Policy

Policy No. ENV1/2025
Ennovie Limitedy

Committed to Quality Product Development, Safety, and Environmental Concerns, Upholding Human Ethics, and Ensuring Customer Satisfaction.

Ennovie Limited is a jewelry manufacturer and exporter. We place a strong emphasis on producing high-quality products, being conscious of safety, and taking responsibility for the environment. We adhere to ethical principles and uphold morality in our operations for sustainable development. Our senior management and all employees are committed to the following:

1. Dedicated to complying with laws, regulations, safety, occupational health, and environmental standards, including ethics, local and national regulations, international agreements, industry standards, and relevant management system requirements with utmost diligence.
2. Building trust by providing customers with quality products, fair pricing, on-time delivery, and conducting ethical business operations to instill confidence.
3. Manufacturing products in accordance with international standards, implementing quality control and safety systems in the workplace to ensure consistent product quality and continuous development.
4. Focusing on accident prevention and minimizing workplace accidents, Zero accidents promoting employee well-being, and safeguarding the health of all employees in the organization.
5. Preventing and controlling environmental pollution, including water and air pollution, and industrial waste management.
6. Carrying out continuous improvements in management system standards and reviewing plans related to quality control, safety, and environmental aspects on an annual basis for ongoing development.
7. Efficiently conserving resources and energy, utilizing resources effectively to achieve maximum efficiency, including the use of renewable energy.
8. Promoting employee knowledge, understanding, and awareness to share responsibility for safety and environmental preservation.

Announced on January 15, 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.

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 15 January 2025.

Policy No. ENV13/2025 
Policy regarding ethics for business operation

Ennovie Co., Ltd. (hereinafter referred to as “Ennovie”) adheres to the guidelines for business operation regarding ethics and responsibility to operate all company businesses. Ennovie operates its business giving precedence to human rights and the environment. Ennovie stipulates all companies or persons doing business with Ennovie (hereinafter referred to as a “Party”) adhere to the guidelines with the same responsibilities and standards.

Pertaining to conditions to conduct business with Ennovie, each Party must adhere to and comply with the following ethics under current laws and regulations.

In the event a Party does not adhere to or comply with said regulations, it shall be deemed as a breach of its agreement. Ennovie may have sole discretion to terminate all agreements with the Party and cancel all available purchase orders without any compensation to the Party. In this case, the Party shall grant Ennovie the power to assign an agent to proceed with an inspection of its organization to confirm adherence to said ethics.

The Party must notify and explain the details of these ethics to its staff by using comprehensible language as well as be responsible for inspections to make sure that all sub-contractors related to any business with Ennovie follow said ethics and ratify or agree in writing.

Ethics standards for Ennovie:

Compliance with all laws and regulations: The Party must comply with all laws and regulations, including codes, disciplines, rules in the region and the country, treaties and applicable industry standards as well as apply publicly announced policies endorsed by senior executives to achieve these ethics.

Child Labor: The Party must prevent hiring child labor under all domestically applicable laws, treaties, guidelines of the United Nations (UN), and the International Labor Organization (ILO). The Party acknowledges that it must protect child rights from economic exploitation and any operations of work that may be dangerous or disturb the right to study of children or is dangerous to the health or body, mind, soul, morals, or social development.

To comply with the purpose of these ethics, “child” means a person who is less than fifteen (15) years old. If the local rule regarding minimum age does not stipulate an age more than this to work or enroll in compulsory education, the rule that stipulates a higher age must be applied in this case. However, Ennovie does not hire any person who is under eighteen (18) years and suggests the Party follow this criterion as well.

The company has a standard to remedy a case in which a person who is less than 18 years working in the company. The stipulated standard is that the staff shall stop working immediately, bring the child from the manufacturing area to a safe place, contact the parents and explain the child policy of the company to be acknowledged. Severance pays will be given according to the law, and such a child will be encouraged to enroll in compulsory education. When such a person is no longer a child and is older than 18 years, he/she can be recruited.

