Corporate Policies

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

All employees and business partners must comply with:

• Applicable local and international laws
• Trade, customs and sanctions regulations
• RJC Code of Practices (COP 2024)

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

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.

We strictly prohibit:

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

We ensure:

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

This policy applies to:

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

We ensure that LGDs:

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

Gold and metals are sourced only from:

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

• 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

We maintain:

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

NOUVEAU GROUP has zero tolerance for:

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

We apply:

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

We aim to:

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

We ensure:

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

All suppliers must:

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

Suppliers must:

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

We encourage anyone to report concerns without fear.

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.

This procedure applies to:

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

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

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

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.

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

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

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.

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.

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.

This policy covers:

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

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

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.

NOUVEAU GROUP implements reasonable safeguards, including:

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

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