Royal Chain Ethical Sourcing
OECD policy Updated March 2024
- Royal Chain is a jewelry wholesale company. This policy confirms Royal Chain’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.
- Royal Chain is a certified member of the Responsible Jewellery Council (RJC). As such, 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 Fundamental 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; and
- enable stakeholders to voice concerns about the jewellery 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.
- We will send out yearly due diligence request for information forms from our vendor partners (an example is further below in this document )
- We commit to working with uncompliant vendor partners who are committed to changing their business practices to adhere to our compliance standards in a reasonable and timely manner. If non compliant vendors are unwilling or unable to meet our standards we will discontinue further business with them.
- Any concerns any person has with Royal Chain or any of our business partners can address them anonymously in that link on our website.
- We will send out yearly due diligence request for information forms from our vendor partners (an example is further below in this document )
- Regarding serious abuses associated with the extraction, transport or trade of diamonds/colored 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 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/colored gemstones 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/colored 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 diamonds/colored gemstones are traded and upstream actors in the supply chain; or
- tax or extort money or diamonds/colored gemstones at mine sites, along transportation routes or at points where diamonds/colored 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 diamonds/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 diamonds/coloured gemstones, 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/colored gemstones.
Employment
Compliance is ensured at all times, with applicable national and, where appropriate, international laws/ regulations with respect to employment and labor. The company shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of workers and provide some discretionary income.
We require all of our business partners to adhere to requirements in the spirit of the above.
Health and Safety
Royal Chain Inc., recognizes the need to develop sustainable, value creating business and is committed to the following:
Any adverse impact of our business processes on those who carry it out shall be identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks. This review will use appropriate standards as required by prevailing laws, expert opinion and our knowledge of best practices. The review will lead to formulation of clearly described work practices and drills. All our staff will be trained in the manner required to adhere to these work practices and drills. The health of our staff, exposed to certain hazardous processes, will be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements. Workers shall not be under the influence of or abusing, drugs, alcohol and/ or other illegal substances. All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will applicable.
We require all of our business partners to adhere to requirements in the spirit of the above.
Human Rights
All employees in the Company’s facilities will be treated with equality, respect and dignity. Royal Chain will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation. The company strongly discourages any form of sexually coercive, threatening, abusive, or exploitative behavior. Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company. Annual sexual harassment trainings will be given to all employees.
We require all of our business partners to adhere to requirements in the spirit of the above.
Non-Discrimination, Disciplinary Practices
Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, gender, religion, age, disability, gender, marital status, sexual orientation, HIV status, migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by the company and any such reported incidents will be viewed as a serious violation of this Business Principles. Royal Chain shall assure all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully.
We require all of our business partners to adhere to requirements in the spirit of the above.
Child Labor
No form of child labor should be employed at Royal Chain. Company will implement suitable policy and procedures to verify the age proof of all new employees joining the organization.
We require all of our business partners to adhere to requirements in the spirit of the above.
Forced Labor
The management of Royal Chain is fully committed to ensuring that forced or involuntary labor is not practiced in any form at any of its facilities or facilities it does business with. Any reported incidents relating to forced labor will be considered as a serious violation of this policy.
The following definitions will be applicable to the above
- The Universal Declaration of Human Rights that states “No one shall be held in slavery or servitude”
- ILO Convention 29, which defines forced or compulsory labor as all work or service which is extracted from any person under the menace of any penalty, and for which the said person has not offered himself voluntarily.
We require all of our business partners to adhere to requirements in the spirit of the above.
Forced and inhuman Labor
Royal Chain takes a hard stance against any type of forced and in-human labor. We are fully committed that our company participated in it nor does any company that we are involved with. Below are examples of behavior that falls into the category of Forced and inhuman labor. This is not an exhaustive list.
- Any forms of torture
- Cruel, inhuman or degrading treatment
- Other gross human rights violations and abuses, such as widespread sexual violence and war crimes
We require all of our business partners to adhere to requirements in the spirit of the above.
Environmental Protection
Royal Chain is committed to effective environmental management as one of its important corporate priorities, and will focus on the following initiatives.
