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Privacy Policy

Who we are

Our website address is: http://starasiathailand.com/about/ .

What personal data we collect and why we collect it

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Responsible Jewellery Council (RJC) Policy

STAR ASIA (THAILAND) LTD. located 322/47,322/49, BANGKOK GEMS &
JEWELRY TOWER, 19TH FLOOR, SURAWONGSE ROAD, SIPHAYA, BANGRAK, BANGKOK

10500, THAILAND

STAR ASIA (THAILAND) LTD. is a member of the Responsible Jewellery Council
(RJC), an organization that establishes and sets standards for corporate responsibility
towards morality, ethics, and human rights. The society and environmental practices
cover the supply chain of jewellery, including diamonds, gold and platinum metals.

As a member of the RJC who received Certification in accordance with the
practices of RIC Company We are committed to conducting business in accordance with
RIC’s code of conduct by integrating responsibility towards morality, ethics, and human
rights. Social and Environmental Practices in the Process of Operation Planning activities
and decisions in business continuously.

In addition, the Company has established policies on quality, environment,
occupational health and safety, and security policy and social responsibility policy to
ensure effective implementation. All the time

This Policy applies to personnel operating under the control of the Company as
well as relevant stakeholders as necessary by providing communication, dissemination
through appropriate channels.

Date : Jan 4,2022

(Kartik Nayanbhai Shah)

Managing director

Star Asia (Thailand) Ltd.

KNOW YOUR CUSTOMER POLICY

STAR ASIA (THAILAND) LTD. located 322/47,322/49, BANGKOK GEMS &
JEWELRY TOWER, 19TH FLOOR, SURAWONGSE ROAD, SIPHAYA, BANGRAK, BANGKOK
10500, THAILAND

This policy document gives an overview on the standards issued by STAR ASIA
(THAILAND) LTD. on the ‘Know your Customer’ setting standards for prevention of
money laundering activities and corporate practises while dealing with their customers.
The company shall adopt all best practises prescribed by the RJC from time to time and
shall make appropriate modifications if necessary to this code to conform to the
standards so prescribed.

The scope of this policy extends to all business segments (Retail & Wholesale).
The company is committed for transparency and fairness in dealing with all stake
holders and customers in ensuring adherence to all laws and regulations, The company
ensures that information collected from customers for any purpose will be kept as
confidential. The company also commits that the information sought from the customer
is relevant to the perceived risk and is not intrusive and is in conformity with the
guidelines issued in this regards. Any other information from the customer shall be
sought from the customer separately with his/her consent and after effective rendering
of service. The company shall also communicate its KYC norms to the customers.

‘KNOW YOUR CUSTOMER’ STAR ASIA (THAILAND) LTD. has issued
comprehensive guidelines on ‘Know Your Customer’ (KYC) norms to ensure that a
proper policy framework on KYC be formulated and put in place with the approval of
the Board. Accordingly, in compliance with the guidelines issued from time to time.

This policy is applicable to all categories of products and services offered by the
Company.

Date : Jan 4,2022

(Kartik Nayanbhai Shah)

Managing director

Star Asia (Thailand) Ltd.

ANTI HUMAN TRAFFICKING POLICY

STAR ASIA (THAILAND) LTD. has committed to the resistance. Labor Trafficking
The use of illegal child labor, as well as forced labor, will comply with labor laws and
company regulations. As follows.

  1. Realize that labor is the one that creates economic benefits for companies and
    countries. Workers must be encouraged and encouraged to have the opportunity to
    apply jobs with value and dignity.
  2. Focus on cooperating with government agencies in combating human
    trafficking, labor illegal child labor Non-forced labor by complying with labor laws and
    international labor standards
  3. Support the protection and care of both Thai and neighboring workers. In
    terms of employment conditions and job conditions Legal wages, as well as promoting
    quality of life to increase the value and dignity of employees.
  4. Control and drive relevant stakeholders, including deliverers, contractors,
    external sources, employment parties, to strictly comply with such policies.

