Ethical Business Conduct

UNI-DESIGN conducts business with honesty, integrity and fairness.

We strictly prohibit:

• Bribery, corruption, facilitation payments or kickbacks
• Conflicts of interest that are not declared
• Fraud, theft or misrepresentation
• Money laundering, terrorist financing or dealings with sanctioned parties

All employees, directors, agents, suppliers and business partners must comply with our Code of Conduct, Anti-Bribery & Anti-Corruption Policy and AML-CFT & KYC Policy.

Human Rights & Labour Standards

UNI-DESIGN respects internationally recognized human rights. We do not tolerate:

• Child labour
• Forced, bonded or involuntary labour
• Human trafficking
• Discrimination, harassment or abuse
• Retaliation against whistle-blowers

We ensure:

• Safe and healthy working conditions
• Fair wages and lawful working hours
• Freedom of association and collective bargaining
• Equal opportunity regardless of gender, religion, caste, nationality or background

Responsible Sourcing of Diamonds & Gold

UNI-DESIGN sources natural diamonds and precious metals responsibly and ethically.

We ensure that:

• Diamonds are conflict-free in compliance with the Kimberley Process
• Gold and precious metals are sourced from legitimate, non-conflict, non-abusive sources
• All suppliers are subject to KYC, AML-CFT and supply chain due diligence
• High-risk suppliers or origins are reviewed, monitored or disengaged when required

We do not knowingly trade in:

• Conflict-affected or human-rights-abusive materials
• Smuggled, stolen or illegally mined diamonds or gold
• Sanctioned or prohibited sources

Product Integrity and Disclosure

We are committed to full transparency and honesty in product information.

UNI-DESIGN guarantees that:

• Natural diamonds are accurately represented and disclosed
• Lab-grown diamonds, treatments and simulants are clearly identified
• Undisclosed mixing of natural and lab-grown diamonds is prohibited
• All customers receive truthful, written and verbal product disclosures

We maintain internal diamond screening, segregation and documentation systems to protect consumer confidence and supply chain integrity.

Environment, Health and Safety

We strive to minimize our environmental impact and protect our employees.

We commit to:

• Efficient use of energy, water and raw materials
• Responsible waste management and recycling
• Reduction of emissions and environmental pollution
• Safe handling of chemicals and hazardous substances
• Safe and healthy workplaces for all employees

Grievance & Whistleblowing Mechanism

Anyone (employees, suppliers, customers or communities) may report concerns related to:

• Human rights abuses
• Ethical misconduct
• Corruption or bribery
• Product misrepresentation
• Unsafe working conditions
• Environmental harm

All complaints will be:

• Treated confidentially
• Investigated fairly
• Free from retaliation

Reports can be sent to compliance@diarough.com or uni.compliance@unidesign-jewel.com

Governance & Continuous Improvement

The Board and senior management of UNI-DESIGN are responsible for implementing and monitoring this policy.

We will:

• Train employees on these commitments
• Monitor supplier compliance
• Conduct internal and external audits
• Continuously improve our ESG and supply chain systems

Our Commitment

UNI-DESIGN respects and supports internationally recognized human rights in line with:

• UN Guiding Principles on Business and Human Rights
• International Labour Organization (ILO) Conventions
• Responsible Jewellery Council (RJC) Code of Practices (COP 2024)

We are committed to conducting our diamond, gold and jewellery operations in a way that respects the dignity, safety and rights of all people.

Prohibited Practices

We strictly prohibit:

• Child labour
• Forced, bonded or involuntary labour
• Human trafficking
• Physical, verbal or psychological abuse
• Discrimination based on gender, religion, caste, nationality or any other status

Fair Employment

We ensure:

• Lawful working hours
• Appropriate renumeration
• Freedom of association
• Equal opportunity
• Safe and healthy workplaces

Supply Chain Responsibilities

We require our suppliers to respect human rights and comply with applicable laws. We assess risks in our diamond and gold supply chains and take action where risks are identified.

Remedy & Grievance

Any person may raise a concern confidentially at: compliance@diarough.com or uni.compliance@unidesign-jewel.com

Others

Human Rights Due Diligence report is available on request.

