• No form of child labour should be employed at SANNIDHYA DIAMONDS.
• 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 entity management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
• If a child is found working at SANNIDHYA DIAMONDS either own or sub-contracted, the responsibility of rehabilitation will be undertaken by the management.
• The above policies will also be applicable to subcontracted labour.

The policies relating to this section are part of the Business Policies adopted by SANNIDHYA DIAMONDS and are presented below for reference:

1. The management of SANNIDHYA DIAMONDS are fully committed to ensuring that forced or involuntary, bonded, indentured or prison labour, is not practiced nor used in any form at any of its facilities. SANNIDHYA DIAMONDS shall ensure that there is no restriction in the freedom of movement of employees and dependents. Any reported incidents relating to forced labour will be considered as a serious violation of the Business Policies.
2. The following definitions will be applicable:
   • 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'

The policies relating to this section are part of the Business Policies adopted by SANNIDHYA DIAMONDS and are presented below for reference:

1. SANNIDHYA DIAMONDS recognizes the need to develop a sustainable, value-creating business and is committed to the following in the areas of health and safety.
2. Providing safe and healthy working conditions for all employees in accordance with applicable law and other relevant industry standards.
3. Any adverse impact of our business processes on those who carry them out shall be identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.
4. We will provide adequate and appropriate labeling and storage of all chemicals and cleaning materials and adopt methods to protect employees from exposure to airborne particles and chemical fumes.
5. Our review of our processes will use appropriate standards as required by prevailing laws, expert opinion, feedback from workers and our knowledge of best practices. The review will lead to formulation of clearly described work practices and safety drills and appropriate safeguards and isolation from mobile equipment. All our staff will be trained in the manner required to adhere to these work practices and drills.
6. 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 is known to have an adverse impact on the health of workers or health of consumers during its use.
7. All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applied. We will take adequate measures to safeguard our employees from fire and other workplace injuries.
8. All products sold by SANNIDHYA DIAMONDS to consumers shall comply with applicable regulations of product health and safety.

• We, SANNIDHYA DIAMONDS, recognize our responsibility to respect human rights. We believe that our business has a role to play in protecting and promoting human rights.
• SANNIDHYA DIAMONDS is committed to respecting internationally recognized human rights throughout our operations and supply chains. In line with the UN Guiding Principles on Business and Human Rights, our Policy is based upon the international standards enshrined in the Universal Declaration of Human Rights and the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work.
• Human rights refer to a set of basic rights and freedoms that belong to every person in the world, regardless of where they are from, what they believe or how they choose to live their life. For SANNIDHYA DIAMONDS, respecting human rights means ensuring that any person involved in, or encountering, our operations, supply chains and products is treated with dignity, respect, fairness and equality.
• Our Policy sets out overarching principles for how we conduct business at SANNIDHYA DIAMONDS. Together with our employees and business partners, we are committed to driving forward the implementation of this Policy throughout our operations and supply chains.
• Code of Conduct as reference in relation to labour rights, working conditions and health & safety:
  1Employment is freely chosen

  2Freedom of association

  3Working conditions are safe and hygienic

  4Child labour shall not be used

  5Living wages are paid

  6Working hours are not excessive

  7No discrimination is practiced

  8Regular employment is provided

  9No harsh or inhumane treatment is allowed
• SANNIDHYA DIAMONDS will continuously work to embed this Policy throughout the relevant processes and procedures of the company to ensure its effective implementation.
• We recognise that we must take steps to identify and address any actual or potential adverse impacts, whether they are directly or indirectly linked to our business activities or relationships.
• We understand that human rights due diligence is a dynamic, on-going process which requires acting on the findings, tracking our actions, and communicating to our stakeholders how we address impacts.
• As our human rights risks and impacts may vary over time, this policy will be subject to review if proven inadequate by our human rights due diligence process.

The policies relating to this section are part of the Business Policies adopted by SANNIDHYA DIAMONDS and are presented below for reference:

1. SANNIDHYA DIAMONDS is committed to prohibit bribery in all business practices and transactions that are carried out by the company or on its behalf by business partners. The company will not offer, accept or countenance any payments, gifts in kind, hospitality, expenses or promises as such that may compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with, or direct business to, any person; to influence the course of the business or governmental decision-making process.
2. SANNIDHYA DIAMONDS considers Bribery Risk as it applies to its organization (including agents) to identify which areas pose high risks. SANNIDHYA DIAMONDS has developed appropriate methods to monitor conduct of employees and agents and eliminate bribery based on this understanding.
3. The management of SANNIDHYA DIAMONDS facilitates the reporting of incidences of attempted bribery or inappropriate gifts within their organization and shall apply appropriate sanctions for bribery and attempted bribery in all forms.
4. SANNIDHYA DIAMONDS ensures that no employee will suffer demotion, penalty or other adverse consequences for voicing a concern, or for refusing to pay a bribe or facilitation payment even if this action may result in the enterprise losing business.

