Supply Chain

This policy confirms N.M. Thune AS’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with relevant UN sanctions, resolutions and laws.

As members of the Responsible 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 International Labour Organization Fundamental Rights at Work
• do not engage in or tolerate bribery, corruption, money laundering or finance 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 jewellery supply chain
• are implementing the OECD 5-Step framework as a management process for risk based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (CAHRAs)

We have a zero-tolerance policy toward any involvement in serious abuse related to the extraction, transport, or trade of precious metals, diamonds, and colored gemstones, including actions that involve, support, or enable:

• 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

We are committed to selling and purchasing only diamonds that fully comply with the Kimberley Process Certification Scheme (KPCS) and the System of Warranties (SoW). Additionally, we strictly oppose any form of direct or indirect support to non-state armed groups, including actions such as sourcing precious metals, diamonds, or gemstones from, making payments to, or otherwise aiding these groups or their affiliates who illegally:

• Control mining sites, transportation routes, trade points, or upstream supply chain actors
• Tax or extort money, precious metals, diamonds, or gemstones from mining sites, transport routes, trade points, intermediaries, export companies, or international traders

If there is a reasonable risk that an upstream supplier is involved in, linked to, or provides support for any abuses, non-state armed groups, or illegal control or extortion related to precious metals, diamonds, or gemstones, we will immediately cease engagement with them.

We affirm that security forces, whether public or private, should ensure protection for workers, facilities, and property in line with the rule of law and respect for human rights. We will not support any security force engaged in abuse or illegal activities as outlined above.

We commit to refraining from offering, accepting, or soliciting bribes to conceal the origin of precious metals, diamonds, or gemstones, or to misrepresent taxes, fees, or royalties paid to governments throughout the supply chain. We fully support initiatives to eliminate money laundering in the extraction, trade, handling, transport, and export of precious metals, diamonds, and gemstones, and will take appropriate action if a reasonable risk is identified.

Human Rights and Ethical Compliance

We acknowledge our responsibility to respect human rights. We believe that our business plays an essential role in protecting and promoting human rights.

N. M. Thune AS is committed to respecting internationally recognized human rights throughout our operations and supply chains. In alignment with the UN Guiding Principles on Business and Human Rights, our policy draws from the international standards enshrined in the Universal Declaration of Human Rights and the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work.

Human rights refer to a set of basic rights and freedoms that belong to every person in the world, regardless of where they are from, what they believe or how they choose to live their life. This concept spans economic, social, cultural, political and civil dimensions.

At N. M. Thune AS, respecting human rights means ensuring that everyone involved in, or connected to, our operations, supply chains and products is treated with dignity, respect, fairness and equality.

Our policy sets out overarching principles for how we conduct our business. Together with our employees and business partners, we are committed to driving forward the implementation of this policy across our operations and supply chains.

We recognize that challenges to these standards may arise, and we are dedicated to addressing them collaboratively with relevant partners and stakeholders.

• Employment is freely chosen: All employees work voluntarily, and no one is forced into employment against their will under any circumstances.
• Freedom of association: Employees have the right to form or join trade unions of their choice and to bargain collectively, without fear of retaliation.
• Working conditions are safe and hygienic: A safe and healthy work environment is provided for all employees, ensuring their well-being and preventing accidents or injuries caused by or related to work or equipment use.
• Child labor shall not be used: No workers under the legal minimum age are employed, and all forms of child labor are prohibited.
• Living wages are paid: All employees receive wages that meet the industry standard, ensuring a decent living.
• Working hours are not excessive: Working hours and overtime comply with applicable laws and do not exceed industry standards.
• No discrimination is practiced: No form of discrimination based on gender, ethnicity, religion, disability, age, sexual orientation or other status is tolerated under any circumstances.
• Regular employment is provided: Employment is based on formal contracts that provide job security and clear terms of employment.
• No harsh or inhumane treatment is allowed: No employee should be subjected to physical, psychological, verbal or sexual harassment, threats or abuse of any kind.
• Zero tolerance for bribery and corruption: Any form of corruption, including bribery, facilitation payments and inappropriate gifts or hospitality, is strictly forbidden in our business practices. Thune protects employees from any negative consequences for reporting concerns in good faith or refusing to engage in corrupt activities. Clear approval procedures for offering and receiving gifts to or from third parties are established.

We recognize that we must take steps to identify and address any actual or potential adverse impacts, whether they are directly or indirectly linked to our business activities or relationships.

Human rights due diligence is an ongoing process, requiring action, tracking and communication with stakeholders on how we address impacts. As our human rights risks and impacts may vary over time, this policy will be reviewed if proven inadequate by our human rights due diligence process.

Anti-Money Laundering & Know Your Counterparty (KYC)

N. M. Thune AS commits to preventing money laundering and the financing of terrorism in its business practices and transactions.

Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. The financing of terrorism is any kind of financial support to those who attempt to encourage, plan or engage in terrorism.

To combat these risks, N. M. Thune AS has implemented Know Your Counterparty (KYC) procedures, which allow us to identify every organization we engage with, assess the legitimacy of these relationships and promptly address any unusual or suspicious activities.

Thune commits to an annual review of our KYC policy and procedures to ensure ongoing relevance and effectiveness.

To support our KYC policy and procedures, N. M. Thune AS has developed a KYC form which we send to all our counterparties to collect relevant business information and identify risks of money laundering.

By collecting and reviewing the information in completed KYC forms, N. M. Thune AS commits to:

• establishing the identity of our counterparties
• checking that our counterparties are not considered high-risk. This means checking whether counterparties are based in FATF high-risk jurisdictions, named on government-sponsored watchlists or international UN sanctions lists, or if they source from conflict-affected and high-risk areas (CAHRAs)
• maintaining an understanding of the nature and legitimacy of all our counterparties' businesses
• maintaining KYC records for at least five years
• maintaining records of all single or linked cash or cash-like transactions above EUR 4,000
• monitoring transactions for unusual or suspicious activity

If counterparties are considered high-risk, we may cease trading with them, identify the beneficial owners of the counterparty and check whether these owners appear on any watchlists or sanctions lists, and, if necessary, conduct an on-site visit to the high-risk counterparty.

Environmental Management

Thune is committed to minimizing the environmental impact of our operations through responsible and sustainable practices.

We manage waste, emissions and natural resources in a way that prioritizes the health of air, water and land, striving to use energy and resources efficiently.

We ensure compliance with all relevant environmental laws, applying principles like Reduce, Reuse and Recycle to protect natural resources, which benefits both communities and the environment.

Grievance Mechanism

N. M. Thune AS has established a grievance procedure to address concerns related to our operations and supply chain.

This mechanism allows employees, suppliers and external stakeholders to raise concerns about issues caused by, contributed to, or linked to Thune's activities or business relationships.

Thune will strive to address each grievance promptly and transparently.

Grievances can be submitted through written communication.

Upon receiving a grievance, we will evaluate its significance and conduct a preliminary analysis of the issue, including investigations and verifications with the complainant, if necessary.

For significant cases, the compliance officer will collaborate with the appropriate representatives to determine and implement the most suitable corrective actions based on the severity and nature of the grievance.

The compliance officer will document each grievance's outcome, including the date of response provided to the complainant, if not anonymous.

All records of grievances and the process followed will be maintained for a minimum of five years.