OECD Annual Report

ANNUAL ETHICAL COMPLIANCE & OECD COMPLIANCE REPORT FOR THE YEAR 2025

Section A: General Information about the Company:

The Choron Group was established in 1985 by Rajesh Gandhi in Antwerp, Belgium; the diamond capital of the world. Drawing on his family’s deep roots in the Indian diamond industry, Rajesh set out to build a trusted diamond company founded on integrity, expertise and long-term partnerships.

Initially focused on rough diamond sourcing and polished diamond distribution, Choron steadily expanded its activities by developing direct relationships with leading rough diamond producers and growing its international presence. Over four decades, the Group has evolved into an internationally recognised, vertically integrated midstream player specialising in the sourcing of rough diamonds and the supply of natural polished diamonds to customers worldwide.

Throughout its growth, Choron has remained committed to the values that have shaped its success: integrity, craftsmanship, transparency and responsible business practices. The Group has strengthened its corporate governance by appointing independent directors, adopting IFRS accounting and auditing principles, and investing in traceability, responsible sourcing and internationally recognised sustainability standards across the natural diamond value chain.

A significant milestone was reached in 2025 with the acquisition of AMC Diamonds, an Antwerp-based diamond manufacturer established in 1983. A long-standing De Beers Sightholder, AMC is recognised for its manufacturing expertise, reliable supply and long-standing relationships with leading luxury jewellery maisons. The integration combines AMC’s manufacturing excellence with Choron’s expertise in rough diamond sourcing and exceptional natural diamonds, further strengthening the Group’s position across the natural diamond value chain.

The following entities are covered in this report:

• Choron Holdings Pte Ltd
• AMC (HK) Limited
• AMC Corporated Ltd.
• AMC Corporated Ltd. – Taiwan Branch
• AMC Diamonds (Shanghai) Co. Ltd
• AMC Diamonds Singapore Pte Ltd
• AMC Finance S.A.
• AMC NV
• AMC NV (Production Unit)
• AMC-Daneel Diamond Ventures (PTY) Ltd
• Choron (Belgium) BV
• Choron BV
• Choron Diamonds FZCO
• Choron FZCO
• Choron Pte Ltd
• AMC Corporated Ltd. – Taiwan Branch (Various Retail Jewellery)

Section B: Financial compliance of the CHORON GROUP:

2.1 Money Laundering, Terrorism Financing, Other Financial Offences

2.1.1 Current Status & Governance Framework

Choron Group maintains a zero-tolerance policy toward Money Laundering, Terrorism Financing (AML/CFT), Bribery, Corruption, and related financial offenses. Recognizing that the diamond, gemstone, and jewellery sectors require robust financial controls. Choron Group operates in full compliance with local financial legislation in all operating jurisdictions, and FATF recommendations.

Compliance Oversight: A designated Group Compliance Officer oversees financial compliance, conducting regular reviews and submitting an annual AML/CFT Compliance Report to Choron Group Senior Management.

Policies & Procedures: All group entities operate under standardized financial compliance guidelines integrated into the Choron Group Handbook: Rules and Policies.

2.1.2 Key Operational Due Diligence Controls

Choron Group executes rigorous “Know Your Counterparty” (KYC/KYS) protocols across all business relationships prior to initiating trade:

Counterparty Identification & UBO Verification: Onboarding requires full identification and verification of business counterparties, including ultimate beneficial owners (UBOs) and legal ownership structures.

Sanctions & PEP Screening: All business partners, directors, and UBOs are systematically screened against international sanctions lists (including UN, EU, OFAC, and UK consolidated lists) and Politically Exposed Person (PEP) databases.

Suspicious Activity Escalation: Defined internal escalation procedures are in place for employees to identify and report red flags or suspicious transactions to the Compliance Officer for review and escalation to relevant legal authorities as required by applicable law.

Ongoing Monitoring: Counterparty profiles and risk profiles are periodically updated and re-screened, commensurate with their assessed risk levels.

