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

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

We commit to:

  • Ethical business conduct
  • Respect for human rights
  • Environmental responsibility
  • Full product disclosure and integrity
  • Compliance with applicable laws and RJC Code of Practices (COP 2024)

1Purpose

This Code defines the ethical principles and professional standards that guide all activities of NOUVEAU GROUP in the lab-grown diamond and jewelry supply chain. Compliance is mandatory for everyone acting on behalf of NOUVEAU GROUP.

2Ethical Business Conduct

All business activities must be conducted with integrity, honesty, transparency, and 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

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

4Human Rights & Workplace Behaviour

NOUVEAU GROUP is committed to a safe, inclusive and respectful workplace. We do not tolerate child labour, forced labour, harassment, abuse, discrimination, or retaliation against whistleblowers.

5Product Integrity & Disclosure

All lab-grown diamonds must be accurately disclosed as lab-grown, properly segregated from natural diamonds, and correctly described in all documentation. Misrepresentation 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.

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.

Applies to: Lab-grown diamonds, seeds, reactors, growth materials, gold and precious metals used in jewelry.

1Scope

  • 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, and are traceable within our internal systems.

3Gold & Metals

Gold and metals are sourced only from legitimate, lawful suppliers and non-conflict, non-abusive sources.

4Due Diligence

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

Applies to: All NOUVEAU GROUP diamond, gold and jewellery operations.

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.

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

Applies to: All NOUVEAU GROUP diamond, gold and jewellery operations.

1Commitment

NOUVEAU GROUP is committed to protecting the environment and minimizing the environmental impact of our operations in accordance with the RJC Code of Practices (COP 2024) and applicable environmental laws. We recognize that responsible environmental management is essential to the sustainability of the diamond and jewellery industry.

2Environmental Responsibility

We commit to:

  • Efficient use of energy, water and raw materials
  • Reducing waste, emissions and pollution
  • Responsible management of chemicals and hazardous substances
  • Safe disposal and recycling of waste
  • Compliance with all environmental regulations

3Climate Responsibility

We seek continuous improvement in reducing our environmental footprint and carbon impact across all operations.

4Compliance

We comply with all applicable environmental laws, regulations and RJC requirements.

1Safety First

Employee health and safety is a core priority for NOUVEAU GROUP across all facilities and operations.

2Controls

We ensure:

  • Safe machinery and equipment at all times
  • Chemical and gas safety procedures are followed
  • Emergency preparedness and response plans are in place
  • Regular safety training for all employees

3Workplace Standards

All workplaces must meet applicable occupational health and safety laws. Risk assessments are conducted regularly and corrective actions taken promptly.

4Reporting

Unsafe conditions or incidents must be reported immediately to management without fear of retaliation.

1Expectations

All NOUVEAU GROUP suppliers must:

  • Comply with all applicable laws and regulations
  • Respect human rights and labour standards
  • Avoid bribery, corruption and financial crime

2Product Integrity

Suppliers must:

  • Accurately disclose all LGD products
  • Prevent undisclosed mixing of LGDs and natural diamonds
  • Cooperate fully with audits and due diligence requests

3Environment

Suppliers are expected to minimize environmental harm across their operations and comply with applicable environmental laws.

4Right to Review

NOUVEAU GROUP reserves the right to assess, audit or inspect suppliers at any time to verify compliance with this Code.

NOUVEAU GROUP encourages anyone to report concerns without fear. We are committed to maintaining the highest standards of integrity, transparency, and accountability.

Scope

This procedure applies to:

  • Employees
  • Customers
  • Suppliers and vendors
  • Contractors and business partners
  • Community members

Principles

  • 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

How to Raise a Complaint

Email: indo.compliance@nouveau-jewellery.com

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

Procedure & Timeline

  • Acknowledgment within 3 business days
  • Investigation typically completed within 10–15 business days
  • Resolution communicated with any corrective action taken

Escalation

If unsatisfied with the resolution, escalate in writing to Mr. Aalay Parikh at the address above.

Record Retention

All records relating to complaints and grievances shall be retained for a period of five years.

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

  • 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 and must not disclose it without authorization. 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, and 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 and use data only as contractually permitted.

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.

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