Kimberley Process
As a concerned leader of the international diamond industry, Lazare Kaplan fully supports policies that prohibit the trade in conflict diamonds, prevent money laundering, and combat the financing of terrorism.  The Company complies with clean diamond trading and anti-money laundering legislation adopted by the United States Government, such as the Clean Diamond Trade Act, and supports relevant resolutions by concerned governments and the United Nations.

Lazare Kaplan will continue to join diamond industry and trade associations in condemning and combating the trade in illicit diamonds and to comply fully with World Diamond Congress (WDC) resolutions for industry self-regulation in respect of the Kimberley Process Certification Scheme, including the implementation of the WDC's prescribed System of Warranties.



SUPPLY CHAIN MANAGEMENT


1. This policy confirms Lazare Kaplan International Inc.’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.


2. Lazare Kaplan International Inc.(“LKI”) is a certified member of the Responsible
Jewelry 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 Labor Organization Declaration of 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; 
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 of others.


4. We only buy or sell diamonds that are fully compliant with the Kimberley Process
Certification Scheme and, as such, will not tolerate direct or indirect support of non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state
armed groups or their affiliates who illegally:
a. Control mines sites, transportation routes, points where diamonds are traded and upstream actors in the supply chain;
b. Tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or
international traders.

5. LKI shall conduct its affairs in accordance with all applicable laws and adherence to the highest ethical business standards.


a. The use of LKI’s funds, services and assets for any unlawful or improper purpose is strictly prohibited. This prohibition covers, among other things, the purchase of privileges or special benefits through improper concessions or payments, such as bribes or pay-offs.


b. We will comply with all USA Patriot Act Anti-Money Laundering provision
c. We will only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and World Diamond Council Statement of Warranties.


6. We will immediately stop engaging with stakeholders if we find a reasonable risk that they are committing any human rights abuses, or sourcing from, or are linked to
any party committing abuses or are providing direct or indirect support to
non-state armed groups who illegally control mine sites, transportation routes,
or extort money or diamonds.

Report on supply chain due diligence

The Company has adopted the Organization for Economic Co-operation and Development (OECD) framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas. Its objective is to help companies respect human rights and avoid contributing to conflict through their sourcing practices. 

The framework includes the establishment of a public supply chain policy that supports due diligence and transparency, increases supplier engagement and encourages risk-awareness with grievance reporting mechanisms. 

To that end, the Company reviews suppliers for known operating locations, certifications and associations and evaluated under Know Your Counterparty standards, and Anti-Money Laundering criteria.  This process is intended to identify risks within the Company’s supply chain.

The Company has historically and prospectively taken a zero-tolerance policy as relates to conflict-affected areas and disengages with stakeholders where a reasonable risk of direct or indirect support of conflict and human rights violations exist.