MSBV-EBP-001
Millennium Star BV — Antwerp, Belgium
This Policies and Procedures Document (MSBV-EBP-001) represent the commitment of Millennium Star BV to comply with the requirements of the Code of Practices, 2024 of the Responsible Jewellery Council.
The contents of this document have been reviewed and approved by the director of the company and subject to annual review or as an when change in process/operations/activity.
All employees of Millennium Star BV are required to be familiar with this document and comply with various requirements contained in this document.
We the management of the company responsible for making changes / revisions to this document and all employees are advised to bring to our attention any problems that they may face in the implementation of the requirements contained in this document.
The following is a description of the policies and approval of policies and procedures that apply to the business partners, internal and external stake older and employees. These are defined as level policies and entity/department level policy should not contradict this policy document.
This Policy Document (FJB-001) is to define rules and regulation and way of working for the operations and activities of the company Millennium Star BV in relation to the requirements of Responsible Jewellery council and ethical business practice. The contents of this document have been reviewed and approved by Director and subject to Annual review.
With over 30 years of industry experience, we have built a trusted name in the global diamond trade. Our journey began with a commitment to authenticity, transparency, and ethical sourcing.
Today, we proudly serve leading jewellers, manufacturers, and retailers across the world, delivering unmatched quality and consistency in every stone.
All internal and external stakeholders of Millennium Star BV are required to be familiar with this document and follow the risk mitigating measures identified in this document. Management is responsible for making changes / revisions to this document and all business partners and stake holder are advised to report any issues violating this document.
The Company is committed to the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on the Company's behalf is responsible for maintaining the Company's reputation and for conducting company business honestly and professionally.
Millennium Star BV
Director
Millennium Star BV is a member of Responsible Jewellery Council – RJC and committed for ethical business practices and compliance with Code of Practices in all its business activities.
The management of Millennium Star BV shall implement responsible ethical, social and environmental practices throughout the diamond supply chain, from mine to retail. We are being a responsible entity of diamond supply chain believe in consumer confidence in our trade and request our business partners to follow same. As a part of best endeavors and responsible business entity, we anticipate co-operation of our business partners in adopting the standard and ensuring that the entire diamond supply chain is compliant with respect to business, social and environmental responsibilities.
We strongly encourage all our business partners to follow and implement the various requirements of the RJC code of practice and other prevailing trade standards.
More information about the Compliance Program is available on http://www.responsiblejewellery.com.
The Millennium Star BV has a set policy and Procedure document and firmly believes that it should be implemented in a true spirit with the involvement of all stake holders. Further, the company shall always involves all stake holder in the process of continues improvement and welcome reporting of any incident or observation of breach of policy and procedure from any third party of stake holder. At the same time company shall always believe that any person who reports the breach incident or observed any violation of policy should be provided adequate immunity against any adverse impact on his job or any threat to his/her life or any form of harassment and torture.
The company shall always maintain the confidentiality of the whistle blower and shall not disclose identity of the whistle blower without written consent from the whistle blower. The company shall always ensure that the person who has reported incident of violation for policy and procedure shall not be penalized or harassed or torture or threaten by any individual.
Business policies of company assure that all employees or third party who comes forward in good faith to report issues, that they will be treated fairly and respectfully. While all efforts will be taken to protect the anonymity of employees as far as practicable, any form of retaliation.
Against any such individuals, assuming they have not been involved in the violation will not be tolerated.
a. Company encourages employees or any third party to voice concerns promptly, if they have a genuine reason to believe that a policy, company operation or practice is or will likely be in violation of any law, regulation or internal company rule or policy, including this. In case of any incident with the Whistle-Blower he/she can report to entity head on following.
Website is https://www.millenniumstar.be
https://www.millenniumstar.be/contact
• In case if employee wants to register their grievance, they can contact To report a labor grievance in Antwerp/Belgium and find government information, visit the Ministry of Labour website. Website: www.rva.be
• General Phone: +32 (0)2 515 44 44.
• Central Administration Address: Boulevard de l'Empereur 7, 1000 Brussels (covers national inquiries).
Antwerp World Diamond Centre 0032 (0)3 222 05 11 info@awdc.be
Hoveniersstraat 22, 2018 Antwerp-Belgium
Our employees, suppliers and other parties can report concerns and alleged violations of supply chain/sourcing/due diligence policy as follows:
Reports can be made anonymously and will be fully kept confidential practicable and allowed by law and shall be addressed in 15 working days.
