History, Values & Commitments

D'OR JOIERS, S.A. is a member of the Responsible Jewellery Council (RJC) and is committed to ethical business practices and compliance with the Code of Practices (CoP) in all its commercial activities.

The management of D'OR JOIERS, S.A. will implement responsible ethical, social and environmental practices throughout the diamond supply chain, from mine to retail. As an entity responsible for the diamond supply chain, we believe in consumer confidence in our trade and request the same from our business partners.

As part of our best efforts and as a responsible business entity, we expect the cooperation of our business partners in adopting the standard and ensuring that the entire diamond supply chain complies with business, social and environmental responsibilities.

We strongly recommend all our business partners to follow and implement the various requirements of the RJC Code of Practices and other applicable commercial standards.

Further information about the Compliance Program is available at:
http://www.responsiblejewellery.com

On behalf of D'OR JOIERS, S.A.
Date: 09/12/2024

1- Ensuring that all business activities are carried out in an honest, ethical, professional and responsible manner is fundamental to the core philosophy of our company.

2- All entities of D'OR JOIERS S.A. are committed to combating dishonesty and fraud in all business transactions in order to maintain and enhance consumer trust and the reputation of the diamond industry.

3- The entities of D'OR JOIERS S.A. will strive to obtain a similar commitment from their Partners.

4- The Company is committed to maintaining the highest standards of financial integrity for the benefit of all our stakeholders.

5- All financial records and reports derived from those records must be maintained and presented in accordance with the applicable laws of each jurisdiction.

6- Compliance with generally accepted accounting principles in the country where the entity is incorporated, as well as with the entity's internal control system, is required at all times.

7- It is the responsibility of D'OR JOIERS S.A. to pursue the enhancement of its corporate value through sound business practices. Our business activities have a direct and indirect impact on the societies in which we operate and, therefore, good business practices require that commercial decisions duly consider the interests of stakeholders, including shareholders, customers, employees, suppliers, business partners and local communities.
All employees of all our entities must strive to conduct D'OR JOIERS S.A.'s business in accordance with these principles.

8- When making business decisions, employees must act in an informed manner, in good faith and with the honest belief that the action taken is in the best interest of the Company.

9- D'OR JOIERS S.A. has implemented programs that monitor the effectiveness of these commitments and therefore support all workers in this effort.

10- All employees and collaborators of D'OR JOIERS S.A. shall operate in compliance with the relevant national and international laws and regulations applicable in the countries in which they operate.

11- All personnel are expected and required to comply with all applicable laws and regulations, as well as with all internal standards and policies of the entity related to their business activities. It is also the responsibility of personnel to know and understand the legal, regulatory and internal requirements that apply to their roles.

12- In order to maintain and enhance customer trust and the reputation of the diamond and jewellery industry, the Company is fully committed to ensuring that all business processes and transactions are carried out in a professional, ethical, environmentally responsible and socially responsible manner.

13- D'OR JOIERS S.A. has defined and adopted a set of Business Principles and a Code of Conduct that establish the basic standards to be observed by all directors, employees, collaborators and third parties.

14- D'OR JOIERS S.A. has also defined and adopted policies regarding Laws and Regulations and Conducting Business in an Ethical, Fair and Responsible Manner.

1- D'OR JOIERS S.A. and its collaborators are committed to prohibiting bribery and facilitation payments in all business practices and transactions carried out by them or by business partners acting on their behalf. They shall neither offer, accept nor approve payments, gifts in kind, hospitality, expenses or promises of such that could compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with any person, or to direct business to any person; or to influence the course of any business or governmental decision-making process.

2- D'OR JOIERS S.A. and its collaborators consider the risk of bribery and facilitation payments as it applies to their organisation (including agents) in order to identify areas of higher risk. Based on this understanding, D'OR JOIERS S.A. has developed appropriate methods to monitor the conduct of employees and agents and to eliminate bribery.

3- The management of D'OR JOIERS S.A. facilitates the reporting of incidents of attempted bribery, facilitation payments or inappropriate gifts within its organisation and shall apply appropriate sanctions for bribery and attempted bribery in all its forms.

