MID RJC 2024

M.I.D. House of Diamonds Anti-Bribery and Corruption Policy

As an Israeli and global company, " M.I.D. House of Diamonds " is dedicated to ensuring full compliance with all anti-bribery and corruption laws and regulations, including the International Organization for Economic Cooperation and Development (the "OECD"), by all of its employees. Generally, anti-bribery and corruption laws prohibit making payments or gifts to government officials to obtain or retain business, or to secure any improper business advantage. Some Israeli bribery laws also prohibit bribery even when non-government entities are involved, for example, diamond officials or diamond companies. " M.I.D. House of Diamonds " understands the importance of eliminating bribery and corruption around the world, and the role that discouraging bribery and corruption plays in creating a safer, more stable political and business environment. It is " M.I.D. House of Diamonds " policy that no company officer, employee, or manager member may accept or offer inappropriate payments to any institution (government ministry, Diamond Company, office for diamond trade, etc.), to make any official act in a manner that will assist " M.I.D. House of Diamonds " in obtaining or retaining business or securing any improper business advantage. Every " M.I.D. House of Diamonds " employee and manager is obligated to keep books, records, and accounts that accurately and fairly reflect all " M.I.D. House of Diamonds " transactions and the use of " M.I.D. House of Diamonds " assets. " M.I.D. House of Diamonds " takes bribery and corruption very seriously, and any employee found to be violating this policy will be subject to disciplinary action, which may include termination. " M.I.D. House of Diamonds " encourages its employees to report any suspicious activity that may violate this policy. There is a confidential and discrete way to report any violations or suspicious activity that is described below. An employee's failure to report known or suspected violations may lead to disciplinary action.

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