Policy Commitments

C&C Jewelry Mfg., Inc.

Sustainability and Responsibility Business Practices

 


C&C Jewelry Mfg., Inc. is a member of the Responsible Jewellery Council (RJC).

The RJC is a standards-setting organization established to advance responsible ethical, human rights, social, and environmental practices throughout the gold, silver, platinum group metals, diamond, and colored gemstone jewelry supply chain.

The RJC has developed a benchmark standard for the jewelry supply chain and credible mechanisms for verifying responsible business practices through third-party auditing.

As an RJC certified member, we commit to operating our business in accordance with the RJC Code of Practices. We commit to integrating ethical, human rights, social, and environmental considerations into our day-to-day operations, business planning activities, and decision-making processes.

Signed/endorsed: Dmitriy Moskalenko – Controller

Date of effect: 8/15/24


Human and Labor Rights Policy

1. Introduction

C&C Jewelry Mfg., Inc. (C&C) is committed to the highest standards of business and ethical behavior including compliance with all applicable laws and regulations, as well as company policies, practices, and procedures. C&C respects internationally recognized Human Rights as established in the Universal Declaration on Human Rights and the International Labor Organization’s Core Conventions.

In line with the UN Guiding Principles on Business and Human Rights, C&C recognizes the corporate responsibility to respect these principles and commits to “know and show” this through ongoing human rights due diligence. Furthermore, our efforts include ongoing robust engagement with our business and major supply chain partners to mitigate potential human rights impacts beyond our direct control.

Our support of internationally recognized Human Rights is consistent with our dedication to enriching our workplace, partnering with our supply chain, preserving the environment, and supporting the communities where we operate.

2. Policy Objectives

The objective of C&C’s documented policies is to provide an overview of expectations for employees and business partners.

In addition, the Human Rights policy exists to:

  • Inform employees, business partners, and customers of C&C’s commitment to human rights.
  • Establish C&C’s commitment to “know and show” its respect for human rights through ongoing human rights due diligence.
  • Maintain C&C’s high ethical standards.
  • Contribute to the realization of human rights globally.

3. Policy Scope

C&C’s Human Rights Policy applies to all C&C employees worldwide, anyone doing business for or with C&C, and others acting on C&C’s behalf. This applies to all locations where C&C conducts business and to all company-sponsored events.

4. Definitions

Human Rights are basic rights inherent to all human beings, regardless of nationality, place of residence, sex, sexual orientation, national or ethnic origin, color, religion, language, or any other status.

5. Guidelines

C&C conducts its business in a manner that respects the rights and dignity of all people, complying with all applicable law and regulations. Our policies reflect our commitment to respecting the protection of internationally recognized Human Rights.

  • All employment with C&C is voluntary. We do not use child or forced labor in any of our operations or facilities. We do not tolerate any form of unacceptable treatment of workers, including but not limited to the exploitation of children, physical punishment or abuse, or involuntary servitude. We fully respect all applicable laws establishing a minimum age for employment, in order to support the effective abolition of child labor worldwide.
  • C&C abides by all laws and regulations regarding pay practices and the classification of employment according to job level and status.
  • We respect our employees’ right to choose to join or not join a trade union, or to have recognized employee representation in accordance with local law.
  • Diversity is embraced by C&C. We recognize that a diverse mix of backgrounds, skills, and experiences drives new ideas, products, and services and provides us with a sustained competitive advantage.
  • We believe everyone should be treated with respect regardless of their background. We are committed to the elimination of discrimination based on gender, race, class, economic status, ethnic background, sexual orientation, age, political beliefs, veteran status, marital status, or any other protected class.
  • C&C respects all human rights.
  • C&C commits to conducting ongoing human rights due diligence to assess and mitigate potential human rights infringements.

6. Responsibility

The Human Rights policy is owned and maintained by C&C’s Human Resources function. Human Resources is responsible for the creation, administration, updating, and communication of policy.

7. Compliance

Employees and suppliers are expected to comply with this and all applicable C&C policies. Violation of this policy or the refusal to cooperate will result in disciplinary action, up to and including termination and referral to the appropriate authorities. Where we have sound reason to believe that our partner organizations infringe Human Rights, we reserve the right to cease those relationships as warranted.