2.1.3 Area of Concern & Remedial Measures

Nil as of December 31, 2025. No material breaches, non-conformances, or suspicious activity escalations were identified during the reporting period.

2.2 Kimberley Process Certification Scheme (KPCS) and World Diamond Council System of Warranties (SoW)

2.2.1 Current Status & Policy Commitment

Choron Group maintains an absolute zero-tolerance policy toward conflict diamonds and is fully committed to upholding the integrity of the natural diamond supply chain. The Group strictly complies with the KPCS for all rough diamond import/export activities and implements the World Diamond Council System of Warranties across all entity operations.

Governance & Oversight: Day-to-day oversight of KPCS and SoW compliance is managed by the Group Compliance Officer, who monitors inventory flows, invoice documentation, and vendor warranties.

WDC Registration & Self-Assessment: Choron Group entities are registered on the WDC SoW online platform and complete the annual WDC SoW Self-Assessment, affirming alignment with human rights, labour, anti-corruption, and AML standards embedded in the revised WDC SoW Guidelines.

2.2.2 Key Operational Controls & Verification Mechanisms

Choron Group enforces systematic operational controls to guarantee compliance across all rough and polished diamond transactions:

Rough Diamond Import/Export Controls: Every cross-border shipment of rough diamonds imported or exported by Choron Group entities is accompanied by an official, government-validated Kimberley Process Certificate, verified for authenticity prior to customs clearance and internal processing.

Inbound Due Diligence (Warranties Received): Procurement teams verify that all incoming B2B invoices and consignment memos for rough and polished diamonds contain the mandatory WDC SoW declaration from suppliers.

Outbound Warranty Declaration (Warranties Issued): All outbound B2B sales invoices and memos generated by Choron Group entities mandate the official WDC System of Warranties declaration.

Annual Reconciliation & Record Retention: Complete records of all inbound and outbound SoW warranty declarations and KP certificates are retained for the minimum required period. An annual audit reconciliation of SoW warranty flows is performed to ensure total pipeline traceability.

2.2.3 Area of Concern & Remedial Measures

Nil as of December 31, 2025. No KPCS violations, missing certificates, or non-compliant SoW invoices were identified during the reporting period.

2.3 Anti-Bribery and Facilitation Payment

2.3.1 Policy & Core Commitments 

Choron Group maintains a strict zero-tolerance policy regarding all forms of bribery, corruption, extortion, and facilitation payments across all operating jurisdictions and group entities, complying with industry standards, and applicable local anti-corruption laws.

Strict Prohibition: Employees, directors, management, contractors, and third-party agents acting on behalf of Choron Group are strictly prohibited from offering, promising, giving, requesting, soliciting, or accepting any bribe, kickback, or undue advantage, whether directly or indirectly, to or from public officials, political candidates, or private sector commercial partners.

Prohibition of Facilitation Payments: Choron Group strictly forbids the payment of facilitation payments (unofficial, small payments made to expedite or secure routine administrative procedures or government services).

2.3.2 Operational Controls & Risk Management

To ensure full compliance and audit transparency, Choron Group enforces specific operational controls:

Gifts, Hospitality & Entertainment Thresholds: Guidelines govern the offering and acceptance of promotional gifts, business hospitality, and entertainment. All gifts or hospitality exceeding established monetary thresholds must receive prior compliance approval and be formally logged in a centralized Group Gift Register.

Whistleblower & Non-Retaliation Safeguards: Choron Group guarantees explicit protection against adverse career consequences, retaliation, or penalties for any employee who refuses to pay a bribe or facilitation payment, even if such refusal results in a loss of business, or who reports suspected corruption in good faith.

Public Grievance Mechanism: Dedicated compliance contact details and confidential grievance channels are published on the Choron Group website. This provides a secure, accessible mechanism for internal employees and external stakeholders to submit complaints or raise ethical concerns.

