Privacy Policy

RJC Compliance Policy

KBS Creations/ KBS Diamonds is a member of Responsible Jewellery Council -RJC and committed for ethical business practices and compliance with Code of Practices in all its business activities.

The management of KBS Creations/ KBS Diamonds shall implement responsible ethical, social and environmental practices throughout the diamond supply chain, from mine to retail. We are a responsible entity of diamond supply chain believe in consumer confidence in our trade and request our business partners to follow same. As a part of best endeavors and responsible business entity, we anticipate co-operation of our business partners in adopting the standard and ensuring that the entire diamond supply chain is compliant with respect to business, social and environmental responsibilities. KBS Creations being RJC member with Jewellery manufacturing activity shall comply with RJC Code of Practice and Chain of Custody requirements. KBS diamonds being diamond trading company is complying with RJC Code of Practice.

We strongly encourage all our business partners to follow and implement the various requirements of the RJC code of practice and other prevailing trade standards.

More information about the Compliance Program is available on http://www.responsiblejewellery.com.

Policy on Corporate social Responsibility

Social responsibility allows the company's business interests to be reconciled with the legitimate interests of the different stakeholders that may be affected, and also assumes the impact of the company's activities on the community in general and the environment.

KBS Creations/ KBS Diamonds maintains a high standards and ethical value when it comes to business. We only deal to those who abide the law and with a high ethical reputation in this industry. As a member of Responsible JewelleryCouncil (RJC), we follow the practical guidance on performing due diligence pertaining to responsible supply chain management of diamond when sourcing from conflict-affected and high risk areas.

While we run our business based on the expectations of our diverse stakeholders, we also understand the importance of contributing to making the world a better place. At KBS Creations/ KBS Diamonds, we strongly believe in the concept wherein the company contributes to building economic, social and environmental imperatives.

Corporate Social Responsibility (CSR) aims to contribute to societal goals of a philanthropic, activist or charitable nature or by engaging in or support volunteering or ethically oriented practices. Our CSR Policy aims to the betterment of a sustainable society and this commitment is ingrained in our core values. We aim to demonstrate these through our actions governed by the CSR policy. This policy applies to our Company and all its activities and may also refer to our suppliers and partners.

Policy on Business Ethics and Transparency

We will conduct our operations in an open, honest and ethical manner.
We will ensure that all our operations are legitimate.
We undertake to keep every partnership and collaboration open and transparent.
We recognize the importance of protecting all our human, financial, physical, informational, social, environmental and reputational assets
We will advise our partners, contractors and suppliers of our CSR Policy and will work with them to achieve consistency with the policy

Governance

KBS Creations/ KBS Diamonds will undertake its CSR activities as approved by theCSR Committee, through a registered trust or society. The Company will assist theCSR Committee to identify the areas of CSR activities, programs and execution of initiatives as per the guidelines defined. The surplus funds if any arising out of theCSR activities will not form part of the business profit of the Company. The surplus funds will be used in the development of CSR projects in the following year. It will be mandatory for (KBS Creations/ KBS Diamonds) to disclose its CSR Policy, programs/projects undertaken, and the expenditure made towards CSR activity. Following activities shall be carried out in 2024;

Donation to Hospitals
Financial support for social and cultural activities.

Whistle-Blower Policy

KBS Creations/ KBS Diamonds has a set policy and Procedure document and firmly believes that it should be implemented in a true spirit with the involvement of all stake holders. Further, the company shall always involves all stake holder in the process of continuous improvement and welcome reporting of any incident or observation of breach of policy and procedure from any third party of stake holder. At the same time company shall always believe that any person who reports the breach incident or observed any violation of policy should be provided adequate immunity against any adverse impact on his job or any threat to his/her life or any form of harassment and torture.

The company shall always maintain the confidentiality of the whistle blower and shall not disclose the identity of the whistle blower without written consent from the whistle blower. The company shall always ensure that the person who has reported an incident of violation of policy and procedure shall not be penalized, harassed, tortured, or threatened by any individual.

The business policies of the company assure that all employees or third parties who come forward in good faith to report issues will be treated fairly and respectfully. While all efforts will be taken to protect the anonymity of employees as far as practicable, any form of retaliation against such individuals — assuming they have not been involved in the violation — will not be tolerated.

