Background

• At H. K. DESIGNS (INDIA) LLP, 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 H. K. DESIGNS (INDIA) LLP 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.

Legislation and Regulations

• H. K. DESIGNS (INDIA) LLP 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.

• 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.

Money Laundering, Terrorism Financing, Other Financial Offences

• H. K. DESIGNS (INDIA) LLP 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.

• H. K. DESIGNS (INDIA) LLP 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.

Kimberley Process and System of Warranties

• H. K. DESIGNS (INDIA) LLP 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 Gem Stone Diamonds’ as agreed by the Kimberley Process will be adopted i.e “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.”

• 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.”

Anti Bribery and Facilitation Payment Policy:

• The H. K. Designs (India) LLP shall ensure complete prohibition Bribery and facilitation payment across organization and in all the 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.

• Company shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.

Disclosure of Treated Diamonds, Synthetics and Stimulants

• 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.

  • 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 stimulant.

  • 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.

• H. K. DESIGNS (INDIA) LLP 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 words ‘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.

• Necessary declaration is provided on invoice incase of CZ or Stimulants are used in jewellery and same is communicated verbally prior to exe.

Conflict Minerals Policy Statement (Gold)

• H. K. Designs (India) LLP is committed to being a responsible corporate citizen and is opposed to human rights abuses. As part of that commitment, H. K. Designs (India) LLP seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility.

• H. K. Designs (India) LLP shall strive to ensure that all its supply of diamonds are not originating from CHARA’s and where practically possible origin of diamonds is known to us.

a. What are "Conflict Diamonds"?

• Blood Diamonds, also known as "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 criminal activities and or funding terrorism.

Identified CAHRA’S Affected Diamond Producing Nations:

• Sierra Leone, Liberia, Angola, the Republic of Congo, Côte d'Ivoire, the Central African Republic, and the Democratic Republic of Congo.

• H. K. Designs (India) LLP shall ensure that none of its supplies are coming from CAHRA’S.

• H. K. Designs (India) LLP shall communicate its sourcing policy to all the stakeholders and will ensure effective implementation.

• Annual reporting of Ethical sourcing:

• For all customers and stake holders , who wants to obtained copy of group/ specific entities Ethical sourcing compliance report, shall have to send such request in writing to below mentioned email address and shall be replied after internal review and conformation from the concerned authorities of the group.

Supply Chain Management / Best Endeavors

The management of H. K. DESIGNS (INDIA) LLP is committed to taking appropriate action to use best endeavors to ensure the commitment of Tier 2 & Tier 3 entities to comply with the Best Practice Principles

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 hours in a week on a regular basis.

• 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.

Health and Safety

H. K. DESIGNS (INDIA) LLP. 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 health of our staff, exposed to certain hazardous processes, will be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.

• 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

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.

• H. K. DESIGNS (INDIA) LLP 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.

• H. K. DESIGNS (INDIA) LLP shall at no time condone the use of corporal punishment or other forms of mental or physical coercion

Child Labour

• No form of child labour should be employed at any of the facilities of H. K. DESIGNS (INDIA) LLP.

• 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.

• Company will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

Forced Labour

• The management of H. K. DESIGNS (INDIA) LLP 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”

Human Rights

• All employees in the Company’s facilities will be treated with equality, respect and dignity.

• H. K. DESIGNS (INDIA) LLP 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.

Environment Protection

H. K. DESIGNS (INDIA) LLP 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.

• 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.

Product Security

H. K. DESIGNS (INDIA) LLP is committed to provide safety of product through out 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 concern 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 switch over of the product.

Public Grievances

• H. K. Designs (India) LLP understands the importance of addressing increasing public grievances.

• Company has introduced the common public grievance cell to look in to matter of reporting non compliance against any of the company policy or raising red flag against any of its business entity or individuals

• Further any query or clarification of diamonds can be raised and same shall be replied with 5 working days as per group public communication policy.

Public Grievances Contact Cell & Annual Ethical Sourcing Policy Contact

Contact person Name: Mr. Paresh Patadia

Phone Number: +91-22-67161616

Address: Unit No. 113, SDF IV, SEEPZ-SEZ, Andheri(East),

Email: paresh.p@hk.co