Foreword

The history of the C. Paolillo & Co. Ltd. company began in 1880, in southern Italy, with brothers Ciro and Gaetano who opened a jewelry store in Torre del Greco, specializing in coral work. Through goldsmithing skills, fine design and artistic influences, they became known overseas.

After World War I, Ciro's son Carlo moved to Rome and, despite the difficulties, kept the business alive by expanding into the Japanese pearl market. Later, with Art Deco, they expanded into the diamond business. In the 1960s, Carlo's sons, Ciro and Paolo, joined the company, further expanding the business. Paolillo became a leader in the gemstone trade, establishing international partnerships and opening several related companies.

In the 1990s, Paolillo won a contract to supply diamonds to IPZS and made a historic agreement with de Beers to supply certified diamonds to the public. Ciro Paolillo becomes a member of the Carat Club and the "More than one diamond" project in 1998 is a great success.

In the 2000s, Ciro Paolillo developed projects with the Queen Mother of England, Bvlgari and the Vatican, achieving success and recognition.

Paolillo continues to innovate, patenting a malleable gold system and collaborating with Poste Italiane to produce gold stamps. In addition to entrepreneurship, Ciro Paolillo devotes himself to teaching and scientific research. He is involved in major archaeological and museum projects, contributing significantly to cultural heritage.

With 143 years of history, the Company C. Paolillo & Co. srl presents itself as a dynamic and innovative entity with successes in the field of precious stones, jewelry and collaboration with cultural institutions.

Our Mission is to.......

The Ethics of C. Paolillo & Co.

The principles enshrined in our Code of Conduct constitute an ethical benchmark within which all our employees and collaborators are invited to act and collaborate to realize the passion that unites them. C. Paolillo & Co. Srl invites everyone, employees, suppliers and collaborators to behave in an exemplary manner in full compliance with the principles set forth herein. Compliance with national and international laws, rules and regulations, as well as respect for good practices especially in ethical, social and environmental matters, is the indispensable prerequisite for the company's credibility and image.

C. Paolillo & Co. undertakes to respect the contents and spirit of this reference text, and to translate its values and principles into responsible behavior. This Code of Conduct is inspired by the core values set forth in the OECD Guidelines for Business and the UN Women's Empowerment Principles, the UN Global Compact, and the Universal Declaration of Human Rights. It forms the foundation on which our work is based.

C. Paolillo & Co. Srl respects Human Rights and complies with the UN Guiding Principles on Business and Human Rights in a manner appropriate to the size of the company, its business and circumstances.

The company adopts a Corporate Social Responsibility Policy clearly includes a commitment to:

Operate with respect for Human Rights and adhere to the United Nations Guiding Principles on Business and Human Rights;

Operate in compliance with applicable mandatory regulations and other requirements that may have been signed (national and international laws, ILO Conventions) regarding respect for workers' rights (freedom of association, respect for working hours, respect for fair pay, prevent discrimination, prevent human trafficking);

Review it regularly with a view to continuous improvement, taking into consideration changes at the legislative level, those related to the requirements of its code of conduct, and any other business requirements;

To work towards continuous improvement of working conditions for the internal satisfaction of employees and key stakeholders;

Involve and raise awareness of suppliers' readiness for monitoring activities throughout the supply chain;

Satisfy employees and pay attention to requests from stakeholders;

Promote appropriate training that has as its ultimate goal the protection of workers' safety;

Giving support to community development in areas where the company operates;

Ensure that it is effectively documented, applied, kept active, communicated and accessible to all personnel, including directors, executives, managers, supervisors and staff;

Make its policy publicly available to interested parties upon their request.

Child labor, forced labor, and discrimination

Child labor

C. Paolillo & Co. Srl undertakes not to use child labor and to respect the minimum age for starting work mentioned of the Italian law.

To this end, management in collaboration with the Personnel Manager, conducts strict checks to verify compliance with the criteria established by the company C. Paolillo & Co. Srl necessary for hiring.

Specifically, it is verified that copies of workers' identity documents, birth certificates, etc., show that they are older than the age established by the definition of a child.

Where young workers are employed, the company shall maintain records of wages paid, from which it can be shown that they are not exploited.

The company C. Paolillo & Co. Srl has prepared a remedial plan to be proposed to suppliers/subcontractors who employ children and young workers; the above applies to the latter, while the following remedial actions are evaluated for children:

Communication to Social Services to facilitate immediate remedial action;

Consider hiring a family member of the child in his or her stead;

Consider connecting the child with a mentoring association (child protection associations, NGOs, etc.).

Ensuring the child's school attendance by taking charge of charges related to school materials, tuition fees, etc.