Specific to this policy, employees and suppliers are expected to:

  • Never infringe on human rights.
  • Be alert to any evidence of human rights infringements in our direct operations or in the operations of our business partners and report any situation in which a human rights infringement is suspected.

8. References

This policy reinforces other relevant policies including the No Child or Forced Labor policy, Diversity and Inclusion policy, Freedom of Association policy, and Wage and Hour Practices policy. For further information regarding human rights, please refer to:

Signed/endorsed: Dmitriy Moskalenko – Controller

Date of effect: 8/15/2


Bribery and Corruption Policy

Introduction

Whomever we may deal with, and wherever we may operate, we are committed to doing so lawfully, ethically, and with integrity. As part of this commitment, all forms of bribery and corruption are unacceptable and will not be tolerated. Facilitation payments are prohibited. We must not, and we must ensure that any third party acting on our behalf does not, act corruptly in our dealings with any other person.

This anti-bribery and corruption policy sets out C&C Jewelry Mfg., Inc.’s policies to prevent acts of bribery and corruption. These policies and procedures have been designed to comply with legislation governing bribery and corruption on a global basis.

This policy provides guidance on the standards of behavior to which we must all adhere, and most of these reflect the common sense and good business practices that we all work to in any event. This policy is designed to help you identify when something is prohibited so that bribery and corruption are avoided, and provide you with help and guidance if you are unsure about whether there is a problem and you need further advice.

Who this policy applies to

The fundamental standards of integrity under which we operate do not vary depending on where we work or who we are dealing with. This policy applies to all C&C’s officers, employees (full and part-time), and temporary workers (such as consultants or contractors) (together referred to as “employees”) across the group no matter where they are located or what they do. It is the responsibility of each of us to ensure that we comply with these standards in our daily working lives. This policy sets out a single standard that all employees must comply with, regardless of whether local law or practices might permit something to the contrary.

Part of C&C’s commitment to prevent bribery and corruption is to ensure that the people acting on our behalf also do so in compliance with effective anti-bribery and corruption policies. Accordingly, where we engage third parties such as agents, distributors, or joint venture partners, we have obligations to complete sufficient due diligence when entering into arrangements to ensure that they are not acting corruptly, and also to periodically monitor their performance to ensure ongoing compliance. In short, if we cannot do it, neither can they.

Failure to comply with this policy, whether or not this is intentional, may lead to disciplinary action (up to and including dismissal), and criminal liability for the individual involved (up to and including imprisonment). Employees will be required to confirm that they have read and understood the policy and that process. In addition, relevant employees will be required to attend training to support the guidance in this policy.

We prohibit retaliation against employees identifying in good faith concerns related to suspected bribery, refusing to participate in bribery, or refusing to pay a facilitation payment where facilitation payments are prohibited.

Getting Help

If you are unsure about your obligations under this policy, you should contact one of the following people for help:

  • In the first instance, your immediate supervisor
  • C&C compliance officer, President of the company, or one of the higher managers
  • Compliance office info: dmitriym@ccjewelry.com; 818-445-1945



Anti-Facilitation Payments Statement

Facilitation payments, which are payments to induce officials to perform routine functions they are otherwise obligated to perform, are bribes. There were no exemptions for such payments under the previous law nor is there under the Bribery Act.

C&C Jewelry Mfg., Inc. does not practice any cash payments and/or small bribes whether directly or indirectly, to or from:

  • A public or government official;
  • A political candidate, party, or official; or
  • Any private sector employees, directors, or officers.

Signed/endorsed: Dmitriy Moskalenko - Controller

Date of effect: 8/15/24
 


Anti-Money Laundering Policy and Procedures

Policy Statement

These are the Anti-Money Laundering (AML) Policy and Procedures adopted by C&C Jewelry Mfg., Inc. in compliance with The Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR). The business will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.

To these ends:

  • The identities of all new and existing clients will be verified to a reasonable level of certainty
  • A risk-based approach will be taken to the monitoring of client tax and accounting affairs
  • Any suspicious activity will be reported, and all AML activities recorded
  • Dmitriy Moskalenko will act as the Money Laundering Reporting Officer (MLRO) to coordinate the AML policies and procedures of the business.
  • All staff that meet or contact clients and potential clients of this firm are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting clients.

