RJECO Inc is committed to sourcing responsibly and in line with all recognized principles and standards. At RJECO Inc we recognize that risks of significant negative impacts may be associated with the gemstones and jewelry industry throughout all stages of the supply chain. For this reason, we commit to managing our supply chain responsibly, in particular when sourcing minerals from Conflict-Affected and High-Risk Areas.
Through this Responsible Sourcing Policy, we commit to respecting human rights and to refraining from any action which contributes to the financing of conflict, including through compliance with the relevant United Nations sanctions and resolutions or, when applicable, domestic laws implementing such resolutions.
To this end, we will implement a due diligence process for our mineral supply chains, with the goal to prevent, identify, and manage risks associated with the extraction, trading, handling, and exporting of minerals from CAHRA. We will carry out due diligence based on the 5-step framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and will focus our efforts on preventing, identifying, and managing, at minimum, the following risk:
Serious human rights abuses, such as forced labor and child labor
Support to non-state armed groups
Risk associated to the contracting of public or private security forces
Bribery and fraudulent misrepresentation of the origin of the mineral
Money Launder and non-payment of taxes, fees and royalties due to governments
Should any such risks be identified, we will take appropriate action, as described below.
While sourcing from, or operating in, CAHRA, we will neither tolerate nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of:
Any forms of torture, cruel, inhumane, or degrading treatment
Any forms of forced or compulsory labor, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily
The worst forms of child labor
Other gross human rights violations and abuses such as widespread sexual violence
War crimes and other serious violations of international humanitarian law, crimes against humanity, or genocide
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they were sourcing from, or linked to, any party committing serious abuses as defined above.
We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling, or export of minerals. “Direct or indirect support” to non-state armed groups through the extraction, transport, trade, handling, or export of minerals includes, but is not limited to, procuring minerals from, making payments to, or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:
Illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or
Illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or
Illegally tax or extort intermediaries, export businesses, or international traders
We will immediately suspend or discontinue engagement with upstream suppliers when we identify 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 defined above.
We agree to eliminate direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export businesses, or international traders.
We recognise that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.
Where we or any business in our supply chain contract public or private security forces, we commit to or we will require that such security forces will be engaged in accordance with the Voluntary Principles on Security and Human Rights. In particular, we will support or take steps, to adopt screening policies to ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired.
We will support efforts, or take steps, to engage with central or local authorities, international organisations and civil society organisations to contribute to workable solutions on how transparency, proportionality and accountability in payments made to public security forces for the provision of security could be improved.
We will support efforts, or take steps, to engage with local authorities, international organisations and civil society organisations to avoid or minimise the exposure of vulnerable groups, in particular, artisanal miners where minerals in the supply chain are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.
Where we identify that such a reasonable risk exists, we will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, as defined above. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan.
We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.
We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.
We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments.
We commit to engage with suppliers and, where relevant, with central or local governmental authorities, international organisations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
RJECO Inc requires executives, management, and employees, as well as contractors and suppliers, to be familiar with their responsibilities and adhere to this policy and related procedures
This policy is revised and updated on a regular basis. For additional information related to our supply chain or for a copy of our annual due diligence report please contact emma@rothschildtrading.com.
RJECO Inc is a member of the Responsible Jewelry Council (RJC) and is committed to operating in accordance with the RJC Code of Practices. We commit to integrating ethical, human rights, social, and environmental considerations into our day-to-day operations, business planning activities, and decision making processes. The below code of conduct outlines the expectation of our suppliers and business partners:
The Company expects all suppliers and business partners to operate in accordance with applicable laws and regulations that govern the jurisdictions in which they operate.
The Company expects all suppliers and business partners to comply with the UN Guiding Principles on Business and Human Rights.
The Company expects all suppliers and business partners to conduct business in an ethical manner free of bribery and corruption in accordance with the US Foreign Corrupt Practices Act and all other applicable laws prohibiting bribery and other improper payments.
The Company expects all suppliers and business partners to institute an Anti-Money Laundering (AML) program in compliance with the US Patriot Act, US Bank Secrecy Act, and other applicable regulatory requirements.
