Ethical Business Policy

Legislation and Regulations

D. NAVINCHANDRA JEWELS shall operate in compliance with relevant national and international legislations / regulations as applicable in the countries in which they operate.

All employees are expected and directed to comply with all applicable laws and regulations and will have to follow the rules and regulations formed by D. NAVINCHANDRA JEWELS regarding its business policies.

The DNJ Compliance Team maintains the list of applicable legal and regulatory requirements is adhered to on a day to day basis. Necessary records of requirements and compliance are also maintained.

Money Laundering, Terrorism Financing, Other Financial Offences

D. NAVINCHANDRA JEWELS recognizes the fact that entities in the gems and jewelry sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.

Strict compliance is required 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.

D. NAVINCHANDRA JEWELS shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations. The following acts and international guidelines are considered while establishing policies of D. NAVINCHANDRA JEWELS.

Prevention of Money Laundering Act 2002

FATF 40 Recommendations and 8 Special Recommendations

It is the responsibility of concerned personnel to know and understand the relevant money laundering / financial offences related legal, regulatory, and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious activity that appears to be questionable may also be considered a violation of the Business Principles, depending on the seriousness of the non-conformance.

The Compliance Officer ensures all the critical steps such as KYC & KYS, identification of suspicious transactions, reporting to management and record keeping as required by the local act and legislations are complied with.

The Compliance Officer carries out a periodic review of AML/CFT compliances and submits his report to management on a quarterly basis.

The company has been undertaking the following steps towards compliance with applicable laws:

• Performs appropriate due diligence (OECD) on a risk based approach over our counterparties.
• Ensures appropriates scrutiny and monitoring of transactions by applying a risk based approach.
• Take steps to contribute to the effective elimination of Money Laundering and Terrorism Financing by promptly reporting of suspicious transactions to the Local Financial Intelligence Unit (FIU).

Kimberley Process and System of Warranties

D. NAVINCHANDRA JEWELS is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and World Diamond Council’s (WDC) System of Warranties Declaration.

We will not engage businesses within the supply chain that deal in ‘conflict diamonds’ or those that do not follow the System of Warranties Declaration on invoices, either knowingly or unknowingly. Any engagement with such businesses will be considered a violation of DNJ Business Principles.

Anti Bribery and Facilitation Payment Policy

The D. NAVINCHANDRA JEWELS shall ensure complete prohibition of bribery and facilitation payment across the organization and within all entities.

D. NAVINCHANDRA JEWELS will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.

The entity shall prohibit bribery and facilitation payments and shall comply with various rules and regulations of the land.

Disclosure of Treated Diamonds, Synthetics and Simulants

The following essential principles will be applicable in all 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.

We deal in real and natural diamonds only and any treatment of real and natural diamonds is disclosed to the customer prior to sales.

Metal Sourcing Policy

Conflict   Minerals Policy Statement (Diamond & Gemstone)

D. NAVINCHANDRA JEWELS is committed to being a responsible corporate citizen and strongly opposes violation of human rights.  As part of that commitment, D. NAVINCHANDRA JEWELS seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility.

D. NAVINCHANDRA JEWELS shall strive to ensure that all its supply of diamonds are not originating from CAHRA’s and where practically possible, the origin of the diamonds is known to us.

What Are ‘Conflict Diamonds’?

‘Conflict Diamonds’ are stones that are produced in areas controlled by rebel forces that are opposed to internationally recognized governments. The rebels sell these diamonds, and the money is used to purchase arms or to fund their military actions.

Conflict Diamonds are often produced through the forced labour of men, women and children. They are also stolen during shipment or seized by attacking the mining operations of legitimate producers. These attacks can be on the scale of a large military operation.

The stones are then smuggled into the international diamond trade and sold as legitimate gems. These diamonds are often the main source of funding for the rebels; however, arms merchants, smugglers, and dishonest diamond traders enable their actions. Enormous amounts of money are at stake, and bribes, threats, torture, and murder are modes of operation.

