Policy Statement

Grandview Klein Diamonds is committed to respecting human rights in our operations and business relationships. We seek to conduct our business in a manner that upholds the dignity of individuals and contributes to responsible and ethical practices across the diamond supply chain.

This policy applies to our employees and, where relevant, to contractors, agents, and business partners acting on our behalf.

Frameworks and Standards

Our approach to human rights is informed by internationally recognized frameworks, including:

• The United Nations Guiding Principles on Business and Human Rights
• The Universal Declaration of Human Rights
• The International Labour Organization Declaration on Fundamental Principles and Rights at Work
• We apply these principles in a manner proportionate to our role and activities as a diamond trader and, where applicable, cutter and polisher.

Key Commitments

We do not tolerate, and seek to prevent, the following in our operations and business relationships:

• Forced labor, human trafficking, or deceptive recruitment practices
• Child labor, including the worst forms of child labor, as defined by ILO Conventions 138 and 182
• Discrimination on any basis unrelated to job requirements
• Harassment, abuse, intimidation, or workplace violence
• Retaliation against individuals who raise concerns in good faith
• We are committed to providing a safe, professional, and respectful working environment.

Due Diligence and Risk-Based Approach

We identify and assess potential human rights risks connected to our business activities and supply chain in alignment with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Where risks are identified, we seek to use appropriate leverage to engage business partners, clarify expectations, and support improvement. Where risks cannot be mitigated, we may suspend or end business relationships in accordance with our policies.

Business Partners

We expect our business partners to respect human rights consistent with internationally recognized standards and applicable laws. Expectations are communicated through our policies, supplier engagement processes, and contractual arrangements, as appropriate to our ability to influence.

Grievance Mechanism and Non-Retaliation

We maintain accessible and rights-compatible mechanisms that allow employees, suppliers, and other stakeholders to raise concerns related to human rights or business conduct without fear of retaliation.

Concerns may be raised through:

• Confidential reporting via ReportIt
• Email at grievance@GKDG.com
• Internal reporting channels such as management or compliance

Concerns are reviewed and addressed in line with our grievance procedures, with confidentiality respected to the extent possible.

Training and Awareness

We provide role-appropriate training to employees to support awareness of this policy and related responsibilities, including training on respectful workplace conduct, grievance mechanisms, and relevant human rights risks.

Governance and Review

This policy is approved by senior management and is reviewed periodically to ensure it remains appropriate to our business activities, risk profile, and the requirements of the Responsible Jewellery Council Code of Practices.

Dated:  January 22, 2026