Our Commitment


NOUVEAU GROUP is committed to conducting its business responsibly, ethically and transparently across the lab-grown diamond and jewelry supply chain.

We commit to:


This policy applies to all employees, directors, contractors, suppliers and business partners.

COMPANY CODE OF CONDUCT


1Purpose

This Code of Conduct defines the ethical principles and professional standards that guide all activities of NOUVEAU GROUP in the lab-grown diamond and jewelry supply chain.

Compliance with this Code is mandatory for everyone acting on behalf of NOUVEAU GROUP.

2Ethical Business Conduct

All business activities must be conducted with:

  • Integrity
  • Honesty
  • Transparency
  • fair dealing

We strictly prohibit:

  • Bribery, corruption or facilitation payments
  • Fraud, theft or misrepresentation
  • Money laundering or terrorist financing
  • Deceptive or misleading marketing practices

3Compliance with Laws

All employees and business partners must comply with:

4Human Rights & Workplace Behaviour

NOUVEAU GROUP is committed to:

  • Respecting human rights
  • Providing a safe, inclusive and respectful workplace

We do not tolerate:

  • Child labour or forced labour
  • Harassment, abuse or discrimination
  • Retaliation against whistleblowers

5Product Integrity & Disclosure (LGD-Specific)

All lab-grown diamonds and LGD jewelry must be:

  • Accurately disclosed as lab-grown
  • Properly segregated from natural diamonds
  • Correctly described in invoices, marketing and documentation

Misrepresentation of lab-grown diamonds as natural diamonds is strictly prohibited.

6Conflicts of Interest

Employees must avoid situations where personal interests conflict with NOUVEAU GROUP's interests. Any actual or potential conflict must be disclosed to management.

7Confidential Information

All confidential, proprietary and customer information must be protected and used only for legitimate business purposes.

8Reporting Concerns

Violations must be reported to: indo.compliance@nouveau-jewellery.com. Reports will be handled confidentially and without retaliation.

9Disciplinary Action

Violations may result in disciplinary action, including termination of employment or business relationships.

HUMAN RIGHTS POLICY


1Commitment

NOUVEAU GROUP respects internationally recognized human rights and aligns with the UN Guiding Principles on Business and Human Rights and ILO conventions.

2Zero Tolerance

We strictly prohibit:

  • Child labour
  • Forced, bonded or involuntary labour
  • Human trafficking
  • Harassment, abuse or discrimination

3Fair Work

We ensure:

  • Legal wages and working hours
  • Freedom of association
  • Safe and healthy workplaces
  • Equal opportunity for all workers

4Supply Chain

Suppliers must respect human rights and comply with all applicable labour laws.

5Grievance

Concerns may be reported confidentially to: indo.compliance@nouveau-jewellery.com.

No retaliation is permitted.

RESPONSIBLE SOURCING POLICY (LGD & GOLD)


1Scope

This policy applies to:

  • Lab-grown diamond rough and polished
  • Seeds, reactors and growth materials
  • Gold and precious metals used in jewelry

2Lab-Grown Diamonds

We ensure that LGDs:

  • Are produced using legitimate CVD or HPHT processes
  • Are not misrepresented as natural diamonds
  • Are traceable within our internal systems

3Gold & Metals

Gold and metals are sourced only from:

  • Legitimate, lawful suppliers
  • Non-conflict and non-abusive sources

4Due Diligence

We conduct risk-based supplier due diligence and disengage where unacceptable risks are identified.

PRODUCT DISCLOSURE & LGD INTEGRITY POLICY


1Transparency Commitment

NOUVEAU GROUP guarantees full, clear and accurate disclosure of lab-grown diamonds at all stages of sale and marketing.

2Disclosure Rules

  • All LGDs are clearly described as "Lab-Grown Diamonds"
  • No LGD is sold, marketed or invoiced as a natural diamond
  • Any treatments applied to LGDs are fully disclosed

3Segregation Controls

We maintain:

  • Physical segregation of LGDs from natural diamonds
  • Separate inventory records for LGDs and natural diamonds
  • Clear labelling and invoicing systems

4Marketing Integrity

All advertising, digital content and certificates accurately represent LGDs without misleading terminology or omissions.

ANTI-BRIBERY, ANTI-CORRUPTION & AML-CFT POLICY


1Zero Tolerance

NOUVEAU GROUP has zero tolerance for:

  • Bribery or corruption of any kind
  • Facilitation payments
  • Fraud or false accounting
  • Money laundering or terrorist financing

2AML & KYC

We apply:

  • Customer and supplier Know Your Customer (KYC) checks
  • Sanctions and watchlist screening
  • Monitoring of suspicious transactions

3Gifts & Hospitality

Gifts and hospitality must be reasonable, transparent and must never influence or appear to influence business decisions.

4Reporting

Suspected violations must be reported immediately to: indo.compliance@nouveau-jewellery.com

ENVIRONMENTAL POLICY


1Commitment

NOUVEAU GROUP recognizes the environmental impact of LGD manufacturing and commits to responsible environmental management.

2Focus Areas

We aim to:

  • Improve energy efficiency in reactors and facilities
  • Reduce water consumption
  • Minimise waste and emissions
  • Safely manage chemicals and gases

3Climate Responsibility

We seek continuous improvement in reducing our environmental footprint.

4Compliance

We comply with all applicable environmental laws, regulations.

OCCUPATIONAL HEALTH & SAFETY POLICY


1Safety First

Employee health and safety is a core priority.