This Policy is effective from January 4, 2022.

(Kartik Nayanbhai Shah)

Managing director

Star Asia (Thailand) Ltd.

Employee grievances Policy

STAR ASIA (THAILAND) LTD. is committed to the quality of life and engagement
with the company of employees. On the basis of fair treatment and mutual respect. The
Company has established a policy to process grievance from employees in cases where
employees are treated unfairly, intimidated, unequalized, sexually harassed, or treated
in accordance with employment and labor management policies, or find any behavior
that may cause inappropriate, unethical or lawless equalization. Financial misconduct or
fraud

To ensure that the grievance is resolved seriously. The complainant’s anonymity
information will be kept as confidential as possible and the complainant will not be
afraid of any unfair retaliation or specter, and to encourage employees to file a
complaint or report their concerns .Following guidelines:

  1. Set Procedures and channels for employee grievances
  2. Establish the process for determining complaints fairly and transparently with
    all parties involved.
  3. Protect the rights of grievances and informants with good faith intent.
  4. Data Confidentiality

This Policy is effective from January 4, 2022.

Human Rights Policy

STAR ASIA (THAILAND) LTD. has a commitment to respect. Protect and
heal. In regards to human rights, it will comply with the legal requirements and
regulations of the company. As follows

  1. The Company will conduct business with importance and respect for the law,
    and employees, executives must strictly comply with the relevant laws.
  2. The Company will value and respect internationally recognized human rights
    as required by law, both in terms of basic rules and rights in the workplace.
  3. The Company will not support and avoid human rights violations against other
    persons and will resolve issues or related human rights consequences.
  4. The Company will seek to prevent or mitigate human rights impacts in relation
    to it.
  5. The Company will provide a process that represents the due diligence process
    for identification. Prevent, mitigate problems and their impact on human rights.
  6. The Company will be involved in considering the impact on human rights and
    restoration through legal processes.

This Policy is effective from January 4, 2022.

(Kartik Nayanbhai Shah)

Managing director

Star Asia (Thailand) Ltd.

Supply Chain Policy

  1. STAR ASIA (THAILAND) LTD. Commitment to respect of human rights. Avoid
    donating money to conflicts and committed to complying with all relevant
    measures and laws by becoming a member of the Reponsible Jewellery
    Council (RJC). We’re committed to proving through independent agency
    verification that following :

  • Do not engage in or allow bribery, corruption, and money laundering
    or terrorism finances.
  • Respect human rights in accordance to the Universal Declaration of
    Human Rights and Basic Human Rights in Work.
  • Support transparency of government payments.
  • Does not provide direct or indirect support to illegal armed groups.
    Help stakeholders express concerns about the jewelry supply chain.
    Galangda follows the OECD’s 5-step framework as a management
    process for due diligence, analysis, risk-based for responsible supply
    chains of minerals from conflict-affected and high-risk areas.

  1. We are committed to using our influence to prevent abuse from others. We
    follow KYC procedures for screening and evaluating our suppliers. To identify
    risks, including establishing grievance procedures for receiving concerns about our Supply Chain.

  • Serious violations related to extraction We will not tolerate or profit
    from counting or convenient commissions of:
    Torture Cruel, inhumane practices, and bad grandmothers. Child labor
  • Violations and violations of human rights.
    War crimes Violation of international humanitarian law Crimes against
  • humanity or genocide?

3.We will immediately cease engaging with the suppliers. If we find a reasonable
risk that they are quailing the abuse described above, or that they are provided from or
linked to any party that qualifies these violations.

4.About 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
only the supply of precious metals. To raise money or to assist or equip non-
state armed groups or illegal affiliates:

  • Control mine sites, transportation routes, precious metals trading points, and supply chain operations, or Taxes or extortionate of silver or precious metals at mine sites, along transport routes or at the point where precious metals are traded, or from intermediaries, export companies or international traders.

