ANNUAL ETHICAL COMPLIANCE & OECD COMPLIANCE REPORT FOR THE FY 2024 - 25

Section A: General Information about the Company:

Company Background

Steckbeck Jewelry Pvt. Ltd. (SBJPL), has been manufacturing and exporting top-of-the-line diamond jewelry selections in Gold, Platinum, and Silver since 2003. SBJPL is a subsidiary of QUALITY GOLD INC. (QGOLD) based in Fairfield, Ohio. QGOLD has a strong presence in the business way back, since 1986. Today, we are known for our high-end unique jewelry selections for bridal wear and special occasions. With 27+ years of experience in the industry, our products come with a certificate of excellence ensuring high levels of satisfaction to our customers.

An understanding of the latest trends and fashions with ongoing market research allows us to remain at pace with the industry. We ensure that only the best product reaches our customers, and we are sure it will help us achieve a good and enduring relationship with our customers in future too. Steckbeck Jewelry employs the best talents in the gem and jewelry industry thus enabling unique creative inputs, and also taking care and ensuring that each design is special and offers greater perceived value to its / our buyers / customers. A reasonable pricing on best quality products, timely delivery of goods, strong network of retailers across the globe, and an uncanny ability to understand customer mindset are our main strengths. This has helped us to achieve much and maintain our strong presence the world over.

Section B: Financial compliance of the Steckbeck Jewelry Pvt Ltd:

2.1 Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

1. a. SBJPL recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
2. b. Strict compliance is ensured at all the entities and a Compliance Officer has been appointed who in turn reports to the Director/Management on compliance status on an annual basis.
3. c. Know Your Counter Party and other compliance of Due Diligence is followed in line with OECD guidance.
4. d .Ongoing monitoring is carried out along with all stakeholders.

Area of concern & Remedial Measures

1. a. Nil As on Date.

2.2 Kimberley Process and System of Warranties

1. a. Steckbeck Jewelry Pvt Ltd is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme of World Diamond Council’s (WDC) System of Warranties Declaration.
2. b. o day monitoring and compliance of SOW is done by compliance officer.
3. c. SBJPL is committed towards conflict free sourcing and zero tolerance policy

Area of concern & Remedial Measures

1. a. Nil As on Date.

2.3 Anti-Bribery and Facilitation Payment Policy:

1. a. Steckbeck Jewelry Pvt Ltd shall ensure complete prohibition Bribery and facilitation payment across organization.
2. b. SBJPL has published compliance team contact details on website to receive any grievance or complaints.

Area of concern & Remedial Measures

1. a. Nil As on Date.

2.4 Ethical Sourcing of Polished Diamonds & Precious Metal Policy:

1. a. Our company is concerned about the environment and social impacts of irresponsible suppliers.
2. b. SBJPL has identified the risk of supply chain with respect to Conflict Affected High Risk Area.
3. c. SBJPL ensure all its supplies are screened for conflict free supplies
4. d. We have published the OECD based ethical sourcing policy and we are communicating our policies to all the supply chain partners and pushing them to adopt the same.

Area of concern & Remedial Measures

1. a. Current concern is lack of awareness about OECD regulation and requirements of sourcing.
2. b. We have started creating awareness about our Ethical sourcing requirements for our supply chain.
3. c. We started Engagement with our global supply chain for obtaining the further supply chain information to ensure ethical and conflict free sourcing in jewellery business.

2.5 Social Compliance

1. a. We ensure full compliance with all applicable national and, where appropriate, international laws / regulations with respect to employment and labour codes in all our establishment
2. b. We respect all regulation for child labour, forced labour, non-discrimination, non-retaliation etc.
3. c. All work man rights are respected and adhere to freedom of association and collective bargaining regulations.

Area of concern & Remedial Measures

1. a. No point has been reported in the social compliance of the SBJPL where remedial measures at SBJPL level is required.