Risk Assessment & Due Diligence: The Group conducts periodic anti-corruption risk assessments across high-risk business processes (e.g., customs clearance, government permitting) and ensures third-party agents acknowledge and adhere to Choron Group’s ethical compliance standards.

2.3.3 Area of Concern & Remedial Measures

Nil as of December 31, 2025. No instances of bribery, facilitation payment demands, or corruption-related grievances were recorded during the reporting period.

2.4 Ethical Sourcing of Loose Diamonds (OECD Due Diligence Framework)

2.4.1 Policy Commitment & Governance Framework

Choron Group is committed to responsible, conflict-free, and ethical diamond sourcing. The Group recognizes the potential environmental, human rights, and social impacts associated with irresponsible mineral extraction and trade in Conflict-Affected and High-Risk Areas (CAHRAs).

To ensure full compliance Choron Group has implemented a supply chain due diligence management system aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (5-Step Framework):

Step 1: Strong Management Systems: Choron Group has adopted an explicit Supply Chain Sourcing Policy, appointed a Group Compliance Officer to oversee execution, and established internal records tracking for diamond inventory origins and supplier documentation.

Step 2: Risk Identification & Assessment: Supply chain mapping and Know Your Supplier evaluations are conducted to identify potential “red flag” origins, transportation routes, or entities associated with human rights abuses, financial crimes, or armed conflict.

Step 3: Risk Mitigation Strategy: Where supply chain risks or compliance gaps (e.g., supplier awareness gaps) are identified, Choron Group engages suppliers through corrective action plans, and capability development.

Step 4: Independent Auditing: Choron Group participates in third-party compliance audits (including RJC COP and De Beers BPP audit verification) to ensure independent assurance over its due diligence practices.

Step 5: Public Reporting: Annual due diligence activities and policy commitments are published in the Group’s annual ethical compliance reporting.

2.4.2 Key Operational Due Diligence Controls

Supplier Screening & Onboarding: All loose diamond suppliers undergo KYS screening to verify legal registration, conflict-free commitments, and compliance with human rights and environmental standards prior to trade engagement.

System of Warranties Integration: Procurement teams enforce strict requirements that all incoming and outgoing loose diamond invoices feature valid WDC System of Warranties declarations.

Traceability & Provenance Protocols: Choron Group prioritizes diamond sources with verified provenance, leveraging long-standing primary supply arrangements to maximize pipeline visibility.

2.4.3 Area of Concern & Remedial Measures

Identified Concern: Variable levels of awareness and technical familiarity regarding OECD Due Diligence requirements among downstream and mid-stream supply chain partners across diverse global jurisdictions.

Remedial Measures Undertaken & In Progress:

1. Supplier Capability Building & Communication: Issued Choron Group’s OECD Ethical Sourcing Policy to all global supply chain partners, formally requiring suppliers to acknowledge and align with these principles.
2. Enhanced KYS & Due Diligence Questionnaires: Rolled out standardized OECD-aligned KYS questionnaires to map upstream sourcing practices, verify CAHRA screening mechanisms, and assess counterparty risk profiles.
3. Targeted Supplier Engagement: Conducting active engagement sessions with key trade partners to clarify due diligence expectations, assist in building internal compliance capacity, and establish clear timelines for complete supply chain documentation.

2.5 Social Compliance

2.5.1 Policy Commitment & Universal Standards

Choron Group is dedicated to upholding exemplary labour standards, treating all employees with dignity, fairness, and respect across every operating facility and global entity. The Group strictly adheres to local statutory labour legislation, the UN Guiding Principles on Business and Human Rights, the Responsible Jewellery Council Code of Practices, and De Beers Best Practice Principles.

International Framework Alignment: Policy commitments strictly embody the International Labour Organization Declaration on Fundamental Principles and Rights at Work.

Governance Oversight: Group Management oversee social compliance, enforcing uniform employment standards across all subsidiaries and joint-venture operations.

