Responsible Business Practices Policy

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

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

[email protected] • WWW.RomanAndJules.com

Responsible Business Practices Policy

March 2026

Responsible Jewellery Council (RJC) policy

Roman & Jules Inc. is a member of the Responsible Jewellery Council (RJC).

The RJC is a standards-setting organisation established to advance responsible, ethical, human rights, social and environmental practices throughout the gold, silver, platinum group metals, diamond, coloured gemstone and lab-grown materials jewellery supply chain.

The RJC has developed a benchmark standard for the jewellery supply chain and credible mechanisms for verifying responsible business practices through third-party auditing.

As an RJC member, we commit to operating our business in accordance with the RJC Code of Practices (COP) Standard. We commit to integrating ethical, human rights, social and environmental considerations into our day-to-day operations, business planning activities and decision-making processes.

We commit to upholding the principles and intent of the RJC Code of Practices, as relevant to the scope of our business.

Human and Labour Rights

We are committed to respecting all human rights in our own operations and business relationships in accordance with the Universal Declaration of Human Rights (UDHR), the UN Guiding Principles on Business and Human Rights and relevant conventions of the International Labour Organization (ILO). Our human rights policy covers the following key commitments:

All forms of violence and harassment in the workplace are prohibited, including but not limited to corporal punishment; harsh or degrading treatment; sexual or physical harassment; mental, physical, verbal or sexual abuse; retaliation; coercion; and intimidation. Both direct and indirect harassment in any form is unacceptable in workplace facilities. This includes violence and harassment based on:
- Race
- Colour
- Ethnicity
- Caste
- National origin
- Religion
- Social aspects, including minority status
- Migrant worker status
- Disability or genetic information
- Gender
- Sexual orientation or other LBTQ status
- Union membership
- Political affiliation
- Marital status
To never engage in or knowingly support child labour (including the worst forms of child labour) as defined by International Labour Organisation (ILO) conventions 138 and 182;
To never engage in or knowingly support forced labour as defined by International Labour Organisation (ILO) Convention 29, including bonded labour, deceptive recruitment, human trafficking and indentured or involuntary prison labour;
To provide a safe and healthy working environment for employees and on-site contractors;
To prohibit all forms of discrimination, including but not limited to discrimination based on race, colour, ethnicity, caste, national origin, religion, disability or genetic information, gender, sexual orientation, union membership, political affiliation or partaking in a legal strike, marital status, parental or pregnancy status, physical appearance, HIV status, age or any other personal characteristic unrelated to the inherent requirements of the work.
To promote human rights in our dealings with business partners and other relevant stakeholders.
To promote worker diversity, equity and inclusivity at all levels of the organisation and across functions, including (but not limited to) recruitment, professional development and mobility, and equitable employment conditions.
To respect the rights of our employees to associate freely with worker unions of their choice and to engage in collective bargaining without fear of retaliation.

Bribery and Corruption

We prohibit bribery and corruption in all our business practices and transactions, including those carried out by agents acting on our behalf. For the purpose of this policy, bribery is defined as giving, offering or receiving any undue advantage to or from:

A public or government official;
A political candidate, party or official; or
Any private sector employees, directors, officers, or their agents or representatives.

Anti-Money Laundering and Financing of Terrorism

We commit to not engaging in or contributing to money laundering or the financing of terrorism. Roman & Jules Inc. has implemented Anti-Money Laundering (AML) and Know Your Counterparty (KYC) procedures to:

Establish the identity of all counterparties;
Verify that counterparties and, if applicable, beneficial owners are not named on relevant government lists for individuals or organisations implicated in money laundering, fraud or involvement with prohibited organisations and/or those financing conflict;
Maintain an understanding of the nature and legitimacy of the businesses operated by counterparties and;
Monitor transactions for unusual or suspicious activity.

Environmental Management

We have established an environmental management system relevant to the scope of our business. We will take all reasonable steps to minimise and/or mitigate adverse environmental impacts associated with our direct business operations.

Product Disclosure

We will not knowingly make any untruthful, misleading or deceptive representation or make any material omission in the selling, advertising or marketing of jewellery products and materials. We further commit to disclosing information on the physical characteristics of our jewellery products and materials in accordance with the Responsible Jewellery Council (RJC) Code of Practices Standard.

Supply Chain Policy – Conflict-Affected and High-Risk Areas (CAHRAs)

