OUR POLICY

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GLOBAL STANDARDS

FOR BUSINESS PARTNERS

Group Dianco believes in doing business with those business partners, including suppliers, manufacturers, contractors, joint venture partners, agents, distributors, and consultants who embrace and demonstrate high standards of ethical business behavior.

The following Global Standards for Business Partners define the minimum requirements for Group Dianco business partners.

Product Quality and Safety

Group Dianco has a fundamental responsibility to ensure that consumers can trust the safety and quality of its products.

Business partners are expected to provide goods and services that meet or exceed all government and all agreed upon quality and safety standards. Any threats to product safety must be immediately reported to Group Dianco.

Group Dianco especially has a focus on transparency and honesty at all times in the relation with their business partners. Our upper goal is to deal in natural diamonds. Any business partner who is misrepresenting a synthetic as a natural diamond to Group Dianco will be brought to court. For Group Dianco it is seen as an act of fraud.

Also we want that all our suppliers have a clear sourcing and supply chain with an extra focus on sourcing from CAHRA’s (conflict-affected and high-risk areas).

Group Dianco demand that all their business partners take the necessary steps that any activity will bring the diamond industry into disrepute or damage the consumer’s perception of Natural Diamonds.

Group Dianco expects that all business partners have auditable systems in their day to day business to avoid contamination between Natural & Synthetic Diamonds at every point into their diamond pipeline.

Employment Practices

Group Dianco has a strong commitment to treating its employees fairly, and with dignity and respect. We believe in doing business with business partners who share this commitment, and we expect business partners to comply with all applicable employment laws and to support fundamental human rights for all people. Our expectations include:

Child labour - Business partners will not employ individuals in violation of the local mandatory school age, or under the legal employment age in each country where they operate. Moreover, in no case will business partners employ non-family workers under age 15, except for child actors and models employed in advertising or media who are protected by applicable child labour requirements.
Compensation - Business partners will, at a minimum, comply with applicable wage and hour laws and regulations, including those relating to minimum wages.
Discrimination - Business partners will not discriminate based on personal characteristics or beliefs. Group Dianco will favour those business partners who provide equal opportunity to all.
Forced labour - Business partners will not use forced or involuntary labour whether bonded, prison or indentured, including debt servitude.
Freedom of association and collective bargaining - Business partners will respect the right of employees to exercise their lawful right of free association. Similarly, business partners will recognize the lawful rights of their employees to choose or not choose collective bargaining representation.
Safety and health - Business partners will operate a safe and healthy work environment for their employees. Where applicable, this also applies to housing and eating facilities.
Workplace harassment or abuse - Business partners will not subject employees to physical, verbal, sexual, or psychological harassment, nor use corporal or physical punishment to discipline employees.
Working hours - Business partners will comply with all applicable laws and regulations regarding working hours.

Environment

Group Dianco believes in doing business with business partners who share its commitment to protecting the quality of the environment around the world through sound environmental management.

Business partners are expected to comply with all applicable environmental laws.

Group Dianco will favour business partners who seek to minimize the use of non-renewable resources, reduce and recycle waste, and minimize the environmental impact of their operations.

Conflicts of Interest

Group Dianco expects business decisions to be made in the best interest of the company. Any situation that creates or appears to create a conflict between personal interests and the interests of Group Dianco must be avoided.

A conflict of interest may arise when doing business with an organization that employs or is partially or fully owned by a Group Dianco employee or an employee's family members or close personal friends.

Business partners are expected to disclose actual or potential conflicts of interest to Group Dianco.

Anti-corruption

Group Dianco strictly abides by all applicable laws relating to anti-corruption, including the Foreign Corrupt Practices Act, and expects business partners to act in a similar manner.

Business partners may not pay bribes or engage in corrupt practices in order to advance Group Dianco's business interests. This includes, directly or indirectly, offering, promising to pay or authorizing the payment of money or anything of value to local government officials, political parties, party officials, candidates for political office, or officials of public international organizations (like the European Union or the World Bank) in an effort to influence any official decision that would assist Group Dianco in obtaining or retaining business, or securing any improper commercial advantage.

Gifts, Favors and Entertainment

Gifts, favors and entertainment are not needed in order to conduct business with Group Dianco, and may lead or appear to lead to a conflict of interest.

In many industries and countries, gifts, favours and entertainment are used to strengthen business relationships. Throughout the world, one principle is common and clear: No gift, favour or entertainment should be provided or accepted if it will obligate or appear to obligate the recipient.

Gifts or entertainment may be provided if they are reasonable complements to business relationships, or of modest value, and, in any event, not against the law or Group Dianco policy. Group Dianco employees may not accept gifts, favors and entertainment valued at more than USD 100 in any year from the same company. In some instances, the Group Dianco entity you are dealing with may have a lower limit. Group Dianco policy expressly prohibits the following situations for Group Dianco employees:

Requesting or soliciting personal gifts, favours, entertainment, or services.
Exploiting their position to solicit vendors, including financial institutions, to provide individual preferential treatment in pricing, terms or loans.
Receiving cash or cash equivalents.
Being provided with lavish or excessive gifts and entertainment.

Confidential Information

Business partners are expected to safeguard Group Dianco's confidential information by keeping it secure, limiting access to those who have a need to know in order to do their job, and avoiding discussion of confidential information in public areas, for example on planes, in elevators and on mobile phones.

