Our Policies

1. Legislation and Regulations

1. SPARK JEWELRY PVT. LTD. shall operate in compliance with relevant national and international legislations / regulations as applicable in the countries in which they operate.
2. All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal SPARK JEWELRY PVT. LTD. rules and policies relating to their business activities
3. It is the responsibility of personnel to know and understand legal, regulatory and internal requirements as they apply to their jobs.
4. Compliance team maintains the list of applicable legal and regulatory requirements and same is followed for compliance on day-to-day basis. Necessary records of requirements and its compliance is maintained.

2. Money Laundering, Terrorism Financing, Other Financial Offences

1. SPARK JEWELRY PVT. LTD. recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
2. SPARK JEWELRY PVT. LTD. shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations. Following acts and international guidelines is considered while establishing company level policies
   
   

   ■ Prevention of Money laundering Act 2002

   ■ FATF 40 Recommendations and 8 special recommendations

3. It is the responsibility of concerned personnel to know and understand the relevant money laundering / financial offences related legal, regulatory and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious activity that appears to be questionable may also be considered as a violation of the Business Principles, depending on the seriousness of the non-conformance.
4. Compliance officers ensure all the critical steps such as KYC & KYS, Identification of suspicious transaction, reporting to management and record keeping as required by the local act and legislations are complied with.
5. Compliance officer caries out periodic review of AML/CFT compliances and submits his report to management on Quarterly basis.

3. Kimberley Process and System of Warranties

1. SPARK JEWELRY PVT. LTD. is dealing in polished diamonds and fully committed to complying with all the requirements specified in World Diamond Council’s (WDC) System of Warranties Declaration.
2. We will not engage in business with the supply chain who deals in ‘conflict diamonds’ or not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, will be considered as a violation of the Business Principles.

4. Anti-Bribery and Facilitation Payment Policy

1. SPARK JEWELRY PVT. LTD. shall ensure complete prohibition of Bribery and facilitation payment across organization and in all the entities.
2. SPARK JEWELRY PVT. LTD. will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.
3. Entity shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land

5. Disclosure of Treated Diamonds, Synthetics and Stimulant

The following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and stimulants.

6. Diamond & Gemstone Sourcing Policy

Conflict Minerals Policy Statement (Diamond & Gemstone)

SPARK JEWELRY PVT. LTD. is committed to being a responsible corporate citizen and is opposed to human rights abuses. As part of that commitment, SPARK JEWELRY PVT. LTD. seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility

SPARK JEWELRY PVT. LTD. shall strive to ensure that all its supply of diamonds is not originating from CAHRA’s and where practically possible origin of diamonds is known to us.

What Are "Conflict Diamonds"?

Blood Diamonds, also known as "Conflict Diamonds” are stones that are produced in areas controlled by rebel forces that are opposed to internationally recognized governments. The rebels sell these diamonds, and the money is used to purchase arms or to fund their military actions.

Blood Diamonds are often produced through the forced labour of men, women and children. They are also stolen during shipment or seized by attacking the mining operations of legitimate producers. These attacks can be on the scale of a large military operation.

The stones are then smuggled into the international diamond trade and sold as legitimate gems. These diamonds are often the main source of funding for the rebels; however, arms merchants, smugglers, and dishonest diamond traders enable their actions. Enormous amounts of money are at stake, and bribes, threats, torture, and murder are modes of operation. This is why the term "blood diamonds" is used.

CAHRAs are.

SPARK JEWELRY PVT. LTD. ensures that none of its supplies come from the aforesaid countries/regions. SPARK JEWELRY PVT. LTD. shall communicate its sourcing policy to all its stakeholders and will ensure effective implementation of its policy amongst all its entities.

SPARK JEWELRY PVT. LTD. shall ensure that none of its supplies come from CAHRA Region sources. For More Details of CAHRA’s refer to list of country under the regulation of EU 2017 https://www.cahraslist.net/cahras

7. Gold & Platinum Group Of Metal Sourcing Policy

Our Company is concerned about environment and social impacts of irresponsible mining.

We at SPARK JEWELRY PVT. LTD. shall ensure that all our gold suppliers are in compliance with gold souring guidelines (Dodd- Frank rules, DRC & other applicable legislation)

Further, we are committed to ensure that sourcing of gold and precious metal products and articles thereof, are under the highest Social, Human right and Environmental standard cautions of trade.

8. Supply Chain Management / Best Endeavours

The management of SPARK JEWELRY PVT. LTD. is committed to take appropriate action to use best endeavours to ensure that the suppliers and contractors are committed for compliance to International Social Standards such as RJC & SMETA etc.

