Annual Report

Our Annual Sustainability Report

RUSHIDIAM BV — Annual Sustainability Report

RUSHIDIAM BV · Antwerpen, Belgium

Reporting Policy

Purpose

The purpose of this policy is to ensure that RUSHIDIAM BV maintains awareness of its obligations to report formally, publicly and on a regular basis on its compliance findings to its stakeholders.

Policy

RUSHIDIAM BV undertakes to communicate on a regular basis to stakeholders on our business practices relevant to overall compliance or sustainability efforts; whether in the framework of the RJC programme or other (i.e. BPP/PI reporting).

In order to fulfil its reporting commitments, the following minimum procedures will be observed:

The annual date for reporting is fixed.
Prior to the annual reporting date, a sustainability meeting will be convened which will address: Review of issues on Supply Chain Due Diligence, Human Rights and other minimum reporting requirements; Outstanding issues from external or internal audit(s); New issues to be considered with respect to sustainability; Any other sustainability issues that might arise.
The meeting and the agenda will be prepared by the Compliance Manager and the Director. Meeting participants will be chosen in function of their competence relevant to the compliance issue.
The report issued after the meeting will be approved by the Director and published to be available to the Company's stakeholders.

Responsibility for the Policy

The Director.

Reporting Requirements

Breaches of this policy will be reported to the Director and will be part of the yearly reporting.

Signed

Shaishav Shah, Director — RUSHIDIAM BV

Antwerp, May 15th 2026

Annual Review

RJC Annual Review Meeting

The annual review of the implementation of the Code of Conduct and Responsible Business Practices takes place in the form of a meeting of the Director and local management. The annual review meeting has been conducted at RUSHIDIAM BV on May 15th 2026.

Practice Area	Questions Reviewed	Answers	Corrective Action
Upholding the Law	Are there areas where we are aware of inadequate compliance with the law? Have we checked with our legal advisors to ensure we are up to date with laws and regulations? Are there changes in legislation that we need to adapt our practices to meet? Are there new legal requirements that our employees need to be informed of?	NoYesNoNo	—
Aligning and Promoting Responsible Industry Practice	Have we maintained our membership of RJC? Have we followed the policies and guidelines of the WCD/RJC/SOW/Kimberley Process? Is there anything more we should do to promote responsible industry practices?	YesYesNo	—
Supporting Human Rights in our Supply Chain	Did we source from any Artisanal or Small-Scale Mining (ASM) operation or area? Did we perform a due diligence check on Human Rights issues with all our stakeholders? Were any red flags raised in the process? Did we implement a Human Rights Due Diligence review? Were any adverse Human Rights impacts observed for the past year? Is our workplace free of discrimination and harassment? Do we comply with all labor laws? Have we conducted a safety risk assessment in the past year? Have we compensated our employees in line with our terms and conditions? Have we invested in our employees' development? Have we ensured we do not employ children or forced labor in our operations?	NoYesNoYesNoYesYesYesYesYesYes	—
Standing against Corruption and Bribery	Have we assessed our business for corruption and bribery risks? Are we sure we are fully compliant with all relevant legislation? Have we appropriately dealt with any incidents of corruption or bribery that occurred? Have we maintained appropriate financial records of all our transactions and audited our inventories in line with policy?	YesYesYesYes	—
Security	Were the necessary security measures maintained in our offices?	Yes	—
Health & Safety	Have the necessary systems, procedures and tools been implemented and/or updated to safeguard a healthy and safe working environment for all? Have there been any H&S issues during the last year?	YesNo	—
Anti-Money Laundering	Have we performed due diligence checks on new customers and suppliers? Have we ensured all our customer and supplier transactions are in line with regulated and defined procedures? Did we file and keep on record proper KYC/Annual AML report documentation? Did at least 1 Director follow the yearly AML Training Course?	YesYesYesYes	—
Provenance Claims	Are all provenance claims properly listed and are we confident that we can back up all claims with written statements by our suppliers?	Yes	—
Supply Chain Due Diligence	Have we sent out our Supply Chain Policy to all our suppliers? Have we sent out and received the Supply Chain Due Diligence Questionnaire to/from ALL our suppliers? Were there any red flag situations with any of our suppliers? If so, has appropriate action been undertaken? Are there any changes to our supply chain mapping?	YesYesNoN/ANo	—
Respecting the Environment	Have we minimized our use of electricity, water, fuel and taken care to minimize waste? Have we recycled our paper and (electronic) waste? Have we avoided business travel unless absolutely necessary?	YesYesYes	—
Risk Management	Have we conducted a business risk assessment and taken appropriate mitigation action? Did we put in place procedures to avoid purchasing and/or selling any goods from countries on sanction lists?	YesYes	—
Communication of our Code of Conduct	Have we informed all new employees of our Code of Conduct? Have we included the Code of Conduct in contracts with new suppliers? Have we encouraged suppliers and partners to align their practices with this Code of Conduct?	NoNoNo	Business/Supplier Code of Conduct under review.
Reporting of Breaches of our Code of Conduct	Have we collaborated effectively in resolving any reported breaches of our Code of Conduct? Did we publicly report on important issues like Human Rights, Supply Chain Due Diligence and overall commitment?	YesYes	—
Training of Personnel	Have all staff and personnel been sufficiently trained in all relevant aspects?	Yes	—

Upholding the Law

Are there areas where we are aware of inadequate compliance with the law?

