NOVITA RESPONSIBLE BUSINESS POLICY 2024

NOVITA is a jewelry wholesale distributing company in the state of California. We have 1 site located in Monrovia, CA and we employ 21 personnel.

NOVITA is a certified member of the Responsible Jewelry Council (RJC). The RJC is a standards-setting organization that has been established to advance responsible ethical, human rights, social and environmental practices throughout the diamond, colored gem stones, gold and platinum group metals jewelry supply chain. The RJC has developed a benchmark standard for the jewelry supply chain and credible mechanisms for verifying responsible business practices through third-party auditing.

As an RJC certified member, we commit to operating our business in accordance with the RJC Code of Practices. We commit to embedding the Sustainable Development Goals (SDGs) into our organizational goals and policies, linked to provisions on responsible sourcing, human rights, general employment terms, working hours, harassment training, violence policy, discipline and grievance procedures, child labor, forced labor, freedom of association and collective bargaining, non-discrimination, health and safety, use of natural resources and community development, foundations of Diversity, Equity and Inclusion (DEI), gender equality, and practices of Pay Equity. We reinforce an understanding that our company will potentially terminate business with any suppliers that use forced labor.

NOVITA is a member of Cal Chamber. We receive advocacy newsletters and alerts covering the latest business and legislative news. We have access to local, state and federal laws regarding labor, human rights, hazardous material, etc. We attend business policy related webinars and sign up for online training courses.

For business ethical considerations we have set Anti Money Laundering (AML), Anti-Bribery, supplier terms of business, and Know Your Counterparty (KYC) policies.

We are also reducing greenhouse gases within our operations to help advance climate action. We are aware of the impact businesses have on the environment, and we are sensitive with our daily practices: reduction of waste, recycling bags, conserving the use of energy and water, etc.

Socially, diversity, equity and inclusivity (DEI) is a part of our policy. We have an equal percentage of men and women in management.

Management shall conduct annual reviews to assess adequacy of the business practices to make improvements and address any gaps. Our due diligence procedures are available upon request.

As our industry moves forward to responsible practices, we ask that as part of your grievances you let us know if there are any violations in the supply chain by emailing at order@novitamail.com.

Our policies and procedures are publicly accessible, on our website, posted in our office, and they are available upon request.

NOVITA Management

March 2024

Responsible Conflict-Free Supply Chain Sourcing Policy 2024

1. NOVITA is a gold & silver jewelry wholesale distributing company. This policy confirms NOVITA’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

2. NOVITA is a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:

   • a. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;
   • b. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
   • c. support transparency of government payments and rights-compatible security forces in the extractives industry;
   • d. do not provide direct or indirect support to illegal armed groups;
   • e. enable stakeholders to voice concerns about the jewelry supply chain; and
   • f. are implementing the OECD 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. NOVITA recognizes that in our industry risks of significant adverse impacts may be associated with trading from conflict-affected and high-risk areas (CAHRAs). We also recognize that we have a responsibility to respect human rights and not contribute to the conflict. We commit to require our supplier to follow our responsible sourcing policy and be conflict-sensitive in sourcing practices, to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

4. Regarding serious abuses associated with the extraction, transport, or trade of gold: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

   • a. torture, cruel, inhuman and degrading treatment;
   • b. forced or compulsory labor;
   • c. the worst forms of child labor;
   • d. human rights violations and abuses; or
   • e. 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 from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

   • a. control mine sites, transportation routes, points where gold is traded and upstream actors in the supply chain; or
   • b. tax or extort money, or gold at mine sites, along transportation routes or at points where gold is 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.

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 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: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold.

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.

NOVITA Management

March 2024