9. Employment

1. Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.
2. The SPARK JEWELRY PVT. LTD. shall not require Staff to work for more than the national limit of hours in a week on a regular basis.
3. SPARK JEWELRY PVT. LTD. shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards.

10. Health and Safety

SPARK JEWELRY PVT. LTD. recognizes the need to develop a sustainable, valuecreating business and is committed to the following:

11. Non-Discrimination, Disciplinary Practices

1. Discrimination can mean distinction, exclusion or preference.
2. Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by the SPARK JEWELRY PVT. LTD. any such reported incidents will be viewed as a serious violation of this Business Principles.
3. We shall at no time condone the use of corporal punishment or other forms of mental or physical coercion.
4. We encourage all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, SPARK JEWELRY PVT. LTD. operation or practice is or will likely be in violation of any law, regulation or internal rule or policy, including this Business Principles

12. Child Labour

1. No form of child labour should be employed at any of the facilities of the SPARK JEWELRY PVT. LTD. Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138)
2. For authorized adolescents (persons below 18 years of age but above 15 years), the SPARK JEWELRY PVT. LTD. Management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
3. As per our SPARK JEWELRY PVT. LTD. policy no child labour or adolence child labour will be employed.
4. SPARK JEWELRY PVT. LTD. will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

13. Forced Labour

1. The management of SPARK JEWELRY PVT. LTD. is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of this Business Principles.
2. The following definitions will be applicable:

   ■ The Universal Declaration of Human Rights that states that ‘No one shall be held in slavery or servitude’

   ■ ILO Convention 29, which defines forced or compulsory labour as ‘all work or service which is extracted from any person under the menace of any penalty, and for which they said person has not offered himself voluntarily”

14. Human Rights

1. All employees in the SPARK JEWELRY PVT. LTD. facilities will be treated with equality, respect and dignity
2. SPARK JEWELRY PVT. LTD. will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation
3. SPARK JEWELRY PVT. LTD. strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.

15. Environment Protection

SPARK JEWELRY PVT. LTD. is committed to effective environmental management as one of its important corporate priorities, and will focus on the following initiatives:

1. Compliance with all applicable environmental laws and regulations
2. The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards and reviewed periodically to mitigate or eliminate such impact.
3. Disposal procedures for waste generated will be clearly defined and practiced in line with standards that are set by law and best practices of the industry.
4. Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.

16. Product Security

SPARK JEWELRY PVT. LTD. is committed to provide safety of product throughout its supply chain by following precaution as mentioned below

1. Each and every stage of product processing it is covered through blanket insurance
2. Suitable safeguarding and storage is ensured at all stage with the help of safes
3. We are taking at most care to ensure safety of visitors, Customers and interested parties, suitable arrangements such as CCTV, Multi level entry doors and other electronic intelligence.
4. All the concern persons are trained on relevant safety and security procedures to be followed at all times

Public Grievances against social & Ethical compliance of the SPARK JEWELRY PVT. LTD

If you come across any instance of non-compliance or specific deviation from our ethical policy, please feel free to reach us.

Further in case if you are interested to obtain the copy of our sourcing annual compliance report based on OECD guidelines. Please send an email communication to below mention email address.

Sr No.	Mode
(i)	By hand	Mr. Nimit Parikh (Director)
(ii)	By Email	admin@sparkjewelry.co.in

BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR THE YEAR 2024 DATED: 2^nd May 2025

Section A: General Information about the Company:

At Spark Jewelry, we believe in the transformative power of adornment. Founded on the principles of creativity, craftsmanship, and passion, we specialize in creating exquisite handcrafted pieces that celebrate life's most cherished moments.

Our journey began with a vision to redefine the boundaries of traditional jewelry design. Guided by a commitment to innovation and excellence, we blend timeless elegance with contemporary flair to craft pieces that resonate with sophistication and style.

Each Spark Jewelry creation is meticulously crafted by skilled artisans who infuse their expertise and artistry into every detail. From the selection of the finest materials to the precision of the finishing touches, our dedication to quality ensures that each piece is a masterpiece to be treasured for generations.

More than just accessories, our jewelry pieces are expressions of individuality and emotion. Whether it's a symbol of love, a token of achievement, or a reflection of personal style, we believe that every piece tells a story and becomes a cherished part of life's journey.

At Spark Jewelry, we invite you to discover a world of elegance, beauty, and inspiration. Join us as we continue to spark joy and create moments that shine bright with brilliance and meaning.

