Code of Conduct Policy

Brilliant Jewelers / MJJ Inc. is Fine Jewelry Wholesaler we are committed to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws. On August 22, 2012, the final rule regarding sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“the Dodd-Frank Act”) was approved by the U.S. Securities and Exchange Commission (“SEC”). Conflict minerals include columbite-tantalite (coltan; i.e., tantalum); cassiterite (i.e., tin); wolframite (i.e., tungsten); gold or their derivatives. The rule imposes reporting requirements on publicly traded companies subject to the SEC to annually report the presence of conflict minerals originating in the Democratic Republic of the Congo (“DRC”) or adjoining countries (“Covered Countries”) in the products they manufacture or contract to manufacture whereby the conflict minerals are necessary to the functionality or production of a product. Brilliant Jewelers / MJJ Inc. supports the humanitarian goal of the Dodd-Frank Act in ending the illegal trade of conflict minerals originating in the DRC.

Brilliant Jewelers / MJJ Inc. is a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:

  • respect human rights according to the Universal Declaration of Human Rights and International Labor 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; and
  • enable stakeholders to voice concerns about the jewelry 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

We also commit to using our influence to prevent abuse of others that why our we ask that you fill out the form correctly and to the outmost honesty. If information is misleading or incorrect we will have to red flag your company. If your company is at high risk and does not comply with RJC guidelines we will cease to conduct business.

Serious abuses associated with the extraction, transport or trade of diamonds/colored gemstones
We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

  • torture, cruel, inhuman and degrading treatment;
  • forced or compulsory labor;
  • the worst forms of child labor;
  • human rights violations and abuses; or
  • war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in 4 or are sourcing from, or linked to, any party committing these abuses.

Direct or indirect support to non-state armed groups
We only sell or purchase diamonds/colored gemstones that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds/colored gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

  • control mine sites, transportation routes, points where diamonds/colored gemstones are traded and upstream actors in the supply chain; or
  • tax or extort money or diamonds/colored gemstones at mine sites, along transportation routes or at points where diamonds/colored gemstones are traded, or from intermediaries, export companies or international traders.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.

Public or private security forces
We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally as described in paragraph 6.

Bribery and fraudulent misrepresentation of the origin of diamonds/colored gemstones
We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of diamonds/colored gemstones, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of diamonds.

Money laundering
We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of diamonds/colored gemstones.

Code of Conduct for Precious Metal/stones Suppliers:
Brilliant Jewelers / MJJ Inc. wishes to ensure that no Precious Metal/Diamonds/Stones from questionable sources are offered to Brilliant Jewelers / MJJ Inc. Therefore, Brilliant Jewelers / MJJ Inc. expects its business partners from whom it procures Precious Metal/Diamonds/Stones (“Suppliers”) to take appropriate measures for the monitoring of the supply chain and to act in compliance with the applicable legal provisions. This Code of Conduct defines the requirements of Brilliant Jewelers / MJJ Inc. placed on its Precious Metal and Stone suppliers.

Compliance with Applicable Law / Prevention of Money Laundering (AML)

  • act in compliance with the applicable laws of the relevant jurisdiction(s).
  • take preventive measures with regard to money laundering and provide training in order to ensure that all employees obtain comprehensive knowledge in the field of the prevention of money laundering.

Prohibition of Corruption and Bribery (ABAC)

  • • Supplier may not tolerate any form of corruption including the direct or indirect bribery of business partners and the acceptance of business courtesies as consideration for the purchase of products or other services of business partners.

Respecting the Fundamental Rights of Employees

  • Supplier may promote equal opportunities and equal treatment of its employees irrespective of color, race, nationality, social background, disability, sexual preference, political or religious conviction, gender or age;
  • Supplier may respect the personal dignity, privacy and personal rights of each individual;
  • Supplier may neither employ individuals against their will nor compel individuals to work;
  • Supplier may not tolerate any unacceptable treatment of employees, such as mental duress, sexual and personal harassment or discrimination;
  • Supplier may not tolerate any conduct or behavior (including gestures, language and physical contact) that is of a sexual, coercive, threatening, abusive or exploitative nature;
  • Supplier may ensure appropriate payment and guarantee the statutory national minimum wage;
  • Supplier may comply with the statutory maximum working hours applicable in the respective country;
  • Supplier may accept the freedom of association of the employees and neither favor nor discriminate members of employees' organizations or trade unions.

Prohibition of Child Labor

  • Supplier may not employ children. For the purposes hereof, all individuals under the age of 15 shall be deemed children unless a higher minimum working age has been determined under national or regional law.

Employee Health and Safety

  • take responsibility for the health and safety of its employees;
  • guarantee a high level of occupational safety and ensure the implementation of optimum preventive measures against accidents and occupational diseases;
  • provide training in order to ensure that all employees have comprehensive knowledge in the field of occupational safety;

Environmental Protection

  • Supplier may comply with all applicable statutory provisions for environmental protection;
  • minimize environmental pollution and continuously improve environmental protection.

Supply Chain

  • Supplier may optimally promote its suppliers' compliance with the content of the Code of Conduct;
  • Supplier may comply with the non-discrimination principles when selecting or dealing with suppliers.

Sources of Supply / Conflict Mineral

  • Supplier may not purchase any Precious Metal/Diamonds/Stones that were mined using child or forced labor, or Precious Metal/Diamonds/Stones that were mined in violation of the environmental law regulations applicable in the country where the mining takes place;
  • apply appropriate methods and procedures for the monitoring of suppliers to ensure that the Precious Metal/Diamond/Stones offered to Brilliant Jewelers / MJJ Inc. do not stem from countries of conflict and that the Precious Metal/Diamonds/Stones were not mined using child or forced labor or in violation of environmental law regulations;
  • in cases of doubt, Supplier may not purchase any Precious Metal/Diamonds/Stones from questionable sources or offer such Precious Metal/Diamonds/Stones to Brilliant Jewelers / MJJ Inc. for resale;
  • make available to Brilliant Jewelers/MJJ Inc, upon request, the relevant certificates of origin;
  • inform Brilliant Jewelers / MJJ Inc., without request, if Precious Metal/Diamonds/Stones from questionable sources were offered.

In order to meet these commitments, Brilliant Jewelers / MJJ Inc. will:

Leverage the web-based Conflict Minerals Resource Center for the most up-to-date information regarding conflict minerals; and Routinely assess our suppliers’ compliance with this policy.

This policy may be updated periodically as required.

If you have any questions or concerns, you may contact us via email compliance@mjjbrilliant.com or in writing:

Brilliant Jewelers / MJJ Inc.
Attn: Compliance Officer
30-30 NORTHERN Blvd, 5th Floor
Long Island City, NY 11101


Signed/endorsed: Atul Kampani Date of effect:6/1/2021