The company C. Paolillo & Co. Srl also shows its willingness in the stipulation of apprenticeship contracts, internships to workers-students, guaranteeing their basic rights, in order to facilitate the entry of young people into the world of work. In this case, the company undertakes to ensure, through verifications carried out by the management, that the young person is not employed in purely manual labor operations and that he or she undergoes the necessary training that will enable the apprentice to achieve the ability to become a skilled worker.

Management has documented its commitment to the non-use of child labor in its social responsibility policy; this policy also requires suppliers to share this commitment and has been made known to all stakeholders (internal and external).

If the Company becomes aware of any behavior contrary to this commitment on the part of one of its suppliers, the Management ensures that the Labor Inspectorate and Social Services of the relevant territory are notified of the findings.

In any case, within the limits of its commercial-contractual power and in the logic of maintaining in the continuity of service delivery, the Management ensures the verification of the possibility of the interruption of supply relations.

By not hiring children under the age of 18, the Company does not expose children or young workers to situations that are dangerous, hazardous or harmful to health either inside or outside the workplace.

Forced labor

The company does not use forced labor as a source of income and labor but suppresses the use of forced or compulsory labor, in any form, and upon hiring does not require workers to leave deposits or original identity documents (in order to avoid the filing of identity documents required for employment, the Company accepts photocopies and self-certifications, as required by current laws). Management has documented its commitment to the non-use of forced labor in the Social Responsibility Policy; this policy also requires suppliers to share this commitment and has been made known to all stakeholders (internal and external).

To this end it undertakes to:

Respect the Workers' Statute;

Ask the worker for copies of the ID, which is filed with the C. Paolillo & Co. Srl partner company itself, and not the originals;

Refrain from requiring staff upon commencement of employment to leave cash "deposits" that could represent a restriction on the employee's own freedom;

Refrain from charging workers full or partial recruitment costs and fees

Recognize the right of staff to leave the workplace at the end of the day and terminate employment, with reasonable notice to the employer

Specify the specific role and duties of any security personnel employed in the company, in the relevant employment contract;

Give evidence of voluntary employment through the presence of the signed individual contract;

Arrange meetings with management to make workers aware of the rules regarding the notice of termination required to receive final pay and how to terminate labor relations.

As with child labor if management becomes aware of behavior contrary to this commitment on the part of one of its suppliers, it will report its findings to the appropriate authorities.

Discrimination

In order to comply with the above, the company C. Paolillo & Co. Srl complies with the provisions of the Constitution of the Italian Republic and the Workers' Statute guaranteeing:

That the composition of the payroll (over the years) does not show discrepancies for people performing similar jobs;

That when hiring personnel, no discriminatory criteria be applied;

That there be no discrimination either in reference to pay or in reference to promotion and training;

That accounting records show the treatment of workers is consistent with seniority, type of duties performed and professional skills;

That for the same company functions and duties, workers are offered the same training opportunities (this is detectable from training records);

That female workers with the same function and company duties receive equal wages, allowances and benefits as workers;

That in the case of female workers, the payment of benefits established by law for women on maternity leave be recorded;

In cases where personnel of religion other than Catholic are hired, they are given the opportunity to observe religious holidays;

That procedures be put in place to bring complaints from workers anonymously.

Any behavior and/or activity and/or language that can be traced back to:

Threat;

Offense;

Coercion;

Exploitation of any kind or nature,

It is reported to management. Such discriminatory behavior or activity or language is handled in accordance with applicable requirements (according to CCNL and applicable mandatory documentation) regarding the administration of disciplinary procedures. The occurrence of such events is also recorded as problematic with respect to the social responsibility system and removed through corrective action and/or remedial action. The company C. Paolillo & Co. Srl subjects female workers to pregnancy tests for no reason. The Medical Officer monitors the health status of pregnant workers as required by current regulations.

Freedom of association and collective contraction

C. Paolillo & Co. Srl guarantees and respects the right of personnel to form or join trade unions of their choice and the right to collective bargaining, enshrined in Article 39 of the Italian Constitution and governed by Law 300 of 1970 (Workers' Statute). Respect for these rights and the exercise of them by workers is demonstrated by the presence, in the case, of workers who are members of different trade unions. The union representative shall exercise his or her role. In order to facilitate the exercise of such rights, the Management shall ensure the provision to workers, upon their written request, of a room where they can carry out union activities. Management shall ensure non-discrimination of the union representative in the company and the ability to communicate with workers in the company. Workers, as provided for in current regulations, have the opportunity to participate in union meetings outside the company.