The policies relating to this section are part of the Business Policies adopted by SANNIDHYA DIAMONDS and are presented below for reference:

1. SANNIDHYA DIAMONDS 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.
2. 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, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.
3. SANNIDHYA DIAMONDS shall act in accordance with national laws and national/international accounting standards with respect to maintaining financial accounts of all business transactions and auditing of its financial accounts.
4. SANNIDHYA DIAMONDS ensures that concerned employees know and understand the relevant regulatory jurisdiction for national and international transactions, 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 Policies, depending on the seriousness of the non-conformance.
5. SANNIDHYA DIAMONDS implements a "Know your Customer" and "Know your Supplier" procedure that establishes the identity of all organizations with which it deals, have a clear understanding of their business relationships and have a reasonable ability to identify and react to transaction patterns appearing out of the ordinary or suspicious.

1. The company shall complete the due diligence process prior to initiating business relationship. The company shall purchase/sale diamonds that are fully compliant with Kimberly Process Certification Scheme (KPCS).
2. The company should ensure that all its respective activities are in line with the OECD Due Diligence Guidelines, and as per Universal Declaration on Human Rights laid down by United Nations.
3. The company shall prohibit any procurement from Conflict-Affected & High-Risk areas and adhere to compliance with standards on Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT).
4. Relevant Employees shall be trained on the Supply Chain & Due Diligence Requirement and OECD guideline at regular interval. We shall also provide support to our business partners and stakeholders for the same.
5. The company shall carry out risk assessment for its supply chain and shall not enter into any business relationship or if may require then shall suspend/discontinue the engagement with any such supplier involved in dealing with Conflict-Affected and High-Risk areas, any form of Human Right Violation; Torture, Cruel, In-Human and Degrading Treatment; Forced/Compulsory Labour; Child Labour; Abuses such as widespread Sexual Violence; War Crimes; other serious violations of International Humanitarian Law, Crime against Humanity; Genocide and/or To Bribe or to be Bribed. We strictly condemn and prohibit any Direct/Indirect support to public/private security forces which illegally Control, Tax or Extort money from Mining Sites, Transportation Routes and Upstream Sectors.
6. The company shall verify counterparty details, including the Know Your Customer (KYC) for any precious metals supplying Counterparties at regular interval. The company shall carry out risk-based assessments, set appropriate verification control and monitoring of all such commercial activities and transactions.
7. The company shall assign responsibility for Supply Chain Integrity and due diligence compliance to senior personnel of the organization to prevent any risk of illegal activities or breach of it. The company should implement the management strategy to respond to identified risks. For the same, Compliance Officer shall report to Senior Management in case of any such violation of this policy.
8. The company has established a risk assessment module and any business partners with high-risk rating shall be red flagged and reports to be submitted to senior management.
9. Grievance Mechanism
   1. The purpose of this document is to outline a process through which any stakeholder can understand due diligence and supply chain integrity policy of the organization. The identity of the person who so ever has registered a concern shall be kept confidential and no retaliatory action shall be taken against any whistle blower. For anonymous submissions, you may refrain from providing your contact information.
   2. Please share your Complaint/Grievance/Suggestion on sannidhyadiamonds@gmail.com

1. Purpose

This procedure outlines the process for the annual review of SANNIDHYA DIAMONDS's human rights policy, procedures, and due diligence processes for effectiveness, and for public reporting on our human rights due diligence efforts, including identified human rights impacts and remedy activities. This process ensures continuous improvement and transparency.

2. Scope

This procedure applies to all human rights-related activities and performance within SANNIDHYA DIAMONDS and its relevant business relationships.

3. Annual Human Rights Review Process

3.1 Frequency: Top management shall conduct these reviews at least annually.

3.2 Review Leadership: Led by the Senior Staff Member for Human Rights Compliance, involving relevant department heads.

3.3 Inputs to the Review: Key inputs include:

• Effectiveness of Human Rights Due Diligence: Results from Human Rights Impact Assessments (HRIA), including methodologies used to determine human rights issues.
• Performance of Complaints and Grievance Mechanism: Data from the mechanism, including number/type of human rights-related grievances, response/resolution times, effectiveness of remedies, and trends.
• Remediation Effectiveness: Assessment of implemented remediation plans and their outcomes.
• Corrective Actions Status: Review of the status and effectiveness of corrective actions implemented from previous reviews or identified impacts.
• Business Partner Engagement: Evaluation of our efforts to influence business partners on human rights.
• Changes in Context: Consideration of any new human rights risks, legal requirements, industry standards, or operational changes.
• Stakeholder Feedback: Input from internal and external stakeholders, including Affected People or Groups.

3.4 Identification of Gaps and Improvements: The review will identify any gaps, weaknesses, or areas for improvement in our human rights policy, procedures, and due diligence processes. Improvement opportunities and corrective actions will be clearly defined, with assigned responsibilities and timelines.

3.5 Documentation of Review: The review process and outcomes, including discussions, decisions, and action plans, must be thoroughly documented.