2.6 Health and Safety

1. a. We at Steckbeck Jewelry Pvt Ltd are concern about the health and safety of employees and are constantly studding about any adverse impact of our business processes are identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.
2. b. This review will use appropriate standards as required by prevailing laws, expert opinion, and our knowledge of best practices.
3. c. All our staff will be trained in the manner required to adhere to these work practices and drills
4. d. The health of our staff, exposed to certain hazardous processes, is be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
5. e. All workplaces are constructed to meet safety standards with local regulations as the minimum standards that will be applicable.

Area of concern & Remedial Measures

1. a. Nil as on date, as no accidents are reported in last one year.
2. a. Organization has been blessed, and we did not have any fire or any other incidents leading to dangerous circumstances.

2.7 Human Rights

1. a. SBJPL is not and will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation.
2. b. The Company strongly discourages any form of sexually coercive, threatening, abusive or exploitative behaviour.
3. c. Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company.
4. d. SBJPL ensures that none of its suppliers and stake holder have engaged in any activity which can violate the Human Right Principles.
5. e. We have carried out the Human Right Due Diligence of suppliers and other Stake holders & based on risk assessment where necessary.

Area of concern & Remedial Measures

1. a. No Area of concern & Remedial Measures has been raised in the Human right for any of our operating units.
2. a. Supplier’s further upstream compliance with respect to Human Right compliance for conflict free sourcing is a new development, where company is heading and would require more focus on the same.

2.8 Environment Protection

1. a. Steckbeck is Complying with all applicable environmental laws and regulations.
2. 1. a. Improvement is seen employee’s environmental awareness and performance with the help of detailed policies and procedures, training, and recognition of excellence.

Area of concern & Remedial Measures

1. a. Nil

ANNUAL REPORTING TEMPLATE (RJC TOOL KIT VERSION 5.0)
Company Name	Steckbeck Jewelry Pvt Ltd
Date	17th Sept, 2025
Reporting Period	April 2024 to March 2025
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	We have published the policy at company level for easy accesses to stakeholder. OECD and Best Practice Annual communication has been sent to all the active supplier Awareness presentation on Ethical sourcing based on OECD guideline has been circulated Detailed policy and procedure at entity level has been established based on risk of CAHRA’s is done
1.B Structure internal management systems to support supply chain due diligence	Additional responsibility has been assigned to Compliance officer to look over the compliance of Ethical souring policy. All key employees involved in souring and procurement of precious metals have been trained on our Ethical precious metal souring policy. Refresher trainings are provided. List of Suppliers has been maintained along with status of their social and ethical compliance On going monitoring of each supply and associated suppliers is carried out with the help of tools such as digital media, web search, review of supply documents, declaration and market intelligence etc
1.C Establish a system of controls and transparency over the minerals supply chain	Supplier upstream information collection process started and to obtained CAHRA’s information and Ethical sourcing compliance at supplier level Currently Source 85% supply from low risk and balance 15% is from non-regular suppliers based on Year 2024-25 and for year 2025-26 review is in process.
1.D Strengthen company engagement with suppliers	As mentioned above supplier questionnaire has been circulated and we are in the process of following up with them to obtained the filed information from them Further we are also obtaining the vital information about suppliers from social platforms and social compliance registration such as BPP & RJC Approved.
1.E Establish A Company-Level, Or Industry Wide, Grievance Mechanism as An Early Warning Risk - Awareness System	We have established the grievance handling policy and procedure at company level, contact details of compliance head provided in our Respnsible Sourcing Policy on our website (Which is publicly available)
Step 2: Identify And Assess Risk In The Supply Chain
Identify And Assess Risks in The Supply Chain and Assess Risks of Adverse Impacts	We have established the detailed policy and procedure for identification of risk at entity level We have trained compliance officer to oversee the financial and ethical sourcing compliances
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	Ongoing monitoring of each supply is done by Compliance officer to confirm its free from Conflict, where required Red Flags are been raised seeking additional information and closed after receiving such information to our satisfaction
Internal Training	SBJPL provides training to all the concern employee involved in buying and selling and compliance monitoring
Communications	We have published all the COP - Policies including responsible sourcing on the website
Prepared by & Approved By: Compliance Office
Date: 17th September 2025