We will not take any retaliatory action against our employees, suppliers, or other parties who make a report in good faith.
Our suppliers are encouraged to contact if they wish to seek guidance on the application of this Policy.
If an employee within an Antwerp diamond company files a formal grievance regarding workplace conditions, discrimination, or wages, the internal appeal must comply with Belgian labor law.
The Company recognises that we are all unique, whether in terms of our background, personal characteristics, experience, skills or motivations, and the Company value its people for the differences they bring. These differences, this diversity is powerful.
The Company is committed to building a culture that values openness, fairness, and transparency with a workforce that is truly representative of communities in which it operates and where employees feel respected and able to achieve their potential. Fostering an inclusive culture helps everyone to benefit from a wider range of different perspectives, experiences, and skills. The Company believes that this creates a happier, more productive working environment for all.
This policy statement applies to anyone working for the Company. This includes employees, workers, contractors, and apprentices. The policy also relates to job applicants and is relevant to all stages of the employment relationship.
The Company is committed to the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on the Company's behalf is responsible for maintaining the Company's reputation and for conducting company business honestly and professionally.
This policy outlines the Company's position on prohibiting and preventing bribery, fraud, dishonesty, and illegal activity. The Senior Management take a zero-tolerance approach and are committed to enforcing effective systems throughout the company to prevent, monitor and eliminate any form of dishonesty and consider that such activities have a detrimental impact on business by undermining good governance and distorting free markets.
This policy applies to all employees of the Company, and business partners and external stakeholders. Every employee and associated person acting for, or on behalf of, the Company is responsible for maintaining the highest standards of business conduct. Any breach of this policy will be treated as grounds for serious disciplinary action, and / or constitute a contractual and criminal matter for the individual concerned. The Company is committed to transparency and believes that fair conduct helps to foster deep relationships of trust between the Company and our business partners and customers and as such a breach of this policy may also cause serious damage to the reputation and standing of the Company.
In compliance with statutory legislations and to embed commitment to integrity and honesty the Company will not sanction the following: –
The success of the Company's measures depends on all employees, and those acting for the Company, playing their part in helping to detect and eradicate dishonesty. Therefore, all employees and others acting for, or on behalf of, the Company are encouraged to report any suspected dishonesty in accordance with the procedures. The Company will support any individuals who make such a report, if it is made in good faith.
This statement sets out the Company actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
As part of the diamond supply chain, we recognize that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic.
The senior management is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
The Company shall ensure appropriate technical and organisational measures are taken to prevent unauthorised or unlawful processing of personal data and commercially sensitive information, and to safeguard against accidental loss or destruction of, or damage to same.
To reassure our business partners and other interested parties of our commitment to protecting, securing and controlling systems and data, the company security controls are verified by independent experts.
The Company will act to ensure that measures are implemented to protect the integrity of information, such measures shall include:
By implementing the above security measures, we shall comply with business, contractual, and regulatory requirements, including those of the General Data Protection Regulation.
This policy is communicated to our supply chain, relevant interested parties and all those working for, or on behalf of, the company.
In Belgium, child labour is strictly prohibited, with the legal working age generally set at 16, provided the child is no longer in full-time compulsory education. Regulations are enforced at both federal and regional levels, primarily through labour inspection services aimed at protecting the welfare of minors.
The policies relating to this section are part of the Business Policies adopted by Millennium Star BV and are presented below for reference:
a. The management of Millennium Star BV are fully committed to ensuring that forced or involuntary, bonded, indentured or prison labour, is not practiced nor used in any form at any of its facilities. Millennium Star BV shall ensure that there is no restriction in the freedom of movement of employees and dependents. Any reported incidents relating to forced labour will be considered as a serious violation of the Business Policies.
b. The following definitions will be applicable:
• Forced labour in Belgium is strictly prohibited by law, with compliance monitored by the Federal Public Service (FPS) Employment, Labour and Social Dialogue. The government utilizes targeted inspections and acts against human trafficking, including severe labor exploitation.
• Labour Inspection - Control of Social Legislation: This department oversees compliance with labor regulations, including the prevention of forced labor and social dumping.
o Phone: +32 (0)2 235 55 60 (French/German) and +32 (0)2 235 55 55 (Dutch).
o Email (Complaints): COMPLAINTS.LabourInspection@employment.belgium.be
Point of Contact for Fair Competition (SPOC): Handles complaints regarding undeclared work and social fraud.
