ESTABLISH AND IMPLEMENT A RESPONSIBLE SOURCING POLICY

A Responsible Sourcing policy is a written statement that clearly articulates a jewellery and/or gemstone business’s commitment to sourcing responsibly, in line with recognized principles and standards, especially when sourcing from conflict-affected  and high-risk areas (CAHRAs), meaning, from areas characterised by the presence of armed conflict, widespread violence, or other risks of harm to people. The policy helps ensure that all relevant stakeholders are aware of the business’s commitment, which will be reflected in the business’s procedures and sourcing decisions.

CIBJO recommends that the policy that meets international expectations and is consistent with the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas of the Organisation for Economic Co-operation and Development (OECD).

A dedicated “compliance officer” should be appointed, to be responsible for establishing and implementing a company’s Responsible Sourcing policy, as well as for due diligence in the company and for reporting (if applicable).

In many cases, especially for small and medium-scale companies, this “compliance officer” may be the owner of the company.

The “compliance officer” should also be responsible for reviewing relevant policies and procedures every year to ensure a company continues to uphold current changes to relevant laws and regulations.

A  Responsible Sourcing policy document relevant to the scope of the business should be created. It should cover the precious metals and gem materials applicable to the business, and the complexity of the business’ supply chains.

This policy should be appropriate for the business, and need not be complicated or detailed. It should be very clearly understood by suppliers and stakeholders, and implementation of the policy should be verifiable through transaction documentation.

A company should be able and ready to supply to interested parties its Responsible Sourcing policy document, describing to them the principles that have been applied and the procedures that have been put in place. The company should have documented terms of business with suppliers and policies and procedures in place which include the company’s Responsible Sourcing policy.

The compliance officer should establish and communicate to suppliers and external stakeholders the company’s policy for responsible practices through the supply chain, especially as it relates to precious metals (gold, silver and platinum group metals) and gem materials (diamonds, coloured gemstones and pearls).

Members of the jewellery and gemstone industries should be able to demonstrate through transaction documentation that these terms of business and policies have been implemented throughout their business, through documentation such as invoices, warranty statements, delivery notes, product certificates, etc.

Suppliers should acknowledge receipt and commit to meeting the expectations set out in the policy. To do this, the company should consider requesting its suppliers to attest in writing that they will comply to the requirements set out in the policy. It is important to make the requirements part of its supplier contractual obligations.