Business Policy – S&J Diamond Corp

2.1 Legislation and Regulations
a. S & J DIAMOND CORP shall operate in compliance with relevant national and international legislations / regulations as applicable in the countries in which they operate.
b. All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal S & J DIAMOND CORP rules and policies relating to their business activities.
c. It is the responsibility of personnel to know and understand legal, regulatory and internal requirements as they apply to their jobs.
d. Legal Compliance Record are Maintained.

2.2 Money Laundering, Terrorism Financing, Other Financial Offences
a. S & J DIAMOND CORP 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.
b. S & J DIAMOND CORP shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations. Following acts and international guidelines is considered while establishing company level policies

US Patriot Act
FATF 40 Recommendations and 8 special recommendations

c. 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 is considered as a violation of the Business Principles, depending on the seriousness of the non-conformance.
d. 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.
e. Compliance officer caries out periodic review of AML/CFT compliances and submits his report to management on Quarterly basis.

2.3 Kimberley Process and System of Warranties
a. S & J DIAMOND CORP is dealing in polished diamonds Studded Jewelry and fully committed to complying with all the requirements specified in World Diamond Council’s (WDC) System of Warranties Declaration.
b. We will not engage in business with the supply chain who deals in ‘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.
c. Statement of Warranties, Declaration is provided on all invoices raised to B2B Customers.

2.4 Anti-Bribery and Facilitation Payment Policy:
a. The S & J DIAMOND CORP shall ensure complete prohibition of Bribery and facilitation payment across organization and in all the entities.
b. S & J DIAMOND CORP will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.
c. Company shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.
d. Compliance Register are Maintained.

2.5 Disclosure of Treated Diamonds, Synthetics and Stimulant
The following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and stimulant

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.
We deal in real and natural diamonds and any treatment of real and natural diamonds is disclose to customer prior to sales
In case of LGD necessary declaration is provided.

2.6 Diamond & Gemstone Sourcing Policy as per OECD
Conflict Minerals Policy Statement (Diamond & Gem Stone)
S & J DIAMOND CORP is committed to being a responsible corporate citizen and is opposed to human rights abuses. As part of that commitment, S & J DIAMOND CORP seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility.
S & J DIAMOND CORP shall strive to ensure that all its supply of diamonds is not originating from CAHRA’s and where practically possible origin of diamonds is known to us.
CAHRAS list is monitored on register basis.
What Are “Conflict Diamonds”?
“Conflict Diamonds,” are stones that are produced in areas controlled by rebel forces that are opposed to internationally recognized governments. The rebels sell these diamonds, and the money is used to purchase arms or to fund their military actions.
CAHRAS are.
Angola ,Coast, Democratic Republic of the Congo ,Liberia, Sierra Leone, Republic of the Congo & Zimbabwe Marange Diamond Fields
S & J DIAMOND CORP shall ensure that none of its supplies are coming from above sources.
CHARAS list is monitored on regular basis.

2.7 Gold & Platinum Group Of Metal Sourcing Policy (As per DRC)
Our Company is concerned about environment and social impacts of irresponsible mining.
We at S & J DIAMOND CORP shall ensure that all our gold Jewelry suppliers are in compliance with gold souring guidelines (Dodd- Frank rules, DRC & other applicable legislation).
Further, we are committed to ensure that sourcing of gold and precious metal products and articles thereof, are under the highest Social, Human right and Environmental standard cautions of trade.

2.8 Supply Chain Management / Best Endeavours
The management of S & J DIAMOND CORP is committed to take appropriate action to use best endeavours to ensure that the suppliers and contractors are committed for compliance to International Social Standards such as RJC & OECD Requirement.

2.9 Employment
a. Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labor.
b. The S & J DIAMOND CORP shall not require Staff to work for more than the national limit of hours in a week on a regular basis.
c. The S & J DIAMOND CORP shall ensure that Salary and benefits for a standard working week shall meet at least national minimum standards.

2.10 Health and Safety
S & J DIAMOND CORP recognizes the need to develop a sustainable, value creating business and is committed to the following:

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.
Workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable

2.11 Non Discrimination, Disciplinary Practices
a. Discrimination can mean distinction, exclusion or preference.
b. 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 S & J DIAMOND CORP Any such reported incidents will be viewed as a serious violation of this Business Principles.
c. We shall at no time condone the use of corporal punishment or other forms of mental or physical coercion.
d. We encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, S & J DIAMOND CORP operation or practice is or will likely be in violation of any law, regulation or internal rule or policy, including this Business Principles.

