Self Assessment Questionnaire



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Responsible Jewellery Council (RJC)

RJC ASSESSMENT WORKBOOK

T003 – RJC Assessment Workbook + Mining Supplement

Public Comment Period (PCP) 3 - Consultation draft – September to October 2009

• Track changes highlights changes since the 2008 published version

© RJC 2009. All rights reserved.

The Responsible Jewellery Council

The Responsible Jewellery Council

The Responsible Jewellery Council (RJC) is a not-for-profit organisation founded in 2005 with the following mission:

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About this Assessment Manual

The RJC Assessment Workbook provides Members with the Assessment Questions (T002_2008) laid out in a table format for the use by Members, with additional prompts and guidance on Objective Evidence. The Workbook also prompts Members to define the Certification Scope, by identifying those parts of their business which actively contribute to the Diamond and/or Gold Jewellery supply chain.

This is a ‘living document’ and the RJC reserves the right to revise this Manual based on implementation experience and emerging good practice. The version posted on the RJC website supersedes all other versions. To verify this document is current, please visit:



Disclaimer

No guarantee, warranty or representation is made as to the accuracy or completeness of the Assessment Workbook (hereinafter the "Workbook") and other documents or information sources referenced in the Workbook. Use of the Workbook is not intended to and does not replace, contravene or otherwise alter the requirements of any specific national, state or local governmental statutes, laws, regulations, ordinances, or other requirements regarding the matters included herein.

Use of the Workbook by non-members is entirely voluntary and is neither intended nor does it create, establish, or recognise any legally enforceable obligations or rights against the RJC and/or its Members or signatories. The Workbook does not create, establish, or recognise any legally enforceable obligations of the RJC and/or its member or signatories to non-members.   Non-members shall have no legal cause of action against the RJC and/or its members or signatories for failure to comply with the Workbook.

Inquiries or feedback

The RJC welcomes feedback on this Workbook. Please contact the Responsible Jewellery Council by email, telephone or post:

Email: info@

Telephone: +44 (0)20 7836 6376

Responsible Jewellery Council

First Floor, Dudley House

34-38 Southampton St

London WC27HF

UNITED KINGDOM

The Responsible Jewellery Council is a trading name of the Council for Responsible Jewellery Practices Ltd, which is registered in England and Wales with company number 05449042.

Part 1.1 Member contact details

|Member name | |

|Membership Forum | Diamond Trading Cutting or Polishing | MiningProducer |

| |Gold Refining, Hedging or Trading |Retail |

| |Jewellery Manufacturing or Wholesale |Service Industry |

|Head Office |Address | |

| |City | |

| |State/ province | |

| |Country | |

| |Telephone number | |

| |Fax number | |

| |E-mail address (if applicable) | |

|Name of designated RJC Coordinator |Name | |

| |Position | |

| |Address | |

| |Telephone number | |

| |Fax number | |

| |E-mail address(if applicable) | |

|Name and position of person(s) completing Self |Person |Name |Position |Contact (Phone or Email) |

|Assessment | | | | |

| | | | | |

|*NOTE: Person 1 should be the designated | | | | |

|contact person for monitors and RJC in the | | | | |

|event of a query or follow up | | | | |

| |1 | |  |  |

| |2 | | | |

| |3 | |  |  |

| |4 | | | |

| |5 | | | |

| |6 | |  |  |

|Other information or comments |

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Part 1.2 Certification Scope

Please list the details associated with the Facilities which make up the Certification Scope. Facilities that must be included within the Certification Scope are all of the premises that are owned by or under the control of a Member and involved with Diamonds and/or Gold with potential for use in jewellery.

|Facility Name |Location (Address/City/Country) |Number of Employees (E) & |Description of Business |Description of Activities (include information about business |

| | |Contractors (C) | |partners and contractors on site, and details of ownership/lease and|

| | | | |changes since the last Self Assessment) |

| | |E |C | | |

| | |E |C | | |

| | |E |C | | |

| | |E |C | | |

| | |E |C | | |

| | | | | | |

The Member is required to complete the Assessment Questions in this section and provide responses, evidence and findings that demonstrate how the Member’s business performs against the provisions in the Code of Practices.

The Assessment Questions cover the following Code of Practices:

Business Ethics

1.1 Bribery and Facilitation Payments

1.2 Money Laundering and Finance of Terrorism

1.3 Kimberley Process

1.4 Product Security

1.5 Product Integrity

1.6 Extractive Industries Transparency Initiative

Human Rights and Social Performance

2.1 Human Rights

2.2 Child Labour and Young Persons

2.3 Forced Labour

2.4 Freedom of Association and Collective Bargaining

2.5 Discrimination

2.6 Health and Safety

2.7 Discipline and Grievance Procedures

2.8 Hours of Work

2.9 Remuneration

2.10 General Employment Terms

2.11 Community Engagement and Development

2.12 Use of Security Personnel

2.13 Indigenous Peoples

2.14 Artisanal and Small-Scale Mining

Environmental Performance

3.1 Environmental Protection

3.2 Hazardous Substances

3.3 Waste and Emissions

3.4 Use of Energy and Natural Resources

3.5 Biodiversity

Management Practices

4.1 Legal Compliance

4.2 Policy

4.3 Business Partners – Contractors, Customers, Suppliers and Partners

4.4 Impact Assessment

4.5 Mine Closure Planning

4.6 Sustainability Reporting

Please see the Assessment Manual for additional instructions for completing this Workbook.