The Company expects all suppliers and business partners to maintain a safe and healthy working environment for all employees and contractors in compliance with all relevant state and federal health and safety standards with the aim to identify and minimize hazards within their operations.
The Company expects all suppliers and business partners to comply with all applicable environment laws, regulations, and reporting requirements, including risk assessments to continually improve environmental practices throughout their business operations.
The Company expects all suppliers and business partners to operate in accordance with all local and federal employment laws and create an environment free of harassment, discrimination, and retaliation. They are also expected to refrain from supporting or engaging in child labor or forced labor, and to provide mechanisms for employees and contractors to submit workplace grievances and complaints.
The Company requires all suppliers and business partners to:
Be aware of, and disclose to the Company upon request, the origin of all precious metal, diamond, and stone products supplied, to assist the Company in performing its due diligence requirements;
To not source gold, silver, or platinum-group metals in contrary to the OECD standards related to sourcing from conflict-affected and high-risk areas;
To comply with with the Kimberly Process Certification Scheme and World Diamond Council System of Warranties
The Company expects all suppliers and business partners to refrain from making untruthful, misleading, or deceptive representations, or to make any material omission in the selling, advertising, or marketing of any gold, silver, platinum-group metals, jewelry products, diamonds, or colored gemstones (including simulant, synthetic, treated, or composite products) supplied to the Company.
The Company will immediately suspend business with any supplier or business partner who violates the Code of Conduct. The Company will undertake an investigation, the outcome of which may result in the Company terminating all business with the supplier or business partner.
RJECO Inc recognizes our responsibility to respect human rights. We believe that our business has a role to play in protecting and promoting human rights.
RJECO Inc 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 refers 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 who they choose to live their life. It is a broad concept, with economic, social, cultural, political, and civil dimensions. For RJECO Inc, 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 RJECO Inc. Together with our employees and business partners, we are committed to drive forward the implementation of this Policy throughout our operation and supply chains. We recognize unique challenges to these standards may arise and we will work to address these challenges in partnership with relevant partners and stakeholders.
RJECO Inc 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 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.
The UN Declaration in its entirety can be found here: https://www.un.org/en/about-
RJECO Inc is committed to protecting the environment, the health and safety of our employees, and the community in which we conduct business. It is our policy to seek continual improvement throughout our business operations to lessen our impact on the local and global environment by conserving energy, water, and other natural resources; reducing waste generation; recycling; and reducing our use of toxic materials.
Environmentally Preferable Purchasing Policy (EPP)
Preference will be given to purchasing products and services that have the following environmentally friendly attributes with acceptable parameters for price, quality, and delivery:
Maximizes post-consumer recycled content
Minimizes packaging and other wastes
Minimizes toxicity
Are made of sustainably produced materials
Conserves energy, water, and other natural resources
Environmentally preferable products and services that are comparable in quality to their standard counterparts will receive a purchasing preference. In situations where the most environmentally preferable product is unavailable or impractical, secondary considerations will include production methods and the environmentally and socially responsible management practices of suppliers and producers. Environmentally preferable purchasing is part of our long term commitment to the environment. By sending a clear signal to producers and suppliers about this commitment, we hope to support wider adoption of environmentally preferable products and practices.
The four Rs – Rethink, Reuse, Reduce, Recycle
Rethink your consumption habits to minimize waste. Look for ways to reuse items whenever possible; reduce consumption to reduce waste. Purchase only items that can be recycled.
RJECO Inc acknowledges the right of any individual or organization relevant to RJECO Inc including customers, suppliers, business partners, service providers or their representatives to be able to raise concerns about our process and to file a grievance about our decision making protocol.
Please contact us with any concern or grievance for review, assessment, and response. Please include all relevant documentation with your submission. All comments about our processes will be taken seriously and submitted to our compliance officer for investigation and review. All relevant submissions will be logged and maintained as a record for a period of five years. RJECO Inc will ensure the confidentiality of the supplier of the information, unless disclosure is required by law. Anonymous submissions can also be made through the RJC website here: https://www.