4. Public Reporting on Human Rights

4.1 Frequency: Annually.

4.2 Communication with Affected People or Groups: Prior to public reporting, we will communicate annually with relevant Affected People or Groups regarding our human rights due diligence efforts.

4.3 Public Reporting Medium: Our annual human rights report will be made publicly accessible on our company website and/or integrated into our broader sustainability or annual report.

4.4 Report Content: The report will transparently cover:

• Methods Used to Determine Human Rights Issues
• List of Identified Human Rights Impacts
• Remedy Activities including grievance mechanism overview and aggregated grievance data
• Corrective Actions taken to cease or change activities contributing to adverse impacts
• Influence on Business Partners
• Performance and Progress
• Future Plans for continuous improvement

4.5 Data Integrity: All information reported will be accurate, verifiable, and consistent with our internal records.

1. Purpose

This procedure outlines SANNIDHYA DIAMONDS's legitimate, rights-compatible, and effective complaints and grievance mechanism. Its purpose is to provide a clear, accessible, and transparent process for all stakeholders (employees, contractors, communities, business partners) to raise concerns, seek information, and resolve disputes related to our business operations and adherence to our policies, particularly concerning human rights-related issues.

2. Principles of the Mechanism

• Consistent with Internationally Recognized Human Rights Standards: Aligned with the UN Guiding Principles on Business and Human Rights.
• Easily and Publicly Accessible: Information on how to access the mechanism is readily available to all relevant stakeholders.
• Communicated to Relevant Stakeholders: Stakeholders are actively informed about its existence, scope, and how to use it.
• Culturally Appropriate and Understandable: Designed to be accessible and clear to diverse users.
• Unbiased, Equitable, Predictable, and Transparent: Ensures fair treatment, consistent processes, and clear communication of outcomes.

3. Scope

This mechanism covers requests for information, and the raising and resolution of disputes and grievances related to SANNIDHYA DIAMONDS's operations, including human rights impacts, labor practices, environmental concerns, ethical conduct, health and safety, and supply chain practices.

4. How to Lodge a Complaint/Grievance

Stakeholders can access the mechanism through the following channels:

Information on how to access the mechanism will be publicly available on our company website, employee handbooks, and posted in prominent locations within our facilities.

5. Grievance Process — Three-Stage Resolution

The grievance process adheres to the following principles and steps:

5.1. Avoid Retaliation:

Processes are designed to explicitly avoid retaliation for individuals or groups filing complaints or engaging the grievance mechanism. Any reports of retaliation will be investigated immediately and disciplinary action taken.

5.2. Submission and Acknowledgment:

Complainants provide details of their grievance. All received complaints will be acknowledged within 3 business days (unless anonymity prevents it). Submissions are logged securely.

5.3. Investigation and Assessment:

• Impartiality:Investigations will be conducted by trained management and personnel at the appropriate level who understand the sensitivities of the situation, particularly in human rights contexts. They will be free from conflicts of interest.
• Fact-Finding:This involves gathering information, interviewing relevant parties, and consulting with external experts if necessary.
• Confidentiality:Information is handled with the utmost confidentiality.
• Consultation: For human rights-related grievances, appropriate consultation with Affected People or Groups will be undertaken in a culturally sensitive manner to understand the full scope of the impact and potential remedies.

5.4. Response and Resolution:

To ensure effective and timely resolution of grievances, the company follows a three-level grievance handling mechanism:

5.5. Implementation of Resolution and Remedy:

Corrective actions and remedies agreed upon will be promptly implemented. This mechanism serves to provide for, or support legitimate processes to enable, the remedy of any adverse human rights impacts that SANNIDHYA DIAMONDS has caused, contributed to, or been linked with.

5.6. Non-Waiver of External Mechanisms:

This mechanism or any resultant resolutions do not waive or preclude the individual’s or group’s right to have the same grievance addressed through other available external mechanisms, including administrative, judicial, or other non-judicial remedies.

5.7. Record Retention and Confidentiality:

Records of complaints and grievances, including responses and outcomes, are retained as per our Human Rights Policy and Management System in a manner that protects the confidentiality and integrity of those filing the grievance, including where anonymity has been requested. Access to these records is strictly controlled.

5.8. Review of Remedies and Corrective Actions:

The remedies provided through the mechanism are regularly reviewed to determine whether corrective actions can be implemented to prevent or mitigate similar grievances in the future. This feedback loop informs our human rights due diligence process.

5.9 Judicial and External Remedies

• This grievance mechanism does not restrict or replace the right of the complainant to seek remedy through judicial or external mechanisms.
• Complainants have the right to approach courts of law, regulatory authorities, or other legal bodies at any stage.
• The jurisdiction for legal matters shall be [Surat-Mumbai, India].
• The company will cooperate with any lawful investigation or legal proceedings.

6. Monitoring and Review

The performance of this complaints and grievance mechanism will be continually monitored and reviewed to determine if its outcomes are successful and if it remains rights-compatible and effective.

Where gaps are identified, prompt corrective actions must be implemented.

Document Control

OECD Due Diligence Guidance — Actions Taken