This policy confirms our commitment to respect human rights, to avoid contributing to the financing of conflict, and to comply with all relevant UN sanctions, resolutions, and laws.
As a member of the Responsible Jewellery Council (RJC), we commit to proving, through independent third-party verification, that we:
1. respect human rights according to the Universal Declaration of Human Rights and the International Labour Organization Declaration on Fundamental Principles and Rights at Work;
2. do not engage in or tolerate bribery, corruption, money laundering or financing of terrorism;
3. support transparency of government payments and rights-compatible security forces in the extractives industry;
4. do not provide direct or indirect support to illegal armed groups;
5. enable stakeholders to voice concerns about the jewellery supply chain; and
6. are implementing the OECD Due Diligence Guidance 5-Step Framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.
We also commit to using our influence to prevent abuses by others.
Regarding serious abuses associated with the extraction, transport or trade of gold, silver, platinum group metals, diamonds and coloured gemstones: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:
1. torture, cruel, inhuman and degrading treatment;
2. forced or compulsory labour;
3. the worst forms of child labour;
4. human rights violations and abuses; or
5. war crimes, violations of international humanitarian law, crimes against humanity or genocide.
We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing the abuses described in paragraph 4, or sourcing from or being linked to any party committing these abuses.
Regarding direct or indirect support to non-state armed groups: We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gold, silver, platinum group metals, diamonds and coloured gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:
1. control mine sites, transportation routes, points where gold, silver, platinum group metals, diamonds and coloured gemstones are traded and upstream actors in the supply chain; or
2. tax or extort money, or minerals at mine sites, along transportation routes, or at points where gold, silver, platinum group metals, diamonds, and coloured gemstones are traded, or from intermediaries, export companies, or international traders.
We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.
Regarding public or private security forces: We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4, or that act illegally as described in paragraph 6.
Regarding bribery and fraudulent misrepresentation of the origin of gold, silver, platinum group metals, diamonds and coloured gemstones: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, silver, platinum groups metals, diamonds and coloured gemstones, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold, silver, platinum groups metals, diamonds and coloured gemstones.
Regarding money laundering: We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of gold, silver, platinum group metals, diamonds and coloured gemstones.

Roman & Jules Inc. expects all of its employees, suppliers and, where applicable, their subcontractors, to take all steps necessary to ensure that this policy is adhered to.

Company Grievance Procedure

Roman & Jules Inc. has established this procedure to hear any concerns or complaints from interested parties and stakeholders regarding its supply chain and business practices.

Concerns can be raised by interested parties via email using the following contact information:

Name: David Hematian

Email: [email protected]

On receiving a complaint, we will aim to:

Contact you as soon as possible to gather more information regarding your grievance, where applicable.
Decide who the appropriate internal person is to handle the grievance, or help redirect you to another entity, such as a relevant company, industry body, or other organisation.
Identify any actions we should take (if any) or monitor the situation.
Advise you of any decisions or outcomes.
Keep records of grievances received and the internal process followed to address them for at least 5 years.

Roman & Jules Inc. operates a strict non-retaliation policy in relation to all complaints and grievances raised through this procedure. All information provided will be treated as strictly confidential and will not be shared with any external party without the prior consent of the person(s) raising the concern, unless required by law. Roman & Jules Inc. also accepts anonymous reports, which may be submitted via the above email address or by post to the following address: 98 Cutter Mill Rd #227, Great Neck Plaza, NY 11021, USA.

This policy is endorsed by David and Shawn Hematian (Owners)

Roman & Jules Inc.

Anti-Bribery Policy and Procedure

Updated: April 2026

1. Purpose

The purpose of this Policy is to assist staff and agents (including consultants, advisers, intermediaries or any other individual or business that acts on behalf of Roman & Jules Inc. (hereinafter referred to as “Company”) in identifying anti-bribery and corruption-related issues and in understanding and complying with our related procedures.

2. What is bribery?

Bribery means giving or offering (as well as demanding or receiving) any undue advantage to or from:

A public or government official
A political candidate, party or official, or
Any private sector employees, directors or officers, or their agents or representatives

3. Zero tolerance policy statement

The Company prohibits bribery and corruption in all business practices and transactions carried out by its staff and by agents acting on its behalf.

All staff and agents of the Company are protected from any penalty or adverse consequences for identifying concerns related to suspected bribery, for refusing to participate in bribery or for refusing to pay a facilitation payment.

Staff and agents of the Company must not engage in bribery in connection with any dealings or activities involving private or public companies, government or public officials, organisations or individuals.

4. Facilitation payments

Facilitation payments are sums of money paid to obtain preferential treatment for something the recipient would otherwise still be required to do.

Facilitation payments of any kind are strictly prohibited under this policy. Staff or agents who are asked to make a facilitation payment should immediately report this to [name of responsible person].

5. Gifts and hospitality

Staff and agents acting on behalf of the Company must never use gifts or hospitality to improperly influence the business decision-making process or cause others to perceive an improper influence.

Gifts or hospitality above must be recorded in the Gifts and Hospitality Register. Gifts and hospitality should be offered only to better present our products or to establish cordial relations with prospective business partners. Staff and agents must disclose if they have been offered gifts and/or hospitality.

6. Charitable and political donations

Charitable donations will never be made to influence a business decision-making process. All such donations (if made) will be made directly to selected charitable organisations and never to an individual. The Company does not make political donations of any kind.

7. Use of cash

No payment to or from any business counterparty shall be made in cash. Any exception to this rule requires advance written approval from David Hematian.

8. Reporting

Any staff or agents who identify (or suspect) instances of bribery should report this immediately to:

Name: David Hematian, Vice President

Email: [email protected]

9. Investigation and sanctions

All actual or suspected cases of bribery will be fully investigated. Staff and agents found to be in breach of this policy could face disciplinary action.