CAHRA (Conflict-Affected and High-Risk Areas)

Angola Coast, Democratic Republic of the Congo, Liberia, Sierra Leone, Republic of the Congo and Zimbabwe Marange Diamond Fields  

D. NAVINCHANDRA JEWELS shall ensure that none of its supplies are coming from the above sources. Sight Holder shall communicate its sourcing policy to all the stakeholders and will ensure effective implementation among them.

Supply Chain Management / Best Endeavours

The management of D. NAVINCHANDRA JEWELS is committed to take appropriate action to use best endeavours to ensure that suppliers and contractors are committed to compliance with International Social Standards.

Annual communications are exchanged within the DNJ supply chain to spread awareness.

Employment

Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.

D. NAVINCHANDRA JEWELS shall not require that staff  works for more than  the national limit of hours in a week  on a regular basis.

D. NAVINCHANDRA JEWELS 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 staff and provide some discretionary income.

Health and Safety

D. NAVINCHANDRA JEWELS recognizes the need to develop a 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.

All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable.

Non Discrimination, Disciplinary Practices

Discrimination can mean distinction, exclusion or preference.

Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, 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 D. NAVINCHANDRA JEWELS and any such reported incidents will be viewed as a serious violation of the DNJ Business Principles.

We will ensure that employees who have certain life threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.

We shall at no time condone the use of corporal punishment or other forms of mental or physical coercion.

We encourage all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy of D. NAVINCHANDRA JEWELS operations or practices are or will likely be in violation of any law, regulation or internal D. NAVINCHANDRA JEWELS rule or policy, including the Business Principles. D. NAVINCHANDRA JEWELS assures all employees who come forward in good faith to report issues, and that they will be treated fairly and respectfully.

Child Labour

No form of child labour shall occur at any of the facilities of D. NAVINCHANDRA JEWELS. Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (as per ILO Convention No. 138).

For authorized adolescents (persons below 18 years of age but above 15 years), D. NAVINCHANDRA JEWELS management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.

D. NAVINCHANDRA JEWELS policy condemns child labour and adolescent child labour.

D. NAVINCHANDRA JEWELS will implement suitable policies and procedures to verify the age proof all new employees joining the organisation.

Forced Labour

The management of D. NAVINCHANDRA JEWELS is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any incidents reported relating to forced labour will be considered as a serious violation of the DNJ Business Principles.

The following definitions will be applicable:

The Universal Declaration of Human Rights states that ‘No one shall be held in slavery or servitude’.

ILO Convention 29, defines forced or compulsory labour 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”.

Human Rights

All employees in the D. NAVINCHANDRA JEWELS’ facilities will be treated with equality, respect, and dignity.

D. NAVINCHANDRA JEWELS will not interfere with the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation.

D. NAVINCHANDRA JEWELS 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 D. NAVINCHANDRA JEWELS.

HSE & anti-sexual harassment committees have been established and committees shall review compliance at regular intervals by holding review meetings.

Environment Protection

D. NAVINCHANDRA JEWELS is committed to effective environmental management as one of its important corporate priorities.

Compliance with all applicable environmental laws and regulations will be ensured.

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.

Disposal procedures for wastes generated will be clearly defined and practiced in line with standards that are set by law and best practices of the industry.

Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence will be promoted.

Product Security

D. NAVINCHANDRA JEWELS is committed to providing the safety of products throughout its supply chain by following the precautions outlined below.

Each and every stage of product processing is covered through blanket insurance.

Suitable safe-guarding and storage is ensured at all stages with the help of safes.

We ensure the safety of visitors, customers and other interested parties through, surveillance systems such as CCTV, multi-level entry doors and other electronic intelligence.

All concerned persons are trained on relevant safety and security procedures to be followed at all times.

Public Grievances against Social & Ethical Compliance of D. NAVINCHANDRA JEWELS

If you encounter any instance of non-compliance or specific deviation from our ethical policies, please inform us as soon as practicable.

Further, if you are interested in obtaining a copy of our annual sourcing compliance report based on OECD guidelines. Please send an email to Sebastian Cardoz (email address provided below).