• Federal Public Service (FPS) Employment, Labour and Social Dialogue: Responsible for overseeing working conditions and worker welfare.
o Website: emploi.belgique.be.
The policies relating to this section are part of the Business Policies adopted by Millennium Star BV are presented below for reference:
a. Millennium Star BV is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and World Diamond Council's (WDC) System of Warranties Declaration.
b. The definition of 'Conflict Gemstone Diamonds' as agreed by the Kimberley Process will be adopted i.e.
"Rough diamonds used by rebel movements or their allies to finance conflict aimed at undermining legitimate Governments, as described in relevant United Nations Security Council (UNSC) resolutions in so far as they remain in effect, or in other similar UNSC resolutions which may be adopted in the future, and as understood and recognized in United Nations General Assembly (UNGA) Resolution 55/56, or in other similar UNGA resolutions which may be adopted in the future."
c. Wherever applicable, the following affirmative statement as recommended by the World Diamond Council's System of Warranties should be printed on all the invoices:
d. "The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict, in compliance with United Nations Resolutions and corresponding national laws. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WDC SoW Guidelines."
e. Entering into transactions involving '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 Policies.
f. Millennium Star BV ensures that concerned personnel within the organization know about government restrictions on the trade in Conflict Diamonds, the Kimberley Process Certification Scheme and the World Diamond Council System of Warranties.
a. Millennium Star BV complies with applicable national laws / regulations with respect to employment.
b. Millennium Star BV is committed to maintaining appropriate records as stipulated by the regulatory authorities for all staff employed, whether on a full time, part time or seasonal basis.
c. Millennium Star BV shall not require workers to work for more than the national limit of hours in a week on a regular basis, with overtime hours not to exceed the national permitted limit per week on a regular basis unless there are legal opt-outs.
d. Millennium Star BV shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of workers.
e. Wages shall be paid to employees on a regular and predetermined basis in a manner and location convenient to employees, accompanied by a wage slip detailing wage rates, benefits and deductions as applicable.
f. Millennium Star BV shall ensure that due process of wage deductions shall be followed where applicable and it shall not be binding on employees to buy provisions from the group.
g. When required, due recognition will be given to the existence, membership and lawful activities of worker representative bodies, and worker representatives will be given access to carry out their responsibilities / functions.
h. Millennium Star BV is committed to addressing the legitimate grievances of its employees.
i. Millennium Star BV shall follow proper procedure as per law for dismissal of employees, in case the need for the same arises, and arbitrary dismissal procedures shall be avoided.
j. Information regarding applicable employment policies and working practices shall be communicated in a transparent manner to all employees.
Millennium Star BV is fully committed to the pursuance of the provision of fair and conducive employment conditions, consistent with applicable laws and regulations.
Belgian employment law is highly regulated, mandatory, and often requires specific language (Dutch, French, or German) based on the region. Key aspects include mandatory written contracts, strict working hour limits (e.g., 6 hours without a break), and a 2026 reform capping notice periods at 52 weeks for new hires. Contact the Social Security Contact Centre for inquiries at +32 (0)2 511 51 51.
The policies relating to this section are part of the Business Policies adopted by Millennium Star BV is presented below for reference:
a. Millennium Star BV recognizes the fact that entities in the gems and jewelry sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
b. Strict compliance is required at all times, with all applicable national and, where appropriate, international laws / regulations with respect to money laundering, terrorism financing, bribery, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.
c. Millennium Star BV shall act in accordance with national laws and national / international accounting standards with respect to maintaining financial accounts of all business transactions and auditing of its financial accounts.
d. Millennium Star BV ensures that concerned employees know and understand the relevant regulatory jurisdiction for national and international transactions, 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 Policies, depending on the seriousness of the non-conformance.
e. Millennium Star BV implements a "Know your Customer" and "Know your Supplier" procedure that establishes the identity of all organizations with which it deals, have a clear understanding of their business relationships and have a reasonable ability to identify and react to transaction patterns appearing out of the ordinary or suspicious and enhanced due diligence including UBO's for all business partners.
Belgium's Anti-Money Laundering (AML) regulations, primarily governed by the Law of 18 September 2017, mandate strict Customer Due Diligence (CDD) and Suspicious Activity Reporting (SAR) to the Financial Intelligence Processing Unit (CTIF-CFI). Key authorities include the National Bank of Belgium (NBB) and the Financial Services and Markets Authority (FSMA).