2.5.2 Operational Controls & Human Rights Protections

Choron Group enforces specific, verifiable operational guidelines across all business units:

Child Labour Prohibition: Strict prohibition of child labour across all operations. Rigorous age-verification protocols (verifying government-issued identification prior to hiring) are enforced to ensure no individual under the legal working age or under 18 is employed in hazardous roles.

Prohibition of Forced Labour & Modern Slavery: Zero tolerance for forced, bonded, indentured, or trafficked labour. Employees retain full possession of their original identity documents, no recruitment fees are levied on workers, and freedom of movement is fully maintained.

Non-Discrimination & Workplace Respect: Equal opportunity in recruitment, compensation, training, and promotion regardless of race, gender, religion, age, disability, sexual orientation, political opinion, or national origin. Zero tolerance for workplace harassment, bullying, or disciplinary abuse.

Remuneration & Working Hours: Wages meet or exceed legal national minimums, standard benefits are provided, and overtime work is voluntary, reasonably capped, and compensated at statutory premium rates.

Freedom of Association & Collective Bargaining: Employees have the unhindered right to join or form worker organizations/trade unions of their choosing and engage in collective bargaining without fear of discrimination, retaliation, or intimidation.

Worker Grievance & Non-Retaliation Mechanisms: Grievance communication channels are established at all operating sites, enabling workers to report labour disputes, safety concerns, or human rights issues confidentially without fear of reprisal.

2.5.3 Area of Concern & Remedial Measures

Nil as of December 31, 2025. No material non-conformances or critical breaches concerning human rights or labour codes were reported at the Choron Group level.

Entity-Level Monitoring & Remediation Framework: 

1. Audit Oversight: Operating entities undergo regular internal social reviews and independent third-party audits (including RJC COP and De Beers BPP verification) conducted by accredited auditing agencies.
2. Corrective Action Protocol: Any minor operational observations or non-conformances identified at the entity level during third-party site audits are formally logged into entity-specific Corrective Action Plans, assigned clear completion timelines, and reported back to Group Management for verification and closure.

2.6 Health and Safety

2.6.1 Policy Statement & Commitments

Choron Group prioritizes the health, safety, and physical well-being of its employees, contractors, and visitors across all corporate offices, and manufacturing facilities. The Group is committed to providing a safe, healthy, and ergonomically sound working environment in compliance with local statutory H&S regulations.

Management System Oversight: Designated facility health and safety representatives oversee compliance at each operating facility, regularly evaluating potential workplace hazards and reporting performance to Group Management.

Continuous Improvement: Choron Group systematically reviews operations to eliminate workplace risks, applying national standards, expert technical guidance, and industry best practices.

2.6.2 Key Operational Health & Safety Controls

Across all global establishments and subsidiaries, Choron Group enforces structured operational safety measures:

Hazard Identification & Risk Assessment: Periodic health and safety risk assessments are conducted to identify potential hazards in office and diamond manufacturing environments. Corrective actions are implemented promptly according to the hierarchy of hazard control.

Training & Drills: Health and Safety induction training is provided to all new hires. All employees undergo regular refresher training, including emergency response procedures, fire safety protocols, and evacuation drills conducted periodically.

Emergency Preparedness & First Aid: Workplaces are equipped with visible emergency exits, unblocked evacuation routes, certified fire extinguishers, and fully stocked first-aid kits.

Facility Standards & Hygiene: All premises are maintained to meet or exceed building safety regulations, ensuring safe electrical systems, proper ventilation, adequate lighting, clean drinking water, and hygienic sanitary facilities.

Personal Protective Equipment (PPE) & Ergonomics: Where operational tasks require PPE, appropriate protective gear is provided free of charge.

Incident Recording & Investigation: A standardized procedure is in place to log, investigate, and report all workplace accidents, near-misses, or occupational health incidents to identify root causes and prevent recurrence.

2.6.3 Area of Concern & Incident Reporting

Nil as of December 31, 2025.

