We at Atit Diamond Corporation believe in doing business with complete responsibility for our practice and complying with trade and legal requirements. Being member of Responsible Jewellery Council (RJC), we encourage and expects our Suppliers to share our commitment to ethical business conduct, human rights, fair and safe labor practices and environmental protection. Atit Diamond Corporation expects all its business partners to comply with the requirements below, and any failure to comply might result in even terminating business relationship with the business partners.
Atit Diamond Corporation shall always carry out our financial transaction through proper banking system and maintain financial accounts of all business transactions in accordance with national or international accounting standards and shall annually undertake a financial audit/review in jurisdictions where permitted, by an independent qualified accountant.
Atit diamond Corporation shall ensure that all the activity and practices carried out by Atit Diamond Corporation shall always complies with all applicable laws and regulations, including laws concerning labor, health and safety, human rights, environmental protection, corruption, bribery and money laundry. We shall comply with applicable employment law including wages payment, working hours, leave benefits. Voluntary overtime is permitted only where it is within the limits allowed under applicable law or Collective bargaining agreements. The Atit Diamond Corporation complies with all rules and regulations regarding sexual or physical harassment, mental, physical or verbal abuse. The Atit Diamond Corporation shall not use Forced Labor as defined in ILO Convention 29, including bonded, indentured or involuntary prison labor. Scope of Commitment Labor rights – such as the right to freedom of association and effective recognition ofcollective bargaining, and freedom from forced labor, child labor and discrimination of any kind.
Social, cultural and economic rights – such as the right to participate in culture, the right to food, the right to work, and the right to education.
Civil and political rights – such as the right to life and liberty, freedom of expression, and equality before the law .
We shall respect human rights by considering all potential and actual impacts in their operations and business relationships. We shall also commit to and implement the UN Guiding Principles on Business and Human Rights (as appropriate to their size and circumstances).
We commit to: a. Respect human rights within their operations and business relationships; and procedures for implementing the policy in alignment with “Responsible Jewelry Council” (RJC) - COP 2 (Policy and implementation).
Have a human rights due diligence process to identify, prevent, mitigate and account for adverse human rights impacts that are connected to their business. Have a grievance mechanism.
Provide for, or support legitimate processes to enable, the remedy of any adverse human rights impacts that it has caused, contributed to or been linked with.
Communicate annually with stakeholders about their human rights due diligence efforts and remedy activities in accordance with “Responsible Jewelry Council” (RJC) - COP 3 (Reporting). Non-Discrimination ATIT DIAMOND CORPORATION do not practice or accept any form of discrimination in the workplace in terms of hiring, remuneration, overtime, access to training, promotion, termination or retirement, which are based on ethnicity, race, national origin, religion, gender, sexual orientation, union membership, political affiliation, marital status, pregnancy status, physical appearance, HIV status, disability, age, or any other prohibited basis. 

Child Labor ATIT DIAMOND CORPORATION will obtain and maintain accurate date of birth documentation and shall not employ children (as defined in ILO Convention 138 and Recommendation 146).
Freedom of Association Where it is not restricted by Applicable Law, ATIT DIAMOND CORPORATION shall respect the right of employees to freedom of association and collective bargaining.
Health and Safety ATIT DIAMOND CORPORATION shall provide safe and healthy working conditions to all employees and on-site Contractors in accordance with Applicable Law and regulations and other relevant industry standards. ATIT DIAMOND CORPORATION shall regularly assess the workplace for hazards and risks and implement appropriate programs to minimize the risks. Hazardous Substances ATIT DIAMOND CORPORATION shall maintain an inventory of Hazardous Substances at Facilities. Supplier shall not manufacture, trade, and/or use chemicals and Hazardous Substances subject to international bans due to their high toxicity to living organisms, environmental persistence, or potential for bioaccumulation, irreversible ecological impacts, or depletion of the ozone layer. Supplier shall employ alternatives to other Hazardous Substances used in business processes wherever technically and economically viable. Due diligence for responsible sourcing ATIT DIAMOND CORPORATION in the gold, silver, PGM, diamonds and colored gemstones supply chain shall exercise due diligence over their supply chains in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”) or other auditable due diligence frameworks recognized by RJC to be aligned with the OECD Guidance (“RJC-recognized due diligence frameworks”), in ways appropriate to their size and circumstances. ATIT DIAMOND CORPORATION shall adopt and communicate publicly and to their suppliers a supply chain policy with respect to sourcing from conflict-affected and high-risk areas.