The Party must have efficient mechanisms to confirm the age of a person before recruitment. Also, the Party must make sure that the wages are fair and provide a break to such staff during the night for at least 12 hours, at least two (2) days off per week, and no overtime work.

Forced Labor: The party acknowledges that forced labor or reluctant labor by staff is not allowed. Further, limiting the freedom to move and travel is not allowed. The staff must be treated with dignity and respect by the Party. In addition, there must not be any physical punishment, threatening violence or physical abuse, sexual abuse, mental abuse, or verbal abuse in other forms to staff. During the process of lodging complaints and investigations, this must be explained to all staff clearly and thoroughly.

Safety and Occupational Health: Working environments must comply with the laws and applicable industry standards to assure safe work conditions. The Party must arrange working conditions in accordance with the best occupational health and safety that can be provided to staff. Moreover, the Party must ensure that safety and hygienic conditions are sufficient in the workplace. There must be training for staff regarding safety standards and occupational health as appropriate. The Party must provide appropriate steps, including installing alarms, stipulating provisions to deal with emergencies, and an evacuation plan to prevent accidents, providing access to health care facilities and infirmaries in the working area, and investigating formal documents when any severe accidents occur.

Gender and Race Equality: The Party acknowledges the importance of gender and race equality. Therefore, Ennovie stipulates the Party accept gender and race equality relating to practices and local traditions, especially the right of men and women from every race to get paid equally for equal work, get the opportunity to be hired equally (including conditions to pay wages), and get occupational development equally (including an opportunity to promote). The Party pledges to promote said rights.

The Party must not discriminate in any form of employment or working condition in its employment.

Working Conditions and Wages: The Party must pay remuneration to staff for finished work or work that must be done in the form of wages (wage payment is in accordance with normal criteria, as agreed before transferring to a bank account, in cash, or by check at the convenience of the staff). This includes overtime pay at a higher rate, maximum working hours, work ratio and other compensation to pay wages. According to the minimum standard, wages must not be less than the rate stipulated by the laws of the country or current industry standard. In case the laws or industry standards provide better conditions for staff, wages must be sufficient for living.

Therefore, the Party must stipulate the conditions for work and the wages for staff, including appropriate and legitimate working hours per day and per week (must not be more than eight hours per day and forty-eight hours per week). There is an exception in accordance with ILO treaty No.1, concerning paid annual leave and weekends, which is one of the staff’s rights.

Right of the Staff to Information and Consulting: The Party acknowledges and agrees that staff or representatives of staff will stay informed as well as get appropriate and prompt consultation under the conditions stipulated by laws and domestic practices.

The Party must ensure that staff or representatives of staff have an opportunity to stay informed about the financial trends of the company frequently and completely. In case there is any significant impact on staff benefits, including the general provisions of employment, there must be provision of said information and a consulting committee as soon as possible to make sure that the suggestions and perspectives of the staff are involved in the decision process by executives.

Staff of the Party must have the opportunity to attend relevant training to support staff to improve the work under their responsibility.

Right to Mutual Negotiation: The Party acknowledges the right of the staff to associate, group up, and mutually negotiate peacefully and legally to protect their benefits without any punishment or interference (as stipulated in section 23 of Universal Declaration of Human Rights and ILO treaty No. 87 and 98). The Party must not hinder mutual negotiation and adhere to the agreement of mutual negotiation in case there is an agreement.

Compliance with Rules pertaining to the Environment: The Party must comply with all laws and regulations pertaining to the environment and apply an appropriate management system and operation to minimize environmental impact. The Party must eliminate chemical waste in accordance with applicable laws and proceed with steps to minimize the amount of garbage/ pollution that occurs as well as the number of energy/ natural resources used. Moreover, the Party must check to ensure the efficiency of business from the perspective of using natural resources, including but not limited to water and energy. The Party must avoid the production, sale, or use of chemical substances and dangerous substances as well as choose alternatives to dangerous chemical substances if possible.

