Policy

PREMISE

Naturalcorundum believes in social responsibility, integrity and transparency as fundamental parameters of the quality of its gems and its work.
We believe that only through a sustainable company can we achieve a healthy and long-lasting working environment, based on responsibility and ethics. These principles must be observed in all relationships established by employees with customers, suppliers, colleagues and third parties in general. These must be conducted on the basis of the utmost correctness, in full observance of the rights of others, in compliance with the laws in force and the principles belonging to the Company.

OBLIGATIONS

OBLIGATIONS FOR EMPLOYEES
The company complies with the laws and regulations in force in all countries in which it operates. All employees will be required to comply with these laws and regulations and to know the rules contained in the code of ethics.

All employees will have the obligation to:
− refrain from behavior contrary to the ethical standards contained in the code;
− report any request made to him to violate ethical standards;
− collaborate in internal investigations conducted by the company on issues governed by ethical standards.

OBLIGATIONS FOR MANAGERS
Each function manager will have the obligation to:
− represent an example for your employees with your ethical behavior;
− direct employees to comply with the code and urge them to raise problems and questions regarding any infringement of ethical standards;
− urge employees to report any shortcomings of the code of ethics, welcoming all the constructive contributions that the employees themselves wish to make in order to improve its contents. The code of ethics must, in fact, be a dynamic tool that is constantly evolving and therefore always perfectible;

OBLIGATIONS OF THIRD PARTIES
Compliance with the principles contained in the code is required in carrying out one's activities and/or in the execution of stipulated contracts.

RECIPIENTS
The following code is addressed to stakeholders, including all Italian or foreign, public or private entities with legitimate interests in the Company in any capacity: collaborators, customers, suppliers, institutions, the financial community and the Public Administration. .

PRINCIPLES AND PROVISIONS

HUMAN RIGHTS
Naturalcorundum follows the principles dictated by the OECD and the UN according to human rights and is committed to condemning any transgression.
It is committed to supporting the fundamental rights of each individual and promotes inclusion and equality in the organizations it is part of and throughout the entire supply chain.
Naturalcorundum undertakes to respect the Universal Declaration of Human Rights and the Declaration of the International Labor Organization on fundamental principles and rights at work as well as in accordance with the legislation currently in force.
The Company also undertakes not to adopt child or forced labor in any case and in any form.

EQUALITY
Naturalcorundum treats collaborators in all capacities according to the principles of equality, respect and dignity according to the UN Guiding Principles on Business and Human Rights, and combats and rejects any form of direct and indirect discrimination of a physical, sexual, racial, religious or psychological.
Naturalcorundum requires that leadership authority is exercised fairly, prohibiting any behavior that could in any way damage the personal dignity and professionalism of the collaborator.
The selection and hiring of staff must be inspired by criteria of transparency, in the evaluation of the requirements of competence and professionalism, individual capacity and potential.
As part of its personnel selection, hiring and management activities, it also undertakes to fully comply with the legislative and regulatory provisions in force from time to time regarding immigration and the condition of foreigners, with reference, among other things, to in particular, to the provisions relating to the procedure for hiring foreign workers, on a fixed or permanent basis.
Naturalcorundum guarantees freedom of association and collective bargaining: membership of a trade union will not be subject to discrimination, and fair treatment is guaranteed.
All staff are invited to promptly report to management any abuse they believe they have suffered or become aware of.

HARASSMENT AND DISCIPLINARY PROCEDURES
Naturalcorundum prohibits any form of harassment, be it psychological, physical or sexual, towards employees, collaborators, suppliers or customers.
Including in this precept any form of intimidation, abuse or threat that is an obstacle to the peaceful performance of one's duties. Any form of mobbing is prohibited according to the concept developed by the prevailing Italian jurisprudential orientation.
The mere prospect of increases in remuneration, other advantages or career progression, as compensation for activities that differ from the laws, the Code and internal rules and regulations, even limited to competence, is also prohibited. Any act of retaliation against those who refuse, complain or report such unfortunate facts is prohibited. All employees can address complaints, grievances or proposals to Management according to the communicated procedures.

LEGAL COMPLIANCE
Any activity carried out in the name and on behalf of Naturalcorundum must be conducted in absolute compliance with current laws and regulations.
Each Recipient undertakes to diligently acquire the necessary knowledge of the laws and regulations applicable to the performance of their functions, as in force at the time.

