Hot Diamonds Group is a jewellery design and distribution company. This policy confirms Hot Diamonds Group’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.
We also commit to using our influence to prevent abuses by others and take all steps to comply with OECD guidelines.
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 every two years
• For ‘higher risk’ suppliers, this evidence will be requested every 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
For questions or to raise any grievance regarding this policy, please contact adryan.cresswell@hdgroup.com.