Human trafficking

C. Paolillo & Co. Srl guarantees that it does not support or engage in human trafficking as defined in company policy.

Corruption and facilitating payments

C. Paolillo & Co. Srl is committed to ensuring compliance with applicable laws against bribery and corruption. It is essential to carefully review and comply with the principles of Anti-Bribery and Corruption for the following reasons:

- Acting in accordance with corporate values;

- Protect the reputation of the Society;

- Demonstrate the Society's commitment to the communities in which it operates;

- Ensure compliance with all anti-corruption laws applicable to the Company;

- Strengthen international enforcement and awareness of anti-corruption laws.

It is also considered bribery to request or receive anything of value or any benefit, either directly or indirectly, from any person, with the intent, as a result, that a particular function or activity be performed improperly, either by you or by another person.

A bribe may be financial or otherwise, and may include giving or receiving money, loans, contributions or donations, travel, offers of employment, reimbursements, discounts, goods, services or anything else that could be considered of value. Under certain circumstances, gifts or entertainment expenses may be construed as forms of bribery. A bribe may also take the form of a "reward" and be paid in return for the improper performance of the relevant task or obligation.

It is considered bribery to offer, promise or give anything of value or any benefit to anyone in order to induce improper performance.

It is also considered bribery to demand or accept anything of value or any benefit from anyone in exchange for granting an improper business advantage to that person.

Gifts, Meals and Entertainment

It is often customary to exchange gifts, meals and entertainment with customers, suppliers and other business partners. The purpose of such exchanges is to maintain a proper relationship between the parties. Excessive or exaggerated gifts, meals or entertainment that might give the appearance of improper influence should be avoided. It is always advisable to consider whether the gift, meal or entertainment you intend to give or receive could be construed as excessive or inappropriate, or induce or imply any obligation.

Receiving Gifts, Meals or Entertainment

- One should not accept gifts, meals, or entertainment in exchange for doing, or promising to do, something for a client, supplier, or other business partner.

- No gifts, meals, or entertainment should be requested from a customer, supplier, or other business partner.

- No cash or cash equivalent gifts, such as gift certificates, should be accepted under any circumstances.

- No excessive gifts, meals or entertainment should be accepted. This is an area where your judgment is paramount. For example, a modest gift during the holidays from a supplier in accordance with local custom, and for the purpose of enhancing a legitimate business relationship, is usually fine, but gifting an expensive weekend is not permissible. Sometimes it is difficult to define the term "excessive," and what is customary and appropriate differs from country to country. On certain occasions, modest personal gifts might be considered excessive because of their overall value and related circumstances. When in doubt, you should always seek prior written authorization from the Competent Legal Officer.

- Gifts of symbolic value, such as trophies and statuettes with engravings commemorating a business relationship, may be accepted.

- If you are offered a gift, meal or entertainment that goes beyond the above guidelines, politely decline and explain the rules of the Society.

If the return of a gift would offend the giver, or the circumstances under which it was given would prevent its return, you must notify your Code Compliance Officer, who will consider with you whether to donate the item to a charity or distribute or raffle the item off among a larger group of employees.

Offering Gifts, Meals or Entertainment.

- Gifts and entertainment for customers, potential customers and suppliers must support the legitimate business interests of the Company and be reasonable and appropriate under the circumstances. You must always be sensitive to the rules regarding the receipt of gifts and entertainment from our customers and suppliers. When in doubt, you should always seek prior written authorization from the Legal Officer in Charge.

- Money or money equivalents should never be offered as gifts.

- It is necessary to keep all receipts for such expenditures.

Exclusive Events

Bringing a customer, supplier, or other business partner to an exclusive event is permissible as long as there is no intent to induce that person to act unbiased or to perform his or her work improperly. For example, it is permissible to invite a customer to attend an exclusive event as a public relations activity for the purpose of establishing good relations or strengthening knowledge of the Company.

Management of giveaways

The gift to be given to the recipient should be selected for the sole purpose of promoting the company's image to the recipient's company/institution.

The type of good/service bestowed will be mainly promotional in nature with unit commercial value not exceeding €100.00.

Gift-giving activities, if provided for in the corporate strategies for a given fiscal year, should be planned through the establishment of an annual budget. Any other activities, not known at the time of annual planning, may be included later, only on the condition that the related costs do not exceed the amounts available in the expenditure chapters of the annual budget by making, where necessary, any substitutions with activities already planned.

The requesting Business Function should formulate a request to the Management to initiate the procedure for the acquisition and delivery of the good/service to be provided to the identified beneficiary.

Sponsorships

Sponsorship will be provided for the sole purpose of promoting the image and services provided by the company.

In case the company is involved in sponsorship activities, the following activities should be carried out:

1. Evaluation of the sponsorship project/proposal with particular reference to verifying the amount allocated for sponsorship in relation to the characteristics of the initiative to be sponsored.

