Annual Sustainability Report Statement 2026

98 Cuttermill Rd #231 • Great Neck • NY • 11021

516-498-8282 • Fax: 516-498-8484 • Orders: 888-426-1212

[email protected] • WWW.RomanAndJules.com

Roman & Jules Inc.

Annual Summary of Human Rights & Responsible Sourcing Due Diligence

Reporting Year: 2025/2026

1. Purpose and Scope

This statement summarises how Roman & Jules Inc. implemented its human rights and supply chain due diligence in accordance with the UN Guiding Principles on Business and Human Rights (UNGP), and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) 5-Step Framework during this reporting year.

2. Governance & Policy Commitments

Roman & Jules Inc. has:

A Human Rights Policy reflecting internationally recognised standards.
A Supply Chain Policy aligned with Annex II of the OECD Guidance.
A defined management structure for due diligence, including senior-level oversight.
Record-keeping systems to retain due diligence, supplier and transaction documentation for the required period.

These commitments are communicated to relevant employees and business partners and integrated into supplier onboarding and internal procedures.

3. Human Rights Due Diligence

Implementation

Roman & Jules Inc. conducted a structured human rights due diligence review covering: recruitment and employment practices, working hours and wages, non-discrimination, grievance mechanisms, workplace conduct, and key in-scope suppliers. The assessment drew on internal policies and records and supplier due diligence information.

Outcome:

No actual or potential human rights risks or impacts were identified in our operations or in-scope supply chain during this reporting period, based on available information and our risk-based assessment.
Existing grievance channels remained accessible; no human-rights-related complaints were received.

Roman and Jules Inc. will continue to conduct periodic reassessments, raise staff awareness, and monitor suppliers so that emerging risks can be identified and addressed.

4. Responsible Sourcing Due Diligence - OECD 5-Step Framework for Downstream Companies

Step 1 – Establish Strong Company Management Systems

Roman & Jules Inc. has:

Maintained and implemented its supply chain due diligence policy for relevant precious metals and precious stones.
Confirmed management responsibilities for the due diligence programme at senior and operational levels.
Operated record-keeping systems capturing supplier information, KYC, contracts, specifications and sourcing decisions.

Step 2 – Identify and Assess Risk in the Supply Chain

Roman & Jules Inc. has:

Mapped its upstream supply chain to identify refiners and the geographical origin of all in-scope materials.
Assessed suppliers’ due diligence practices using questionnaires, available certifications/assurance, and public information.
Applied a documented risk assessment methodology considering origin, refiner/supplier profile, product type and OECD red-flag indicators.

Outcome: For this period, no sourcing from Conflict-Affected and High-Risk Areas (CAHRAs) and no other OECD red flags were identified.

Step 3 – Design and Implement a Strategy to Respond to Identified Risks

Roman & Jules Inc. has:

A risk management framework, including escalation, engagement, enhanced due diligence, and potential disengagement.

Outcome: No instances of risk mitigation were required, and therefore, no follow-up cases arose.