Human Rights Policy

We, CERISE DIAM LIMITED, recognize our responsibility to respect human rights. We believe that our business has a role to play in protecting and promoting human rights.

CERISE DIAM LIMITED is committed to respecting internationally recognized human rights throughout our operations and supply chains. In line with the UN Guiding Principles on Business and Human Rights, our Policy is based upon the international standards enshrined in the Universal Declaration of Human Rights and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.

Human rights refer to a set of basic rights and freedoms that belong to every person in the world, regardless of where they are from, what they believe, or how they choose to live their life. It is a broad concept, with economic, social, cultural, political, and civil dimensions. For CERISE DIAM LIMITED, respecting human rights means ensuring that any person involved in, or coming into contact with, our operations, supply chains, and products is treated with dignity, respect, fairness, and equality.

Our Policy sets out overarching principles for how we conduct business at CERISE DIAM LIMITED. Together with our employees and business partners, we are committed to driving forward the implementation of this Policy throughout our operations and supply chains. We recognize unique challenges to these standards may arise, and we will work to address these challenges in partnership with relevant partners and stakeholders.

ETI Base Code as a reference as well as the RJC COPs related to labour rights, working conditions, and health & safety:

  • 1. Employment is freely chosen
  • 2. Freedom of association
  • 3. Working conditions are safe and hygienic
  • 4. Child labour shall not be used
  • 5. Living wages are paid
  • 6. Working hours are not excessive
  • 7. No discrimination is practiced
  • 8. Regular employment is provided
  • 9. No harsh or inhumane treatment is allowed

CERISE DIAM LIMITED will continuously work to embed this Policy throughout the relevant processes and procedures of the company to ensure its effective implementation.

We recognize that we must take steps to identify and address any actual or potential adverse impacts, whether they are directly or indirectly linked to our business activities or relationships.

We understand that human rights due diligence is a dynamic, ongoing process that requires acting on the findings, tracking our actions, and communicating to our stakeholders how we address impacts.

As our human rights risks and impacts may vary over time, this policy will be subject to review if proven inadequate by our human rights due diligence process.

Policy Statement - Use of Supply Chain

The company shall complete the due diligence process prior to initiating a business relationship. The company shall purchase/sell diamonds that are fully compliant with the Kimberly Process Certification Scheme (KPCS).

The company shall ensure that all of its respective activities are in line with the OECD Due Diligence Guidelines, The Responsible Jewellery Council Standard, and the Universal Declaration on Human Rights laid down by the United Nations.

The company shall prohibit any procurement from Conflict-Affected & High-Risk areas and adhere to compliance with standards on Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT).

Relevant employees shall be trained on the Supply Chain & Due Diligence Requirements and OECD guidelines at regular intervals. We shall also provide support to our business partners and stakeholders for the same.

The company shall carry out risk assessments for its supply chain and shall not enter into any business relationship or, if required, shall suspend/discontinue engagement with any supplier involved in dealing with Conflict-Affected and High-Risk areas. This includes any form of human rights violations, torture, cruel, inhumane, and degrading treatment, forced/compulsory labor, child labor, abuses such as widespread sexual violence, war crimes, other serious violations of international humanitarian law, crimes against humanity, genocide, or bribery. 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 company shall verify counterparty details, including Know Your Customer (KYC) for any precious metals supplying counterparties at regular intervals. The company shall carry out risk-based assessments, set appropriate verification controls, and monitor all such commercial activities and transactions.

The company shall assign responsibility for Supply Chain Integrity and due diligence compliance to senior personnel of the organization to prevent any risk of illegal activities or breaches. The company shall implement a management strategy to respond to identified risks. For the same, the Compliance Officer shall report to Senior Management in case of any such violation of this policy.

The company has established a risk assessment module, and any business partners with a high-risk rating shall be red-flagged, with reports submitted to senior management.

Grievance Mechanism

The purpose of this document is to outline a process through which any stakeholder can understand the due diligence and supply chain integrity policy of the organization. The identity of the person registering a concern shall be kept confidential, and no retaliatory action shall be taken against any whistleblower. For anonymous submissions, you may refrain from providing your contact information.

