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OECD Annual Report

Choron Group > OECD Annual Report

ANNUAL ETHICAL COMPLIANCE & OECD COMPLIANCE REPORT FOR THE YEAR 2024

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. With invaluable experience from his roots in India, Rajesh set out to create a reputed and trusted diamond company. In its early years, Choron focused its operations on procuring rough diamonds from secondary sources in Antwerp and distributing the rough diamonds in India. At the same time, Choron was purchasing polished diamonds from manufacturers in India for distribution to clients across Europe and the Far East.

As the business expanded over the years, Choron set sights on developing relationships with the major rough diamond producers in order to secure direct supplies. Throughout the 1990s, Choron solidified its rough diamond supply from key mining companies and transformed into a leading diamond house in the industry. Parallelly, Choron broadened its sales network by increasing its footprint with offices across the globe enabling the polished diamonds division to reach new
heights.

The turn of the millennium brought with it continued success and the addition of a wholesale jewelry arm to service its growing client base. The global presence of the Choron Group led to dedicated efforts to implement corporate social responsibility initiatives with a keen attention to supporting the communities in and around the business operations. Further to this, the Choron Group prioritized its corporate governance and introduced measures to improve transparency and sustainability by appointing independent directors and adopting IFRS accounting & auditing principles.

Today, the Choron Group is a leading international diamond and jewelry Group primarily focused on the sourcing, assortment & sale of rough diamonds, the manufacturing of exceptional rough diamonds, the sale of polished diamonds and the distribution of wholesale jewelry. The Group is amongst a handful of players to procure rough diamonds from major mining companies including De Beers and Sodiam, whilst our polished diamonds division caters to businesses, discerning clients and retailers globally.

Following company covered in this report: Company falls under Midstream Tier 1

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

Section B: Financial compliance of the CHORON GROUP:

2.1  Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

  • CHORON GROUP recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
  • Strict compliance is ensured at all the entities and compliance officer has been appointed who in turn reports to CHORON GROUP Management on compliance status on annual basis.
  • Know Your Counter Party and other compliance of Due Diligence is followed in line with OECD guidance.
  • Ongoing monitoring is carried out along with all stakeholders.

Area of concern & Remedial Measures

  • Nil As on Date.

2.2 Kimberley Process and System of Warranties

  • CHORON GROUP is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme of World Diamond Council’s (WDC) System of Warranties Declaration.
  • Day t
  • o day monitoring and compliance of SOW is done by compliance officer.
  • CHORON GROUP is committed towards conflict free sourcing and zero tolerance policy is followed at CHORON GROUP level.

Area of concern & Remedial Measures

  • Nil As on Date.

2.3 Anti-Bribery and Facilitation Payment Policy:

  • The CHORON GROUP shall ensure complete prohibition Bribery and facilitation payment across organization and in all the entities.
  • CHORON GROUP has published compliance team contact details on website to receive any grievance or complaints.

Area of concern & Remedial Measures

  • Nil As on Date.

2.4 Ethical Sourcing of Loose Diamonds Policy:

  • Our company is concerned about the environment and social impacts of irresponsible mining.
  • CHORON GROUP has identified the risk of supply chain with respect to Conflict Affected High Risk Area.
  • CHORON GROUP ensure all its supplies are screened for conflict free supplies.
  • We have published the OECD based ethical sourcing policy and we are communicating our policies to all the supply chain partners and pushing them to adopt the same.

Area of concern & Remedial Measures

  • Current concern is lack of awareness about OECD regulation and requirements of sourcing.
  • We have started creating awareness about our Ethical sourcing requirements for our supply chain.
  • We started Engagement with our global supply chain for obtaining the further supply chain information to ensure ethical and conflict free sourcing in metal business.

2.5 Social Compliance

  • We ensure full compliance with all applicable national and, where appropriate, international laws / regulations with respect to employment and labour codes in all our establishment.
  • We respect all regulation for child labour, forced labour, non-discrimination, non-retaliation etc.
  • All work man rights are respected and adhere to freedom of association and collective bargaining regulations.