|Code of Practices Provisions |

|Members will prohibit Bribery in |Confirm that the Member has systems to|Policy and procedures | Documentation | | Head office | Conformance |

|all business practices and |prohibit involvement in Bribery of any|Relevant job descriptions |Observation | |Divisional/ Business |Minor NC |

|transactions that are carried out|form and ensure that these systems are|Training materials and records|Testimonial | |unit |Major NC |

|by them, or on their behalf by |communicated to and understood by | |None | |Facility |Not Applicable |

|Business Partners. They will not|personnel and others that conduct | | | |None |Reason: |

|offer, accept or countenance any |transactions on their behalf. | | | |Details: | |

|payments, gifts in kind, | | | | | | |

|hospitality, expenses or promises| | | | | | |

|as such that may compromise the | | | | | | |

|principles of fair competition or| | | | | | |

|constitute an attempt to obtain | | | | | | |

|or retain business for or with, | | | | | | |

|or direct business to, any | | | | | | |

|person; to influence the course | | | | | | |

|of the business or governmental | | | | | | |

|decision-making process. | | | | | | |

| |Determine whether these systems |Training materials and records| Documentation | | Head office | Conformance |

| |include measures that control not |Interviews with managers, |Observation | |Divisional/ Business |Minor NC |

| |offering, accepting or countenancing |buyers, contracting personnel |Testimonial | |unit |Major NC |

| |any facilitation payments, gifts in |and other relevant staff |None | |Facility |Not Applicable |

| |kind, hospitality, expenses or | | | |None |Reason: |

| |promises as such that may compromise | | | |Details: | |

| |the principles of fair competition or | | | | | |

| |constitute an attempt to obtain or | | | | | |

| |retain business for or with, or direct| | | | | |

| |business to, any person, or to | | | | | |

| |influence the course of the business | | | | | |

| |or governmental decision-making | | | | | |

| |process. | | | | | |

|Members will consider Bribery |Confirm that the risk of bribery has |Risk assessment procedures | Documentation | | Head office | Conformance |

|Risk as it applies to their |been considered by the business and |Risk assessment records (e.g. |Observation | |Divisional/ Business |Minor NC |

|organisation (including agents) |that any areas considered high risk |a risk register) |Testimonial | |unit |Major NC |

|to identify which areas pose high|have been identified. |Risk management action plans |None | |Facility |Not Applicable |

|Risks. Members will develop | |In-country risk assessment | | |None |Reason: |

|appropriate methods to monitor | |especially where bribery is | | |Details: | |

|conduct of Employees and agents | |known to exist | | | | |

|and eliminate Bribery based on | |Training materials and records| | | | |

|this understanding. | | | | | | |

| |Confirm whether there is a system to |In-country risk assessment | | | | |

| |monitor conduct of employees and |especially where bribery is | | | | |

| |agents to eliminate Bribery. |known to exist | | | | |

| | |Recording and monitoring | | | | |

| | |system for facilitation | | | | |

| | |payments, bribery attempts and| | | | |

| | |sanctions applied | | | | |

|Members will facilitate the |Determine whether the business |Recording and monitoring | Documentation | | Head office | Conformance |

|reporting of incidences of |encourages employees and contractors |system for facilitation |Observation | |Divisional/ Business |Minor NC |

|attempted Bribery or |to report instances of attempted |payments, bribery attempts and|Testimonial | |unit |Major NC |

|inappropriate gifts within their |Bribery or inappropriate gifts, and |sanctions applied |None | |Facility |Not Applicable |

|organisation and will apply the |that, in response to each report of |Last financial audit report | | |None |Reason: |

|appropriate sanctions for Bribery|Bribery and attempted Bribery in all |and auditor qualifications | | |Details: | |

|and attempted Bribery in all |forms, the appropriate investigation |Training materials and records| | | | |

|forms. |and subsequent sanctions are applied. |Interviews with managers, | | | | |

| | |buyers, contracting personnel | | | | |

| | |and other relevant staff | | | | |

|Members will clearly communicate |Confirm that employees who refuse to |Interviews with managers, | Documentation | | Head office | Conformance |

|to their Employees that no |participate in bribery or facilitation|buyers, contracting personnel |Observation | |Divisional/ Business |Minor NC |

|Employee will suffer demotion, |payments are supported by the |and other relevant staff |Testimonial | |unit |Major NC |

|penalty or other adverse |business, and that employees are aware| |None | |Facility |Not Applicable |

|consequences for voicing a |that they will not suffer demotion, | | | |None |Reason: |

|concern, or for refusing to pay a|penalty or other adverse consequences | | | |Details: | |

|bribe or Facilitation Payment |for voicing a concern, or for refusing| | | | | |

|even if this action may result in|to pay a bribe or Facilitation payment| | | | | |

|the enterprise losing business. |even if this action may result in the | | | | | |

| |enterprise losing business. | | | | | |

|Where Members have not yet been |Confirm that the organisation |Policy and procedures | Documentation | | Head office | Conformance |

|able to eliminate Facilitation |endeavours to eliminate all |Training materials and records|Observation | |Divisional/ Business |Minor NC |

|Payments, they will implement |facilitation payments, and that where |Clear information on legal |Testimonial | |unit |Major NC |

|appropriate controls to monitor, |they do occur, appropriate controls to|requirements and a system for |None | |Facility |Not Applicable |

|oversee and fully account for all|monitor, oversee and fully account for|updating | | |None |Reason: |

|Facilitation Payments made. They |the payments are implemented. |Policy and procedures | | |Details: | |

|will work to ensure that they are| |Relevant job descriptions | | | | |

|of limited nature and scope, with| |Training materials and records| | | | |

|an ultimate objective to | |Recording and monitoring | | | | |

|eliminate all Facilitation | |system for facilitation | | | | |

|Payments. | |payments, bribery attempts and| | | | |

| | |sanctions applied | | | | |

|Code of Practices Provisions |

|Members must maintain financial |Determine whether the business |Clear information on legal | Documentation | | Head office | Conformance |

