Supply Chain Due Diligence Procedure

Purpose

The purpose of this document is to outline the steps that need to be carried out as part of our supply chain due diligence with regards to human rights and ethical sourcing.  For the purposes of human rights due diligence these procedures must be carried out with all suppliers and whenever gold, silver or platinum group metal are being sourced in the form of raw material, sub-assemblies or finished products this protocol will be extended to our supplier's suppliers until we identify and evaluate the refiners in the supply chain.

Procedure

Step 1
All active and new suppliers are requested to provide external audit results regarding sourcing and human rights topics conducted within the last twelve months.  All suppliers should follow the Organisation for Economic Co-operation and Development (OECD) due diligence guidelines.  Precious metal suppliers are also asked for the identity of their upstream precious metal refiners. Diamond suppliers are asked for the origin of their supply to confirm these are from legitimate sources not involved in funding conflict.  Diamond suppliers are also required to comply with the World Diamond Council System of Warranties and are in compliance with the United Nations Resolutions.  If the supplier is unaware or unwilling to disclose the required information, we will attempt to create a mutually agreeable procedure for how the information should be gathered and shared.

Step 2
All relevant documents will be used to assess the supplier for actual or potential human rights risks. For precious metal suppliers, once upstream refiners have been identified we will gather information pertaining to the refiner's due diligence process and check against the OECD due diligence framework to confirm it is sufficient and satisfactory. In both scenarios, if satisfactory and a responsible level of due diligence regarding both human rights and ethical sourcing of raw materials is shown we will proceed to step 4. 

In the event a red flag is detected where human rights may have been violated or materials were sourced or transported through CAHRAs. Further inquiries with our relevant direct supplier need to be initiated.  Additionally, to ensure we comply with SRSP we will confirm that our upstream refiners of Gold, Silver and PGM have been audited and accredited by one of the following standards:

• LBMA silver or gold
• SCS Global Services' Responsible source standard
• The Chain Chamber of Commerce of Metals Minerals and Chemicals Importers and Exporters (CCCMC) Guidelines
• DMCC Dubai good delivery list for gold
• CRAFT code for artisanal and small-scale mining
• The Fair Trade Gold Standard through registered refineries
• The Responsible Mineral Initiative (RMI)
• The Responsible Mineral Assurance Process (RMAP)
• Responsible Jewellery Council (RJC Code)
• Organisation for Economic Co-operation and Development (OECD) due diligence guidelines

Step 3
Begin by sending out and requesting replies for:
• Jacmel Jewelry Inc. Supplier self-assessment
• Conflict mineral policy acknowledgment
• Conflict diamond policy acknowledgment
• Business code of conduct acknowledgment

For current suppliers, any documents gathered within the last 3 years can be used for the purposes of evaluation for a continued business relationship. We will review the responses given to these documents and assess for ethical sourcing and human rights violation risks. All red flags need to be assessed for the severity of the potential or real risks. For the most severe cases immediate suspension of the relevant direct supplier may be necessary. Where possible preventative and mitigating measures can be put in place to continue the relationship with the relevant direct supplier.

Step 4
Annually review due diligence and information collection procedures. Streamline where possible to ensure only relevant and important information is being collected. Where needed introduce extra steps in order to conclude with confidence that our supply chain is in fact ethical.

Step 5
Report annually:
• Our supply chain policy
• Due diligence procedure
• Assessment of refiner's due diligence procedures
• Identified risks both real and potential
• Prevention and mitigation efforts of risks
• Progress report 6 months after initial engagement

The responsibility of carrying out the supply chain due diligence will fall upon Mr. Laurence Meskin
(lmeskin@jacmel.com) and Ms. Dominique M. Railey (drailey@jacmel.com)

Review Procedure
This document will be reviewed as part of the annual policy and procedure review.

Thank you,

Dominique Railey
Global Compliance Manager
January 12, 2024