2. Approval of the Project/sponsorship proposal by the management.

3.Use of appropriate contractual arrangements, appropriately formalized, possibly subject to evaluation by a Legal Counsel, which must also provide for the prohibition of the beneficiary of the sponsorship initiative to use credit assignment and mandate for collection as well as (for the purpose of settlement/payment of invoices) and the application of the principle of bank domiciliation exclusively in the country of residence/registered office of the beneficiary, unless specifically requested by the latter for bank domiciliation in another country.

The conclusion of contracts is the sole responsibility of the administrator as well as the approval of any related variants/additions.

4.Formalization of any relationships with external parties (consultants, third parties, representatives or other) appointed to carry out activities in support of the company, including a specific clause binding them to comply with the principles set out in the "Code of Ethics."

5.Traceability of individual process steps to enable reconstruction of responsibilities and reasons for choices.

Any exceptions to the above principles must in all cases be authorized by the chief executive officer.

Public and charitable contributions

Public and charitable contributions and subsidized financing are normally linked to public calls for proposals issued by state, community, territorial or otherwise disbursed by public entities through which the same intend to encourage and/or reward business development.

These processes show essentially similar development:

- Selection and identification of available calls of interest to the company;

- Identification and verification of any requirements for the application;

- submission of the application in the manner prescribed in the notice with any documents proving the requirements and/or statements;

- Relationship management in case of any further requests from the Entity;

- if obtained, verification of the performance of the activity for which the grant was given;

- Management of inspections/inspections.

The control system is based on traceability of acts.

In the case of obtaining and receiving the requested grants, the administration shall verify the performance of the activities or the application of the facility obtained by reporting the details of such activities on the same document.

In the event that external parties (consultants, third-party representatives or others) are appointed to support the company in making the request, the relationship must be formalized by including a specific clause in the contracts that binds them to comply with the ethical behavioral principles adopted by the company.

Behavior with the public administration

Both employees and contractors have a duty to report to management any violation or suspected violation of conduct.

Reports must be made exclusively in non-anonymous form. It will be the responsibility of the company to protect the one who files a report from any prejudicial effect that may result from the report.

Each department head must report crime-risk behaviors of which they have become aware either directly or from their co-workers; they must also report news of which they become officially aware, including from law enforcement agencies, concerning offenses and/or crimes with risks of business impact.

The administrator who has contact activities with the Public Administration must provide adequate traceability mechanisms about information flows to the PA.

Any assignment to external parties to act as the company's representative to the PA must be formally assigned and include a clause binding compliance with the principles adopted by the company and set forth in the "Company Policy."

In the event of attempted bribery by a public official or otherwise by persons appearing on behalf of the PA, the following actions are to be taken against an employee (or other associates):

- Do not follow up on the request,

- Provide timely information to their Manager,

- The person in charge must give formal notice to management.

The following are some risky behaviors to be avoided; these pointers are also to be considered in indirect dealings with PA representatives through appointed third parties:

- Promising or making cash disbursements for purposes other than institutional and service purposes;

- Promising or granting "privileged solutions" (e.g., interventions on private vehicles outside of normal company operating modes, interest and/or facilitation regarding the hiring of relatives/kin/friends, etc.);

- Making unjustified entertainment expenses for purposes other than merely promoting the corporate image;

- Promising to provide or improperly provide, including through third parties, the performance of works/services (e.g., work on private vehicles, renovation work on private residential buildings, etc.);

- Promising or granting direct or indirect gifts that are not of modest value;

- Provide or promise to provide confidential information and/or documents;

- favoring or promising to favor, in purchasing processes, suppliers and sub-suppliers as indicated by the representatives themselves as a condition for the subsequent performance of activities (e.g., awarding of the job order, granting of subsidized financing).

In addition, towards the Public Administration (PA) and institutions it is prohibited to:

- Produce false or altered documents/data;

- Engage in deceptive conduct that could mislead the PA in the technical and economic evaluation of the products and services offered/supplied;

- Omit due information in order to steer PA decisions in their favor;

- Devote public contributions/grants/funding to purposes other than those for which they were obtained

- Access PA information systems in any way, in an unauthorized manner, to obtain and/or change information for the benefit of the company.

Money laundering and terrorist financing

C. Paolillo & Co. Srl applies the KYC (Know Your Customer) principles for partners of supplier enterprises and for customers of Diamonds, Gold and Platinum idi containing such products and in addition:

Establishes the identity and, based on the risk assessment or Applicable Law, the beneficial owner and owners/clients of the supplier or customers;

Ensures up-to-date knowledge of the nature of the business;

Monitors transactions to detect unusual or suspicious activity and report suspicions of money laundering or terrorist financing to the appropriate authority.

Maintains records of all cash or similar transactions exceeding or equal to 3,000 euros, and if necessary, report to the competent authority.