Please share your Complaint/Grievance/Suggestion at: ashirwad_diamonds@yahoo.com

COP 6 & 7: Human Rights & Due Diligence

Contact Information

Company Name: CERISE DIAM LIMITED

Date: 03.01.2025

Reporting Period: January 2024 - December 2024

Company Management Systems

CERISE DIAM LIMITED has the following policies in place, detailing our commitment to respect human rights throughout our supply chain and due diligence on natural diamonds originating from conflict-affected and high-risk areas.

We endorse these policies to our suppliers and stakeholders by distributing them via Email. These policies can also be accessed internally via notice board display or by contacting the compliance manager, and externally via Email.

Reference Document

S.NORef NoDocument NameIssue DateNext Review Date
1CDL-POL-16Policy Statement of RJC ComplianceApril 2024August 2025
2CDL-POL-07Policy Statement of Human RightsApril 2024August 2025
3CDL-POL-15Policy Statement of Supply ChainApril 2024August 2025

Company Implemented System

A. Supply Chain Due Diligence

To support supply chain due diligence, we have implemented the following internal measures:

  • Appointment of Senior Manager – MR. UMESHKUMAR LUKHI is responsible for overseeing supply chain due diligence.
  • Establishment and implementation of Human Rights and Supply Chain Policy.
  • MR. UMESHKUMAR LUKHI, Senior Manager, is responsible for the same.
  • Conducting Human Rights Due Diligence review once every six months to identify and mitigate human rights risks in our products and services.
  • Communication of human rights system to stakeholders and suppliers through Email.

Reference Document

Responsible Person Name & Designation: MR. UMESHKUMAR LUKHI (Senior Manager)

S.NORef NoDocument NameIssue DateNext Review Date
1CDL-AML-01Appointment Order of Senior ManagerJan-2024-
2CDL-POL-07Policy Statement of Human RightsApril 2024April 2025
3CDL-POL-15Policy Statement of Supply ChainApril 2024April 2025
4CDL-HRT-08Human Rights Due DiligenceSeptember 2024March 2025

B. Supply Chain Transparency Control

CERISE DIAM LIMITED has established a system of controls and transparency over our supply chain, which includes our approach for identifying suppliers and identifying sources of our materials.

  • The company shall purchase/sale polished diamonds that are fully compliant with Legal Requirements.
  • The company shall ensure that all its activities align with the OECD Due Diligence Guidelines, the Responsible Jewellery Council Standard, and the Universal Declaration on Human Rights by the United Nations.
  • Relevant employees shall be trained on Supply Chain & Due Diligence Requirements and the OECD guideline at regular intervals. We also provide support to our business partners and stakeholders.
  • The company shall carry out risk assessments for its supply chain and shall not enter into any business relationship or, if required, suspend/discontinue engagement with suppliers involved in dealing with Conflict-Affected and High-Risk areas.
  • The company shall verify counterparty details, including Know Your Supplier (KYS) for any precious metals supplying counterparties at regular intervals.
  • We communicate our expectations regarding human rights and supply chain due diligence through emails at frequent intervals. Additionally, we conduct due diligence on human rights and responsible sourcing to achieve continual improvement.

Reference Document

Responsible Person Name & Designation: MR. UMESHKUMAR LUKHI (Senior Manager)

S.NORef NoDocument NameIssue DateNext Review Date
1CDL-CRA-001Due Diligence ProcedureApril 2024April 2025
2CDL-CRA-001Due Diligence Responsible SourcingApril 2024April 2025
3CDL-ARN-001Annual Reporting Responsible SourcingApril 2024April 2025

C. Grievance Mechanism

Internal Stakeholder Grievance Mechanism

Our grievance mechanism for internal stakeholders can be accessed via contacting senior manager, grievance register, and suggestion box.

External Stakeholder Grievance Mechanism

Our external grievance mechanism is available via Email to ashirwad_diamonds@yahoo.com.

The employee responsible for these grievance mechanism(s) is MR. UMESHKUMAR LUKHI (Senior Manager).