Bribery and Payment for Convenience: The Party must resist all kinds of bribery, consider the risk of bribery, and have appropriate measures to monitor such risk. The Party must facilitate reporting the possibility of bribery, enforce the punishment in case there is a bribe/ attempted bribe, and proceed with appropriate measures to monitor all payments for convenience, without punishing the person who reports or refuses to be bribed in all cases.

Money Laundering and Funding Terrorism: The Party must keep financial statements, which are audited and verified by all organizations doing business with the Party. International transactions may be subject to more than one regulation.

Diamonds and Gems: The Party must agree to support a voluntary self-care plan for the diamond and gem industry. The Party must not buy or sell conflict diamonds that are already known from Kimberly certification process. The Party must comply with and keep records of all Kimberly certificates, which are evaluated and corresponded. The Party must comply with the resolution of the World Diamond Council pertaining to self-care by keeping all invoices (which must contain guarantees from the World Diamond Council[4]) and have a system to prevent the buying and selling of illegal diamonds. Staffers must acknowledge the restrictions concerning the sale and purchase of diamonds.

Conflict Mineral: The Party must have a policy to certify the gold material in any product to ensure that it does not financially support or provide benefits, directly or indirectly, to any armed group who seriously infringes on human rights. The Party must confirm the source and do so in good faith, which includes inspecting the status of the source and the possessor’s cycle of evidence for such gold, as well as administer status inspection measures as requested.

Security of the Products: The Party must have security measures in place for the products indoors and during delivery, including the hiring of armed security guards if necessary. Concurrently, the Party must primarily give precedence to the security of staff, visitors, and business partners.

Integrity of Products: The Party must comply with all relevant standards and laws. In addition, it must correctly disclose all physical characteristics of the product and must not provide false statements or omit any substantial action. The Party must disclose the purity of gold, use signs to show the quality of permitted gold, and disclose information about the quality of diamonds, gems, and other semi-precious stones, including disclosure of information for diamonds in terms of quality improvement, laboratory-grown diamonds, and imitation diamonds.

Harassment, discipline, grievance procedures and non-retaliation: The party will not use anything of violence and harassment in the workplace. Employees must not be harassed or subjected to violence against themselves, their families, or their colleagues. The party must have a clear grievance and investigation process. Confidential and impartial for this process will communicate and apply to all employees. Employees are free to file a grievance without any penalty or retaliation by using the company complaint box and record employee grievances.

Ennovie shall adjust its ethics to be always updated, and the Party must agree to said adjusted information if there is no change in a substantial clause that affects the Party.

Policy No 14/2025
Code of Conduct

Ennovie Co., Ltd. (hereinafter referred to as “Ennovie”) adheres to the guidelines for business operation regarding ethics and responsibility to operate all company businesses. Ennovie operates its business giving precedence to human rights and the environment. Ennovie stipulates all companies or persons doing business with Ennovie (hereinafter referred to as a “Party”) adhere to the guidelines with the same responsibilities and standards.

Pertaining to conditions to conduct business with Ennovie, each Party must adhere to and comply with the following ethics under current laws and regulations.

In the event a Party does not adhere to or comply with said regulations, it shall be deemed as a breach of its agreement. Ennovie may have sole discretion to terminate all agreements with the Party and cancel all available purchase orders without any compensation to the Party. In this case, the Party shall grant Ennovie the power to assign an agent to proceed with an inspection of its organization to confirm adherence to said ethics.

The Party must notify and explain the details of these ethics to its staff by using comprehensible language as well as be responsible for inspections to make sure that all sub-contractors related to any business with Ennovie follow said ethics and ratify or agree in writing.

Ennovie’s Code of Conduct Standards:

Compliance with all laws and regulations: The Party must comply with all laws and regulations, including codes, disciplines, rules in the region and the country, treaties and applicable industry standards as well as apply publicly announced policies endorsed by senior executives to achieve these ethics.

