Better Health for All

The company's principal goods, diamonds, have no significant positive or negative health impact, and it generates no revenue from products with direct health harms. The company does not offer health-related products or services requiring accessibility considerations, nor does it hold healthcare-related patents, produce food products, conduct clinical trials, or deal with addictive products. The company demonstrates exceptional risk transparency regarding operational risks that could impact community health, conducting rigorous safety inspections and audits of dam walls, maintaining an early warning system for dam failure, reporting and investigating all incidents including near misses, and publicly disclosing sustainability policies.

Regarding health externalities, the company actively mitigates negative health impacts from its operations, addressing coliform, E. coli, and elevated nitrate levels in water sources through initiatives such as a nitrate management study, wetland construction, bioremediation, refined blasting practices, and providing safe drinking water and sanitation facilities since 2010. The company provides substantial support for healthcare workforce capacity, including training 260 healthcare workers in Mokhotlong in 2015 and offering healthcare worker training during the COVID-19 response in 2020 and 2021. It also offers comprehensive mental health programs for employees, including financial and other wellness services with trained counselors, and considered psychological welfare during the COVID-19 response. The company maintains a perfect track record of zero breaches of confidentiality and privacy of client or customer information in 2019 and 2024.

Fair Pay & Worker Respect

In 2024, the company reported a Lost Time Injury Frequency Rate (LTIFR) of 0.18 per 200,000 man-hours

and an All Injury Frequency Rate (AIFR) of 0.61, with zero fatalities . Group-wide voluntary staff turnover was 2% in 2024 . The company recorded zero discrimination cases, zero incidents of child or forced labor, and zero strikes or lockouts during 2024 . No complaints or reports of modern slavery or human trafficking have been received, supported by an ethics hotline and supply chain vetting . As of year-end 2024, 21.16% of the workforce comprised contractors, who receive a fixed-term contract allowance of 20% of their basic salaries .

No War, No Weapons

The company's ethical framework includes a zero-tolerance approach to fraud, theft, modern slavery, child labor, bribery, and other wrongdoing

, reporting zero incidents of child or forced labor, bribery, corruption, or anti-competitive behavior in 2023 and 2024 across its value chain , . All rough diamond exports are certified through the Kimberley Process certification scheme, which aims to prevent conflict diamonds , . The company explicitly states it will neither tolerate nor profit from, contribute to, assist with, or facilitate gross human rights violations, war crimes, or other serious violations of international humanitarian law, crimes against humanity, or genocide by any party in its procurement . GemFair commissions an annual third-party audit of its due diligence management system, with a summary of each report published online . In 2020, the company invested US$0.3 million in social projects , representing 0.157% of its US$190 million revenue . The company exports diamonds in accordance with Kimberley Process requirements and is compliant with relevant government regulations and voluntary codes , , and is not subject to the Arms Trade Treaty.

Planet-Friendly Business

Letšeng Diamonds, a subsidiary, is accused of polluting drinking water in three villages in Lesotho with E. coli and nitrates, leading to a pending lawsuit.

A confidential report previously showed the company admitted to contaminating these sources. Despite this, the company reported zero major environmental incidents and zero fines for environmental transgressions in 2024 and for 15 consecutive years, respectively. The company's net water usage in 2023 was 3.0 million m³, with revenue of US$140.3 million, resulting in 21,382.75 m³ per $1M revenue. The company has a target to reduce Scope 1 and 2 emissions by 30% by 2030 (vs. 2021 baseline), but these targets are not explicitly stated as SBTi-validated. The TCFD framework was fully adopted in 2023, and a comprehensive climate change scenario analysis was conducted in 2021 by an independent expert, considering 1.4°C, 1.9°C, 3.3°C, and 6.0°C pathways, which informed its internal carbon-pricing model.

Respect for Cultures & Communities

Gem Diamonds' Letšeng mine workforce is highly localized, with 99% comprising Lesotho nationals in both 2023 and 2024.

The company directs a significant portion of its in-country procurement to local communities, with US$29.7 million (76.5% of US$38.8 million in-country procurement) sourced from Project Affected Communities and communities around Letšeng in 2024. The company has implemented a community grievance mechanism and a documented external grievance management process for its operations. For 2023 and 2024, zero major or significant community grievances or stakeholder complaints were recorded, and zero violations of indigenous communities’ rights were reported. The company conducts operation-specific social and environmental impact assessments (SEIAs) that align with IFC Performance Standards, Equator Principles, and FPIC guidelines, and has a “Chance Find Procedure” for cultural heritage discoveries. It also commits to protecting known cultural heritage sites within its mine lease area.

Safe & Smart Tech

The company reported zero breaches of customer confidentiality in both 2023 and 2024.

It explicitly states full regulatory compliance with Know Your Client (KYC), anti-money laundering processes, the UK Bribery Act, South Africa's Protection of Personal Information Act (POPIA), the Consumer Protection Act, and EU data protection legislation. Users are provided with standard rights to access, correct, erase, object to, and restrict the processing of their personal information, as well as to withdraw consent and block cookies. The company's policy is to limit personal information processing and retention to what is necessary or legally required. Its Letšeng security processes align with ISO 18788, a recognized security operations management standard.

Zero Waste & Sustainable Products

The company has not incurred any fines for environmental transgressions or non-compliance with host country legislation for 15 consecutive years.

It has implemented over 10 waste reduction initiatives, including an updated life of mine plan, mineral waste optimisation since 2021, tyre reuse projects, green procurement promotion, enhanced food waste composting, an updated waste management strategy in 2024, refined blasting protocols, continuously refining pit designs, relocating diesel depots, and introducing a heavy equipment trailer. These initiatives have led to measurable results such as a 30% reduction in haulage distances and a 19% reduction in accommodation heating energy. Hazardous waste management complies with the Basel Convention, includes permits for transboundary disposal to certified sites in South Africa, and features on-site medical waste incineration, along with safe handling, storage, and segregation. Waste monitoring is comprehensive, with annual internal and external sustainability audits, quarterly hazardous waste reporting, and daily, weekly, monthly, and quarterly inspections across various waste aspects and facilities. Supplier contracts mandate compliance with the Code of Conduct and HSE standards, ensuring waste removed from site adheres to legal requirements and international norms.