On this page we'll share resources, answer questions, and compile answers to the most questions asked through our contact form. Please be patient as we get all our resources together and listed on this page for you!
CRAFT Code is an open source tool that encourages industry and government to promote responsible artisanal and small-scale mineral supply chains. (Source: Craftmines.org website)
At its basic level, supply chain or third-party due diligence describes the efforts taken to investigate a potential business partner. Third parties in a modern supply chain are diverse. They can include anything from suppliers, distributors, agents, advisors and consultants, and even customers. Third-party due diligence applies both up and down the supply chain. Any external partner, be it entity or individual, that a firm works with is a third party and therefore a potential corruption risk.
The objective of third-party due diligence is to discover any corruption risks associated with the potential partner.1 Ultimately, an effective due diligence screening program allows a firm to make an informed decision about whether it is safe to proceed with a proposed business partnership. As such, proper due diligence should begin before engaging with a third party–such as through an onboarding questionnaire–and continue throughout the relationship through monitoring. The level of effort that a firm invests in conducting a due diligence investigation on a third party should correlate with the level of risk the third party potentially presents.
Fairmined is a label applied to gold and silver that is sourced exclusively from artisanal and small-scale mining organizations that meet the requirements of the Fairmined Standard written by the Alliance for Responsible Mining (ARM). This standard attempts to improve trading conditions and environmental sustainability for producers in developing countries. (Source: The Jewelry Glossary Project)
A label applied to products that are third-party certified against standards created by FLOcert (Fairtrade Labeling Organizations International), the certification body of Fairtrade International. This standard attempts to improve trading conditions and environmental sustainability for producers in developing countries. As of 2019, gold and silver are the only Fairtrade jewelry-related products. (Source: The Jewelry Glossary Project)
The Initiative for Responsible Mining Assurance (IRMA) is a global mining standard that covers all mined materials (except energy fuels) coming from all sizes of industrial mines with independent third-party certification at the site of the mine.
To help prevent, mitigate, and manage risks that undermine responsible sourcing, companies should collect, verify and archive information on their customers, suppliers, contractors and other third parties with they conduct business regularly. These measures, called Know Your Customer/Counterparty (KYC), are considered a first step for conducting due diligence.
Members of the jewellery and gemstone industries should apply KYC to their supply chains, establishing wherever possible the identity of all organisations with which they deal, having a clear understanding of their business relationships, and having a reasonable ability to identify and react to transaction patterns appearing out of the ordinary or suspicious.
A key objective of KYC is for the company to demonstrate that it has carried out checks on its counterparties, even if to rule out their association with any money laundering or illicit activities. The expectation is that reasonable effort should be taken to complete these checks, commensurate with the size and nature of the business.
The Responsible Jewellery Council (RJC) is a standard-setting organization for the jewelry and watch industry.
The RMAP is a standard managed by the Responsible Minerals Initiative. The conformance with the standard is indicated by independent third-party assessments of smelter/refiner management systems and sourcing practices and employs a risk-based approach to validate smelters' company-level management processes for responsible mineral procurement.
SCS provides third-party audits for supply chain responsibility certifications and financial reporting mandates.
Jewelry businesses that commit to the RJC Code of Practice (CoP) (a common standard for ethical, social, human rights and environmental practices) and/or the voluntary, RJC Chain of Custody (CoC) are required to be audited against the standard by a third party - like SCS - within 2 years.
Jewelry businesses can also satisfy their due diligence requirements for Dodd-Frank (1502) and the EU Conflict Minerals Regulation (2017/821) and comply with public reporting manadates from the US Securities and Exchange Commission (SEC) and EU Regulators with SCS Global Services.
Is your business partner in a location where there are sanctions or no?
The US sanctions are narrowly-tailored and do not apply broadly to Russia when it comes to jewelry materials. Currently, only the Russian diamond producer, Alrosa, is affected by US and European sanctions, and while they do not prevent companies from actually purchasing Alrosa diamonds, they do limit the ability of Alrosa to raise capital, potentially affecting memo transactions. At the time these FAQs were published, no sanctions on Russian gold, Russian refineries, etc. were in place.
Gold purchases either from banks, refiners, bullion dealers, as recycled stock, from manufactures, as finished jewelry etc. all present potential entry points for Russian gold. Russian gold refers to gold mined in Russia, gold purchased from Russian communities, gold purchased by Russia from other countries.
At the time these FAQs were published the following organizations have taken steps to limit inflows of Russian gold.
There are reports that ICMM has suspended a Russian gold mine member. We are working to find verification of this.
The Jewelers Vigilance Committee (JVC) has prepared an anti-money laundering (AML) kit that will guide you through the process. The process of assembling your documentation takes some time, but the kit makes it understandable and easy to follow.
You can buy the kit directly from JVC.
Almost all jewelry businesses in the United States must comply with Anti-Money Laundering laws and regulations. This includes foreign-based businesses who have a presence in the US. This set of laws is sometimes referred to as “AML”, “PATRIOT Act”, or “KYC/Know Your Customer” rules.
If you qualify as a dealer (you buy and sell $50,000 or more in precious metals, precious stones, or jewelry for which 50% of the value is derived from precious stones or precious metals), you must create and implement a comprehensive anti-money laundering program.
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