Commitment to Business Ethics

DN Diamonds 2007 LTD commits itself to the highest standards of product quality and business integrity. The provisions as set forth in this Code of Conduct provide the minimum standards expected of DN Diamonds’ business partners, in compliance with Annex II of the OECD guidance.

‘Business Partner’ means any company, corporation or other entity that sells, or seeks to sell goods or services to DN Diamonds, including the Business Partner’s employees, suppliers, agents, distributors and other representatives including contractors.

Our Business Partners must live up to this Business Partners’ Code of Conduct as a condition of doing business with us.

Upon request, Business Partners will provide DN Diamonds with information to enable DN Diamonds to assess conformance with the code. We want to work with our Business Partners to improve conditions. DN Diamonds reserves the right to assess conformance to these requirements at any time. If a Business Partner refuses or is unable to correct the non-conformance to our satisfaction, we may terminate the relationship as a last resort.

The following paragraphs describe the responsibilities of Business Partners doing business with DN Diamonds. These highlight our expectations towards our Business Partners, over and above any other contractual agreements such as supply, customer, agent, contractor and distribution agreements and purchase orders. DN Diamonds reserves the right to amend this list of responsibilities.

Human Rights and Labour

Business Partners should recognize and be committed to upholding the human rights of workers, and to treat them with dignity and respect as understood by the international community.

DN Diamonds supports the Universal Declaration of Human Rights and aims to apply these principles within its spheres of influence and activities. Business Partners need to identify, assess and manage the human rights risks arising from their business operations.

DN Diamonds expects its business partners to support and respect the protection of internationally proclaimed human rights and to ensure that they are not complicit in human rights abuses.

Business Partners need to ensure the following standards are met:

1. No Forced Labour: Forced, bonded or indentured labour or involuntary labour is not to be used. All work will be voluntary, and workers should be free to leave work or terminate their employment upon reasonable notice as the local law requires. Workers must not be required to hand in any government-issued identification or work permits. Business Partners shall ensure that contracts for both direct and contract workers clearly convey the conditions of employment in a language understood by the worker.
2. No Child Labour: Child labour is strictly prohibited in any stage of manufacturing. The term “child” refers to any person employed under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform hazardous work and may be restricted from night work with consideration given to educational needs.
3. No Discrimination: There is to be no discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training. Business Partners will under no circumstance discriminate workers on the basis of medical test results except where required by law or regulation or prudent for workplace safety.
4. No Harsh or Inhumane Treatment: There is to be no harsh and inhumane treatment, or any forms of torture, cruel, inhuman and degrading treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment.
5. Minimum Wages: Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Any disciplinary wage deductions are to conform to local law. The basis on which workers are being paid is to be clearly conveyed to them in a timely manner.
6. Working Hours: A work week shall not exceed 56 hours, including overtime, and workers shall be allowed at least one day off every seven days except in emergency or unusual situations. Work weeks are never to exceed the maximum set by applicable law. Any overtime performed shall be voluntary and shall be compensated at the rate required by applicable law.
7. Freedom of Association: Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Business Partners are to respect the rights of workers to associate freely and to communicate openly with management regarding working conditions without fear of reprisal, intimidation or harassment. Workers’ rights to join labor unions, seek representation and/or join worker’s councils in accordance with local laws should be acknowledged.

Workplace Health and Safety

Business partners are expected to provide a safe and healthy working environment. Business Partners should recognize that the quality of products and services, consistency of production, and workers’ morale are enhanced by a safe and healthy work environment.

