates.
• 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 officer 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

• ZENSTAR JEWELRY LLC recognizes the fact that entities in the gems and jewelry 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.
• ZENSTAR JEWELRY LLC 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 KYC & KYS, 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

• ZENSTAR JEWELRY LLC 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 will be adopted i.e. “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 in so far 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 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

• The ZENSTAR JEWELRY LLC shall ensure complete prohibition of Bribery and facilitation payment.
• 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 types 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 simulants:
• 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 simulants.
• 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.
• ZENSTAR JEWELRY LLC 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.
• Stimulants: A diamond stimulant is any object or product used to imitate some or all of the properties associated with a diamond and includes any material, which does not meet the requirements specified in the definition of the word ‘diamond’ above.
• Note: Necessary declaration is provided on invoice in case of CZ or Stimulants 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 ZENSTAR JEWELRY LLC shall ensure that all our gold suppliers comply with gold sourcing guidelines.
• Further, we are committed to ensuring that sourcing of gold and precious metals products and articles are under the highest social, human rights, and environmental standards of trade.

8. Supply Chain Management / Best Endeavours

• The management of ZENSTAR JEWELRY LLC is committed to taking appropriate action to use best endeavors to ensure the commitment of its suppliers to comply with the RJC CoP.
• Note: Wherever applicable, necessary declaration of compliance is obtained.

9. Conflict Minerals Policy Statement as per OECD

• ZENSTAR JEWELRY LLC is committed to trade in a conflict-free supply chain and as a part of its compliance strategy, the majority of our upstream supplies are coming from known sources where the origin of precious metals and diamonds is known and can be easily established that it is conflict-free.
• Sourcing policy has been communicated to all the suppliers and vendor questionnaires have been circulated to seek information for their upstream supply chain.
• Ongoing monitoring by the compliance officer is carried out to ensure compliance with these sourcing policies.
• 90% plus products are sourced directly from known and associated business partners.

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 employees to work for more than the national limit of 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 not be used.
• Information regarding applicable employment policies and working practices should be communicated in a transparent manner to all employees.

11. Health and Safety

• ZENSTAR JEWELRY LLC 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 the 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.
• 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 materials, which are known to cause an adverse impact on the health of employees or the health of consumers in the course of its use.
• All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable.
• Wherever applicable, Health, Safety, and Environment Committee will be nominated, 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.
• ZENSTAR JEWELRY LLC 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.
• ZENSTAR JEWELRY LLC shall at no time condone the use of corporal punishment or other forms of mental or physical coercion.
• ZENSTAR JEWELRY LLC 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. ZENSTAR JEWELRY LLC assures 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 ZENSTAR JEWELRY LLC.
• 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 of all new employees joining the organization.

14. Forced Labour

• The management of ZENSTAR JEWELRY LLC is fully committed to ensuring that forced or involuntary labour is not practiced in any form. 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 will be treated with equality, respect, and dignity.
• ZENSTAR JEWELRY LLC 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 behavior.
• 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, HSE & Anti-sexual harassment committees are formed, and the committee shall review the compliance at regular intervals by holding review meetings.

16. Environment Protection

• ZENSTAR JEWELRY LLC 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 its operations on the environment will be systematically assessed for compliance with appropriate standards and reviewed periodically to mitigate or eliminate such impact.
• Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.
• Commitment to a continual improvement process in environmental management.

17. Product Security

• ZENSTAR JEWELRY LLC is committed to providing safety of products throughout its supply chain by following precautions as mentioned below:
• Each and every stage of product processing is covered through blanket insurance.
• Suitable safeguarding and storage are ensured at all stages with the help of safes.
• Office areas are monitored by closed-circuit cameras.
• All the concerned persons are trained on relevant safety and security procedures to be followed at all times.

Public Grievances

Keeping in view the increasing importance to redress public grievances, company has introduced the 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 activity 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.

Contact Details

Compliance Officer: Mrs. Nandini Doshi

Contact Number: +1 212 840 6970

Email: rupa.doshi@jewelexgroup.com

Date: 8th January, 2024