  1. We will immediately cease engaging with the suppliers. If we find a
    reasonable risk that they are procuring or linking up with any party that
    provides direct or indirect support to non-state armed groups as described.
  2. About the Public or Private Security Division. We would like to confirm that
    the role of the Public or Private Security Division is to provide security to
    workers.
  3. Convenience stuff Equipment and property in accordance with the rule of law,
    including laws that guarantee human rights. We will not provide direct or
    indirect support to public or private security divisions that quailize described
    violations or illegal quailization as described.
  4. Regarding bribery and misrepresentation of false truths about precious metals
    sources, we will not offer, commit, give or solicit bribes, and will resist bribery
    claims. To conceal or obscure the origin of precious metals or to counterfeit
    taxes, fees and royalties paid to the government for extraction purposes.
    Trade, management, transportation and export of precious metals.
  5. Regarding money laundering, we will not support or do business support
    efforts to eradicate money laundering where we identify reasonable risks that
    are the result of or involve extraction. Trade Management Transportation or
    export of precious metals.
  6. Make sure the product is non-conflicting and check that precious metals do
    not come from conflict countries and that precious metals are not mined
    using child labor or children or in violation of environmental laws. To conduct training with employees and related partners and encourage them to report any suspicious relationships and/or transactions to management and/or compliance officers. In accordance with the regulations, we require our employees, agents, consultants and business partners to comply with our policies and will enforce appropriate measures wherever possible, up to and including terminations or contracts.

Effective from January 1, 2022

(Kartik Nayanbhai Shah)

Managing director

Star Asia (Thailand) Ltd.

 

ANTI-CORRUPTION POLICY

This policy is outlined in the Topic of Anti-Corruption in Ethical Practices. STAR ASIA (THAILAND) LTD. prohibits graft and corruption in all business dealings in all countries. This policy applies to all activities within the company and with other organizations, whether between companies and private entities or between companies and government officials. particularly Strict prohibitions on the use of attempts to convince government officials, as well as activities from public sector personnel who are overseen or regulated by the public sector in connection with commercial activities.

Transparent payout regulations under the anti-corruption policy:

Employees and intermediaries are prohibited from smearing or accepting bribes, payments or valuable items to obtain or undermine contracts, businesses, government approvals. Contributing to tariffs and customs or to secure the interests of the wrong business to any organization or to provide personal, bribes, money under the table. Payment or provision of illegal benefits. It is illegal to prohibit quail, although it is common to be practiced by others in the category or industry in which the company has been adopted to highlight such a requirement. Therefore, the Company has established the following policies:

 
   

The company maintains accounting records that represent the transactional activities of the organization. Honestly and maintaining a system of adequate internal control. Books and records must store details to represent transactions and use of company assets. Other books related to intermediaries or private companies Foreign governments or other agencies are in violation of this policy.

Guidelines for reviewing and understanding the following issues:

  1. The value of paying anything of value, give a broad interpretation, the usual examples are cash, gifts, food, entertainment, stocks, personal property. Raising debts, charitable donations and services, although the value may be negligible, there is still an opportunity for violations, which must be avoided.
  2. Effectiveness of the proposal under the laws of many countries The Company stipulates that even though the offer of bribery has been given up, the company has not yet been granted a bribe. Whether or not it has been paid or the recipient has not taken any action to be deemed to have been violated at the time of the incorrect offer.
  3. Government officials or private companies The company policy prohibits bribery and corruption between companies and trading partners, including between companies and government officials, which only enforces cases of paying bribes to

Ltd.

Gems                        Tower,

Bangkok-10500, :

StarAsia

domestic or foreign government officials. With a penalty or penalty for violations. In many countries the government

May be partly owned, has a stake in the organization in which the company has smeared the transaction. It does not appear that the company has become a business partner or has some level of public ownership. Therefore, It is not to interfere with offering bribes or incorrect payments.

