Responsible Jewellery Council (RJC) policy
Samuel Sylvio Designs is a member of the Responsible Jewellery Council (RJC).
The RJC is a standards-setting organisation established to advance responsible ethical, human rights, social
and environmental practices throughout the gold, silver, platinum group metals, diamond and coloured
gemstone jewellery supply chain.
The RJC has developed a benchmark standard for the jewellery supply chain and credible mechanisms for
verifying responsible business practices through third-party auditing.
As an RJC member we commit to operating our business in accordance with the RJC Code of Practices
Standard. We commit to integrating ethical, human rights, social and environmental considerations into our
day-to-day operations, business planning activities and decision-making processes.
Human and Labour Rights
We are committed to respecting all human rights in our own operations and business relationships in
accordance with the International Bill of Human Rights, Universal Declaration of Human Rights (UDHR), the
UN Guiding Principles on Business and Human Rights (UNGP) and all relevant conventions of the
International Labour Organization (ILO). Our human rights policy covers the following key commitments:
- All forms of violence and harassment in the workplace are prohibited, including but not limited to
corporal punishment; harsh or degrading treatment; sexual or physical harassment; mental, physical,
verbal or sexual abuse; retaliation; coercion; and intimidation. Both direct and indirect harassment in any
form is not acceptable in workplace facilities.
- To never engage in or knowingly support child labour (includin the worst forms of child labour) as defined
by International Labour Organisation (ILO) Conventions 138 and 182;
- To never engage in or knowingly support forced labour as defined by International Labour Organisation
(ILO) Convention 29, including bonded labour, deceptive recruitment, human trafficking and indentured
or involuntary prison labour;
- To provide a safe and healthy working environment for employees and on-site contractors;
- To prohibit all forms of discrimination, including but not limited to discrimination based on race, colour,
ethnicity, caste, national origin, religion, disability or genetic information, gender, sexual orientation,
union membership, political affiliation, marital status, parental or pregnancy status, physical appearance,
HIV status, age or any other personal characteristic unrelated to the inherent requirements of the work.
- To implement employment practices that promote diversity, inclusion and equal opportunities.
- To respect our employees' rights regarding freedom of association and collective bargaining.
- To promote human rights in our dealings with business partners and other relevant stakeholders.
- To take all reasonable steps to remedy negative human rights impacts identified in our organisation
and/or supply chain in accordance with the UNGP and OECD Due Diligence Guidance[1] frameworks.
Bribery and Corruption
We prohibit bribery and corruption in all business practices and transactions carried out by us and by agents
acting on our behalf. For the purpose of this policy, bribery is defined as giving, offering or receiving any
undue advantage to or from:
- A public or government official;
- A political candidate, party or official; or
- Any private sector employees, directors or officers, or their agents or representatives.
Anti-Money Laundering and Finance of Terrorism
We commit to not engaging in or contributing to money laundering or the finance of terrorism. Samuel Sylvio
Designs has implemented Anti-Money Laundering (AML) and Know Your Counterparty (KYC) procedures to:
- Establish the identity of all counterparties;
- Verify that counterparties and, if applicable, beneficial owners are not named on relevant government
lists for individuals or organisations implicated in money laundering, fraud or involvement with
prohibited organisations and/or those financing conflict;
- Maintain an understanding of the nature and legitimacy of the businesses operated by counterparties
and;
- Monitor transactions for unusual or suspicious activity.
Environmental Management
We commit to reducing and managing the environmental impacts of our business operations by
implementing an Environmental Management System (EMS). This includes:
- The responsible management of all wastes and emissions to air, water and land.
- Establishing energy and water efficiency measures.
- Seeking to ensure the responsible and efficient use of other natural resources, where applicable.
Product Disclosure
We will not knowingly make any untruthful, misleading or deceptive representation, or make any material
omission in the selling, advertising or marketing of jewellery products and materials. We further commit to
disclosing information on the physical characteristics of jewellery products and materials in accordance with
the Responsible Jewellery Council (RJC) Code of Practices Standard.
Conflict Diamonds
We will not knowingly buy or sell Conflict Diamonds
[2] and require that all of our suppliers of diamonds comply
with the requirements of the Kimberly Process Certification Scheme (KPCS) and World Diamond Council
System of Warranties (SoW).
Supply Chain Policy – Conflict-Affected and High-Risk Areas
- This policy confirms our commitment to respect human rights, avoid contributing to the finance of
conflict and comply with all relevant UN sanctions, resolutions and laws.
- As a member of the Responsible Jewellery Council (RJC), we commit to proving, through independent
third-party verification, that we:
- respect human rights according to the Universal Declaration of Human Rights and International
Labour Organization Declaration on Fundamental Principles and Rights at Work;
- do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
- support transparency of government payments and rights-compatible security forces in the
extractives industry;
- do not provide direct or indirect support to illegal armed groups;
- enable stakeholders to voice concerns about the jewellery supply chain; and
- are implementing the OECD five-step framework as a management process for risk-based due
diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.