- Compliance with all applicable environmental laws and regulations.
- The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards and reviewed periodically to mitigate or eliminate such impact.
We require all of our vendor Partners to adhere to requirements in the spirit of the above.
Product Security
Royal Chain is committed to provide safety of product throughout its supply chain by following precautions as mentioned below:
- There is blanket insurance on our facility.
- Suitable safe guarding and storage is ensured at all stages with the help of safes and security personnel.
- All concerned persons are trained on relevant safety and security procedures to be followed at all Time.
We require all of our vendor Partners to adhere to requirements in the spirit of the above.
Metal Sourcing Policy
Royal Chain is concerned about the environment and social impacts of irresponsible mining. We at Royal Chain ensure to the best of our ability that all our suppliers comply with sourcing guidelines. Further we here by certify that all specified metals (Gold and Silver) that we used are sourced only from refineries, banks or metal trading companies that meet one or more of the following criteria
- On the LMBA gold/ Silver delivery list
- Responsible Business Alliance (RBA), with a specific division for metals supply chains called the Responsible Minerals Initiative (RMI). Through their RMAP audits of smelters and refiners, they have compiled a list of RMAP-Conformant smelters and refiners which is free online
- Certified members of the RJC
- Certify and independently audit that all gold/ Silver supplies are; in accordance with the RJC Chain of Custody Standard for precious metals, OECD due diligence guidance for responsible supply chains of minerals from conflict-affected and high-risk areas, or world gold council conflict free standard.
- That none of the metal in our product is being sourced from Conflict Affected and High-Risk Areas
- Scrap or recycled gold/ silver which is certified by an independent audit that all scrap and recycled gold/ silver is identifiable as its own production and supply, i.e., scrap gold/silver is returned product from customers, faulty inventory or scrap generated during the production process.
We require all of our vendor Partners to adhere to the above requirements.
Money Laundering, Terrorism Financing, Other Financial Offences/ AML-CFT
Royal Chain recognizes that the fact that entities in the gem and jewelry sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals. Strict compliance is ensured at all times, with all applicable national and, where appropriate, international laws/ regulations with respect to money laundering, terrorism financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing, and tax evasion. Royal Chain shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations. KYC is enforced.
We require all of our vendor Partners to adhere to the above requirements.
Diamond Sourcing-Kimberley Process and System of Warranties
Royal Chain is fully committed to complying with all the requirements specified in the Kimberly process certification scheme and world Diamond Council’s System of Warranties Declaration. The definition of “Conflict Gem Stone Diamonds” as agreed by the Kimberly Process has been adopted and declarations are received from suppliers and issued to all Customers.
We require all of our vendor Partners to adhere to the above requirements.
Gemstone Sourcing Policy
Royal Chain is concerned about the environment and social impacts of irresponsible gemstone mining. We at Royal Chain ensure to the best of our ability that all our suppliers comply with responsible sourcing guidelines. We ask our suppliers to confirm that no gemstone is being supplied from Conflict Affected and High-Risk Areas
We require all of our vendor Partners to adhere to the above requirements.
Anti-Bribery and Facilitation Payment Policy
The group shall ensure complete Prohibition of Bribery Facilitation payment across organization and in all entities. Company will not offer, accept or countenance any payment, gift, in kind, hospitality, and expense or promises as such that may compromise promises of fair competition. Periodic training and awareness shall be carried out to educate employees about various types of bribery and facilitation payments.
We require all of our vendor Partners to adhere to requirements in the spirit of the above.
Disclosure of Treated Diamonds, Synthetics and simulant
The following essential principles will be applicable in the transactions involving treated diamonds, synthetics, and stimulants. Full disclosure i.e., the complete and total release of all available information about a Diamond and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the diamond. No misuse of terminology or mis-representations or attempts of treated diamonds, synthetics and simulant. The world “diamond” will not be used in the case of names of firms, manufacturers or trademarks; in connection with treated diamonds or diamond simulant or synthetic diamonds.
We require all of our vendor Partners to adhere to the above requirements.
