CONFLICT FREE DIAMOND POLICY

Jacmel Jewelry Inc. supports the efforts of leading suppliers in the diamond industry that have agreed on a voluntary program of self-regulation to complement the Kimberly Process Certification Scheme created by the governments of nations involved in the diamond/gemstone trade.  Conflict diamonds are those illegally traded to fund conflict in war-torn areas, particularly in central and western Africa, DRC, and their adjoining countries.  These are the following countries bordering the DRC: Angola, Burundi, Central African Republic, Rwanda, Sudan, Tanzania, Uganda, and Zambia. This definition can be extended to any supply of diamonds that perpetuate conflict. The United Nations defines conflict diamonds as “…diamonds that originate from areas controlled by forces or factions opposed to legitimate and internationally recognized governments and are used to fund military action in opposition to those governments, or in contravention of the decisions of the Security Council.”  These diamonds are sometimes referred to as “blood diamonds.”  

As a condition of doing business with Jacmel Jewelry Inc., all suppliers of diamonds must agree to the following guidelines.

  • Jacmel Jewelry Inc. requires all vendors that fabricate product from rough diamonds mined on or after January 2003, to guarantee that all diamonds provided to us have been purchased from legitimate sources not involved in funding conflict and in compliance with United Nations Resolutions.  Vendors shall guarantee that these diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier(s) of these diamonds.   

  • Jacmel Jewelry Inc. requires all vendors that fabricate product from diamonds mined before January 1, 2003, to guarantee that they are not knowingly selling conflict diamonds to us, and that, to the best of their ability, they will undertake reasonable measures to help prevent the sale of conflict diamonds.

  • Jacmel Jewelry Inc. requires vendors to ensure they are not selling us any diamond, gemstone, pearl or other jewelry product which has been used to fund, or is the product of, illegal, violent, inhumane or terrorist activity.  Vendors will ensure the legitimate origin and commerce stream of their products.

  • Jacmel Jewelry Inc. requires vendors to provide us with proof of warranty from their sources of merchandise upon request.  Vendors will retain for at least five years the warranties accompanying their purchases.

  • Jacmel Jewelry Inc. expects all their suppliers to send immediate written notification in the event of any change to their sourcing.

  • Jacmel Jewelry Inc. maintains a zero tolerance policy for all suppliers.  Should it be discovered that a supplier is using materials from a conflict area the business relationship will be terminated immediately.

  • In the event any risk is suspected, Jacmel Jewelry Inc. will investigate and take action as per the above zero tolerance policy for suppliers.

SUMMARY

COMPLIANCE
This policy applies to Jacmel Jewelry Inc.’s global business operations. Employees whose responsibilities relate to the supply or sourcing of parts, components, and materials should be informed and are expected to comply with these requirements and associated legislation or regulation.

NON-COMPLIANCE
Jacmel Jewelry Inc. will work with its suppliers to seek remedies for non-compliance with this policy. These remedies may include suspension or discontinuing engagement with the supplier.

REPORTING VIOLATIONS
Violations or potential violations of this policy should be reported by employees to their supervisor or to direct management.

ADDITIONAL INFORMATION / CONTACTS
General questions from employees, suppliers and customers about conflict minerals and this policy should be directed to Jacmel Jewelry Inc.’s Global Compliance Manager, Ms. Dominique M. Railey (drailey@jacmel.com).

Thank you,

Dominique Railey
Global Compliance Manager
January 12, 2024