Code of Conduct

Etalery conducts all business activities honestly, fairly, and in compliance with applicable laws, regulations, and international trade standards.

All stakeholders are expected to:

• •Act with integrity in every professional interaction
• •Avoid deceptive, misleading, or fraudulent practices
• •Conduct business in a manner that upholds Etalery’s reputation and trust

Unethical behavior, misrepresentation, or abuse of the platform will not be tolerated.

Etalery operates within a compliance-first framework and requires strict adherence to all applicable local, national, and international laws, including but not limited to:

• •Trade and export regulations
• •Anti-money laundering (AML) laws
• •Anti-bribery and anti-corruption laws
• •Data protection and privacy regulations
• •Sanctions and embargo requirements

All participants must comply with these legal obligations as a condition of platform access.

Etalery maintains a zero-tolerance policy toward bribery, corruption, facilitation payments, or improper influence of any kind.

Stakeholders must not:

• •Offer, give, solicit, or accept bribes or improper benefits
• •Engage in any activity intended to improperly influence business decisions
• •Use third parties to circumvent anti-corruption obligations

Any suspected violations must be reported immediately through appropriate channels.

Etalery supports fair and open competition and prohibits any conduct that undermines market integrity.

Prohibited behaviors include:

• •Price manipulation or collusion
• •Misrepresentation of products, certifications, or origin
• •Abuse of confidential or non-public information
• •Unfair or deceptive trade practices

All sourcing activity must be conducted transparently and in good faith.

All diamonds, jewellery, and materials sourced through the Etalery platform must originate from responsible and ethical sources.

Participants are required to:

• •Ensure lawful and documented origin of goods
• •Avoid conflict-related or prohibited materials
• •Provide accurate certification and provenance documentation
• •Adhere to responsible manufacturing and labor practices

Etalery reserves the right to suspend or terminate access for non-compliance.

Etalery is committed to respecting internationally recognized human rights principles across its ecosystem.

We prohibit:

• •Forced labor, child labor, or human trafficking
• •Discrimination, harassment, or abusive conduct
• •Unsafe or unlawful working conditions

Suppliers and partners must comply with applicable labor laws and ethical employment practices.

Etalery treats data security and confidentiality as fundamental responsibilities.

All stakeholders must:

• •Protect confidential, proprietary, and personal data
• •Use platform data solely for authorized business purposes
• •Comply with applicable data protection and privacy laws

Unauthorized disclosure, misuse, or access to sensitive information is strictly prohibited.

All stakeholders must avoid situations where personal, financial, or external interests could improperly influence professional judgment or business decisions.

Any actual or potential conflict of interest must be:

• •Promptly disclosed
• •Managed transparently
• •Approved in accordance with Etalery’s governance procedures

Failure to disclose conflicts may result in disciplinary action.

Access to the Etalery platform is a privilege granted under strict governance.

Users must:

• •Use the platform only for lawful, authorized purposes
• •Respect confidentiality and platform rules
• •Refrain from misuse, circumvention, or unauthorized communication

Etalery reserves the right to monitor activity to ensure compliance with this Code.

Etalery encourages a culture of accountability and transparency.

Stakeholders are expected to:

• •Report suspected violations of this Code
• •Cooperate with investigations
• •Act in good faith without fear of retaliation

All reports will be handled confidentially and investigated appropriately.

Violations of this Code may result in corrective action, including but not limited to:

• •Suspension or termination of platform access
• •Contractual remedies
• •Legal action where applicable

Etalery enforces this Code consistently and fairly across all participants.

This Code of Conduct is reviewed periodically to reflect evolving regulatory requirements, industry standards, and best practices.

Etalery remains committed to continuous improvement in governance, ethics, and responsible trade.