Area of concern & Remedial Measures

  • No point has been reported in the social compliance of the CHORON GROUP where remedial measures at CHORON GROUP level is required.
  • Entity level remedial measures are taken based on internal and external audits conducted by reputed agencies.

2.6 Health and Safety

  • We at CHORON GROUP are concern about the health and safety of employees and are constantly studding about any adverse impact of our business processes are identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.
  • This review will use appropriate standards as required by prevailing laws, expert opinion, and our knowledge of best practices.
  • All our staff will be trained in the manner required to adhere to these work practices and drills.
  • The health of our staff, exposed to certain hazardous processes, is be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
  • All workplaces are constructed to meet safety standards with local regulations as the minimum standards that will be applicable.

Area of concern & Remedial Measures

  • Nil as on date, as no accidents are reported in last one year.
  • Organization has been blessed and we did not have any fire or any other incidents leading to dangerous circumstances.

2.7 Human Rights

  • CHORON GROUP is not and 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 behaviour.
  • Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company.
  • CHORON GROUP ensures that none of its suppliers and stake holder have engaged in any activity which can violate the Human Right Principles.
  • We have carried out the Human Right Due Diligence of suppliers and other Stake holders & based on risk assessment where necessary.

Area of concern & Remedial Measures

    • No Area of concern & Remedial Measures has been raised in the Human right for any of our operating units.
    • Supplier’s further upstream compliance with respect to Human Right compliance for conflict free sourcing is a new development, where company is heading and would require more focus on the same.

2.8 Environment Protection

  • CHORON GROUP is Complying with all applicable environmental laws and regulations.
    • Improvement is seen employee’s environmental awareness and performance with the help
      of detailed policies and procedures, training, and recognition of excellence.

Area of concern & Remedial Measures

  • Nil

 

 