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DISCLOSURE POLICY

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The Atit Diamond Corporation shall properly disclose all its material lie natural polished diamonds /Gold /Silver/Platinum/Coloured Gemstone and its jewellery product. Any treatment that change the nature of product shall be clearly defined in the sales invoice. Diamonds - Treated Diamonds Treated Diamonds shall be disclosed as either “Treated” or with specific reference to the particular Treatment. The description shall be equally conspicuous as the word(s) “Diamond”. Any special care requirements that the Treatment creates shall be disclosed. Diamond Warranties ATIT DIAMOND CORPORATION, where involved in buying and selling Diamonds, polished or set in Jewelry, shall adopt the World Diamond Council System of Warranties and have systems to ensure that all associated invoices contain the following affirmative statement, or equivalent wording which provides the same warranty:
“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.”
“The diamonds herein invoiced are exclusively of natural origin and untreated based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.”
Based on the written assurance from our supplier, our diamonds are not originated from Mbada and Marange region of Zimbabwe. All our diamonds are natural origin. The diamonds herein invoiced are not sourced from artisanal mines. The diamonds are in compliance with the relevant WFDB Charter on disclosure of synthetic, treated natural and natural diamonds, OFAC guideline and OECD standards on due diligence for the diamond supply chain and not originated from any of Conflict-affected and high-risk areas – CAHRAs.”

Policy updates, implementation and training Atit Diamond Corporation shall conduct management review meeting annually or as and when any changes in policy or non-compliance observed to review and update its ethical business policy and to defined corrective action plan ATIT DIAMOND CORPORATION management shall: a. hold annual updates and training to workers regarding different relevant policy subjects. b. update the stuffs about emergency exits and evacuation plans and have yearly practice for fire and earthquake emergency evacuation. b. have trained and certified stuff in the premises for emergency first aid.
Responsible Jewellery Council (RJC) Compliance Policy
Atit Diamond Corporation is located in 18E 48th Street #1200 NYC, NY 10017. Atit Diamond Corporation is RJC certified members (Certified Member # 3850).
The RJC is a standard-setting organization established to advance responsible ethical, human rights, social and environmental practices throughout the diamond, gold and platinum group metal jewelry supply chain.
As an RJC member, we commit to operating our business in accordance with the RJC Code of Practice (COP). We commit to integrating ethical, human rights, social and environmental considerations into our day-to-day operations, business planning activities and decision-making processes.
We shall also continue to comply with all applicable laws and regulations, including laws concerning child labor, health and safety, human rights, environmental protection, sexual or physical harassment, mental, physical or verbal abuse, corruption, bribery and money laundry.

​As an RJC member, we fully commit to supplying conflict free gold, silver, platinum and diamond and maintain all records accordingly.
Internal and External Stakeholders Grievance Procedure
We have developed and implemented grievance procedures for internal and external stakeholders. Any complaint or suggestion or grievance received on mailed id shall be properly addressed with confidentially and without any retaliation. We shall ensure that there shall be no retaliation or discrimination against those who express grievances, and that any grievances shall be treated confidentially. Management shall treat grievances seriously and take prompt and appropriate action in response. Any internal or external stake holder can report any violation of ethical business policy to the defined mail id below. Reporting individuals shall remain anonymous. Any grievance or complaint found with malafide intention shall not be addressed by the management of the Atit Diamond Corporation. How to Report
Reporting should be in clear words with proper information and in proper language should be avoided. Complaint/Grievance/Suggestion should have followings:
Subject and reference of violation of ethical business policy/ name of sender subject to confidentiality and anonymity/Details of incident and actual complaint/Effect of incident and expected results
Normally any Complaint/Grievance/Suggestion be addressed in 15 working days however resolution of any complex complaint may take time up to 4 working weeks.
Filing grievance via email For filing a grievance, the stakeholder should email his/her grievance to this email address:

