Supply Chain Policy

 

 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

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