Performance Metrics:

Reportable Accidents / Fatalities: Zero (0)

Dangerous Circumstances / Near-Miss Escalations: Zero (0)

Lost Time Injuries (LTI): Zero (0)

Remedial Actions: No group-level remedial measures were required during the reporting period. Entity-level safety reviews and routine maintenance inspections continue according to scheduled compliance timelines.

2.7 Human Rights

2.7.1 Core Policy Commitments & Governance

Choron Group is committed to respecting and protecting internationally recognized human rights across all internal business operations, joint ventures, and global supply chain partnerships.

Executive Oversight: Choron Group Senior Management and the Group Compliance Officer oversee human rights compliance, ensuring policy integration into operational processes and supplier evaluations.

Non-Discrimination & Equal Opportunity: Choron Group respects the fundamental rights and individual dignity of all employees. The Group guarantees equal treatment and strictly prohibits interference with employee rights or practices based on caste, race, colour, national origin, gender, age, religion, disability, sexual orientation, union membership, or political affiliation.

2.7.2 Anti-Harassment & Workplace Respect Framework

Choron Group maintains a zero-tolerance stance against any form of abusive, degrading, or coercive behaviour in the workplace:

Prohibition of Harassment & Abuse: Physical, sexual, racial, religious, psychological, or verbal harassment, threats, intimidation, corporal punishment, or exploitation are strictly forbidden across all entity establishments.

Reporting & Non-Retaliation Safeguards: Employees and contractors can report suspected harassment or human rights violations via grievance channels published on the Choron Group website. The Group explicitly guarantees that whistleblowers and complainants are protected against retaliation, victimization, or adverse employment action.

2.7.3 Human Rights Due Diligence & Supply Chain Controls

In accordance with RJC COP 6 and OECD guidelines, Choron Group enforces continuous Human Rights Due Diligence to evaluate and mitigate human rights risks across operations and supply chains:

Internal Reviews: Periodic reviews are conducted across all corporate, and manufacturing units to verify compliance with non-discrimination, safe working conditions, fair wages, and worker rights.

Supplier Due Diligence & Risk Screening: Choron Group requires suppliers and business partners to commit to respecting human rights. Through risk-based Know Your Supplier assessments, suppliers are evaluated for potential adverse human rights impacts, particularly regarding forced labour, child labour, human trafficking, and conflict-sensitive sourcing.

Mitigation & Engagement: Where potential risks or knowledge gaps are identified within supply chain partners, Choron Group engages suppliers to implement corrective actions, and capacity building.

2.7.4 Areas of Concern & Continuous Improvement

Nil as of December 31, 2025. No material human rights violations, formal grievances, or abuse incidents were recorded or escalated across any operating entities during the reporting period.

Remedial Measures & Continuous Improvement:

• Continuous HRDD Optimization: Choron Group actively enhances its internal and supply chain due diligence procedures to adapt to evolving global regulatory standards, emerging geopolitical risks, and high-risk area designations.
• Stakeholder & Supplier Capability Enhancement: Expanding communication across key upstream trade partners to promote alignment with the Group’s standards.

2.8 Environmental Protection and Sustainability Policy

2.8.1 Policy Commitment & Governance Framework

Choron Group is committed to minimizing its environmental footprint, promoting sustainable resource usage, and advocating for climate resilience across all global operations. The Group strictly complies with applicable national environmental laws, and industry standards, such as Watch & Jewellery Initiative 2030 (WJI 2030) sustainability commitments.

Environmental Management System: Designated facility managers and ESG Leads oversee environmental performance at each operating facility.

Continuous Improvement: Group Management regularly reviews environmental performance to identify opportunities for reducing energy consumption, resource optimization, and environmental impacts across offices and manufacturing sites.

2.8.4 Area of Concern & Remedial Actions

Nil as of December 31, 2025.

Remedial Actions: No environmental remediation was required during the reporting period. Periodic internal reviews continue to ensure long-term environmental performance.

Prepared by: Compliance Officer

Approved by: CFO