4- No employee shall suffer demotion, penalty or other adverse consequences for raising a concern or for refusing to pay a bribe or facilitation payment, even if such refusal may result in a loss of business for the company.

5- Collaborators and entities where full elimination has not yet been achieved shall ensure appropriate controls are in place to monitor, supervise and fully account for all facilitation payments, with the ultimate objective of their elimination.

1- D'OR JOIERS S.A. acknowledges that entities within the gemstone and jewellery sector must take responsibility for assessing their potential vulnerabilities to money laundering and for implementing the specific measures required to protect against misuse by criminals.

2- Strict compliance is required at all times with all applicable national laws and regulations and, where applicable, international regulations relating to money laundering, terrorist financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, extortion, transfer pricing and tax evasion in all relevant jurisdictions.

3- All collaborators of D'OR JOIERS S.A. shall act in accordance with national laws regarding the auditing of their financial accounts.

4- It is the responsibility of personnel to know and understand the legal, regulatory and internal requirements relating to money laundering and relevant financial crimes as they apply to their roles. Ignoring or failing to report suspicious activities that appear questionable may also be considered a violation of the Business Principles, depending on the severity of the non-compliance.

1- D'OR JOIERS S.A. is fully committed to complying with all requirements specified in the Kimberley Process Certification Scheme and the World Diamond Council (WDC) System of Warranties Declaration.

2- The definition of conflict diamonds agreed by the Kimberley Process shall be adopted, namely rough diamonds used by rebel movements or their allies to finance conflicts aimed at undermining legitimate governments, as described in the relevant United Nations Security Council (UNSC) resolutions, to the extent that they remain in force, or in other similar UNSC resolutions that may be adopted in the future, and as understood and recognized in United Nations General Assembly (UNGA) Resolution 55/56, or in other similar UNGA resolutions that may be adopted in the future.

3- Where applicable, the following affirmative statement as recommended by the World Diamond Council System of Warranties shall be printed on all invoices:
"The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and in compliance with United Nations resolutions and corresponding national laws. The seller hereby guarantees that these diamonds are conflict-free and confirms adherence to the WDC SoW guidelines."

4- Entering into transactions involving conflict diamonds, or failing to follow the System of Warranties Declaration on invoices, whether knowingly or unknowingly, shall be considered a violation of the Business Principles. D'OR JOIERS S.A. will always adhere to responsible sourcing and ensure compliance with CAHRA and OECD requirements for conflict-affected and high-risk areas. D'OR JOIERS S.A. will establish appropriate policies and procedures for responsible sourcing, due diligence and supplier risk assessment.

It is the responsibility of the relevant personnel to know and understand the applicable standards and procedures related to conflict diamonds as they affect their roles.

1- D'OR JOIERS S.A. and its collaborating entities are committed to establishing and implementing product security measures within facilities and during transportation to protect against theft, damage or substitution of the product.

2- The safety and well-being of employees, visitors and other relevant business partners are prioritised when establishing product security measures.

3- All diamonds sold by collaborators to consumers must comply with applicable product health and safety standards.

1- The following essential principles shall apply to all transactions of the entity involving gold, diamonds, treated diamonds, synthetics and simulants or other gemstones.

▪ Full disclosure, meaning the complete and total disclosure of all available information about the gold, diamond or other gemstone and all material steps it has undergone prior to sale to the buyer, regardless of whether the information is specifically requested or not, and regardless of its impact on the value of the item being sold.

▪ Misuse of terminology, misrepresentation or any attempts to disguise the product in the sale, advertising and distribution of gold, diamonds, treated diamonds, synthetics and simulants or other gemstones shall not occur.

▪ D'OR JOIERS S.A. shall conduct risk assessments and identify points of contamination within its supply chain. To address the identified points of contamination, D'OR JOIERS S.A. shall establish specific policies, procedures and training programmes for each identified risk.

Full disclosure shall be maintained at all times, including verbal disclosure prior to and during the sale, as well as written disclosure on every sales invoice, receipt, laboratory report or other documentation related to the transaction, in the appropriate local language.

