Governance Framework

Our Policies

Governance Framework for Responsible Global Trade

Etalery operates a private, institutional-grade diamond and jewellery sourcing platform. To protect buyers, suppliers, and the integrity of global trade, Etalery follows a comprehensive policy framework aligned with international best practices, regulatory expectations, and ethical standards.

Our policies are designed to ensure transparency, accountability, security, and responsible conduct across all aspects of our operations and supply ecosystem.

1

Corporate Governance Policy

Etalery follows a governance-first operating model, ensuring that decision-making, oversight, and platform operations are conducted responsibly and consistently.

  • Clear accountability and management oversight
  • Defined governance roles and escalation mechanisms
  • Separation of operational, compliance, and oversight functions
  • Periodic review of governance practices
2

Code of Conduct

Establishes expectations for ethical behavior across employees, partners, suppliers, and platform participants.

  • Integrity, honesty, and professional conduct
  • Compliance with laws and regulations
  • Fair competition and ethical trade practices
  • Respect for confidentiality and proprietary information
3

AML & CTF Policy

Robust framework designed to prevent misuse of the platform for financial crime.

  • Risk-based AML controls
  • Customer due diligence (KYC/KYB)
  • Enhanced due diligence for higher-risk cases
  • Transaction monitoring and review
4

Sanctions & Trade Compliance

Complies with applicable sanctions regimes, export control laws, and trade restrictions.

  • Prohibition of sanctioned jurisdictions
  • Restriction of diamonds of Russian origin
  • Mandatory supplier export compliance confirmation
  • Trade compliance transaction reviews
5

Responsible Sourcing Policy

Governs how diamonds, jewellery, rough stones, and materials enter the platform.

  • Lawful and documented sourcing
  • Zero tolerance for conflict-related materials
  • Verified supplier sourcing declarations
  • Alignment with ethical trade standards
6

Supplier Verification Policy

All suppliers must undergo structured verification before onboarding and ongoing monitoring.

  • Business identity and ownership checks
  • License and export registration review
  • Sourcing and procurement assessment
  • Ethical and labor practice declarations
7

Human Rights & Labor Standards

Etalery is committed to respecting internationally recognized human rights.

  • Prohibition of forced or child labor
  • Prevention of human trafficking
  • Safe and lawful working conditions
  • Zero tolerance for discrimination or harassment
8

Modern Slavery Policy

Maintains a zero-tolerance approach to modern slavery and human trafficking.

  • Risk-based supplier assessments
  • Ethical declarations during onboarding
  • Ongoing monitoring and escalation
  • Confidential reporting of concerns
9

Environmental Responsibility

Recognizes environmental responsibility as an important aspect of sustainable trade.

  • Supporting traceable sourcing
  • Encouraging certified lab-grown alternatives
  • Reducing waste through digital-first sourcing
  • Promoting efficient procurement workflows
10

Privacy & Data Protection

Protects personal and business information through a comprehensive policy.

  • Lawful and transparent data processing
  • Secure storage and access controls
  • Limited data sharing under strict safeguards
  • Respect for individual data rights
11

Information Security Policy

Applies technical and organizational measures to protect platform data and systems.

  • Secure authentication and access controls
  • Monitoring for unauthorized access
  • Data protection safeguards
  • Periodic security reviews
12

Platform Usage & License

Access to the Etalery platform is governed by a Platform License Agreement.

  • Authorized use of the platform
  • Prohibited activities
  • Confidentiality obligations
  • Suspension and termination conditions
13

Fair Competition Policy

Supports fair competition and transparent trade practices.

  • Prohibition of price manipulation
  • Prevention of product misrepresentation
  • Protection of confidential information
  • Requirement for good faith participation
14

Risk Management Policy

Identifies, assesses, and manages operational, compliance, and sourcing risks.

  • Risk-based onboarding and monitoring
  • Continuous policy review
  • Escalation and mitigation procedures
  • Senior management oversight
15

Reporting & Accountability

Encourages reporting of concerns related to misconduct or compliance breaches.

  • Confidential reporting mechanisms
  • Protection against retaliation
  • Proper investigation and resolution
  • Strengthening ecosystem trust
16

Policy Review & Improvement

Policies are reviewed periodically to reflect changes and emerging risks.

  • Regulatory and legal updates
  • Industry best practice alignment
  • Platform evolution adjustments
  • Continuous improvement commitment

Our Position

Policies at Etalery are not symbolic documents. They are operational controls that govern how trade occurs on the platform.

By enforcing clear, consistent, and internationally aligned policies, Etalery builds a sourcing ecosystem that institutional buyers and ethical manufacturers can trust.

ETALERY
Governed Trade.Ethical Standards.Institutional Confidence.