Group Dianco's confidential information may not be disclosed as it provides Group Dianco a competitive advantage. Examples of confidential information include trade secrets, detailed sales and profit figures, new product or marketing plans, research and development ideas or information, manufacturing processes, personnel information, and information about potential acquisitions, divestitures and investments. The obligation to preserve Group Dianco's confidential information may be ongoing, even after the business relationship ends.

Group Dianco will respect and safeguard the confidential information of our business partners.

Fair Competition and Antitrust

Group Dianco believes in free and open competition, and strictly abides by all applicable fair competition and antitrust laws in the many countries where Group Dianco conducts business.

Business partners are expected to comply with all applicable laws and regulations regarding fair competition and antitrust.

Other Legal Requirements

Business partners are expected to comply with all applicable laws not otherwise set forth in these Standards. When used in these Standards, "applicable laws" include all applicable local, state, provincial, and national laws, codes, rules and regulations as well as all applicable treaties.

Communication

We expect our business partners to communicate these Standards to their employees and their business partners, and for their employees and business partners to adhere to them.

Monitoring and Compliance

Business partners are expected to notify Group Dianco immediately if they become aware of any non-compliant practices by themselves, their employees and their business partners under these Standards. Business partners are further expected to promptly develop and implement plans or programs to correct any such practices. Business partners should also be aware of the fact Group Dianco engages in various monitoring activities to confirm compliance with these Standards, including conducting its own and independent third-party site inspections and audits.

Our Expectation

We expect all business partners to live up to these Standards and do the right thing.

A business partner's failure to observe and abide by these Standards may result in Group Dianco ceasing to do business with it.

Questions or Concerns

Group Dianco strongly encourages any business partner who feels pressured by a Group Dianco employee or another business partner to violate these Standards to contact the senior management of the Group Dianco.

RESPONSIBLE SOURCING POLICY

SOURCING FROM CONFLICT-AFFECTED AND HIGH RISK AREAS POLICY

SOURCING FROM

CONFLICT- AFFECTED AND HIGH RISK AREAS POLICY

Introduction:

According to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (DDG), conflict-affected and high-risk areas (CAHRA’s) are characterized by “the presence of armed conflict, widespread violence or other risks of harm to people”.

Armed conflict may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of liberation, or insurgencies, civil wars, etc.

High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure and widespread violence. Such areas are often characterized by widespread human rights abuses and violations of national or international law.

And as we all know, diamonds are also minerals. That implicates that our industry is also responsible for all issues of minerals from conflict-affected and high-risks areas. The diamond industry has to look for viable solutions to ensure responsible and conflict-free sourcing through legitimate trade and positive development in the affected regions.

Statement from Dianco Group on sourcing of minerals from Conflict-Affected and High-Risk Areas

Group Dianco will always trying to avoid sourcing diamonds from Conflict-Affected and High-Risk Areas.

We also understand that in certain occasions or circumstances our suppliers sell diamonds to our group that may originate from CAHRA’s.

In those cases we rely on support from our suppliers to provide information on the origin and the sources of the diamonds.

We require our suppliers to have or establish effective due diligence processes, in line with the OECD Due Diligence Guidance for Responsible Supply chains of Minerals from Conflict-Affected and High-Risk Areas, when sourcing rough diamonds.

This enables the Group Dianco to improve our Pipeline Risk Assessment and can we better evaluate that our sourced diamonds did not originate from sources that indirectly or directly contribute to the finance of armed groups or otherwise cause or contribute to human rights violations.

In support of this statement relating to our efforts around responsible sourcing Group Dianco will:

Continue to actively support industry-wide efforts to find solutions to improve the traceability of diamonds;
Actively continue to improve our Code of Conduct for Business Partners and our Responsible Sourcing Policy;
Exercise due diligence in relation to relevant suppliers.

Rules Determined for Sourcing

As reference we refer to our Policy Responsible Sourcing.

In support of the above, the Group Dianco wants that all relevant staff are directed to follow and be trained on procedures implement a conflict diamonds due diligence system to designed to:

Exercise due diligence with relevant suppliers consistent with the OECD Guidance and encourage our suppliers to do the same.
Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm diamonds in our supply chain do not contribute to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of OECD Guidance.
Establish long-term relationships with our immediate suppliers and counterparties.
Support suppliers and counterparties to improve performance and conform to Group Dianco’s supply chain policy.
Suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
Immediately discontinue engagement with suppliers who pose reasonable risk to be causing severe human rights abuses.
To undergo an annual self-assessment to verify our conflict-free status as well as identify opportunities to continually improve our conflict diamonds due diligence management system.
Commit to transparency in the implementation of this policy.

Any concerns about our policy or due diligence system should be reported through our Policy ‘Grievance Policy for Customers and Suppliers. For that reason we have to make sure that our customers and suppliers are surely aware of the existence of this policy.

Conclusion

This Policy forms part of the effort by the Group Dianco to develop a long-term ethical diamond business. In that aim we strive to maximize the possibilities to have no trade from Conflict-Affected and High-Risk Areas.

To realize this ultimate goal, the Group Dianco can only act in an open atmosphere of transparency between all Business Partners within the worldwide diamond industry.

