Policy

Policy No. ENV12/2025
Human Resources and Organizational Management Policy

Ennovie Company Limited, hereinafter referred to as “Ennovie”, operates its business in strict adherence to ethical principles and a strong sense of corporate responsibility. Our core focus is on upholding both human rights and environmental standards. As a result, we have established policies that align with international human rights guidelines and standards, including compliance with Thailand’s labor laws and meeting customer requirements. Our commitment extends to enhancing the well-being of our employees based on the fundamental principles of human rights, which is reflected in our comprehensive Human Resources and Organizational Management Policy.

Child Labor: Contract Party must prevent employment of Children in accordance with all applicable national laws, and United Nations (UN) and International Labor Organization (ILO) Conventions and Recommendations. Contract Party recognizes the right of children to be protected from economic exploitation and from performing any work that is likely to be hazardous or to interfere with the Child’s education, or to be harmful to the Child’s health or physical, mental, spiritual, moral or social development.
For the purpose of this Code of Conduct, a “Child” means every human being below the age of fifteen (15), unless local minimum age requirements stipulate a higher age for work or mandatory schooling, in which case the higher age would apply; However, at Ennovie, we do not hire anyone under the age of eighteen (18) and strongly suggest our Contract Party to follow suit.

Contract Party shall have an effective mechanism for verifying age prior to recruitment and, where persons under the age of 18 years are employed, ensure fair payment for work, at least 12 hours nightly rest time and at least two (2) weekly rest days, and no overtime working.

Forced Labor: Contract Party recognizes that the use of forced or involuntary labour and the restriction of employees’ freedom of movement are not permitted. Employees must be treated with dignity and respect by the Contract Party, and any corporal punishment, threats of violence or other forms of physical, sexual, psychological or verbal harassment must not be used against them. As for grievance procedures and investigation processes, they must be clear and clearly explained to all Employees

This policy will come into effect on 17 January 2025.

Policy No.ENV2/2025
Combating Bribery, Money Laundering, and Financial Terrorism Policy

Ennovie Company Limited, hereinafter referred to as “Ennovie”, operates its business in strict adherence to ethical principles and a strong sense of corporate responsibility. Our unwavering dedication is demonstrated through our resolute stance against bribery, money laundering, and any involvement in financial terrorism, all of which is articulated in our comprehensive Combating Bribery, Money Laundering, and Financial Terrorism Policy.

Bribery and Facilitation Payment: Contract Party must act against any form of bribery, consider bribery risk and have appropriate methods to monitor such risk. Contract Party must facilitate the reporting of potential bribery, apply sanctions for bribery/attempted bribery and implement appropriate controls to oversee all payment facilitation. There should be no penalty for voicing a concern or declining to pay a bribe under any
circumstances.

Money Laundering and Finance of Terrorism: Contract Party must maintain audited financial accounts and acknowledge the identity of all organizations Contract Party deals with. Any transaction that is of international scope may be subject to more than one regulation.

Diamonds and Stones: Contract Party must agree and support a voluntary program of self-regulation in the diamonds and gemstones trade industry. Contract Party must not knowingly buy or sell Conflict Diamonds, according to Kimberley Process. Contract Party will adhere to and keep records of audited and reconciled Kimberley Process Certificates. Contract Party will adhere to World Diamond Council Resolution on Industry Self-Regulation, keep records of all invoices (which shall contain the World Diamond Council warranty statement ) and have a system to prevent any illegal diamond purchase or sale. Employees are informed about the restrictions on buy or sell diamonds.

Conflict Minerals: Contract Party must have a policy to reasonably assure that the Gold material, in products they manufacture, does not directly or indirectly finance or benefit armed groups causing serious human rights abuses. Contract Party must, to the best reasonable extent, ensure ethical sourcing and complete due diligence on the source and chain of custody of Gold, and make its due diligence measures available upon request.

This policy will come into effect on 17 January 2025.

Policy No. ENV3/2025
Occupational Safety, Health, and Environmental Compliance Policy

Ennovie Company Limited, hereinafter referred to as “Ennovie”, operates its business in strict adherence to ethical principles and a strong sense of corporate responsibility. We prioritize the safety and working conditions of our employees, ensuring that our industrial standards adhere to the principles of safety in accordance with our Corporate Occupational Safety, Health, and Environmental Compliance Policy.