Violations can lead to, significant, fines, ranging up to Euro 1250,000 for non financial companies or of annual turnover for financial institutions.
For specific regulatory guidance or to report suspicious, activities, entities must contact the CTIF-CFI directly, while financial, institutions primarily report to the NBB or FSMA, based on their, authorization. In Belgium, there is a cash limit of 3.000 EUR
The policies relating to this section are part of the Business Policies adopted by Millennium Star BV and are presented below for reference:
a. Millennium Star BV will not prevent employees from associating and collective bargaining
b. Discrimination can mean distinction, exclusion or preference.
c. Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, ethnicity, caste, national origin, religion, age, disability, gender, marital status, physical appearance, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by Millennium Star BV and any such reported incidents will be viewed as a serious violation of this Business Policies.
d. Millennium Star BV will ensure that employees who have certain life threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.
e. Individuals who are "Fit for Work" shall be accorded equal opportunities and shall not be discriminated against on the basis of factors unrelated to their ability to perform their job.
f. Millennium Star BV shall not use corporal punishment under any circumstances and will ensure that employees are not subjected to harsh or degrading treatment, sexual or physical harassment or other forms of mental or physical coercion, abuse or intimidation.
g. Millennium Star BV encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, entity operation or practice is or will likely be in violation of any law, regulation or internal entity rule or policy, including this Business Policies. Millennium Star BV assures all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully. While all efforts will be taken to protect the anonymity of employees as far as practicable, any form of retaliation against any such individuals, assuming they have not been involved in the violation, will not be tolerated.
a. Millennium Star BV is committed to complying with relevant trading standard legislation and specific national and local regulations applicable to its products.
b. The following essential Policies will be applicable in all transactions of Millennium Star BV involving diamonds, treated diamonds, synthetics and stimulant
c. Millennium Star BV has adopted the following definitions:
Diamond: A diamond is a natural mineral consisting essentially of pure carbon crystallized with a cubic structure in the isometric system. Its hardness in the Mohs scale is 10; its specific gravity is approximately 3.52; it has a refractive index of 2.42 and it can be found in many colours.
Synthetic: A synthetic is any object or object that has been either partially or wholly crystallized or re-crystallized due to artificial human intervention such that, with the exception of being non-natural, the product meets the requirements specified in the definition of the word 'diamond' above.
Treated Diamond: A treated diamond is any object or product that meets the requirements specified in the definition of the words 'diamond' and 'synthetic' above, but has been subject to some form of treatment i.e. any process, enhancement changing, interfering with and/or contaminating the natural appearance or composition of a diamond other than historically accepted practices of cutting and polishing. This includes colour and decolourisation treatment, fracture filling, laser and irradiation treatment and coating.
Simulants: A diamond simulant is any object or product used to imitate some or all of the properties associated with a diamond and includes any material, which does not meet the requirements specified in the definition of the word 'diamond' above.
Coloured Gemstone: a coloured gemstone is a mineral that has formed completely by nature without human interference during its formation, with each variety possessing unique chemical, optical, and physical properties.
Scope in Standards: Under the RJC Code of Practices (COP), references to the coloured gemstone supply chain initially prioritized the "Big Three" gem varieties—rubies, sapphires, and emeralds
Natural Formation: It must originate entirely through natural geological processes without artificial creation or human intervention during its growth.
Distinct Properties: Every specific variety exhibits its own one-of-a-kind chemical composition, optical behavior, and physical characteristics.
a. Millennium Star BV is committed to establish and implement product security measures within the premises and during shipments to protect against product
The policies relating to this section are part of the Business Policies adopted by Millennium Star BV and are presented below for reference:
a Millennium Star BV is committed to prohibit bribery in all business practices and transactions that are carried out by the company or on its behalf by business partners. The company will not offer, accept or countenance any payments, gifts in kind, hospitality, expenses or promises as such that may compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with, or direct business to, any person; to influence the course of the business or governmental decision – making process.
b. Millennium Star BV considers Bribery Risk as it applies to its organization (including agents) to identify which areas pose high risks. Millennium Star BV has developed appropriate methods to monitor conduct of employees and agents and eliminate bribery based on this understanding.
c. The management of Millennium Star BV facilitates the reporting of incidences of attempted bribery or inappropriate gifts within their organization and shall apply appropriate sanctions for bribery and attempted bribery in all forms.
d. Millennium Star BV ensures that no employee will suffer demotion, penalty or other adverse consequences for voicing a concern, or for refusing to pay a bribe or facilitation payment even if this action may result in the enterprise losing business.
