Due Diligence Policy

Gemstar Ltd . pride themselves on their reputation for honesty, integrity and excellence. We hold our Suppliers to the same high standards to which we hold ourselves.
Gemstar Ltd . therefore expects and requires that its goods and services are procured from Suppliers that share our commitment to and meet certain criteria with respect to human rights, fair and safe labor practices, environmental protection and ethical business conduct.
We not only expect our Suppliers to operate in full compliance with all applicable laws, rules and regulations, we expect each Supplier to go beyond legal compliance and strive to meet internationally recognized standards for the advancement of human rights, business ethics, and social and environmental responsibility. Suppliers shall align with the United Nations Guiding Principles on Business and Human Rights and work conscientiously to operate within its framework.

REQUIREMENTS FOR ALL SUPPLIERS
Business Integrity: The highest standards of integrity are to be upheld in all business interactions. Supplier shall conduct business ethically and all business dealings should be transparently performed and accurately reflected on Supplier’s business books and records. Supplier shall have a policy that describes its commitment to business integrity and corporate responsibility.
Conflict Diamonds
Suppliers will not support or source from conflict affected & high-risk areas.
Legal Compliance: Supplier shall comply with all applicable laws and regulations currently in effect and as they become effective. Supplier shall have systems in place that maintain awareness of and ensure compliance with all applicable laws and regulations, including but not limited to, laws concerning labor, health and safety, human rights, environmental protection and corruption and bribery.
Anti-Corruption and Bribery: Supplier shall not engage in any form of corrupt practices, including bribery, extortion, embezzlement, or fraud. Supplier represents and warrants that it shall not violate or cause Gemstar Ltd. to violate any applicable anti-corruption or bribery law (including without limitation the United States Foreign Corrupt Practices Act).
Security: Supplier shall ensure the safety and security of its employees, contractors, and visitors. Supplier shall assess security risks and establish measures that protect against product or intellectual property theft, unauthorized access to or loss of employee or customer personal information, and damage or substitution of products within the premises and off-site or in-transit.
Child Labor: Supplier shall not employ children. Children refer to any person under the age of 15, or under the age for completing compulsory education, or under the legal minimum age for employment in the country, whichever is greatest.
Working Hours: Employees shall not be required to work more than 60 hours per week, including overtime, except in extraordinary business circumstances with their consent.
Health and Safety: Supplier shall provide a safe and healthy work environment and fully comply with all applicable safety laws, regulations and industry standards. Supplier shall regularly assess the workplace for hazards and implement appropriate programs and engineering controls to minimize the risks of work related accidents.

Summary
Gemstar Ltd.  is a Tier 2 midstream and downstream company. We prepared a Supply Chain policy.
This policy has been communicated to all employees and made it publicly available on our website. A senior executive has been appointed to be responsible for the due-diligent program. He is responsible for collecting the information from all suppliers and keeping the records for analyzing continuous improvements. Risk assessment has been done and presented to the company’s top management.

Lior Eshed – CEO

9/4/2025