RESPONSIBLE

SOURCING POLICY

Whenever doing business, Group Dianco is committed to follow its values of Responsibility, Mutual Respect, Integrity and Honesty. As a result of these business principles Group Dianco has implemented a ‘Responsible Sourcing Policy’ which defines the way to source goods and services from the market.

Group Dianco therefore is committed only to do business with suppliers who follow business practices which are aligned with our Values and our Ethics.

In addition to the legal standards mentioned in this Code, suppliers will comply with all other applicable laws in the provision of products or services to Group Dianco. Group Dianco applies a “Zero Tolerance” regarding unethical business behaviour, bribery, corruption and forced labour.

The Group Dianco Code of Business Conduct for Suppliers

This Code of Business Conduct for Suppliers sets forth basic principles for supplier conduct when working with Group Dianco. Group Dianco is committed to these principles and expects its suppliers to be as well.

Human Rights and Labour Practices

Respect for People is a core Group Dianco’s value. Suppliers must respect the Human Rights of their employees and treat them fairly and with respect, in accordance with applicable laws.

No Forced and Compulsory Labour: Suppliers will not use forced or involuntary labour, including indentured labour, bonded labour or slave labour.
No Harassment and Abuse of Labour: Suppliers will ensure that their employees are not subjected to psychological, verbal, sexual or physical harassment or any other form of abuse, and will comply with all applicable laws on harassment and abuse of employees.
No Child Labour: Suppliers shall not employ full time employed workers under the age of 15 or, in those countries subject to the developing country exception of the ILO Convention 138, shall not employ full time employed workers under the age of 14."
No Discrimination: Suppliers must promote equal opportunities, not discriminate in any condition of employment on the basis of race, color, national origin, sex, religion, age, disability or any other personal characteristic unrelated to job performance, and will comply with all applicable employment discrimination laws
Appropriate Work Hours and Wages: Suppliers will comply with applicable laws on work hours and overtime, as well as applicable laws on wages and benefits. Where no sufficient legal protection exists, suppliers must ensure at least 1 uninterrupted day off per week and compensate work at a minimum so that employees can meet their basic needs.

Environment, Health and Safety

Group Dianco commitment to sustainability includes efficient use of resources in the light of the Circular Economy, as well as the commitment to protect the environment and to provide healthy and safe workplaces. Group Dianco is committed to avoid using conflict resources and expects its suppliers to make similar commitments to continuously improve their environmental, health and safety performance.

Respect the Environment: Suppliers will comply with applicable environmental laws and shall have systems in place to ensure safe management of waste, air emission and wastewater discharges. Suppliers must seek to continuously minimize environmental impact and make continuous improvements to resource efficiency, for instance by using recycled materials
Protect Health and Safety: Suppliers will provide a safe and healthy workplace for their employees, including appropriate controls, training, work procedures and personal protective equipment. Suppliers will comply with all health and safety laws that are applicable to the workplace.

Ethics and Legal Requirements

Group Dianco expects its suppliers to conduct their business ethically and in compliance with the law.

Avoid Conflicts of Interest: Suppliers will avoid any interaction with a Dianco employee that may conflict, or appear to conflict, with the employee's ability to act in the best interests of Group Dianco.
No Bribery: Group Dianco does not tolerate corruption in any form. Suppliers shall not influence nor seek to influence Group Dianco employees by payments of money or any other thing of value, including corporate hospitality and gifts. Group Dianco requires compliance with all applicable anti-bribery and corruption laws in the conduct of business. Compliance is required of any third party acting for or on our behalf, such as agents, distributors, contractors, consultants, etc. Bribery is corruption. It is the giving to or receiving by any person of anything of value, either directly or indirectly, as an inducement to gain an undue commercial, contractual, regulatory or personal advantage or to influence contrary to the principles of honesty and integrity. Bribery can occur, and is unlawful, in both the private (between commercial companies) and the public sector (bribing a public official).
Fair Competition: Suppliers will be committed to vigorous, lawful, straightforward and ethical competition and must ensure that their business practices fully comply with the competition laws wherever they do business.
Accurate Accounting and Business Records: Suppliers will keep accurate records of all matters related to the supplier's business with Group Dianco companies.
Protect Information: Suppliers will protect Group Dianco confidential information and act to prevent its misuse, theft, fraud or improper disclosure. Suppliers must take all due care in handling, discussing or transmitting sensitive or confidential information that could affect Group Dianco, its employees, its customers, the business community or the general public.
Sanctioned Parties: Couriers (armed or not) may not use any supplier of services or equipment which (a) is located in any country subject to United Nations, U.S. or EU economic sanctions (or acting on behalf of persons or entities located in such countries) or (b) appears on lists of restricted or prohibited persons maintained by the United Nations, U.S., EU or the country of manufacture, origin/destination.

Expectations in Respect to the Code of Business Conduct for Suppliers

Group Dianco expects suppliers to implement systems and controls to promote compliance with applicable laws and the principles set forth in this Code, including policies, training, monitoring and auditing mechanisms. Suppliers should also apply these or similar principles to the subcontractors and suppliers they work with in providing goods and services to Group Dianco.

Group Dianco reserves the right to assess and monitor suppliers' compliance with this Code. Suppliers who are not in compliance with this Code are expected to implement corrective actions or face the prospect of not being considered by Group Dianco for future business.

