Ethical Business Policy

Policy owner: General Manager / Senior Management

Effective date: 11 August 2026

Review cycle: At least annually, and when material risks or RJC requirements change

1. Purpose

Australian Opal Cutters Pty Ltd is committed to conducting business with integrity, transparency, fairness and respect. This policy sets the minimum ethical standards expected of directors, managers, employees, contractors and, where relevant, business partners.

2. Our commitments

We comply with applicable laws, regulations and recognised jewellery-industry requirements relevant to our activities.

We do not tolerate bribery, corruption, facilitation payments, fraud, money laundering, terrorist financing, deliberate tax evasion or other dishonest business practices.

We avoid, disclose and appropriately manage actual or potential conflicts of interest.

We maintain accurate business records and do not knowingly create false, misleading or deceptive records, invoices, product descriptions or claims.

We market and describe jewellery, gemstones and opals honestly. Material information about products, including relevant treatments, synthetics, composites or other characteristics, is disclosed as required by law and applicable industry standards.

We compete fairly and respect confidential information, intellectual property and the privacy of customers, employees, suppliers and business partners.

We select and deal with suppliers and business partners on legitimate commercial grounds and expect them to act lawfully and ethically.

We provide channels for genuine concerns to be raised and do not retaliate against a person for reporting a concern in good faith.

3. Gifts, hospitality and improper influence

Gifts, hospitality, commissions or other benefits must never be offered, requested or accepted where they could improperly influence a business decision or reasonably appear to do so. Any material concern must be disclosed to senior management.

4. Breaches and corrective action

Suspected breaches will be assessed and, where appropriate, investigated. Australian Opal Cutters may take corrective or disciplinary action, review a commercial relationship, report unlawful conduct where required, and improve controls to prevent recurrence.

5. Responsibility and review

Senior management endorses this policy and is responsible for ensuring that ethical expectations are communicated and supported by appropriate procedures. This policy will be reviewed periodically and updated where required.

Prepared with reference to the Responsible Jewellery Council (RJC) Code of Practices 2024, including COP 2 (Policy and Management Systems), COP 6 (Human Rights), COP 7 (Due Diligence for Responsible Sourcing) and related ethical business requirements. This policy supports RJC alignment but does not by itself establish or guarantee RJC certification.

Australian Opal Cutters Pty Ltd | Public Policy