Responsible Jewellery Council (RJC) policy 

Grandview Diamonds LLC is a member of the Responsible Jewellery Council (RJC). 

 The RJC is a standards-setting organization established to advance responsible ethical, human rights, social and environmental practices throughout the gold, silver, platinum group metals, diamond and colored gemstone jewelry supply chain. 

The RJC has developed a benchmark standard for the jewelry supply chain and credible mechanisms for verifying responsible business practices through third-party auditing. 

 As an RJC member we commit to operating our business in accordance with the RJC Code of Practices Standard. We commit to integrating ethical, human rights, social and environmental considerations into our day-to-day operations, business planning activities and decision-making processes. 

DeBeers Best Practice Principles (BPP) and the UN Sustainable Development Goals 

Grandview Diamonds LLC additionally commits to: 

• Operating our business in accordance with the DeBeers Group Best Practice Principles (BPP) Assurance Programme Requirements; and 
• Taking all reasonable steps to align our business practices with the United Nations Sustainable Development Goals. 

Human and Labor Rights

We are committed to respecting all human rights in our own operations and business relationships in accordance with the International Bill of Human Rights, Universal Declaration of Human Rights (UDHR), the UN Guiding Principles on Business and Human Rights (UNGP) and all relevant conventions of the International Labor Organization (ILO). Our human rights policy covers the following key commitments:

• All forms of violence and harassment in the workplace are prohibited, including but not limited to corporal punishment; harsh or degrading treatment; sexual or physical harassment; mental, physical, verbal or sexual abuse; retaliation; coercion; and intimidation. Both direct and indirect harassment in any form is not acceptable in workplace facilities. 
• To never engage in or knowingly support child labor (including the worst forms of child labor) as defined by International Labor Organization (ILO) conventions 138 and 182;
• To never engage in or knowingly support forced labor as defined by International Labor Organization (ILO) convention 29, including bonded labor, deceptive recruitment, human trafficking and indentured or involuntary prison labor;
•  To provide a safe and healthy working environment for employees and on-site contractors; 
•  To prohibit all forms of discrimination, including but not limited to discrimination based on race, color, ethnicity, caste, national origin, religion, disability or genetic information, gender, sexual orientation, union membership, political affiliation, marital status, parental or pregnancy status, physical appearance, HIV status, age or any other personal characteristic unrelated to the inherent requirements of the work. 
• To implement employment practices that promote diversity, inclusion and equal opportunities. 
• To promote human rights in our dealings with business partners and other relevant stakeholders
• To take all reasonable steps to remedy negative human rights impacts identified in our organization and/or supply chain in accordance with the UNGP and OECD Due Diligence guidance¹ frameworks. 

1.OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. 

Bribery and Corruption

We prohibit bribery and corruption in all business practices and transactions carried out by us and by agents acting on our behalf. For the purpose of this policy, bribery is defined as giving, offering or receiving any undue advantage to or from:

• A public or government official; 
• A political candidate, party or official; or 
• Any private sector employees, directors or officers, or their agents or representatives. 

Anti-Money Laundering and Finance of Terrorism 

We commit to not engaging in or contributing to money laundering or the finance of terrorism. Grandview Klein Diamonds Group has implemented Anti-Money Laundering (AML) and Know Your Counterparty (KYC) procedures to: 

• Establish the identify of all counterparties; 
• Verify that counterparties and, if applicable, beneficial owners are not named on relevant government lists for individuals or organizations implicated in money laundering, fraud or involvement with prohibited organizations and/or those financing conflict; 
• Maintain an understanding of the nature and legitimacy of the businesses operated by counterparties and; 
• Monitor transactions for unusual or suspicious activity. 

Environmental Management 

We commit to reducing and managing the environmental impacts of our business operations through the implementation of an Environmental Management System (EMS). This includes: 

• The responsible management of all wastes and emissions to air, water and land. 
• Establishing energy and water efficiency measures. 
• Seeking to ensure the responsible and efficient use of other natural resources, where applicable. 

Product Disclosure 

We will not knowingly make any untruthful, misleading or deceptive representation, or make any material omission in the selling, advertising or marketing of jewelry products and materials. We further commit to disclosing information on the physical characteristics of jewelry products and materials in accordance with the Responsible Jewellery Council (RJC) Code of Practices Standard. 

Conflict Diamonds 

We will not knowingly buy or sell Conflict Diamonds² and require that all of our suppliers of diamonds comply with the requirements of the Kimberly Process Certification Scheme (KPCS) and World Diamond Council System of Warranties (SoW). 

2.Rough diamonds used by rebel movements or their allies to finance conflict aimed at undermining legitimate governments, as described by the UN Security Council (UNSC) and as recognized by the UN General Assembly 

Supply Chain Policy – Conflict-Affected and High-Risk Areas 

1. This policy confirms our commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws. 

2. As a member of the Responsible Jewellery Council (RJC), we commit to proving, through independent third-party verification, that we: 

• a. respect human rights according to the Universal Declaration of Human Rights and International Labor Organization Declaration on Fundamental Principles and Rights at Work; 
• b. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism; 
• c. support transparency of government payments and rights-compatible security forces in the extractives industry; 
• d. do not provide direct or indirect support to illegal armed groups; 
• e. enable stakeholders to voice concerns about the jewelry supply chain; and 
• f. 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. 

4. Regarding serious abuses associated with the extraction, transport or trade of gold, silver, platinum group metals, diamonds and colored gemstones: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of: 

• a. torture, cruel, inhuman and degrading treatment; 
• b. forced or compulsory labor;
•  c. the worst forms of child labor; 
• d. human rights violations and abuses; or 
• e. 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. Regarding direct or indirect support to non-state armed groups: We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gold, silver, platinum group metals, diamonds and colored gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally: 

• a. control mine sites, transportation routes, points where gold, silver, platinum group metals, diamonds and colored gemstones are traded and upstream actors in the supply chain; or 
• b. tax or extort money, or minerals at mine sites, along transportation routes or at points where gold, silver, platinum group metals, diamonds and colored gemstones 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 gold, silver, platinum group metals, diamonds and colored gemstones: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, silver, platinum groups metals, diamonds and colored gemstones, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold, silver, platinum groups metals, diamonds and colored gemstones. 

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 gold, silver, platinum group metals, diamonds and colored gemstones. 

Grievance procedure 

Grandview Klein Diamonds Group has established this procedure to hear any concerns or complaints from interested parties and stakeholders regarding its supply chain and business practices. 

 Concerns can be raised by interested parties via email using the following contact information: 

Name: Moshe Lenzky 

Email: grievance@GKDG.com

On receiving a complaint, we will aim to: 

• contact you as soon as possible to gather more information regarding your grievance, where applicable; 
• decide who is the appropriate person internally to handle the grievance, or help redirect you to another entity, such as a relevant company, industry body or other organization; 
• identify any actions we should take (if any), or monitor the situation; 
• advise you of any decisions or outcomes; and;
•  keep records on grievances received and the internal process followed to address such grievances, for at least five years. 

Grandview Klein Diamonds Group expects all of its global employees, suppliers and sub-contractors to take steps to ensure that this policy is adhered to, as applicable. 

This policy is endorsed by: 

Name: A.D. Klein 

Position: Chief Executive Officer 

Date: May 17, 2023