Safety and Health: Workplace environment must comply with relevant applicable Laws and industry standards to ensure a safe conduct of work. As such, Contract Party is required to provide employees with the best possible human health and safety working conditions. Contract Party shall also ensure adequate and appropriate safety arrangements and hygienic conditions at the workplace. Employees must be appropriately trained as to safety and health measures. Contract Party should have appropriate procedures in place, including installing alarms, establishing emergency procedures and evacuation plans, to prevent accidents, and provide access to on-site health and medical facilities. Any serious incidents should be formally investigated and documented.

Environmental Compliance: Contract Party must comply with all applicable environmental laws and regulations and is encouraged to introduce appropriate management and operating systems to minimize its impact on the environment. Contract Party should dispose of waste substances in compliance with Applicable law and take steps to reduce the quantity of waste/emissions produced and energy/natural resources used. Additionally, Contract Party will ensure the efficiency of their business operations in terms of consumption of natural resources including but not limited to water and energy. Contract Party should not manufacture, trade and/or use chemicals and hazardous substances and should employ
alternatives to other hazardous substances used wherever possible.

This policy will come into effect on 17 January 2025.

Policy No. ENV4/2025
Policy on OECD Standard Status Verification

Ennovie Company Limited adheres to the business practices under the Company’s business code of conduct and responsibility in all aspects and realizes the various significance, therefore, the following practices are
determined:

1. The Company determines various policies to express its responsibility for the supply chain and compliance with standards defined by OECD (Organization for Economic Co-operation and Development) comprising policies on human rights, anti-forced labor, non-exploitation or harmful usage of child labor, and anti- bribery, anti-terrorism, and anti-money laundering;
2. The Company implements risk verification and review by assessment of third parties;
3. The Company conducts improvements and developments to mitigate risks;
4. The Company prepares the OECD standard compliance report every year.

This policy will come into effect on 17 January 2025.

Policy No. ENV5/2025
Employee Complaints Policy

The Company places precedence on the employees’ quality of life and paying respect to each other, therefore, the Company determines the policy on grievance denoting the case that any employee suffers unsatisfaction from work such as work condition, employment condition, mastership, work order, work assignment, remuneration payment, or discovery of any behaviors which may lead to misconduct, unethical act, unlawful acts, or financially improper, or fraudulent behaviors, or other benefits between the Company or superiors against the employee or between employees, and the employee proposes such unsatisfaction or grievance to the Company or his/her superior to request them to solve or cease such event. In this regard, to enable a good relationship between the Company or superiors and employees and the work happiness of the employees, the following procedures are determined:

Clause 1 Procedure to Cease Grievance

1.1 Upon the consideration of the superior in each level, the cause of grievance shall be solved or ceased and the result shall be notified to the relevant employee. If he/she satisfies the result, the superior will be promptly notified but in the case of the grieving employee’s dissatisfaction, the written appeals must be submitted to the top superior within 7 days of the date of acknowledgment of such result from the lower superior.

1.2 The top superior shall consider the appeal and perform relevant action to solve or cease the grievance and notify the result to the relevant employee within 15 days.

1.3 If the grieving employee remains not satisfied with the result of the top superior’s action, he/she shall be entitled to perform other lawful procedures.

Clause 2 Protection for Grieving Employee and Associated Persons

Since the grievance performed in good faith shall provide the Company and employees with benefits, therefore, the grieving employee, the employees who provide testimonies, information, facts, or evidence relevant to such grievance, and the employees who consider the grievance in good faith, even it cause any troubles to the Company, they shall be guaranteed by the Company that they shall not suffer termination of employment, punishment, or any negative impact unless such grievance conflicts any laws and order or implies any dishonesty causing damage to the Company.

This Policy shall be effective from January 17th, 2025 onwards.

Policy No. ENV6/2025
Corporate Social Responsibility Policy

The Company focuses on social responsibility. In order to benefit the communities and broad social, the Company deems
it appropriate to determine the corporate social responsibility policy to be implemented as the practices for sustainable development as follows:

Employees
The Company’s employees are obligated to perform tasks in compliance with practices and policies on corporate social responsibility. Additionally, the Company places importance on personnel training and development by supporting the employees to be prosperous and promising in their careers.

• Work practices;
• Personnel training and development.

Product Suppliers and Service Providers
The Company promotes product suppliers and service providers who are equipped with social and environmental responsibility.

