Our Annual Sustainability Report
RUSHIDIAM BV — Annual Sustainability Report
Our 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
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 |
| NoYesNoNo | — |
| Aligning and Promoting Responsible Industry Practice |
| YesYesNo | — |
| Supporting Human Rights in our Supply Chain |
| NoYesNoYesNoYesYesYesYesYesYes | — |
| Standing against Corruption and Bribery |
| YesYesYesYes | — |
| Security |
| Yes | — |
| Health & Safety |
| YesNo | — |
| Anti-Money Laundering |
| YesYesYesYes | — |
| Provenance Claims |
| Yes | — |
| Supply Chain Due Diligence |
| YesYesNoN/ANo | — |
| Respecting the Environment |
| YesYesYes | — |
| Risk Management |
| YesYes | — |
| Communication of our Code of Conduct |
| NoNoNo | Business/Supplier Code of Conduct under review. |
| Reporting of Breaches of our Code of Conduct |
| YesYes | — |
| Training of Personnel |
| Yes | — |
Upholding the Law
Are there areas where we are aware of inadequate compliance with the law?
NoHave we checked with our legal advisors to ensure we are up to date with laws and regulations?
YesAre there changes in legislation that we need to adapt our practices to meet?
NoAre there new legal requirements that our employees need to be informed of?
NoAligning and Promoting Responsible Industry Practice
Have we maintained our membership of RJC?
YesHave we followed the policies and guidelines of the WCD/RJC/SOW/Kimberley Process?
YesIs there anything more we should do to promote responsible industry practices?
NoSupporting Human Rights in our Supply Chain
Did we source from any Artisanal or Small-Scale Mining (ASM) operation or area?
NoDid we perform a due diligence check on Human Rights issues with all our stakeholders?
YesWere any red flags raised in the process?
NoDid we implement a Human Rights Due Diligence review?
YesWere any adverse Human Rights impacts observed for the past year?
NoIs our workplace free of discrimination and harassment?
YesDo we comply with all labor laws?
YesHave we conducted a safety risk assessment in the past year?
YesHave we compensated our employees in line with our terms and conditions?
YesHave we invested in our employees' development?
YesHave we ensured we do not employ children or forced labor in our operations?
YesStanding against Corruption and Bribery
Have we assessed our business for corruption and bribery risks?
YesAre we sure we are fully compliant with all relevant legislation?
YesHave we appropriately dealt with any incidents of corruption or bribery that occurred?
YesHave we maintained appropriate financial records of all our transactions and audited our inventories in line with policy?
YesSecurity
Were the necessary security measures maintained in our offices?
YesHealth & Safety
Have the necessary systems, procedures and tools been implemented and/or updated to safeguard a healthy and safe working environment for all?
YesHave there been any H&S issues during the last year?
NoAnti-Money Laundering
Have we performed due diligence checks on new customers and suppliers?
YesHave we ensured all our customer and supplier transactions are in line with regulated and defined procedures?
YesDid we file and keep on record proper KYC/Annual AML report documentation?
YesDid at least 1 Director follow the yearly AML Training Course?
YesProvenance Claims
Are all provenance claims properly listed and are we confident that we can back up all claims with written statements by our suppliers?
YesSupply Chain Due Diligence
Have we sent out our Supply Chain Policy to all our suppliers?
YesHave we sent out and received the Supply Chain Due Diligence Questionnaire to/from ALL our suppliers?
YesWere there any red flag situations with any of our suppliers?
NoIf so, has appropriate action been undertaken?
N/AAre there any changes to our supply chain mapping?
NoRespecting the Environment
Have we minimized our use of electricity, water, fuel and taken care to minimize waste?
YesHave we recycled our paper and (electronic) waste?
YesHave we avoided business travel unless absolutely necessary?
YesRisk Management
Have we conducted a business risk assessment and taken appropriate mitigation action?
YesDid we put in place procedures to avoid purchasing and/or selling any goods from countries on sanction lists?
YesCommunication of our Code of Conduct
Have we informed all new employees of our Code of Conduct?
NoHave we included the Code of Conduct in contracts with new suppliers?
NoHave we encouraged suppliers and partners to align their practices with this Code of Conduct?
NoCorrective 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?
YesDid we publicly report on important issues like Human Rights, Supply Chain Due Diligence and overall commitment?
YesTraining of Personnel
Have all staff and personnel been sufficiently trained in all relevant aspects?
YesSigned
Shaishav Shah, Director — RUSHIDIAM BV
Antwerp, May 15th 2026
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