  1. Use of other agencies or intermediaries The Company uses agencies to assist in the delivery of products or services. It is clear to understand that payments to these intermediaries is prohibited. The Company is responsible if any entity or inheritance agency has illegally paid bribes to existing customers or will be. Incorrect bribery payments are prohibited from being used with friends or relatives of employees of clients or government officials. If the Company recognizes or believes that the payment will benefit the customer or the government for the wrong purpose.
  2. The choice of agencies and intermediaries is defined as a business objective that the agent or intermediary must meet. It must understand is also engaged in business with and ensure that the quailization on behalf of the company must be ethical and in line with the policy. Related Laws and Regulations There must be an internal process developed to review the preliminary selection of agents and intermediaries, as well as integrity throughout the relationship period.
  3. The same level of check is required to select co-investors. Candidates for acquisition and representatives The Company is responsible for the wrong activities operated by the acquired organization or by the co-investors. If abnormalities are found to
  • Review of areas of risk potential
  • To practice the conformity roadmap or
  • Stop such invalid activity.
  1. Returns, advances, discounts, as well as many organizations On occasion, the Company has arranged for returns, advances and discounts, as well as paying or discounting customers to obtain or maintain contracts or businesses as part of agreed commercial arrangements. So it’s not a mistake. If it is made clear in the contract, Rational, fulfilling and incompetent with the practice at.

Yes, this is not a cash payment, paid directly to a specific customer who is not paid to or paid through any person or independent agency without the approval of a law enforcement officer, Which is recorded correctly in the book and in accordance with the contractual obligations.

Ltd.

Gems Jewelry Tower,

U StarAsia

THAILAND

  1. In law, the Company may be criminally charged if it does not prevent bribery carried out on behalf of the Company by employees or agents. Agent’s case The

Company is responsible without anyone in the company knowing about the bribery.

  1. Gifts, food, travel Hospitality and Entertainment in accordance with guidelines Reasonable and proper giving, which gifts Food Travel Welcoming and entertaining customers, deliverers and business partners, which is useful in creating goodwill and positive relationships. In some cultures, modest gifts are expected from business partners.
  2. Do not allow overcharged or inappropriate giving of goods or services. Natural gifts, food, travel. Hospitality and entertainment must be proportional to the occasion and in line with local policies and laws and regulations in the recipient’s country, for example, even if it is appropriate and acceptable to the travel expenses of customers visiting the production facility. As a precaution, research or selecting another factory that meets the needs of the business purpose, the period of visit must be suitable for the time required to apply to ensure the business objectives are satisfied.
  3. Expenses and activities that are part of the hospitality Travel, gifts, entertainment and food must be transparent. In the accounting, each related expense must be referenced. Clearly state your business objectives. Activities and the amount of money spent.
  4. Charitable assistance The Company provides regular aid to qualified charities, which may be vulnerable to anti-bribery and anti-corruption laws.
  5. It is a risk to assist a charity that has been requested directly by a government official or business partner. Such assistance can be seen as an indirect bribe to obtain or retain contracts, businesses or government approvals. Donations on behalf of the Company must be approved by the Chairman of the Executive Committee or the Legal Affairs Committee.

The impact of actions contrary to this policy

  1. Violation of anti-corruption policies and laws and bribery to criminal and civil sanctions for both the Company and the persons involved. Therefore, there must be avoidance of opportunities or violations of strict regulations, both fiscal and criminal sanctions under specific laws can lead to years of imprisonment or fines which the company will not pay.
  2. Violatiorl of this Policy and the Law The decree led to the enforcement bf the company’s. discipline. Even if I’m fired.

Ltd.

Gerns Jewelry Tower,

Bangkok- 10500. :

 

THAILAND

The finance and accounting manager is responsible for establishing the controls to ensure that the business is carried out in accordance with the relevant policies and regulations. Regular audits help monitor and review policy compliance. Relevant Regulations and Referenced Law Requirements.

This Policy is effective from January 4, 2022.

