Annual Business Responsible Report

ANNUAL BUSINESS RESPONSIBLE REPORT

For the period of 2024-2025

Date: 24th May 2025

  1. Section A: General Information about the Company:

1.1 ZENSTAR JEWELLERY LLP PROFILE

Like the multiple facets of a diamond, Zenstar Jewellery LLP goes beyond the value chain by providing superior products, customer care and services that are acknowledged within the global jewellery industry. We are among the world's leading vertically integrated diamond and jewellery companies known for integrity, innovation and trust. Being in the gems and jewellery business for over half 16 years, Zenstar has obtained a strong reputation. This is reflected by our wide range of product lines, strong global presence, and deep manufacturing expertise earned over the years. We are also a member of the Responsible Jewellery Council. We are recognized for consistency, excellent customer service and transparency in our operations. Integrated business model, cutting-edge technology, and skilled human resources have ensured Jewelex to be the supplier of choice for leading jewellery brands. Continuous innovation, unrelenting desire for excellence, care towards all stakeholders and working with complete integrity are the spirits which drive Zenstar.

2. Section B: Financial compliance of the ZENSTAR JEWELLERY LLP:

2.1 Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

  1. ZENSTAR JEWELLERY LLP 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.
  2. Strict compliance is ensured at all the entities and compliance officer has been appointed who in turn reports to ZENSTAR JEWELLERY LLP Management on compliance status on annual basis.
  3. Know Your Counter Party and other compliance of Due Diligence is followed in line with OECD guidance.
  4. 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

  1. ZENSTAR JEWELLERY LLP 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.
  2. Day to day monitoring and compliance of SOW is done by compliance officer.
  3. ZENSTAR JEWELLERY LLP is committed towards conflict free sourcing and zero tolerance policy is followed.

Area of concern & Remedial Measures

Nil As on Date.

2.3 Anti-Bribery and Facilitation Payment Policy:

  1. The ZENSTAR JEWELLERY LLP shall ensure complete prohibition Bribery and facilitation payment.
  2. ZENSTAR JEWELLERY LLP has published compliance officer’s 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:

  1. Our company is concerned about the environment and social impacts of irresponsible mining.
  2. ZENSTAR JEWELLERY LLP has identified the risk of supply chain with respect to Conflict Affected High Risk Area.
  3. ZENSTAR JEWELLERY LLP ensure all its supplies are screened for conflict free supplies.
  4. 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

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

Area of concern & Remedial Measures

  1. No point has been reported in the social compliance of the ZENSTAR JEWELLERY LLP where remedial measures at ZENSTAR JEWELLERY LLP level is required.
  2. Entity level remedial measures are taken based on internal and external audits conducted by reputed agencies.

2.6 Health and Safety

  1. We at ZENSTAR JEWELLERY LLP 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.
  2. This review will use appropriate standards as required by prevailing laws, expert opinion, and our knowledge of best practices.
  3. All our staff will be trained in the manner required to adhere to these work practices and drills.
  4. The health of our staff, exposed to certain hazardous processes, is being monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
  5. All workplaces are constructed to meet safety standards with local regulations as the minimum standards that will be applicable.

Area of concern & Remedial Measures

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

2.7 Human Rights

  1. ZENSTAR JEWELLERY LLP does 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.
  2. The Company strongly discourages any form of sexually coercive, threatening, abusive or exploitative behaviour.
  3. 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.
  4. ZENSTAR JEWELLERY LLP ensures that none of its suppliers and stake holder have engaged in any activity which can violate the Human Right Principles.
  5. 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

  1. No Area of concern & Remedial Measures has been raised in the Human right for any of our operating units.
  2. 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

  1. ZENSTAR JEWELLERY LLP is Complying with all applicable environmental laws and regulations.
  2. Improvement is seen in 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

Company Name: ZENSTAR JEWELLERY LLP

Date: 24th May, 2025

Reporting Period : Financial Year 2024-25

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 suppliers.
  • Awareness presentation on Ethical sourcing based on OECD guideline has been circulated.
  • Detailed policy and procedure has been established based on risk of CAHRA’s.

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 sourcing policy.
  • All key employees involved in souring and procurement of precious metals have been trained on our Ethical precious metal sourcing policy.
  • List of Suppliers has been maintained along with status of their social and ethical compliance.
  • Ongoing monitoring of 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 85% of supply is from low risk and balance 15% is from non-regular suppliers.

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 obtain the relevant information from them.
  • Further we are also obtaining the vital information about suppliers from social platforms and social compliance registration such as BPP & RJC, etc.

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 Website.

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.
  • Compliance officer oversees 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 that they are free from Conflict, wherever required Red Flags are been raised in order to seek additional information and Red Flags are 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 incomplete or not satisfactory, management starts engagement practice and begins 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 transactions and wherever required Red Flags are being 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 periodic status reports of OECD compliance to the management.

Internal Training

Each entity of the Group provides periodic training to all concerned employees who are involved in buying and selling and compliance monitoring teams.

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

RJC COP Audit

  • At ZENSTAR JEWELLERY LLP, 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:

  • Recently we have finalised the RJC COP 2019 Re-Certification audit and same is scheduled in end of May 2025.

Grievances And Remediation

  • No grievance of what so ever has been reported till date.

Prepared By & Approved by: Group Compliance Head and Compliance Manager

Date: 24th May 2025

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