Business Policies

RJC Compliance Policy

D’OR JOIERS, S.A. is a member of Responsible Jewellery Council (RJC) and committed for ethical business practices and compliance with Code of Practices in all its business activities.

The management of D’OR JOIERS, S.A. shall implement responsible ethical, social and environmental practices throughout the diamond supply chain, from mine to retail. We being a responsible entity of diamond supply chain believe in consumer confidence in our trade and request our business partners to follow same. 

As a part of best endeavors and responsible business entity, we anticipate co-operation of our business partners in adopting the standard and ensuring that the entire diamond supply chain is compliant with respect to business, social and environmental responsibilities. 

We strongly encourage all our business partners to follow and implement the various requirements of the RJC Code of Practice and other prevailing trade standards. 

More information about the Compliance Program is available on 

http://www.responsiblejewellery.com

 

Policy on Ethical Business Commitment with Integrity and Fairness

  1. Ensuring that all business activities are conducted in an honest, ethical, professional and accountable manner is fundamental to the core philosophy of our Company. 
  2. All entities of D’OR JOIERS, S.A. is committed to combating dishonesty and fraud in all business transactions in order to maintain and enhance consumer trust in, and the reputation of the diamond industry. 
  3. The entities of the D’OR JOIERS, S.A. shall strive to get similar commitment from their Associates.
  4. D’OR JOIERS, S.A. is committed to maintaining the highest standards of financial integrity for the benefit of all our stakeholders.
  5. All accounting records, and reports produced from those records, must be maintained and presented according to the laws of each applicable jurisdiction.
  6. Compliance with generally accepted accounting principles in the country where the entity is incorporated and the entity’s system of internal controls is required at all times. 
  7. It is the responsibility of D’OR JOIERS, S.A. to pursue its corporate value enhancement through sound business practices. Our business activities have direct and indirect impact on the societies in which we operate, and therefore sound business practice requires that business decisions give due consideration to the interests of its stakeholders including shareholders, customers, employees, suppliers, business partners, local communities.

All employees in all our entities must endeavor to conduct the business of D’OR JOIERS, S.A. accordingly. 

  1. In making business decisions, employees must act on an informed basis, in good faith, and in the honest belief that the action taken is in the best interest of the Company.
  2. D’OR JOIERS, S.A. has put in place programmes that monitor the effectiveness of these commitments and hence supporting all workers in this endeavor.
  3. All entities of D’OR JOIERS, S.A. shall operate in compliance with relevant national and international legislations / regulations as applicable in the countries in which they operate. 
  4. All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal entity rules and policies relating to their business activities. It also is the responsibility of personnel to know and understand legal, regulatory and internal requirements as they apply to their jobs 
  5. To maintain and enhance customer trust in, and the reputation of the diamond and jewellery industry, the Company is fully committed to ensuring that all the business processes and transactions are undertaken in a professional, ethical, environment friendly and socially accountable manner. 
  6. D’OR JOIERS S.A. has defined and adopted a Business Principles and Code of Conduct documents that sets forth the basic standards to be observed by all directors, officers and employees. 
  7. D’OR JOIERS, S.A. has defined and adopted policies with respect to “Legislation and Regulations” and “Conducting Business Ethically, with Integrity, and in Fairness.

Policy on Bribery, Anti-Corruption, Facilitation Payments and Gifts

  1. D’OR JOIERS, S.A. and its entities are committed to prohibit bribery and facilitation payment 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, expense 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; to influence the course of the business or governmental decision–making process.
  2. D’OR JOIERS, S.A. and its entities consider Bribery and facilitation payment Risk as it applies to its organization (including agents) to identify which areas pose high risks. D’OR JOIERS, S.A. has developed appropriate methods to monitor conduct of employees and agents and eliminate bribery based on this understanding. 
  3. The management facilitates the reporting of incidences of attempted bribery and facilitation payment or inappropriate gifts within their organization and shall apply appropriate sanctions for bribery and attempted bribery in all forms.
  4. No employee will suffer demotion, penalty or other adverse consequences for voicing a concern, or for refusing to pay a bribe or facilitation payment even if this action may result in the enterprise losing business.
  5. Appropriate controls to monitor, oversee and fully account for all facilitation payments, with ultimate objective for elimination shall be ensured by entities where full elimination has not been achieved.

