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Corporate Policies

Our Commitment

Diarough Group is committed to conducting its business in a responsible, ethical, transparent and sustainable manner across all operations in the natural diamond, gold and jewellery supply chain.

We affirm our commitment to:

We believe that respect for people, the environment and integrity of the diamond and jewellery supply chain is fundamental to our success and reputation.

Company Code of Conduct

Our Code of Conduct sets forth requirements with respect to the labour standards and working conditions. The principles embodied in our Code are designed to be consistent with core conventions of the International Labour Organization (ILO), the specialized agency of the United Nations focused on global labour standards, as well as codes set forth by key labour standards organizations

1.      Ethical Business Conduct

Diarough Group conducts business with honesty, integrity and fairness.

We strictly prohibit:

  • • Bribery, corruption, facilitation payments or kickbacks
  • • Conflicts of interest that are not declared
  • • Fraud, theft or misrepresentation
  • • Money laundering, terrorist financing or dealings with sanctioned parties

All employees, directors, agents, suppliers and business partners must comply with our Code of Conduct, Anti-Bribery & Anti-Corruption Policy and AML-CFT & KYC Policy.

2.      Human Rights & Labour Standards

Diarough Group respects internationally recognized human rights.

We do not tolerate:

  • • Child labour
  • • Forced, bonded or involuntary labour
  • • Human trafficking
  • • Discrimination, harassment or abuse
  • • Retaliation against whistle-blowers

We ensure:

  • • Safe and healthy working conditions
  • • Fair wages and lawful working hours
  • • Freedom of association and collective bargaining
  • • Equal opportunity regardless of gender, religion, caste, nationality or background

3.      Responsible Sourcing of Diamonds & Gold

Diarough Group sources natural diamonds and precious metals responsibly and ethically.

We ensure that:

  • • Diamonds are conflict-free in compliance with the Kimberley Process
  • • Gold and precious metals are sourced from legitimate, non-conflict, non-abusive sources
  • • All suppliers are subject to KYC, AML-CFT and supply chain due diligence
  • • High-risk suppliers or origins are reviewed, monitored or disengaged when required

We do not knowingly trade in:

  • • Conflict-affected or human-rights-abusive materials
  • • Smuggled, stolen or illegally mined diamonds or gold
  • • Sanctioned or prohibited sources

4.      Product Integrity and Disclosure

We are committed to full transparency and honesty in product information.

Diarough Group guarantees that:

  • • Natural diamonds are accurately represented and disclosed
  • • Lab-grown diamonds, treatments and simulants are clearly identified
  • • Undisclosed mixing of natural and lab-grown diamonds is prohibited
  • • All customers receive truthful, written and verbal product disclosures

We maintain internal diamond screening, segregation and documentation systems to protect consumer confidence and supply chain integrity.

5.      Environment, Health and Safety

We strive to minimize our environmental impact and protect our employees.

We commit to:

  • • Efficient use of energy, water and raw materials
  • • Responsible waste management and recycling
  • • Reduction of emissions and environmental pollution
  • • Safe handling of chemicals and hazardous substances
  • • Safe and healthy workplaces for all employees

6.      Grievance & Whistleblowing Mechanism

Anyone (employees, suppliers, customers or communities) may report concerns related to:

  • • Human rights abuses
  • • Ethical misconduct
  • • Corruption or bribery
  • • Product misrepresentation
  • • Unsafe working conditions
  • • Environmental harm

All complaints will be:

  • • Treated confidentially
  • • Investigated fairly
  • • Free from retaliation

Reports can be sent to compliance@diarough.com

7.      Governance & Continuous Improvement

The Board and senior management of DIAROUGH GROUP are responsible for implementing and monitoring this policy.

We will:

  • • Train employees on these commitments
  • • Monitor supplier compliance
  • • Conduct internal and external audits
  • • Continuously improve our ESG and supply chain systems

Human Rights Policy

Applies to:
All Diarough Group companies, employees, contractors and business partners

1. Our Commitment

DIAROUGH GROUP respects and supports internationally recognized human rights in line with:=

  • • UN Guiding Principles on Business and Human Rights
  • • International Labour Organization (ILO) Conventions
  • • Responsible Jewellery Council (RJC) Code of Practices (COP 2024)

We are committed to conducting our diamond, gold and jewellery operations in a way that respects the dignity, safety and rights of all people.

