JEWELEX

ETHICAL BUSINESS POLICY

1. Background

At ZENSTAR JEWELRY LLP our philosophy is to measure success by not only the results we achieve, but also how we achieve them.
This Business Principles document, adopted by ZENSTAR JEWELRY LLP sets forth the basic internal standards to be observed by all Partners, officers and employees of the Company with respect to conducting business in a legal, ethical, professional and accountable manner.
The company is required to take appropriate steps to ensure that the same is understood and put into practice by all of its Partners, officers and employees.
Also appropriate steps are taken to assure adherence to this Business Principles document, including establishing appropriate disciplinary procedures where violations of this document will result in sanctions up to and including discharge.

2. Legislation and Regulations

ZENSTAR JEWELRY LLP shall operate in compliance with relevant national and international legislations / regulations as applicable in the country in which it operates.
All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal Company rules and policies relating to their business activities.
It is the responsibility of personnel to know and understand legal, regulatory and internal requirements as they apply to their jobs.
Compliance officer maintains the list of applicable legal and regulatory requirements and same is followed for compliance on day to day basis. Necessary records of requirements and its compliance is maintained.

3. Money Laundering, Terrorism Financing, Other Financial Offences

ZENSTAR JEWELRY LLP 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 required 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.
ZENSTAR JEWELRY LLP shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations.
It is the responsibility of concerned personnel to know and understand the relevant money laundering / financial offences related legal, regulatory and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious activity that appears to be questionable may also be considered as a violation of the Business Principles, depending on the seriousness of the non-conformance.
Compliance officer ensure all the critical steps such as KYC & KYS, Identification of suspicious transaction, reporting to management and record keeping as required by the local act and legislations are complied with.

4. Kimberley Process and System of Warranties

ZENSTAR JEWELRY LLP 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 following definition shall be followed as per Kimberley Process Certification System: "Rough diamonds used by rebel movements or their allies to finance conflict aimed at undermining legitimate Governments, as described in relevant United Nations Security Council (UNSC) resolutions insofar as they remain in effect, or in other similar UNSC resolutions which may be adopted in the future, and as understood and recognized in United Nations General Assembly (UNGA) Resolution 55/56, or in other similar UNGA resolutions which may be adopted in the future."
Wherever applicable, the following affirmative statement as recommended by the World Diamond Council's System of Warranties should be printed on all the invoices: "The diamonds herein invoiced have been sourced / purchased from legitimate sources not involved in funding conflict, in compliance with United Nations resolutions and corresponding national laws. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WDC SoW Guidelines."
Entering into transactions involving 'conflict diamonds' or not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, will be considered as a violation of the Business Principles.
As far as ZENSTAR JEWELLERY LLP is a jewellery manufacturing unit of the group thus Kimberly process is not applicable fully and further all its diamond needs are supplied by associate companies (most of the transaction within the group only) however necessary SOW is ensured.

5. Anti-Bribery and Facilitation Payment Policy:

ZENSTAR JEWELLERY LLP shall ensure complete prohibition of Bribery and facilitation payment across organization and in all the group 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.
The company shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.
Periodic training and awareness shall be carried out to educate employees about various type and ways of bribery and facilitation payments.

6. Disclosure of Treated Diamonds, Synthetics and Simulant

The following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and simulant
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.
Necessary declaration is provided on invoice as per the guideline of WFDB, & KPCS

7. Gold Sourcing Policy:

Company is committed to being a responsible corporate citizen and is opposed to human rights abuses. As part of that commitment, Company seeks to source products, components and materials from companies that share our values about human rights, ethics and environmental responsibility.
We discourage supply form "conflict minerals" originating from the Democratic Republic of the Congo (the "DRC") or adjoining countries. Revenue from the mining and transport of these conflict minerals is believed to be financing or benefiting groups that are responsible for human rights violations.
The four most commonly mined conflict minerals (known as 3TGs, from their initials) are Cassiterite (for tin), Wolframite (for tungsten), Coltan (for Tantalum) and gold ore, which are extracted from the eastern Congo, and passed through a various intermediary before being purchased.
Company strongly recommends the entire suppliers of Gold & 3T's not to supply any mineral or metals sourced from above regions.
Company supports industry-wide efforts to identify, reduce and eliminate the use of conflict minerals originating from the DRC and adjoining countries.
Company is committed to complying with any applicable requirements under the Conflict Minerals Rule and has implemented a Due-diligence process to meet its obligations under the legislation.
Supplier's to Company are expected to establish their own conflict minerals policies, Due-diligence frameworks and management systems that are designed to prevent sourcing of conflict minerals originating from the DRC or an adjoining country to ensure we don't fund conflict. In the event if Group determines that a supplier has failed to develop and implement reasonable steps to comply with this Policy, Company reserves the right to take appropriate actions, which may include discontinuing the business relationship with the supplier.

8. Supply Chain Management / Best Endeavours

The management of ZENSTAR JEWELLERY LLP is committed to taking appropriate action to use best endeavours to ensure the commitment of Tier 2 & Tier 3 entities to comply with the Best Practice Principles.

