KYC (Know Your Counterparty) Policy and Procedures

1. Introduction

This policy sets out the standards and procedures for Crossfor Co., Ltd. and its consolidated subsidiaries to verify the reliability of their counterparties and conduct appropriate transactions. The Company implements the KYC process in accordance with the standards of the RJC (Responsible Jewellery Council)

2. Purpose

The purpose of this policy is to verify the identity, reliability, and legal and ethical compliance of counterparties to ensure a sustainable and ethical supply chain

3. Scope

This policy applies to all counterparties (suppliers, customers, partner companies, etc.).

4. Overview of the KYC Process

4.1 Identity Verification of Counterparties

• ・Obtain the official name, registered address, and contact information of the counterparty.
• ・Verify official documents such as the counterpart’s commercial register, corporate number, and other official documents.

4.2 Reliability Assessment

• ・Verify the counterparty's financial status (financial statements, credit reports, etc.).
• ・Check past transaction history and reputation (feedback and reviews from third parties).

4.3 Legal and Ethical Compliance Verification

• ・Confirm whether the counterparty complies with RJC standards (RJC certification status)
• ・Confirm compliance with the Kimberley Process (KPCS certification status).
• ・Verify compliance with other legal regulations (environmental protection laws, human rights protection laws, etc.)

5. Due Diligence Implementation

・Use a due diligence checklist.

・Conduct on-site visits and interviews as necessary

6. Continuous Monitoring

・Conduct regular evaluations and audits of counterparties

・Respond promptly to new risks and issues as they arise

7. Record Keeping

Properly store and manage all records related to the KYC process for at least 5 years, or for the period required by law, whichever is longer.

8. Training and Communication

・Provide training on the KYC policy and procedures to employees.

・Communicate KYC requirements to counterparties and ensure understanding.

9. Policy Review

This policy will be reviewed periodically and updated as needed. Revised policies will be promptly communicated to all stakeholders.

10. Responsibility for this Policy and Procedures

The Director of the Management Division is responsible for this policy and procedures, and the Management Division will serve as the secretariat

Supply Chain Policy

1. Introduction

This policy sets out the standards and guidelines to ensure ethical and sustainable transactions within the supply chain of Crossfor Co., Ltd. (hereinafter referred to as "the Company"). The Company pledges to fulfill its social and environmental responsibilities in accordance with the standards of the RJC (Responsible Jewellery Council).

2. Compliance

The Company will fully comply with RJC standards in the following areas:

(1)Labor Standards

Ensure a safe and fair working environment for all workers

(2)Environmental Protection

Implement measures to minimize environmental impact.

(3)Human Rights Respect

Respect the fundamental human rights of all stakeholders and eliminate any form of discrimination or forced labor.

3. Kimberley Process

The Company will comply with the Kimberley Process Certification Scheme (KPCS) to prevent the trade of conflict diamonds. For all diamond transactions, appropriate documentation and certification will be secured to ensure that conflict diamonds do not enter the supply chain.

4. Supplier Selection

The Company will consider the following criteria when selecting suppliers:

• ・RJC certification status
• ・Adherence to labor standards and environmental protection practices
• ・Fulfillment of social responsibilities

5. Continuous Improvement

The Company aims for continuous improvement in sustainability and ethical transactions within the supply chain. Regular audits and evaluations will be conducted to identify areas for improvement and implement appropriate measures.

6. Communication and Training

The Company will provide education and training on this policy to employees and suppliers to ensure understanding and compliance.

7. Policy Revision

The Company will periodically review and revise this policy as needed. Revised policies will be promptly communicated to all employees and stakeholders.

8. Scope of application

・Crossfor Co.,Ltd.

・Crossfor H.K.Ltd.

・Crossfor China Ltd.

・D.Tech Co., Ltd.

・Crossfor(Thailand)Co.,Ltd.

・Crossfor India Private Limited