PAT Holding Company Limited located at 143/2 Soi Prasartsuk Yenarkart Road Chong Nongsri Yannawa 10120 Bangkok Thailand is committed to adhering to Corporate Social Responsibility (CSR) principles, Responsible Jewellery Council (RJC) Standards, and client requirements. We recognize the importance of sustainability, providing benefits, supporting communities, and conserving the environment. Our goal is to foster a culture of social and organizational responsibility that benefits the community through collaboration with stakeholders, including employees, business partners, communities, and government agencies.

Human and Labour Rights

We are dedicated to upholding human rights in our operations and business relationships in accordance with the UN Guiding Principles on Business and Human Rights, International Labour Organization (ILO) conventions, and RJC Code of Practices (COP) requirements. Our key commitments include:

• Prohibiting all forms of violence and harassment in the workplace, including corporal punishment, harsh or degrading treatment, sexual or physical harassment, verbal abuse, coercion, and intimidation. Harassment, whether direct or indirect, is strictly unacceptable.
• Never engaging in or supporting child labor (including the worst forms of child labor) as defined by ILO Conventions 138 and 182.
• Never engaging in or supporting forced labor as defined by ILO Convention 29, including bonded labor, human trafficking, and deceptive recruitment.
• Prohibiting all forms of discrimination based on race, ethnicity, caste, national origin, religion, disability, gender, sexual orientation, political affiliation, marital or pregnancy status, or any other characteristic unrelated to job requirements.
• Upholding the right to freedom of association in compliance with local laws, international standards, and RJC requirements.
• Ensuring regular working hours do not exceed 48 hours per week, with a total maximum of 60 hours per week as per local law. Employees are entitled to one day off after six consecutive working days.
• Providing fair wages and benefits in compliance with local laws.
• Promoting human rights through interactions with business partners and stakeholders.

Bribery and Corruption

We strictly prohibit bribery and corruption in all business practices and transactions. Bribery is defined as offering, giving, or receiving any undue advantage to or from:

• Public or government officials,
• Political candidates, parties, or officials, or
• Private sector employees, directors, or agents.

Anti-Money Laundering and Financing of Terrorism

As part of our compliance with RJC Standards and industry best practices, we are committed to preventing money laundering and the financing of terrorism. To achieve this, we have implemented Anti-Money Laundering (AML) and Know Your Counterparty (KYC) procedures, which include:

• Verifying the identity of all counterparties.
• Ensuring counterparties and beneficial owners are not listed on government databases for money laundering, fraud, or prohibited activities.
• Understanding the nature and legitimacy of counterparties’ businesses.
• Monitoring transactions for unusual or suspicious activity.

Occupational Health & Safety Management

We comply with all relevant health and safety laws and provide a safe working environment. We prioritize education and awareness about health and safety for employees and on-site contractors. Our Occupational Health & Safety practices align with RJC Code of Practices requirements to ensure continuous improvement and legal compliance.

Environmental and Energy Management

We are committed to reducing and managing the environmental impacts of our operations by:

• Managing waste and emissions responsibly.
• Promoting the efficient use of natural resources.
• Complying with environmental laws, including waste disposal and wastewater management.
• Adopting the principles of Reduce, Reuse, and Recycle (3R) to benefit the environment, communities, and employees.
• Ensuring compliance with RJC Standards for environmental impact management.

Product Disclosure

We are committed to transparency in disclosing information about the physical characteristics of jewelry products and materials in line with Corporate Social Responsibility, RJC Standards, and client requirements. We aim to build strong relationships with suppliers and business partners to promote responsible practices across our supply chain. To achieve this, we conduct due diligence on all suppliers in alignment with the UN Guiding Principles on Business and Human Rights and RJC Code of Practices.

This policy is documented, communicated to all interested parties, and consistently applied throughout the organization. Compliance with RJC Standards is monitored and reviewed regularly to ensure adherence to industry-leading ethical and sustainability practices.

