ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR

THE YEAR 2023-2024

Section A: General Information about the Company:

Our passion at A. S. EXPORT is to make life’s important moments, even more sparkling and precious.

We focus on craftsmanship and delivering full satisfaction to our customers.

Our vertically integrated business model begins with procurement of rough diamonds and extends to

manufacturing; distribution and after sales service of polish diamonds.

A. S. EXPORT operates across the continent with like - minded people in countries like the U.S.A.

with a team of highly trained artisans operating in state of the art infrastructure in the manufacture of

rough diamonds.

Section B: Financial compliance of the A. S. EXPORT:

2.1 Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

 recognizes the fact that entities in the gems and jewellery sector have to take on the onus of

analysing their potential vulnerabilities to money laundering and implement specific steps that are

required for protection against abuse by criminals.

 Strict compliance is ensured at all the entities and compliance officer has been appointed who in

turn reports to A. S. EXPORT Management on compliance status on annual basis.

 Know Your Counter Party and other compliance of Due Diligence is followed in line with OECD

guidance.

 Ongoing monitoring is carried out along with all stakeholders.

Area of concern & Remedial Measures

 Nil As on Date.

2.2 Kimberley Process and System of Warranties

 A. S. EXPORT is fully committed to complying with all the requirements specified in the

Kimberley Process Certification Scheme of World Diamond Council’s (WDC) System of

Warranties Declaration.

 Day to day monitoring and compliance of SOW is done by compliance officer.

 A. S. EXPORT is committed towards conflict free sourcing and zero tolerance policy is followed

at A. S. EXPORT level.

ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR

THE YEAR 2023-2024

Area of concern & Remedial Measures

 Nil As on Date.

2.3 Anti-Bribery and Facilitation Payment Policy:

 The A. S. EXPORT shall ensure complete prohibition Bribery and facilitation payment across

organization and in all the entities.

 A. S. EXPORT has published compliance team contact details on website to receive any grievance

or complaints.

Area of concern & Remedial Measures

 Nil As on Date.

2.4 Ethical Sourcing of Loose Diamonds Policy:

 Our company is concerned about the environment and social impacts of irresponsible mining.

 A. S. EXPORT has identified the risk of supply chain with respect to Conflict Affected High Risk

Area.

 A. S. EXPORT ensure 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

 Current concern is 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 for obtaining the further supply chain

information to ensure ethical and conflict free sourcing in metal business.

2.5 Social Compliance

 We ensure full compliance with all applicable national and, where appropriate, international laws /

regulations with respect to employment and labour codes in all our establishment.

 We respect all regulation for child labour, forced labour, non-discrimination, non-retaliation etc.

 All work man rights are respected and adhere to freedom of association and collective bargaining

regulations.

ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR

THE YEAR 2023-2024

Area of concern & Remedial Measures

 No point has been reported in the social compliance of the A. S. EXPORT where remedial measures

at A. S. EXPORT level is required.

 Entity level remedial measures are taken based on internal and external audits conducted by reputed

agencies.

2.6 Health and Safety

 We at A. S. EXPORT are concern about the health and safety of employees and are constantly

studding about any adverse impact of our business processes are 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.

 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 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 on date, as no accidents are reported in last one year.

 Organization has been blessed and we did not have any fire or any other incidents leading to

dangerous circumstances.

2.7 Human Rights

 A. S. EXPORT 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.

 The Company 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.

ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR

THE YEAR 2023-2024

 A. S. EXPORT ensures that none of its suppliers and stake holder have engaged in any activity

which can violate the Human Right Principles.

 We have carried out the Human Right Due Diligence of suppliers and other Stake holders & based

on risk assessment where necessary.

Area of concern & Remedial Measures

 No Area of concern & Remedial Measures has been raised in the Human right for any of our

operating units.

 Supplier’s further upstream compliance with respect to Human Right compliance for conflict free

sourcing is a new development, where company is heading and would require more focus on the

same.

2.8 Environment Protection

 A. S. EXPORT is Complying with all applicable environmental laws and regulations.

 Improvement is seen employee’s environmental awareness and performance with the help of

detailed policies and procedures, training, and recognition of excellence.

Area of concern & Remedial Measures

 Nil, mainly Sales office and no manufacturing activity.

ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR

THE YEAR 2023-2024

ANNUAL REPORTING TEMPLATE (RJC TOOL KIT VERSION 5.0)

Company Name:

A. S. EXPORT

Date:

17th January 2025

Reporting Period :

Year 2023-2024

Step 1: Establish strong company management systems

1.A. Adopt and clearly communicate to

suppliers and the public, a company policy for

the supply chain of minerals originating from

conflict- affected and high-risk areas

 We have published the policy at company

level for easy accesses to stakeholder.