usha@atitdiamond.com

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All counterparties are requested to comply with following policies
ATIT DIAMOND CORPORATION is proud to have become a certified member of the Responsible Jewellery Council (RJC) and encourages and expects its Suppliers to share ATIT DIAMOND CORPORATION’s commitment to ethical business conduct, human rights, fair and safe labor practices and environmental protection. ATIT DIAMOND CORPORATION expects all its suppliers to comply with the requirements below, and any failure to comply might result in canceling all outstanding purchases, suspending future purchases, or even terminating ATIT DIAMOND CORPORATION’s business relationship with the Supplier.

GENERAL REQUIREMENTS
Business Conduct: Supplier shall Maintain financial accounts of all business transactions in accordance with national or international accounting standards, and shall annually undertake a financial audit, or financial review in jurisdictions where permitted, by an independent qualified accountant. Supplier shall conduct his business in an ethical and transparent manner, and all his business activities should be accurately reflected on his business records. Subcontractors: Supplier shall not use any subcontracting services for any of ATIT DIAMOND CORPORATION’s projects unless ATIT DIAMOND CORPORATION confirms it (in writing) and the Subcontractor reads and signs this Code of Conduct.
Compliance with Applicable Law: Supplier shall comply with all applicable laws and regulations, including laws concerning labor, health and safety, human rights, environmental protection and corruption and bribery. Human Rights: Supplier shall respect Human Rights and observe the UN Guiding Principles on Business and Human Rights in ways appropriate to its size and circumstances.
Bribery and Corruption: Supplier shall not engage in bribery or any other form of corruption and shall not violate or cause ATIT DIAMOND CORPORATION to violate any applicable anti-corruption or bribery law. In order to ensure full compliance with Applicable Anti-Corruption and Bribery Laws, the Supplier shall set the criteria and approval procedures to be followed by employees (including for offer and/or acceptance of gifts with third parties).
Security: Supplier shall establish measures that protect against product theft, damage or substitution of products within the premises and during shipments, and shall ensure the safety and security of its employees, contractors, and visitors. Supplier shall ensure that all security personnel respect the Human Rights and dignity of all people and use force only when strictly necessary and the minimum proportionate to the threat.
Money Laundering and Finance of Terrorism: Supplier shall support and contribute to efforts to eliminate money laundering. Supplier shall report any suspicious activity regarding money laundering or finance of terrorism to the relevant designated authority. Working Hours: Supplier shall comply with Applicable Law on working hours. Voluntary overtime is permitted only where it is within the limits allowed under Applicable law or Collective bargaining agreements. Discipline: Supplier shall not use corporal punishment, harsh or degrading treatment, sexual or physical harassment, mental, physical or verbal abuse, coercion or intimidation, or threats of these towards themselves, family or colleagues. Supplier shall provide clear grievance procedures and investigation processes and clearly explain these to all Employees.
Voluntary Employment: Supplier shall not use Forced Labor as defined in ILO Convention 29, including bonded, indentured or involuntary prison labor. All Supplier’s employees shall be free to leave their employment, and the Supplier shall not unreasonably restrict their freedom of movement in the workplace nor in on-site housing. Non-Discrimination: Supplier shall not practice or accept any form of discrimination in the workplace in terms of hiring, remuneration, overtime, access to training, promotion, termination or retirement, which are based on ethnicity, race, national origin, religion, gender, sexual orientation, union membership, political affiliation, marital status, pregnancy status, physical appearance, HIV status, disability, age, or any other prohibited basis.
Child Labor: Supplier shall obtain and maintain accurate date of birth documentation, and shall not employ children (as defined in ILO Convention 138 and Recommendation 146). Supplier shall not engage in or support Worst Forms of Child Labor (as defined in ILO Convention 182 and Recommendation 190) which includes Hazardous Child labor or all forms of child slavery and practices similar to slavery.
Salaries: Supplier shall not pay less than the minimum wages (as set by the applicable laws). Supplier shall provide each employee with a clear detailed salary statement which elaborates working days (or hours), and deductions.
Freedom of Association: Where Applicable Law does not clearly restrict that, Supplier shall respect the right of employees to freedom of association and collective bargaining.
Health and Safety: Supplier shall provide safe and healthy working conditions to all employees and on-site Contractors in accordance with Applicable Law and regulations and other relevant industry standards. Supplier shall regularly assess the workplace for hazards and risks, and implement appropriate programs to minimize the risks.