Synthetic Diamonds
Royal Chain is committed to fight against undisclosed synthetic diamonds. Following methodology has to be adopted for ensuring compliance to undisclosed synthetic diamonds:
- Access to effective detection system
- Buying from trusted suppliers
- Reporting of un-disclosure synthetics to supplier and interested parties whenever detected.
- Record the incidents of contamination and implement suitable corrective and preventive measures for effective controls.
- Classify contamination of points into different categories (High, Medium, Low)
We require all of our vendor Partners to adhere to the above requirements.
Information Regarding the above policies has been communicated in a transparent manner to all our Employees, is available to the Public on our company website. Any feedback can be made anonymously on the feedback button on our website.
Royal Chain OECD Due Diligence
Below is a copy of the latest KYC letter sent to our active (2023-2024 YTD) Vendor base
Our KYC supplier information form is combined with our Supply Chain Due Diligence, Human Rights Policy, Precious Metal And Gemstone and Diamond ethical sourcing policy.
What is OECD Due Diligence Guidance
OCED due diligence guidance is a five step framework in which a company seeks information about the origin of the materials they are purchasing to ensure that there were no human rights abuses and to determine whether the materials originated from a conflict affected or high risk areas.
Statement on Royal Chain Human Rights Policies
We, at Royal Chain, recognize our responsibility to respect human rights. We believe that
our business has a role to play in protecting and promoting human rights.
Royal Chain is committed to respect internationally recognized human rights throughout
our operations and supply chains. In line with the UN Guiding Principles on Business and Human Rights, our Policy is based upon the international standards enshrined in the Universal Declaration of Human Rights and the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.
Human rights refer to a set of basic rights and freedoms that belong to every person in the world, regardless of where they are from, what they believe or how they choose to live their life. It is a broad concept, with economic, social, cultural, political and civil dimensions. For Royal Chain, respecting human rights means ensuring that any person involved in, or coming into contact with, our operations, supply chains and products is treated with dignity, respect, fairness and equality.
Our Policy sets out overarching principles for how we conduct business at Royal Chain.
Together with our employees and business partners, we are committed to drive forward the
implementation of this Policy throughout our operations and supply chains. We recognize that
unique challenges to these standards may arise and we will work to address these challenges in partnership with relevant partners and stakeholders.
- Employment is freely chosen.
- Freedom of association.
- Working conditions are safe and hygienic.
- Child labor shall not be used.
- Living wages are paid.
- Working hours are not excessive.
- No discrimination is practiced.
- Regular employment is provided.
- No harsh or inhumane treatment is allowed.
Child Labor
Child labor is not used. There is no recruitment of child labor. The Employer shall develop
or participate in policies and programs which provide for the transition of any child involved
in child labor into quality education until no longer a child. No one under eighteen years old is 40 RJC - COP 6 Human Rights Implementation Toolkit employed at night or in hazardous work or conditions. In this Code, “child” means anyone under fifteen years of age, unless national or local law stipulates a higher mandatory school leaving or minimum working age, in which case the higher age shall apply; “child labor” means any work by a child or young person, unless it is considered acceptable under the ILO Minimum Age Convention 1973 (C138). ILO Minimum Age Convention 1973 (C138).
Royal Chain will continuously work to embed this Policy throughout the relevant processes and procedures of the company to ensure its effective implementation.
We recognize that we must take steps to identify and address any actual or potential adverse Impacts, whether they are directly or indirectly linked to our business activities or relationships.
We understand that human rights due diligence is a dynamic, on-going process which requires acting on the findings, tracking our actions, and communicating to our stakeholders how we address impacts. As our human rights risks and impacts may vary over time, this policy will be subject to review if proven inadequate by our human rights due diligence process.
Statement on Royal Chain AML and KYC Policies
This policy confirms Royal Chain’s commitment to prevent money-laundering and the financing of terrorism in its business practices and transactions. Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. The financing of terrorism is any kind of financial support to those who attempt to encourage, plan or engage in terrorism.