Whenever a movement takes place, it is necessary to identify the client.

The obligation of identification is understood as the acquisition of the information necessary to ascertain the identity of the natural person materially carrying out the transaction. The verification of the customer's identity and the acquisition of the customer's identification data is carried out solely and exclusively through the mode of direct acquisition in the presence of the customer with the request for a valid and unexpired identification document.

It is also necessary to ask the customer whether he/she is making the transaction on his/her own behalf or whether there is a different beneficial owner, i.e., whether the natural person making the transaction on behalf of a legal person (company) or on behalf of a different natural person. If this is the case then the customer must indicate that there is a beneficial owner other than himself and the beneficial owner must also be identified.

Security

C. Paolillo & Co. Srl evaluates product security risks and establishes measures to protect against theft of products, damage or replacement of products at its premises and during transportation. These security measures first of all consider the protection of employees, subcontractors and visitors as well as the employed personnel of business partners.

The company's headquarters is equipped with all the necessary security measures to protect against theft, robbery, damage or replacement of products on the premises and in transportation such as cameras, security doors, walk-in booths, safes, connections with operations center, vaults etc.

Statement of provenance

C. Paolillo & Co. Srl markets products only with valid and evidence-based Declarations of Origin. All documentation pertaining to the products is kept in administration by the person in charge in the archive present at the headquarters.

General conditions of employment

C. Paolillo & Co. Srl ensures that Employees understand their current conditions of employment with regard to pay, working hours, and other conditions of employment:

Contracts are written in language that workers understand, and indicating their rights and responsibilities with respect to wages, working hours and other conditions.

In the case of unwritten contracts (e.g., in some small businesses or for some older or long-time employees), in these cases the company makes sure that these employees are familiar with the terms and conditions of their of employment. The latter may be official company information made available to the employee.

C. Paolillo & Co. Srl does not avoid fulfilling its obligations to Employees with respect to labor and social security under Applicable Law by resorting to labor hire agreements, sham apprenticeship programs, excessive short-term consecutive employment contracts, and/or subcontracting or work-from-home arrangements.

The company C. Paolillo & Co. Srl maintains adequate records of Employee data, including piecework records and wage payments in addition to hours worked, for all full-time, part-time or seasonal Employees.

Working Hours.

C. Paolillo & Co. Srl complies with the provisions of the Constitution of the Republic of Italy, the Workers' Statute and the relevant CCNL (National Collective Labor Agreement), in relation to compliance with the scheduled working hours.

Specifically, C. Paolillo & Co. Srl meets the standards defined by the CCNL in that:

The work week (whatever the distribution of working hours) turns out to consist of six days;

The standard number of hours for each week is 36 hours, and in any case the company C. Paolillo & Co. Srl has never required its employees to work beyond the limits established as standard hours;

There shall be at least one day off for every six consecutive days of work (except where there are freely negotiated collective bargaining agreements that allow working hours to be calculated on an average basis, including appropriate rest periods).

Remuneration

The company C. Paolillo & Co. Srl in compliance with the provisions of current legislation and the CCNL (National Collective Labor Agreement), guarantees, in relation to the characteristics of remuneration, compliance with the legal minimum wage, and ensures that the salary is adequate to meet the essential needs of the worker, and in line with the CCNL of the sector.

In this regard, the company stipulates that:

Salary deductions shall not be used for disciplinary purposes. The reasons for any deductions should be specified;

Employment counselor explain to new employees or when requested, the composition of payroll items;

Apprenticeship contracts be limited in time, provide for less pay due to the amount of work, and that age limits be respected;

Each worker is registered in the Single Labor Book;

The manner in which the paycheck is disbursed will take the form of a check, bank account credit, or in such a way that workers do not have to incur additional costs to receive it.

At the time of writing, payment of wages at C. Paolillo & Co. Srl is made by bank transfer. Should an employee request different methods of disbursement from the one listed above to the Company in charge of the payroll service she will be responsible for submitting them to Management and, having verified their feasibility, Management may approve the employee's request.

Payroll records show that workers are paid regularly.

In case there is a trend of the increase of fixed-term contracts, this should be justified by the Labor Consultant, who will issue, at the management review, a written report explaining the above trend.

Resolution of business disputes

No employee shall be subjected to usurious activities, corporal punishment or degrading treatment, sexual or physical harassment, mental, physical or verbal abuse, coercion or intimidation, or threats of any of the above toward themselves, their families or colleagues.

The company has communicated through training courses and internal policy the disciplinary standards and treatment of employees.

Any employee is free to file a grievance without penalty or reprisal.