THIRD PARTY DUE DILIGENCE POLICY

THIRD PARTY

DUE DILIGENCE POLICY

Rationale of the policy

Group Dianco does business with many types of third party including, but not limited to contractors, agents, suppliers, logistics, law and advisory firms.

This policy sets out Group Dianco’s commitments in doing business with third parties in order to mitigate the risks of bribery, corruption, money laundering, fraud and violation to human rights, risks that the Group is exposed to in its relations with third parties.

This policy extends not only to Group Dianco employees, but to third parties with which it does business.

Group Policy

Applicability of this policy:

A third party is defined as any company, organization or individual not owned, controlled or employed by Group Dianco and/or group companies that is retained to provide goods or services or engage business activities on behalf of Group Dianco and/or group companies.

All third parties has to comply at all times with all applicable laws and regulations in force and effect at their legal seat, the place of performance and the place of delivery and final destination of the products and services.

Group Dianco policy commitments are as follows:

Group Dianco and his group companies will only do business with third parties that do not engage in bribery and corruption. Specifically, Group Dianco and his group companies will not permit any third party to pay, offer to pay or accept a bribe on behalf of Group Dianco and his group companies.
Group Dianco and/or group companies will only do business with third parties that uphold anti-bribery and corruption, anti-money laundering, fraud and human right laws to which both Group Dianco and the third party are subject to.
Group Dianco and/or group companies will only do business with third parties that either:
Have in place adequate controls that are equivalent in standard to Group Dianco

Adopt Group Dianco counter bribery and corruption policies.
Group Dianco and/or group companies will only make payments to third parties that are proper and proportionate to the services provided and in accordance with the contract or written agreement.

Risk assessment

Group Dianco will assess every third party prior to doing business with them in respect to the aforementioned risks the third party may expose Group Dianco.

Special attention will be in place for the suppliers who source diamonds from Conflict-Affected and High-Risk Areas although Group Dianco will always try to avoid purchases from CAHRA’s.

Due Diligence

Group Dianco will conduct due diligence on every third party prior to doing business with them based on the results of the initial risk assessment. The level of due diligence conducted on a third party will be proportionate to the risks identified and to the possibility to perform the due diligence according to the type of third party.

Group Dianco will periodically review and amend the arrangements with a third party to mitigate anti-bribery and corruption risks identified as part of Group Dianco ongoing compliance monitoring. The renewal period for reviewing and updating written agreements with a third party will be no longer than three years. Mitigating strategies may include, but there are not limited to:

Periodically receiving defined information from a third party supporting its compliance with anti-bribery policies.
Periodically exercising Group Dianco audit rights.
Providing anti-bribery and corruption training to a third party.

Monitoring
Group Dianco will conduct red flag analysis with respect to:

Prevention of bribery and corruption;
Fair competition;
Confidentiality and data privacy;
Adherence to sanctions;
Preventing Conflict of Interest;
Safeguarding Assets;
Intellectual property;
Compliance with International Labor Standards;
Freely chosen employment;
No child labor and protection of young workers;
Freedom of association;
Legal and fair compensation;
Prevention of excessive working hours;
No discrimination;
Respect and dignity;
Safe and healthy working conditions;
Environmental Management;
Traceability.

Based on the results of these analyses Group Dianco will define and implement appropriate strategies to mitigate risk throughout the duration of the relationship with a third party.

Training

Group Dianco will provide adequate training and coaching to its employees that have a responsibility to manage any part of the relationship with a third party.

Reporting

Group Dianco welcomes and provides for third parties to report incidents or suspicions of unethical behavior to the senior management of the group.

General guidelines

General principles of due diligence

If as a result of the due diligence it is concluded that the risks associated with the third party cannot be managed to an appropriate level by Group Dianco, the third party must be rejected and any business relationship with it discontinued.
The due diligence conducted on a third party must be approved by the senior management of the Group Dianco
If there are any material changes to the risks associated with a third party, then the due diligence already conducted must be updated based on the new information. This will require the original risk rating of the third party to be reconsidered and additional due diligence procedures to be conducted as appropriate.

Guidance and reporting

For further guidance please contact the local director of the company belonging the Group Dianco.
If you would like to make an anonymous report of violations or suspicions of violations of this policy, you can contact always Group Dianco or one of the group companies.

COMPLIANT & CONCERN FORM

GRIEVANCES POLICY FOR SUPPLIERS & CUSTOMERS

GRIEVANCES POLICY

FOR SUPPLIERS AND CUSTOMERS

Purpose

The purpose of this policy is to outline the processes the Group Dianco uses to manage and respond to customer or supplier grievances. Further, the purpose of this Grievance Policy is to provide a mechanism by which customers or suppliers can appeal on issues faced with either polished or rough diamonds, services rendered by the Group Dianco or general behavior on the international diamond market .

Under this procedure, they can request an investigation of the whole process by the Management of the Group Dianco

Scope

This policy applies to customers and to suppliers to whom the Group Dianco affiliates are dealing with in relation to their commercial activities as a worldwide trading diamond group.

Background

The Group Dianco believes in being fair and unbiased to any customer or any supplier dealing with the Group Dianco affiliates. The Group Dianco aim is to ensure that customers and suppliers associated with it have the right to respectful and responsive services and goods. In case, there arise an incident by which the customer or supplier is aggrieved, then in such cases the same needs to be addressed in a fair manner and corrective steps taken when necessitated.

