Section A: General Information about the Company:

GROUP PROFILE

A.JAFFE's legacy dates back to its founding in New York City in 1892. The brand's rich heritage spans the Jazz Age and Art Deco period, through two world wars, and into a new millennium. The historic American bridal brand is recognized for its iconic Signature Shank™ and Quilted Interior™ design features that provide superior balance and a luxurious fit with minimal twisting of the ring on the finger.

Section B: Financial compliance of the Group:

1.1 Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

• A.JAFFE recognizes that entities in the gems and jewelry sector must take on the responsibility of analyzing their potential vulnerabilities to money laundering and implementing specific measures to protect against criminal abuse.
• Strict compliance is ensured for all entities, and a compliance officer has been appointed at the entity level, reporting to the Group CFO on compliance status on an annual basis.
• Know Your Counterparty and other due diligence compliance measures are followed in line with OECD guidance.
• Ongoing monitoring is carried out in collaboration with all stakeholders.

Area of Concern & Remedial Measures

• Nil as on date.

1.2 Kimberley Process and System of Warranties

• A.JAFFE is fully committed to complying with all requirements specified in the Kimberley Process Certification Scheme of the World Diamond Council’s (WDC) System of Warranties Declaration.
• Day-to-day monitoring and compliance of SOW is done by an entity compliance officer.
• Group is committed towards conflict-free sourcing, and zero tolerance policy is followed at the group level

Area of Concern & Remedial Measures

• Nil as on date.

1.3 Anti Bribery and Facilitation Payment Policy:

• A.JAFFE shall ensure complete prohibition of Bribery and facilitation payment across the organization and in all the entities.
• The group has published compliance team contact details on the website to receive any grievance or complaints.

Area of Concern & Remedial Measures

• Nil as on date.

1.4 Ethical Sourcing of Loose Diamonds, Gold, Silver & PGM-Studded Jewelry Policy:

• Our company is concerned about the environmental and social impacts of irresponsible mining.
• The group has identified the risk of the supply chain concerning Conflict Affected High Risk Area.
• Group ensures all its supplies are screened for conflict-free supplies.
• 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

• The current concern is a 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 to obtain further supply chain information to ensure ethical and conflict-free sourcing in the metal business.

1.5 Social Compliance

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

Area of Concern & Remedial Measures

• No point has been reported in the social compliance of the group were remedial measures at group level is required.
• Entity-level remedial measures are taken based on internal and external audits conducted by reputed agencies,

1.6 Health and Safety

• A.JAFFE highly regards the health and safety of employees and is focused on continuously identifying and eliminating any adverse impact of our business processes that may be hazardous. To 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.
• 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, is to be monitored periodically through appropriate medical checks and reviewed using expert inputs for improvements.
• All workplaces are constructed to meet safety standards with local regulations as the minimum standards that will be applicable

Area of Concern & Remedial Measures

• Nil as of date, has had no accidents that have been reported in the last year
• The organization has not experienced any fires or any other incidents leading to dangerous circumstances.

1.7 Human Rights

• A.JAFFE is 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
• A.JAFFE 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.
• A.JAFFE ensures that none of its suppliers and stakeholders have engaged in any activity that can violate Human rights principles.
• We have carried out the Human Right Due Diligence of suppliers and other Stakeholders & based on risk assessment where necessary.

Area of Concern & Remedial Measures

• No area of concern or remedial measures has been raised in Human rights for any of our operating units.
• The company’s further upstream compliance concerning Human rights compliance for conflict-free sourcing is a new development, where the company is heading, and would require more focus on the same.

1.8 Environment Protection

• A.JAFFE is complying with all applicable environmental laws and regulations
• The impact of each of our operations on the environment is studied systematically and assessed for compliance with appropriately defined standards and reviewed periodically to mitigate or eliminate such impact.
• Disposal procedures for waste generated are followed in line with the applicable national and international regulations.
• Improvement is seen in employees’ environmental awareness and performance with the help of detailed policies and procedures, training, and recognition of excellence.

Area of Concern & Remedial Measures

• The emerging need for sustainable growth and responsible manufacturing is the area for improvements, and management has suggested a step-by-step approach to grow in this direction.

Approved By: Sam Sandberg

1.1 Legislation and Regulations

• A.JAFFE shall operate in compliance with relevant national and international legislations/regulations as applicable in the countries in which they operate.
• All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal A.JAFFE 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.
• The compliance team maintains the list of applicable legal and regulatory requirements, and the same is followed for compliance on a day-to-day basis. Necessary records of requirements and its compliance are maintained.