The following form contains the names and signatures of members of the staff that have read the Anti-Money Laundering policy and procedures of this practice.

NAME OF STAFF MEMBER SIGNATURE DATE
Dmitriy Moskalenko (MLRO)    
Robert Connolly (Owner)    
Mikhail Chekhman (Owner)    
Arturo Padin (VP of Sales)    
Lindsey Morris (Operations)    



Anti-Money Laundering Procedures

1. Due Diligence

The business has established a Know-Your-Counterparty (KYC) policy to ensure that the identities of all new and existing counterparties are verified to a reasonable level of certainty. This will include all individual counterparties, all directors and shareholders with a stake holding of 25% or more of counterparties, all counter partners of counterparties partnerships, and every board member of counterparties charities. Identities will be verified either online or face-to-face or by a combination of both.

Only recognized online identity verification agencies, which use data from multiple sources over a period of time, will be used (such as DUN & BRADSTREET). These commercial agencies must have processes that allow the enquirer to capture and store the information they use to check and verify an identity.

The following documentation may be presented by the individual:

  • In person
    • Either a passport, driver’s license, or government issued document featuring a matching photograph of the individual, and a full name and date of birth matching those provided.
    • An original recent utility bill, or government issued document with the same and address matching those provided by the individual.
  • Not in person
    • As in person but additionally: Any government issued document that provides the date of birth, SSN or FIN or other such government identifier.
    • Other forms of identity confirmation, such as evidence of a long-standing relationship with the client, or a letter of assurance from independent and reliable persons or organisations, who have dealt with the client for some time, may also provide a reasonable level of certainty.

If the business fails to verify the identity of counterparties with reasonable certainty it will not establish a business relationship or proceed with the transaction. If a potential or existing client either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the business shall refuse to commence a business relationship or proceed with the transaction requested.

2. Risk Assessment and Ongoing Monitoring

The business shall take a risk-based approach in monitoring the financial activities of its counterparties. This will be carried out whilst preparing the accounts or tax returns, or conducting any other business with the counterparties.

  • We use Heartland Payroll Co to verify individual identity

The business will actively not accept high-risk counterparties that are identified as follows:

  • Counterparties with larger one-off transactions, or a number of transactions carried out by the same customer within a short space of time.
  • Counterparties with complex business ownership structures with the potential to conceal underlying beneficiaries.
  • Counterparties based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organized crime, or drug production/distribution.
  • Situations where the source of funds cannot be easily verified.
  • Unusual patterns of transactions that have no apparent economic or visible lawful purpose.
  • Money sent to or received from areas known to have high levels of criminality or terrorist activity.

The business will conduct ongoing monitoring of business relationships with customers, to ensure that the documents, data, or information held evidencing the customer’s identity are kept up to date.

The following are examples of changes in a counterparties situation that may be considered suspicious:

  • A sudden increase in business from an existing customer;
  • Uncharacteristic transactions which are not in keeping with the customer’s known activities;
  • Peaks of activity at particular locations or at particular times;
  • Unfamiliar or untypical types of customers or transaction.

Whenever there is cause for suspicion, the counterparties will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners. No action need be taken if there is no cause for suspicion.

3. Internal Controls and Communications

Internal controls and Communication are not applicable as the business only has one employee involved in counterparties compliance and they are also the MLRO.

4. Monitoring and Managing Compliance

The MLRO will regularly monitor the following procedures to ensure they are being carried out in accordance with the AML policies and procedures of the business:

  • Counterparty’s identity verification;
  • Reporting suspicious transactions;
  • Record keeping.

The MLRO will also monitor any developments in the MLR and the requirements of the MLR supervisory body. Changes will be made to the AML policies and procedures of the business when appropriate to ensure compliance.

5. Suspicious Activity Reporting

A Suspicious Activity Report (SAR) will be made to the National Crime Agency (NCA) as soon as the knowledge or suspicion that criminal proceeds exist arises. The MLRO will be responsible for deciding whether or not the suspicion of illegal activity is great enough to justify the submission of a SAR.

Further details on NCA and SARS can be found at National Crime Agency.