Company encourages employees or any third party to voice concerns promptly, if they have a genuine reason to believe that a policy, company operation or practice is or will likely be in violation of any law, regulation or internal company rule or policy, including this. In case of any incident with the Whistle-Blower he/she can report to entity head and external lawyer on following Email.
info@kbsdiamonds.com
info@kbscreations.com

Our employees, suppliers and other parties can report concerns and alleged violations of supply chain/sourcing/due diligence policy as follows:
Reports can be made anonymously and will be fully kept confidential, practicable and allowed by law.
We will not take any retaliatory action against our employees, suppliers, or other parties who make a report in good faith.
Our suppliers are encouraged to contact us if they wish to seek guidance on the application of this Policy.

Equality, Diversity & Inclusion Policy Statement

The Company recognizes that we are all unique, whether in terms of our background, personal characteristics, experience, skills or motivations, and the Company value its people for the differences they bring. These differences, this diversity is powerful.

The Company is committed to building a culture that values openness, fairness, and transparency with a workforce that is truly representative of communities in which it operates and where employees feel respected and able to achieve their potential. Fostering an inclusive culture helps everyone to benefit from a wider range of different perspectives, experiences, and skills. The Company believes that this creates a happier, more productive working environment for all.

This policy statement applies to anyone working for the Company. This includes employees, workers, contractors, and apprentices. The policy also relates to job applicants and is relevant to all stages of the employment relationship.

Ethical Business Policy Statement

The Company is committed to the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on theCompany's behalf is responsible for maintaining the Company's reputation and for conducting company business honestly and professionally.

This policy outlines the Company's position on prohibiting and preventing bribery, fraud, dishonesty, and illegal activity. The Senior Management take a zero-tolerance approach and are committed to enforcing effective systems throughout the company to prevent, monitor and eliminate any form of dishonesty and consider that such activities have a detrimental impact on business by undermining good governance and distorting free markets.

This policy applies to all employees of the Company, and business partners and external stakeholders. Every employee and associated person acting for, or on behalf of, the Company is responsible for maintaining the highest standards of business conduct. Any breach of this policy will be treated as grounds for serious disciplinary action, and / or constitute a contractual and criminal matter for the individual concerned. The Company is committed to transparency and believes that fair conduct helps to foster deep relationships of trust between the Company and our business partners and customers and as such a breach of this policy may also cause serious damage to the reputation and standing of the Company.

In compliance with statutory legislations and to embed commitment to integrity and honesty the Company will not sanction the following: -
Give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received, or to reward any business received.Accept any offer from a third party that is known or suspected to be made with the expectation that the Company will provide a business advantage for their business or anyone else.
Give or offer any payment to a Government official in any country to facilitate or speed up a routine or necessary procedure.

Tangible assets and intangible assets such as computer systems, bespoke processes, software, intellectual property, trade secrets and confidential information shall not be used for unauthorized or unlawful purposes or for personal gain.

Engage in any business practice which is unethical or amounts to unfair competition.

Unlawfully or inadvertently acquire, use or disclose to any third party any proprietary information or intellectual property of another party.

Engage in any activity or business practice whether unilaterally or in conjunction with any other party which is in breach of any applicable competition and/or anti-trust law in the relevant jurisdiction.

Unlawfully induce any party to breach a contract with any third party.

Make false statements about a competitor's products and/or services.

Engage in business with service providers, agents or representatives that do not support our ethical business objectives.

The success of the Company's measures depends on all employees, and those acting for the Company, playing their part in helping to detect and eradicate dishonesty. Therefore, all employees and others acting for, or on behalf of, theCompany are encouraged to report any suspected dishonesty in accordance with the procedures. The Company will support any individuals who make such a report, if it is made in good faith.

Modern Slavery Statement

This statement sets out the Company actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

As part of the diamond supply chain, we recognize that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic.

The senior management is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Policy Statement of Child Labour

No form of child labour should be employed at KBS Creations / KBS Diamonds.
The minimum age for employment that will be applicable is fifteen (as per ILO Convention No. 138).
For authorized adolescents (persons below 18 years of age but above 15 years), the entity management is responsible for providing working conditions, hours of work, and wages in compliance with applicable local laws as a minimum.
If a child is found working at KBS Creations / KBS Diamonds, either directly or through subcontractors, the responsibility of rehabilitation will be undertaken by the management.
The above policies will also be applicable to all business partners.

