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MK Luxury Group have undertaken to implement practices and procedures for responsible sourcing and social
responsibilities in accordance with the RJC guidelines. We commit to integrating ethical, human rights, social and
environmental considerations into our day-to-day operations, business planning activities and decision-making
processes. MK believes that a responsible conflict-free supply chain is fundamental to the reputation of the diamond
and jewelry industry. Our framework:

Establish Management System

A -
Supply chain policy – our efforts ensure that we source precious metals and diamonds only from legitimate and ethical sources, and they have not associated with crime, armed conflict, or human rights abuse. We don’t tolerate or want to be linked to:

1. Torture, cruel, inhuman, and degrading treatment
2. Worst forms of child labour or any form of forced labour
3. Corruption or any other illegal activities or bribery (offering, promising, giving, demanding, accepting undue advantage, or obtaining preferential treatment)
4. Violations of international humanitarian law
5. Direct or indirect support to non-state armed groups
6. Misrepresentation of origin of minerals

B - Supplier Engagement - we aim to establish long-term relationships with our suppliers. MK exercises due diligence with their suppliers consistent with the OECD Guidelines. MK Supplier Protocol introduces Suppliers to practices and procedures required by MK management. MK expects suppliers of precious metals and diamonds to take appropriate steps to ensure they adopt similar policy and that provisions of this policy are communicated to their employees and down their supply chain. MK relies on the Suppliers’ full support in meeting the requirements of MK’s business requests and each Supplier ensures that all staff that support MK’s business are fully conversant with and will abide by its policies and procedures.

C - Internal Capacity- MK ensures all staff are trained and assigned responsibilities that hold them accountable.
The Compliance Officer has the authority to deny suppliers classified as high risk.

D - Internal Control- MK builds system of control to know our Counterparty (KYC), gathers data on Suppliers’
chain of minerals supply over gold and diamonds, requires suppliers of minerals to maintain the highest
standards in supply chain management, ensuring that precious metals and diamonds are ethically sourced.
MK will stop engaging with suppliers if a reasonable risk for committing abuses is found.

E - Grievance Mechanism- MK has an open-door policy system and everyone can report issue they spot.
Employees, agents or suppliers who report any issue will not be terminated, suffer adverse consequences,
or be retaliated against for their concerns to management. MK implemented a Grievance Mechanism to
stakeholders. Such concerns are treated discreetly and strictly confidential. Suppliers are expected to set-up
a system for grievance mechanism.