PAT Holding Company Limited is recognized as one of the world’s leading jewelry and gems centers. Our company emphasizes creating value and success with our customers through the development and production of costume jewelry and accessories. This policy confirms our commitment to respecting human rights, avoiding contributions to the financing of conflict, and complying with all relevant UN sanctions, resolutions, and laws.

Commitment to Responsible Practices

As a certified member of the Responsible Jewellery Council (RJC), PAT Holding Company Limited commits to proving through independent third-party verification that we:

• Respect human rights as per the Universal Declaration of Human Rights and the International Labour Organization (ILO) Fundamental Rights at Work;
• Do not engage in or tolerate bribery, corruption, money laundering, or the financing of terrorism;
• Support transparency in government payments and ensure rights-compatible security forces in the extractives industry;
• Do not provide direct or indirect support to illegal armed groups;
• Enable stakeholders to voice concerns about the jewelry supply chain; and
• Implement the OECD 5-Step Framework as a risk-based due diligence management process for responsible supply chains of minerals from conflict-affected and high-risk areas.

Supply Chain Risk Management

1. Risk Assessment and Supplier Engagement:
   • The company shall conduct a regular risk assessment of its supply chain.
   • The company will not enter into or continue any business relationship with suppliers involved in:
     • Conflict-affected and high-risk areas;
     • Human rights violations, including torture, forced or compulsory labor, child labor, or sexual violence;
     • War crimes, crimes against humanity, or other serious violations of international humanitarian law.
2. Verification and Monitoring:
   • The company will verify counterparty details, including Know Your Customer (KYC) procedures, for all suppliers of precious gemstones and metals.
   • Risk-based assessments will be performed, with appropriate verification controls and monitoring of commercial activities and transactions.
3. Assignment of Responsibility:
   • Senior personnel will be assigned to ensure Supply Chain Integrity and compliance with due diligence processes.
   • This role will focus on preventing risks of illegal activities or breaches of compliance standards.
4. High-Risk Supplier Management:
   • Suppliers identified as high-risk through the company’s risk assessment module will be flagged.
   • A report on these suppliers will be submitted to senior management for review and decision-making.

Specific Policies for Supply Chain Practices

Regarding Serious Abuses in the Extraction, Transport, or Trade of Gemstones:
We will not tolerate, profit from, or assist in any of the following:

• Torture, cruel, inhuman, or degrading treatment;
• Forced or compulsory labor;
• The worst forms of child labor;
• Human rights violations or abuses;
• War crimes, crimes against humanity, or genocide.

If we identify a reasonable risk that an upstream supplier is involved in such activities, we will immediately cease engagement with them.

Regarding Direct or Indirect Support to Non-State Armed Groups:
We only trade in diamonds and colored gemstones that are fully compliant with the Kimberley Process Certification Scheme. We will not tolerate direct or indirect support to non-state armed groups, including:

• Procuring materials from or making payments to such groups;
• Supporting groups that illegally control mine sites, transportation routes, or trading points;
• Allowing taxation, extortion, or illegal transactions related to diamonds or gemstones.

If we identify a reasonable risk that an upstream supplier is involved in such activities, we will immediately cease engagement with them.

Regarding Public or Private Security Forces:
We affirm that public and private security forces must operate lawfully to provide security for workers, facilities, and property, while respecting human rights. We will not support any security forces involved in abuses or illegal actions.

Regarding Bribery and Fraudulent Misrepresentation of Origin:
We will not offer, promise, give, or demand bribes. We will resist attempts to:

• Conceal or falsify the origin of metals, diamonds, or gemstones;
• Misrepresent taxes, fees, or royalties paid to governments for the extraction, trade, or export of these materials.

Regarding Money Laundering:
We will support efforts to eliminate money laundering and address any reasonable risks associated with the extraction, trade, or handling of metals, diamonds, or gemstones.

Policy Communication and Application

This policy will be documented, communicated to all relevant parties, and consistently applied within the organization.