2. Prohibited Practices

We strictly prohibit:

  • • Child labour
  • • Forced, bonded or involuntary labour
  • • Human trafficking
  • • Physical, verbal or psychological abuse
  • • Discrimination based on gender, religion, caste, nationality orany other status

3. Fair Employment

We ensure

  • • Lawful working hours
  • • Appropriate renumeration
  • • Freedom of association
  • • Equal opportunity
  • • Safe and healthy workplaces

4. Supply Chain Responsibilities

We require our suppliers to respect human rights and comply with applicable laws. We assess risks in our diamond and gold supply chains and take action where risks are identified.=

5. Remedy & Grievance

Any person may raise a concern confidentially at:
compliance@diarough.com

6. Others

Human Rights Due Diligence report is available on request.

E-mail request can be sent at compliance@diarough.com

Responsible Sourcing Policy

Applies to: Natural diamonds, gold, precious metals and jewellery

1. Our Commitment

DIAROUGH GROUP sources diamonds and gold responsibly and ethically in line with:

  • • OECD Due Diligence Guidance
  • • Kimberley Process Certification Scheme (KPCS)
  • • RJC COP 2024 & COC 2024

2. Diamonds

We only trade in natural diamonds that:

  • • Are conflict-free
  • • Are legally mined, exported and imported
  • • Are not associated with human rights abuses

3. Gold & Precious Metals

We source gold only from:

  • • Legitimate refiners and suppliers
  • • Non-conflict, non-abusive sources

We conduct risk-based supplier due diligence.

4. High-Risk Areas

We screen suppliers and countries for:

  • • Conflict risk
  • • Sanctions
  • • Human rights violations

Where risks are identified, we take corrective action or disengage.

5. Grievance

Any grievances related to ‘Sourcing’ can also so be addressed to compliance@diarough.com

Product Disclosure & Natural Diamond Integrity Policy

1. Our Commitment

We guarantee full transparency and honesty in all diamond and jewellery products.

2. Natural Diamonds

All diamonds sold as natural are:

    • Not lab-grown
  • • Not treated unless disclosed
  • • Not synthetic or simulated

3. Screening & Controls

We maintain:

  • • Diamond segregation systems
  • • Screening and verification processes
  • • Staff training to prevent undisclosed mixing

4. Customer Trust

All customers receive accurate written and verbal disclosures.

Complaints and Grievance Procedure

OUR COMMITMENT

We encourage anyone to report concerns without fear.

POLICY

DIAROUGH GROUP seeks to maintain its reputation in the Diamond and Jewellery industry. The management of DIAROUGH GROUP is committed to maintaining its responsiveness to the needs and concerns of its employees, customers, suppliers and other stakeholders.

At DIAROUGH GROUP, we are committed to maintaining the highest standards of integrity, transparency, and accountability in all our dealings. We recognize that employees, customers, suppliers, and other stakeholders may, at times, have concerns or grievances.
This Complaints and Grievance Procedure is designed to ensure that all such matters are addressed promptly, fairly, and effectively.

SCOPE

This procedure applies to:

  • • Employees
  • • Customers
  • • Suppliers and vendors
  • • Contractors
  • • Business partners
  • • Community members and other stakeholders

 

PRINCIPLES

We are committed to ensuring that:

  • • Complaints are taken seriously and handled professionally.
  • • All parties are treated with respect and fairness.
  • • Complaints are resolved in a timely manner.
  • • Confidentiality is maintained throughout the process.
  • • Retaliation against complainants will not be tolerated.

RAISING A COMPLAINT

Where a complaint is about a particular engagement, product or staff, the complainant can address his issue to an appropriate member of that engagement team, verbally, by letter, email or fax. Where possible, complaints should be made in writing..

Please email details of any grievances or issues to compliance@diarough.com or write to us at:

Diarough N.V.

Attn: Compliance Department

Hoveniersstraat 30, Bus 211

2018 Antwerp

Belgium

INFORMATION TO INCLUDE

Please provide the following details to help us address your concern effectively:

  • • Full name and contact details
  • • Relationship to the company (employee, customer, supplier, etc.)
  • • Detailed description of the issue
  • • Any relevant dates, documents, or evidence
  • • Expected resolution or outcome

PROCEDURE AND TIMELINE

1. Acknowledgment

  • • You will receive an acknowledgment within 3 business days of submitting your complaint.