ANNUAL REPORTING TEMPLATE (RJC TOOL KIT VERSION 5.0)
Company Name: CHORON GROUP
Date: 13 th June, 2025
Reporting Period : January 2024 to December 2024
Step 1: Establish strong company management systems
1.A. Adopt and clearly communicate to
suppliers and the public, a company policy
for the supply chain of minerals originating
from conflict­ affected and high-risk areas
  • We have published the policy at
    company level for easy accesses to
    stakeholder.
  • OECD and Best Practice Annual
    communication has been sent to all the
    active supplier.
  • Awareness presentation on Ethical
    sourcing based on OECD guideline has
    been circulated.
  • Detailed policy and procedure at entity
    level has been established based on risk
    of CAHRA’s is done.
1.B Structure internal management systems
to support supply chain due diligence.
  • Additional responsibility has been
    assigned to Compliance officer to look
    over the compliance of Ethical souring
    policy.
  • All key employees involved in souring
    and procurement of precious metals
    have been trained on our Ethical
    precious metal souring policy.
    Refresher trainings are provided.
  • List of Suppliers has been maintained
    along with status of their social and
    ethical compliance.
  • On going monitoring of each supply
    and associated suppliers is carried out
    with the help of tools such as digital media,
    web search, review of supply
    documents, declaration and market
    intelligence etc.
1.C Establish a system of controls and
transparency over the minerals supply chain.
  • Supplier upstream information
    collection process started and to
    obtained CAHRA’s information and
    Ethical sourcing compliance at supplier
    level.
  • Currently Choron Group 85% supply
    from law risk and balance 15% is from
    non-regular suppliers based on Year
    2023-24 and for year 2024-25 review is
    in process.
1.D Strengthen company engagement
with suppliers.
  • As mentioned above supplier
    questionnaire has been circulated and
    we are in the process of following up
    with them to obtained the filed
    information from them.
  • Further we are also obtaining the vital
    information about suppliers from social
    platforms and social compliance
    registration such as BPP & RJC
    Approved ASM programs etc
  • We are in the process of compiling
    filled supplier questionnaire data, after
    analysis we will be formulate supplier
    engagement practices based on risk
    reported at each supplier level (if any)
1.E Establish A Company-Level, Or
Industry Wide, Grievance Mechanism
as An Early Warning Risk-Awareness
System.
  • We have established the grievance
    handling policy and procedure at
    company level, contact details of
    compliance head provided in our Group
    Social and Ethical policy on our Web
    site under Business Principal Section
    (which is publicly available)
Step 2: Identify And Assess Risk In The Supply Chain
Identify And Assess Risks in The Supply
Chain and Assess Risks of Adverse Impacts.
  • We have established the detailed policy
    and procedure for identification of risk
    at entity level.
  • Each entity has appointed and trained
    compliance officer to oversee the
    financial and ethical sourcing
    compliances.
  • We have categorized supply chain in to
    2 major segments that its Secondary
    supplier and Open market suppliers.
  • All suppliers are bifurcated in to this
    category and open market supplies are
    considered as potential risk for supplies
    from CAHRA’s and thus step by step
    information are gathered from this
    category of supplier as mentioned in
    point 1.B & 1.C.
Step 3: Design And Implement A Strategy To Respond To Identified Risks (If
Applicable)
Report Findings of The Supply Chain Risk
Assessment to The Designated Senior
Management of The Company.
  • Ongoing monitoring of each supply is
    done by compliance officer to confirm
    its free from Conflict, were required
    Red Flags are been raised for seeking
    additional information and closed after
    receiving such information to our
    satisfaction.
  • Entity level compliance officer shall
    report all un-answered flags to local
    management and Group compliance
    officer.
  • In worst situation where information is
    half or not satisfactory management
    starts engagement practice and
    discussion and dialogue with suppliers
    is carried out to ensure full information
    in further business.
Devise And Adopt A Risk
Management Plan.
  • We have formulated the risk
    management plans at entity level
    considering individual entities position
    in supply chain and position of supplier
    in supply chain.
  • Entity compliance officer carries out
    monitoring of each and every business
    transaction and were required Red Flags
    are been raised and further steps are
    followed as mention above.
  • Brief of companies Risk Management
    Practices has been mentioned in
    communication of Business policy on
    our website.
Implement The Risk Management Plan and
Monitor Performance of Risk Mitigation
Efforts.
  • Entity level and group level monitoring
    of Red Flags and its effective closure is
    monitored.
  • Compliance officer provides period
    status reports of OECD compliance to
    the management.
Internal Training
  • Each entity of the Group provides
    period training to all the concern
    employee involved in buying and
    selling and compliance monitoring
    team.
Communications
  • Business principle has been published
    on the website covering all the COP wise policy
    including Ethical Precious Metal souring policy
    of the group.
  • Over and above Annual communication
    on Business policy and Awareness on
    various best practices and expectation
    from business partners is communicated
OPTIONAL INFORMATION ON Step 4:Carry Out Independent Third-Party Audit
Communications
  • Business principle has been published
    on the website covering all the COP wise policy
    including Ethical Precious Metal souring policy
    of the group.
  • At Choron Group, we hold ourselves
    to the highest standards of ethical
    and responsible business practices.
    As part of our commitment to
    transparency and accountability, we
    are proud to announce our
    compliance certifications and
    adherence to industry guidelines.

RJC COP Certification:

  • Choron Group is certified by the
    Responsible Jewellery Council
    (RJC) Code of Practices (COP) in
    multiple regions including Belgium,
    UAE, South Africa.

BPP Compliance:

  • We are pleased to confirm that
    Choron Group adheres rigorously to
    the Best Practice Principles (BPP)
    established by De Beers. Our
    compliance with the De Beers BPP
    guidelines reflects our commitment
    to integrity, transparency, and
    sustainability across all facets of our
    business operations.
  • Annual BPP Compliance Audit
    conducted by BPP team and BPP
    Compliance annual report available on
    DeBeers Smart System
Grievances And Remediation
  • No grievance of what so ever has beenreported till date.

Prepared By & Approved by: Compliance Officer
Date : 13 th June 2025

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