Have we checked with our legal advisors to ensure we are up to date with laws and regulations?

Yes

Are there changes in legislation that we need to adapt our practices to meet?

Are there new legal requirements that our employees need to be informed of?

Aligning and Promoting Responsible Industry Practice

Have we maintained our membership of RJC?

Yes

Have we followed the policies and guidelines of the WCD/RJC/SOW/Kimberley Process?

Yes

Is there anything more we should do to promote responsible industry practices?

Supporting Human Rights in our Supply Chain

Did we source from any Artisanal or Small-Scale Mining (ASM) operation or area?

Did we perform a due diligence check on Human Rights issues with all our stakeholders?

Yes

Were any red flags raised in the process?

Did we implement a Human Rights Due Diligence review?

Yes

Were any adverse Human Rights impacts observed for the past year?

Is our workplace free of discrimination and harassment?

Yes

Do we comply with all labor laws?

Yes

Have we conducted a safety risk assessment in the past year?

Yes

Have we compensated our employees in line with our terms and conditions?

Yes

Have we invested in our employees' development?

Yes

Have we ensured we do not employ children or forced labor in our operations?

Yes

Standing against Corruption and Bribery

Have we assessed our business for corruption and bribery risks?

Yes

Are we sure we are fully compliant with all relevant legislation?

Yes

Have we appropriately dealt with any incidents of corruption or bribery that occurred?

Yes

Have we maintained appropriate financial records of all our transactions and audited our inventories in line with policy?

Yes

Security

Were the necessary security measures maintained in our offices?

Yes

Health & Safety

Have the necessary systems, procedures and tools been implemented and/or updated to safeguard a healthy and safe working environment for all?

Yes

Have there been any H&S issues during the last year?

Anti-Money Laundering

Have we performed due diligence checks on new customers and suppliers?

Yes

Have we ensured all our customer and supplier transactions are in line with regulated and defined procedures?

Yes

Did we file and keep on record proper KYC/Annual AML report documentation?

Yes

Did at least 1 Director follow the yearly AML Training Course?

Yes

Provenance Claims

Are all provenance claims properly listed and are we confident that we can back up all claims with written statements by our suppliers?

Yes

Supply Chain Due Diligence

Have we sent out our Supply Chain Policy to all our suppliers?

Yes

Have we sent out and received the Supply Chain Due Diligence Questionnaire to/from ALL our suppliers?

Yes

Were there any red flag situations with any of our suppliers?

If so, has appropriate action been undertaken?

N/A

Are there any changes to our supply chain mapping?

Respecting the Environment

Have we minimized our use of electricity, water, fuel and taken care to minimize waste?

Yes

Have we recycled our paper and (electronic) waste?

Yes

Have we avoided business travel unless absolutely necessary?

Yes

Risk Management

Have we conducted a business risk assessment and taken appropriate mitigation action?

Yes

Did we put in place procedures to avoid purchasing and/or selling any goods from countries on sanction lists?

Yes

Communication of our Code of Conduct

Have we informed all new employees of our Code of Conduct?

Have we included the Code of Conduct in contracts with new suppliers?

Have we encouraged suppliers and partners to align their practices with this Code of Conduct?

Corrective action: Business/Supplier Code of Conduct under review.

Reporting of Breaches of our Code of Conduct

Have we collaborated effectively in resolving any reported breaches of our Code of Conduct?

Yes

Did we publicly report on important issues like Human Rights, Supply Chain Due Diligence and overall commitment?

Yes

Training of Personnel

Have all staff and personnel been sufficiently trained in all relevant aspects?

Yes

Signed

Shaishav Shah, Director — RUSHIDIAM BV

Antwerp, May 15th 2026

Management Review

Yearly Sustainability Report & Management Review Meeting

An annual management review meeting has been conducted at RUSHIDIAM BV on May 15th 2026. The following points were reviewed:

There are no changes observed in the section 'General Requirements'.

All our Business Partners are screened with regards to AML legislation, Human Rights due diligence and Bribery issues and no major risks have been assessed.

We have implemented a Human Rights Due Diligence review and no adverse Human Rights impacts have been observed for the past year.

We have rolled out our implementation of the COP7 standard in line with our policy and procedures.

No direct sourcing from artisanal and small-scale mining has occurred in the past year.

The security in our offices has been maintained at a satisfactory level and no security breaches have been observed.

We have completed a process to obtain written assurances from all our suppliers concerning provenance claims.

No violations to labour rights and working conditions have been observed.

There have been no Health & Safety occurrences in the period under review.

No breach of product integrity has been observed and all procedures have been followed.

No new risks have been identified.

Signed

Shaishav Shah, Director — RUSHIDIAM BV

Antwerp, May 15th 2026

← Back to Ethical Sourcing