Following issues should be considered:

1. Product Safety: Business partners will communicate in a transparent manner on the products they supply, including raw materials, handling and disposal. Expertise should be used to benefit our customers, bringing them added value and high-quality products. Full disclosure should be given to the customer.
2. Occupational Health and Safety: Business partners should ensure uniformly high health protection, safety, environmental protection and quality standards (HSEQ) at their sites through the implementation of appropriate management systems and the elimination of any hazards where possible. Business partners are expected to protect their employees from any chemical, biological and physical hazards in the workplace as well as from risks associated with any infrastructures used by their employees. Business partners will provide appropriate controls, safe work procedures, preventative maintenance, and necessary technical protective measures to mitigate health and safety risks in the workplace. Business partners will provide employees with appropriate personal protective equipment. In case of an incident, priority must be placed on the security of people over the security of a product.
3. Process Safety: Business partners will have safety programs in place for managing and maintaining all their production processes in accordance with the applicable safety standards. Business partners will address product-related issues and their potential impact during all stages of the production process. For hazardous installations the business partner will conduct specific risk analyses and implement measures that prevent the occurrence of incidences such as chemical releases and/or explosions.
4. Emergency Evacuation: Business partners will identify and assess potential emergency situations in the workplace and minimize their impact by implementing emergency plans and response procedures.
5. Dormitory and Dining: Where applicable, business partners must provide workers with clean toilet facilities, access to clean drinking water and sanitary food preparation and storage facilities. Dormitories should be clean and safe, provided with adequate heat and ventilation systems.

Product Integrity and Disclosure

DN Diamonds is committed to deal only in diamonds that are natural and conflict-free. We will fully and accurately disclose the material characteristics of the products that we sell, and expect the same of our business partners.

We expect our Business Partners to adhere to:

Kimberley Process Certification Scheme: In July 2000, the global diamond industry made clear to the international community they will implement a zero-tolerance policy towards conflict diamonds. Dedicated to eradicate the trade in conflict diamonds, the industry worked closely with the UN, governments and NGOs to create the Kimberley Process Certification Scheme. In addition to the Kimberley Process, the System of Warranties was developed by the World Diamond Council (WDC) to extend the Kimberley Process assurance to polished diamonds and to provide means by which consumers can be assured their diamonds are from conflict free sources. We expect all our business partners to comply with the Kimberley Process Certification Scheme and System of Warranties.

Business Integrity

Business Partners are expected to conduct their business with integrity.
Ethical requirements include the following aspects:

1. No Corruption: Business Partners are expected not to practice or tolerate any form of bribery and/or corruption. Business Partners will not offer or accept bribes or other unlawful incentives to directors, officers, employees of DN Diamonds or third parties in exchange for business opportunities. The highest standards of integrity are to be expected in all business interactions. All forms of corruption are strictly prohibited.
2. Anti-Money Laundering and Tax Evasion: We are committed to anti-money laundering practices and will take steps to ensure our operations are not linked to illicit financial flows.
3. Disclosure and Privacy of Information: Means to effectively safeguard customer information regarding business activities, structure, financial situation, performance, and/or any other information deemed confidential shall be disclosed only in accordance with the guidelines specified within any agreed upon Non-Disclosure Agreement (NDA), between the Business Partner and DN Diamonds and within the guidelines of all applicable laws and regulations.
4. No Improper Advantage: Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted. No Business Partner, or its representatives or employees, shall offer to any DN Diamonds employee a kickback, favor, gratuity, entertainment or anything of value to obtain favorable treatment from DN Diamonds. DN Diamonds employees are similarly prohibited from soliciting such items. As long as a gift is not intended to obtain favorable treatment for the Business Partner and does not create the appearance of a bribe, kickback, payoff or irregular type of payment.
5. Fair Business, Advertising and Competition: Standards of fair business, advertising and competition are to be upheld. Business Partners of DN Diamonds shall not engage in unfair trade practices in violation of federal or state antitrust laws.
6. Direct or Indirect Support of Non-State Armed Groups: We will not tolerate any direct or indirect support to non-state armed groups, including but not limited to procuring minerals from, making payments to, or otherwise providing assistance to such groups or their affiliates.
7. Community Engagement: Community engagement is encouraged to help foster social and economic development.
8. Protection of Intellectual Property: Intellectual property rights are to be respected; transfer of technology and knowhow is to be done in a manner that protects intellectual property rights.