2. Investigation

  • • An impartial investigation will be initiated.
  • • We may contact you for additional information.
  • • This process is typically completed within 10-15 business days, depending on the complexity of the matter.

3. Resolution

  • • We will communicate the outcome and advise of any corrective action taken.
  • • If further time is needed, you will be informed of the updated timeline.

ESCALATION

If you are unsatisfied with the outcome or handling of your complaint, you may escalate the matter by writing to:

Mr. Richard Hume

Hoveniersstraat 30, Bus 211

2018 Antwerp

Belgium

CONFIDENTIALITY AND PROTECTION

All complaints will be handled confidentially to the extent possible. Whistleblowers and complainants are protected from retaliation under our company’s ethics policy.

CONTINUOUS IMPROVEMENT

We use complaints and feedback as a tool for continuous improvement in our operations and stakeholder relationships.
Lessons learned may lead to changes in our processes or policies.

CONTACT US

If you have any questions about this procedure or need assistance submitting a complaint, please contact our Compliance Team at compliance@diarough.com or +32 3 234.24.24

RETENTION OF RECORDS

All records relating to any complaints and grievance, Legal allegation, report of a retaliatory act or the investigation of any such report shall be retained for a period of five years.

Environmental Policy

Applies to: All DIAORUGH GROUP diamond, gold and jewellery operations

1. Our Commitment

DIAROUGH GROUP is committed to protectingthe environment and minimizing the environmental impact of our operations inaccordance with the RJC Code of Practices (COP 2024) and applicable environmental laws.

We recognize that responsible environmental management is essential to the sustainability of the diamond and jewellery industry.

2. Environmental Responsibility

We commit to:

  • • Efficient use of energy, water and raw materials
  • • Reducing waste, emissions and pollution
  • • Responsible management of chemicals and hazardous substances
  • • Safe disposal and recycling of waste
  • • Compliance with all environmental regulations

3. Climate & Emissions

We aim to:

  • • Monitor and reduce greenhouse gas emissions
  • • Improve energy efficiency
  • • Promote environmentally responsible practices across our operations

4. Employees & Suppliers

We train employees in environmentally responsible practices and encourage suppliers to meet similar environmental standards.

5. Continuous Improvement

We regularly review our environmental performance and take steps to improve our environmental footprint.

Anti-Bribery, Anti-Corruption & AML-CFT Policy

Applies to: All directors, employees, agents, suppliers and business partners

1. Our Commitment

DIAROUGH GROUP maintains a zero-tolerance approach to bribery, corruption, money laundering and terrorist financing in line with:

  • • RJC COP 2024
  • • International anti-corruption and financial crime laws

2. Prohibited Conduct

We strictly prohibit:

  • • Offering or receiving bribes or kickbacks
  • • Facilitation payments
  • • Fraud, theft or false accounting
  • • Doing business with sanctioned or criminal parties

3. AML & KYC Controls

We apply:

  • • Customer and supplier identification (KYC)
  • • Sanctions and watch-list screening
  • • Monitoring of unusual or suspicious transactions
  • • Reporting of suspicious activities

4. Gifts & Hospitality

Gifts or hospitality must be reasonable, transparent and never intended to influence business decisions.

5. Reporting Concerns

Suspected bribery, corruption or financial crime must be reported to:
compliance@diarough.com

Supplier Code of Conduct

Applies to: All diamond, gold, jewellery, service and logistics
suppliers

1. Our Expectation

DIAROUGH GROUP expects all suppliers to operate ethically, legally and responsibly.

2. Legal & Ethical Compliance

Suppliers must:

  • • Follow all applicable laws
  • • Not engage in bribery, corruption or money laundering
  • • Provide truthful and accurate business information

3. Human Rights

Suppliers must:

  • • Not use child or forced labour
  • • Provide safe working conditions
  • • Respect freedom of association
  • • Not discriminate or abuse workers
4. Responsible Sourcing

Suppliers must:

  • • Supply only conflict-free diamonds
  • • Provide legally sourced gold and precious metals
  • • Cooperate with DIAROUGH GROUP’s due-diligence checks

5. Product Integrity

Suppliers must:

  • • Disclose any lab-grown diamonds or treatments
  • • Not mix natural and lab-grown diamonds without disclosure

6. Environmental Responsibility

Suppliers must:

  • • Minimize pollution and waste
  • • Follow environmental laws

7. Right to Audit

DIAROUGH GROUP reserves the right to review or audit suppliers to ensure compliance.

Accreditations