The Risk Assessment shall consider Hazards associated with the Supplier activities and products which shall include, where relevant: use of machinery and mobile equipment, storage and handling of chemicals including cleaning materials, exposure to excessive fumes, airborne particles, noise and temperature levels and inadequate lighting and ventilation. Supplier shall provide training and information about Health and Safety and shall ensure that appropriate Personal Protective Equipment (PPE) is provided free of charge. Environment: Supplier shall identify environmental risks and impacts, and the opportunities for improving environmental performance. Supplier shall implement and regularly review controls to minimize identified environmental risks and significant environmental impacts, and to improve environmental performance. Hazardous Substances: Supplier shall maintain an inventory of Hazardous Substances at Facilities. Supplier shall not manufacture, trade, and/or use chemicals and Hazardous Substances subject to international bans due to their high toxicity to living organisms, environmental persistence, or potential for bioaccumulation, irreversible ecological impacts, or depletion of the ozone layer. Supplier shall employ alternatives to other Hazardous Substances used in business processes wherever technically and economically viable. Wastes and Emissions: Supplier shall identify and responsibly manage significant wastes and emissions to air, water and land generated in their business processes, while taking into account:

1. environmental impact considerations alongside cost considerations.

2. applying the principles of reduce, recover, re-use and recycle to reduce environmental impact where applicable.

3. discharging or disposing wastes and emissions in compliance with Applicable Law, or where Applicable Law does not exist, by adopting prevailing international standards.
Supply chain - Due diligence: Supplier shall do a detailed and full Due Diligence process for each of its counterparties which involves:

a. verifying its identity and address.

b. doing an ongoing effort to identify risks regarding money laundering & finance of terrorism, Bribery and Conflict Affected and High-Risk Area (CAHRA).

c. having periodical risk assessments which involves the nature, severity and probability of each risk and where required (e.g., where any unusual or suspicious activity is identified): (i) having a systematic risk mitigation process (ii) reporting to the appropriate authorities Ethical Sourcing/Due Diligence and Risk Assessment Policy
The Policy promotes the standards that we expect all our suppliers to comply with when producing and supplying Diamonds/Jewellery/Coloured Gemstone to Companies, no matter where they operate in the world. We hereby inform all our suppliers to provide the first mine of origin for the material they supply to us. We request all our suppliers not to supply any material that is subject to restriction as per EU Reg. 833/2014
The senior management of Companies advocate this policy, and we shall review as and when changes in the process or compliance requirement or any violation of sourcing policy or Changes in risk and due diligence criteria. We shall carry out review of this entire document at least annually.
We recognize that full compliance with these criteria may take time for some suppliers, and we are committed to working with our suppliers to implement improvement plans and help them achieve compliance.
Member Companies are committed to working in partnership with its suppliers to help achieve compliance with this Policy.
All the supplier should comply with national and international law and trade requirement like RJC with respect to Bribery and Corruption, Financial Offence, Labour Rights, Kimberley process and World Diamond Council – SoW, Product disclosure, Labour Rights, Working Condition, Child labour, Forced labour, Human rights, Discrimination, Fair wages and working hours, Environment compliance, Health and safety of the employees and visitor.
Policy – Supply Chain and Ethical Sourcing
At Companies, we take Ethical business practice, social and environmental factors into consideration in making decisions on the procurement of Jewellery or polish diamonds.