• The Company shall deal with product suppliers and service providers who are equipped with social responsibility.

Good Governance and Ethical Practices
The Company promotes and improves ethical standards for business to be consistent with the ethical practices including data disclosure, internal data usage supervision and control, maintenance of the Company’s good governance standard, and good
governance.

• Provisions concerning disclosure of internal data;
• Transparency;
• Data disclosure.

Social and Environmental Responsibility
The Company foresees the importance of the environment and strong communities. Without a good environment and community, sustainable business shall not be achieved. The Company is ready to support any activities and projects concerning environmental conservation such as foresting, cleaning, and donations to foundations.

• The Company supports donations to any foundations;
• The Company supports environmental conservation-related activities and projects.

All shall be informed accordingly.

This Policy shall be effective from January 17th, 2025 onwards.

Policy No. ENV7/2025
Governing Employee Responsibility Policy on Harassment and Violation

Ennovie Co., Ltd. is committed to taking care of its employees in all aspects, including non- violence and all forms of harassment in the workplace. Employees are not harassed or subjected to violence against themselves, family or colleagues. The parties shall have a clear grievance and investigation process. It is confidential and impartial, and this procedure is communicated to all employees. Employees are free to file grievances with impunity or retaliation using the complaint box and the employee’s grievances are recorded.

This Policy shall be effective from January 17th, 2025 onwards.

Policy No. ENV8/2025
Code of Conduct Policy in accordance with RJC

Ennovie Co., Ltd. (hereinafter referred to as “Ennovie”) adheres to the Code of Conduct and responsibility for all aspects of the Company’s business. Ennovie operates its business with an emphasis on human rights and the environment. Ennovie specifies all companies or individuals with whom Ennovie does business (hereinafter referred to as “Parties”) to adhere to the same responsible practices and standards.

According to the terms of doing business with Ennovie, each party shall adhere to and comply with the following Code of Conduct under current laws and practices.

Failure of the parties to adhere to and apply the provisions hereof will constitute a breach of their terms and Ennovie in its sole discretion, terminate all existing contracts with the parties and terminate all existing orders without payment of any compensation to the parties. In this case, the parties shall authorize Ennovie and its designated agents to conduct audits of their respective agencies to confirm compliance with this Code of Conduct.

The parties shall inform and explain the details of this Code to their employees in a language that they can understand. It is also responsible for ensuring that all subcontractors involved in Ennovie’s business comply with this Code of Conduct and have ratified or approved it in writing.

This Policy shall be effective from January 17th, 2025 onwards.

Policy No. ENV9/2025
Provenance Claims Policy

Ennovie Co., Ltd. is committed to being a socially responsible jewelry and precious metals dealer in accordance with international standards. All employees and stakeholders are involved in achieving this policy. The supply chain must comply with policies related to silver and precious metals and other precious stones to conduct supplier’s supply chain due diligence checks. All items procured from refineries or smelters are audited and certified without conflict under the OECD Due Diligence. Valid mineral source certification documents must be publicly identified and verified through a sustainability management system. We will check the origin of raw materials correctly and traceable according to the lot number and source from which vendor and the amount. The company has to check the quality of every product that in case there is a problem on how we respond when we receive an accurate report of the complaint.

1. Describe our complaints process and find out how the complainant wants us to handle it.
2. Assign the suitable person to Handle complaints.
3. Problems can be dealt with internally and additional information can be provided accurately and appropriately.
4. Advise the complainant about decisions or outcomes.
5. Keep a record of at least 5 years of complaint information.

At this stage, stakeholders can raise concerns via email channels, customer service contacts.

This Policy shall be effective from January 17th, 2025 onwards.

Policy No. ENV10/2025
Anti-Corruption Policy

Ennovie Co., Ltd. has an anti-corruption policy or bribery and payment of facilitation fees, and the parties must fight all forms of bribery and consider the risks of bribery and have appropriate methods to monitor them. The parties shall facilitate the reporting of the possibility of bribery, enforce sanctions in case of bribery/attempted bribery and implement appropriate control measures to supervise the payment of all facilities. No person shall be punished for reporting or refusing to accept bribes under any circumstances, whether it is a government agency, activities from personnel supervised by the government or controlled in relation to commercial activities.

