RISK CATEGORISATION:
• Key suppliers are to be split into ‘lower risk’ and ‘higher risk’ categories
- RJC suppliers or those audited by RJC harmonized organisations are ‘lower risk’
- Non-RJC suppliers or those not audited by RJC harmonized organisations are ‘higher risk’
SUPPLY CHAIN DUE DILIGENCE:
• Suppliers will be asked to disclose their RJC or RJC harmonized organisation certificates where applicable
• In addition, suppliers are asked to demonstrate and provide written evidence that they source the gold, silver and diamonds that they use for manufacturing from sources which are compliant with the SRSP
- The company will review this documentation and file it accordingly so that it is available for auditors to access
• For ‘lower risk’ suppliers, this evidence will be requested annually in January of each year
• For ‘higher risk’ suppliers, this evidence will be requested every 6 months in January and July of each year
• The company will adopt a ‘KYC’ approach to its supply chain and will research the background of each key potential supplier before onboarding
TERMS OF BUSINESS:
• The company’s terms of business will always include that all suppliers must be compliant with meeting the minimum standards set out in the SRSP
- This requirement will be communicated to all existing suppliers and will form part of the onboarding process for all new suppliers
STAFF AWARENESS, DUE DILIGENCE AND ESCALATION:
• The company will communicate to its staff its supply chain policy and the SRSP supply chain requirements
• The company will encourage its staff to highlight any potential risk areas within its supply chain and to communicate these to the Head of Commerce
INVESTIGATING RISKS AND HANDLING NON-CONFORMANCE:
• Through due-diligence and the actions above, the company will identify any risks within its supply chain and act accordingly:
- Risks will be investigated by the Head of Commerce
- Non-conformity of a supplier will either result in:
o Corrective action being required by the company whilst trading continues;
0 A temporary suspension of trading whilst the risks are being worked on;
0 In serious cases a cessation of the business relationship.
ACCOUNTABILITY:
• The company’s compliance officer is the Head of Commerce