|accounts of all business |maintains financial accounts of all |requirements and a system for |Observation | |Divisional/ Business |Minor NC |

|transactions where required by |relevant business transactions where |updating |Testimonial | |unit |Major NC |

|Applicable Law and in accordance |required by Applicable Law, and in |Policy and procedures |None | |Facility |Not Applicable |

|with national or international |accordance with national, and where |Relevant job descriptions | | |None |Reason: |

|accounting standards. These |appropriate, international accounting |Last financial audit report | | |Details: | |

|accounts must be independently |standards. |and auditor qualifications | | | | |

|certified and/or audited by a | |Customer identification | | | | |

|properly qualified auditor who is| |procedures | | | | |

|appointed free of any bias or | |Transaction monitoring and | | | | |

|influence. | |recording system, including | | | | |

| | |any correspondence with | | | | |

| | |authorities | | | | |

| |Determine whether the financial |Policy and procedures | Documentation | | Head office | Conformance |

| |accounts are annually independently |Last financial audit report |Observation | |Divisional/ Business |Minor NC |

| |certified and/or audited. |and auditor qualifications |Testimonial | |unit |Major NC |

| | |Training materials and records|None | |Facility |Not Applicable |

| | |Interviews with managers, | | |None |Reason: |

| | |buyers, contracting personnel | | |Details: | |

| | |and other relevant staff | | | | |

| |Confirm that audits are undertaken by |Last financial audit report | Documentation | | Head office | Conformance |

| |an appropriately qualified auditor, |and auditor qualifications |Observation | |Divisional/ Business |Minor NC |

| |and that the selection process |Auditor selection process and |Testimonial | |unit |Major NC |

| |appoints an auditor that is free of |records |None | |Facility |Not Applicable |

| |any bias or influence. | | | |None |Reason: |

| | | | | |Details: | |

|Members should be aware that |Determine whether there is a system to|Clear information on legal | Documentation | | Head office | Conformance |

|international transactions may be|identify the various jurisdictions |requirements and a system for |Observation | |Divisional/ Business |Minor NC |

|subject to more than one |encountered with each transaction, and|updating |Testimonial | |unit |Major NC |

|regulatory jurisdiction. |the associated regulatory |Policy and procedures |None | |Facility |Not Applicable |

|Where no Applicable Law exists, |requirements. |Relevant job descriptions | | |None |Reason: |

|Members should comply with the | | | | |Details: | |

|provisions in the Financial | | | | | | |

|Action Task Force (FATF) 40 | | | | | | |

|Recommendations and 9 Special | | | | | | |

|Recommendations as applicable to | | | | | | |

|dealers in Precious Metals and | | | | | | |

|gemstones under the Designated | | | | | | |

|Non-Financial Business | | | | | | |

|Professions (DNFBP). | | | | | | |

| | | | | | | |

|Cash or cash-like transactions | | | | | | |

|should always take place in | | | | | | |

|compliance with Applicable Law. | | | | | | |

|Where they occur above the | | | | | | |

|relevant defined financial | | | | | | |

|threshold, records need to be | | | | | | |

|lodged with the relevant | | | | | | |

|designated authority. | | | | | | |

| |Confirm that the business complies |FATF 40 Recommendations and 8 | Documentation | | Head office | Conformance |

| |with the relevant legislation relating|Special Recommendations as |Observation | |Divisional/ Business |Minor NC |

| |to international transactions, or, |applicable to the Designated |Testimonial | |unit |Major NC |

| |where no Applicable Law exists, the |Non-Financial Business |None | |Facility |Not Applicable |

| |provisions in the Financial Action |Professions (DNFBP) i.e. | | |None |Reason: |

| |Task Force (FATF) 40 Recommendations |dealers in Precious metals and| | |Details: | |

| |and 8 Special Recommendations as |gemstones | | | | |

| |applicable to the Designated |Financial Audit reports and | | | | |

| |Non-Financial Business Professions |auditor qualifications | | | | |

| |(DNFBP) i.e. dealers in Precious |Interviews with managers, | | | | |

| |metals and gemstones. |buyers, contracting personnel | | | | |

| | |and other relevant staff | | | | |

| |Confirm that cash or cash-like |Financial Audit reports and | Documentation | | Head office | Conformance |

| |transactions always take place in |auditor qualifications |Observation | |Divisional/ Business |Minor NC |

| |compliance with Applicable Law and are|Records of cash and cash-like |Testimonial | |unit |Major NC |

| |lodged with the designated authority |transactions |None | |Facility |Not Applicable |

| |if above the relevant defined |Records of correspondence with| | |None |Reason: |

| |financial threshold. |designated authorities | | |Details: | |

|Members must operate according to|Determine whether there is a system |Customer identification | Documentation | | Head office | Conformance |

|the principles of “know your |for checking the identity of all |procedures |Observation | |Divisional/ Business |Minor NC |

|customer” so as to establish the |suppliers and customers, and |Interviews with managers, |Testimonial | |unit |Major NC |

|identity of all organisations |monitoring for unusual transactions. |buyers, contracting personnel |None | |Facility |Not Applicable |

|with which they deal, have a | |and other relevant staff | | |None |Reason: |

|clear understanding of their | | | | |Details: | |

|business relationships and have a| | | | | | |

|reasonable ability to identify | | | | | | |

|and react to transaction patterns| | | | | | |

|appearing out of the ordinary or | | | | | | |

|suspicious. | | | | | | |

| |Confirm that there is a clear |Interviews with managers, | Documentation | | Head office | Conformance |

| |understanding of the business’ |buyers, contracting personnel |Observation | |Divisional/ Business |Minor NC |

| |relationships with these individuals |and other relevant staff |Testimonial | |unit |Major NC |