 OECD and Best Practice Annual

communication has been sent to all the active

supplier.

 Awareness presentation on Ethical sourcing

based on OECD guideline has been

circulated.

 Detailed policy and procedure at entity level

has been established based on risk of

CAHRA’s is done.

1.B Structure internal management systems to

support supply chain due diligence.

 Additional responsibility has been assigned

to Compliance officer to look over the

compliance of Ethical souring policy.

 All key employees involved in souring and

procurement of diamonds have been trained

on our Ethical precious metal souring policy.

Refresher trainings are provided.

 List of Suppliers has been maintained along

with status of their social and ethical

compliance.

 On going monitoring of each supplies and

associated suppliers is carried out with the

help of tools such as digital media, web

search, review of supply documents,

declaration and market intelligence etc.

ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR

THE YEAR 2023-2024

1.C Establish a system of controls and

transparency over the minerals supply chain.

 Supplier upstream information collection

process started and to obtained CAHRA’s

information and Ethical sourcing

compliance at supplier level.

 Currently A. S. Export 80% & more supply

from low risk and balance 20% is from non-

regular suppliers.

1.D Strengthen company engagement

with suppliers.

 As mentioned above supplier questionnaire

has been circulated and we are in the process

of following up with them to obtained the

filed information from them.

 Further we are also obtaining the vital

information about suppliers from social

platforms and social compliance registration

such as BPP & RJC, Approved ASM

programs etc

 We are in the process of compiling filled

supplier questionnaire data , after analysis

we will be formulate supplier engagement

practices based on risk reported at each

supplier level (if any)

1.E Establish A Company-Level, Or

Industry Wide, Grievance Mechanism As

An Early Warning Risk-Awareness

System.

 We have established the grievance handling

policy and procedure at company level,

contact details of compliance head provided

in our Social and Ethical policy on our Web

site under Business Principle Section ( which

is publicly available)

Step 2: Identify And Assess Risk In The Supply Chain

Identify And Assess Risks In The Supply

Chain And Assess Risks Of Adverse Impacts.

 We have established the detailed policy and

procedure for identification of risk at entity

level.

ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR

THE YEAR 2023-2024

 Each entity has appointed and trained

compliance officer to oversee the financial

and ethical sourcing compliances.

 We have categorized supply chain in to 2

major segments that its Secondary supplier

and Open market suppliers.

 All suppliers are bifurcated in to this

category and open market supplies are

considered as potential risk for supplies from

CAHRA’s and thus step by step information

are gathered from this category of supplier as

mentioned in point 1.B & 1.C.

Step 3: Design And Implement A Strategy To Respond To Identified Risks (If

Applicable)

Report Findings Of The Supply Chain Risk

Assessment To The Designated Senior

Management Of The Company.

 Ongoing monitoring of each supplies is done

by compliance officer to confirm its free

from Conflict, were required Red Flags are

been raised for seeking additional

information and closed after receiving such

information to our satisfaction.

 Entity level compliance officer shall report

all un-answered flags to local management

and Group compliance officer.

 In worst situation were information is half or

not satisfactory management starts

engagement practice and discussion and

dialogue with suppliers is carried out to

ensure full information in further business.

Devise And Adopt A Risk

Management Plan.

 We have formulated the risk management

plans at entity level considering individual

ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR

THE YEAR 2023-2024

entities position in supply chain and position

of supplier in supply chain.

 Entity compliance officer carries out

monitoring of each and every business

transactions and were required Red Flags are

been raised and further steps are followed as

mention above.

 Brief of companies Risk Management

Practices has been mentioned in

communication of Business policy on our

website.

Implement The Risk Management Plan And

Monitor Performance Of Risk Mitigation

Efforts.

 Entity level and group level monitoring of

Red Flags and its effective closure is

monitored.

 Compliance officer provides period status

reports of OECD compliance to the

management.

Internal Training

 Organisation has provides period training to

all the concern employee involved in buying

and selling and compliance monitoring team.

Communications

 Business principle has been published on the

website covering all the COP wise policy

including Ethical diamond souring policy of

the company level.

 Over and above Annual communication on

Business policy and Awareness on various

best practices and expectation from business

partners is communicated

OPTIONAL INFORMATION ON Step 4:Carry Out Independent Third-Party Audit

RJC COP Audit

 Our office has finalized the RJC COP audit

on 20th and 21st January 2025. Once the audit

ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR

THE YEAR 2023-2024

is completed, the final report will be made

available to us. We will ensure transparency

and accountability by sharing the annual

compliance reports with our stakeholders

upon request. These reports are essential in

showcasing our adherence to industry

standards and best practices.

Grievances And Remediation

 No grievance of what so ever has been

reported till date.

Prepared By & Approved by : Mr. Ruben Parikh (Compliance Officer)

Date : 17th January 2025