Web Policy

BUSINESS PRINCIPLES DOCUMENT

Money Laundering, Terrorism Financing, Other Financial Offences / AML-CFT

• Choron Group recognizes the fact that entities in the gems and jewelry sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
• Strict compliance is ensured at all times, with all applicable national and, where appropriate, international laws / regulations with respect to money laundering, terrorism financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.
• Choron Group shall act in accordance with the national laws applicable in the countries we operate (of which country/ies?) with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations.
• Our Compliance officer ensures all critical steps including KYC (Know Your Counterparty), identification of suspicious transactions, reporting to management and record keeping as required by the local act and legislations are complied with.

Kimberley Process and System of Warranties

• Choron Group is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and World Diamond Council’s (WDC) System of Warranties Declaration.
• The definition of ‘Conflict Gem Stone & Diamonds’ as agreed by the Kimberley Process has been adopted and declaration are received from suppliers and issued to all the customers.
• We ensure KP compliance in all our trade of rough diamonds, which is audited by our internal audit team and by an independent auditor and compliance certificate is issued by them.

Disclosure of Treated Diamonds, Synthetics and Simulants

Although the Choron Group deals exclusively with natural diamonds, the following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and stimulant:

• Full disclosure i.e. the complete and total release of all available information about a Diamond and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the diamond.
• No misuse of terminology or mis-representations or attempts to disguise the product will be made in the selling, advertising and distribution of treated diamonds, synthetics and simulant.
• The word ‘diamond’ will not be used in the case of names of firms, manufacturers or trademarks, in connection with treated diamonds or diamond simulant or synthetic diamonds.

Synthetic Diamonds

Choron Group does not trade in synthetic diamonds and is committed to stand against undisclosed synthetic diamonds. Following methodology has to be adopted for ensuring compliance to undisclosed synthetic Diamonds :

• Access to effective detection system
• Buying from trusted suppliers
• Reporting of undisclosed synthetics to supplier and interested parties whenever detected.
• Recording the incidents of contamination reported and implementing suitable corrective and preventive measures for effective controls.
• Classify contamination points into different categories (High, Medium & Low)
• Identify the policy, procedure and test mechanism to implement test mechanism in the organization which includes testing all uncertified polished diamonds.
• Necessary declaration of compliance is obtained from the supply chain and chain of assurance and passed to customers by printing synthetic declarations on all our invoices.

Anti-Bribery and Facilitation Payment Policy

• The Group shall ensure complete Prohibition of Bribery and Facilitation payment across organization and in all the entities.
• Company will not offer, accept, or countenance any payment, gift, in kind, hospitality, expense or promises as such that may compromise promises of fair competition.
• Periodic training and awareness shall be carried out to educate team members about various type and ways of bribery and facilitation payments.

Supply Chain Management / Best Endeavors

• The management of Choron Group is committed to taking appropriate action to use best endeavors to ensure the commitment of business partners and associated manufacturing units complying with the same.
• Annual circulation of Best Practices is done among all trade suppliers and customer.

Gold Sourcing Policy:

• Choron Group is concerned about the environment and social impacts of irresponsible mining.
• Choron Group will ensure that all our gold suppliers comply with ethical & conflict free minerals as per OECD guideline.
• Further we are committed to ensure that sourcing of gold and precious metals products and articles are under the highest social, human rights and environmental standards of trade.

Conflict Minerals Policy Statement (Diamond & Gemstone)

• Choron Group is committed to being a responsible corporate citizen and is opposed to human rights abuses. As part of that commitment, Choron Group seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility.
• Choron Group shall strive to ensure that all its supply of diamonds are not originating from CHARA’s and where practically possible origin of diamonds is known to us.
• What are “Conflict Diamonds”? : Conflict Diamonds are stones produced in areas controlled by rebel forces that are opposed to internationally recognized governments and funding terrorism.
• Identified CAHRA’S Affected Diamond Producing Nations: Russia, Sierra Leone, Liberia, the Republic of Congo, Côte d’Ivoire, the Central African Republic, and the Democratic Republic of Congo.
• Choron Group shall ensure that none of its supplies are coming from above sources.
• Choron Group shall communicate its sourcing policy to all the stakeholders and will ensure effective implementation among them.