| |and organisations, and that the |Records of customer reviews |None | |Facility |Not Applicable |

| |operation has a reasonable ability to | | | |None |Reason: |

| |identify and react to transaction | | | |Details: | |

| |patterns appearing out of the ordinary| | | | | |

| |or suspicious. | | | | | |

|Code of Practices Provisions |

|Members must not knowingly buy or|Determine whether there are procedures|Policy and procedures | Documentation | | Head office | Conformance |

|sell Conflict Diamonds or assist |or systems in place to prevent the |Relevant job descriptions |Observation | |Divisional/ Business |Minor NC |

|others to do so. |purchase or sale of rough diamonds by |Recording and monitoring |Testimonial | |unit |Major NC |

| |employees or agents, without |system for invoices and |None | |Facility |(= Critical Breach) |

| |appropriate Kimberley Process |certificates of diamond | | |None |Not Applicable |

| |documentation. Procedures and systems|shipments | | |Details: |Reason: |

| |must comply with the Kimberley Process|Sample invoices and | | | | |

| |and relevant national legislation. |certificates | | | | |

| |This includes preventing the purchase |List of workers involved in | | | | |

| |of Conflict Diamonds from countries or|the buying and selling of | | | | |

| |regions that have not implemented the |diamonds | | | | |

| |Kimberley Process or are subject to a |Selection process for diamond | | | | |

| |governmental advisory that exports |suppliers | | | | |

| |from such regions are not in |Physical controls in relation | | | | |

| |conformance with the Kimberley |to the movement of diamonds | | | | |

| |Process. |Last KP audit report and | | | | |

| | |auditor qualifications | | | | |

| | |Training materials and records| | | | |

| | |Interviews with managers, | | | | |

| | |buyers, contracting personnel | | | | |

| | |and other relevant staff | | | | |

|Members, where involved with the |Determine whether there is a rigorous |Recording and monitoring | Documentation | | Head office | Conformance |

|international trade of rough |audit process to reconcile rough |system for invoices and |Observation | |Divisional/ Business |Minor NC |

|Diamonds must apply the rough |diamond trade records i.e. Kimberley |certificates of diamond |Testimonial | |unit |Major NC |

|Diamond export and import |Process Certificates (in and out). |shipments |None | |Facility |(= Critical Breach) |

|verification system and controls |Confirm that audits are conducted no |Training materials and records| | |None |Not Applicable |

|as laid out by the Kimberley |less than annually and by independent |Interviews with managers, | | |Details: |Reason: |

|Process Certification Scheme and |auditors. |buyers, contracting personnel | | | | |

|relevant national legislation. | |and other relevant staff | | | | |

|Members must keep records of | |Last KP audit report and | | | | |

|Kimberley Process Certificates | |auditor qualifications | | | | |

|for rough Diamonds. Kimberley | | | | | | |

|Process certificates must be | | | | | | |

|independently audited and | | | | | | |

|reconciled by a company’s own | | | | | | |

|independent auditor on an annual | | | | | | |

|basis. If asked for by a duly | | | | | | |

|authorised government agency, | | | | | | |

|these records must be able to | | | | | | |

|prove compliance with the | | | | | | |

|Kimberley Process. | | | | | | |

| |Determine whether these records are |Recording and monitoring | Documentation | | Head office | Conformance |

| |sufficient to prove compliance with |system for invoices and |Observation | |Divisional/ Business |Minor NC |

| |the Kimberley Process. |certificates of diamond |Testimonial | |unit |Major NC |

| | |shipments |None | |Facility |(= Critical Breach) |

| | | | | |None |Not Applicable |

| | | | | |Details: |Reason: |

|Members, where involved in buying|Determine whether there are procedures|Last KP audit report and | Documentation | | Head office | Conformance |

|and selling Diamonds, whether |or systems in place including the need|auditor qualifications |Observation | |Divisional/ Business |Minor NC |

|rough, polished or set in |to keep records, to prevent the |Records of WDC SoW |Testimonial | |unit |Major NC |

|Jewellery, must fully adhere to |purchase or sale of diamonds, whether |Recording and monitoring |None | |Facility |(= Critical Breach) |

|the principles of the “World |rough, polished or set in jewellery |system for invoices and | | |None |Not Applicable |

|Diamond Council Resolution on |without appropriate warranties in |certificates of diamond | | |Details: |Reason: |

|Industry Self-Regulation”. |accordance with the World Diamond |shipments | | | | |

|Members are required to have |Council System of Warranties. |Interviews with managers, | | | | |

|systems in place so that all | |buyers, contracting personnel | | | | |

|invoices for Diamonds, whether | |and other relevant staff | | | | |

|rough, polished or set in | |Invoices of diamond purchases | | | | |

|Jewellery, either bought or sold,| | | | | | |

|contain the World Diamond Council| | | | | | |

|warranty statement. Members must | | | | | | |

|keep records of all such | | | | | | |

|invoices. Members must have | | | | | | |

|systems in place so that they do | | | | | | |

|not purchase from sources that do| | | | | | |

|not provide the World Diamond | | | | | | |

|Council warranty statement on | | | | | | |

|their invoices. | | | | | | |

|Members will inform all Employees|Determine whether there is a system |Training materials and records| Documentation | | Head office | Conformance |

|that buy or sell Diamonds about |for educating employees that are |Interviews with managers, |Observation | |Divisional/ Business |Minor NC |

|government restrictions on the |involved in the buying and selling of |buyers, contracting personnel |Testimonial | |unit |Major NC |

|trade in Conflict Diamonds, the |diamonds. Verify that Employees have |and other relevant staff |None | |Facility |(= Critical Breach) |

|Kimberley Process Certification |a satisfactory understanding of the | | | |None |Not Applicable |