Bribery and facilitation payments are strictly prohibited under Belgian law, with a robust legal framework in place to govern interactions with government officials, including foreign officials. The regulations, primarily found in the Belgian Criminal Code (BCC), treat any advantage, regardless of its value, as a potential bribe.
Facilitation payments—small payments made to speed up routine governmental actions (e.g., permits, licenses)—are forbidden under Belgian law. They are considered bribery, regardless of the amount.
The policies relating to this section are part of the Business Policies adopted by Millennium Star BV and are presented below for reference:
Millennium Star BV is committed to effective environmental performance and will focus on the following initiatives:
The policies relating to this section are part of the Business Policies adopted by Millennium Star BV and are presented below for reference:
Millennium Star BV recognizes the need to develop a sustainable, value creating business and is committed to the following in the areas of workplace health and safety:
The policies relating to this section are part of the Business Policies adopted by Millennium Star BV and are presented below for reference:
a) All employees in Millennium Star BV will be treated with equality, respect and dignity.
b) Millennium Star BV believes in and respects fundamental human rights according to the United Nations Universal Declaration of Human Rights.
c) Millennium Star BV 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
d) Millennium Star BV strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.
e) Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the Group.
f) Security personnel, if employed by Millennium Star BV are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat.
g) Wherever the any violation of human rights are observed, the company shall take mitigation action and if needed hire an external non-governmental organization for the implementation.
h) Human rights risk assessment shall be done annually covering internal and external stakeholders.
i) The company shall conduct human right risk assessment and upon any violation observed internal or external stake holders, company shall develop and implement risk mitigation plan according to severity of incident. The company may seek assistance from external NGO's or experts to develop and implement mitigation plan and monitoring.
j) The company shall provide support and consultation to external stakeholders upon written requests by the business partners.
• Federal Institute for the Protection and Promotion of Human Rights (FHR/IFDH): This is the central federal body for protecting human rights in Belgium.
o Address: Leuvenseweg 48, 1000 Brussels.
The policies relating to this section are part of the Business Policies adopted by Millennium Star BV and are presented below for reference:
Security personnel, if employed by Millennium Star BV are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat.
The Policy promote the standards that we expect all of our suppliers to comply with when producing and supplying Diamonds/Gemstone to Millennium Star BV, no matter where they operate in the world. We request all our business partners to disclose first mine of origin and source to comply with ethical business practice. We also request to provide us refinery certificate in case of any metal supplied. We request our suppliers not to supply any material that is subject to EU. Reg. 833/2014.
The senior management of Millennium Star BV advocate this policy and we shall review as and when changes in the process or compliance requirement or any violation of sourcing policy or Changes in risk and due diligence criteria. We shall carry out review of this entire document at least annually.
We recognise that full compliance with these criteria may take time for some suppliers, and we are committed to working with our suppliers to implement improvement plans and help them achieve compliance.
Millennium Star BV is committed to working in partnership with its suppliers to help achieve compliance with this Policy.
All the supplier should comply with national and international law and trade requirement like RJC with respect to Bribery and Corruption, Financial Offence, Labour Rights, Kimberley process and World Diamond Council – SoW, Product disclosure, Labour Rights, Working Condition, Child labour, Forced labour, Human rights, Discrimination, Fair wages and working hours, Environment compliance, Health and safety of the employees and visitor.
At Millennium Star BV, we take Ethical business practice, social and environmental factors into consideration in making decisions on the procurement of Rough or polish diamonds.
This Policy shows company's commitment and its expectations for its product suppliers regarding actions to address Conflict Diamonds.
Millennium Star BV expects it's suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that diamonds supplied to us containing conflict free diamonds are not belongs to Conflict affected and high-risk areas – CAHRAs.
We being a responsible company, Millennium Star BV supports the goal of the Dodd-Frank Act of preventing armed groups in the conflict affected and high risk countries from benefitting from the sourcing of Conflict diamonds from that region.
Millennium Star BV is committed to working with its suppliers to educate them on these matters and concerning steps they can take to obtain increased transparency regarding the origin of diamonds mined or manufacture and sell to Millennium Star BV. Millennium Star BV reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy.