1. Money Laundering, Terrorism Financing, Other Financial Offences Current Status

2. Kimberley Process and System of Warranties

3. Anti-Bribery and Facilitation Payment Policy:

4. Ethical Sourcing of Loose Diamonds Policy:

5. Social Compliance:

6. Health and Safety:

7. Human Rights:

8. Environment Protection:

ANNUAL REPORTING TEMPLATE (RJC TOOL KIT VERSION 5.0)
Company Name:	SPARK JEWELRY PVT. LTD.
Reporting Period :	Calendar Year 2024-25
Step 1: Establish strong company management systems
1.A. Adopt and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict- affected and high-risk areas	■ We have published the policy at company level for easy accesses to stakeholder. ■ OECD and Best Practice Annual communication has been sent to all the active suppliers. ■ Awareness presentation on Ethical sourcing based on OECD guideline has been circulated. ■ Detailed policy and procedure at entity level has been established based on risk of CAHRA’s is done.
1.B Structure internal management systems to support supply chain due diligence.	■ Additional responsibility has been assigned to Compliance officer to look over the compliance of Ethical souring policy. ■ All key employees involved in souring and procurement of precious metals have been trained on our Ethical precious metal souring policy. latest trainings are provided. ■ List of Suppliers has been maintained along with status of their social and ethical compliance. ■ On going monitoring of each supplies and associated suppliers is carried out with the help of tools such as digital media, web search, review of supply documents, declaration and market intelligence etc.
1.C Establish a system of controls and transparency over the minerals supply chain.	■ Supplier upstream information collection process started and to obtained CAHRA’s information and Ethical sourcing compliance at supplier level. ■ Currently SPARK JEWELRY PVT. LTD. 90% supply from low risk and balance10% is from non-regular suppliers.
1.D Strengthen company engagement with suppliers.	■ As mentioned above supplier questionnaire has been circulated and we are in the process of following up with them to obtained the filed information from them. ■ Further we are also obtaining the vital information about suppliers from social platforms and social compliance registration such as BPP & RJC, Approved ASM programs etc ■ We are in the process of compiling filled supplier questionnaire data, after analysis we will be formulate supplier engagement practices based on risk reported at each supplier level (if any)
1.E Establish A Company-Level, Or Industry Wide, Grievance Mechanism As An Early Warning Risk-Awareness System	■ We have established the grievance handling policy and procedure at company level, contact details of compliance head provided in our Social and Ethical policy on our Web site under Business Principle Section ( which is publicly available)
Step 2: Identify And Assess Risk In The Supply Chain
Identify And Assess Risks In The Supply Chain And Assess Risks Of Adverse Impacts.	■ We have established the detailed policy and procedure for identification of risk at entity level. ■ Entity has appointed and trained compliance officer to oversee the financial and ethical sourcing compliances. ■ We have categorized supply chain in to two major segments that its Secondary supplier and Open market suppliers. ■ All suppliers are bifurcated in to this category and open market supplies are considered as potential risk for supplies from CAHRA’s and thus step by step information are gathered from this category of supplier as mentioned in point 1.B & 1.C.
Step 3: Design And Implement A Strategy To Respond To Identified Risks (If Applicable)
Report Findings Of The Supply Chain Risk Assessment To The Designated Senior Management Of The Company.	■ Ongoing monitoring of each supplies is done by compliance officer to confirm its free from Conflict, were required Red Flags are been raised for seeking additional information and closed after receiving such information to our satisfaction. ■ Entity level compliance officer shall report all un-answered flags to local management and compliance officer. ■ In worst situation were information is half or not satisfactory management starts engagement practice and discussion and dialogue with suppliers is carried out to ensure full information in further business.
Devise And Adopt A Risk Management Plan.	■ We have formulated the risk management plans at entity level considering individual entities position in supply chain and position of supplier in supply chain. ■ Entity compliance officer carries out monitoring of each and every business transactions and were required Red Flags are been raised and further steps are followed as mention above. ■ Brief of companies Risk Management Practices has been mentioned in communication of Business policy on our website.
Implement The Risk Management Plan And Monitor Performance Of Risk Mitigation Efforts.	■ Entity level and level monitoring of Red Flags and its effective closure is monitored. ■ Compliance officer provides period status reports of OECD compliance to the management.
Internal Training	■ Each entity of the provides period training to all the concern employee involved in buying and selling and compliance monitoring team.
Communications	■ Business principle has been published on the website covering all the COP wise policy including Ethical Precious Metal souring policy of the . ■ Over and above Annual communication on Business policy and Awareness on various best practices and expectation from business partners is communicated.
OPTIONAL INFORMATION ON Step 4: Carry Out Independent Third-Party Audit
RJC COP Audit	■ Recently Our office has finalised the RJC COP 2019 Certification audit at Dubai office and same is scheduled on 7th and 8th May 2025.
Grievances And Remediation	■ No grievance of whatsoever has been reported till date.