Health and Safety

C. Paolillo & Co. Srl through the competent company figures and also using external consultants, ensures the safety of the workplace by complying with the provisions of Legislative Decree 81/08 and smi, providing a risk analysis that highlights the potential risk factors related to the activities carried out, in order to highlight the critical points and / or deficiencies.

Specifically C. Paolillo & Co. Srl:

Provides for the appointment of a Workers' Safety Representative;

Provides for the establishment of the prevention and protection service and appoints a person in charge of it;

Defines workplace health and safety documents disseminated to all staff;

Defines and implements health and safety training programs for all staff;

Drafts reports on risk assessment of particular jobs;

Drafts reports on incidents that have also occurred in the past in order to extrapolate improvement actions;

Drafts a disciplinary for anyone who fails to comply with safety regulations.

In addition to the specific figures provided for by 81/08 such as the RSPP (prevention and protection service manager), competent doctor, fire and first aid emergency officer, and workers' safety representative, the company C. Paolillo & Co. Srl employs additional figures to ensure the safety of the workplace.

Working Environment

The organization ensures a safe and healthy Work Environment through the following aspects:

Valid business operating permits (fire prevention and electrical system compliance certificates; permits and certificates of compliance for equipment and machinery such as boilers, generators, elevators, cylinders, chemical storage tanks and fuel tanks; construction, emission and waste disposal permits)

Ergonomics of workstations

Adequate lighting, ventilation and temperature control

Electrical systems maintained and connected to grounding

Evacuation plans highlighting the actions that personnel should follow in the event of a fire, with the presence of escape routes identified by appropriate signage and sufficient emergency exits, and equipped with panic bars that can be opened to the outside, sufficient number of assembly points

Presence of fire-fighting equipment (fire extinguishers, fire hydrants and hose reels) fully functional and regularly maintained

Presence on vehicles intended for ecological services of protective and safety devices

Proper storage of hazardous and non-hazardous waste

Compliance with Health Surveillance

Presence of one first aid kit for every 100 workers

Toilets in sufficient number in relation to the number of employees present and in optimal hygienic conditions

The offices of C. Paolillo & Co. Srl are dated with restrooms. The restrooms are kept clean through the work of the cleaners employed by the company in question.

It is the duty of all employees to check the state of cleanliness of these rooms and the constant presence of accessories.

The company has no in-house canteen.

There are no dormitories for workers at the company because, the location of the registered office allows workers to easily reach it via public or private transportation.

All personnel have the right to leave the workplace, in case of serious and imminent danger, without seeking permission from the company.

Risk analysis

Based on the type of activities carried out by C. Paolillo & Co. Srl of the equipment used to carry out the activities, and the infrastructure within which the activities are carried out, it is the responsibility of the Management to provide coordination of activities aimed at determining potential risks that exist for its employees.

The outcome of this analysis is documented on a Risk Assessment Document that states:

Description of the organization (structure, activities and geographical location)

Main cogent references (for the drafting of the document itself)

Mode of risk assessment

Analysis of potential hazards (including determination of whether the hazard is present or actually absent and its evaluation)

Other possible aspects to be kept under control (management of pregnant workers, labor organization, management of outside companies,...)

The risk assessment document is formally approved by the legal representative and other appointed safety figures at C. Paolillo & Co. Srl.

It is the responsibility of management to ensure that all obligations under mandatory legislation aimed at excluding or determining a risk factor (e.g., analysis and subsequent certification/self-certification related to noise risk) are met. All documentation produced is retained by the employer.

Personal protective equipment

The company shall provide, at its own expense if necessary, appropriate personal protective equipment to all workers. It also undertakes to provide first aid and assist the worker in case of accidents and/or injuries.

Staff have and use PPE as stipulated in the occupational health and safety risk assessment carried out by the organization.

All personnel demonstrate familiarity and knowledge of the following aspects:

What PPE is needed for each activity, operation or process;

When PPE is needed;

How to set up and use devices;

Limitations of device use;

Proper storage and maintenance of devices

The recording of injuries

The employer has ensured that written records of all accidents occurring to its company's workers are maintained by means of special accident registers, endorsed by the ASL and kept at the registered office of the company C. Paolillo & Co. Srl, on which the following are noted: the name of the injured worker, his or her job description, the date of the accident and the date of resumption of work.

