ANNUAL STATEMENT ON RESPONSIBLE BUSINESS PRACTICES

Reporting Year: 2026 

During this reporting period, Chatham Created Gems, Inc. continued to strengthen its systems for ethical sourcing, environmental stewardship, and human rights protection. Our policies and procedures are reviewed regularly and remain aligned with recognized international frameworks, including the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs).

We continued to focus on responsible sourcing of gold, platinum group metals, lab-grown colored gemstones, lab-grown diamonds, and mined diamonds, as well as supplier transparency and OECD-aligned due diligence. In 2026, Chatham also completed its RJC recertification cycle for the Code of Practices and Laboratory Grown Material Standard and continued preparing for the next required surveillance audit.

Key Areas of Progress:

1.       Supply Chain Due Diligence

Wemaintained a structured due diligence program supported by regular Know Your Counterparty (KYC) updates, supplier risk reviews, and additional requests when ownership, business information, location, product or material scope changed. We also continued reviewing invoices and supplier activity for indicators that new materials, jurisdictions, refiners, smelters, or sourcing details required follow-up.

Actions included:

·      Completing OECD Step 2-3 assessments and documenting supplier risk reviews.

·      Monitoring invoices and supplier activity for material-scope changes, including gold, platinum group metals, lab-grown colored gemstones, lab-grown diamonds, and mined diamonds.

·      Triggering CAHRA re-screening and supplemental disclosure requests when sourcing scope changed or documentation was incomplete.

·      Continuing the use of OECD-aligned supplier forms and templates to improve origin, refiner, smelter, and upstream sourcing disclosures.

·      Strengthening onboarding and account-review expectations, including documentation to verify legal entity, business address, and trade status where applicable.

 

These measures supported improved traceability, more consistent recordkeeping, and clearer escalation steps for missing or incomplete sourcing information.

2.    Policy Framework and Implementation

Our Commitment to Responsible Business Practices, Human Rights Policy, Due Diligence/Responsible Sourcing Policy, CAHRA Identification Procedure, Anti-Bribery/Anti-Corruption Policy, and AML/KYC Policy and Procedures remained central to our compliance program. Policies continued to be made available internally and, on our website, and supplier acknowledgments were requested as part of our responsible sourcing and compliance review process.

 

In 2026, Chatham refreshed internal training materials and related procedures so employees could review key compliance obligations. Separate training acknowledgments continued to be maintained for recordkeeping. These updates supported consistent implementation of the policies across onboarding, supplier review, CAHRA identification, escalation procedures, and documentation follow-up. 

3.    Risk Identification and Mitigation

Chatham continued to evaluate actual and potential risks connected to supplier transparency, incomplete sourcing disclosures, delays in upstream documentation, CAHRA exposure, and changes in supplier or material scope. The previously identified supplier transparency risk involving a supplier that refused to complete KYC or disclose its own suppliers remained resolved through disengagement in 2024, consistent with our risk management procedures.

For 2026, risk mitigation focused on reinforcing documentation requirements, maintaining defined response timelines, documenting escalation steps, and using hold, review, or disengagement measures when required. Improvements identified through the RJC recertification process were also incorporated into internal controls, including annual review procedures, training-completion tracking, and timekeeping controls.

4.    Training and Capacity Building

Staff training and retraining materials were updated to address the Human Rights Policy, grievance procedures, recognition of potential human rights and supply chain risks, OECD Steps 1-5, CAHRA identification, supplier engagement expectations, AML/KYC expectations, and risk mitigation procedures. Training records and acknowledgments continued to be retained separately from training-copy documents.

Supplier capacity building continued through direct communication, follow-up on missing or incomplete sourcing details, and assistance with OECD-aligned forms. These activities reinforced human rights protections, improved supplier responsiveness, and supported ongoing transparency across covered material categories.

5.    Grievance Mechanisms and Outcomes

Our grievance mechanisms remain accessible through dedicated communication channels and our website. No grievances related to human rights risks or supply chain due diligence were identified through these channels during the current reporting period.

