Policy

1. 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.
   • Any private sector employees, directors or officers, or their agents or representatives.
2. D. RAJ GROUP PRIVATE LIMITED is committed to prohibit bribery in all business practices and transactions that are carried out by the company or on its behalf by business partners, agents or employees. The company will not offer, accept or countenance any payments, gifts in kind, hospitality, expenses or promises as such that may compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with, or direct business to, any person; to influence the course of the business or governmental decision-making process.
3. D. RAJ GROUP PRIVATE LIMITED considers Bribery Risk as it applies to its organization (including agents) to identify which areas pose high risks. The company has developed appropriate methods to monitor conduct of employees and agents and eliminate bribery based on this understanding.
4. The management of D. RAJ GROUP PRIVATE LIMITED facilitates the reporting of incidences of attempted bribery or inappropriate gifts within their organization and shall apply appropriate sanctions for bribery and attempted bribery in all forms.
5. D. RAJ GROUP PRIVATE LIMITED ensures that no employee will suffer demotion, penalty or other adverse consequences for voicing a concern, or for refusing to pay a bribe or facilitation payment even if this action may result in the enterprise losing business.

1. D. RAJ GROUP PRIVATE LIMITED 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.
2. Strict compliance is required at all times, with all applicable national and, where appropriate, international laws / regulations with respect to money laundering, terrorism financing, bribery, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.
3. D. RAJ GROUP PRIVATE LIMITED 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.
4. D. RAJ GROUP PRIVATE LIMITED 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 as a violation of the Business Policies, depending on the seriousness of the non-conformance.
5. D. RAJ GROUP PRIVATE LIMITED implements a “Know your Customer” and “Know your Supplier” procedure that establishes the identity of all organizations with which it deals, have a clear understanding of their business relationships and have a reasonable ability to identify and react to transaction patterns appearing out of the ordinary or suspicious.
6. D. RAJ GROUP PRIVATE LIMITED apply high standards in the selection, screening and acceptance of suppliers and purchasers of rough and polished diamonds, ensuring anti-money laundering policies and procedures are adopted, mandating due diligence during the selection process, continued transaction monitoring and relevant and appropriate worker training.
7. Financial auditors should be alerted to applicable national legislation imposing special anti-money laundering/combating the financing of terrorism compliance rules on dealers in precious stones or high value goods.
8. Identification and verification of counterparties, by checking government-issued identification and government listings for money laundering, fraud, involvement in prohibited organisations and/or financing conflict.
9. Monitoring transactions and report suspicious transactions to relevant authorities.
10. Maintaining records for at least 5 years (or longer if required by national legislation).
11. Maintain records of all single or apparently linked cash or cash-like transactions equal to or above €10,000 euros/$10,000/USD or the threshold defined by applicable law (whichever is lower) and, where required by law, implement a process to report such transactions to the relevant designated authority.

The company shall complete the due diligence process prior to initiate business relationship. The company shall purchase/sale diamonds that are fully compliant with Kimberly Process Certification Scheme (KPCS) and shall purchase precious metals from legitimate source only.

The company shall ensure that all of its respective activities are in line with the OECD Due Diligence Guidelines, The Responsible Jewellery Council Standard and as per Universal Declaration on Human Rights laid down by United Nations.

The company shall prohibit any procurement from Conflict-Affected & High-Risk areas and adhere to compliance with standards on Anti-Money Laundering (AML) and Combatting the Financing of Terrorism (CFT).

Relevant Employees shall be trained on the Supply Chain & Due Diligence Requirement and OECD guideline at regular interval. We shall also provide support to our business partners and stakeholder for the same.

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 Right Violation; Torture, Cruel, In-Human and Degrading Treatment; Forced/Compulsory Labour; Child Labour; Abuses such as widespread Sexual Violence; War Crimes; other serious violations of International Humanitarian Law, 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 verify counterparty details, including the Know Your Customer (KYC) for any precious metals supplying Counterparties at regular interval. The company shall carry out risk-based assessment, set appropriate verification control and monitoring of all such commercial activities and transactions.

The company shall assign responsibility of Supply Chain Integrity and due diligence compliance to senior personnel of the organisation to prevent any risk of illegal activities or beach of it. The company shall implement the management strategy to respond to identified risks. For the same, Compliance Officer shall report to Senior Management in case of any such violation of this policy.

The company has established a risk assessment module and any business partners with high risk rating shall be red flagged and report to be submitted to senior management.

Grievance Mechanism

The purpose of this document is to outline a process through which any stakeholder can understand due diligence and supply chain integrity policy of the organization. The identity of the person who so ever has registered a concern shall be kept confidential and no retaliatory action shall be taken against any whistle blower. For anonymous submissions, you may refrain to provide your contact information.

Please share your Complaint/Grievance/Suggestion on mail id available on website.