- We also commit to using our influence to prevent abuses by others.
- Regarding serious abuses associated with the extraction, transport or trade of gold, silver, platinum group
metals, diamonds and coloured gemstones: We will neither tolerate nor profit from, contribute to, assist
or facilitate the commission of:
- torture, cruel, inhuman and degrading treatment;
- forced or compulsory labour;
- the worst forms of child labour;
- human rights violations and abuses; or
- war crimes, violations of international humanitarian law, crimes against humanity or genocide.
- We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are
committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing
these abuses.
- Regarding direct or indirect support to non-state armed groups: We will not tolerate direct or indirect
support to non-state armed groups, including, but not limited to, procuring gold, silver, platinum group
metals, diamonds and coloured gemstones from, making payments to, or otherwise helping or equipping
non-state armed groups or their affiliates who illegally:
- control mine sites, transportation routes, points where gold, silver, platinum group metals,
diamonds and coloured gemstones are traded and upstream actors in the supply chain; or
- tax or extort money, or minerals at mine sites, along transportation routes or at points where
gold, silver, platinum group metals, diamonds and coloured gemstones are traded, or from
intermediaries, export companies or international traders.
- We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are
sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups
as described in paragraph 6.
- Regarding public or private security forces: We affirm that the role of public or private security forces is
to provide security to workers, facilities, equipment and property in accordance with the rule of law,
including law that guarantees human rights. We will not provide direct or indirect support to public or
private security forces that commit abuses described in paragraph 4, or that act illegally as described in
paragraph 6.
- Regarding bribery and fraudulent misrepresentation of the origin of gold, silver, platinum group metals,
diamonds and coloured gemstones: We will not offer, promise, give or demand bribes, and will resist the
solicitation of bribes, to conceal or disguise the origin of gold, silver, platinum groups metals, diamonds
and coloured gemstones, or to misrepresent taxes, fees and royalties paid to governments for the
purposes of extraction, trade, handling, transport and export of gold, silver, platinum groups metals,
diamonds and coloured gemstones.
- Regarding money laundering: We will support and contribute to efforts to eliminate money laundering
where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling,
transport or export of gold, silver, platinum group metals, diamonds and coloured gemstones.
Grievance procedure
Samuel Sylvio Designs has established this procedure to hear any concerns or complaints from interested
parties and stakeholders regarding its supply chain and business practices.
Concerns can be raised by interested parties via email using the following contact information:
Name: Jurghis Gottlieb
Email: info@samuelsylvio.com
On receiving a complaint, we will aim to:
- contact you as soon as possible to gather more information regarding your grievance, where applicable;
- decide who is the appropriate person internally to handle the grievance, or help redirect you to another
entity, such as a relevant company, industry body or other organisation;
- identify any actions we should take (if any), or monitor the situation;
- advise you of any decisions or outcomes; and;
- keep records on grievances received and the internal process followed to address such grievances, for at
least five years.
Samuel Sylvio Designs expects all of its global employees, suppliers and sub-contractors to take steps to
ensure that this policy is adhered to, as applicable.
This policy is endorsed by:
Name: Jurghis Gottlieb
Position: Compliance Officer
Date: 4/8/2024
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As a member of the Responsible Jewellery Council (RJC), Samuel Sylvio Designs is committed to
implementing the RJC’s Code of Practices (COP) standard. As such, we have developed a range
of policies and procedures to ensure our ongoing compliance with its requirements.
We are also committed to developing and nurturing strong relationships with suppliers and
other business partners to promote responsible business practices throughout our supply chain.
This includes taking steps to identify and, where applicable, mitigate negative supply chain
impacts with a particular focus on addressing issues related to human rights, child labour and
forced labour.
To achieve this, we conduct due diligence on all of our suppliers in alignment with the UN
Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Due
Diligence Guidance 5-Step Framework). This includes:
- Adopting a Human Rights and Supply Chain Policy (See the Responsible Business
Practices Policy on our website);
- Developing internal control systems and processes for collecting and recording
information on the origin of jewellery materials in our supply chain and the labour
practices of our suppliers; and
- Implementing a system for responding to human rights and supply chain risks.
Through this process, we have encouraged an open exchange of information with our suppliers,
which is crucial for maintaining integrity and ethical standards in our operations and supply
chain.
While we recognise that there are still areas where information is incomplete, we have not
identified any specific human rights risks associated with our existing supplier relationships.
Our supply chain mapping has identified two countries of mining origin in our coloured
gemstone supply chain that meet the definition of a Conflict-Affected and High-Risk Area
(CAHRA) in accordance with the OECD Due Diligence Guidance, and we are now gathering
further information about these sources in alignment with Step 2 and Step 3 of the OECD 5-Step
Framework. Further steps will be taken, where necessary, to mitigate any risks associated with
these sources of supply.
Our commitment to sustainability is a continuous journey. We acknowledge the challenges and
remain dedicated to improving and evolving our practices to meet the expectations of our
customers and other stakeholders.
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