Employment and Labor Management Policy

STAR ASIA (THAILAND) LTD. recognizes that employees are valuable assets and are at the heart of the organization’s drive towards sustainable success and growth. Therefore, we value the care and treatment of employees fairly and on the basis of respect for human rights. It focuses on promoting participation and value of difference to create value for employees and create Aspirations to work to the fullest potential.

However, this is The Company’s employment and labor management policies are set to international human rights guidelines and standards. This includes the United Nations Universal Declaration of Human Rights (UNDHR) and the Declaration on the Basic Principles and Rights of Work of the International Labor Organization (ILO), declaration on Fundamental Principles and Rights at Work, as well as the Labor Law of Thailand. Guidelines for international standards adhering to by the Company The Company’s management policy and customer requirements to enhance the quality of life and commitment to the company of employees. On the basis of fair treatment and mutual respect, the Company has established the following guidelines:

  • Child Labor

The Company shall comply with the minimum employment age law at least 18 years old and will not allow minor workers to perform tasks that harm health and development, as well as affect compulsory education.

  • Forced Labor

The Company will not act or encourage the use of forced labor in any form and will not charge or hold any employee identification documents unless it is unconstitutional.

  • Discrimination

The company will respect differences and treat employees equally. Without favoring or unfair deprivation of the rights of employees caused by race, nationality, ethnicity, color of skin, family tree, religion, social status, gender, age, disability or disability, concept. Politically, as well as marital status. In addition, it will establish preventive measures and solve problems with sexual harassment.

  • Compensation

The Company will pay wages, compensation and benefits in various ways that comply with labor law and oh time, and will not’ deduct employee pay unless it is unconstitutional.

 

Star                             Ltd.

322/47,                                        Gems &

Bangrak,

6318913 E -mali

  1. V) StarAsia

THAILAND

  • Labor Hours

The Company will set no more than 48 normal working hours per week and will ensure that employees’ overtime hours are not more than 12 hours per week, total working hours, no more than 60 hours per week, as required by law and not contrary to RJC requirements.

  • Freedom of Association and Collective Bargaining

The Company will respect the right of employees to association or incorporate in any form that is unconstitutional, including participating in the negotiation process in accordance with the legal procedures.

  • Occupational Health, Safety, Environment and Facilities

The Company will continue to promote, support, maintain and continuously improve the safe working environment. Prevents adverse health effects on employees and related parties, as well as focus on care. Prevent and reduce the environmental impact caused by the activities of the Company and related parties. By complying with the law.

In addition, the company will provide hygienic bathrooms and toilets. Clean, hygienic drinking water Factors in proper first aid A place to eat and a place to preserve clean, sanitized food.

  • Labor Protection of Pregnant Employees

The company will arrange for pregnant female employees to perform safe work. At the appropriate time and without harming the pregnancy or harming the unborn child, neither will it be terminated. Demote or reduce benefits due to pregnancy.

  • Discipline and Disciplinary Action

The Company will not use inappropriate verbal and non-corporal methods, including not committing coercive, threatening and assaulting employees.

In the event that the international standards that the Company adheres to or the customer’s requirements are higher. The above guidelines shall apply the international standards that the Company adheres to or customer requirements to be considered as relevant practices as appropriate.

Anti-Money Laundering and Financing Terrorism Policy

STAR ASIA (THAILAND) LTD. has a commitment to the opposition. Money laundering and supporting terrorism financing will be carried out in accordance with the company’s legal and regulatory requirements. As follows