 

Policy on Financial Offences

  1. D’OR JOIERS, S.A. recognizes the fact that entities in the gems and jewelry sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
  2. Strict compliance is required at all times, with all applicable national and, where appropriate, international laws / regulations with respect to money laundering, terrorism financing, bribery, facilitation payment, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion in all relevant jurisdictions 
  3. All entities of D’OR JOIERS S.A. shall act in accordance with national laws with respect to auditing of its financial accounts.
  4. It is the responsibility of concerned personnel to know and understand the relevant money laundering / financial offences related legal, regulatory and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious activity that appears to be questionable may also be considered as a violation of the Business Principles, depending on the seriousness of the non-conformance.

Policy on Kimberley Process and System of Warranties

  1. D’OR JOIERS, S.A. is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and World Diamond Council’s (WDC) System of Warranties Declaration.
  2. The definition of “Conflict Gem Stone Diamonds” as agreed by the Kimberley Process will be adopted i.e. “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 in so far as they remain in effect, or in other similar UNSC resolutions which may be adopted in the future, and as understood and recognized in United Nations General Assembly (UNGA) Resolution 55/56, or in other similar UNGA resolutions which may be adopted in the future.” 
  3. Wherever applicable, the following affirmative statement as recommended by the World Diamond Council’s System of Warranties should be printed on all the invoices: ”The diamonds herein invoiced have been 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.”
  4. Entering into transactions involving “conflict diamonds” or not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, will be considered as a violation of the Business Principles. The Company shall always adherer to ethical sourcing and ensure compliance with Conflict Affected and High risk Areas-CAHRA’s as well as OECD requirement. D’OR JOIERS, S.A. shall prepare policy and procedure for ethical sourcing, due diligence and risk assessment of suppliers. 

It is the responsibility of concerned personnel to know and understand the relevant regulations and procedures relating to “conflict diamonds” as they apply to their jobs..

Policy on Product Security

  1. The D’OR JOIERS S.A. and its entities are committed to establish and implement product security measures within the premises and during shipments to protect against product theft, damage or substitution.
  2. The security and well being of employees, visitors and other relevant business partners is prioritized when establishing product security measures.
  3. All diamond sold by entities to consumers shall comply to applicable regulations of product health and safety.

 

Policy on Disclosure

  1. The following essential principles will be applicable in all the entity’s transactions involving gold, diamond, treated diamonds, synthetics and simulant or other stone

▪ Full disclosure i.e the complete and total release of all available information about Gold, a Diamond or other stone and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the item being sold. 

▪ No misuse of terminology or mis-representations or attempts to disguise the product will be made in the selling, advertising and distribution of gold, diamond, treated diamonds, synthetics and simulant or other stone.

▪ D’OR JOIERS, S.A. shall do the risk assessment and identify the contamination point of their pipeline. To address the identified contamination points, D’OR JOIERS, S.A. shall create a unique policy, procedure and training programme for each risk. Full disclosure at all times – including verbal disclosure prior to and during sale, and written disclosure in each bill of sale, receipt, laboratory certificate or other documentation relating to the sale in the relevant local language. Any term used to conceal the fact that a diamond is synthetic or misinforms the consumer must not be used.

The word “diamond” will not be used in the case of names of firms, manufacturers or trademarks; in connection with treated diamonds or diamond simulant or synthetic diamonds.

  1. D’OR JOIERS, S.A. has adopted the following definitions: 

DIAMOND – The World Jewellery Confederation (CIBJO) and the Federal Trade Commission (FTC) define a diamond as ‘a natural mineral consisting essentially of pure carbon crystallized with a cubic structure in the isometric system’. A natural mineral is one formed completely by nature without human intervention. 

SYNTHETIC DIAMOND – A product that has been either partially or wholly crystalized or re-crystallized due to artificial human intervention. This is produced either by high pressure and temperature (HPHT) or by chemical vapor deposition (CVD). Synthetics require cutting and polishing. The appearance of a pre-polished synthetic differs from that of a natural diamond. Simulant – A non-diamond material that is used to emulate the appearance of a diamond. 

Wherever applicable, the following affirmative statement as recommended by the World Federation of Diamond Bourse’s should be printed on all the invoices.