Overall outcomes included:

·      Continued RJC Code of Practices and Laboratory Grown Material Standard certification, with certificates issued in May 2026 and a certification period of May 15, 2026 through February 15, 2029.

·      No confirmed human rights violations identified through grievance or due diligence channels.

·      Continued improvement in supplier disclosure follow-up, CAHRA screening documentation, and escalation tracking.

·      Stronger internal training, onboarding, and compliance recordkeeping practices.

 

Looking Ahead

Through the remainder of 2026 and the next reporting cycle, Chatham will continue building supplier capacity, strengthening upstream documentation verification, and enhancing monitoring systems.

 Planned actions include:

· Preparing for the next required RJC surveillance audit within the applicable audit window.

· Continuing regular supplier KYC updates and risk assessments, with immediate follow-up on ownership, business, location, product, or material-scope changes.

· Further integrating escalation procedures into supplier management to support timely responses and complete documentation.

· Continuing targeted staff training and supplier engagement on responsible sourcing, human rights, CAHRA identification, and grievance procedures.

· Maintaining website disclosures and accessible grievance channels for internal and external stakeholders.

 

We remain committed to transparency with stakeholders, ongoing alignment with recognized due diligence standards, and continuous improvement in responsible business practices.

POLICY COMMITMENTS & RESPONSIBLE SOURCING

 

Responsible Jewellery Council (RJC) Policy

Chatham Created Gems, Inc. (“Chatham”) is a member of the Responsible Jewellery Council (RJC).

The RJC is a standards-setting organization established to advance responsible ethical, human rights, social, and environmental practices throughout the gold, silver, platinum group metals, mined diamonds, lab-grown diamonds, lab-grown colored gemstones, and colored gemstone jewelry supply chain.

The RJC has developed benchmark standards for the jewelry supply chain and credible mechanisms for verifying responsible business practices through third-party auditing. As an RJC member, we commit to operating our business in accordance with theRJC Code of Practices (COP) Standard. Where applicable, Chatham also follows theRJC Laboratory Grown Material Standard (LGMS) for lab-grown diamonds and lab-grown colored gemstones within our certification scope.

We commit to integrating ethical, human rights, social, and environmental considerations into our day-to-day operations, business planning activities, and decision-making processes. 

Human and Labor Rights

We are committed to respecting all human rights in our own operations and business relationships in accordance with theUniversal Declaration of Human Rights (UDHR), theUN Guiding Principles on Business and Human Rights, and relevant conventions of theInternational Labour Organization (ILO). Our human rights policy covers the following key commitments:

·      All forms of violence and harassment in the workplace are prohibited, including but not limited to corporal punishment, harsh or degrading treatment, sexual or physical harassment, mental, physical, verbal, or sexual abuse, retaliation, coercion, and intimidation. Both direct and indirect harassment in any form is not acceptable in workplace facilities. We are committed to ensuring that our employees are not subjected to harassment or violence, or threatened with such behavior toward themselves, their families, or colleagues.

·      To never engage in or knowingly support child labor (including the worst forms of child labor) as defined by theInternational Labour Organization (ILO) conventions 138 and 182.

·      To never engage in or knowingly support forced labor as defined by the International Labour Organization (ILO) Convention 29, including bonded labor, deceptive recruitment, human trafficking, and indentured or involuntary prison labor.

·      To provide a safe and healthy working environment for all employees.

·      To treat employees with dignity and respect, which includes:

o  Ensuring fair and transparent discipline and grievance procedures.

o  Recognizing and respecting the right of all employees to associate freely and enter into collective bargaining. 

o  Providing all employees with fair terms of employment and legally mandated benefits.

o  Prohibiting all forms of discrimination, including but not limited to discrimination based on race, color, ethnicity, caste, national origin, religion, disability or genetic information, gender, sexual orientation,

union membership, political affiliation, marital status, parental or pregnancy status, physical appearance, HIV status, age, or any other personal characteristic unrelated to the inherent requirements of the work.

o  Promoting human rights in our dealings with business partners and other relevant stakeholders.