It is in this connection that Group Dianco implemented the grievances policy with a clear process to bring the grievances forward and have them resolved in a timely manner.

Responsibility

Senior management of the Group Dianco

Guidelines

This policy is applicable to those instances:
- Where the goods have not the right quality;
- Where an order has not been delivered on time;
- Where a service request has not been attended to;
- Where abuses were found on doing business and behavior in general sense (e.g. competition, sourcing, human rights,…)
This policy covers instances where the Group Dianco affiliates has sold rough or polished diamonds and the performance is not as per the prescribed standards. So, the customer feels aggrieved about the same.
This policy covers instances where the customer has placed an order for polished or rough diamond(s) and the same has not been delivered by the entity of the Group Dianco in spite of the customer having fulfilled all

formalities/requirements.
This policy covers instances where the customer or supplier has placed a request for service and the same has not been attended to for more than 48 hours.
This policy also covers all other grievances within the commercial activities and the general behavior developed by the Group Dianco affiliates.
The preferred method for submitting a customer or supplier grievance and / or concern is through a standard document, added hereto, to the management of the local entity.
In case an aggrieved party contacts a staff member in respect of any grievance and / or concern, the staff member shall consult the local management for further instructions.
Any exceptions other than what has been detailed in this policy will be addressed on a case to case basis. However, all exceptions need to be approved by senior management of the Group Dianco before the same can be considered.
The aggrieved party has to deliver his complaint(s) within 14 days of the facts being known.
The local management has to inform always senior management of Group Dianco when a complaint is received.
The local management will contact the aggrieved company in writing (including via e-mail) within seven business days after receipt of the grievance and / or concern with the following:
- An overview of the grievance and or concern process;
- A request for additional information (if applicable);
- An initial timeline for review and resolution of the grievance and / or concern.
The local management will be responsible for reviewing all appropriate records related to the grievance / concern. In addition to reviewing the data, the local management will be responsible for interviewing internal personnel as appropriate.
Notwithstanding anything contained in the above the following will not be a valid grievance:
- In case the aggrieved party fails to submit the grievance by the deadline specified in the policy and/or other minimum requirements essential to investigate a grievance and / or concern such cases shall be ignored and shall not be subject to review.
- As a policy the local management shall send 2 written reminders to the aggrieved party for submission of data/information essential for conducting the said investigation and if in spite of the above the aggrieved party does not cooperate and the said relevant
  
  data/information has not been received within 10 days from the last written reminder sent to them.
- Any other matter which in the decision of the local management does not qualify the grievance to be admitted.
The Group Dianco shall provide a written response to the aggrieved party within 45 days of receipt of the original grievance indicating disposition of the matter, unless such time period has been extended in order to obtain feedback not readily available. However, in any case the Group Dianco shall dispose of the matter within 90 days of the receipt of the original grievance.
In case the aggrieved party is not satisfied with the decision of the local management, the said party can escalate the matter to the senior management of the Group Dianco.
Pursuant to the grievance being heard the decisions which shall be taken by the Group Dianco could be one of the following:
- Uphold the decision of the local management by the senior management of the Group Dianco.
- Replace the rough or polished diamonds when the other parcel(s) are returned.
- Inform the aggrieved party on the measures taken by the Group Dianco to avoid new conflicts in the future.
- Provide or redo the required service in a proper way

FORM

COMPLAINT AND CONCERN

The Group Dianco encourages their suppliers and customers to contact them if there exists a complaint and / or concern, or experience a problem that affects their business with the Group Dianco. Only in that way we can improve our commercial effectiveness and / or global performance. Please feel free to download the form below and email it to willy.frans@diancogroup.com.

STATEMENT

OF INTENT

Group Dianco, as a worldwide oriented diamond company, is committed to adopting and complying with all local legislations where we are developing commercial activities.

We confirm that we are committed to implementing the following principles

Leading our group by:
- Agreeing our vision, purpose and values and making sure that they remain relevant;
- Developing, resourcing, monitoring and evaluating a plan to make sure that our company achieves its stated purpose;
- Managing, supporting and holding to account staff and all who act on behalf of the company.
Exercising control over our group and companies by:
- Identifying and complying with all relevant legal and regulatory requirements;
- Making sure that there are appropriate internal financial and management controls;
- Identifying major risks for our company and deciding ways of managing the risks.
Being transparent and accountable by:
- Identifying those who have a legitimate interest in doing business with the Group Dianco and companies (stakeholders) and making sure that there is regular contact and effective communication with all of them;
- Responding to our stakeholders' relevant questions or views about our business and our company and how we run it;
- Encouraging and enabling the engagement of those who work for the Group Dianco and companies in the planning and decision-making of our business model.
Working effectively. We do this by:
- Making sure that the management teams and staff (employees & workers) understand their:
  - Role,
  - Legal duties, and
  - Delegated responsibility for decision-making;
- Making sure that the board of our group, companies and the management exercise our responsibility to suppliers, customers, employees, workers and third parties through board meetings that are efficient and effective;
- Making sure that there is suitable board recruitment, development and retirement processes in place;
- Recruiting the right male / female for the job(s).
Behaving with integrity by:
- Making sure that our senior management committee, individual board members, and staff understand their role, legal duties, and delegated responsibility for decision-making.
- Making sure that as a board we exercise our collective responsibility through board meetings that are efficient and effective.
- Making sure that there is suitable board recruitment, development and retirement processes in place.
- Making sure that we work compliant to local legislations.
- Implementing the necessary policies, procedures and management systems.
- Auditing the commercial activities and financial figures of our company by independent auditor(s) and / or chartered accountant(s).
- Being honest, fair and independent;
- Understanding, declaring and managing conflicts of interest and conflicts of loyalties;
- Protecting and promoting the Group Dianco and companies business and reputation.
- Threat our suppliers, customers, staff and third parties with the necessary respect.