Protecting the Environment

DN Diamonds expects its business partners to have an effective environmental policy and to comply with existing legislation and regulations regarding the protection of the environment. Business Partners should wherever possible support a precautionary approach to environmental matters, undertake initiatives to promote greater environmental responsibility and encourage the diffusion of environmentally friendly technologies implementing sound life-cycle practices.

Following measurements should be taken:

1. Product Content Restrictions: Business Partners are to adhere to applicable laws and regulations regarding prohibition or restriction of specific substances including labeling laws and regulations for recycling and disposal.
2. Chemical and Hazardous Materials: Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal.
3. Wastewater and Solid Waste: Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled and treated as required prior to discharge or disposal.
4. Air Emissions: Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge.
5. Environmental Permits and Reporting: All required environmental permits and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.
6. Pollution Prevention and Resource Reduction: Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.

Management Systems

Partners must adopt or establish a management system whose scope is related to the content of this Code and proportional to a Business Partner’s environmental and social accountability profile. The management system shall be designed to ensure compliance with applicable laws and regulations; conformance with this Code; and identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement.

The following practices can be applied:

1. Company Commitment: Corporate social and environmental responsibility statements that affirm the Business Partner’s commitment to compliance and continual improvement.
2. Management Accountability and Responsibility: Business Partners should clearly identify a company representative responsible for ensuring implementation and periodic review of the status of the management systems.
3. Legal and Customer Requirements: Identification, monitoring and understanding of applicable laws, regulations and customer requirements.
4. Risk Assessment and Risk Management: Process to identify the environmental, health and safety and labor practice risks associated with Business Partner’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the identified risks.
5. Performance Objectives with Implementation Plan and Measures: Written standards, performance objectives, targets and implementation plans including a periodic assessment of the Business Partner’s performance against those objectives.
6. Training: Programs for training managers and workers to implement Business Partner’s policies, procedures and improvement objectives.
7. Communication: Process for communicating clear and accurate information about Business Partner’s performance, practices and expectations to workers, suppliers and customers.
8. Employee Feedback and Participation: Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.
9. Audits and Assessments: Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code, and customer contractual requirements related to social and environmental responsibility.
10. Corrective Action Process: Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
11. Documentation and Records: Creation of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

DN Diamonds' Commitment to its Business Partners

1. DN Diamonds 2007 LTD Commitment to its Business Partners:

   DN Diamonds' relationships with its Business Partners must be characterized by honesty and fairness. We will not make payments to any employees of Business Partners to attain lower prices or additional business. DN Diamonds shall not reveal a Business Partner’s pricing, technology or other confidential information without prior written permission.

   We will not make false or misleading remarks to others about Business Partners or their products or services. DN Diamonds shall hold our Business Partners to the same standards and expectations as to which we hold our own operations and employees.

2. Evaluation of Business Partners:

   DN Diamonds shall be entitled to request information from its Business Partners as to their compliance with the terms of this Code of Conduct. Where necessary, DN Diamonds may require a Business Partner to provide evidence of its compliance by way of independent third-party auditing. DN Diamonds shall be entitled to visit Business Partners’ production facilities and the facilities of their subcontractors and suppliers to establish whether the terms of Code of Conduct are being complied with.

   DN Diamonds reserves the right to terminate business relationships with any Business Partner who violates this Code of Conduct or whose suppliers or subcontractors violate this Code of Conduct.

ACKNOWLEDGEMENT OF THIS CODE OF CONDUCT

Company Name: ……………………………………………………………………………………

Contact Name: ………………………………………………………………………………………

Phone Number: …………………………………………………………………………………….

E-mail: …………………………………………………………………………………………

Does your Company adhere to any of the following voluntary initiatives?