HEALTH & SAFETY
Naturalcorundum guarantees safety at work. It undertakes to comply with the regulations in force on the subject, and to apply due diligence by adopting a risk management system that prevents the occurrence of accidents.
Safety in the workplace is ensured both by rigorously implementing the provisions of the laws in force and by actively promoting the culture of safety through specific training programs. Staff training represents a central element of the management system adopted.

FAIR COMPETITION
Naturalcorundum conducts its commercial affairs in an ethical and correct manner for all stakeholders and pursues the value of fair competition with other operators, refraining from any collusive and abusive behavior to the detriment of customers and colleagues.
The recipients of this code undertake to preserve fair competition and to refrain from implementing behaviors that may undermine this principle.

DUE DILIGENCE ON THE SUPPLY CHAIN
This policy reflects Naturalcorundum's commitment to respecting human rights and non-tolerance towards conflict financing and to aligning with all sanctions, UN regulations and laws.
Naturalcorundum is a certified member of the Responsible Jewelery Council (RJC). Therefore, we are committed to demonstrating, through independent third-party verification, that we:

A. respect human rights according to the Universal Declaration of Human Rights and the Declaration of the International Labor Organization on Fundamental Principles and Rights at Work;
B. not engage in or tolerate bribery, corruption, money laundering or terrorist financing;
C. support transparency of government payments and rights-compatible security forces in the extractive industry;
D. not provide direct or indirect support to illegal armed groups;
E. implement the five-step framework from OECD guidelines CAHRA edition 3 as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

We are also committed to avoiding abuse by third parties, implementing a strict policy of relations with suppliers and applying know your counterparty procedures in order to verify the identity of the counterparties.

RELATIONSHIPS WITH SUPPLIERS
Naturalcorundum is committed to implementing all forms of due diligence regarding business dealings in high risk areas. All commitments with suppliers will immediately cease if they carry out actions in conflict with the underlying rules.
Naturalcorundum in particular prohibits direct or indirect support to non-governmental armed groups, the making of payments or the assistance or supply of equipment to non-governmental armed groups or their affiliates who illegally control mining sites, transport routes , gem marketing points and upstream operators in the supply chain.
Naturalcorundum intends to oppose the solicitation of bribes, requests to conceal or disguise the origin of gems, or misrepresentations regarding taxes, duties, tariffs and royalties paid to governments for the purposes of mining, trading, handling, transportation and export .

More generally he is against:

1. War crimes, violations of international humanitarian law and crimes against humanity.
2. Promotion of forced labor or any modern form of slavery or human trafficking.
3. Child labour, do not employ workforce under 16 years of age.
4. Non-discrimination on the basis of racial, ethnic, gender, disability, religion, sexual orientation, political orientation or any area of discrimination in all phases of their employment.
5. Abuse, must not be involved in any form of psychological or sexual abuse, any form of intimidation, threat or coercion of a sexual nature or promise of reward in the field of sexual favours.
   

Instead he claims:

1. Legal compliance and adaptation to current regulations regarding work, environment, health and safety.
2. Absolute respect for human rights according to guidelines promoted by the Organization for Economic Co-operation and Development. (OECD) and United Nations Standards for Business (UN)
3. Freedom of association and collective bargaining, the rights of representation and freedom of speech, freedom of association and collective bargaining must be respected.

Traceability and provenance. When requested, the recipient suppliers must be able to recover the origin of the chain of custody and provide adequate documentary reporting such as customs notes, etc.

KNOW YOUR COUNTERPARTY
Naturalcorundum decides not to have commercial relationships of any kind with non-referenced subjects and also imposes know your counter party procedures to deal with the risk of indirectly financing terrorist groups or contributing to money laundering.
Naturalcorundum undertakes to identify and register each new customer or supplier and keep track of it for at least 5 years from the last relationship established.
Legislative decree 21 November 2007, n. 231 in Implementation of Directive 2005/60/EC concerning the prevention of the use of the financial system for the purpose of laundering the proceeds of criminal activities and terrorist financing as well as Directive 2006/70/EC which contains implementing measures.
Naturalcorundum, in compliance with the Italian anti-money laundering law, undertakes not to accept cash payments with a value exceeding €999 and in any case to keep track of all payments for 5 years.

RISK ASSESSMENT
Naturalcorundum is committed to adopting a risk management model that allows for the consistent evaluation of its activities and those of its suppliers.
An agenda regarding risk assessment is established annually in the Board of Directors and a related procedure is also drawn up which also includes risk management activities.
By examining the risk and after evaluating its level (high, medium, low), we proceed to analyze the measures implemented to control it. If the risk and the containment method are acceptable, we proceed with the operating practices used previously.