6. Record-Keeping

Records of all identity checks will be maintained for up to 5 years after the termination of the business relationship or 5 years from the date when the transaction was completed. The business will ensure that all documents, data, or information held in evidence of customer identity are kept up to date.

Copies of any SAR, together with any supporting documentation filed will be maintained for 5 years from the date of filing the SAR. All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.

7. Training

The training of staff is not applicable as the business only has one employee involved in ML compliance who is also the MLRO. All affected employees are provided with training that explains The Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017, The Proceeds of Crime Act 2002 and section 18 and 21A Terrorism Act 2000, and how these affect the firm, its counterparties, and its employees.

All affected employees are trained on their responsibilities in relation to money laundering legislation, and are aware of how to identify and deal with transactions that may involve money laundering.
 


Environmental Management Policy 

We commit to reducing and managing the environmental impacts of our business operations through the implementation of an Environmental Management System (EMS). This includes:

  • The responsible management of all wastes and emissions to air, water, and land.
  • Establishing energy and water efficiency measures.
  • Seeking to ensure the responsible and efficient use of other natural resources, where applicable.



Product Disclosure

We will not knowingly make any untruthful, misleading, or deceptive representation, or make any material omission in the selling, advertising, or marketing of jewelry products and materials.

We further commit to disclosing information on the physical characteristics of jewelry and materials in accordance with the RJC Code of Practices Standards.
 


Sustainability Statement

C&C Jewelry Mfg., Inc. (“C&C” or “Company”) maintains certain policies with respect to standards of conduct expected in areas such as sourcing of diamonds, gold, tin, tantalum, tungsten (also referred to as 3TG) and platinum group metals in the product we sell. Being involved in improper activities could damage the Company's reputation and otherwise result in serious adverse consequences to C&C. As an RJC Member, C&C commits to integrating ethical, human rights, social, and environmental considerations into our day-to-day operations, business planning activities, and decision-making processes.

Ethical Sourcing & Provenance Traceability

Implementing certain policies in conjunction with jewelry supply chain management and supervision became one of the most important topics of our business operations. We established certain processes with regards to handling Diamonds. All Diamonds are procured through our diamond office in Hong Kong, from our diamond vendors who we have visited to make sure they are adhering to our diamond guidelines including checking for LGD’s and knowing their supply source. Then, Diamonds are tested for LGD’s before arriving in our US office. Prior to shipment, Diamonds are assorted by size and quality, after which Diamonds for a particular order are picked for the size and clarity and quantity needed. Approximately 1-2% extra diamonds are sent along with the order in case of breakage. When we receive diamond shipment at our office, Diamonds are screened again before being sealed. Sealed Diamond bags are hand delivered to the corresponding factory where they are signed for by said factory representative. While at factory we have said right to inspect the process at any time during manufacturing. We require all factory employees to submit to random searches when entering or leaving factory area. When an order is complete, excess diamonds along with the finished orders are sent to our office in Los Angeles by secured and insured carrier. Upon arrival, package is counted and sent to our quality control department for random karat assay and diamond weight check. During the quality control portion all jewelry is screened for LGD’s using our J Secure+ machinery. All excess diamonds are counted, weighed, and checked to make sure all diamonds are accounted for by weight and quantity. These excess diamonds are then returned to our diamond office in Hong Kong. Finally, finished approved pieces are stored in our secure vault areas until needed.

Product Quality and Authenticity

Quality of a jewelry product means to incorporate features that have a capacity to meet consumers’ trust and needs and gives them satisfaction of buying from the trusted source and relying on the honest manufacturer and/or seller within the jewelry supply chain. Our Company has maintained consumer satisfaction and loyalty and continues to implement and guarantee the authenticity of our diamond products along with gold and platinum group metals in the product we sell. Our product disclosure includes key features, benefits, and risks of our diamond and/or gold product we sell.

Responsible Practices & Respect for Human Rights

C&C conducts its business to bring the finished product to the consumer in a manner that respects the rights and dignity of all people, complying with all applicable laws and regulations and with respect to transparent and reputable practices.

Our Human Rights policy exists to:

  1. Inform employees, business partners, and customers of C&C’s commitment to human rights.
  2. Establish C&C’s commitment to “know and show” its respect for human rights through ongoing human rights due diligence.
  3. Maintain C&C’s high ethical standards.
  4. Contribute to the realization of human rights globally.



