A.S. EXPORT

ETHICAL BUSINESS COMPLIANCE POLICY

BUSINESS PRINCIPLES DOCUMENT

2.1 Legislation and Regulations

a. A.S. EXPORT shall operate in compliance with relevant national and

international legislations / regulations as applicable in the countries in which

they operate.

b. All employees are expected and directed to comply with all applicable laws

and regulations as well as will have to follow the rules and regulation formed

by A.S. EXPORT regarding its business policies

c. Compliance team maintains the list of applicable legal and regulatory

requirements and same is followed for compliance on day to day basis.

Necessary records of requirements and its compliance is maintained.

2.2 Money Laundering, Terrorism Financing, Other Financial Offences

a. A.S. EXPORT 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.

b. 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, facilitation payments, corruption,

smuggling, embezzlement, fraud, racketeering, transfer pricing and tax

evasion.

c. A.S. EXPORT shall act in accordance with 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 policies of the A.S. EXPORT.

 Prevention of Money laundering Act 2002

 FATF 40 Recommendations and 8 special recommendations

d. 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

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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.

e. 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.

f. Compliance officer caries out periodic review of AML/CFT compliances and

submits his report to management on Quarterly basis.

2.3 Kimberley Process and System of Warranties

a. A.S. EXPORT is fully committed to complying with all the requirements

specified in the Kimberley Process Certification Scheme and World Diamond

Council’s (WDC) System of Warranties Declaration.

b. We will not engaged 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.

2.4 Anti-Bribery and Facilitation Payment Policy:

a. The A.S. EXPORT shall ensure complete prohibition of Bribery and facilitation

payment across organization and in all the entities.

b. A.S. EXPORT will not offer, accept or countenance any payment, gift in kind,

hospitality, expense or promises as such that may compromise promises of

fair competition.

c. Entity shall prohibit bribery and facilitation payment and shall comply with

various rules and regulations of the land.

2.5 Disclosure of Treated Diamonds, Synthetics and Simulant

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

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diamond.

 We deal in real and natural diamonds only and any treatment of real and

natural diamonds is disclosed to customer prior to sales

2.6 Metal Sourcing Policy:

Conflict Minerals Policy Statement (Diamond & Gem Stone)

A.S. EXPORT is committed to being a responsible corporate citizen and is

opposed to human rights abuses.  As part of that commitment, A.S.

EXPORT seeks to source products, components and materials from companies

that share our values around human rights, ethics and environmental

responsibility.

A.S. EXPORT 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 labour 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. This is why the

term "blood diamonds" is used.

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CAHRA’s are.

A.S. EXPORT shall ensure that none of its supplies are coming 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

2.7 Supply Chain Management / Best Endeavours

The management of A.S. EXPORT 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.

Annual communications are exchanged with all the supply chain to spread

awareness.

2.8 Employment

a. Compliance is required at all times, with applicable national and, where

appropriate, international laws / regulations with respect to employment and

labour.

b. The A.S. EXPORT shall not require Staff to work for more than the national

limit of hours in a week on a regular basis.

c. The A.S. EXPORT shall ensure that wages and benefits for a standard working

week shall meet at least national minimum standards and shall be sufficient to

meet the basic needs of Staff and provide some discretionary income.

2.9 Health and Safety

A.S. EXPORT 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.

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 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, will be

monitored periodically through appropriate medical checks, and reviewed

using expert inputs for improvements.

 All workplaces will be constructed to meet safety standards with local

regulations as the minimum standards that will be applicable

2.10 Non Discrimination, Disciplinary Practices

a. Discrimination can mean distinction, exclusion or preference.

b. 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.S. EXPORT and

any such reported incidents will be viewed as a serious violation of this

Business Principles.

c. We will ensure that employees who have certain life-threatening diseases or

illnesses are not treated differently from other employees, and will continue to

employ such personnel, as long as they are physically and mentally fit to

attend to their normal job responsibilities.

d. We shall at no time condone the use of corporal punishment or other forms of

mental or physical coercion.

e. We encourages all personnel to voice concerns promptly, if they have a

genuine reason to believe that a policy, A.S. EXPORT operation or practice is

or will likely be in violation of any law, regulation or internal A.S. EXPORT rule

or policy, including this Business Principles. A.S. EXPORT assures all

employees who come forward in good faith to report issues, that they will be

treated fairly and respectfully.

2.11 Child Labour

a. No form of child labour should be employed at any of the facilities of the A.S.

EXPORT Unless local laws stipulate a higher age, the minimum age for

employment that will be applicable is fifteen (As per ILO Convention No. 138).

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b. For authorized adolescents (persons below 18 years of age but above 15

years), the A.S. EXPORT management is responsible for providing working

conditions, hours of work and wages in compliance with applicable local laws

as a minimum.

c. As per our A.S. EXPORT policy no child labour or adolence child labour will be

employed.

d. A.S. EXPORT will implement suitable policy and procedures to verify the age

proof all new employees joining the organization.

2.12 Forced Labour

a. The management of A.S. EXPORT 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.

b. 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”

2.13 Human Rights

 All employees in the A.S. EXPORT’ facilities will be treated with equality,

respect and dignity.

 A.S. EXPORT 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.S. EXPORT strongly discourages any form of sexually coercive,

threatening, abusive or exploitative behavior.

 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 A.S. EXPORT.

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 HSE & Anti sexual harassment committees are formed and committee shall

review the compliance at regular intervals by holding review meetings.

2.14 Environment Protection

A.S. EXPORT 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.

 Disposal procedures for waste generated will be clearly defined and

practiced in line with standards that are set by law and best practices of

the industry.

 Improvement of employee environmental awareness and performance

through detailed policies and procedures, training, and recognition of

excellence.

2.15 Product Security

A.S. EXPORT 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

 Suitable 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.

Public Grievances against social & Ethical compliance of the A.S. EXPORT.

If you come across any instance of non-compliance or specific deviation from our ethical policy,

please feel free to reach us.

Further in case if you are interested to obtain the copy of our sourcing annual compliance report

based on OECD guidelines. Please send an email communication to below mentioned email

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ETHICAL BUSINESS COMPLIANCE POLICY

address.

Sr No.

Mode

Details

(i)

By hand

Contact: Mr. Ruben Parikh (Compliance Officer)

(iii

By Email

ruben@asexport.com