2Controls

We ensure:

  • Safe machinery and equipment
  • Chemical and gas safety procedures
  • Emergency preparedness
  • Regular safety training

3Reporting

Unsafe conditions must be reported immediately without fear of retaliation.

SUPPLIER CODE OF CONDUCT


1Expectations

All suppliers must:

  • Comply with laws and regulations
  • Respect human rights
  • Avoid bribery, corruption and financial crime

2Product Integrity

Suppliers must:

  • Accurately disclose all LGD products
  • Prevent undisclosed mixing
  • Cooperate fully with audits and due diligence

3Environment

Suppliers are expected to minimize environmental harm.

4Right to Review

NOUVEAU GROUP reserves the right to assess or audit suppliers.

COMPLAINTS AND GRIEVANCE PROCEDURE


OUR COMMITMENT

We encourage anyone to report concerns without fear.

POLICY

NOUVEAU GROUP seeks to maintain its reputation in the Lab Grown Diamond & Jewelry industry. The management of NOUVEAU GROUP is committed to maintaining its responsiveness to the needs and concerns of its employees, customers, suppliers and other stakeholders.

At NOUVEAU GROUP, we are committed to maintaining the highest standards of integrity, transparency, and accountability in all our dealings. We recognize that employees, customers, suppliers, and other stakeholders may, at times, have concerns or grievances. This Complaints and Grievance Procedure is designed to ensure that all such matters are addressed promptly, fairly, and effectively.

Scope

This procedure applies to:

  • Employees
  • Customers
  • Suppliers and vendors
  • Contractors and business partners
  • Business partners
  • Community members and other stakeholders

Principles

We are committed to ensuring that:

  • Complaints are taken seriously and handled professionally
  • All parties are treated with respect and fairness
  • Complaints are resolved in a timely manner
  • Confidentiality is maintained throughout the process
  • Retaliation against complainants will not be tolerated

RAISING A COMPLAINT

Where a complaint is about a particular engagement, product or staff, the complainant can address his complaint to an appropriate member of that engagement team, orally, by letter, email or fax. Where possible, complaints should be made in writing so that the details of the complaint are clear and complete.
For Grievances Redressal a single point platform to submit or register your grievances e-mail to indo.compliance@nouveau-jewellery.com or write to us at:

Indojewel Jewellery Pvt. Ltd.
Attn: Compliance Department
Multi-Storied Building, 001 & 003, Seepz,
Andheri East, Mumbai, Maharashtra – 400096, India

INFORMATION TO INCLUDE

Please provide the following details to help us address your concern effectively:

  • Full name and contact details
  • Relationship to the company (employee, customer, supplier, etc.)
  • Detailed description of the issue
  • Any relevant dates, documents, or evidence
  • Expected resolution or outcome

PROCEDURE AND TIMELINE

  1. Acknowledgment
    • You will receive an acknowledgment within 3 business days of submitting your complaint.
  2. Investigation
    • An impartial investigation will be initiated.
    • We may contact you for additional information.
    • This process is typically completed within 10–15 business days, depending on the complexity of the matter.
  3. Resolution
    • We will communicate the outcome and any corrective action taken.
    • If further time is needed, you will be informed of the updated timeline.

ESCALATION

If you are unsatisfied with the outcome or handling of your complaint, you may escalate the matter by writing to:

Mr. Aalay Parikh
Add: Multi-Storied Building, 001 & 003,
Seepz, Andheri East,
Mumbai, Maharashtra - 400096
India

CONFIDENTIALITY AND PROTECTION

All complaints will be handled confidentially to the extent possible. Whistleblowers and complainants are protected from retaliation under our company's ethics policy.

CONTINUOUS IMPROVEMENT

We use complaints and feedback as a tool for continuous improvement in our operations and stakeholder relationships. Lessons learned may lead to changes in our processes or policies.

CONTACT US

If you have any questions about this procedure or need assistance submitting a complaint, please contact our Compliance Team at indo.compliance@nouveau-jewellery.com.

RETENTION OF RECORDS

All records relating to any complaints and grievance, legal allegation, report of a retaliatory act or the investigation of any such report shall be retained for a period of five years.

DATA PROTECTION & CONFIDENTIALITY POLICY


1Purpose

NOUVEAU GROUP is committed to protecting the confidentiality, integrity and lawful use of personal, commercial and business data obtained through its operations.

2Scope of Data

This policy covers:

  • Employee personal data
  • Customer and supplier data
  • Business and financial information
  • Intellectual property and technical data

3Data Protection Principles

NOUVEAU GROUP commits to:

  • Collecting data lawfully and fairly
  • Using data only for legitimate business purposes
  • Protecting data from unauthorized access, loss or misuse
  • Retaining data only for as long as necessary

4Confidentiality Obligations

Employees and partners must:

  • Keep confidential information secure
  • Not disclosing confidential data without authorization
  • Use company information only for approved business purposes

Confidential information includes pricing, customer lists, designs, LGD production data, reactor parameters, sourcing records and internal reports.

5Information Security

NOUVEAU GROUP implements reasonable safeguards, including:

  • Access controls
  • Password protection
  • Secure storage of physical and electronic records

6Third-Party Data Handling

Suppliers and service providers with access to NOUVEAU GROUP data must:

  • Protect data confidentiality
  • Use data only as contractually permitted
  • Comply with applicable data-protection laws

7Breach Reporting

Any suspected data breach must be reported immediately to management or at: indo.compliance@nouveau-jewellery.com

8Non-Retaliation

No individual will face retaliation for reporting data-protection concerns in good faith.