DAI RJC POLICY STATEMENT

Updated: Nov 18, 2022

With pride, we at Dana Augustine Inc (DAI) continue to be a certified member of the Responsible Jewellery Council (RJC).  As a RJC member, we adopted and adhere to the RJC Code of Practices.  Together with RJC and other RJC members, we meet high ethical standards promoting human rights, safety and environmentally friendly practices throughout our supply chain.

We implemented Responsible Sourcing practices in accordance with Dodd Frank, UN and OECD guidelines.  DAI’s commitment is to operate in a manner with the safeguards in place to ensure our customers and the public at large that none of our products (diamonds or gemstones including rubies, emeralds and sapphires, as well as precious metals) come from Conflict Affected High Risk Areas and areas of known human rights violations.  We expect the same commitment throughout our organization from our employees to our suppliers, customers and other affiliated relationships.  This united commitment is the only way to make a difference in human rights, fighting corruption and protecting the environment.

We remain vigilant in our efforts by assessing risk and reviewing our sourcing relationship to honor this commitment to provide conflict-free products to our consumers.  With our suppliers, we have implemented a due diligence system based on a scorecard to assess risk across several factors to generate a weighted risk score.  We have identified certain risks factors associated with geographic location of the suppliers and supplier’s sources, length and quality of the business relationship, financial risk and supplier’s assessment practices.  Our risk assessment on these factors is scaled 1 to 5, where 5 is little or no risk and 1 is high risk.  A score of 4 to 5 is considered low risk and 3 to 4 is medium risk.  Any supplier falling in the medium risk area will be enter our remediation protocol, which involves a review of the red flags generating the risk and developing a plan to remediate the risk. Purchasing from any supplier falling below a weighted risk score of 3 will be suspended until such time the supplier provides adequate proof the risks or problem areas have been addressed and a track record of the improvement has been established.

The risk factor identified as Supplier’s Assessment practices involves the Supplier’s own responsible sourcing practices.  We expect our suppliers to implement a supplier due diligence system like our own following OECD guidelines to identify and assess risk in their supply chain, implement strategies to remediate the risks identified and communicate with DAI on those risks identified and plan in place to remediate or rectify.

DAI supply chain due diligence is an ongoing process where prospective suppliers are reviewed through the completion of extensive KYC documentation, checking all beneficial owners against the OFAC/SDN Watchlists and more, assessing an initial risk score based on the factors above and reviewing through the entire lifespan of the business relationship.  These reviews will involve a semi-annual review of the risk score and annual requests from the supplier for reaffirmation on their commitment to responsible sourcing, disclosures of changes in management and/or ownership, and a review of the supplier’s due diligence.  DAI’s finance department will be responsible for conducting these initial assessments and ongoing reviews of the supply chain.

Part of our Responsible Sourcing protocol is being open to your input.  Do you have any questions or concerns regarding our sourcing practice?  Do you know of any issues in our Supply Chain?  You may email us directly with any question, concern or grievance at [email protected].

Follow us on social media or visit our website where we will post our annual Social Responsibility Report (SRR) to let you know what we have done in the last year and any updates we may have during the year.

This policy has been reviewed and endorse by senior management and all owners of Dana Augustine Inc.

Sincerely,

Dana J Augustine

CEO

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