E-mail request can be sent at compliance@diarough.com or uni.compliance@unidesign-jewel.com

Our Commitment

UNI-DESIGN sources diamonds and gold responsibly and ethically in line with:

• OECD Due Diligence Guidance
• Kimberley Process Certification Scheme (KPCS)
• RJC COP 2024 & COC 2024

Diamonds

We only trade in natural diamonds that:

• Are conflict-free
• Are legally mined, exported and imported
• Are not associated with human rights abuses

Gold & Precious Metals

We source gold only from:

• Legitimate refiners and suppliers
• Non-conflict, non-abusive sources

We conduct risk-based supplier due diligence.

High-Risk Areas

We screen suppliers and countries for:

• Conflict risk
• Sanctions
• Human rights violations

Where risks are identified, we take corrective action or disengage.

Grievance

Any grievances related to 'Sourcing' can be addressed to compliance@diarough.com or uni.compliance@unidesign-jewel.com

Our Commitment

We guarantee full transparency and honesty in all diamond and jewellery products.

Natural Diamonds

All diamonds sold as natural are:

• Not lab-grown
• Not treated unless disclosed
• Not synthetic or simulated

Screening & Controls

We maintain:

• Diamond segregation systems
• Screening and verification processes
• Staff training to prevent undisclosed mixing

Customer Trust

All customers receive accurate written and verbal disclosures.

Our Commitment

UNI-DESIGN is committed to protecting the environment and minimizing the environmental impact of our operations in accordance with the RJC Code of Practices (COP 2024) and applicable environmental laws.

We recognize that responsible environmental management is essential to the sustainability of the diamond and jewellery industry.

Environmental Responsibility

We commit to:

• Efficient use of energy, water and raw materials
• Reducing waste, emissions and pollution
• Responsible management of chemicals and hazardous substances
• Safe disposal and recycling of waste
• Compliance with all environmental regulations

Climate & Emissions

We aim to:

• Monitor and reduce greenhouse gas emissions
• Improve energy efficiency
• Promote environmentally responsible practices across our operations

Employees & Suppliers

We train employees in environmentally responsible practices and encourage suppliers to meet similar environmental standards.

Continuous Improvement

We regularly review our environmental performance and take steps to improve our environmental footprint.

Our Commitment

UNI-DESIGN maintains a zero-tolerance approach to bribery, corruption, money laundering and terrorist financing in line with:

• RJC COP 2024
• International anti-corruption and financial crime laws

Prohibited Conduct

We strictly prohibit:

• Offering or receiving bribes or kickbacks
• Facilitation payments
• Fraud, theft or false accounting
• Doing business with sanctioned or criminal parties

AML & KYC Controls

We apply:

• Customer and supplier identification (KYC)
• Sanctions and watch-list screening
• Monitoring of unusual or suspicious transactions
• Reporting of suspicious activities

Gifts & Hospitality

Gifts or hospitality must be reasonable, transparent and never intended to influence business decisions.

Reporting Concerns

Suspected bribery, corruption or financial crime must be reported to: compliance@diarough.com or uni.compliance@unidesign-jewel.com

Our Expectation

UNI-DESIGN expects all suppliers to operate ethically, legally and responsibly.

Legal & Ethical Compliance

Suppliers must:

• Follow all applicable laws
• Not engage in bribery, corruption or money laundering
• Provide truthful and accurate business information

Human Rights

Suppliers must:

• Not use child or forced labour
• Provide safe working conditions
• Respect freedom of association
• Not discriminate or abuse workers

Responsible Sourcing

Suppliers must:

• Supply only conflict-free diamonds
• Provide legally sourced gold and precious metals
• Cooperate with UNI-DESIGN's due-diligence checks

Product Integrity

Suppliers must:

• Disclose any lab-grown diamonds or treatments
• Not mix natural and lab-grown diamonds without disclosure

Environmental Responsibility

Suppliers must:

• Minimize pollution and waste
• Follow environmental laws

Right to Audit

UNI-DESIGN reserves the right to review or audit suppliers to ensure compliance.