• United Nations Global Compact     * yes    * no
• Responsible Jewelry Council     * yes    * no
• SA 8000     * yes    * no
• ISO 14 001     * yes    * no
• ISO 26 000     * yes    * no
• Best Practice Principles (BPP)     * yes    * no
• Others, please specify: ……………………………………………………

Does your company have a Code of Conduct of similar standards to which your operations adhere?    * yes    * no

The terms of the DN Diamonds Business Partners Code of Conduct are hereby accepted and agreed to on behalf of:

Company Name: ……………………………………………………………………………..

Name Contact Person: ……………………………………………………………………….

Signature and Date: ……………………………………………………………………

Human Rights Policy

DN DIAMONDS supports the "Universal Declaration of Human Rights", and aims to apply its principles, and is aligned with Annex II of the OECD guidelines and address risks associated with CAHRA's (Conflict-Affected High-Risk Areas).

The commitment of the company regarding human rights is to:

• Identify, assess and manage the human rights and labour risks arising from business operations.
• Follow the requirements of national law where this sets a tougher standard than the ILO (International Labour Organization).
• Treat employees with integrity and respect their human rights as employees.
• Provide healthy and safe working conditions.
• Pay fair wages and equal pay for equal work.
• Not employ forced, bonded or exploitative child labour.
• Ensure the avoidance of discrimination and harassment.
• Provide flexible working practices recognizing the need for employees to balance their working life with other interests and responsibilities.
• Offer employees a secure and confidential means of providing feedback to management without fear of reprisals in accordance with the Employee Grievance Policy & Procedure.
• Support employees’ right to pursue their labour rights, including (but not limited to) freedom of assembly, association and collective bargaining.
• Will adhere to collective bargaining agreements, where such agreements exist.
• Provide direction and training to enable employees to meet their obligation to conduct business with regard for human rights.
• Report publicly on performance against this policy.
• Encourage our contractors and partners to demonstrate the same level of commitment to human rights.
• Make available appropriate resources to implement this policy.
• Assure compliance with the policy through a process of education, review and audit.

DN DIAMONDS encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, entity operation or practice is or will likely be in violation of any law, regulation or internal entity rule or policy.

The entity assures all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully.

While all efforts will be taken to protect the anonymity of employees as far as possible, any form of retaliation against any such individuals, assuming they have not been involved in the violation, will not be tolerated.

Definitions as to this Policy

Human Rights

Human rights are rights inherent to all human beings, regardless of nationality, place of residence, sex, national or ethnic origin, colour, religion, language, or any other status. These rights are all interrelated, interdependent and indivisible.

Claims for human rights depend on three interlocking qualities. Human rights must be:

• Natural – inherent in human beings;
• Equal – the same for everyone; and
• Universal – applicable everywhere.

In other words, for rights to be human rights, all humans everywhere in the world must possess them equally and only because of their status as human beings.

The kinds of rights which are regarded as human rights include:

• Civil and political rights – such as the right to life and liberty, freedom of expression, and equality before the law; and
• Social, cultural and economic rights – such as the right to participate in culture, the right to food, the right to work, and the right to education.

Child Labour

Child labour is often defined as work that deprives children of their childhood, their potential and their dignity, and that is harmful to their social, physical and mental development. A young person is any worker over the minimum age for work and under the age of 18 years.

DN DIAMONDS is committed not to tolerate any form of child labour at its offices and any subcontracted labour or operations.

The local management should ensure strict adherence to this policy.

Forced Labour

Forced labour is any work or service exacted by governments, companies or individuals under the menace of penalty, and which a person has not offered voluntarily to do. It also refers to work or service that is demanded as a means of repayment of debt.

DN DIAMONDS is fully committed to ensure that forced or involuntary labour (including bonded, indentured or prison labour) is not practiced in any form at its offices. The management does not restrict the freedom of movement of employees. Any reported incident relating to forced labor will be considered as a serious violation to this policy.