Personnel involved in corporate security management

It is Management's responsibility to provide for the organization of the protection and prevention service (in accordance with applicable legislation). Management also provides for appointing and/or having workers (in the case of the Workers' Safety Representative) appoint the following safety figures:

Health and Safety Committee composed of the RSPP, RLS, Competent Doctor who is trained and periodically updated in order to ensure continuous efforts in improving health and safety conditions in the workplace; the committee's responsibilities include:

Conducting Periodic Meetings

Analysis and assessment of risks to workers' health and safety

Prevention and Protection Service Manager. The responsibilities/tasks of the RSPP include:

Carry out risk assessment, identification of risk factors, identification of safety measures in work environments;

Propose the information and training program to the consultations;

Attend the periodic prevention meeting;

Provide specific information to all workers on potential risks and prevention measures

After the potential Manager has been identified and prior to his or her appointment, it is the responsibility of Management to check that he or she possesses appropriate attested training in relation to:

Methodologies for risk analysis

Hazard prevention methodologies

Mandatory regulations applicable to the business reality

Tasks assigned to the manager according to the requirements of the mandatory regulations

Level of responsibility officially borne by that role and any resulting actions (e.g., liability for administrative sanctions)

Workers' Safety Representative. The appointment of this representative is by direct election by the workers, documented by the minutes of the appointment. The authorities/responsibilities/duties of the workers' safety representative include:

Access to all workplaces where activities take place

Consultations regarding risk assessment

Consultation regarding the appointment of the other corporate figures that are part of health and safety management according to the following paragraphs

Involvement with regard to training (initial and continuing staff training)

Access to all existing health and safety prescriptive documentation

Management agrees to provide such a staff-elected worker safety representative:

training with regard to constitutional and civil law principles; general and special legislation on accident prevention and occupational hygiene; the main parties involved and their obligations; the definition and identification of risk factors; risk assessment; identification of measures (technical, organizational, procedural) of prevention and protection; regulatory aspects of worker representation; notions of communication techniques.

Time necessary for the performance of the assignment without loss of remuneration, as well as means necessary for the exercise of the functions and faculties granted to him.

Management undertakes not to act with prejudice toward the appointed Workers' Representative by ensuring that he or she has the independence and authority necessary to carry out the duties assigned to him or her.

Initial and continuing education

A training session on the contents of the risk analysis and preventive measures in place is carried out at the start of an employment relationship, specifically on:

Emergency evacuation

Recognition of hazards and emergencies as well as on appropriate actions to be taken

Proper use and storage of personal protective equipment (PPE), tools, machinery and equipment

On the tools, systems, tasks, and work areas that require specific training and skills

When using chemicals on the safe use and handling of mixtures and chemicals, as well as any emergency treatment that may be necessary

Fire drills take place at least once a year for all shifts.

Similarly, meetings are convened when there are any significant changes in risk exposure conditions, including the planning and introduction of new technologies that affect the safety and health of workers.

All meetings held are duly recorded. These training sessions take place during working hours and do not entail any financial burden on workers.

Inattention to established requirements

It is the responsibility of the Workers' Safety Officer and the Workers' Representative for Social Responsibility to continuously monitor the behavior of personnel to check that they timely comply with the established occupational safety and health requirements.

If an operator disregards what has been established, it is the responsibility of the person who detected the deficiency to provide for compliance with the management process that follows (when faced with the futility of one action, one moves on to the next):

Immediate callback to the operator

Anonymous reporting to management

Awareness session to all staff by Manager

Asset management

Of the above activity a record remains.

Environmental Management

The company C. Paolillo & Co. Srl identifies environmental risks, particularly significant environmental influences and opportunities to improve environmental protection compliance.

The Company, with the cooperation of the other functions responsible for the various sectors involved and external consultants, is responsible for identifying the environmental aspects related to its activities. In order to identify all the environmental aspects of the Company, it is necessary to take into account all the activities that are carried out in it, under conditions:

Normal operations;

Operational not normal or in the presence of criticality;

Of possible emergency, accident or unforeseen event.

Both carried out by internal staff and external service providers.

In this analysis of activities, the environmental aspects related to them are identified, particularly taking into account:

Water resources;

Waste;

Energy consumption;

Use of hazardous substances;

Soil contamination.

In addition to the environmental aspects that it can directly keep under control, aspects over which the company can exert influence are also considered.

In order to identify environmental impacts, the analytical tools and methodologies deemed appropriate for examining activities in their various operating conditions, in relation to the environmental aspects defined above, should be used.

All aspects identified will, therefore, be evaluated to define their level of significance.

Hazardous substances

C. Paolillo & Co. Srl has proceeded in the identification of any hazardous substances taking into due consideration what is reported in Legislative Decree 25/2002, which identifies the following "hazardous chemical agents":

Chemical agents classified as hazardous substances in accordance with Legislative Decree No. 52 of February 3, 1997, as amended, as well as agents that meet the criteria for classification as hazardous substances set forth in that decree. Environmentally hazardous substances only are excluded;

Chemical agents classified as dangerous preparations in accordance with Legislative Decree No. 65 of March 14, 2003, as amended, as well as agents that meet the criteria for classification as dangerous preparations set forth in that decree. Preparations that are dangerous only for the environment are excluded;

Chemical agents that, although not classifiable as hazardous, according to paragraphs (a) and (b) above, may pose a risk to the safety and health of workers because of their chemical-physical, chemical or toxicological properties and the way they are used or present in the workplace, including chemical agents that have been assigned an occupational exposure limit value;

Detailed information regarding the chemical substances and/or preparations present in the company, as well as the quantities held and used by personnel during the performance of their duties, is provided in the detailed document "Assessment Report Relating to "Chemical Risk" (where applicable).