Royal Chain has established Know Your Counterparty* (KYC) and Anti-Money Laundering (AML) procedures to combat money laundering and the financing of terrorism. These procedures allow us to identify every organisation that we deal with, to understand the legitimacy of our business relationships and to identify and react to unusual or suspicious activity.
Royal Chain is responsible for development and implementation of this policy and relevant procedures, and Royal Chain commits to review our KYC policy and procedure every year.
To support our KYC policy and procedures, Royal Chain has developed a KYC form which we send to all our counterparties* (this is our business partners: suppliers and customers) to collect relevant business information to identify risks of money-laundering. We require the form to be completed for all existing and new counterparties.
By collecting and reviewing the information contained in completed KYC forms, Royal Chain commits to:
- Establishing the identity of our counterparties
- Checking that our counterparties are not considered high-risk (this means checking whether counterparties are based in FATF high-risk jurisdictions, named on government sponsored watch lists or international (UN) sanctions lists, or if they source from conflict-affected and high-risk areas (CAHRAs))
- Maintaining an understanding of the nature and legitimacy of all our counterparties’ businesses
- Maintaining KYC records for at least five years
- Maintaining records of all single or linked cash (or cash-like) transactions above 10,000EUR
- Monitoring transactions for unusual or suspicious activity – this type of activity will cause the counterparty to be considered high-risk.
If counterparties are considered high-risk for any reason (for example, named on a sanctions list or engaging in unusual activity) we may:
- Cease trading with the counterparty.
- Identify the beneficial owners of the counterparty and check whether the beneficial owners are on any watch lists or sanctions list.
- Make an on-site visit to the high-risk counterparty.
Statement on Royal Diamond and Colored Gemstone Policies
Our Commitment to Sourcing Minerals Responsibly
Royal Chain is committed to ensure that DIAMOND / COLOURED GEMSTONES are sourced with due respect for human rights, the need to avoid contributing to conflict, and the desire to support development through our supply chain practices.
At the same time, Royal Chain does not ban the use of DIAMOND / COLOURED GEMSTONES that originate in conflict-affected and high-risk areas when they are sourced in accordance with existing international standards. Avoiding the sourcing of all DIAMOND / COLOURED GEMSTONES from these areas would cause a de facto embargo with serious adverse impact on the living conditions of local populations.
Please find here a link to Royal Chain’s supply chain policy, which we expect our suppliers to follow. www.oecd.org/fr/daf/inv/mne/mining.htm.
We are conducting due diligence as per the requirements of the Responsible Jewellery Council’s provision 7 (COP 7). This provision is based upon OECD Due Diligence Guidance which is an internationally recognised framework.
What is OECD Due Diligence Guidance?
OCED due diligence guidance is a five step framework in which a company seeks information about the origin of the materials they are purchasing to ensure that there were no human rights abuses and to determine whether the materials originated from a conflict affected or high risk area.
Statement on Royal Chain Precious Metal Policy
Our Commitment to Sourcing Minerals Responsibly
- Royal Chain is a certified member of the Responsible Jewellery Council (RJC). As such, 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 (and Supplement on Gold if applicable) 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 We will not engage in any business with a supplier that does not comply with our policy.
- Regarding serious abuses associated with the extraction, transport or trade of gold:
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.
4. 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.
5. 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 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 is traded and upstream actors in the supply chain; or
- tax or extort money, or gold at mine sites, along transportation routes or at points where gold is traded, or from intermediaries, export companies or international traders.
6. 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
7.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.
8. Regarding bribery and fraudulent misrepresentation of the origin of gold:
We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold.
9. 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.
- Precious Metal Policies Royal Chain is a certified member of the Responsible Jewellery Council (RJC). As such, 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 (and Supplement on Gold if applicable) for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.
- Regarding serious abuses associated with the extraction, transport or trade of gold:
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
- 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 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 is traded and upstream actors in the supply chain; or
- tax or extort money, or gold at mine sites, along transportation routes or at points where gold is 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 or that act illegally.
Regarding bribery and fraudulent misrepresentation of the origin of gold:
We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold.
- 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.