Employment

• Compliance is ensured at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.
• Choron Group shall ensure that wages and benefits for a standard working week shall meet at least international living wage and shall be sufficient to meet the basic needs of workers and provide some discretionary income.
• Information regarding applicable employment policies and working practices has been communicated in a transparent manner to all team members.

Health and Safety

Choron Group recognizes the need to develop a sustainable and responsible business and is committed to the following:

• Any adverse impact caused by business processes on any persons out shall be identified and eliminated. We will regularly and systematically review our operations to identify sources of health and safety related risks.
• This review will use appropriate standards as required by prevailing laws, expert opinion and our knowledge of best practices.
• The review will lead to formulation of clearly described work practices and drills.
• All our team members will be trained in the manner required to adhere to these work practices and drills. · We do not allow our team members to be exposed to any hazardous processes. This policy will be monitored periodically , and reviewed by third party experts to ensure compliance and inputs for improvements.
• We will prohibit the use of any materials that are known to cause an adverse impact on the health of any persons or health of consumers in the course of its manufacture or use.
• All workplaces will be constructed to meet safety standards with local regulations as the minimum standard.

Non Discrimination, Disciplinary Practices

• Any form of discrimination relating to the hiring, discharge, pay, promotion and training of team members on the basis of race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, HIV status, migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by the Company and any such reported incidents will be viewed as a serious violation of this Business Principles. · Choron Group will ensure that team members who have certain life threatening diseases or illnesses are not treated differently from other team members, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.
• Choron Group encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, company operation or practice is or will likely be in violation of any law, regulation or internal Company rule or policy, including this Business Principles.
• Choron Group will prioritize UN SDG 5 focusing on Gender Equality and will remain a signatory to the UN Women’s Empowerment Principles.

Child Labour

• No form of child labour is employed at any of the facilities of the Choron Group. · Furthermore, no child labour or adolescent child labour will ever be considered for employment at any of the facilities of the Choron Group.
• Company will maintain suitable policies and procedures to verify the age all new team members joining the organization.

Forced Labour

• The management of Choron Group is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of these Business Principles.
• The following definitions will be applicable:
  1. The Universal Declaration of Human Rights that states that ‘No one shall be held in slavery or servitude’.
  2. ILO Convention 29, which defines forced or compulsory labour as ‘all work or service which is extracted from any person under the menace of any penalty, and for which the said person has not offered himself voluntarily”.

Human Rights

• All team members in the Company’s facilities will be treated with equality, respect and dignity.
• Choron Group will not interfere in the right of team members to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation.
• Choron Group will not tolerate any form of sexually coercive, threatening, abusive or exploitative behavior.
• 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.
• HSE & Anti sexual harassment committees are formed and committee shall review the compliance at regular intervals.
• All team members will always have access to an anonymous grievance mechanism with direct communication and reporting to the independent director on the Board of the Choron Group.

Environment Protection

Choron Group is committed to effective environmental management as one of its important corporate priorities, and will focus on the following initiatives:

• Compliance with all applicable environmental laws and regulations.
• The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards and reviewed periodically to mitigate or eliminate such impact.
• Improvement of team member environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.
• Measurement of environmental performance through auditing with team member accountability and reporting to senior management.

Public Grievances

• Choron Group is committed to resolving public grievances and has appointed a public grievance contact to look in to matter of reporting non-compliance against any of the company policies and/or raising a red flag against any of its business entities or individuals involved in activities that may contravene and national and/or international regulations.

Public Reporting Contact Detail

Name of Contact Person: Mr. Hiren Shah Email Address: hiren@chorongroup.com

Phone: +971 4 2443131; M:+971 555510340