  1. The Company is committed to protecting itself from being part of the money laundering process or financing terrorism.
  2. The Company will document and implement the Know Your Counterparty (KYC) policy and procedures. For business partners who are suppliers and customers, gold, silver, PGM, diamonds, colored gemstones or jewelry products are assembled with these. The policies and procedures must:
    1. The parties are identified by checking government-issued identification, being used by risk assessment, assessment or applicable laws for the sake of expressing ownership in accordance with the principles of being a party.
    2. Review the parties and, if possible, the owner of the benefit is not a named person or belongs to an organization involved in money laundering, fraud or engagement with prohibited organizations and / or those financial conflicts.
    3. Maintain understanding of the nature and legitimacy of the business.
    4. Check transactions for unusual or suspicious activity lists and report money laundering or terrorism finances to relevant authorities.
    5. Keep adequate records for at least five years or accordingly as required by law
  3. The Company shall hold responsible for implementing KYC’s policies and procedures.
  4. KYC’s policies and procedures for members must be current and appropriate, including training, documentation procedures and regular review.
  5. Records of all cash transactions or obvious links or cash-like transactions equal to or greater than 10,000 euros/ US dollars or thresholds must be kept.

Announced on January 4, 2022

Safety, Health, Environment & Energy Promotion Policy

For management safety occupational health environment and energy of STAR ASIA (THAILAND) LTD. able to operate effectively as well as control and monitor effectively. The Board of Directors has the following duties and responsibilities:

  1. Plan various events for encourage the entire company’s employees have awareness and role models abound occupational health safety environment.
  2. Support occupational health, safety activities Environment and Energy within the Company.
  3. Monitoring and evaluating security, occupational health, safety environment and energy continuously.
  4. Report progress to the Board of Directors continuously.

Announced on January 4, 2022

Provenance Claims Policy

STAR ASIA (THAILAND) LTD. located 322/47,322/49, BANGKOK GEMS & JEWELRY TOWER, 19TH FLOOR, SURAWONGSE ROAD, SIPHAYA, BANGRAK, BANGKOK 10500, THAILAND, committed to becoming Cut and Polished Diamonds traders in the precious metals business, committed to social responsibility in accordance with international standards, which all employees and stakeholders are involved in achieving this policy. The Company’s demanding process in the supply chain, in accordance with the policies associated with Cut and Polished Diamonds, conducts due diligence of all suppliers supplying in the supply chain status of all suppliers who supply Polished Diamonds obtained independently as conflict-free under the OECD Due Diligence.

  • Respond when receiving an accurate report of a complaint
  • Describe our complaint procedures and find out how the complainant wants to handle them.
  • Assign someone to be the right person within to handle a complaint or assist by redirecting the complaint to another agency, such as the relevant authority, supplier or institution, such as the relevant industry body. Ld The problem can be dealt with internally.
  • Consult the complainant about decisions or outcomes.
  • Keeping records on complaints received for at least 5 years

In this procedure, stakeholders can raise any concerns as detailed on the website. https://starasiathailand.com/

Whistleblowing Policy

STAR ASIA (THAILAND) LTD. located 322/47,322/49, BANGKOK GEMS & JEWELRY TOWER, 19TH FLOOR, SURAWONGSE ROAD, SIPHAYA, BANGRAK, BANGKOK

10500, THAILAND

1. ABOUT THIS POLICY

1.1. We are committed to conducting our business with honesty and integrity, and we expect all staff to maintain high standards. However, all organizations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do

occur.

1.2. The aims of this policy are: (a) To encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected. (b) To provide staff with guidance as to how to raise those concerns. (c) To reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

1.3. This policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers (collectively referred to as “staff” in this policy).

1.4. This policy takes account of the Whistleblowing Arrangements Code of Practice issued by the British Standards Institute and Public Concern at Work.

1.5. This policy does not form part of any employee’s contract of employment and it may be amended at any time.

2. PERSONNEL RESPONSIBLE FOR THE POLICY

2.1. The Board has overall responsibility for this policy, and for reviewing the effectiveness of actionstaken in response to concerns raised under this policy.

2.2. The Whistleblowing Officer has day-to-day operational responsibility for this policy, and must ensure that all managers and other staff who may deal with concerns or investigations under this policy receive regular and appropriate training.

Jewelry Tower.

Bangkok-10500.

-rnaal

THAILAND

2.3. The Whistleblowing Officer, in conjunction with the Board should review this policy from a legal and operational perspective at least once a year.