“The diamonds herein invoiced are exclusively of natural origin and untreated based on personal knowledge and/or written guarantees provided by the supplier of these diamonds. The acceptance of goods herein will be as per the WFDB guidelines”

Treated Diamond – a diamond that has been altered by any unnatural process by means of human intervention such as fracture, filing or irradiation.

Treatment – any process changing, interfering with and/or contaminating the natural appearance or composition of a diamond other than the accepted practices of cutting and polishing. This includes colour (and decolourization) treatment, fracture filling and laser and irradiation treatment and coating. HPHT- Unprocessed CVD – Laser sawn unpolished.

Policy on Provenance Claims

The policies relating to this section are part of the Business Principles adopted by D’OR JOIERS S.A. and are presented below for reference:

“D’OR JOIERS S.A. shall ensure all its Provenance Claims made will be fully valid along with available evidence to support the Claim(s”

Origin – Geographical origin of material, for example country, region, mine or corporate ownership of the Mining Facility/ies; and/or 

Source – Type of source, for example recycled, mined, artisanally mined, or date of production; and/or

Practices – Specific practices applied in the supply chain relevant to the Code of Practices, including but not limited to, standards applicable to extraction, processing or manufacturing, conflict-free status, or due diligence towards sources.

Provenance Claims may also relate to origin, sources or practices that are specifically excluded from the supply chain, such as through a ‘negative warranty’. 

D’OR JOIERS S.A. shall ensure that all claims and statements (made to consumers or other businesses) on practices in the supply chain and the origin or source of Diamonds, Colored Gemstones, Gold and / or Platinum through the use of both descriptions and symbols are valid.

D’OR JOIERS S.A. shall ensure that there will be no attempt to mislead consumers through illustrations, descriptions, expressions, words, figures, depictions or symbols relating to the Provenance Claim(s).

D’OR JOIERS S.A. shall ensure that all the relevant employees are aware about the provenance claim and it procedures.

Policy on Melee Assurance Protocol

The policies relating to this section are part of the Business Principles adopted by D’OR JOIERS, S.A. and are presented below for reference:

D’OR JOIERS, S.A. shall ensure compliance in the company/entity/facility that purchase, trades and manufactures rough/polished diamonds that are 0.01Carats and below.

D’OR JOIERS, S.A. ensures pipeline risk assessment and develops procedure for each contamination points for the entity/facility that that purchase, trades and manufactures rough/polished diamonds that are 0.01Carats and below.

D’OR JOIERS, S.A. will conduct regular internal audit and review of policy and procedure to address evolving risk and to ensure compliance for the melee assurance protocol.

D’OR JOIERS, S.A. shall ensure that all contractors that purchase, trades and manufactures rough/polished diamonds that are 0.01 Carats and below will be participating in melee assurance protocol and they will be mapped as a substantial contractor on BPP extranet. 

Further the principle Company shall ensure annual internal audit with respect to compliance of melee assurance protocol. 

D’OR JOIERS, S.A. shall ensure that contractor shall return the manufactured diamonds in temper proof material.

D’OR JOIERS, S.A. shall ensure that all the relevant employees are aware about the melee assurance protocol and it procedures.

D’OR JOIERS, S.A. shall ensure that its contractor provide the guarantee that the polished diamonds return by the contractor is belongs to same rough provided by D’OR JOIERS, S.A. and his customers.

Policy on Supply Chain Management / Best Endeavours

The management of D’OR JOIERS, S.A. is committed to taking appropriate action including risk assessment and best endeavours to ensure the compliance of Tier B entities to comply with the Best Practice Principles.

D’OR JOIERS, S.A. shall always source it material from legitimate sources and ensure compliance with OECD guideline on Conflic Affected and High Risk Areas – CAHRA’s.

Policy on Employment

  1. Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.
  2. D’OR JOIERS shall not require workers to work for more than the national limit of hours in a week on a regular basis, with overtime hours not to exceed the national permitted limit per week on a regular basis unless there are legal opt-outs. 
  3. The Company shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of workers and provide some discretionary income.
  4. Wages shall be paid to employees on a regular and predetermined basis in na manner and location convenient to employees, accompanied by a wage slip detailing wage rates, benefits and deductions as applicable.
  5. It is the responsibility of concerned personnel to know and understand the relevant employment and labour related legal, regulatory and internal requirements as they apply to their jobs. 
  6. When required, due recognition will be given to the existence, membership and lawful activities of worker representative bodies, and worker representatives will be given access to carry out their responsibilities / functions.
  7. The procedures detailed in the internal proceduures and legislation should be followed for dismissal of employees, in case the need for the same arises, and arbitrary dismissal procedures should be avoided.
  8. Information regarding applicable employment policies and working practices should be communicated in a transparent manner to all employees.