Royal Chain is committed to ensure that precious metals are sourced with due respect for human rights, the need to avoid contributing to conflict, and the desire to support development through our supply chain practices.
At the same time, Royal Chain does not ban the use of precious metals that originate in conflict-affected and high-risk areas when they are sourced in accordance with existing international standards. Avoiding the sourcing of all precious metals from these areas would cause a de facto embargo with serious adverse impact on the living conditions of local populations.
We are conducting due diligence as per the requirements of the Responsible Jewellery Council’s provision 7 (COP 7). This provision is based upon OECD Due Diligence Guidance which is an internationally recognised framework.
If you would like to learn more about responsible supply chains or minerals from conflict-affected and high-risks areas, please visit: www.oecd.org/fr/daf/inv/mne/mining.htm.
We are asking:
1) Our suppliers of products containing precious to provide information to identify the furthest known upstream source in their supply chains. Royal Chain will protect confidential and business sensitive information through our data collection.
2) In an effort to maximize the effectiveness of the above policy, and to streamline the process we are requiring all Royal Chain Vendors to supply all Precious Metals for product delivered to Royal Chain from the following refineries only
- Chimet S.P.A,Italy
- Nadir Metal Refineri, Turkey
- Metalor Technologies SA, Switzerland and US
- MMTC-PAMP INDIA PVT. LTD., India
- HERAEUS LIMITED, Hong Kong
- GOLD FIELD REFINERY CO., LTD, Thailand
Dear Vendor Partner:
As part of our commitment to responsible sourcing, we are now working with our suppliers to understand their sources of supply and due diligence procedures for managing risks in their supply chain.
To fulfil our obligations, we ask that you share the following information with us
If you would like to learn more about responsible supply chains or minerals from conflict-affected and high-risks areas, please visit: www.oecd.org/fr/daf/inv/mne/mining.htm.
List of Additional Information Needed
- Your Business Name
- A Copy Of your Business License
- Your Business Address
- Your Business City, State, Country, ZIP Code
- Your Business Phone
- Your Business Owners Name and any additional beneficial owners
- Your Compliance Officer Name
- Please send us your Human Rights Policy
- Please send us your OECD Policy
- Do you complete anti money laundering and KYC training annually?
- Do they have records of your last AML and KYC training?
- Please give assurance Kimberly Process Certification scheme is being followed
- Please give assurance World Diamond Council System of Warranties (SOW) is being followed
- An invoice with your SOW statement if you are a diamond supplier
- Please list your ethical gemstone sourcing policy
- Please advise that you are not sourcing materials from a conflict affected and high -risk area-Please check that any material you supply Royal Chain is not from any countries/ regions on this link) https://www.cahraslist.net/.
- Please send us your RJC membership certificate
- Please advise that you are sourcing all precious metals from one (or more) of the below refineries:
- Chimet S.P.A,Italy
- Nadir Metal Refineri, Turkey
- Metalor Technologies SA, Switzerland and US
- MMTC-PAMP INDIA PVT. LTD., India
- HERAEUS LIMITED, Hong Kong
- GOLD FIELD REFINERY CO., LTD, Thailand
We are also running all of our vendors through a database on the JVC website that flags entities/ countries that are on US watch lists.
All information will be kept on our vendor spread sheet to track where we track received and incomplete vendor information.
Royal Chain is conducting due diligence and KYC gathering on all of our suppliers on an annual basis. The
We are also running all of our vendors through a database on the creditsafe.com that flags entities/ countries that are on US watchlists.
All information will be kept on our vendor spread sheet to track what we receive and are missing.
Royal Chain OECD Identify Red Flags/ Risk Assessment/Manage Risk
We have taken a risk assessment through Jewelers Mutual which is below:
OBJECTIVE ASSESSMENT OF THE RISKS
On May 5, 2021 the Company conducted a methodical analysis of its standard practices and
evaluated the extent to which they present vulnerability to the Risks.
The purpose of this exercise was to raise awareness of the Risks, thereby enabling the
Company’s Compliance Officer to develop reasonable, appropriate and effective Counter-
Measures.