Transparent payment regulations under the Anti-Corruption Policy are as follows:

Employees and intermediaries are prohibited from making or accepting bribes, payments or articles of value in order to obtain or maintain contracts, businesses, tax and customs contributions, or to secure benefits from illegal business to any organization or personally bribe, illegal benefit payment against prohibited ethical principles.

Ennovie Co., Ltd. will maintain and collect accounting information to reflect the organization’s transaction activities with integrity and adequate internal management system and accountability.

This policy is effective from 17 January 2025.

Policy No. ENV11/2025
Supply Chain policy

1. Ennovie Co., Ltd. adheres to the Code of Conduct and responsibility in all aspects of the Company’s business operations and human rights by avoiding donations to cause conflict.

2. Ennovie Co., Ltd to committed comply with all relevant measures and laws. It is certified and verified by the responsible jewelry council (RJC), we are committed to proving that we are audited by the Responsible jewelry council (RJC) and certified and a member of RJC, which we adhere to the following principles:
2.1. Respect for human rights in accordance with the Universal Declaration of Human Rights and Fundamental Human Rights.
2.2. Not having any interest in, or participating in or accepting bribery, corruption, money laundering, and terrorist financing.
2.3. Implement OECD management procedures for responsible supply chain risk due diligence monitoring and analysis of minerals from conflict-affected and high-risk areas.
2.4. Support transparency of government payments
2.5. It does not directly or indirectly support illegal armed groups.

3. Ennovie Co., Ltd. is committed to using our existing policies to prevent infringement of rights from others, and we conduct KYC
audits on all our suppliers to identify risks and establish a grievance process for supply chains.

4. We will not tolerate the exploitation or sponsorship and facilitation in giving commission of the following.
4.1. Harsh and inhumane treatment
4.2. Child and forced labor
4.3. Human rights violations or international war crimes

This policy is effective from 17 January 2025.

2023 Annual Report

Introduction:

Ennovie Co., ltd. 2023 annual report detailing our responsible business policies in accordance with the Responsible Jewellery Council standard of practice, the scope of this report covers all Code of Practice 2019 as the achieved member shall meet all the standard guidelines and transform all practices into measurable action.

Under the enactment of the “Code of Conduct Policy”, we stated the commitment for transparent and responsible supply chain management. Ennovie established the principle of avoiding the use of conflict minerals produced through an inhuman process or involved in accounting fraud. In addition, in order to fundamentally prevent the use of conflict minerals we have a process of due diligence before entering into transaction with Gold and Silver suppliers, and do not trade with suppliers who are not complying with “Code of Conduct Policy”.

Ennovie adopted, established, implemented and exercises Code of Practice 2019 with full commitment with the action and results stated below;

Legal Compliance (COP 1):

Ennovie have a system in place to monitor legal development and identify risk within our company. Legal area under COP provisions is covered within our system, such as bribery and facilitation payments, money, laundering, working hours, remuneration, health safety and product disclosure.

All legal documents are completed and truthful.

Policy and Implementation (COP 02):

Ennovie has established code of business conduct and committed to high ethical standard Including transparency, honesty with legal compliance practices both local and international laws. We were respect in human rights and having due diligence process on mineral that conflicted and risk. We are not support any form of corruption, fraud, the receiving or giving on bribery. It is also a prohibited for company to engage in any business that relate to money laundering or financial terrorism. All company transactions are transparency and disclose information of raw materials that are acquired or distributed in supply chain system. In addition, Ennovie were practiced to meet the Kimberley Process Certification (KPC) or the voluntary assurance system of the World Diamond Council (WDC). The transport of products was appropriate in standard, including the information protection of trade partners which will not be used or disclosed without consent. All policy and implementation are completed, no suppliers found under the red flags assessment.

Reporting (COP 3): 

We communicate publicly and directly with stakeholders on annually on the business practice relevant to the COP.

Financial Accounts (COP 4):

We maintain financial accounts of all business transactions in accordance to relevant regulations. Internal auditing is conducted on the preventive and protection basis. The audited financial statements for the year 2023                   All transaction is transparent, and no fraud was found.

Business Partners (COP 5):

We use our best endeavours, commensurate with our ability to influence and promote responsible business practices among our significant business partners. We encourage our suppliers to employ a due diligence process to identify and minimize the supply chain risk with fully understanding that the business continuity is based on their cooperation on doing the due diligence on our concerning criteria.