9. Conflict Minerals Policy Statement (Diamond & Gem Stone)

Company is committed to being a responsible corporate citizen and is opposed to human rights abuses. As part of that commitment, Company seeks to source products, components and materials from companies that share our values about human rights, ethics and environmental responsibility.
Company strive to ensure that none of its supplies of diamonds is originating from CAHRA's and where practically possible origin of diamonds is known to us.
Blood Diamonds, also known as "Conflict Diamonds," are stones that are produced in areas controlled by rebel forces that are undermines internationally recognized governments. The rebels sell these diamonds, and the money is used for criminal activities and or funding terrorism.
ZENSTAR JEWELLERY LLP ensures that none of its supplies come from the aforesaid countries/regions. ZENSTAR JEWELLERY LLP shall communicate its sourcing policy to all its stakeholders and will ensure effective implementation of its policy amongst all its entities.
ZENSTAR JEWELLERY LLP shall ensure that none of its supplies come from CAHRA Region sources. For More Details of CAHRA's refer to list of country under the regulation of EU 2017 https://www.cahraslist.net/cahras

10. Employment

Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.
The Company shall not require workers to work for more than the national limit of working hours.
The Company shall ensure that employees are paid above minimum wages and working hours shall be in adherence to local law.
It is the responsibility of concerned personnel to know and understand the relevant employment and labour related legal, regulatory and internal requirements as they apply to their jobs.
When required, due recognition will be given to the existence, membership and lawful activities of worker representative bodies, and worker representatives will be given access to carry out their responsibilities / functions.
The procedures detailed in the Employee Manual should be followed for dismissal of employees, in case the need for the same arises.
Information regarding applicable employment policies and working practices should be communicated in a transparent manner to all employees.

11. Health and Safety

ZENSTAR JEWELLERY LLP recognizes the need to provide safe and healthy working conditions to all its employees.
Any adverse impact of our business processes on those who carry it out shall be 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.
The review will lead to formulation of clearly described work practices and drills.
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, will be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
Workers shall not be under the influence of or abusing, drugs, alcohol and/ or other illegal substances.
We will seek to substitute the use of material, which are known to cause an adverse impact on the health of workers 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 standards that will be applicable.
Wherever requires and applicable, individual entities will nominate a Health, Safety and Environment Committee, headed by a senior management representative, which will have its fullest support in executing operational changes required to carry out these policies.

12. Non Discrimination, Disciplinary Practices

Discrimination can mean distinction, exclusion or preference.
Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees 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.
ZENSTAR JEWELLERY LLP will ensure that employees who have certain life threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.
ZENSTAR JEWELLERY LLP shall at no time condone the use of corporal punishment or other forms of mental or physical coercion
ZENSTAR JEWELLERY LLP 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. ZENSTAR JEWELLERY LLP shall assure all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully.

13. Child Labour

No form of child labour should be employed at any of the facilities of ZENSTAR JEWELLERY LLP.
Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).
For authorized adolescents (persons below 18 years of age but above 15 years), the Company management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
As per our company policy no child labour or adolescent child labour will be employed.
Company will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

14. Forced Labour

The management of ZENSTAR JEWELLERY LLP 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 this Business Principles.
The Universal Declaration of Human Rights that states that 'No one shall be held in slavery or servitude'
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"

15. Human Rights

All employees in the Company's facilities will be treated with equality, respect and dignity.
ZENSTAR JEWELLERY LLP 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.
Grievance Committee & Anti sexual harassment committees are formed and committee shall review the compliance at regular intervals.

16. Environment Protection

ZENSTAR JEWELLERY LLP 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.
Disposal procedures for waste generated will be clearly defined and practiced in line with standards that are set by law and best practices of the industry.
Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.
Measurement of environmental performance through auditing with employee accountability and reporting to senior management.
Commitment to a continual improvement process in environmental management.

17. Product Security

ZENSTAR JEWELLERY LLP is committed to secure its product throughout its supply chain by following precaution as mentioned below
Each and every stage of product processing it is covered through blanket insurance
Suitable safe guarding and storage is ensured at all stage with the help of safes
All the manufacturing, sales and retailing units are guarded by security agency and monitored by close circuit cameras.
All the concern persons are trained on relevant safety and security procedures to be followed at all time.
Organization has developed emergency plan, which includes procedure in case of emergency (include emergency scenario such as theft, robbery, etc.)
Product purity, quality and other parameters are monitored at each stage to avoid switching of the product.

18. Environment Responsibility

ZENSTAR JEWELLERY LLP is committed to comply with environment regulations and shall ensure all its facility have adequate arrangement for reduction, reuse and recycling of process wastes.
Compliance with all applicable environmental laws and regulations.
Effective communication of environment requirements and its compliance procedure to all the concerned employees on regular basis.
All the entities of the organization will identify the manufacturing processes being carried out in the premises. Once the activities are identified than it will be reviewed for environmental hazards associated with each of the activities.
Environmental hazards will be evaluated in terms of probability of occurrence of an activity and associated risks to environment. This will be further classified in to high, medium and low risk.

19. Synthetic Diamonds

ZENSTAR JEWELLERY LLP is committed to fight 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
Factory controls in place and safety measure are to be implemented to control switchover of diamonds.
Reporting of un-disclosed synthetics to supplier and interested parties whenever detected.
Record the incidents of contamination reported and implement suitable corrective and preventive measures for effective controls.
Identify the policy, procedure and test mechanism to implement testing procedures in the organization.

Public Grievances

Keeping in view the increasing importance to redress public grievances, company has introduced the common grievance cell to look in to the matter of reporting noncompliance of any of the company policy or raising red flag against any of its business entity or individual involved in activities that are against the company policy and which will bring industry in to disrepute. Any such matter can be communicated to below mentioned members.

Contact Details

Compliance Officer: Mrs. Prescilla D'Souza

Contact Number: +91 22 4244 1500

Email: PRESCILLA@jewelexindia.com

ANNUAL BUSINESS RESPONSIBLE REPORT

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.