|Scheme and the World Diamond |Kimberley Process Certification Scheme| | | |Details: |Reason: |

|Council System of Warranties. |and government restrictions on the | | | | | |

| |trade in Conflict Diamonds and the WDC| | | | | |

| |System of Warranties. | | | | | |

|Code of Practices Provisions |

|Members will establish product |Confirm Members have implemented |Quality and/or security | Documentation | | Head office | Conformance |

|security measures within the |product security measures that protect|systems in place including |Observation | |Divisional/ Business |Minor NC |

|premises and during shipments to |products against theft, damage or |policy and procedures |Testimonial | |unit |Major NC |

|protect against product theft, |substitution, whilst the products are |Relevant job descriptions |None | |Facility |Not Applicable |

|damage or substitution. |on site or during shipments. |Interviews with management | | |None |Reason: |

| | |Incident reports focussing on | | |Details: | |

| | |below satisfactory physical | | | | |

| | |integrity of product shipment | | | | |

| | |and/or related breaches to | | | | |

| | |security (e.g. tampering, | | | | |

| | |theft, etc) | | | | |

| | |Insurance premiums (e.g. an | | | | |

| | |increasing trend (over time) | | | | |

| | |from claims submitted because | | | | |

| | |of security incidents) | | | | |

|The security and well being of |Confirm that the Member prioritises |Policy and procedures | Documentation | | Head office | Conformance |

|Employees, Visitors and other |the security of Employees, Contractors|Interviews with management |Observation | |Divisional/ Business |Minor NC |

|relevant Business Partners shall |working in the Facilities, visitors |Risk Assessments and controls |Testimonial | |unit |Major NC |

|be prioritised when establishing |including customers to the Facilities,|regarding security and |None | |Facility |Not Applicable |

|product security measures. |and other affected stakeholders, when |wellbeing of Employees, | | |None |Reason: |

| |implementing reasonable precautionary |Contractors, visitors | | |Details: | |

| |product security measures, to prevent |including customers to the | | | | |

| |product theft, damage or substitution,|Facilities, and other affected| | | | |

| |whilst on the premises and during |stakeholders, | | | | |

| |shipments. | | | | | |

|Code of Practices Provisions |

|General: Members will at all |Determine that the business identifies |Up to date register or list | Documentation | | Head office | Conformance |

|times comply with relevant |and complies with relevant local, |(database) of legal & other |Observation | |Divisional/ Business |Minor NC |

|trading standards legislation |national and global trading standards |requirements |Testimonial | |unit |Major NC |

|and, where they exist, specific |and legislation that is specifically |Access to legal advice though|None | |Facility |(= Critical Breach) |

|national and/or local regulations|applicable to its diamond and gold |subscriptions or legal firms | | |None |Not Applicable |

|applicable to Diamond and Gold |jewellery products. |regarding trading practices | | |Details: |Reason: |

|Jewellery products. Where no | |Periodic compliance | | | | |

|specific trading standards or | |evaluation assessments | | | | |

|product integrity regulations | | | | | | |

|apply, Members must comply with | | | | | | |

|the requirements listed below. | | | | | | |

| |Confirm that the business adopts the |Implementation of CIBJO | Documentation | | Head office | Conformance |

| |Code of Practices ‘Product Integrity’ |regulations in policies and |Observation | |Divisional/ Business |Minor NC |

| |provisions where there is no local |procedures |Testimonial | |unit |Major NC |

| |applicable law. | |None | |Facility |(= Critical Breach) |

| | | | | |None |Not Applicable |

| | | | | |Details: |Reason: |

|Proper Disclosure: Members must |Confirm that gold, diamonds and gold |Product disclosure statements| Documentation | | Head office | Conformance |

|make all reasonable efforts to |and/or diamond jewellery products |Inventory records for gold, |Observation | |Divisional/ Business |Minor NC |

|properly disclose all relevant |purchased or sold have appropriate |treated diamonds, synthetic |Testimonial | |unit |Major NC |

|information on the physical |product disclosure including applicable |diamonds, diamond simulants |None | |Facility |(= Critical Breach) |

|characteristics, such as |information on: |and diamond quality | | |None |Not Applicable |

|mass/weight, cut, colour, clarity|Mass/weight |Interviews with management, | | |Details: |Reason: |

|or fineness, of a Diamond or Gold|Cut |buyers, sales staff and | | | | |

|Jewellery product. |Colour |relevant agents | | | | |

| |Clarity/fineness. |Approval processes for | | | | |

| | |development of sales material| | | | |

| | |Legal advice | | | | |

|Misrepresentation: Members will |Determine that information used for | | Documentation | | Head office | Conformance |

|not make any untruthful, |selling, advertising or distribution of | |Observation | |Divisional/ Business |Minor NC |

|misleading or deceptive |Diamond and/or Gold products is not | |Testimonial | |unit |Major NC |

|statement, representation or |misleading, untruthful or deceptive, or | |None | |Facility |(= Critical Breach) |

|material omission in the selling,|that that material information has not | | | |None |Not Applicable |

|advertising or distribution of |been omitted. | | | |Details: |Reason: |

|any Diamond, Treated Diamond, | | | | | | |

|Synthetic or Simulant, or any | | | | | | |

|Gold product, in any medium, | | | | | | |

|including the Internet. | | | | | | |

|Gold: |Confirm that the gold fineness is |Product disclosure statements| Documentation | | Head office | Conformance |

|Members will accurately disclose |accurately disclosed for gold products. |Inventory records for gold |Observation | |Divisional/ Business |Minor NC |

|the fineness of the Gold used in | |sources and products |Testimonial | |unit |Major NC |

|their products. | |Records for gold sources and |None | |Facility |(= Critical Breach) |