The process included scrutiny and evaluation of the Company’s methods of transacting money,
receiving and distributing Covered Goods, sources of supply, methods of “Knowing Your
Customer (KYC)” and other factors relating to the Risks.
Each of the Company’s standard practices was scored to assess whether it presented HIGH,
MEDIUM or LOW Risks. The score for each practice was averaged to produce an Overall Risk
Score was LOW.
We had our latest training in March 2024 where we spoke about possible red flags and ways to identify risks AML violations.
All company employees were directed to either go through our anonymous feedback button on our website or to come to the compliance officer, Nicole Griffin with any red flags.
When we receive all our information back from our vendor partners, compliance and management will meet (in April 2024) to identify any red flags and manage our risk accordingly (contact factories, switch vendors, etc.). Meeting notes and action plans will be kept of this meeting.
Royal Chain OECD Annual Report
COP REPORTING MARCH 2024
Contact Information
COMPANY NAME: Royal Chain
DATE: 3-25-2024
REPORTING PERIOD: Jan 2023-March 2024
CONTACT: [email protected]
ISSUES and ACTIONS
Royal Chain will be providing details on the following issues that were identified during our due diligence information gathering and processing activities.
When reviewing our company activity in regards to climate, we concluded the maximum impact we can make as an organization in this area is to conserve the amount of fossil fuels used on air travel and boat/ air freight for shipping product.
The actions we took regarding the above was to have an open dialogue and company policy about weighing our business travel as really needed with concern for fossil fuel usage. The company committed to pay increased airfare for direct flights for business travel when applicable because this greatly reduces carbon admissions.
The company also continuously evaluates the ability of us to consolidate shipping of product to also limit carbon admissions.
Because Royal Chain is a rents its office space we also have exerted continued pressure on the owners and management company of our office space to continue to improve our building to move as close to carbon neutral as possible. We also rent office space andare located in mid -town Manhattan, New York, which greatly decreases the amount of Carbon emissions our employees use to commute to and from our offices.
We sell or donate our old electronic items if possible in order to not create hard plastic, electronic, battery waste, and also purchase second hand electronics when ever possible.
We established a heath and safety committee of diverse employees to discover and advise company management on workplace safety and rights issues.
COP 6 & 7: HUMAN RIGHTS
& DUE DILIGENCE
COMPANY MANAGEMENT SYSTEMS
Royal Chain have policies in place referenced in the above document, detailing our commitment to respect human rights throughout our supply chain and our supply chain due diligence on the following minerals gold, silver, diamonds, emeralds rubies and sapphies originating from conflict-affected and high-risk areas. Royal Chain endorse these policies to our suppliers and stakeholders by distributing them via the above letter. These policies can also be accessed by our internal stakeholders and externally via our website www.royalchain.com.
To support supply chain due diligence, we have implemented the following internal measures . KYC and AML training, information gathering and tracking via correspondence with our suppliers and our internal vendor tracjer.The senior manager responsible for overseeing supply chain due diligence is Shlomo Ozdamar. To aid us in identifying our human rights impacts we have developed and implemented the follow systems checking all companies and stakeholders via creditsafe.com; we have a human rights policy in place that can be found above. The senior manager responsible for overseeing our human rights impacts is Selim Ozdamar.
Royal Chain have established a system of controls and transparency over our supply chain, which include our approach for identifying suppliers, whom we purchase from and identifying sources of our metals by asking our suppliers to only purchase metals from specific refineries. In our first rounds of due diligence in this area we realized it was too hard, because of our extremely large vendor base to monitor every refinery our vendors used. We therefore asked them to only purchase metals from specific refineries we were comfortable with.
We also have established a system of control and transparency for our diamond supplied goods by making syre all of our vendors adhere to the Kimberly process and Signet SRSP guideines.
We are in process of making sure all gemstone vendors are adhering to SRSP guidelines.
Our grievance mechanism for internal stakeholders and external grievances can be accessed via our website. We have not have any grieviences reported but are committed to investigating 100% of these griveinces.The employee responsible for these grievance mechanism is Stephanie Madero.