Purpose and Scope

Grandview Klein Diamonds is a certified member of the Responsible Jewellery Council and is committed to implementing the 2024 Code of Practices as applicable to our certification scope in the diamond supply chain, including trading, cutting and polishing activities. This policy applies to employees and, where relevant, to contractors, agents, and business partners acting on our behalf.

Our Commitments

We are committed to conducting business responsibly and with integrity. Ethical, human rights, social, and environmental considerations are integrated into our operations, business planning, and decision making, supported by documented management systems and training.

Human Rights and Labor Rights

We respect internationally recognized human rights in our operations and business relationships and align our approach with the UN Guiding Principles on Business and Human Rights.

At a minimum, we prohibit and do not tolerate:

• Forced labor, human trafficking, and deceptive recruitment
• Child labor, including the worst forms of child labor
• Discrimination, harassment, and workplace violence
• Retaliation against individuals who raise concerns in good faith

We aim to provide a safe, professional, and respectful workplace and to address confirmed adverse impacts we cause, contribute to, or are linked with through our business relationships.

Due Diligence and Responsible Sourcing

We conduct supply chain due diligence across our diamond supply chain aligned with the OECD Due Diligence Guidance and the UN Guiding Principles on Business and Human Rights.

We maintain and implement a public supply chain policy and communicate relevant expectations to suppliers.

Our due diligence approach includes supplier engagement, risk identification, documented risk response, and periodic review.

Kimberley Process and System of Warranties

We do not knowingly buy or sell conflict diamonds and maintain controls aligned with the Kimberley Process Certification Scheme and the World Diamond Council System of Warranties.

Anti-Bribery and Corruption

We prohibit all forms of corruption, including bribery, in all business practices and transactions carried out by us and by agents acting on our behalf.

We maintain controls to manage bribery risk, including training for relevant personnel, criteria and approval procedures for gifts, and mechanisms to raise concerns.

Anti-Money Laundering and Know Your Counterparty

We do not engage in money laundering or the financing of terrorism. We document and apply KYC policy and procedures for counterparties and business partners that are suppliers of and customers for diamonds, including identity verification, sanctions screening, understanding business legitimacy, transaction monitoring, and record retention.

Our KYC program includes training, documentation procedures, and regular reviews.

Product Integrity and Disclosure

We do not make misleading or deceptive representations in the selling or marketing of diamond products and commit to accurate product disclosure.

Environmental Responsibility

We manage environmental impacts associated with our operations in a manner proportionate to our activities and applicable legal requirements.

Complaints and Grievance Mechanism

We maintain accessible reporting and grievance mechanisms, including confidential reporting through ReportIt and email, and prohibit retaliation for good faith reporting.

Training and Review

We provide role appropriate training and review this policy at least annually.

This policy is endorsed by:

Name: A.D. Klein

Position: Chairman

Date: January 22, 2026