Child Labor: The Party must prevent hiring child labor under all domestically applicable laws, treaties, guidelines of the United Nations (UN), and the International Labor Organization (ILO). The Party acknowledges that it must protect child rights from economic exploitation and any operations of work that may be dangerous or disturb the right to study of children or is dangerous to the health or body, mind, soul, morals, or social development.

To comply with the purpose of these ethics, “child” means a person who is less than fifteen (15) years old. If the local rule regarding minimum age does not stipulate an age more than this to work or enroll in compulsory education, the rule that stipulates a higher age must be applied in this case. However, Ennovie does not hire any person who is under eighteen (18) years and suggests the Party follow this criterion as well.

The company has a standard to remedy a case in which a person who is less than 18 years working in the company. The stipulated standard is that the staff shall stop working immediately, bring the child from the manufacturing area to a safe place, contact the parents and explain the child policy of the company to be acknowledged. Severance pays will be given according to the law, and such a child will be encouraged to enroll in compulsory education. When such a person is no longer a child and is older than 18 years, he/she can be recruited.

The Party must have efficient mechanisms to confirm the age of a person before recruitment. Also, the Party must make sure that the wages are fair and provide a break to such staff during the night for at least 12 hours, at least two (2) days off per week, and no overtime work.

Forced Labor: The party acknowledges that forced labor or reluctant labor by staff is not allowed. Further, limiting the freedom to move and travel is not allowed. The staff must be treated with dignity and respect by the Party. In addition, there must not be any physical punishment, threatening violence or physical abuse, sexual abuse, mental abuse, or verbal abuse in other forms to staff. During the process of lodging complaints and investigations, this must be explained to all staff clearly and thoroughly.

Safety and Occupational Health: Working environments must comply with the laws and applicable industry standards to assure safe work conditions. The Party must arrange working conditions in accordance with the best occupational health and safety that can be provided to staff. Moreover, the party must ensure that safety and hygienic conditions are sufficient in the workplace. There must be training for staff regarding safety standards and occupational health as appropriate. The Party must provide appropriate steps, including installing alarms, stipulating provisions to deal with emergencies, and an evacuation plan to prevent accidents, providing access to health care facilities and infirmaries in the working area, and investigating formal documents when any severe accidents occur.

Gender and Race Equality: The Party acknowledges the importance of gender and race equality. Therefore, Ennovie stipulates the Party accept gender and race equality relating to practices and local traditions, especially the right of men and women from every race to get paid equally for equal work, get the opportunity to be hired equally (including conditions to pay wages), and get occupational development equally (including an opportunity to promote). The Party pledges to promote said rights.

The Party must not discriminate in any form of employment or working condition in its employment.

Working Conditions and Wages: The Party must pay remuneration to staff for finished work or work that must be done in the form of wages (wage payment is in accordance with normal criteria, as agreed before transferring to a bank account, in cash, or by check at the convenience of the staff). This includes overtime pay at a higher rate, maximum working hours, work ratio and other compensation to pay wages. According to the minimum standard, wages must not be less than the rate stipulated by the laws of the country or current industry standard. In case the laws or industry standards provide better conditions for staff, wages must be sufficient for living.

Therefore, the Party must stipulate the conditions for work and the wages for staff, including appropriate and legitimate working hours per day and per week (must not be more than eight hours per day and forty-eight hours per week). There is an exception in accordance with ILO treaty No.1, concerning paid annual leave and weekends, which is one of the staff’s rights.

Right of the Staff to Information and Consulting: The Party acknowledges and agrees that staff or representatives of staff will stay informed as well as get appropriate and prompt consultation under the conditions stipulated by laws and domestic practices.

The Party must ensure that staff or representatives of staff have an opportunity to stay informed about the financial trends of the company frequently and completely. In case there is any significant impact on staff benefits, including the general provisions of employment, there must be provision of said information and a consulting committee as soon as possible to make sure that the suggestions and perspectives of the staff are involved in the decision process by executives.

Staff of the Party must have the opportunity to attend relevant training to support staff to improve the work under their responsibility.