 

Chatham expects all its employees, suppliers, and subcontractors to take steps to ensure that this policy is adhered to.

 

 

Bribery and Corruption

We prohibit bribery and corruption in all business practices and transactions carried out by employees and by agents acting on our behalf. For the purpose of this policy, bribery is defined as giving, offering, or receiving any undue advantage to or from:

·      A public or government official

·      A political candidate, party, or official

·      Any private-sector employees, directors or officers, or their agents or representatives

 

Anti-Money Laundering and Financing of Terrorism

We commit to not engaging in or contributing to money laundering or the financing of terrorism. Chatham has implemented Anti-Money Laundering (AML) and Know Your Counterparty (KYC) procedures to:

·      Establish the identity of all counterparties.

·      Verify that counterparties and, if applicable, beneficial owners are not named on relevant government lists for individuals or organizations implicated in money laundering, fraud, or involvement with prohibited organizations and/or those financing conflicts.

·      Maintain an understanding of the nature and legitimacy of the businesses operated by counterparties.

·      Monitor transactions for unusual or suspicious activity. 

 

Environmental Management

We commit to reducing and managing the environmental impacts of our business operations through the implementation of an Environmental Management System (EMS). This includes:

·      Managing all wastes and emissions to air, water, and land

·      Establishing energy and water efficiency measures

·      Seeking to ensure the responsible and efficient use of other natural resources, where applicable

 

Product Disclosure

We will not knowingly make any untruthful, misleading, or deceptive representation, or make any material omission in the selling, advertising, or marketing of jewelry products and materials. We further commit to disclosing information on the physical characteristics of jewelry products and materials in accordance with the Responsible Jewellery Council (RJC) Code of Practices Standard.

 

Conflict Diamonds

We will not knowingly buy or sell Conflict Diamonds[1] and require that all our suppliers of diamonds comply with the requirements of theKimberley Process Certification Scheme (KPCS) andWorld Diamond Council System of Warranties (SoW).

 

Supply Chain Policy – Conflict-Affected and High-Risk Areas (CAHRAs)

1.    This policy confirms our commitment to respecting human rights, preventing the financing of conflict, and complying with all relevant UN sanctions, resolutions, and laws.

2.    As a member of theResponsible Jewellery Council (RJC), we commit to proving, through independent third-party verification, that we:

·      Respect human rights according to the Universal Declaration of Human Rights and the International Labour Organization Declaration on Fundamental Principles and Rights at Work.

·      Do not engage in or tolerate bribery, corruption, money laundering, or financing of terrorism.

·      Support transparency of government payments and 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.

·      Are implementing theOECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

3.    We also commit to using our influence to prevent abuses by others.

4.    Regarding serious abuses associated with the extraction, transport, or trade of gold, silver, platinum group metals, diamonds, and colored gemstones: We will neither tolerate nor profit from, contribute to, assist, or facilitate the commission of:

·      Torture, cruel, inhuman, and degrading treatment

·      Forced or compulsory labor

·      The worst forms of child labor

·      Human rights violations and abuses

·      War crimes, violations of international humanitarian law, crimes against humanity, or genocide

5.    We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4, or are sourcing from, or linked to, any party committing these abuses.

6.    Regarding direct or indirect support to non-state armed groups: We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gold, silver, platinum group metals, diamonds and colored gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

·      Control mine sites, transportation routes, points where gold, silver, platinum group metals, diamonds, and colored gemstones are traded, and upstream actors in the supply chain.

 

·      Tax or extort money, or minerals at mine sites, along transportation routes, or at points where gold, silver, platinum group metals, diamonds, and colored gemstones are traded, or from intermediaries, export companies, or international traders.

7.    We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.

8.    Regarding public or private security forces: We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment, and property in accordance with the rule of law, including the law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4, or that act illegally as described in paragraph 6.

9.    Regarding bribery and fraudulent misrepresentation of the origin of gold, silver, platinum group metals,diamonds and colored gemstones: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, silver, platinum group metals, diamonds and colored gemstones, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold, silver, platinum group metals, diamonds and colored gemstones.