Policy Statement Kimberley Process

The policies relating to this section are part of the Business Policies adopted byKBS Creations/ KBS Diamonds are presented below for reference:

KBS Creations / KBS Diamonds is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and the World Diamond Council's (WDC) System of Warranties Declaration.
The definition of 'Conflict Gemstone Diamonds' as agreed by the Kimberley Process will be adopted, i.e.:
"Rough diamonds used by rebel movements or their allies to finance conflict aimed at undermining legitimate Governments, as described in relevant United Nations Security Council (UNSC) resolutions in so far as they remain in effect, or in other similar UNSC resolutions which 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 which may be adopted in the future."
Wherever applicable, the following affirmative statement as recommended by the World Diamond Council's System of Warranties should be printed on all invoices:
"The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict, 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."
Entering into transactions involving 'conflict diamonds' or not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, will be considered a violation of the Business Policies.
KBS Creations / KBS Diamonds ensures that concerned personnel within the organization are aware of government restrictions on the trade in Conflict Diamonds, the Kimberley Process Certification Scheme, and the World Diamond Council System of Warranties.

Policy Statement Money Laundering and Finance of terrorism

The policies relating to this section are part of the Business Policies adopted byKBS Creations/ KBS Diamonds is presented below for reference:

KBS Creations / KBS Diamonds recognizes the fact that entities in the gems and jewelry sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
Strict compliance is required at all times, with all applicable national and, where appropriate, international laws and regulations with respect to money laundering, terrorism financing, bribery, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing, and tax evasion.
KBS Creations / KBS Diamonds shall act in accordance with national laws and national / international accounting standards with respect to maintaining financial accounts of all business transactions and auditing of its financial accounts.
KBS Creations / KBS Diamonds ensures that concerned employees know and understand the relevant regulatory jurisdiction for national and international transactions, money laundering / financial offences-related legal, regulatory, and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious activity that appears to be questionable may also be considered a violation of the Business Policies, depending on the seriousness of the non-conformance.
KBS Creations / KBS Diamonds implements a "Know Your Customer" and "Know Your Supplier" procedure that establishes the identity of all organizations with which it deals, ensures a clear understanding of their business relationships, and maintains a reasonable ability to identify and react to transaction patterns appearing out of the ordinary or suspicious.

Disclosure of Treated Diamonds, Synthetics and Stimulants

Policy Statement

The policies relating to this section are part of the Business Principles adopted byKBS Creations/ KBS Diamonds. and are presented below for reference:

The following essential principles will be applicable in all the entity's transactions involving treated diamonds, synthetics and stimulants.

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 diamond.
Full disclosure to the purchaser will take place when offered for sale, such that:
- Full verbal disclosure will clearly take place during sale.
- Full written disclosure will be conspicuously included on each bill of sale or receipt in plain language and readily understandable to the purchaser. Written disclosure will normally be in English.
No misuse of terminology or misrepresentations or attempts to disguise the product will be made in the selling, advertising, and distribution of treated diamonds, synthetics, and stimulants.
The word 'diamond' will not be used in the case of names of firms, manufacturers, or trademarks in connection with treated diamonds, diamond stimulants, or synthetic diamonds.

"KBS Creations/ KBS Diamonds" has adopted the following definitions:

Diamond: A diamond is a natural mineral consisting essentially of pure carbon crystallized with a cubic structure in the isometric system. Its hardness in the Mohs scale is 10; its specific gravity is approximately 3.52; it has a refractive index of 2.42 and it can be found in many colours.

Synthetic: A synthetic is any object that has been either partially or wholly crystallized or re-crystallized due to artificial human intervention such that, with the exception of being non-natural, the product meets the requirements specified in the definition of the word 'diamond' above.

Treated Diamond: A treated diamond is any object or product that meets the requirements specified in the definition of the words 'diamond and synthetic' above, but has been subject to some from of treatment i.e. any process, enhancement changing, interfering with and/or contaminating the natural appearance or composition of a diamond other than historically accepted practices of cutting and polishing. This includes color and decolourisation treatment, fracture filling, laser and irradiation treatment and coating.

Stimulants: A diamond stimulant is any object or product used to imitate some or all of the properties associated with a diamond and includes any material, which does not meet the requirements specified in the definition of the word 'diamond' above.

This control system is applicable for The Millennial Diamond LLC, a trading company and Scope of the materials are laboratory grown diamonds withGold/Silver Jewellery. The company has implemented policy and procedure forthe segregation of Laboratory grown diamonds with other materials including natural diamonds. The entity deals in laboratory grown diamonds studdedJewellery. Following are the identified contaminations points where laboratory grown diamonds could contaminate with natural diamonds or natural diamond studded Jewellery;
Contamination during Transportation
Inventory
Dispatch and Sales documentation

The Millennial Diamond LLC has implemented robust segregation system within premises to ensure that at no level laboratory Grown Diamonds and contaminated with natural diamonds.