Right to Mutual Negotiation: The Party acknowledges the right of the staff to associate, group up, and mutually negotiate peacefully and legally to protect their benefits without any punishment or interference (as stipulated in section 23 of Universal Declaration of Human Rights and ILO treaty No. 87 and 98). The Party must not hinder mutual negotiation and adhere to the agreement of mutual negotiation in case there is an agreement.

Compliance with Rules pertaining to the Environment: The Party must comply with all laws and regulations pertaining to the environment and apply an appropriate management system and operation to minimize environmental impact. The Party must eliminate chemical waste in accordance with applicable laws and proceed with steps to minimize the amount of garbage/ pollution that occurs as well as the number of energy/ natural resources used. Moreover, the Party must check to ensure the efficiency of business from the perspective of using natural resources, including but not limited to water and energy. The Party must avoid the production, sale, or use of chemical substances and dangerous substances as well as choose alternatives to dangerous chemical substances if possible.

Bribery and Payment for Convenience: The Party must resist all kinds of bribery, consider the risk of bribery, and have appropriate measures to monitor such risk. The Party must facilitate reporting the possibility of bribery, enforce the punishment in case there is a bribe/ attempted bribe, and proceed with appropriate measures to monitor all payments for convenience, without punishing the person who reports or refuses to be bribed in all cases.

Money Laundering and Funding Terrorism: The Party must keep financial statements, which are audited and verified by all organizations doing business with the Party. International transactions may be subject to more than one regulation.

Diamonds and Gems: The Party must agree to support a voluntary self-care plan for the diamond and gem industry. The Party must not buy or sell conflict diamonds that are already known from Kimberly certification process. The Party must comply with and keep records of all Kimberly certificates, which are evaluated and corresponded. The Party must comply with the resolution of the World Diamond Council pertaining to self-care by keeping all invoices (which must contain guarantees from the World Diamond Council) and have a system to prevent the buying and selling of illegal diamonds. Staffers must acknowledge the restrictions concerning the sale and purchase of diamonds.

Conflict Mineral: The Party must have a policy to certify the gold material in any product to ensure that it does not financially support or provide benefits, directly or indirectly, to any armed group who seriously infringes on human rights. The Party must confirm the source and do so in good faith, which includes inspecting the status of the source and the possessor’s cycle of evidence for such gold, as well as administer status inspection measures as requested.

Security of the Products: The Party must have security measures in place for the products indoors and during delivery, including the hiring of armed security guards if necessary. Concurrently, the Party must primarily give precedence to the security of staff, visitors, and business partners.

Integrity of Products: The Party must comply with all relevant standards and laws. In addition, it must correctly disclose all physical characteristics of the product and must not provide false statements or omit any substantial action. The Party must disclose the purity of gold, use signs to show the quality of permitted gold, and disclose information about the quality of diamonds, gems, and other semi-precious stones, including disclosure of information for diamonds in terms of quality improvement, laboratory-grown diamonds, and imitation diamonds.

Harassment, discipline, grievance procedures and non-retaliation: The party will not use anything of violence and harassment in the workplace. Employees must not be harassed or subjected to violence against themselves, their families, or their colleagues. The party must have a clear grievance and investigation process. Confidential and impartial for this process will communicate and apply to all employees. Employees are free to file a grievance without any penalty or retaliation by using the company complaint box and record employee grievances.

Ennovie shall adjust its ethics to be always updated, and the Party must agree to said adjusted information if there is no change in a substantial clause that affects the Party.

2024 Annual Report
Introduction:

Ennovie Co., ltd. 2025 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 2025

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.

Sourcing directly from artisanal and small-scale mining (COP 08):

The company does not source directly from mines.

Sourcing post-consumer industrial precious metals directly from informal recyclers (COP 09):

The company has no related business operation according to COP 09.

Society Development (COP 10):

The company has been cooperating in developing the surrounding society. Prize-giving activity to support Children’s Day at Ban Mai School, Nakhon Pathom Primary Educational Service Area Office, Area 1 on January 9, 2025.

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 : 20 February, 2025