Purpose of Grievance Mechanism

The purpose of this grievance mechanism is to outline a process through which any stakeholder can understand due diligence and supply chain integrity policy of the organization. The identity of the person who registers a concern shall be kept confidential and no retaliatory action shall be taken against any whistleblower. For anonymous submissions, you may refrain from providing your contact information.

Please share your Complaint/Grievance/Suggestion on ashirwad_diamonds@yahoo.com.

MR. UMESHKUMAR LUKHI is responsible for implementing and reviewing this procedure.

Contact Information

Concerns can be raised by interested parties via email or telephone to:

Responsible Sourcing & Contact Information

Responsible Person

Name & Designation: MR. UMESHKUMAR LUKHI (Senior Manager)

Document List

S.NOREF. NODOCUMENT NAMEISSUE DATENEXT REVIEW DATE
1CDL -POL-15Policy Statement of Supply ChainAPRIL 2024APRIL 2025
2CDL -CRA-12CAHRA Grievance RegisterMonthlyMonthly

Contact Information

Concerns can be raised by interested parties via email or telephone to:

D. Identified & Assessed Risks

Risk Assessment Overview

We assess our own and supplier’s due diligence practices and those relating to human rights by conducting due diligence for the Human Rights process.

During our assessment of our own and our supplier’s due diligence practices and those relating to human rights, we identified low risks within our supply chain. Therefore, there is no further action required.

Reference Document

Responsible Person Name & DesignationRef. NoDocument NameIssue DateNext Review Date
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -HRT-08Human Rights Due DiligenceSEPTEMBER 2024March 2025
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -HRT-007Human Rights Breach Incidents RegisterMonthlyMonthly

Steps Taken to Enhance Internal Systems and Controls

  • Mitigation control plan is established and implemented.
  • Monitoring documents are established and implemented.
  • Appointment of a responsible person for monitoring.

Strategy & Training and Capacity Building

E. Strategy:

Our risk assessment findings are received by the Director of CERISE DIAM LIMITED.

To respond to the risks identified within our supply chain, we took the following steps to design and implement a risk management plan. Our risk management plan consists of the following: mitigation plan, monitoring document, responsible person for monitoring, and next review date.

In addition to this, we evaluated the improvement of this risk after six months through the due diligence process.

Reference Document

Responsible Person Name & DesignationRef. NoDocument NameIssue DateNext Review Date
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -HRT-08Human Rights Due DiligenceSEPTEMBER 2024MARCH 2025
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -HRT-007Human Rights Breach Incidents RegisterMonthlyMonthly
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -CRA-001Due Diligence Responsible SourcingAPRIL 2024APRIL 2025
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -ARN-001Annual Reporting Responsible SourcingAPRIL 2024APRIL 2025

F. Training and Capacity Building:

CERISE DIAM LIMITED has provided training regarding human rights and other RJC requirements to our employees in August 2024. This training included information on the human rights process in our organization. We have also provided training regarding our due diligence activities to all of our employees on the same date; this training included information on the due diligence process in our organization.

Training Records

Responsible Person Name & DesignationRef. NoDocument NameTraining DateNext Training Date
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -TRN-002Training RecordsAUGUST 2024FEBRUARY 2025

G. Due Diligence Communication:

CERISE DIAM LIMITED communicates to our stakeholders regarding our due diligence activities and efforts to prevent human rights risks. This communication is in the form of Email. When a human rights risk is identified, we communicate the risk and how we are addressing it to potentially affected stakeholders via Email.

Since our last report, no grievances have been raised regarding human rights risks or our supply chain due diligence.

Reference Documents

Responsible Person Name & DesignationRef. NoDocument NameIssue DateNext Review Date
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -HRT-08Human Rights Due DiligenceSEPTEMBER 2024March 2025
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -HRT-007Human Rights Breach Incidents RegisterMonthlyMonthly
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -CRA-001Due Diligence Responsible SourcingAPRIL 2024APRIL 2025
MR. UMESHKUMAR LUKHI (Senior Manager)CDL -ARN-001Annual Reporting Responsible SourcingAPRIL 2024APRIL 2025

H. Carry Out a Third Party Audit (optional information)

CERISE DIAM LIMITED has joined the RJC in 2024 and has been planning to achieve certifications.