No terminology shall be used to obscure the fact that a diamond is synthetic or to mislead the consumer.

The word "diamond" shall not be used in relation to company names, manufacturers or trademarks in connection with treated diamonds, diamond simulants or synthetic diamonds.

2- D'OR JOIERS S.A. has adopted the following definitions:

▪ DIAMOND: The World Jewellery Confederation (CIBJO) and the Federal Trade Commission (FTC) define a diamond as a natural mineral consisting essentially of pure carbon crystallised in a cubic structure in the isometric system. A natural mineral is one that is formed completely by nature without human intervention.

▪ SYNTHETIC DIAMOND: A product that has been partially or fully crystallised or recrystallised due to artificial human intervention. This occurs through High Pressure High Temperature (HPHT) or Chemical Vapour Deposition (CVD). Synthetics require cutting and polishing. The appearance of an unpolished synthetic diamond differs from that of a natural diamond.

– Simulant: A material that is not a diamond but is used to imitate the appearance of a diamond.

Where applicable, the following affirmative statement, as recommended by the World Federation of Diamond Bourses, must be printed on all invoices:
"The diamonds herein invoiced are exclusively of natural origin and untreated, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds. Acceptance of the goods described in this document shall be made in accordance with WFDB guidelines."

– Treated diamond: a diamond that has been altered by any non-natural process through human intervention, such as fracture filling, laser drilling or irradiation.

– Treatment: any process that changes, interferes with, and/or contaminates the natural appearance or composition of a diamond, other than accepted practices of cutting and polishing. This includes colour treatment (and decolourisation), fracture filling, laser treatment, coating and irradiation. HPHT: CVD rough: laser sawn, unpolished.

The policies relating to this section form part of the Business Principles adopted by D'OR JOIERS S.A. and are presented below for reference:

"D'OR JOIERS S.A. shall ensure that all Provenance Claims made are fully valid and supported by available evidence."

▪ Origin: Geographic origin of the material, for example country, region, mine or corporate ownership of the mining facility(ies); and/or

▪ Source: Type of source, for example recycled, mined, artisanal mined or date of production; and/or

▪ Practices: Specific practices applied in the supply chain in relation to the Code of Practices (CoP), including, but not limited to, applicable standards for extraction, processing or manufacturing, conflict-free status or due diligence towards sources.

Provenance claims may also relate to origin, sources or practices that are specifically excluded from the supply chain, such as through a negative assurance.

D'OR JOIERS S.A. shall ensure that all claims and declarations (made to consumers or other businesses) regarding supply chain practices and the origin or source of Diamonds, Synthetics, Gold and/or Platinum, using descriptions and symbols, are valid.

D'OR JOIERS S.A. shall ensure that no attempt is made to mislead consumers through illustrations, descriptions, expressions, wording, figures, representations or symbols relating to provenance claims.

D'OR JOIERS S.A. shall ensure that all relevant employees are aware of provenance claims and the associated procedures.

The policies relating to this section form part of the Business Principles adopted by D'OR JOIERS S.A. and are presented below for reference:

D'OR JOIERS S.A. shall ensure compliance by any company/entity/facility that purchases, trades or manufactures rough or polished diamonds of 0.01 carats or less.

D'OR JOIERS S.A. shall carry out supply chain risk assessments and develop appropriate procedures for each identified point of contamination for any company/entity/facility that purchases, trades or manufactures rough or polished diamonds of 0.01 carats or less.

D'OR JOIERS S.A. shall conduct periodic internal audits and review its policies and procedures to address evolving risks and ensure compliance with the on-site verification protocol.

D'OR JOIERS S.A. shall ensure that all contractors involved in the purchase, trading or manufacture of rough or polished diamonds of 0.01 carats or less participate in the on-site verification protocol and are identified as significant contractors on the BPP Extranet.

In addition, D'OR JOIERS S.A. shall ensure an annual internal audit regarding compliance with the on-site verification protocol.

D'OR JOIERS S.A. shall ensure that contractors return manufactured diamonds in tamper-resistant packaging.

