Ethical Business Principles

Money Laundering, Terrorism Financing, Other Financial Offences

HARI KRISHNA GROUP recognises the fact that entities in the gems and jewellery sector have to take on the onus of analysing 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 / regulations with respect to money laundering, terrorism financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.

HARI KRISHNA GROUP shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations.

It is the responsibility of concerned personnel to know and understand the relevant 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 Principles, depending on the seriousness of the non-conformance.

Compliance officer ensure all the critical steps such as KYC & KYS, Identification of suspicious transaction, reporting to management and record keeping as required by the local act and legislations are complied with.

Kimberley Process And System Of Warranties

HARI KRISHNA GROUP is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and World Diamond Council’s (WDC) System of Warranties Declaration.

The definition of ‘Conflict Gem Stone Diamonds’ as agreed by the Kimberley Process will be adopted i.e:

“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.”

Wherever applicable, the following affirmative statement as recommended by the World Diamond Council’s System of Warranties should be printed on all the 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.”

Anti Bribery And Facilitation Payment Policy

The Hari Krishna Group shall ensure complete prohibition Bribery and facilitation payment across organisation and in all the entities.

Company will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.

Company shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.

Disclosure Of Treated Diamonds, Synthetics And Stimulants

• Full disclosure: 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.
• No misuse of terminology or mis-representations or attempts to disguise the product.
• The word ‘diamond’ will not be used in case of names of firms, manufacturers or trademarks; in connection with treated diamonds or diamond simulant or synthetic diamonds.

Definitions:
Diamond: A diamond is a natural mineral consisting essentially of pure carbon crystallized with a cubic structure in the isometric system.
Synthetic: A synthetic is any object or 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: Meets the requirements specified in the definition of the words ‘diamond’ and ‘synthetic’ above, but has been subject to some form 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.
Stimulants: 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.

Necessary declaration is provided on invoice in case of CZ or Stimulants are used in jewellery and same is communicated verbally prior to exe.

Conflict Minerals Policy Statement (Diamond & Gem Stone)

Hari Krishna Group is committed to being a responsible corporate citizen and is opposed to human rights abuses. As part of that commitment, Hari Krishna Group seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility.

What are "Conflict Diamonds"?
Blood Diamonds, also known as "Conflict Diamonds," are stones that are produced in areas controlled by rebel forces that are opposed to internationally recognized governments. The rebels sell these diamonds, and the money is used to criminal activities and/or funding terrorism.
Regions identified include: Sierra Leone, Liberia, Angola, the Republic of Congo, Côte d'Ivoire, the Central African Republic, and the Democratic Republic of Congo.

• Hari Krishna Group shall ensure that none of its supplies are coming from CAHRA’S.
• Hari Krishna Group shall communicate its sourcing policy to all the stakeholders and will ensure effective implementation.
• Annual reporting of Ethical sourcing.

For all customers and stakeholders, who want to obtain a copy of group/specific entities Ethical sourcing compliance report, such request shall have to be sent in writing to the below mentioned email address and shall be replied after internal review and confirmation from the concerned authorities of the group.

Supply Chain Management / Best Endeavors

The management of HARI KRISHNA GROUP is committed to taking appropriate action to use best endeavors to ensure the commitment of Tier 2 & Tier 3 entities to comply with the Best Practice Principles.

Employment

Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.

The Company shall not require workers to work for more than the national limit of hours in a week on a regular basis.

The Company shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of workers and provide some discretionary income.

Non Discrimination, Disciplinary Practices

Discrimination can mean distinction, exclusion or preference.

Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by the Company and any such reported incidents will be viewed as a serious violation of this Business Principles.

HARI KRISHNA GROUP will ensure that employees who have certain life threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.

HARI KRISHNA GROUP shall at no time condone the use of corporal punishment or other forms of mental or physical coercion.

Child Labour

No form of child labour should be employed at any of the facilities of HARI KRISHNA GROUP.

Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).

For authorised adolescents (persons below 18 years of age but above 15 years), the Company management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.

Company will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

Forced Labour

The management of HARI KRISHNA GROUP is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of this Business Principles.

Applicable definitions:
The Universal Declaration of Human Rights that states that “No one shall be held in slavery or servitude.”
ILO Convention 29, which defines forced or compulsory labour as “all work or service which is extracted from any person under the menace of any penalty, and for which the said person has not offered himself voluntarily.”

Human Rights

All employees in the Company’s facilities will be treated with equality, respect and dignity.

HARI KRISHNA GROUP 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.

The Company strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.

Environment Protection

HARI KRISHNA GROUP is committed to effective environmental management as one of its important corporate priorities, and will focus on the following initiatives:

• Compliance with all applicable environmental laws and regulations.
• The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards and reviewed periodically to mitigate or eliminate such impact.
• Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.
• Measurement of environmental performance through auditing with employee accountability and reporting to senior management.

Product Security

• Suitable safeguarding and storage is ensured at all stages with the help of safes.
• All the manufacturing, sales and retailing units are guarded by security agency and monitored by close circuit cameras.
• All the concerned persons are trained on relevant safety and security procedures to be followed at all times.
• Organization has developed emergency plan, which includes procedure in case of emergency (include emergency scenario such as theft robbery etc.).
• Product purity, quality and other parameters are monitored at each stage to avoid switch over of the product.

Public Grievances

Hari Krishna Group understands the importance of addressing increasing public grievances.

Company has introduced the common public grievance cell to look into matters of reporting non-compliance against any of the company policy or raising red flag against any of its business entity or individuals.

Further any query or clarification of diamonds can be raised and same shall be replied with 5 working days as per group public communication policy.