|When applying Gold Quality Marks | |products | | |None |Not Applicable |

|to articles wholly or in part | |Product disclosure statements| | |Details: |Reason: |

|composed of Gold, Members will | | | | | | |

|apply a Mark authorised to be | | | | | | |

|applied thereto under Applicable | | | | | | |

|Law that correctly indicates the | | | | | | |

|quality of the Gold of which the | | | | | | |

|article is in whole or in part | | | | | | |

|composed. The Mark will be | | | | | | |

|applied in a manner authorised by| | | | | | |

|Applicable Law or relevant | | | | | | |

|international standards. | | | | | | |

| |Confirm that when applying Gold Quality |Product disclosure statements| Documentation | | Head office | Conformance |

| |Marks to gold products, the Mark is |Inventory records for gold |Observation | |Divisional/ Business |Minor NC |

| |authorised to be applied and accurately |sources and products |Testimonial | |unit |Major NC |

| |indicates gold quality. |Interviews with management, |None | |Facility |(= Critical Breach) |

| | |buyers, sales staff and | | |None |Not Applicable |

| | |relevant agents | | |Details: |Reason: |

| | |Inventory records for gold | | | | |

| | |sources and products | | | | |

| | |Product disclosure statements| | | | |

|Treated diamonds |Confirm that treated diamonds are |Procedures for identification| Documentation | | Head office | Conformance |

|A Treated Diamond must be |properly disclosed as such, including to|and product representation of|Observation | |Divisional/ Business |Minor NC |

|disclosed as either “Treated” or |always have the word “diamond” preceded |treated diamonds |Testimonial | |unit |Major NC |

|with specific reference to the |by the word “treated”, the nature of the|Product statements and |None | |Facility |(= Critical Breach) |

|particular Treatment. The |treatment and any special care |advertisements | | |None |Not Applicable |

|description must be as equally |requirements. Confirm that the treated |Qualified independent | | |Details: |Reason: |

|conspicuous and placed |diamond product information does not |assessments | | | | |

|immediately preceding the word(s)|mislead or incorrectly represent the |Checking/testing of | | | | |

|“Diamond” or “Synthetic”, as the |product. |procedures | | | | |

|case may be. Specifically: | | | | | | |

|Any term that is designed to | | | | | | |

|disguise that Treatment has | | | | | | |

|occurred, or to imply that a | | | | | | |

|Treatment is part of the normal | | | | | | |

|polishing process, or that | | | | | | |

|misleads the consumer in any way,| | | | | | |

|must not be used. For example, | | | | | | |

|the term “improved” must not be | | | | | | |

|used to describe a Treated | | | | | | |

|Diamond. | | | | | | |

|Any special care requirements | | | | | | |

|that the Treatment creates must | | | | | | |

|be disclosed. | | | | | | |

|Names of firms, manufacturers or |Confirm that the term “treated diamond” |Procedures for identification| Documentation | | Head office | Conformance |

|trademarks are not to be used in |is clearly associated with any use of |and product representation of|Observation | |Divisional/ Business |Minor NC |

|connection with Treated Diamonds,|the names of firms, manufacturers or |treated diamonds |Testimonial | |unit |Major NC |

|unless such names are clearly |trademarks used to describe treated |Product information |None | |Facility |(= Critical Breach) |

|succeeded by the word “Treated” |diamonds. | | | |None |Not Applicable |

|as defined in this section or are| | | | |Details: |Reason: |

|otherwise equally conspicuously | | | | | | |

|and prominently disclosed as | | | | | | |

|Treated. | | | | | | |

|Synthetic diamonds |Confirm that Synthetic diamonds (whether|Procedures for identification| Documentation | | Head office | Conformance |

|A wholly or partially Synthetic |wholly or partially) are properly |and product representation of|Observation | |Divisional/ Business |Minor NC |

|diamond must always be disclosed |disclosed as such and always have the |synthetic diamonds |Testimonial | |unit |Major NC |

|as “laboratory created”, |word “diamond” preceded by words such |Product information |None | |Facility |(= Critical Breach) |

|“laboratory grown”, “man-made”, |as: |Product statements and | | |None |Not Applicable |

|“[Manufacturer’s name] created”, |Synthetic |advertisements | | |Details: |Reason: |

|and/or “Synthetic” and the |Laboratory Created or Grown | | | | | |

|description must be equally as |Man-made | | | | | |

|conspicuous and immediately |[Manufacturer name] created | | | | | |

|preceding the word “diamond”. | | | | | | |

| |Confirm that there are effective | | | | | |

| |procedures or systems that specifically | | | | | |

| |prohibit the use of the terms including | | | | | |

| |but not limited to the following when | | | | | |

| |representing synthetic diamonds: | | | | | |

| |Natural | | | | | |

| |Real | | | | | |

| |Genuine. | | | | | |

|Members will not use the words |Confirm that synthetic diamond products |Procedures for identification| Documentation | | Head office | Conformance |

|“real”, “genuine” or “natural” to|are clearly identifiable and |and product representation of|Observation | |Divisional/ Business |Minor NC |

|describe any Synthetic, or any |distinguishable by the product |synthetic diamonds |Testimonial | |unit |Major NC |

|terms that may disguise the fact |statements from ‘natural’ or ‘mined’ |Product information |None | |Facility |(= Critical Breach) |

|that a diamond is Synthetic or |diamond products, and that terms are not|Product statements and | | |None |Not Applicable |

|that mislead the consumer in any |used that may mislead the consumer in |advertisements | | |Details: |Reason: |

|way. |any way. | | | | | |

|Diamond Simulants |Confirm that diamond simulants are |Procedures for identification| Documentation | | Head office | Conformance |

|Members must always disclose a |properly disclosed and always have the |and product representation of|Observation | |Divisional/ Business |Minor NC |