Supply Chain Grievance Mechanism

At DN Diamonds 2007 Ltd., we are committed to responsible sourcing within our diamond supply chain. Our grievance mechanism provides a structured process for stakeholders to report concerns, particularly around issues in the supply chain involving diamonds from conflict-affected and high-risk areas. We encourage interested parties to reach out if they have any concerns or grievances.

Contact Information:
Email: nirtzo@gmail.com
Phone: +972-543977713

Our grievance approach aligns with industry standards to ensure concerns are addressed thoroughly and responsibly.

Grievance Handling Process

1. Receiving the Complaint:

   Upon receiving a report, we will aim to gather a complete and accurate description of the grievance. We will maintain confidentiality and determine how the complainant wishes the issue to be resolved.

2. Assessment of the Complaint:

   We will evaluate the eligibility of the complaint, determining if it falls within our supply chain’s scope. If the issue cannot be addressed internally (e.g., if it involves an external supplier), we may refer it to the appropriate entity.

3. Internal Review and Action:

   For grievances that can be addressed within our company, we will conduct a thorough review. This may include gathering information from relevant parties in our supply chain, identifying actions we can take, and monitoring the situation.

4. Resolution and Feedback:

   Once a decision is made, we will communicate the outcome to provide ongoing updates as necessary.

5. Record Keeping:

   We will maintain records of all grievances and resolutions for a minimum of five years to ensure transparency and accountability in our supply chain practices.

Supply Chain Policy

1. This policy confirms the DN DIAMONDS 2007 LTD. commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws and is aligned with Annex II of the OECD guidelines and address risks associated with CAHRA's (Conflict-Affected High-Risk Areas).
2. DN DIAMONDS 2007 LTD. is in the process of becoming a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:
   • Respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;
   • Do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
   • Do not provide direct or indirect support to illegal armed groups;
   • Enable stakeholders to voice concerns about the jewellery supply chain;
   • Are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.
3. We also commit to using our influence to prevent abuses by others. By choosing carefully with whom we work and partner, we do not contribute to any possible risks in the supply chain.
4. Regarding serious abuses associated with the extraction, transport or trade of minerals: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:
   • Torture, cruel, inhuman and degrading treatment;
   • Forced or compulsory labour;
   • Forms of child labour;
   • Human rights violations and abuses; or
   • War crimes, violations of international humanitarian law, crimes against humanity or genocide.
5. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.
6. We only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:
   • Control mine sites, transportation routes, points where diamonds are traded and upstream actors in the supply chain; or
   • Tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders.
7. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.
8. Regarding public or private security forces: We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally as described in paragraph 6.
9. Regarding bribery and fraudulent misrepresentation of the origin of minerals: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of minerals.
10. Regarding money laundering: We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of minerals.

Provenance Claim Policy Statement

The policies relating to this section are part of the Business Principles adopted by DN DIAMONDS 2007 LTD. and are presented below for reference:

1. The company shall ensure all its Provenance Claims made will be fully valid along with available evidence to support the Claim(s).
   • Origin – the geographical origin of the material, which can refer to the country, region, mine or corporate ownership of the product and/or
   • Source – Type of source, for example recycled, mined, artisanally-mined or date of production and/or
   • Practices – specific practices applied in the supply chain in the extraction and/or manufacture applied towards the source.

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

2. The company shall ensure that all claims and statements (made to consumers or other businesses) on practices in the supply chain and the origin or source of Diamonds through the use of both descriptions and symbols are valid.
3. The company shall ensure that there will be no attempt to mislead consumers through illustrations, descriptions, expressions, words, figures, depictions or symbols relating to the Provenance Claim(s).
4. The company shall ensure that all the relevant employees are aware about the provenance claim and its procedures.

Grievance Mechanism

The company has established this grievance mechanism where concerns can be raised about circumstances in the provenance claim and sourcing from conflict-affected areas. The compliance officer is responsible for implementing and reviewing this procedure. Provenance claim related concerns can be raised by interested parties via email to nirtzo@gmail.com.