Health and Safety Policy

1. Principles

Safety is a core value at C&C Jewelry Mfg., Inc. (“C&C”) and C&C is committed to continued advancement of an institutional safety culture with strong programs of personal safety, accident and injury prevention, wellness promotion, and compliance with applicable environmental and health and safety laws and regulations.

C&C makes all reasonable efforts to:

  • Promote occupational and personal safety, health, and wellness;
  • Protect the health and safety of C&C employees;
  • Provide information to employees about health and safety hazards;
  • Identify and correct health and safety hazards and encourage employees to report potential hazards;
  • Conduct activities in a manner protective of the environment, and inform the Management regarding environmental impacts associated with institutional operations; and
  • Maintain a risk-based emergency management program to reduce the impact of emergency events at C&C.

2. Responsibilities

Adherence to good health and safety practices and compliance with applicable health and safety regulations are a responsibility of all employees. Line responsibility for good health and safety practice begins with the department supervisor and proceeds upward through the levels of management.

A. Supervisory Responsibilities

C&C Management is responsible for protecting the health and safety of employees. This responsibility entails:

  • Being current with and implementing C&C health and safety policies, practices, and programs;
  • Ensuring that workplaces are safe and well maintained; and
  • Ensuring that employees under their supervision or within their work areas have been provided with appropriate safety training and information, and adhere to established safety practices and requirements.

B. Managerial Responsibilities

C&C Management is responsible for ensuring that:

  • Individuals under their management have the authority to implement appropriate health and safety policies, practices, and programs;
  • Areas under their management have adequate resources for health and safety programs, practices, and equipment; and
  • Areas under their management are in compliance with C&C health and safety policies, practices, and programs.

C. Environmental Health and Safety Responsibilities

Environmental Health and Safety (EH&S) is responsible for:

  • Providing guidance and technical assistance to employees in identifying, evaluating, and correcting health and safety hazards;
  • Providing training materials, assistance, and programs in safe work practices;
  • Providing guidance on effective emergency management and emergency response services for incidents involving hazardous materials; and
  • Providing fire prevention, inspection, and systems maintenance services.

D. Employees Responsibilities

Employees are responsible for:

  • Keeping themselves informed of conditions affecting their health and safety;
  • Participating in safety training programs as required by C&C policy and their supervisors and instructors.

E. Safety Performance

Each individual at C&C is expected to perform all work safely. Managers and supervisors shall establish and maintain a system of positive reinforcement and escalated discipline to support good health and safety practices. Safety performance shall be a part of every individual’s role and responsibility as well as performance expectation and evaluation.

3. Providing a Safe Workplace

C&C's program for providing a safe workplace for employees includes: hazard identification, workplace inspection and corrective action, and emergency preparedness.

A. Hazard Identification and Correction

C&C encourages employees to report health and safety hazards to their supervisors, managers, or EH&S. Employees shall not be discriminated against in any manner for bona fide reporting of health and safety hazards to C&C or to appropriate governmental agencies. Supervisors shall inform employees of this policy and encourage reporting of workplace hazards.

Supervisors shall assure that regular, periodic inspections of workplaces are conducted to identify and evaluate workplace hazards and unsafe work practices.

  • The frequency of inspections should be proportional to the magnitude of risk posed in the particular workplace.
  • Means of correcting discovered hazards and/or protecting individuals from the hazards shall be determined and implemented appropriately.
  • Unsafe conditions which cannot be corrected by the supervisor must be reported to the next higher level of management. Any employee who becomes aware of a serious concealed danger to the health or safety of individuals shall report this danger promptly to the Department of EH&S and to the management who may be affected.

B. Emergency Response and Preparedness

EH&S coordinates overall emergency response planning for the institution and provides guidelines for departmental emergency response plans. Departments shall have emergency response plans and shall develop business continuity and contingency plans and implement appropriate mitigation programs to reduce the impact of emergency events.

Emergency plans shall include evacuation and assembly procedures, posted evacuation maps, reporting and communication practices, training, and drills.

4. Safety Communication and Training

Safety and compliance required training shall be communicated in a manner readily understandable to employees, in accordance with the communication policy outlined below.