2.4. All staff are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing. Staff are invited to comment on this policy and suggest ways in which it might be improved.

Comments, suggestions and queries should be addressed to the Whistleblowing Officer.

  1. WHAT IS WHISTLEBLOWING.
    • Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:
      • Criminal activity;
      • Failure to comply with any legal or professional obligation or regulatory requirements;
      • Miscarriages of justice;
      • Danger to health and safety;
      • Damage to the environment;
      • Bribery under our Anti-corruption and Bribery Policy;
      • Financial fraud or mismanagement;
      • Breach of our internal policies and procedures;
      • conduct likely to damage our reputation or financial wellbeing;
      • Unauthorized disclosure of confidential information;
      • Negligence;
      • The deliberate concealment of any of the above matters.
    • whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.
    • This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the Grievance Procedure as outlined in the Staff Handbook.

& Jewelry Tower,

Bangkok- 10500,

-mati

  1. O) StarAsia

THAILAND

3.4. If you are uncertain whether something is within the scope of this policy you should seek advice from the Whistleblowing Officer, whose contact details are at the end of this policy.

  1. RAISING A WHISTLEBLOWING CONCERN

4.1. We hope that in many cases you will be able to raise any concerns with your line manager OR the HR Manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively. In some cases they may refer the matter to the Whistleblowing Officer.

4.2. However, where the matter is more serious, or you feel that your line manager OR the HR Manager has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact one of the following: (a) The Whistleblowing Officer, Richard Crook. (b) The CEO, Chris Chidley. Contact details are set out at the end of this policy.

4.3. We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

4.4. We will take down a written summary of your concern and provide you with a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the matter.

         5. CONFIDENTIALITY           

5.1. We hope that staff will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you.

5.2. We do not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible. Whistleblowers who are concerned about possible reprisals if their identity is revealed should, come forward to the Whistleblowing Officer or one of the other contact points listed in paragraph 4 and appropriate measures can then  be taken to preserve confidentiality. If you are in any doubt you can seek advice

& Jewelry Tower,

Bangkok-10500,-mati

StarAsia

from Public Concern at Work, the independent whistleblowing charity, who offer a confidential helpline. Their contact details are at the end of this policy.

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6. INVESTIGATION AND OUTCOME

6.1.Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide further information.

  1. In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimize the risk of future wrongdoing.

6.3. We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

6.4.If we conclude that a whistleblower has made false allegations maliciously or with a view to personal gain, the whistleblower will be subject to disciplinary action.

7. IF YOU ARE NOT SATISFIED

  1. While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this.

7.2. If you are not happy with the way in which your concern has been handled, you can raise it with one of the other key contacts in paragraph 4. Alternatively, you may contact the Company’s secretary. Contact details are set out at the end of this policy.

 8. EXTERNAL DISCLOSURES

8.1. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the •workplace. In most cases you should not find it necessary to alert anyone externally.

& Jewelry Tower,

Bangkok-10500.

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OECD DUE DILIGENCE POLICY

STAR ASIA (THAILAND) LTD. has a commitment to responsible producer and therefore has established a policy to check the status of minerals in accordance with the rules of the Organization for Economic Cooperation and Development (OECD).As follows

  1. The Company will provide policies to demonstrate responsibility in the supply chain in order to have compliance with the guidelines. The OECD (Organization of Economic Cooperation and Development) consists of: Human Rights Policy, non-forced labor, Not using child labor in a bad way, Non-violence, abuse or virtuous conduct, Not supporting terrorism, Treating a person in unlawful safety matters, Not supporting money laundering giving or accepting bribes or nonpayment of taxes, Resistance to all forms of crime against humanity.
  2. Provide risk indication and assessment for raw material sources and high-risk areas according to the criteria. OECD.
  3. Provide ways to improve or improve the risk and consider taking action.
  4. In case of failure to assess the risk The Third Party Audit method can be used.
  5. Prepare reports and review every year, including announcements to stakeholders.

Announced on January 4, 2022