D'OR JOIERS S.A. shall ensure that all relevant employees are aware of the on-site verification protocol and its procedures.

D'OR JOIERS S.A. shall ensure that contractors provide assurance that the polished diamonds returned correspond to the same rough diamonds supplied by D'OR JOIERS S.A. or its clients.

The management of D'OR JOIERS S.A. is committed to taking appropriate measures, including risk assessments and best efforts, to ensure compliance of Tier B entities with the Code of Good Practices.

The Company shall always source materials from legitimate sources and ensure compliance with the OECD guidelines for conflict-affected and high-risk areas (CAHRA).

1- Compliance with applicable laws, regulations and agreements relating to employment and labour, both at national level and, where applicable, international level, shall be required at all times.

2- D'OR JOIERS S.A. shall ensure strict compliance with working hours limits established by the applicable legislation in force, ensuring that these limits are not exceeded under any circumstances. In cases where overtime is required, the annual limits permitted by applicable regulations shall always be respected, unless exceptions are provided for by law.

3- D'OR JOIERS S.A. shall ensure that wages and benefits comply with the applicable legal framework and shall in no case be lower than the minimum salaries established under the relevant sectoral collective agreement, ensuring fairness at all levels.

4- Compensation shall be paid to employees on a regular and periodic basis in accordance with the deadlines established by applicable regulations. Such payments shall be accompanied by the corresponding payslip, detailing earnings and applicable deductions, thereby ensuring transparent payroll processes.

5- It is the responsibility of employees to know and understand the legal, regulatory and internal requirements governing their employment, as well as the conditions applicable to their roles.

6- Where applicable, the existence, representation and lawful activities of employee representative bodies shall be recognised and respected. Likewise, it shall be ensured that employee representatives are able to carry out their functions and responsibilities within the framework of the applicable legislation.

7- In the event that termination of employment is necessary, the procedures established by the applicable national legislation and the relevant collective bargaining agreement shall be strictly followed, avoiding inappropriate dismissal practices at all times.

8- Information regarding employment policies and applicable labour practices shall be communicated clearly and transparently to all employees, ensuring full awareness and understanding.

The policies relating to this section form part of the Business Policies adopted by D'OR JOIERS S.A. and are presented below for reference:

1- D'OR JOIERS S.A. shall not interfere with employees' rights to associate and to engage in collective bargaining.

2- Discrimination may involve distinction, exclusion or preferential treatment.

3- D'OR JOIERS S.A. rejects any form of discrimination in recruitment, remuneration, promotion, training or any other aspect related to working conditions, based on age, gender, origin, sexual orientation, religion, disability or any other personal condition. Any reported incident related to these matters shall be considered a serious violation of company policies.

4- D'OR JOIERS S.A. shall ensure that employees suffering from illnesses or health conditions that may pose a risk to their lives are not treated differently and may continue their employment, provided they are physically and mentally able to perform their usual work responsibilities.

5- Individuals deemed fit to work shall be granted equal opportunities and shall not be discriminated against for reasons unrelated to their abilities or capacity to perform their work.

6- D'OR JOIERS S.A. shall under no circumstances permit the use of corporal punishment, threats of violence or any other form of coercion, whether mental or physical, nor any form of psychological, physical, moral or sexual harassment, including harassment based on gender, sexual orientation, gender identity or expression, that may create an intimidating or offensive environment for employees.

7- D'OR JOIERS S.A. encourages all personnel to raise concerns in a timely manner if they have legitimate reasons to believe that any company policy, operation or practice infringes or may infringe any law, regulation, standard or internal policy.

8- D'OR JOIERS S.A. guarantees that all personnel who report irregular conduct or violations in good faith will be treated fairly and respectfully. Although every effort will be made to safeguard the anonymity of whistleblowers where possible, necessary measures will be taken to prohibit any form of retaliation, including threats or attempts of retaliation, against those reporting, provided that their conduct is not involved in the violation.

1- No form of child labour shall be employed in any of D'OR JOIERS S.A.'s facilities.