Human Rights (COP 6):

Ennovie conducts business in accordance with the law. All employees and executives are required to strictly abide to laws and related to human rights. By having established various criteria related to work on non discrimination, non-forced labour, having freedom of association and collective bargain. Ennovie has established a due diligence procedure to prevent, mitigate, and reduce impact related to human rights violations. There is also a rehabilitation plan in case of human rights violations as required by law.

Due Diligence for Responsible Sourcing from Conflict Affected and High-Risk Areas (COP 7):

Ennovie has established the business conduct code for those in the jewellery manufacturing supply chain, including trade partners, supplier, contractors to be actively coordinated. In order to create a transparent and controllable operating system. KYC (Know Your Counterparty) system is used to identify and assess for risk of human rights or conflicted in supply chain. All of mineral such Gold, Silver, PGM, Diamonds, Gems should be certify that not sourcing from conflict affected and high-risk area. This is to prove and certify supplier not relate to money laundry and financial terrorism by UN or AMLO (Anti Money Laundering Office) designated list. The results of this implementation were not found red flag (prohibited) on trade partners.

Society Development (COP 10):

The company has been cooperating in developing the surrounding society. With a donation to support the activities of the community surrounding the establishment is Sharing Happiness Project for Children Grant scholarships Stationery and snacks for students on October 19, 2023.

Transactions without Corruption or Bribery and facilities payment (COP 11):

Ennovie committed to do a business with transparency by adhering to the principles of corporate governance in order to operate with quality and sustainability. Anti-corruption and bribery policies were established. All Ennovie staffs are prohibited not to engage with corruption or bribery. As well as the financial that is paid to support the operations of the company, donations to make such payments are prohibited. Except for giving which is based on tradition and practice to the government. In order to monitor such matters or complaints, a whistleblowing process has been established to providing protection to the person who informs or provides such information.

Non supported of money laundering or financial terrorism (COP 12):

Ennovie has established a code of business conduct for anti-money laundering and non-support financial of terrorism either directly or indirectly in this section. There are KYC (Know You Counterparty) system to identify and verify all of trade partners from the AMLO and UN designate list or any another red-flag list. All of material such golds, silvers, PGM, Diamonds and Gems having conflict free or originate certified. All various transactions with higher than normal value are to be reported to the government in accordance with the rules of Anti-Money Laundering Act as a surveillance approach has been established.

Security (COP 13):

We assess security risks and establish risk assessment policy and procedure to protect employees, contractors and visitors against product theft and damage within the premises.

Provenance claims (COP 14):

We established the Provenance Policy and declaration on all the final selling documents such as invoice, and it is available on our website ennovie.com.

Labor Management (COP 15-22):

Ennovie has labour management to comply with human rights principles. By issuing a policy to eliminate discrimination. Whether it is a matter of individual status, gender, religion, nationality, race, taste, etc., The eliminate of the worst forms of child labour. therefore, the company has a policy of not hiring children to work with in all cases. Ennovie also stipulates not to use of forced labour or illegal treatment of persons in matters of safety. Non-involvement in human trafficking, Sexual harassment which the company has specified In addition. All labour management practices, the company has adhered to the principles of accuracy and fairness in

accordance with Labor Protection Act, B.E. 2541

Safety and health management (COP 23):

Ennovie has a safety and health policy to require all employees comply with the rules of the law. In various matters, a safety committee were established in workplace by election. There is an operational risk assessment in place. All employees were safety awareness and evacuation with fire drills trained.

Environment Management (COP 24-27):

Ennovie are bonded in sustainability program. The factory are nearly zero emissions, 90% of all water consumption comes from rain and recycled water, while 70% of all energy usage comes from solar energy with 3R program (Reduce, Reuse, Recycle). The factory has a stringent dust filtration system. Dust generated by polishing and grinding is collected by spot exhaust suction through a 1 μm filter. Thereafter, the air is further filtered through HEPA filters. All environmental impact monitoring as required by law.

Product disclosure (COP 28):

We installed policies, procedure, training and monitoring systems to publicly disclose the origin, transaction and physical characteristic of the materials.

Kimberley Process Certification Scheme และระบบ World Diamond Council of warranties (COP 29):

We committed and installed the policy and procedure to ensure that all the diamonds shall be incompliant with KPCS and WDC (sow).

Conclusion:

Ennovie achieve our goals with pride and integrity of our people. All exercise and performance are in compliance with the standard of Responsible Jewellery Council, COP 2019

Date : 27 June, 2024