10. Regarding money laundering:We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from or connected to the extraction, trade, handling, transport, or export of gold, silver, platinum group metals, diamonds, and colored gemstones.

 

Grievance Procedure

Chatham has established this procedure to hear any concerns or complaints from interested parties and stakeholders regarding its supply chain and business practices.

Concerns can be raised by interested parties via email using the following contact information:

Name: Maya Mather

Title:   Compliance Officer

Email:  compliance@chatham.com

 

On receiving a complaint, we will aim to:

• Contact you as soon as possible to gather more information regarding your grievance, where applicable.

• Decide who is the appropriate person internally to handle the grievance, or help redirect you to another entity, such as a relevant company, industry body, or other organization.

• Identify any actions we should take (if any) or monitor the situation.

• Advise you of any decisions or outcomes.

• Keep records on grievances received and the internal process followed to address such grievances, for at least five years.

 

 

Appendix A – Responsible Sourcing Guidelines for Precious Metals (Platinum, Gold & Silver)

As part of our commitment to ethical sourcing and compliance with the Responsible Jewellery Council (RJC) Code of Practices (COP),Chatham Created Gems, Inc. (“Chatham”) expects all gold, platinum group metals and silver suppliers to meet the responsible sourcing standards outlined in this policy. These requirements support conflict-free, traceable supply chains and are aligned with internationally recognized frameworks including:

·      OECD Due Diligence Guidance

·      LBMA Good Delivery Standards

·      RJC Chain of Custody Standard

·      SCS Global Services certification or assurance programs, where applicable

·      World Gold Council Conflict-Free Gold Standard

 

A. Acceptable Refinery Sources

Chatham only accepts gold, silver, and platinum group metals from refineries that meet at least one of the following standards:

·      Listed on the applicable current Good Delivery list:

Good-Delivery Current List - Gold

Good-Delivery Current List - Silver

LPPM - Platinum Metals

·      Included in the RMI RMAP Conformant Refiners List

RMI RMAP Conformant List

·      Certified Members of the Responsible Jewellery Council (RJC)

Responsible Jewellery Council Member Directory

·      Independently audited refiners that certify all gold, silver, and platinum group metals are conflict-free, following one or more of these standards:

1.    RJC Chain of Custody Standard
RJC Member Certification • COC 2024 • Responsible Jewellery Council

2.    OECD Due Diligence Guidance for Minerals from CAHRAs

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas | OECD

3.    SCS Global Services certification or assurance programs, where applicable

SCS Global Services - Mining, Refining and Jewelry

4.    World Gold Council Conflict-Free Standard

Standards on Gold | World Gold Council

 

B. Subcontractors of Component Parts or Finished Products 

Chatham requires that all subcontractors meet the same conflict-free sourcing standards as our direct suppliers. This means our suppliers must ensure their subcontractors are also compliant with the guidelines outlined in this policy. Acceptable sources include:

·      Subcontractors who certify and are independently audited to confirm that all gold, silver, and platinum group metals are sourced from refineries and/or precious metals trading companies that meet the requirements listed under Section A – Acceptable Refinery Sources above.

OR 

·      Subcontractors who certify and are independently audited to confirm that their supplies of gold, silver, and platinum group metals are conflict-free in accordance with any of the following recognized standards:

1.    The RJC Chain of Custody Standard for Precious Metals

RJC-2024-COC-Standard

2.    RJC Membership Certification, including verified “Provenance Claims” under the RJC Code of Practices

3.    The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Supplement on Gold

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas | OECD

4.    SCS Global Services certification or assurance programs, where applicable

SCS Global Services – Mining, Refining and Jewelry

 

Summary

Chatham expects all suppliers to maintain transparent documentation and conduct reasonable due diligence to ensure all gold, silver, and platinum group metals provided are responsibly sourced, conflict-free, and traceable.

We appreciate your cooperation in supporting our ethical sourcing commitments and global compliance standards.