SUPPLY CHAIN POLICY

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

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

1. a) Respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;

2. b) Do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;

3. c) Support transparency of government payments and rights- compatible security forces in the extractives industry;

4. d) Do not provide direct or indirect support to illegal armed groups;

5. e) Enable stakeholders to voice concerns about the jewelry supply chain;

6. 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 commit to using our influence to prevent abuse by others.

4. Regarding serious abuse associated with the extraction, transport or trade of colored gemstones: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

a) Torture, cruel inhumane and degrading treatment;

b) Forced or compulsory labour;

c) The worst forms of child labour;

d) Human rights violations and abuse;

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 abuse as stated in paragraph 3 or we find they are sourcing from, or linked to, any party committing abuse.

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 colored gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

a) Control mine sites, control transportation routes, and control points where colored gemstones are traded to upstream actors in the supply chain;

b) Tax or extort money, or minerals at mine sites, along transportation routes or at points where colored gemstones are traded, or come 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 they 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 abuse stated in paragraph 3, or that act illegally as stated in paragraph 5.

9. Regarding bribery and fraudulent misrepresentation of the origins of colored gemstones:

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes. We will not conceal or disguise the origin of colored gemstones, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of colored gemstones.

10. Regarding money laundering:

We will support and contribute to efforts to eliminate money laundering, upon identifying a reasonable risk resulting from or connected to the extraction, trade, handling, transport or export of colored gemstones.