Milros Responsible Business Practice Policy

The Responsible Jewellery Council (RJC) is a non-profit organization with the following
mission:
“To advance responsible ethical, social and environmental practices, which respect human
rights, throughout the gold and silver jewellery supply chain, from mine to retail”
Its "Code of Practices 2019" outlines the standards for responsible sourcing, human
rights, social responsibility, and environmental stewardship that all RJC members are
expected to follow. Milros Company, Inc. is a member of the Responsible Jewelry
Council (RJC) and is committed to adher to the Responsible Jewellery Council’s (RJC)
"Code of Practices 2019."
This commitment ensures that ethical, human rights, social, and environmental
considerations are integrated into every aspect of the company's operations. The
company's policies and guidelines related to commitment to RJC standards are detailed
in the Milros Company, Inc. employee guide and policy manual, which help employees
uphold these standards. Milros Company, Inc. encourages its business partners to
follow RJC requirements, with additional information available on the RJC website -
www.responsiblejewellery.com
Impact on SDGs

Milros Company, Inc. strictly prohibits child labor in any form, adhering to International
Labor Organization (ILO) convention 138 and 182. No individuals under the age of 15 or
the highest applicable legal minimum age as per ILO standards will be employed.
Adequate human resource systems and practices will ensure verification of employees'
ages, which includes written hiring policies, training, proof of age documentation, and
accurate record-keeping. Authorized adolescents (15-18 years) will have working
conditions and wages that comply with local laws. The company will not engage in or
support child slavery, debt bondage, trafficking, forced child labor, or use of children in
armed conflict. If a child is found working or its subcontractors, the management will take
responsibility for their rehabilitation, and all policies will be extended to subcontracted
labor also.
Impact on SDGs

Milros Company, Inc. pledges never to engage in or support forced labor practices such
as bonded labor, deceptive recruitment, human trafficking, involuntary prison labor and is
fully committed to eradicate it in all its facilities in accordance with International Labor
Organization (ILO) convention 29. Milros Company, Inc. shall also ensure that there is
no unrestricted freedom of movement for employees and dependents. Any incidents of
forced labor are treated as serious violations of business policies. The following
definitions will be applicable:
 The Universal Declaration of Human Rights that states that ‘No one shall be held in
slavery or servitude’

 ILO Convention 29, which defines forced or compulsory labour as ‘all work or service
which is extracted from any person under the menace of any penalty, and for which
the said person has not offered himself voluntarily”
Impact on SDGs

Milros Company, Inc. supports employees' rights to associate and collective bargain and strictly prohibits discrimination in hiring, discharge, pay, promotion, and training based on race, ethnicity, caste, national origin, religion, age, disability, gender, marital status, physical appearance, sexual orientation, HIV status, migrant status, worker representation, political affiliations, or any unlawful criteria. Employees with life-threatening illnesses will be treated equally, provided they are fit to work. Milros Company, Inc. forbids corporal punishment and any form of harsh or degrading treatment, harassment, or abuse.

Employees are encouraged to voice concerns about potential policy or law violations without fear of retaliation, with assurances of fair and respectful treatment and efforts to protect anonymity.

Milros Company, Inc. complies with national employment laws and maintains required records for all staff. It ensures work hours and overtime do not exceed legal limits, wages and benefits meet or exceed national minimum standards, providing for workers' basic needs. Wages are paid regularly with detailed wage slips, and wage deductions and follow due process. The company recognizes and supports worker representative bodies and addresses legitimate employee grievances. Dismissal procedures adhere to legal standards, avoiding arbitrary actions. Employment policies and working practices are communicated transparently, and Milros Company, Inc. is committed to providing fair and conducive employment conditions in line with laws and regulations.

Milros Company, Inc. ensures safe and healthy working conditions for all employees in compliance with applicable laws and industry standards. The company systematically reviews operations to identify and eliminate health and safety risks, providing adequate labeling and storage of chemicals and protecting employees from exposure to air bone particles and chemical fumes. Our process reviews based on legal standards, expert opinions, worker feedback, and best practices, will lead to clear work practices, safety drills. Employees are trained to adhere to these practices and must not be under the influence of drugs, alcohol, or illegal substances. Milros Company, Inc. seeks to substitute harmful materials, constructs workplaces to meet safety standards, and implements measures to protect employees from fire and other injuries. All products sold comply with health and safety regulations.

Milros Company, Inc. is committed to effective environmental performance by conducting business responsibly and complying with all environmental laws and regulations. The company will periodically assess and review the environmental impact of its operations to mitigate or eliminate it. Responsibly manages waste, emissions, by following legally defined waste disposal procedures. Employee environmental awareness and performance will be improved through training. Milros Company, Inc. will efficiently use energy and natural resources to minimize waste generation, with a commitment of continual improvement in environmental management.

Milros Company, Inc. prohibits all forms of workplace violence and harassment, including but not limited to corporal punishment, degrading treatment, and various forms of abuse or intimidation and ensures that employees are not subjected to harassment, violence, or threatened with these towards themselves, their family, or colleagues. The company respects fundamental human rights as outlined in the UN Universal Declaration of Human Rights, and treats employees with dignity and respect by ensuring fair discipline and grievance procedures, recognizing the right to association and collective bargaining, providing fair employment terms, and prohibiting discrimination based on personal characteristics unrelated to job requirements. Milros Company, Inc. is committed to providing a safe and healthy work environment, protecting human rights in business dealings, and expects adherence to these policies from all employees, suppliers, and customers.