1. All employees in D. RAJ GROUP PRIVATE LIMITED will be treated with equality, respect and dignity.
2. D. RAJ GROUP PRIVATE LIMITED creates and ensures a safe environment that is free of sexual harassment, including safety from persons/visitors coming into contact at the workplace.
3. D. RAJ GROUP PRIVATE LIMITED will not tolerate any sexual advances, requests for sexual favours, and verbal or physical conduct of a sexual nature that are, implicitly or explicitly, made a term or condition of teaching/guidance, employment, participation, or evaluation of a person's engagement in any activity.
4. D. RAJ GROUP PRIVATE LIMITED will not tolerate any sexual advances, and verbal, non-verbal and/or physical conduct such as loaded comments, remarks or jokes, letters, phone calls or e-mails, gestures, exhibition of pornography, lurid stares.
5. 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 D. RAJ GROUP PRIVATE LIMITED.
6. D. RAJ GROUP PRIVATE LIMITED will take cognizance of complaints about sexual harassment, conduct enquiries, provide assistance and redressal to the victims, recommend punitive action or take immediate action against the harasser, if necessary.
7. Security personnel, employed by D. RAJ GROUP PRIVATE LIMITED, are trained to respect the human rights and dignity of all people and use minimum force proportionate to the perceived threat.

Introduction

D. RAJ GROUP PRIVATE LIMITED, a leading wholesaler of high-quality charms and charm bracelets, is committed to integrating Environmental, Social, and Governance (ESG) principles into our business operations. We recognize the importance of sustainability and strive to operate in a manner that is environmentally responsible, socially equitable, and governed by high ethical standards. This policy outlines our commitment to ESG and sustainability across all aspects of our business.

Environmental Responsibility

Sustainable Sourcing:

• We are committed to sourcing our materials responsibly, ensuring that all are obtained from legitimate and sustainable sources.

Resource Efficiency:

• We aim to minimize our environmental footprint by improving resource efficiency in our operations. This includes reducing waste, conserving energy, and using water responsibly.
• We continuously seek ways to reduce our carbon footprint through energy-efficient practices and by exploring renewable energy options.

Waste Management:

• We implement waste reduction strategies, including recycling and reusing materials where possible.
• We ensure proper disposal of hazardous materials in compliance with environmental regulations.

Social Responsibility

Ethical Labor Practices:

• We are committed to upholding the highest standards of labor practices, ensuring fair wages, safe working conditions, and the right to collective bargaining for all employees.
• We strictly prohibit child labor, forced labor, and any form of human rights abuse within our operations and supply chain.

Community Engagement:

• We actively engage with the communities in which we operate, contributing to social development through initiatives such as education, healthcare, and local economic development.
• We encourage our employees to volunteer and participate in community service activities.

Diversity and Inclusion:

• We promote a diverse and inclusive workplace where all employees are treated with respect and have equal opportunities for growth and advancement.
• We are committed to eliminating discrimination based on race, gender, age, disability, religion, or sexual orientation.

Governance

Ethical Business Practices:

• We conduct our business with integrity and transparency, adhering to all applicable laws and regulations.
• We maintain a robust anti-corruption and anti-bribery policy, ensuring that all business dealings are conducted ethically.

Risk Management:

• We have established a comprehensive risk management framework to identify, assess, and mitigate risks associated with our operations, including environmental, social, and governance risks.
• We regularly review and update our risk management policies to address emerging issues and ensure continuous improvement.

Stakeholder Engagement:

• We engage with our stakeholders, including customers, suppliers, employees, and investors, to understand their concerns and expectations regarding our ESG performance.
• We are committed to transparent communication, regularly reporting on our ESG initiatives and progress.

D. RAJ GROUP PRIVATE LIMITED is dedicated to operating as a responsible and sustainable business. By integrating ESG principles into our core operations, we aim to create long-term value for our stakeholders and contribute positively to society and the environment. We believe that our commitment to sustainability is essential for the success and resilience of our business and the well-being of our planet.

Policy Statement

Company strictly prohibits retaliation against any member of its community for reporting or inquiring in good faith about what the member believes to be wrongful or unlawful activity, or for participating in an investigation or proceeding related to such activity. The Company considers such reporting, inquiring, or participating to be protected activities in which all members of the Company community may freely engage.

Purpose

Company is committed to operating with fairness and integrity and expects members of its community to act legally, honestly, and ethically. The purpose of this Policy is to promote an academic, research, and work environment that encourages community members to report any activity they believe in good faith to be wrongful or unlawful.

Audience

All Company employees, including faculty, staff, students, postdoctoral scholars, researchers, visitors, contractors, and volunteers.

Definitions

• In good faith: Done with honest belief that wrongful or unlawful activity may have occurred.
• Materially adverse: Sufficiently harmful to deter a reasonable person from engaging in protected activities.
• Protected activities: Include (i) reporting (whether internally or externally) or inquiring, in good faith, about suspected wrongful or unlawful activity; (ii) assisting others in making such a report; or (iii) participating in an investigation or proceeding related to suspected wrongful or unlawful activity.
• Retaliation: An action, performed directly or through others, that is aimed to deter a reasonable person from engaging in a protected activity or is done in retribution for engaging in a protected activity.

Retaliation can take many forms, as described in Section II below. Action in response to a protected activity is not retaliatory unless (i) it would not have occurred in the absence of the protected activity; and (ii) it has a materially adverse effect on the individual.