CONFLICT FREE MINERALS POLICY

INTRODUCTION

On August 22nd of 2012, the US Securities and Exchange Commission (SEC) released the final rule for Section 1502 on Conflict Minerals in the Dodd-Frank Act.  Compliance with this provision impacts manufacturers, distributors, wholesalers, and retailers within the precious metals industry.  As part of this legislation, certain companies who file reports with the SEC will be required to provide annual disclosures regarding their use of conflict minerals defined in sec 1502.

DEFINITIONS

Conflict minerals are defined as columbite-tantalite, cassiterite, gold, wolframite, and their derivatives tantalum, tin, and tungsten. This list may change since conflict minerals are also any mineral or its derivatives that the U.S. Secretary of State determines are financing conflict in the DRC or its adjoining countries.

DRC adjoining countries 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 precious minerals that perpetuate conflict.

DRC conflict free is defined as parts or components that do not contain conflict minerals necessary to the functionality or production of the product that directly or indirectly finance or benefit armed groups in the DRC or DRC adjoining countries.

Conflict minerals obtained from recycled, or scrap sources are defined as conflict minerals obtained from recycled metals. These recycled metals are reclaimed end-user or postconsumer products, or scrap processed metals created during product manufacturing. Recycled metals include excess, obsolete, defective and scrap metal materials containing refined or processed metals that are appropriate to recycle in the production of tin, tantalum, tungsten, or gold. Minerals partially processed, unprocessed or a byproduct from another ore are not included in this definition. Any refiner we engage with must be accredited by SRSP approved bodies.

Jacmel Jewelry Inc. supports the SEC’s final ruling and is positioned to supply jewelry items which are fully compliant with SEC guidelines.

  • Jacmel Jewelry Inc. will only accept gold, silver and rhodium from refiners on the LBMA good delivery list, EICC/GeSi conflict-free compliant smelter list, certified members of the Responsible Jewelry Council or refiners which certify and independently audit that all gold suppliers are conflict free, in accordance with one of the following standards: RJC chain of custody standard, OECD Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas Supplement or World Gold Council Conflict-Free Standard.

  • Jacmel Jewelry Inc. will only accept gold, silver and rhodium from Banks which certify and independently audit that all gold is supplied from Refineries which adhere to the refinery compliance requirements listed above.

  • Jacmel Jewelry Inc. will only accept gold, silver and rhodium from Precious Metals Trading Companies which certify and independently audit all gold from Refineries and / or Banks which adhere to the Refinery & Bank compliance requirements listed above.

  • Jacmel Jewelry Inc. will only accept scrap and / or recycled gold, silver and rhodium from customers or suppliers which certify and independently audit that all scrap and recycled gold, silver and rhodium is identifiable as its own production and supply, i.e. scrap gold, silver and rhodium is returned from customers, faulty inventory or scrap generated during the production process.

  • Jacmel Jewelry Inc. does not utilize Tin, Tantalum or Tungsten in its products or processes.

The following requirements must be met by Jacmel Jewelry Inc. suppliers:

  • Assist Jacmel Jewelry Inc. in compliance with the SEC regulations related to conflict minerals and provide all necessary declarations.

  • Undertake reasonable due diligence within their supply chain to determine the chain of custody and origin of all minerals. Due diligence includes developing policies and management systems to use DRC conflict free minerals, including making these requirements apply to their direct suppliers and sub-tier suppliers and requiring them to do the same with lower tiers of suppliers.

  • Take measures to purchase parts, components or materials from their direct suppliers and sub-tier suppliers who source minerals for their products from smelters or refiners validated as being DRC conflict free in accordance with a nationally or internationally recognized due diligence framework.

  • Comply with information requests on the source and origin of all minerals in the parts, components or materials provided to Jacmel Jewelry Inc. Chain of custody data shall be maintained for five years and be provided to Jacmel Jewelry Inc. upon request.

  • Jacmel Jewelry Inc. expects all their suppliers to produce with precious metals from a conflict-free area.  All suppliers must be able to readily provide the names of the smelters they use and must fill out a conflict mineral reporting template on a yearly basis.  This template will be used by Jacmel Jewelry Inc to trace where each supplier is sourcing their materials.

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