Policy Statement of Human Rights

The policies relating to this section are part of the Business Policies adopted byKBS Creations/ KBS Diamonds and are presented below for reference:

All employees in KBS Creations / KBS Diamonds will be treated with equality, respect, and dignity.
KBS Creations / KBS Diamonds believes in and respects fundamental human rights according to the United Nations Universal Declaration of Human Rights.
KBS Creations / KBS Diamonds 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.
KBS Creations / KBS Diamonds 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 Group.
Security personnel, if employed by KBS Creations / KBS Diamonds, are trained to respect the human rights and dignity of all people and to use the minimum force proportionate to the perceived threat.
Wherever any violation of human rights is observed, the company shall take mitigation action and, if needed, hire an external non-governmental organization for the implementation.
Human rights risk assessment shall be conducted annually, covering internal and external stakeholders.
The Group shall conduct human rights risk assessments and, upon any violation observed in internal or external stakeholders, develop and implement a risk mitigation plan according to the severity of the incident. The company may seek assistance from external NGOs or experts to develop and implement the mitigation plan and monitoring.
The Group shall provide support and consultation to external stakeholders upon written request by business partners.

Ethical business Practice and Supply chain compliance

The Policy promote the standards that we expect all of our suppliers to comply with when producing and supplying Diamonds to KBS Creations/ KBSDiamonds, no matter where they operate in the world. We hereby inform all our suppliers to provide first mine of origin for the material they supply to us.We request all our suppliers not to supply any material that is subject to restriction as per EU Reg. 833/2014.

The senior management of KBS Creations/ KBS Diamonds advocate this policy and we shall review as and when changes in the process or compliance requirement or any violation of sourcing policy or Changes in risk and due diligence criteria. We shall carry out review of this entire document at least annually.

We recognise that full compliance with these criteria may take time for some suppliers, and we are committed to working with our suppliers to implement improvement plans and help them achieve compliance.

KBS Creations/ KBS Diamonds is committed to working in partnership with its suppliers to help achieve compliance with this Policу.

All the suppliers should comply with national and international law and trader equirement like RJC with respect to Bribery and Corruption, Financial Offence,Labour Rights, Kimberley process and World Diamond Council - SoW, Product disclosure, Labour Rights, Working Condition, Child labour, Forced labour,Human rights, Discrimination, Fair wages and working hours, Environment compliance, Health and safety of the employees and visitor.

Policy - Supply Chain and Ethical Sourcing

At KBS Creations/ KBS Diamonds, we take Ethical business practice, social and environmental factors into consideration in making decisions on the procurement of Rough or polish diamonds.

This Policy shows company's commitment and its expectations for its product suppliers regarding actions to address Conflict Diamonds.

KBS Creations/ KBS Diamonds expects it's suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that diamonds supplied to us containing conflict free diamonds are not belongs toConflict-affected and high-risk areas - CAHRAS.

We being a responsible company, KBS Creations/ KBS Diamonds supports the goal of the Dodd-Frank Act of preventing armed groups in the conflict affected and high risk countries from benefitting from the sourcing of Conflict diamonds from that region.

KBS Creations/ KBS Diamonds is committed to working with its suppliers to educate them on these matters and concerning steps they can take to obtain increased transparency regarding the origin of diamonds mined or manufacture and sell to KBS Creations/ KBS Diamonds. KBS Creations/ KBSDiamonds reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy.

KBS Creations/ KBS Diamonds reserves the right to request additional documentation from its suppliers regarding the origin/source of diamonds sold to KBS Creations/ KBS Diamonds.

Suppliers who do not reasonably comply with this Policy shall be reviewed byKBS Creations/ KBS Diamonds 's for future business.

KBS Creations/ KBS Diamonds is committed to ensuring that our supply chain is free of any diamonds which was procured for the support or benefit of armed and anti-social conflict groups or involving serious abuses of human rights and non-compliant with OECD Guidelines.

KBS Creations/ KBS Diamonds clearly criticizes such activity and will reject any material which we believe was obtained involving serious human rights violations or which benefitted or supported armed rebels or terrorist groups through illegal finance or other activities.

