Business Responsibilities

The Best Practice Principles ensure that diamonds from CrownStone Diamonds, on their journey from discovery to consumer, have met the highest professional, ethical and technical standards. Established in the early 2000s, they help prevent unacceptable business, environmental and social practices across the diamond pipeline.

Business Responsibilities form one of the four core responsibility areas of the Best Practice Principles. They encompass the commitment to combating dishonesty and fraud in all business transactions, adherence to national and international law, and the systems required to monitor and support these commitments throughout the diamond supply chain.

To maintain and enhance consumer trust in, and the reputation of, the gem diamond industry, there must be a commitment to combating dishonesty and fraud in all business transactions.

Best Practice Principles

ETHICAL STANDARDS

There must be a programme in place that monitors the effectiveness of these commitments and to support all workers in that endeavour. All businesses should adhere to national laws. Where no appropriate national laws exist, the appropriate United Nations and/or International Labour Organisation (ILO) Conventions and Declarations should be followed.

Furthermore, where local laws stipulate certain general standards but provide that certain businesses (for example, small businesses) are subject to lower or no set standards, you must demonstrate compliance with the general standards. No practice or conduct must be engaged in that brings the diamond industry into disrepute.

COMMITMENT

Demonstrate commitment to responsible business practices both internally to employees, and publicly to stakeholders. A policy is required to demonstrate commitment to responsible business practices for all parts of the business. It should be documented and communicated to employees in addition to being made publicly available.

Senior management should continuously monitor and document the implementation of the policy and procedures along with the performance throughout the business. A formal performance review should be undertaken and documented to identify any gaps that occur between the policy and the business practices. This review should take place frequently throughout the year, potentially as part of the board meetings.

The entity should identify issues relevant to the RJC Code of Practices Membership through their own operations, or, through involvement in community initiatives and communicate their policies or positions along with any actions that were taken or objectives to their stakeholders.

BUSINESS INTEGRITY

Entities must implement effective policies and adequate procedures to prohibit involvement in bribery in all business practices and transactions that are carried out by them, or on their behalf by Business Partners. They will not offer, accept or countenance any payments, gifts in kind, hospitality, expenses or promises as such that may compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with, or direct business to, any person.

Entities will provide systems for the reporting and investigation of allegations of attempted bribery or inappropriate gifts within their organisation and will apply the appropriate sanctions for bribery and attempted bribery in all forms. This will include clear communication to their workers that they will not suffer retaliation for such reports or refusing to pay a bribe or facilitation payment even if this action may result in the entity losing business.

Where entities have not yet been able to eliminate facilitation payments, they will implement appropriate controls to monitor, oversee and fully account for all facilitation payments made. They will work to ensure that they are of limited nature and scope, with an ultimate objective to eliminate all facilitation payments.

FINANCIAL PROBITY

Compliance is required with national, and where appropriate international, legislation and regulations with respect to money laundering, terrorism financing, bribery, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.

If entities and/or facilities are not included in any other financial accounts (for example, but not limited to, those of a parent company), they will need annual independently audited financial accounts, and will need to demonstrate that the audit was carried out by a properly qualified auditor to international accounting standards and that the appointment of the auditor was free of any bias or influence.

Financial auditors should be alerted to applicable national legislation imposing special anti-money laundering/combating the financing of terrorism compliance rules on dealers in precious stones or high value goods. Entities must demonstrate that they are fully informed of all relevant legislation and regulations regarding bribery and facilitation payments in all relevant jurisdictions.

• Ethical Standards
• Commitment & Policy
• Business Integrity
• Financial Probity
• Kimberley Process Compliance
• Product Security
• Full Disclosure

KIMBERLEY PROCESS AND SYSTEM OF WARRANTIES

The definition of 'Conflict Gem Stone Diamonds' agreed by the Kimberley Process must be adopted: rough diamonds used by rebel movements or their allies to finance conflict aimed at undermining legitimate governments, as described in relevant United Nations Security Council (UNSC) resolutions.

The World Diamond Council proposed system of warranties must be adopted and all buyers and sellers of both rough and polished diamonds must make the following affirmative statement on all invoices: 'The diamonds herein invoiced have been sourced or purchased from legitimate sources not involved in funding conflict, in compliance with United Nations Resolutions and corresponding national laws. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WDC SoW Guidelines.'