1.2 Money Laundering, Terrorism Financing, Other Financial Offences

• A.JAFFE recognizes that entities in the gems and jewellery 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.
• A.JAFFE shall act following national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations. Following acts and international guidelines is considered while establishing company level policies:
  • US Patriot Act
  • FATF 40 Recommendations and 8 special recommendations
• 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.
• Compliance officer caries out periodic review of AML/CFT compliances and submits his report to management on Quarterly basis.

1.3 Kimberley Process and System of Warranties

• A.JAFFE is dealing in polished diamonds Studded Jewellery and fully committed to complying with all the requirements specified in World Diamond Council’s (WDC) System of Warranties Declaration.
• We will not engage in business with the supply chain who deals in ‘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.

1.4 Anti-Bribery and Facilitation Payment Policy:

• The A.JAFFE shall ensure complete prohibition of Bribery and facilitation payment across organization and in all the entities.
• A.JAFFE will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.
• Entity shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.

1.5 Disclosure of Treated Diamonds, Synthetics and Stimulant

The following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and stimulant

• Full disclosure i.e. the complete and total release of all available information about a Diamond and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the diamond.
• We deal in real and natural diamonds only and any treatment of real and natural diamonds is disclose to customer prior to sales

1.6 Diamond & Gemstone Sourcing Policy as per OECD

Conflict Minerals Policy Statement (Diamond & Gem Stone)

A.JAFFE is committed to being a responsible corporate citizen and is opposed to human rights abuses. As part of that commitment, A.JAFFE seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility.

A.JAFFE shall strive to ensure that all its supply of diamonds is not originating from CAHRA’s and where practically possible origin of diamonds is known to us.

What Are "Conflict Diamonds"?

Blood Diamonds, also known as "Conflict Diamonds,"are stones that are produced in areas controlled by rebel forces that are opposed to internationally recognized governments. The rebels sell these diamonds, and the money is used to purchase arms or to fund their military actions.

Blood Diamonds are often produced through the forced labor of men, women and children. They are also stolen during shipment or seized by attacking the mining operations of legitimate producers. These attacks can be on the scale of a large military operation.

The stones are then smuggled into the international diamond trade and sold as legitimate gems. These diamonds are often the main source of funding for the rebels; however, arms merchants, smugglers, and dishonest diamond traders enable their actions. Enormous amounts of money are at stake, and bribes, threats, torture, and murder are modes of operation.

CAHRAS are.

A.JAFFE ensures that none of its supplies come from the aforesaid countries/regions. A.JAFFE shall communicate its sourcing policy to all its stakeholders and will ensure effective implementation of its policy amongst all its entities.

A.JAFFE 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

1.7 Gold & Platinum Group Of Metal Sourcing Policy (As per DRC)

Our Company is concerned about environment and social impacts of irresponsible mining.

We at A.JAFFE shall ensure that all our gold Jewellery suppliers are in compliance with gold souring guidelines (Dodd- Frank rules, DRC & other applicable legislation).

Further, we are committed to ensure that sourcing of gold and precious metal products and articles thereof, are under the highest Social, Human right and Environmental standard cautions of trade.

1.8 Supply Chain Management / Best Endeavours

The management of A.JAFFE is committed to take appropriate action to use best endeavours to ensure that the suppliers and contractors are committed for compliance to International Social Standards such as RJC.

1.9 Employment

• Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.
• The A.JAFFE shall not require Staff to work for more than the national limit of hours in a week on a regular basis.
• The A.JAFFE shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards.

1.10 Health and Safety

A.JAFFE recognizes the need to develop a sustainable, value creating business and is committed to the following:

• 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 workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable

1.11 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 A.JAFFE. Any such reported incidents will be viewed as a serious violation of this Business Principles.
• We shall at no time condone the use of corporal punishment or other forms of mental or physical coercion.
• We encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, A.JAFFE operation or practice is or will likely be in violation of any law, regulation or internal rule or policy, including this Business Principles.

1.12 Child Labour

• No form of child labour should be employed at any of the facilities of the A.JAFFE. 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 A.JAFFE. Management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
• As per our A.JAFFE, policy no child labour or Young Labour will be employed.
• A.JAFFE will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

1.13 Forced Labour

• The management of A.JAFFE 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 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 they said person has not offered himself voluntarily”

1.14 Human Rights

• All employees in the A.JAFFE facilities will be treated with equality, respect and dignity.
• A.JAFFE 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 A.JAFFE strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.

1.15 Environment Protection

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

• Compliance with all applicable environmental laws and regulations
• The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards and reviewed periodically to mitigate or eliminate such impact.
• Improvement of employee & supplier’s environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.