We confirm that the Group Dianco is effectively committed to implementing the standards outlined in these principles.

STATEMENT OF INTENT

POLICY ON

HUMAN RIGHTS

Background:

We are part of the societies in which we operate; opportunities and challenges in the local communities are our challenges and opportunities alike. Our investments, our diamond trade, money transfers, payments and supply chains have a global impact. This entails both local and global responsibilities on our part. We recognize the possible risk of adverse human rights impact through our activities or as the result of our business relations. We are committed to always operate in accordance with universal human rights, and this approach applies to all markets where we operate and to all our business relations. Respecting human rights is fundamental in our commitment to be a sustainable and responsible diamond group. In particular, we will promote and respect human rights by contributing to the development of a sound and sustainable diamond market facilitating an accessible and reliable economic infrastructure.

Purpose:

The purpose of this policy is to provide a basis for our Group Dianco’s work, to respect human rights throughout all business functions: our employees, our business relations and our supplier engagements.

Definition:

Human rights are defined as universal rights that should allow individuals the freedom to lead a dignified life, free from fear or want, and free to express independent beliefs. These rights shall be applied equally and universally in all countries for all individuals, regardless of nationality, place of residence, sex, national or ethnic origin, colour, religion, language, or any other status.

We base our human rights definition and commitments on The International Bill of Human Rights. We also support the principles concerning fundamental rights stipulated in the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, as well as the United Nations Convention on the Rights of the Child. Furthermore, we are committed to use the UN Guiding Principles on Business and Human Rights as a starting point for our responsibility to respect human rights.

Our responsibility:

Respecting human rights:

To avoid causing or contributing to adverse human rights impacts through our own activities, and address such impacts when they occur, stressing organizational responsibility as well as individual responsibility in Group Dianco’s business conduct.
To seek to prevent or mitigate adverse human rights impacts that are directly linked to our operations, products or services by our business relationships, even if we have not contributed to those impacts.
To use our potential impact on people rather as a proactive leverage in order to strengthen and transform human rights within our business operations.
To embed the respect for human rights as an integral part of Group Dianco´s vision and values, and as to encourage our employees to uphold human rights throughout the group entities.

Commitments and guiding principles:

Diversity and gender equality

We endorse the principles of diversity and gender equality. Gender equality and diversity is for Group Dianco ultimately the ability to utilize a variety of experiences and competencies that make diversity a factor in consistently raising profitability and ensuring that the Group Dianco remains an attractive employer, partner and diamond group. Consequently, gender equality and diversity are of strategic importance. Non-discrimination and inclusion are fundamental to our business.

Act with due diligence

We act with due diligence to avoid infringing on the rights of others in our business activities and operations. Hence, we assess human rights risks in business relations and decisions. The risk assessment contains a sustainability risk framework stipulating human rights criteria in all business processes; supplier engagement and investments; and an exclusion list on companies we won’t do business with based on, among other areas, their violation of human rights.

Labour rights

We promote human rights in our labour practices and accept no discrimination. The respect of labour rights include, but are not limited to, freedom of association, the right to collective bargaining and no child- or forced labour.

Special attention to vulnerable groups

We recognize that children are an especially vulnerable group and that we all share the responsibility to respect and promote children’s rights. As an international diamond group, we acknowledge our responsibility to do our utmost to prevent usage of the financial system to abuse children’s rights. We recognize that particular groups, such as women and indigenous people and minority groups are especially vulnerable to violations of their human rights. We commit to having special attention to protecting their enjoyment of rights, also applying cross-cutting principles on non-discrimination, participation and accountability.

Tax revenue

We acknowledge that tax revenues can be an important contribution to societies’ work with human rights. We therefore contribute with our fair share in the countries where we operate, by paying the correct amount of tax in due time. We encourage our business partners to do the same.

Stakeholder dialogue

We are committed to engage continuously with external stakeholders in order to strengthen our capacity to improve human rights policy and its statements. We do our utmost to have an ongoing and transparent dialogue with our stakeholders, to enable our stakeholders to understand our work, challenges and ambitions.

Remedy

We acknowledge that despite concerted efforts, abuse can occur. If the Group’s activities entail a direct violation of the human rights of others, we shall take action to rectify the situation, taking into account the interests of those whose rights are being violated.

COMPLAINT FORM

HUMAN RIGHTS

The Group Dianco encourages their suppliers and customers to contact them if there exists a complaint and / or concern, or experience a problem that affects their business with the Group Dianco. Only in that way we can improve our commercial effectiveness and/or global performance. Please feel free to download the form below and email it to willy.frans@diancogroup.com.