The rules of the Kimberley Process and the requirements of the World Diamond Council shall be effectively communicated to the relevant workers involved in the buying and selling of rough diamonds and/or the buying and selling of polished diamonds and/or diamond jewellery.

Each company trading in rough and polished diamonds is obliged to keep records of Kimberley Process Certificates and warranty invoices received, and the warranty invoices issued, when buying or selling diamonds. This flow of certificates and warranties must be audited and reconciled on an annual basis.

PRODUCT SECURITY

Entities will establish and implement product security policies and procedures within the premises and during shipment to protect against product theft, damage or substitution. Entities will prioritise the security and well-being of employees, visitors and other relevant business partners when establishing product security measures. All businesses should ensure that diamond or gold jewellery products sold by members to end consumers will be compliant with the applicable regulations for product health and safety.

DISCLOSURE

Full disclosure is the complete and total release of material information about gold, a diamond or other stone and the material steps it has undergone prior to sale to the purchaser. The vendor must make all reasonable efforts to ensure this information is disclosed at all times during the selling process. Full disclosure of all material facts must take place whether or not the information is specifically requested and regardless of the effect on the value of the item being sold.

It is recommended that the nomenclature standards defined in the International Standard on 'Jewellery – Consumer confidence in the diamond industry', ISO 18323:2015 (E) are adhered to ensure clear and accurate labelling on how to describe diamonds, treated diamonds, synthetic diamonds, composite diamonds and imitations of diamonds.

A synthetic diamond must only and always be disclosed as 'synthetic diamond', 'man-made', 'laboratory created', 'laboratory-grown' or 'artificial' and the description must be equally as conspicuous and immediately preceding the word 'diamond'. Treatment means any process, treatment or enhancement changing, interfering with and/or contaminating the natural appearance or composition of a diamond other than the historically accepted practices of cutting and polishing.

SUPPLY CHAIN MANAGEMENT/BEST ENDEAVOURS

Programmes and/or procedures, including risk assessments, should be established to address compliance with the BPPs by business partners such as contractors, sub-contractors, suppliers, clients, agents and security providers that are directly involved in the mining, handling, manufacture and sale (or purchase as applicable) of gold, diamonds and/or diamond or gold jewellery.

Due diligence that may have been undertaken on areas such as human rights and forced labour can be incorporated into the risk assessment. Evidence of commitment to responsible business practices through certification such as SA8000, ISO14001 and RJC certification could be taken into consideration when addressing the reputational risk posed by a relationship with a business partner.

Companies/Entities/Facilities will need to demonstrate that they have taken appropriate action to satisfy the requirement to use Best Endeavours to ensure the commitment of non-Substantial contractors to comply with the BPPs (the Best Endeavours Requirement).

PROVENANCE CLAIMS

Companies/Entities/Facilities will need to confirm if they make claims or statements to consumers or other businesses on practices in their supply chain and the origin or source of diamonds, synthetic diamonds, gold and/or platinum through the use of descriptions or symbols. Advertising, marketing and other sales-related documentation should be used to establish if this section is relevant.

Any and all provenance claims made by the Company/Entity/Facility must be disclosed on the BPP SMART System Group Profile Page. Each relevant Company/Entity/Facility shall maintain appropriate record keeping procedures, and verify that the criteria or requirements are met.

A manager should be responsible for ascertaining which employees require training on the Provenance Claim(s). These employees respond to product enquiries and should be aware of their accountabilities demonstrating a full understanding of the Provenance Claim(s) made. All documentation related to training shall be maintained, including but not limited to: written procedure, training materials and training register. Interested parties should have access to a complaints or grievance mechanism.

Conclusions

Business Responsibilities within the Best Practice Principles ensure that diamonds from CrownStone Diamonds, on their journey from discovery to consumer, have met the highest professional, ethical and technical standards. By adhering to ethical standards, demonstrating commitment, maintaining business integrity, ensuring financial probity, complying with the Kimberley Process and System of Warranties, protecting product security, practising full disclosure, managing the supply chain responsibly, and backing up provenance claims with verified evidence, CrownStone Diamonds upholds the highest standards of responsible business conduct across the diamond industry.