 

Policy Statement of Freedom of association and Collective Bargaining, Discrimination and Discipline and Grievance Procedures

The policies relating to this section are part of the Business Policies adopted by D’OR JOIERS, S.A. and are presented below for reference:

  1. D’OR JOIERS, S.A. will not prevent employees from associating and collective bargaining 
  2. Discrimination can mean distinction, exclusion or preference. 
  3. Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, ethnicity, caste, national origin, religion, age, disability, gender, marital status, physical appearance, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by D’OR JOIERS S.A. and any such reported incidents will be viewed as a serious violation of this Business Policies.
  4. D’OR JOIERS, S.A. will ensure that employees who have certain life threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.
  5. Individuals who are “Fit for Work” shall be accorded equal opportunities and shall not be discriminated against on the basis of factors unrelated to their ability to perform their job.
  6. D’OR JOIERS, S.A. shall not use corporal punishment under any circumstances and will ensure that employees are not subjected to harsh or degrading treatment, sexual or physical harassment or other forms of mental or physical coercion, abuse or intimidation.
  7. D’OR JOIERS, S.A. encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, entity operation or practice is or will likely be in violation of any law, regulation or internal entity rule or policy, including this Business 

D’OR JOIERS, S.A. assures all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully. While all efforts will be taken to protect the anonymity of employees as far as practicable, any form of retaliation against any such individuals, assuming they have not been involved in the violation, will not be tolerated.

Policy on Non Discrimination, Disciplinary Practices

  1. Discrimination can mean distinction, exclusion or preference. 
  2. Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by D’OR JOIERS, S.A. and any such reported incidents will be viewed as a serious violation of this Business Principles.
  3. D’OR JOIERS, S.A. will ensure that employees who have certain life threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities. 
  4. D’OR JOIERS, S.A. shall at no time condone the use of corporal punishment or other forms of mental or physical coercion. 
  5. D’OR JOIERS, S.A. encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, entity operation or practice is or will likely be in violation of any law, regulation or internal entity rule or policy, including this Business Principles. 

D’OR JOIERS, S.A. assures all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully. While all efforts will be taken to protect the anonymity of employees as far as practicable, any form of retaliation against any such individuals, assuming they have not been involved in the violation, will not be tolerated.

Policy on Child Labour

  1. No form of child labour should be employed at any of the facilities of D’OR JOIERS, S.A.
  2. Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138). 
  3. For authorized adolescents (persons below 18 years of age but above 16 years), the entity management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
  4. If a child is found working at any facility of D’OR JOIERS, S.A., either own or subcontracted, the responsibility of rehabilitation will be undertaken by the management of the concerned entity. 
  5. The above policies will also be applicable to subcontracted labour or operations and the local management should ensure strict adherence to the above police.

Policy on Forced Labour

 

  1. The management of D’OR JOIERS, S.A. is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of this Business Principles.
  2. The following definitions will be applicable: 

▪ The Universal Declaration of Human Rights that states that “No one shall be held in slavery or servitude”.

▪ ILO Convention 29, which defines forced or compulsory labour as “all work or service which is extracted from any person under the menace of any penalty, and for which the said person has not offered himself voluntarily”.

Policy on Human Rights

  1. All employees in D’OR JOIERS, S.A. facilities will be treated with equality, respect and dignity.
  2. D’OR JOIERS, S.A. believes in and respects the fundamental human rights according to the United Nations Universal Declaration of Human Rights.
  3. D’OR JOIERS, S.A. will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation.
  4. D’OR JOIERS, S.A. strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.
  5. Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by D’OR JOIERS, S.A.
  6. Security personnel, if employed by D’OR JOIERS, S.A. and its entities, are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat.

 

Policy on Community Development and Engagement

 

D’OR JOIERS, S.A. is committed to the development of communities where it operates, contributing to their social and economic welfare.