2- Unless local laws stipulate a higher age, the applicable minimum age for employment shall be fifteen years (in accordance with ILO Convention No. 138).

3- For authorised adolescents (individuals under 18 years of age but over 15 years of age), the management of the entity is responsible for providing working conditions, working hours and wages in accordance with applicable local laws, at a minimum.

4- If a child is found working in any company facility, whether owned or subcontracted, responsibility for remediation shall be assumed by the management of the corresponding entity.

5- The above policies shall also apply to subcontracted labour or operations, and local management must ensure strict compliance with this policy.

1- The management of D'OR JOIERS S.A. is fully committed to ensuring that no form of forced or involuntary labour is practised in any of its facilities. Any reported incident related to forced labour shall be considered a serious violation of these Business Principles.

2- The following definitions shall apply:

– The Universal Declaration of Human Rights, which states that "No one shall be held in slavery or servitude."

– ILO Convention No. 29, which defines forced or compulsory labour as "all work or service which is exacted from any person under the threat of any penalty and for which the said person has not offered himself voluntarily."

1- All employees within D'OR JOIERS S.A. facilities shall be treated with equality, respect and dignity.

2- D'OR JOIERS S.A. recognises and respects fundamental human rights as set out in the United Nations Universal Declaration of Human Rights.

3- D'OR JOIERS S.A. shall not interfere with employees' right to observe principles or practices based on caste, race, national origin, gender, religion, disability, trade union affiliation or political affiliation.

4- D'OR JOIERS S.A. strictly rejects any form of coercive, threatening, abusive or exploitative sexual behaviour.

5- D'OR JOIERS S.A. shall not tolerate any reported incident related to harassment or abuse of any kind, including physical, sexual, racial, religious, psychological, verbal or any other form, whether direct or indirect, nor any form of intimidation or degrading treatment.

6- Security personnel, where employed by D'OR JOIERS S.A. or its collaborators, are trained to respect the human rights and dignity of all individuals and to use minimum force proportionate to the perceived threat.

D'OR JOIERS S.A. is committed to the development of the communities in which it operates, contributing to their social and economic well-being.

This policy applies to all activities of D'OR JOIERS S.A. and is effective as of April 2022. It covers Diamond/Gold/Silver/Platinum Group metals and coloured gemstones.

This policy reflects the commitment of D'OR JOIERS S.A. and its expectations of its product suppliers regarding actions taken to address the sourcing of conflict minerals and metals.

D'OR JOIERS S.A. expects its suppliers to have appropriate policies and due diligence measures in place to reasonably assure that the products and components supplied to us contain conflict-free minerals and metals.

As a responsible business entity, D'OR JOIERS S.A. supports the objective of the Dodd-Frank Act to prevent armed groups in conflict-affected areas from benefiting from the sourcing of conflict minerals and metals from those regions.

D'OR JOIERS S.A. is committed to working with its suppliers to raise awareness on these matters and on the steps they can take to achieve greater transparency regarding the origin of the minerals and metals contained in the products they manufacture and supply to D'OR JOIERS S.A.

D'OR JOIERS S.A. reserves the right to assess the extent to which a supplier has reasonably failed to comply with this policy.

D'OR JOIERS S.A. reserves the right to request additional documentation from its suppliers regarding the origin of conflict minerals and metals included in the products supplied to D'OR JOIERS S.A.

Suppliers who fail to reasonably comply with this policy will be reviewed by D'OR JOIERS S.A. in future business engagements.

D'OR JOIERS S.A. is committed to ensuring that its supply chain is free of metals and minerals, including diamonds, gold, silver, PGMs and coloured gemstones, that have been sourced in a manner that directly or indirectly supports or benefits armed and antisocial groups in conflict or involves serious human rights abuses, in violation of OECD Guidelines.

D'OR JOIERS S.A. clearly condemns such activities and will reject any materials believed to have been obtained through serious human rights violations or that have benefited or supported armed rebels or terrorist groups through illegal financing or other activities.

