Human Rights 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. Commitment

Australian Opal Cutters Pty Ltd respects internationally recognised human rights and is committed to conducting its operations and business relationships in a manner consistent with the United Nations Guiding Principles on Business and Human Rights. Our approach is proportionate to the size, nature and circumstances of our business.

2. Our expectations

We do not tolerate forced labour, bonded labour, human trafficking, slavery, the worst forms of child labour, harassment, violence, abuse or unlawful discrimination.

We respect lawful freedom of association and collective bargaining rights and support fair, respectful and safe working conditions.

We expect employees, suppliers and contractors to respect human rights and to avoid causing, contributing to or being directly linked to serious adverse human rights impacts through their activities or business relationships.

We pay particular attention to heightened human rights risks in mineral and gemstone supply chains, including risks associated with conflict-affected and high-risk areas and vulnerable workers or communities.

We seek to identify and assess material human rights risks through proportionate due diligence, supplier review, workplace practices and consideration of credible concerns raised by stakeholders.

We will take reasonable steps to prevent or mitigate identified adverse impacts and will track appropriate corrective actions.

3. Remedy and grievances

Where Australian Opal Cutters identifies that it has caused or contributed to an adverse human rights impact, we will provide for or cooperate in appropriate processes aimed at remedy. Employees and external stakeholders may raise genuine human rights concerns with management without fear of retaliation.

4. Implementation

Senior management endorses this policy. Relevant employees are expected to understand their responsibilities, and appropriate procedures and records will support implementation. Human rights considerations will be integrated into relevant business decisions and supplier due diligence.

5. Communication and review

This policy is publicly available and may be communicated to employees, suppliers, contractors and other relevant stakeholders. We will review our human rights approach periodically, including when material risks, business activities, legal requirements or RJC expectations change.

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