2.12 Child Labour
a. No form of child labour should be employed at any of the facilities of the S & J DIAMOND CORP Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).
b. For authorized adolescents (persons below 18 years of age but above 15 years), the S & J DIAMOND CORP Management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
c. As per our S & J DIAMOND CORP, policy no child labours or Young Labour will be employed.
d. S & J DIAMOND CORP will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

2.13 Forced Labour
a. The management of S & J DIAMOND CORP 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.
b. 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 they said person has not offered himself voluntarily”

2.14 Human Rights

All employees in the S & J DIAMOND CORP facilities will be treated with equality, respect and dignity.
S & J DIAMOND CORP 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 S & J DIAMOND CORP strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.

2.15 Environment Protection
S & J DIAMOND CORP 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.

2.16 Product Security
S & J DIAMOND CORP is committed to provide safety of 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
We are taking at most care to ensure safety of visitors, Customers and interested parties, suitable arrangements such as CCTV, Multi level entry doors and other electronic intelligence.
All the concern persons are trained on relevant safety and security procedures to be followed at all time.

Public Grievances against social & Ethical compliance of the S & J DIAMOND CORP

If you come across any instance of non compliance or specific deviation from our ethical policy, please feel free to reach us.

Further in case if you are interested to obtain the copy of our sourcing annual compliance report based on OECD guidelines. Please send an email communication to below mentioned email address.

Sr No.	Mode	Detail
(I)	By Email	Name : Ms. Kinjal Shah Email : Accounting@snjny.com

ANNUAL REPORTING

Company Name:	S & J DIAMOND CORP
Date:	March 1st, 2023
Reporting Period:	Calendar year 2022

Step1: Establish strong company management systems

1.A. Adopt and clearly communicate to suppliers and the public, accompany policy for the supply chain of minerals originating from conflict affected and high-risk areas	We have published the policy at group level for easy accesses to stake holder. OECD and Best Practice Annual communication has been sent to all the active customers and supplier Awareness presentation on Ethical sourcing based on OECD guideline has been circulated Detailed policy and procedure at entity level has been established based on risk of CAHRA’s is done.
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 souring policy All key employees involved in souring and procurement of precious metals have been trained on our Ethical precious metal souring policy. Refresher trainings are provided. List of Suppliers has been maintained along with status of their social and ethical compliance Ongoing monitoring of each supply and 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 started to obtained CAHRA’s information and Ethical sourcing compliance at supplier level.
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 obtained the filed information from them. Further we are also obtaining the vital information about suppliers from social platforms and social compliance registration such as BPP, RJC programs etc. We have received the filled questionnaire from various suppliers and in the process of compiling filled supplier questionnaire data, after analysis we will be formulate supplier engagement practices based on risk reported at each supplier level (if any)
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 organization level and contact details of compliance head has been provided in our Ethical policy, which has been published on our Web site

Step2: Identify and Assess Riskin 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 at entity level.

We have categorized supply chain in to 3 major segments that its Primary suppliers, Secondary supplier and Open market suppliers.

All suppliers are bifurcated in to this category and open market supplies are considered as potential risk for supplies from CAHRA’s and thus step by step information are gathered from this category of supplier as mentioned in point 1.B & 1.C.

No potential or high risk suppliers has been reported during the review period

Step3: Design and Implement a Strategy to Respond to Identified Risks

Report Findings of The Supply Chain Risk Assessment to The Designated Senior Management of The Company.	Ongoing monitoring of each supply is done by compliance officer to confirm its free from Conflict, were required Few Red Flags are been raised for seeking additional information and same are closed after receiving additional information provided by the suppliers. Compliance officer shall report all un-answered flags to management. In worst situation where information is half or not satisfactory management shall starts engagement practice and discussion and dialogue with suppliers is carried out to ensure full information in further business
Devise And Adopt a Risk Management Plan.	We have formulated the risk management plans at entity level considering individual entities position in supply chain and position of supplier in supply chain. Entity compliance officer carries out monitoring of each and every business transaction and were required Red Flags are been raised and further steps are followed as mention above. Brief of companies Risk Management Practices has been is mentioned in communication of Business policy on our website.
Implement The Risk Management Plan and Monitor Performance of Risk Mitigation Efforts.	Entity level and group level monitoring of Red Flags and its effective closure is monitored. Compliance officer provides period status reports of OECD compliance to the management.
Internal Training	Each entity of the Group provides period training to all the concern employee involved in buying and selling and compliance monitoring team
Communications	Business principle has been published on the website covering all the COP wise policy including Ethical Precious Metal souring policy of the group. Over and above Annual communication on Business policy and Awareness on various best practices and expectation from business partners is communicated

OPTIONAL INFORMATIONON
Step 4: Carry Out Independent Third-Party Audit

RJC COP Audit	Our first external assessment has been scheduled in the month of march 2023 and once the third party audit completed, status will be updated.
Grievances And Remediation	No grievance of whatsoever has been reported till date.