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Policy and Procedure Supply Chain

Supply Chain

  • A network between a company and its suppliers to produce and distribute Gold, Diamonds, Jewelry to the buyer.

OECD

  • Organization for Economic Co-operation and Development.

CAHRA

  • Conflict Affected and High Risk Area. Areas where the risk of violation of Human Rights is

Legal Requirements

  • OECD Guidelines
  • Universal Declaration of Human Rights

Policy

  • NYJ Group LLC is a Diamond and Jewelry Trading Company. This policy confirms NYJ Group’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.
  • As such, we commit to proving, through independent third-party verification where required, that we:
    • Respect human rights according to the Universal Declaration of Human Rights and International Labor Organization Fundamental Rights at Work;
    • Do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
    • Support transparency of government payments;
    • Do not provide direct or indirect support to illegal armed groups; and
    • Enable stakeholders to voice concerns about the jewelry supply chain.
    • Are implementing the OECD 5-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. Our suppliers are not from CAHRA and we do not procure goods from CAHRA.
  • Regarding serious abuses associated with the extraction, transport or trade of diamonds
  • We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:
    • Torture, cruel, inhuman and degrading treatment;
    • Forced or compulsory labor;
    • The worst forms of child labor;
    • 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 4 or are sourcing from, or linked to, any party committing these abuses.
  • Regarding direct or indirect support to non-state armed groups; we only sell or purchase diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds 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 diamonds are traded and upstream actors in the supply chain; or
    • Tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds 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 diamonds. We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of diamonds/colored gemstones/Gold, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of diamonds.
  • 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 diamonds.

Records

  • Risk Assessment & Mitigation Plan
  • Vendor Code of Conduct & Supplier Commitments
  • Visit Reports
  • Human Rights Due Diligence

Map the Supply Chain

  • Identify the areas & Geographies where the suppliers are located.
  • Identify if these areas are CAHRA
  • Identify the major suppliers in different areas

Identify the Risks

  • Identify the risks related to each supplier
  • Each area where the supply comes from
  • The risks from the suppliers supply chain
  • Unresolved red flags

Assess the Risks

  • Assess the risks for each supplier by rating them
  • Identify the high risks in different areas
  • Identify any red flags in the supply chain
  • Use the RJC Risk Assessment Template for location based generic risk assessment

Establish a Mitigation Plan

  • Engage with the supplier to resolve the red flags
  • Identify & establish a Risk Mitigation plan
  • Implement the risk mitigation plan
  • Where the current controls are already effective, ensure that the controls remain effective.

Implement the Mitigation Plan

  • Implement the mitigation plan and verify the effectiveness.
  • Ensure that the risk is adequately controlled.

Review the Human Rights Risks

  • Annually review the Human Rights risks.
  • Review the risks when a new supplier comes on board. Review the risks in case of any concerns raised by third party on [email protected]