|Simulant either as the mineral or|word “diamond” preceded by words such |diamond simulants |Testimonial | |unit |Major NC |

|compound that it is, or as a |as: |Product statements and |None | |Facility |(= Critical Breach) |

|“diamond Simulant” or “imitation |Simulant |advertisements | | |None |Not Applicable |

|diamond”. The unqualified word |Imitation | | | |Details: |Reason: |

|“Diamond” must never be used with| | | | | | |

|Simulants. |Confirm that there are effective | | | | | |

|Members will not use the words |procedures or systems that specifically | | | | | |

|“real” and “genuine” to describe |prohibit the use of the terms including | | | | | |

|any Simulant. |but not limited to the following when | | | | | |

|Members will not use the word |representing simulant diamonds: | | | | | |

|“natural” to describe any |Real | | | | | |

|Simulant if the Simulant is not a|Genuine | | | | | |

|naturally occurring mineral or |Naturally occurring mineral or compound | | | | | |

|compound. | | | | | | |

|Diamond Quality – Cut and |Determine whether the business |Up to date register or list | Documentation | | Head office | Conformance |

|Polished Diamonds |identifies and complies with recognised |(database) of legal & other |Observation | |Divisional/ Business |Minor NC |

|Members when describing the |guidelines applicable to the description|requirements |Testimonial | |unit |Major NC |

|weight, colour, clarity or cut of|of cut and polished diamonds, in terms |Access to legal advice though|None | |Facility |(= Critical Breach) |

|Diamonds will at all times do so |of: |subscriptions or legal firms | | |None |Not Applicable |

|in accordance with the recognised|Weight |regarding trading practices | | |Details: |Reason: |

|guidelines appropriate to the |Colour |Product statements and | | | | |

|particular jurisdiction. |Clarity or |advertisements | | | | |

| |Cut | | | | | |

|Members will not use the word |Confirm that there are effective |Procedures for identification| Documentation | | Head office | Conformance |

|“flawless” or “perfect” to |procedures or systems that specifically |and product representation of|Observation | |Divisional/ Business |Minor NC |

|describe either: |prohibit the use of the terms “flawless”|diamonds and diamond products|Testimonial | |unit |Major NC |

|any Diamond that discloses flaws,|or “perfect” when representing diamond |Product statements and |None | |Facility |(= Critical Breach) |

|cracks, inclusions, carbon spots,|products that when viewed under |advertisements | | |None |Not Applicable |

|clouds, internal lasering, or |magnification at 10 power, have any of | | | |Details: |Reason: |

|other blemishes or imperfections |the following imperfections: | | | | | |

|of any sort when examined under a|Flaws | | | | | |

|corrected magnifier at 10-power, |Cracks | | | | | |

|with adequate illumination by a |Inclusions | | | | | |

|person skilled in Diamond |Carbon spots | | | | | |

|grading; or |Clouds | | | | | |

|any article of jewellery that |Internal lasering | | | | | |

|contains any Diamonds that do not|Blemishes | | | | | |

|meet the definition of “flawless”| | | | | | |

|or “perfect”. | | | | | | |

|Members will not use the terms |Confirm that these procedures or systems|Procedures for identification| Documentation | | Head office | Conformance |

|“brilliant”, “brilliant cut” or |only permit the use of the terms |and product representation of|Observation | |Divisional/ Business |Minor NC |

|“full cut” to describe, identify |“brilliant”, “brilliant cut” or “full |diamonds and diamond products|Testimonial | |unit |Major NC |

|or refer to any Diamond except a |cut” specifically for a round diamond |Product statements and |None | |Facility |(= Critical Breach) |

|round Diamond that has at least |that has at least 32 facets plus the |advertisements | | |None |Not Applicable |

|32 facets plus the table above |table above the girdle, and at least 24 | | | |Details: |Reason: |

|the girdle, and at least 24 |facets below it. | | | | | |

|facets below it. | | | | | | |

|Code of Practices Provisions |

|Members with Mining Facilities |Verify that Members with Mining |Policies and procedures | Documentation | | Head office | Conformance |

|will commit to and support |Facilities have committed to and |Public declaration supporting |Observation | |Divisional/ Business |Minor NC |

|implementation of the Extractive |support implementation of the |EITI Principles and Criteria |Testimonial | |unit |Major NC |

|Industries Transparency |Extractive Industries Transparency |EITI Self Assessment |None | |Facility |Not Applicable |

|Initiative (EITI). |Initiative (EITI). |International-level Company | | |None |Reason: |

| | |Self-Assessment Form | | |Details: | |

| | |Annual contribution to the | | | | |

| | |international management of | | | | |

| | |the EITI | | | | |

|Code of Practices Provisions |

|Members shall at all times |Determine whether the business has |Access to the United Nations | Documentation | | Head office | Conformance |

|respect the fundamental human |identified, is knowledgeable of and |Universal Declaration of |Observation | |Divisional/ Business |Minor NC |

|rights and the dignity of the |complies with the articles from the |Human Rights |Testimonial | |unit |Major NC |

|individual, according to the |United Nations Universal Declaration of |Training records |None | |Facility |Not Applicable |

|United Nations Universal |Human Rights that are applicable to its |Meeting minutes | | |None |Reason: |

|Declaration of Human Rights. |business, to that ensure fundamental |Personal files/records of | | |Details: | |

| |human rights and the dignity of the |individuals | | | | |

| |individual are respected at all times. |Incident/CAR reports | | | | |

| | |Enforcement actions against | | | | |

| | |Members in relation to Human | | | | |

| | |Rights | | | | |

| | |Interviews with Human | | | | |

| | |Resources department | | | | |

|Code of Practices Provisions |

|Members shall not engage in or |Determine whether there is a policy |Policy and procedures | Documentation | | Head office | Conformance |