CORRUPTION
Naturalcorundum adopts a "zero tolerance" policy against any form of corruption and illicit influence peddling, implementing a series of measures aimed at preventing, identifying and punishing the aforementioned crimes as part of its activities.

1. the payment or acceptance, direct or indirect, of bribes or hidden commissions;
2. the payment of "facilitating" payments (occasional payments of modest amounts aimed at ensuring or accelerating the fulfillment of certain actions in the normal performance of one's duties).

As a general rule, any payment to third parties must be justified by a fair service and price, as agreed with the aforementioned third parties.

ENVIRONMENTAL PROTECTION
Naturalcorundum believes in sustainable development and environmental protection, and is therefore committed to safeguarding natural resources, reducing waste and keeping environmental risks under control.

Concretely, it is proposed:

1. safe access to raw materials and protection of biodiversity; traceability and conformity of raw materials and substances;
2. compliance with good environmental practices and cooperation with suppliers to guarantee the best environmental standards along the entire supply chain;
3. internal practice provides that each potentially dangerous substance must be allocated with a particular criterion and name, and disposed of with diligence in the appropriate containers and through specific ecological procedures.

DECLARATIONS OF ORIGIN AND PRODUCT INFORMATION
The truthfulness and good faith in the declarations of origin are guaranteed because the company believes in the values of transparency and ethics in business activity.
Naturalcorundum, in compliance with the law of the Italian consumer code, undertakes not to falsely declare or omit crucial information when selling and advertising its products or services.

PRIVACY
The Management guarantees, in compliance with the provisions of the law, the confidentiality of the information in its possession and requires all Recipients to use the same for purposes exclusively connected to the exercise of their professional activities. All information obtained from the Recipients in relation to their work and collaboration relationship is the property of Naturalcorundum.

Proprietary information means:

1. personal data of Recipients and third parties. Any information relating to a natural or legal person, body or association, identified or identifiable, even indirectly, by reference to any other information is considered "personal data";
2. confidential information. Any information relating to Naturalcorundum of a confidential nature which, if disclosed in an unauthorized or involuntary manner, could cause damage to Naturalcorundum itself is considered "confidential information". By way of example, knowledge of a project, a proposal, an initiative, a negotiation, an understanding, a commitment, an agreement, a fact or an act, even if future or uncertain, relating to the sphere of activity of Naturalcorundum, which is not in the public domain.

Naturalcorundum also respects the principles of equal access and transparency in the disclosure of confidential information, in full compliance with the law and without altering the regular performance of activities.

RELATIONS WITH PA AND AUTHORITIES
Relationships with the Authorities and with the Public Administration must be based on maximum clarity, transparency and collaboration, in full compliance with the law and according to the highest moral and professional standards.
The Recipients, unless expressly authorized, cannot relate in the name and on behalf of Naturalcorundum with the Authorities and the Public Administration.
In relations with Public Officials, Public Service Representatives, and the Public Administration in general, the authorized Recipients maintain the highest levels of correctness and integrity, abstaining from any form of pressure, explicit or veiled, aimed at obtaining any advantage undue for himself or for Naturalcorundum.

IMPLEMENTATION

SANCTION SYSTEM
The Company, through the bodies and functions specifically appointed for this purpose, takes steps to impose, with coherence, impartiality and uniformity, sanctions proportionate to the respective violations of this Code and compliant with the current provisions on the regulation of employment relationships.
Any behavior carried out by consultants, collaborators, suppliers and business partners connected by a non-employee contractual relationship and, in any case not subject to management or supervision, in violation of the provisions of this
In more serious cases, the contractual relationship may even be terminated, without prejudice to any request for compensation if such behavior causes damage to the company.

COMMUNICATION OF THE CODE
The Management informs all Recipients of the provisions and application of the Code, requesting compliance.

In particular it provides:

1. the interpretation and clarification of the provisions of the Code;
2. updating its provisions, according to the needs that may arise from time to time.

In order to guarantee the effectiveness of this Code, Naturalcorundum prepares information channels through which all those who become aware of any illicit behavior carried out within Naturalcorundum can report, freely, directly and in an absolutely confidential manner to the Management .
It is the obligation of each Recipient to report any behavior that does not comply with the principles of the Code to the Management. The Management will be responsible for ensuring confidentiality regarding the identity of the person making the report as well as protecting him from retaliation, illicit influence, inconvenience and discrimination of any kind in the workplace, for having reported the violation of the contents of this Code.