POLICY ON HUMAN RIGHTS

HUMAN RIGHTS COMPLAINT FORM

OECD 5 STEP FRAMEWORK

UPSTREAM & DOWNSTREAM SUPPLY CHAINS

Company Management Systems
- Group Dianco – Responsible Sourcing Policy
- Group Dianco – Policy on Sourcing from Conflict-Affected and High-Risk Area’s
- Group Dianco – Policy Third Party Due Diligence
- Group Dianco – Grievances Policy for Suppliers and Customers
- Group Dianco – Human Rights Policy
- Group Dianco – Global Standards for Business Partners
- Group Dianco – Procedure Receipt of Goods
Identify & Assess Risks in the Supply Chain
- Position in supply chain category as per OECD and implementation strategy
  
  The Group entities studied detailed the OECD guideline and COP Provision for sourcing of Diamond & Gem Stone supplies based on the study and our understanding. We came to the conclusion that within the supply chain we situated as ‘Downstream’
- Brief overview of Group entities in the diamond and Gemstone supply chain:

Dianco BV - Antwerp
- Dianco BV its position at downstream level sourcing is a business with recognized mining companies, diamond suppliers and customers.
- The ratio of trading in rough diamonds and polished diamond is Rough Diamonds 90% – 95%% and Polished Diamonds 5% - 10 % on an annual basis.
- Almost 98 % of Rough Diamond supplies are from primary and secondary suppliers (midstream companies).
- The other 2% of the purchases come from Tier 1 & Tier 2 mid-stream companies who sourced from the primary market, however the information on the origin of the rough diamonds is not enough sufficient.
- For polished diamonds 95 % of the supply is from a group Dianco member, where mine to market information clear.
- The other 5% is from Down Stream polished traders who does not have source information, mainly because multiple hands might have changed.
- Considering Dianco BV trade the following products: rough: -10ct MB / MBCL / CLIV white & brown, polished: 0,05 – 40 points VVS – I2.

Dianco DMCC – Dubai
- Almost similar to the commercial activities as Dianco BV.
Dianco (HK) Ltd – Hong Kong
- Only trading of polished diamonds, no rough diamonds.
- Polished diamonds 75% - 80% are purchased from the Group Dianco entities.
- Polished product range in line with Dianco BV – Antwerp and Dianco DMCC – Dubai.

Dianco Shanghai Ltd – China
- Only trading of polished diamonds, no rough diamonds.
- Polished diamonds are purchased only from the Group Dianco entities.

3. Manage Risks

A list of all suppliers will be prepared and kept up-to-date. On a regular base a due diligence will be done to monitor their position in the global supply chain.
All relevant policies and procedures will be published on the website of the Group Dianco – www.diancogroup.com.
All suppliers will be informed about the possibility to consult our website to create awareness and to let them understand what the requirements are for business partners of the Group Dianco.
At the beginning of every year all procedures and policies will be revised by an appointed responsible person and if necessary new ones will be implemented.
Subsequently training will be foreseen for all staff and afterwards they have to sign a certificate that they have been trained, understood and will respect the guidelines of the Group and their entity.
In case of a necessity through the year an update will be planned and communicated.
The compliance officer of the respective entities will monitor financial requirements in relation to KYC, Anti-Bribery, KP Process, etc.
Overall we have to ensure to our supply chain remains transparent and that in all stages of the process all criteria are fulfilled. This implicates:
- Due diligence questionnaire for each supplier in our supply chain with an update every two years;
- To ensure that the steps as foreseen for the receipt of goods are strictly followed so that no discussion can be raised afterwards about the origin of the goods;
- Ensuring that our sourcing remains conflict free based on the information given by suppliers and that this information is correct;
- To ensure that all applicable national and international legislation is respected;
- Ensuring that all of business partners respects the basic human rights, in particular ‘The Universal Declaration of Human Rights’ and ‘C29 Forced Labour Convention, 1930’;
- In case of mining, to investigate and to ensure that these operations are with consent of all local communities;
- Regularly reports from the Compliance Officers in relation to any possible issue.

4. Due Diligence Practices - Documents

4.1 Mid-Stream Tier -1 & Tier -2

KYC document needs to be obtained and monitored on a regular basis.

Due diligence questionnaire needs to be obtained and evaluated with attention to the OECD requirements. If needed, the supplier’s attention will be drawn on these OECD requirements.
Each supplier has to ensure us by consulting (website, social media, etc.), visits and/or providing documents on:
- Social Compliance;
- Ethical Sourcing Policy;
- Annual reporting.
All documents to be evaluated by the management of each entity and in case of doubts and/or issues senior management of the Group Dianco.

4.2 Down Stream trader of Polished Diamonds

KYC document needs to be obtained and monitored on a regular basis.
Due diligence questionnaire needs to be obtained and evaluated with attention to the OECD requirements. If needed, the supplier’s attention will be drawn on these OECD requirements.
Each supplier has to ensure us by consulting (website, social media, etc.), visits and/or providing documents on:
- Social Compliance;
- Ethical Sourcing Policy;
- Annual reporting
All documents to be evaluated by the management of each entity and in case of doubts and/or issues senior management of the Group Dianco

5. Reports

5.1 Suspicious Transaction Identification Procedure( Red Flag / CAHRA’s):

Each entity must obtain a duly filled in Annex 1;
If the elements are not satisfying, additional investigations will be done;

Canceling or putting a commercial relationship on hold is the sole competence of the senior management of the Group Dianco.
The Compliance Officer of the Company is responsible to ensure that all the applicable regulations with respect to reporting cash and non-cash equivalents to the relevant Regulatory Bodies are fully adhered to.