​This Policy shows Atit Diamond Corporation’s commitment and its expectations for its product suppliers regarding actions to address Conflict Diamonds.
Companies expects it's suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that diamonds supplied to us containing conflict free diamonds are not belongs to Conflict-affected and high-risk areas – CAHRAs .
We being a responsible Atit Diamond Corporation, Companies supports the goal of the Dodd-Frank Act of preventing armed groups in the conflict affected and high risk countries from benefitting from the sourcing of Conflict diamonds from that region.
Companies are committed to working with its suppliers to educate them on these matters and concerning steps they can take to obtain increased transparency regarding the origin of diamonds mined or manufacture and sell to Companies. Companies reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy.
Companies reserves the right to request additional documentation from its suppliers regarding the origin/source of diamonds sold to Companies.
Suppliers who do not reasonably comply with this Policy shall be reviewed by Companies ’s for future business.
We shall communicate to our supplier to derive firs mine of origin and we request all our supplier through this policy to share with us for first mine of origin for diamond/gold and other relevant materials.
Companies are committed to ensuring that our supply chain is free of any diamonds which was procured for the support or benefit of armed and anti-social conflict groups or involving serious abuses of human rights and non-compliant with OECD Guidelines.
Companies clearly criticizes such activity and will reject any material which we believe was obtained involving serious human rights violations or which benefitted or supported armed rebels or terrorist groups through illegal finance or other activities.
The Atit Diamond Corporation 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 Atit Diamond Corporation shall carry out due diligence to assess risks related to procurement from the Conflict-affected and high-risk areas – CAHRAs and shall always source from compliant miners/traders.
We shall always set reasonable efforts to source Diamonds from miners and traders validated as being Conflict Free and require their direct and indirect suppliers to do the same;
We strive to work supportively with our customers and supply chain partners in implementing conflict free compliance programs for Diamond Supply chain.
Policy – Due Diligence and Risk Assessment
The Atit Diamond Corporation shall always undertake to ensure that the extraction and trade of diamond support peace and development, not conflict.
Companies remain committed to enhance its Supply Chain Due Diligence program through internal review and external assessments. We have zero tolerance policy for the supplier violating OECD due diligence guideline and we shall immediately stop commercial relationship if any of our business associates found non-compliant or High-Risk during our internal/external risk assessment.
All the suppliers are also requested to carry our risk assessment and due diligence for their suppliers and products they are sourcing.
Currently Companies procure it’s diamonds from RJC CoP/Ethical business practice compliant miners/traders. However, we have established a strong due diligence process and we shall review it as an when we observed significant risk or upon receipt of any grievance or complaint but in normal course, we shall carry our due diligence process on annual basis.

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Identify red-flags and Risk
The Atit Diamond Corporation has checked transaction methods and name and individuals of Atit Diamond Corporation on SDN list of USA treasury and EU sanction list. All the suppliers are found low in risk and in compliance with OECD requirement of CAHRA’s.
Risk mitigation plan
Atit Diamond Corporation shall always deal with legitimate Atit Diamond Corporation.
Always complete due diligence and risk assessment before establishing commercial relationships.
Make sure that do transaction shall be carried out with business sense.
Immediately stop commercial relationship upon any violation observed an report to concerned internal and external reporting authority.
Continuously monitor suspicious transactions and red flag records
Communication and awareness to suppliers
Supplier Risk Assessment /Due Diligence Report
We the senior management of Companies and compliance officer has verified all our supplier with respect to following ;
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
US OFAC Sanctions/EU Sanctions/Global Peace Index/Know Your Country
Transparency International (TI)
The Office of the United Nations High Commissioner for Human Rights (OHCHR)
http://www.responsiblemineralsinitiative.org/minerals-due-diligence/risk-management/conflict-affected-and-high-risk-areas/Publication (Detailed report is with Compliance team and may produce to concerned parties upon request)

We have conducted risk assessment and due diligence of all our suppliers and customers with respect to latest OECD requirements and RJC guideline and we found all our supplier are complying with requirements did not find any risk pertaining to their business involvement in Conflict Affected and high-risk Areas’ (CAHR’s).

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