Milros Company, Inc. defines bribery as giving, offering, or receiving any undue advantage to or from public officials, political entities, or private sector representatives. The company is committed to prohibit bribery in all its business practices and transactions carried out by the company or on its behalf by business partners, agents or employees, rejecting payments, gifts, or promises that compromise fair competition or influence business or government decisions. Milros Company, Inc. assesses bribery risks within the organization, including agents, and has developed monitoring methods to eliminate bribery. The company encourages reporting of attempted bribery or inappropriate gifts and applies appropriate sanctions for such actions. Employees are protected from demotion or penalties for voicing concerns or refusing to engage in bribery, even if it results in business loss.

Milros Company, Inc. is committed to establish and implement product security measures both within its premises and during shipments to prevent theft, damage, or substitution. The company prioritizes the security and well-being of employees, visitors, and business partners when establishing product security measures. Each and every stage of product processing is covered through blanket insurance. Suitable safe guarding and storage is ensured at all stage with the help of safes. All manufacturing, sales and retailing units are guarded by security agency and monitored by close circuit cameras. All concerned persons are trained on relevant safety and security procedures to be followed at all times.

Milros Company, Inc. acknowledges the responsibility of identifying potential vulnerabilities to money laundering in the gems and jewelry sector and implementing protective measures against criminal abuse. The company is committed to strict compliance with all relevant national and international laws regarding money laundering, terrorism financing, bribery, corruption, and other financial crimes. Employees are educated on regulatory requirements and must report suspicious activities to avoid policy violations. The company follows "Know Your Customer" and "Know Your Supplier" procedures to verify the identity and business legitimacy of all partners, ensuring the ability to detect and respond to unusual or suspicious transactions.

High standards are applied in selecting and screening suppliers and purchasers, ensuring anti-money laundering policies, continuous monitoring and relevant training are implemented. Financial auditors are informed of anti-money laundering rules applicable to precious stones and high-value goods dealings. Anti-Money Laundering (AML) and Know Your Counterparty (KYC) procedures are implemented to establish counterparties' identities, verify they are not on government watchlists, and monitor transactions for unusual activities. Records are maintained for at least five years, and transactions equal to or above €10,000euros / $10,000/USD are reported as required by law.

Milros Company, Inc. is dedicated to complying with relevant trading standards and national and local regulations for its products. The company's essential policies for gold and silver jewelry include:

• Disclosure: Accurate disclosure of material characteristics, including mass/weight, cut, color, clarity, or fineness, in line with RJC standards.
• Misrepresentation: Avoiding untruthful or misleading statements in the selling, advertising, or distribution of jewelry.
• Jewelry Quality: Describing jewelry attributes according to recognized guidelines.
• Full Disclosure: Providing complete information about the jewelry's characteristics and processing steps prior to sale, regardless of its effect on value.
• Terminology: Ensuring no misuse or misrepresentation of product terms in selling or advertising.

Security personnel, if employed by Milros Company, Inc. are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat.

Milros Company, Inc. is committed to the development of communities where it operates, contributing to their social and economic welfare.

Milros Company, Inc. is committed to responsible sourcing and ethical business practices in line with the Responsible Jewellery Council (RJC) Code of Practices. We adhere to international standards including the OECD Due Diligence Guidelines and the Universal Declaration of Human Rights.

Our policy includes:

• Due Diligence: Ensuring that all precious metals are sourced from legitimate and compliant suppliers.
• Prohibition of Conflict Materials: Avoiding procurement from conflict-affected and high-risk areas.
• AML and CFT Compliance: Design policies to prevent anti-money laundering and counter-terrorism financing measures.
• Training and Support: Providing regular training to employees and supporting business partners in understanding due diligence requirements and OECD guidelines.
• Risk Assessment: Regularly assessing supply chain risks and suspending relationships with suppliers involved in human rights violations, bribery, or corruption.
• Verification: Conducting Know Your Customer (KYC) checks and applying a risk-based approach to monitor activities and transactions.
• Compliance and Reporting: Assigning senior personnel to oversee compliance, with a grievance mechanism for confidential reporting of concerns.

• Periodic Reviews: Conducting management reviews, supplier questionnaires, and annual risk assessments to ensure ongoing compliance and address any issues.

It outlines our commitment to maintain the integrity of our supply chain and ensuring ethical practices throughout our operations.

Milros Company, Inc. is committed to treat all employees with equality, respect, and dignity. We maintain a safe environment free from sexual harassment, including safety from visitors. Any sexual advances, requests for sexual favors, or verbal and physical conduct of a sexual nature will not be tolerated, nor will sexual comments, jokes, gestures, or exhibition of pornography. We do not accept any form of harassment or abuse, including physical, sexual, racial, religious, psychological, or verbal. Milros Company, Inc. will address complaints of harassment by conducting inquiries, assisting victims, and taking necessary actions against perpetrators.