1.16 Product Security

A.JAFFE is committed to provide safety of product throughout its supply chain by following precaution as mentioned below:

• Each and every stage of product processing it is covered through blanket insurance
• SuitableSuitable safe guarding and storage is ensured at all stage with the help of safes
• We are taking at most care to ensure safety of visitors, Customers and interested parties, suitable arrangements such as CCTV, Multi level entry doors and other electronic intelligence.
• All the concern persons are trained on relevant safety and security procedures to be followed at all time.

1.17 Supply Chain Grievance

• A.JAFFE Grievance Procedures have been established and available for all employees to raise any issue/grievance for work culture, discipline, practices and supply chain concerns.
• If any Grievance from a customer and/or supply chain partner has been reported, relating to any actual, alleged or suspected breach of this Policy, this matter should be raised in accordance with Supply Chain Grievance Policy.
• The Relevant Worker responsible for the relationship with the Supplier must communicate to the Supplier about the receipt of the complaint and issue a summary report on the conclusion of the investigation.
• It is required that the Supplier’s staff have been informed of our supply chain grievance policy and it is available to them as well and can be used by them as a way of raising any concerns.
• With respect to breaches, by any party in the Supply Chain Policy Commitments and/or in the Supplier Code of Conduct, the breach will be reported to senior management and based on an investigation report, necessary actions shall if needed be taken.

Public Grievances against Social and/or Ethical compliance of A.JAFFE

• If you come across any instance of non-compliance or specific deviation from our ethical policy, please feel free to reach out to us.

f you are interested in obtaining a copy of our sourcing annual compliance report, based on OECD guidelines. Please send an email request to the below mentioned email address

Sr No.	Mode	Details
(I)	By Email	Name : Mr. Sam Sandberg ssandberg@ajaffe.com

OECD STEP 5 ANNUAL REPORTING
Company Name & Address:	A.JAFFE 50 West 47th Street, Suite 1901, New York, NY 10036
Date:	25 July, 2021
Reporting Period:	January to December 2020
OECD DUE DILIGENCE GUIDANCE	ACTION TAKEN
Step. 1. Establishing Strong Company Management Systems
1.A Adopt and clearly communicate to suppliers and the public company policy for the supply chain of mineral originated from conflict affected and high risk areas.	A.JAFFE's legacy dates back to its founding in New York City in 1892. The brand's rich heritage spans across the Jazz Age and Art Deco period, through two world wars and into a new millennium. The historic American bridal brand is recognized for its iconic Signature Shank and Quilted Interior , design features that provide superior balance, a luxurious fit, and minimize twisting of the ring on the finger
1. B Structure internal management system to support supply chain due diligence	A. JAFFE’s has established strong internal risk assessment to ensure that all its supplies are conflict free and ethically sourced. Company has carried out countrywide risk assessment and supplier wise risk assessment in accordance with the OECD requirements
1.C. Establishing system of controls and transparence over the minerals supply chain.	Suppliers are requested to share the information, which is analyzed to identify potential risk of CAHRA”s if any.
1.D. Stringent company engagement with suppliers.	Regular communication and awareness are carried out with suppliers (upstream suppliers). Ongoing monitoring is carried and two way communications are carried out to strengthen the supply chain.
1.E. Establishing a company-level or industry wide grievance mechanism as an early warning risk-awareness system.	Grievance mechanism has been established and published on the web site of the company. Company level employee training and awareness is carried out on an annual basis on the ethical sourcing as per OECD five step framework and training by circulation is done on a periodic basis.
Step. 2. Identify And Assess The Risk In The Supply Chain
2. Identify and assess the risks in the supply chain and assess risk of adverse impact.	Company has established a strong ongoing monitoring system for each and every transaction and annual review of declaration and information exchanged are carried out. Ongoing due diligence for KYC and other supply chain information is carried out.
Step. 3. Identify And Assess The Risk In The Supply Chain
3.1. Report findings of the supply chain risk assessment to the designated senior management of the company.	Compliance officer shall review all the transactions and where queries are raised or red flags raised.
3.2. Device and adopt risk management plan.	Compliance officer shall seek the additional information and after its review further decision of raising CARA shall be issued.
3.3. Implement the risk management plan and monitor the performance of the risk mitigation efforts.	Compliance officers shall monitor the effectiveness Mitigation actions taken and revised status of the associate risk if any.
3.4. Internal Training.	Regular training is carried out among all the affected employees.
3.5. Communication.	Period communication is sent across the supply chain for increasing awareness about ethical sourcing as per OECD regulations.
Step. 4. Optional Information On Step 4
4.1. RJC COP Audit done on & Done By.	Audit is scheduled by RJC approved auditor during
4.2. Grievance and recommendation.	Nothing reportable. We have provided public accesses for reporting grievances, through our website and the stakeholders are been communicated.