The company shall carry out risk assessment for its supply chain and shall not enter into any business relationship or if may require then shall suspend/discontinue the engagement with any such supplier involved in dealing with Conflict-Affected and High-Risk areas, Any form of Human RightViolation; Torture, Cruel, In-Human and Degrading Treatment;Forced/Compulsory Labour; Child Labour; Abuses such as widespread SexualViolence; War Crimes; other serious violations of International HumanitarianLaw, Crime against Humanity; Genocide and/or To Bribe or To be Bribed. We strictly condemn and prohibit any Direct/Indirect support to public/private security forces which illegally Control, Tax or Extort money from Mining Sites,Transportation Routes and Upstream Sectors.

The Company shall carry out due diligence to assess risks related to procurement from the Conflict-affected and high-risk areas - CAHRAs and shall always source from compliant miners/traders.

We shall always set reasonable efforts to source Diamonds from miners and traders validated as being Conflict Free and require their direct and indirect suppliers to do the same;

We strive to work supportively with our customers and supply chain partners in implementing conflict free compliance programs for Diamond/JewellerySupply chain.

Policy - Due Diligence and Risk Assessment

The company shall always undertake to ensure that the extraction and trade of diamond/coloured gemstone/gold/silver/pgm support peace and development, not conflict.

KBS Creations/ KBS Diamonds remains committed to enhance its Supply ChainDue Diligence program through internal review and external assessments. We have zero tolerance policy for the supplier violating OECD due diligence guideline and we shall immediately stop commercial relationship if any of our business associates found non-compliant or High-Risk during our internal/external risk assessment.

All the suppliers are also requested to carry our risk assessment and due diligence for their suppliers and products they are sourcing.

Currently KBS Creations/ KBS Diamonds procure its diamonds/gold/silver/pgm/coloured gemstone from RJC CoP/Ethical business practice compliant miners/traders. However, we have established a strong due diligence process and we shall review it as an when we observed significant risk or upon receipt of any grievance or complaint but in normal course, we shall carry our due diligence process on annual basis.

Identify red-flags and Risk

The company has checked transaction methods and name and individuals of company on SDN list of USA treasury and EU sanction list. All the suppliers are found low in risk and in compliance with OECD requirement of CAHRA's.

Risk mitigation plan

The company shall always deal with legitimate companies.
Always complete due diligence and risk assessment before establishing commercial relationships.
Ensure that all transactions are carried out with sound business sense.
Immediately stop commercial relationships upon any violation observed and report to the concerned internal and external reporting authority.
Continuously monitor suspicious transactions and maintain red flag records.
Communicate and raise awareness with suppliers.

Supplier Risk Assessment /Due Diligence Report

We the senior management of KBS Creations/ KBS Diamonds and compliance officer has verified all our supplier with respect to following;

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
US OFAC Sanctions
EU Sanctions
Global Peace Index
Know Your Country
Transparency International (TI)

The Office of the United Nations High Commissioner for Human Rights(OHCHR)
https://www.responsiblemineralsinitiative.org/minerals-due-diligence/risk-management/conflict-affected-and-high-risk-areas/

Publication (Detailed report is with Compliance team and may produce to concerned parties upon request)

Compliance team of KBS Creations/ KBS Diamonds has completed the due diligence and Risk assessment of all its metals and Minerals supplier with respect to latest RJC guideline and we found all our supplier are complying with requirements did not find any risk pertaining to their business involvement in Conflict Affected and high risk Areas' (CAHR's).

RJC COP Annual Compliance - 2024: The company has carried our ethical business practice and carried out policy and procedure review with respect to its implementation. The company has complied with the latest RJC Code of Practice and all its requirement.
‍Ethical Standard/Commitment-- No practice or conduct observed during the assessment period that brings the diamond industry into disrepute. All businesses practices have adhered to national laws and applicable rules and regulation during the assessment period.We have conducted risk assessment and due diligence of all our suppliers and customers with respect to latest OECD requirements and RJC guideline and we found all our supplier are complying with requirements did not find any risk pertaining to their business involvement in Conflict Affected and high-riskAreas' (CAHR's).

Sr#	Description	Comments
1	Is the company dealing with any illegitimate customers/suppliers?	No
2	Any violation of CAHRA’s during last one year?	No
3	Dealing with any illegitimate business partners?	No
4	Any incident of Human right violation or financial offence observed?	No
5	Suppliers are complying with OECD requirements?	Yes
6	Any material sourced from Violated area?	No
7	Any unethical business practice observed in any business partners activity?	No
8	Over all Suppliers Risk assessed in assessment period?	Low