In support of our continuous improvement journey, our latest third-party RJC audit is planned within our organization against the RJC COP 2024 in February 2025.

Annual Reporting on Responsible Sourcing and Due Diligence Mechanism

Date: 09/04/2024

Reporting Period: 04/2023 to 03/2024

OECD Due Diligence GuidanceAction Taken
Step 1: Establish strong company management systems
1.A Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas.
  • Sourcing Policy has been established with document no. CDL-POL-015.
  • Sourcing Policy communicated to internal interested parties through training and also displayed on notice board.
  • The Sourcing Policy has been communicated to external interested parties via email and is publicly displayed on the office premises' notice board to ensure accessibility for visitors.
1.B Structure internal management systems to support supply chain due diligence.
  • The Company has prepared Manuals for Sourcing compliance and due diligence which includes procedure for risk assessment, methods for identification of red flags, risk mitigation etc.
  • Training on responsible sourcing has been imparted to relevant personnel.
  • The company has appointed senior official Mr. UMESHKUMAR LUKHI who bears the competence, knowledge and experience to be responsible for implementing due diligence management system.
1.C Establish a system of controls and transparency over the minerals supply chain.
  • The Company collects supplier details through KYC/KYS documents from each associated parties which include Business registration documents, Completed KYC questionnaire. Also checks against relevant government lists for individuals or organisations implicated in money laundering, fraud or involvement with prohibited organisations and/or those financing conflict.
  • The company collects all information pertaining to physical description and origin of supplies from suppliers for each parcel through Invoice and sales documents and Gemmological laboratory reports and/or certificates (polished stones only).
  • The company has established supplier packet and shared with all the suppliers along with the company’s requirement and obligations to comply with OECD requirements to make engagement with suppliers, the supplier packet which contains questions related to sourcing, their supplier due diligence mechanism etc.
1.D Strengthen company engagement with suppliers.
  • The company has established supplier’s packet and shared with all the suppliers along with OECD requirements and its 5 steps of due diligence mechanism.
  • The suppliers packet also contains agreement to take reasonable steps to ensure that all the supplies are supplied in accordance with Company’s policy on supply chain/sourcing.
1.E Establish a company-level, or industry wide, grievance mechanism as an early warning risk-awareness system.
  • The company has established this grievance procedure to hear concerns about circumstances in the supply chain involving supplies from conflict-affected and high-risk areas.
  • The company shares email address on each invoice and also in supply chain/sourcing policy to contact to register grievance.
  • The company also maintains grievance register to keep records on monthly basis.
Step 2: Identify and assess risk in the supply chain
Identify and assess risks in the supply chain and assess risks of adverse impacts.
  • The company has conducted risk assessment of all the suppliers based on information from supplier’s packet, government assessments and from official websites.
  • No any red flag identified nor any suppliers found from conflict affected high risk areas.
Step 3: Design and implement a strategy to respond to identified risks (if applicable)
Report findings of the supply chain risk assessment to the designated senior management of the company.Mr. UMESHKUMAR LUKHI receives the findings of risk assessments.
Devise and adopt a risk management plan.The company has established risk mitigation plan to respond to the risks and impacts if identified.
Implement the risk management plan and monitor performance of risk mitigation efforts.The company has developed a Monitoring and evaluation plan to monitor and track the effectiveness of mitigation measures, including the results of follow-up activities after six months to evaluate significant and measurable improvement.
Internal trainingThe company has imparted trainings to all relevant employees in the month of February 2024 and August 2023.
CommunicationsThe company takes feedback from stakeholders if any risk identified and based on procedure to summaries the outcome of your engagement with relevant stakeholders.
OPTIONAL INFORMATION ON Step 4: Carry out independent third-party audit
Annual auditThe company has appointed an independent third-party auditor Mr. Jatin Patel who conducted audit twice in a year and last audit conducted for the period of October – 2023 to March - 2024 and no any non-conformances identified.
Grievances and remediationThe company has not received any grievance in the assessment year.