Millennium Star BV reserves the right to request additional documentation from its suppliers regarding the origin/source of diamonds sold to Millennium Star BV.
Suppliers who do not reasonably comply with this Policy shall be reviewed by Millennium Star BV 's for future business.
Millennium Star BV is committed to ensuring that our supply chain is free of any diamonds/gemstones which was procured for the support or benefit of armed and anti-social conflict groups or involving serious abuses of human rights and non-compliant with OECD Guidelines.
Millennium Star BV clearly criticizes such activity and will reject any material which we believe was obtained involving serious human rights violations or which benefitted or supported armed rebels or terrorist groups through illegal finance or other activities.
The company shall carry out risk assessment for its supply chain and shall not enter into any business relationship or if may require then shall suspend/discontinue the engagement with any such supplier involved in dealing with Conflict-Affected and High-Risk areas, Any form of Human Right Violation; Torture, Cruel, In-Human and Degrading Treatment; Forced/Compulsory Labour; Child Labour; Abuses such as widespread Sexual Violence; War Crimes; other serious violations of International Humanitarian Law, Crime against Humanity; Genocide and/or To Bribe or To be Bribed. We strictly condemn and prohibit any Direct/Indirect support to public/private security forces which illegally Control, Tax or Extort money from Mining Sites, Transportation Routes and Upstream Sectors.
The Company shall carry out due diligence to assess risks related to procurement from the Conflict-affected and high-risk areas – CAHRAs and shall always source from compliant miners/traders.
We shall always set reasonable efforts to source Diamonds from miners and traders validated as being Conflict Free and require their direct and indirect suppliers to do the same;
We strive to work supportively with our customers and supply chain partners in implementing conflict free compliance programs for Diamond/Jewellery Supply chain.
The company shall always undertake to ensure that the extraction and trade of diamond support peace and development, not conflict.
Millennium Star BV remains committed to enhance its Supply Chain Due Diligence program through internal review and external assessments. We have zero tolerance policy for the supplier violating OECD due diligence guideline and we shall immediately stop commercial relationship if any of our business associates found non-compliant or High-Risk during our internal/external risk assessment.
All the suppliers are also requested to carry our risk assessment and due diligence for their suppliers and products they are sourcing.
Currently Millennium Star BV procure it's diamonds RJC CoP/Ethical business practice compliant miners/traders. However, we have established a strong due diligence process and we shall review it as an when we observed significant risk or upon receipt of any grievance or complaint but in normal course, we shall carry our due diligence process on annual basis.
The company has checked transaction methods and name and individuals of company on SDN list of USA treasury and EU sanction list. All the suppliers are found low in risk and in compliance with OECD requirement of CAHRA's.
We the senior management of Millennium Star BV and compliance officer has verified all our supplier with respect to following;
Publication (Detailed report is with Compliance team and may produce to concerned parties upon request)
RJC CoP Annual Compliance - 2025: The company has carried our ethical business practice and carried out policy and procedure review with respect to it's implementation. The company has complied with latest RJC Code of Practice and all its requirements. Ethical Standard/Commitment-- No practice or conduct observed during the assessment period that brings the diamond industry into disrepute. All businesses practices have adhered to national laws and applicable rules and regulation during the assessment period. The company has done environmental assessment including carbon foot print assessment and report is maintained.
Compliance team of Millennium Star BV has completed the due diligence and Risk assessment of all its Minerals supplier with respect to latest RJC/OECD guideline and we found all our supplier are complying with requirements did not find any risk pertaining to their business involvement in Conflict Affected and high-risk Areas' (CAHR's) or any other human right violation. All internal and external stakeholders fond low on human rights risk. The company has done due diligence and risk assessment covering 17 parameters on human rights.