 

Policy – Supply Chain

This policy is made applicable to all the activity of D’OR JOIERS, S.A. and effective from April 2022. It covers Diamond/Gold/Silver/Platinum Group metals and Coloured Gemstone. 

This Policy shows D’OR JOIERS, S.A. commitment and its expectations for its product suppliers regarding actions to address Conflict Minerals and metals.

D’OR JOIERS, S.A. expects it’s suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict free minerals and metals.

We being a responsible business entity, D’OR JOIERS, S.A. supports the goal of the Dodd-Frank Act of preventing armed groups in the conflict affected countries from benefitting from the sourcing of Conflict Minerals and metals from that region.

D’OR JOIERS, S.A. is committed to working with its suppliers to educate them on these matters and concerning steps they can take to obtain increased transparency regarding the origin of minerals and metals contained in the products they manufacture and sell to D’OR JOIERS, S.A.

D’OR JOIERS, S.A. reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy. 

D’OR JOIERS, S.A. reserves the right to request additional documentation from its suppliers regarding the origin of any Conflict Minerals and metals included in any products sold to D’OR JOIERS, S.A.

Suppliers who do not reasonably comply with this Policy shall be reviewed by D’OR JOIERS, S.A. for future business.

Policy – Sourcing

 

D’OR JOIERS, S.A. is committed to ensuring that our supply chain is free of any metal and minerals including Diamond/Gold/Silver/PGM/Coloured Gemstone which was procured for the support or benefit of armed and anti social conflict groups or involving serious abuses of human rights and non compliant with OECD Guidelines.

D’OR JOIERS, S.A. clearly criticizes such activity and will reject any material which we believe was obtained involving serious human rights violations or which benefitted or supported armed rebels or terrorist groups through illegal finance or other activities.  

D’OR JOIERS, S.A. shall carry out risk assessment for its supply chain and shall not enter into any business relationship or if may require then shall suspend/discontinue the engagement with any such supplier involved in dealing with Conflict-Affected and High-Risk areas, Any form of Human Right Violation; Torture, Cruel, In-Human and Degrading Treatment; Forced/Compulsory Labour;  Child Labour; Abuses such as widespread Sexual Violence; War Crimes; other serious violations of International Humanitarian Law, Crime against Humanity; Genocide and/or To Bribe or To be Bribed. We strictly condemn and prohibit any Direct/Indirect support to public/private security forces which illegally Control, Tax or Extort money from Mining Sites, Transportation Routes and Upstream Sectors.

D’OR JOIERS, S.A. shall carry out due diligence to assess risks related to procurement from the Conflict-affected and high-risk areas – CAHRAs and shall always source from compliant miners/refiners/traders.

We shall always set reasonable efforts to source Conflict Minerals from smelters and refiners validated as being Conflict Free, and require their direct and indirect suppliers to do the same.

We strive to work supportively with our customers and supply chain partners in implementing conflict minerals compliance programs.

Policy – Due Diligence and Risk Assessment

The Company shall always undertake to ensure that the extraction and trade of Diamonds support peace and development and not conflict.

D’OR JOIERS, S.A. remains committed to enhance its Supply Chain Due Diligence and risk assessment  program through internal review and external assessments. We have zero tolerance policy for the supplier violating OECD due diligence guideline and we shall immediately stop commercial relationship if any of our business associates found non-compliant or High-Risk during our internal/external risk assessment. 

Currently DO’R JOIERS, S.A. procure it’s precious metals from suppliers involved in ethical business practice. However, we have established a strong due diligence process and we shall review it as an when we observed significant risk or upon receipt of any grievance or complaint but in normal course, we shall carry our due diligence process on annual basis.

Grievance Mechanisms

Our employees, vendors and other parties can report concerns and suspected violations supply chain/sourcing/due diligence/ethical business policy/financial offense of the following way: https://dorjoiers.com/contact/ Reports can be made anonymously and will be kept completely confidential to the extent as possible and permitted by law. The compliance team will take the necessary actions within 20 business days after receipt of the Claim. We will not take any action retaliation against our employees, vendors or other parties who make a report in good faith. Our suppliers are encouraged to contact https://dorjoiers.com/contact/ if they wish to seek guidance on the application of this Policy.