Waste and emissions

Behavioral methods regarding waste management are disseminated to all personnel through special training sessions.

Within the offices, it is the responsibility of all personnel to deliver waste to the appropriate containers designated for separate collection and clearly identified and marked; the waste produced by office activity is mostly similar to MSW (municipal solid waste) and is:

- charter

- plastic and glass

- damp

- metals

- damp

- toner

Mainly these wastes are collected by firms specializing in the field and under municipal management.

In case there should be special waste, the final destination of the special waste must be identified. The qualification of the suppliers to whom the waste is delivered should be verified and they should be authorized to receive the waste identified with the EWC codes at their facility.

Use of Natural Resources

C. Paolillo & Co. Srl performs continuous monitoring on its activities that may have a significant impact on the environment by taking regular measurements on certain specially identified characteristics. The company evaluates on an annual basis the environmental performance related to the listed significant environmental aspects and analyzes the data related to the indicators.

Subsequent to risk assessment and monitoring, goals for improving environmental performance will be defined.

The objectives developed are consistent with its environmental policy, taking into consideration all significant environmental aspects, legal and other requirements that may be subscribed to, and the views of interested parties.

Staff are trained and informed about environmental risks and related goals.

Product disclosures

C. Paolillo & Co. Srl declares that it does not make untrue, misleading or deceptive statements or make material omissions in selling, advertising or marketing Diamonds, Synthetics or Simulants and/or Products containing Gold or Platinoids.

Management is aware that serious misrepresentation or omission involves evading or providing false statements or information that could influence the buyer's decision, and may be contrary to law.

For this purpose, all advertising or marketing materials as well as commercial offers are reviewed by management or sales managers.

Kimberley Process Certification System and World Diamond Council System of Warranties.

The company does not buy or sell Diamonds from conflict zones or assist others in doing so.

Management implements procedures to ensure that certificates are always provided for any exported diamond that proves compliance with the Kimberley Process scheme and to demonstrate that it does not import from, or export to, a country that is not a member of the Kimberley Process.

Management implements monitoring of its suppliers to avoid diamond transactions from suspicious sources,

or from countries that have not implemented the KPCS, or that might involve targeted individuals, entities, or organizations.

In the case of rough diamonds Every shipment lot, which is exported and crosses an international border, must be accompanied by a progressively numbered Kimberley Process Certificate validated by the government.

When purchasing or selling Diamonds, rough, finished or mounted in jewelry, C. Paolillo & Co. Srl adopts the World Diamond Council's System of Warranties and have systems in place to ensure that all related invoices contain the following positive statement, or equivalent terms indicating the same warranty:

"The Diamonds referred to in this invoice were purchased from legitimate sources not involved in conflict financing and in accordance with United Nations resolutions. Seller hereby warrants that these Diamonds are not connected with conflict zones, based on personal knowledge and/or written warranties made available by the Supplier of these Diamonds."

No consignment of diamonds will be accepted unless they are accompanied by the warranty statement, in case the supplier does not provide an adequate warranty it will first be solicited and then removed from the supplier list.

C. Paolillo & Co. Srl shall keep maintains records for 5 years of all certificates regarding the Kimberley Process and invoices related to the Warranty System received and issued. Upon request of an authorized public body such records shall be able to demonstrate compliance with the Kimberley Process.

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Code of Ethics

C. Paolillo & Co. Srl

Foreword

Respect for basic human rights

Workers' rights and working conditions

Health, Safety and Environment

Diamonds, Gold and Platinum

CODE DISSEMINATION

The Code of Ethics is available on the website of C. Paolillo & Co. Srl. It is brought to the attention of all employees and collaborators. The Group has also developed good governance tools covering the following areas: environment; supplier relations; recruitment; information security; anti-corruption; competition law compliance; publicity; and other topics or areas covered in this Code and for which the company has established internal guidelines.

In the event of non-compliance with the principles set forth in this Code and in the internal guidelines, employees expose themselves to the risk of disciplinary measures and sanctions commensurate with the seriousness of the violation found, in accordance with the provisions of the Internal Regulations (or any other equivalent document) of the company to which they belong, applicable laws and regulations.