A. Systems of Communication

Supervisors shall establish, implement, and maintain a system for communicating with employees about health and safety matters. Information should be presented in a manner readily understood by the affected employees. Due attention must be paid to levels of literacy and language barriers. Verbal communications should be supplemented with written materials or postings if appropriate. Whenever appropriate, statutes and policies affecting employees shall be available in the workplaces.

B. Communication About Hazards

Employees who may come in contact with hazardous substances or practices either in the workplace or in laboratories shall be provided information concerning the particular hazards which may be posed, and the methods by which they may deal with such hazards in a safe and healthful manner.

C. Training

Supervisors shall be experienced, trained, or knowledgeable in the safety and health hazards to which employees under their immediate direction and control may be exposed and shall be knowledgeable of current practices and safety requirements in their field.

Employees shall have or be provided the knowledge to protect themselves from hazards in their working environment. Supervisors shall ensure that employees have received appropriate training and information regarding:

  • General health and safety practices of the workplace, including emergency procedures;
  • Job-specific health and safety practices and hazards;
  • Recognition and assessment of health and safety risks;
  • How to minimize risks through sound safety practices and use of protective equipment; and
  • Awareness of appropriate practices to protect the environment.

Training shall occur when:

  • An employee is hired;
  • An employee is given a new assignment for which training has not previously been received; and
  • New hazards are introduced by new substances, processes, or equipment.

Employees should, periodically, be retrained or demonstrate an understanding of current standard safety practices and requirements for their areas.

5. Documentation and Recordkeeping

Documentation and records as required by regulation shall be kept to demonstrate compliance with applicable statutes, regulations, and policies.



Grievance Procedure

C&C Jewelry has established this procedure to hear any concerns or complaints from interested parties and stakeholders regarding its supply chain and business practices.

Concerns can be raised by interested parties via email using the following contact information:

Name: Dmitriy Moskalenko

Email: dmitriym@ccjewelry.com

On receiving a complaint, we will aim to:

  • Contact you as soon as possible to gather more information regarding your grievance, where applicable;
  • Decide who is the appropriate person internally to handle the grievance, or help redirect you to another entity, such as a relevant company, industry body, or other organization;
  • Identify any actions we should take (if any), or monitor the situation;
  • Advise you of any decisions or outcomes; and
  • Keep records on grievances received and the internal process followed to address such grievances, for at least five years.



Supply Chain Policy

1. Introduction

C & C Jewelry Mfg., Inc. is a jewelry manufacturer and wholesaler of finished jewelry products, including gold, PGM, silver, and diamonds. This policy confirms C & C Jewelry Mfg., Inc’s commitment to respect human rights, avoid contributing to the finance of conflict, and comply with all relevant UN sanctions, resolutions, and laws. C&C Jewelry Mfg. Inc. 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. Furthermore, we are committed to sourcing only gold and precious metals from one of the following: LBMA Good Delivery list, RMI RAMP Compliant Smelter list, RJC CoC certified entities, sources conformant with OECD Guidelines.

2. Responsible Jewellery Council Membership

C & C Jewelry Mfg., Inc is a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:

  • Respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;
  • Do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
  • Support transparency of government payments and rights-compatible security forces in the extractives industry;
  • Do not provide direct or indirect support to illegal armed groups;
  • Enable stakeholders to voice concerns about the jewelry supply chain; and
  • Are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

3. Influence and Consequences

We also commit to using our influence to prevent abuses by others. The consequences of non-compliance by our supplier will include, but not be limited to, reputation damage, which may result in lack of market access and product distribution delays. We will make sure that non-compliant suppliers will be publicly announced and the rest of the interested parties are made aware.

4. Serious Abuses

Regarding serious abuses associated with the extraction, transport, or trade of minerals: We will neither tolerate nor profit from, contribute to, assist, or facilitate the commission of:

  • Torture, cruel, inhuman, and degrading treatment;
  • Forced or compulsory labour;
  • The worst forms of child labour;
  • Human rights violations and abuses; or
  • War crimes, violations of international humanitarian law, crimes against humanity or genocide.

5. Upstream Suppliers

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.

6. Non-State Armed Groups

Regarding direct or indirect support to non-state armed groups: We only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

  • Control mine sites, transportation routes, points where diamonds are traded and upstream actors in the supply chain; or
  • Tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders.