ANNEX II – General Information

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 purchase arms or to fund their military actions.

Blood Diamonds are often produced through the forced labor of men, women and children. They are also stolen during shipment or seized by attacking the mining operations of legitimate producers. These attacks can be on the scale of a large military operation.

The stones are then smuggled into the international diamond trade and sold as legitimate gems. These diamonds are often the main source of funding for the rebels; however, arms merchants, smugglers, and dishonest diamond traders enable their actions. Enormous amounts of money are at stake, and bribes, threats, torture, and murder are modes of operation. This is why the term "blood diamonds" is used.

(geology.com)

What Are “Conflict-Affected and High Risks Areas (CAHRA’S)

Definitions:

OECD definition of conflict-affected and high-risk areas: Conflict-affected and high-risk areas are identified by the presence of armed conflict, widespread violence or other risks of harm to people. Armed conflict may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of liberation, or insurgencies, civil wars, etc. High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, the collapse of civil infrastructure and widespread violence. Such areas are often characterized by widespread human rights abuses and violations of national or international law.

EU definition of conflict-affected and high-risk areas: Areas in a state of armed conflict, fragile post-conflict areas, as well as areas witnessing weak or non-existing governance and security, such as failed states, and widespread and systematic violations of international law, including human rights abuses.

CAHRAs Procedure Guidance:

To support companies' development of their CAHRAs procedures, the RMI created Example Procedures to Identify CAHRAs for companies. This document covers the requirements defined in the Responsible Minerals Assurance Process (RMAP) and is grounded in the OECD Due Diligence Guidance and EU Conflict Minerals Regulation. When developing the CAHRAs procedure, companies can take into account size and complexity of their operations. Companies may find a combination of the publicly available resources referenced below and other resources (such as custom-tailored tools such as the RMI’s Country Risk Assessment Tool available to RMI members and RMAP auditees), may work best for their company’s operations. Once a company designs their procedure, the next step is to review the countries of origin and transit of their materials and the country where the company is operating against the procedure to identify if any would qualify as CAHRAs.

According to the RMI RMAP Standard, the CAHRAs shall include, at a minimum, countries identified as high-risk by relevant conflict minerals regulation, such as: The Democratic Republic of the Congo (DRC) and its nine adjoining countries as outlined in Section 1502 of the Dodd Frank Act, namely Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia; and, the indicative and non-exhaustive list of CAHRAs provided by the European Commission pursuant to Article 14.2 of the European Union Regulation 2017/821.

On December 17, 2020 pursuant to Article 14.2 of the European Union Conflict Minerals Regulation 2017/821 the European Commission Directorate General for Trade (DG TRADE) published the indicative, non-exhaustive and regularly updated list of conflict-affected and high-risk areas (CAHRAs).

(R.I.M.)

QR-Code: OECD Due Diligence Guidance for Minerals – 5-Step Framework for Upstream and Downstream Supply Chains

OECD 5 STEP FRAMEWORK FOR UPSTREAM & DOWNSTREAM SUPPLY CHAINS

ANNUAL REPORT 2021 – 2022

BUSINESS RESPONSIBILITY

Section A: Group Profile:

The group Dianco is a worldwide oriented diamond group with trading entities in Antwerp – Dubai – Hong Kong – China. We deal in rough and polished diamonds and our supply is derived from predominantly mining sources.

Depending on our needs and those from our customers we also attract diamonds from the open market and by exception from Conflict-Affected and High-Risk Area’s (CAHRA’s).

Sourcing from CAHRA’s is an element in our day-to-day business that we try to avoid at all

times but sometimes there is no other alternative.

The group has also manufacturing units in India but these are outside the scope of this report

given the specific requirements in this part of the overall diamond industry.

During the year 2021 the group started a new manufacturing unit in Namibia – ‘Dianco Diamonds (PTY) Ltd at Prosperita. Also in 2022 a new manufacturing unit will be started in Botswana – Dianco Botswana Proprietary Limited – Gaborone. In this way we want to expand our range of products that we can offer to our customers and potential customers but also to contribute in the social performance of the lives of the community in both countries.

Section B: Financial compliance of the Group:

2.1 Money Laundering, Terrorism Financing, Other Financial Offences Current Status

The Group Dianco recognizes the fact that entities in the diamond industry have to take on the onus of analyzing their potential vulnerabilities to money laundering. They have to implement specific steps that are required to the protection against abuses by criminals.
Compliance is ensured in all the entities of the group and a compliance officer has been appointed at the entity level. They report internally to the group CFO in relation to possible compliance issues on an annual basis.
In each entity two reports are kept on a monthly basis. ‘Cash Transactions’ and ‘Suspicious Transactions’. This includes no HARD cash transactions – Belgium < EUR 3.000 / Other entities max. USD 10.000. Possible suspicious transactions are immediately reported to the Financial Intelligence Unit of each country and to senior management of the group.
Know Your Counter Party and other Due Diligence Compliance is followed in line with OECD guidance
Ongoing monitoring is carried out among all stakeholders.