| No. | Steps | Source of Verification | Classification of Risk | Risk Mitigation Action |
|---|---|---|---|---|
| 1 | Serious abuses associated with the extraction, transport or trade of minerals
| To ensure these all ethical assurance of the seller we verify through supplier information questionnaire, UN social security information, supplier diamond sourcing practice policies other procedures along with their due diligence report and KYC documents along with the declarations pertaining to it. | Low | Any confrontation with such violation by any of supplier; The management of the company shall immediately inform to Ministry of mines of Local government. The company shall procure materiel from socially compliant suppliers and company shall verify details in Public domains to validate compliance with the risk defined. The company shall obtain self declaration from the supplier for the compliance of OECD guidelines. Updated list of Conflict affected areas: https://www.knowyourcountry.com/copy-of-country-reportshttps://www.knowyourcountry.com/human-trafficking |
| 2 | Direct or indirect support to non-state armed groups | Low | We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups. | |
| 3 | Direct or indirect support to public or private security forces who illegally control, tax or extort money from mine sites, transportation routes and S. | Low | We will immediately alert relevant central government authority (e.g. Ministry of Mines) of abusive and exploitative practices occurring in the supply chain; In areas in which minerals are illegally taxed or extorted, we will take immediate steps to ensure that upstream intermediaries and consolidators disclose downstream or publicly the payments made to public or private security forces for the provision of security. We will engage with intermediaries and consolidators to help build their capabilities to document the behaviour of security and payments to security forces. While sourcing from areas of artisanal and small-scale mining ("ASM"), support the formalisation of security arrangements between ASM communities, local government, and public or private security forces, in cooperation with civil society and international organisations, as appropriate, to ensure that all payments are freely made and proportionate to the service provided, clarify rules of engagement consistent with the Voluntary Principles on Security and Human Rights, the UN Code of Conduct for Law Enforcement Officials and the UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials; We will support the establishment of community forums to share and communicate information. We will support the establishment of a trust or other similar fund, where appropriate, through which security forces are paid for their services; We will build partnership with international organisations or civil society organisations, as appropriate, to support capacity building of security forces consistent with the Voluntary Principles on Security and Human Rights, on mine sites, and UN Code of Conduct for Law Enforcement Officials or the UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials | |
| 4 | Bribery and fraudulent misrepresentation of the origin of minerals | Official notifications by DeBeers, Regulatory department notifications and circulars, | Low | We will cooperate through associations, assessment teams or other suitable means to build capabilities of suppliers, in particular SMEs, to conduct due diligence for responsible supply chains of minerals from conflict affected and high-risk areas. Immediately stop commercial relationship and inform to relevant financial Intelligence Unit of the region and relevant government bodies |
| 5 | Money laundering and non-payment of taxes and royalties due to governments | Data bank from World bank, UN security notifications, https://www.un.org/sc/ctc/news/keyword/aml/ Supplier diamond/gemstone sourcing questionnaire, KYC Checks. | Low | We will develop supplier, customer and transactional red flags to identify suspicious behaviour and activities; We will identify and verify the identity of all suppliers, business partners and customers; We will report suspicious behaviour of criminal activity to local, national, regional and international law enforcement agencies. |
| Sr# | Objects (KPI's) | Outcome | Results |
|---|---|---|---|
| 1 | Investment and Procurement Practices | Low Risk | Any suppliers and contractors found violation human rights at workplace? No |
Employees are trained on aspects of human rights that are relevant to operations? Yes all employees are trained twice in a year on Human rights aspects. | |||
Any Sourcing from Conflict affected and High Risk Areas in Assessment year? No sourcing from CAHRA's | |||
| 2 | Non-Discrimination | Low Risk | Total number of incidents of discrimination and actions taken. No discrimination incidents in last one year |
| 3 | Freedom of Association and Collective Bargaining | Low Risk | Operations identified in which the right to exercise freedom of association and collective bargaining may be at significant risk, and actions taken to support these rights. The company has open door management principle for any individual |
| 4 | Child Labour | Low Risk | Operations identified as having significant risk for incidents of child labor, and measures taken to contribute to the elimination of child labor. The entity has not hired any child labour during assessment period and no indirect child labour abuse observed |
| 5 | Forced and Compulsory Labor | Low Risk | Operations identified as having significant risk for incidents of forced or compulsory labor, and measures taken to contribute to the elimination of forced or compulsory labor. No incident of any forced or compulsory or bonded labour observed during interaction with employees. No such incident reported in suggestion/complaint register. |
| 6 | Security Practices | Low Risk | Percentage of security personnel trained in the organization's policies or procedures concerning aspects of human rights that are relevant to operations. Security guards are used only for the protection of company assets and never used to suppress or bully any individuals. They are also trained on Human Right aspects. |
| 7 | Indigenous Rights | Low Risk | Total number of incidents of violations involving rights of indigenous people and actions taken. No violation or threats incident observed during assessment period. |
| Conclusion: KPI's reviewed and verified by the compliance head and management of the company found all Key Indicators are Low Risk. | |||
Date: 30th January 2026
Place: Antwerp/Belgium