D'OR JOIERS S.A. shall carry out supply chain risk assessments and will not engage in any business relationships with, or if necessary will suspend or discontinue engagements with, suppliers that are involved in conflict-affected and high-risk areas (CAHRA). Any form of human rights abuse, including torture, cruel, inhuman or degrading treatment, forced or compulsory labour, child labour, widespread sexual violence, war crimes, other serious violations of international humanitarian law, crimes against humanity, genocide, and acts of bribery, whether offering or receiving, is strictly prohibited and considered unacceptable.

D'OR JOIERS S.A. condemns and strictly prohibits any direct or indirect support to public or private security forces that illegally control, tax or extort mining sites, transport routes and upstream/extractive sectors.

D'OR JOIERS S.A. shall conduct due diligence to assess risks related to sourcing from conflict-affected and high-risk areas (CAHRA) and shall only source from miners, refiners and traders that meet the required standards.

D'OR JOIERS S.A. shall make reasonable efforts to source conflict minerals from smelters and refiners validated as "conflict-free" and shall require its direct and indirect suppliers to do the same.

We strive to work collaboratively with our clients and supply chain partners in the implementation of conflict minerals compliance programmes.

D'OR JOIERS S.A. is committed to ensuring that the extraction and trade of diamonds support peace and development and do not contribute to conflict.

D'OR JOIERS S.A. maintains its commitment to improving its Supply Chain Due Diligence and Risk Assessment through internal reviews and external assessments. We apply a zero-tolerance policy toward suppliers that violate OECD due diligence guidelines and will immediately terminate any business relationship if any of our partners fail to meet the requirements or present a high risk during our internal or external risk evaluations.

Currently, D'OR JOIERS S.A. sources its precious metals from suppliers engaged in ethical business practices. However, we have established a robust due diligence process, which will be reviewed whenever significant risks are identified or upon receipt of any complaint or claim. Under normal circumstances, our due diligence process will be carried out on an annual basis.

Date: 09/12/2024

Our employees, suppliers and other parties may report concerns and alleged violations related to supply chain, sourcing, due diligence, ethical business practices or financial misconduct through the following channel:
https://www.dorjoiers.com/es

Reports may be submitted anonymously and will be handled with full confidentiality to the extent possible and as permitted by law. The compliance team will take appropriate action within 20 business days of receiving the complaint.

No retaliatory action will be taken against employees, suppliers or other parties who submit a report in good faith.

Suppliers are encouraged to contact https://www.dorjoiers.com/es if they wish to seek guidance on the implementation of this Policy.

The Management of D'OR JOIERS S.A., within the framework of its values, principles and sustainability, context, governance and social responsibility policies, and aware of the importance of aspects related to quality management, safety, occupational health and the environment — as well as their impact on process efficiency, results, corporate image, environmental performance, customer satisfaction and, above all, the well-being and physical and mental integrity of all individuals involved with the organisation — establishes and assumes the following commitments:

✓ To design, document, integrate and implement a management system in accordance with the requirements of internationally recognised and applicable sectoral standards.

✓ To plan and manage all required resources and technologies efficiently in order to implement policies and achieve the established objectives and targets.

✓ To ensure compliance with all applicable legal, technical, voluntary and customer requirements.

✓ To promote consultation and active participation of all personnel through established representation, communication, consultation and training mechanisms.

✓ To identify, control and continuously improve the organisation's strategic, operational and support processes, ensuring their safety, quality and sustainability, as well as that of the products and services provided.

✓ To implement tools that, from an integrated perspective, allow the identification, elimination, assessment, reduction and control of hazards and risks that may cause harm to health, assets, products or the environment.

✓ To provide safe and healthy working conditions at organisational, technical and environmental levels in order to prevent injury and deterioration of health.

✓ To protect the environment through the identification and evaluation of environmental aspects and impacts, prevention of pollution, contribution to climate change mitigation and adaptation, and the sustainable and efficient use of resources.

✓ To document and communicate this policy and all key elements of the management system to all relevant stakeholders.

✓ To establish, monitor and periodically evaluate the performance of the management system and the results achieved.

✓ To implement mechanisms that ensure effective change management and support the continuous improvement of the organisation, its systems, products and processes.