7. Engagement with Upstream Suppliers

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.

8. Security Forces

Regarding public or private security forces: We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment, and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally as described in paragraph 6.

9. Bribery and Fraudulent Misrepresentation

Regarding bribery and fraudulent misrepresentation of the origin of minerals: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport, and export of minerals.

10. Money Laundering

Regarding money laundering: We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport, or export of minerals.

Signed/endorsed: Dmitriy Moskalenko - Controller

Date of effect: 8/15/24



Ethical Business Practices

1. Statement of Policy

It is a policy of C&C Jewelry Mfg., Inc. (the company) to conduct its business with honesty and integrity and in accordance with the highest legal and ethical standards.

The ethical business practices policy set forth in this policy provides guidance in specific situations. It is not possible to provide guidance for all situations that may arise; therefore, it is the individual employee’s responsibility to exercise good judgment to act in a manner that will reflect favorably upon the company and the individual.

Employees shall comply with the spirit as well as the letter of this policy. Employees shall not attempt to achieve indirectly, through the use of agents or other intermediaries, what is forbidden directly.

2. Applicability

The policy applies to all employees of the company throughout the world, including employees of subsidiaries controlled by the company.

3. Implementation

All managers are responsible for both ensuring that employees under their supervision are familiar with the policy and for promoting compliance with the policy.

Employees having questions on how to proceed or on interpretation should consult their managers and/or HR department.

Employees associated with the companies not controlled by the company shall be guided in their conduct by the provisions of the policy. They shall attempt to influence those companies to conduct their activities in conformity with all applicable laws and the policy and shall report violations in accordance with the policy.

The internal audit activity will review management’s processes for ensuring compliance with this policy and will determine compliance with the policy as part of its auditing procedures.

Compliance with the policy is essential. Violations will result in disciplinary action, including dismissal where warranted.

The use of any funds or assets of the company for any unlawful or improper purpose is strictly prohibited. Protecting company assets, which specifically include intangible assets such as customer accounts and intellectual property related to business processes and systems, is critical. All employees are personally responsible for protecting the property entrusted to them and for helping to protect the company’s assets in general. All employees should be alert to any situations or incidents that could lead to the loss, misuse, or theft of company property and report all such situations to their manager as soon as they come to their attention.

Company proprietary information is any information that is owned by the company. Much of the proprietary information is confidential and gives the company a competitive advantage. It may also be subject to copyright, patent, or other intellectual property or legal rights. Proprietary information includes such things as: technical information relating to current or future products, services, or research; business or marketing plans or projections; earnings and other financial data; personal information, including executive and organizational changes; and software.

It is critical that no employee discloses or distributes that information except as authorized by the company and that all employees follow all company safeguards for protecting that information.

No payments from the company’s funds or assets shall be made to or for the benefit of a representative of any domestic or foreign government, labor union, or any current or prospective customer or supplier for the purpose of improperly obtaining a desired government action, or any sale, purchase, contract, or other commercial benefit. This prohibition applies to direct or indirect payments made through third parties and employees as well as is intended to prevent bribes, kickbacks, or any other form of payoff. In addition, employees of the company shall not accept payments of the kinds described in this paragraph.

Nothing of value (for example, gifts or entertainment) may be provided to government personnel unless clearly permitted by law, any applicable regulation, and this policy.

Reasonable business entertainment would cover, for example, a lunch, dinner, or occasional athletic or cultural event; gifts of nominal value (approximately $100 or less); entertainment at facilities of the company; or authorized transportation in the company’s vehicle. In addition, reasonable business entertainment covers traditional promotional events sponsored by the company.

Using company work time to perform non-company work, including time given with pay to handle personal matters is not permitted. In addition, employees are not permitted to use company equipment/resources or proprietary information for outside work.

4. Conflicts of Interest

A conflict of interest is deemed to exist whenever an employee is in a position, as a result of the nature or responsibilities of his or her employment with the company, to further any personal financial interest of the employee or a member of the employee’s immediate family.

Actual or potential conflicts of interest involving an employee or his/her immediate family shall be reported in writing to the employee’s immediate supervisor who shall consult with the management to determine whether a conflict of interest actually exists and to recommend measures to be taken to neutralize the adverse effect of the conflict of interest reported.

This procedure shall be applied so as to minimize its effect on the personal affairs of employees consistent with the protection of the company’s interests.

No employee should permit himself/herself to be placed in a position that might give rise to the appearance that there is a conflict of interest.

5. Books and Records of the Company

The company’s books, records, and accounts shall accurately and fairly reflect the transactions of the company in reasonable detail and in accordance with the company’s accounting practices and policies.

For example:

  • No false or deliberately inaccurate entries (such as over or under billing) shall be made for any reason. Discounts, rebates, credits, and allowances do not constitute under billing when lawfully granted. The reason for the grant should be set forth in the company’s records, including the party requesting the treatment.
  • No payments shall be made with the intention or understanding that all or any part of it is to be used for any purpose other than that described by the documents supporting the payment.
  • No undisclosed or unrecorded funds or assets shall be established for any purpose.
  • No false or misleading statements, written or oral, shall be made to any internal or external accountant or auditor with respect to the company’s financial statements or documents to be filed with the regulatory authorities.

6. Payments of Amounts Due Customers, Agents, or Distributions

All commissions, distributions, or any other arrangements must be in writing and provide for services to be performed and for a fee that is reasonable in amount and reasonably related to the services to be rendered.

7. Inside Trading

Material inside information is information that is not available to the general public. The company will not tolerate the improper use of inside information.

As with investments, employees should not evade these policies by acting through anyone else or by giving inside information to others for their use even if the employee will not financially benefit from it.

8. Employee Privacy

The company collects and maintains personal information which relates to the employment of its staff, including medical and benefit information. Access to such information is restricted to people with a need to know. Personal information is normally released to outside parties only with employee approval, except that the company may release personal information to verify employment, to satisfy the legitimate requirements of a company or other entity which is considering acquiring some of the company’s business operations, or for appropriate investigatory, business, or legal reasons. Employees who have access to personal information must ensure that the information is not disclosed in violation of any law or company policies or practices.

9. Reporting violating

All employees of the company are responsible for bringing violations of this policy to the attention of their senior company management through normal reporting channels. In addition, all managers are responsible for taking corrective action when potential violations involving the policy come to their attention.
 


Child Labor Policy

C&C Jewelry Mfg., Inc. (“C&C”) endeavors to provide a conducive working environment that is characterized by equality and mutual respect. The company will not tolerate the use of child or forced labor, nor exploitation of children in any of its operations and facilities.

Definition

Almost all minors under the age of 18 are subject to California’s child labor protections. Under the California Labor Code, “minor” means any person under the age of 18 years who is required to attend school under the provisions of the Education Code, and includes minors under age six. Nonresidents of the state who would be subject to California’s compulsory education laws if they were residents are also considered minors and are subject to all the requirements and protections of the Labor Code. [LC 1286(c)] (See Chapter 3 of this digest). The Labor Code definition means, for example, the high school graduates under the age of 18, who are not subject to the compulsory education laws, are entirely excluded from permit requirements, work hour restrictions, and all occupational prohibitions. However, under federal regulation high school graduates may not be employed in an occupation prohibited to minors under 18 unless they have also completed a bona fide course of training in that occupation. [29 CFR 570.50] “Dropouts” are still subject to California’s compulsory education laws, and thus are subject to all state child labor requirements. (See Chapter 2 of this digest). Emancipated minors are subject to all California’s child labor laws, except that they may apply for a work permit without their parents’ permission. [FC 7050] (See Chapter 3 of this digest).

In the conduct of its business, C&C:

  • Will not employ children that fall into the above definition and local regulation;
  • Will comply with all other applicable child labor laws, including those related to wages, hours worked, overtime, and working conditions;
  • Is against all forms of exploitation of children. The company does not provide employment to children before they have reached the legal age to have completed their compulsory education, as defined by the relevant authorities;
  • Expects its business partners and associates to have and uphold similar standards and abide by country-governing laws in countries wherein they operate. Should violation of these Principles become known to C&C and not be remediated, we will take serious action, including discontinuation of the business relationship;
  • It is the responsibility of local management and Human Resource Department to implement and ensure compliance with this policy at all C&C operations and facilities.