|support the employment of |and/or a system to prevent engaging in |Relevant job descriptions |Observation | |Divisional/ Business |Minor NC |

|Children (younger than 15 years, |or supporting the employment of Children| |Testimonial | |unit |Major NC |

|or 14 years where the law of the |(younger than 15 years, or 14 years | |None | |Facility |(= Critical Breach) |

|country permits) beyond those |where the law of the country permits). | | | |None |Not Applicable |

|circumstances defined in ILO | | | | |Details: |Reason: |

|Convention 138 and Recommendation| | | | | | |

|146 unless sanctioned by national| | | | | | |

|and/or local government or as | | | | | | |

|part of a recognised apprentice | | | | | | |

|scheme, in accordance with the | | | | | | |

|guidelines laid down in the | | | | | | |

|Global Compact. | | | | | | |

| |Confirm that there are effective systems|Policy and procedures | Documentation | | Head office | Conformance |

| |supported by procedures, practices and |Site visits and observations |Observation | |Divisional/ Business |Minor NC |

| |written agreements with contractors that|Interviews with management, |Testimonial | |unit |Major NC |

| |prevent the employment of Children, |workers, labour contractors |None | |Facility |(= Critical Breach) |

| |including an effective mechanism for |and management and other | | |None |Not Applicable |

| |verifying age prior to recruitment, |stakeholders | | |Details: |Reason: |

| |maintaining copies of documentary |Recruitment records | | | | |

| |evidence on file, and investigating |Evidence of age | | | | |

| |potential discrepancies. |Interviews with management, | | | | |

| | |and contractors | | | | |

|Where any Children are found to |Where children have been found to be |Employee age records | Documentation | | Head office | Conformance |

|be in employment, Members shall |working within the business, determine |Rosters and records of |Observation | |Divisional/ Business |Minor NC |

|provide adequate support to |whether there is an effective phased |working hours and wages |Testimonial | |unit |Major NC |

|enable them to attend and remain |remediation process that ensures the |Labour contractors’ policies |None | |Facility |Not Applicable |

|in school until no longer a |continued welfare of each Child employed|and/or contracts | | |None |Reason: |

|Child. Child Labour Remediation |and their family, that the work does not|Site visits and observations | | |Details: | |

|processes shall include steps for|interfere with schooling, and that a | | | | | |

|the continued welfare of the |structured educational program is | | | | | |

|Child and consider the financial |supported. Confirm that any child | | | | | |

|situation of the Child’s family. |workers found to be in employment | | | | | |

|Children found to be in |receive fair payment for their work, at | | | | | |

|employment contrary to minimum |least 12 hours nightly rest time and | | | | | |

|age requirements may remain in |weekly rest days, and do not work | | | | | |

|partial employment during a |overtime. | | | | | |

|phased Remediation process. | | | | | | |

|Members shall provide a minimum | | | | | | |

|period of night time rest of 12 | | | | | | |

|hours, with customary weekly rest| | | | | | |

|days; and ensure that overtime is| | | | | | |

|prohibited and the Child receives| | | | | | |

|fair payment for the work he or | | | | | | |

|she is undertaking. | | | | | | |

|Members shall promote education |Confirm that where young persons are |Interviews with management, | Documentation | | Head office | Conformance |

|for Children covered under ILO |employed, they are employed according to|workers, labour contractors |Observation | |Divisional/ Business |Minor NC |

|recommendation 146 and Young |the requirements of Applicable Law, or |and management and other |Testimonial | |unit |Major NC |

|Persons who are subject to local |if no such law exists, the provisions of|stakeholders |None | |Facility |(= Critical Breach) |

|compulsory education laws or |ILO Convention 138 and Recommendation |Where applicable, evidence | | |None |Not Applicable |

|attending school, including means|146. |for budgeted funds towards | | |Details: |Reason: |

|to ensure that no such Child or | |education programs | | | | |

|Young Person is employed during | |Contributions to Community | | | | |

|school hours and that combined | |development programs | | | | |

|hours of daily transportation (to| | | | | | |

|and from work and school), school| | | | | | |

|and work time does not exceed 10 | | | | | | |

|hours a day. | | | | | | |

|Members shall not expose a Child |Determine whether hazardous work areas |Regulatory requirements | Documentation | | Head office | Conformance |

|or Young Person to work, which by|and activities have been identified, |Personnel records – evidence |Observation | |Divisional/ Business |Minor NC |

|its nature or the circumstances |that workers are mapped against tasks by|of age |Testimonial | |unit |Major NC |

|in which it is carried out, is |age, and that there are no young persons|Rosters and records of |None | |Facility |(= Critical Breach) |

|likely to jeopardise the Health, |under the age of 18 (or 16 under strict |working hours and wages | | |None |Not Applicable |

|Safety or morals of persons |conditions) engaged in ‘hazardous work’.|Labour contractors’ policies | | |Details: |Reason: |

|younger than 18 years (or 16 | |and/or contracts | | | | |

|years subject to authorisation in| |Specific documents relating | | | | |

|Applicable Law and the receipt of| |to hazardous work | | | | |

|adequate and specific instruction| | | | | | |

|or vocational training in the | | | | | | |

|relevant branch of activity). | | | | | | |

|Code of Practices Provisions |

|Members will not use Forced |Confirm that the business does not use |Policy and procedures | Documentation | | Head office | Conformance |

|Labour (including bonded, |Forced Labour (including bonded, |Relevant job descriptions |Observation | |Divisional/ Business |Minor NC |

|indentured or prison labour), nor|indentured or prison labour) or restrict|Employees’ contracts |Testimonial | |unit |Major NC |

|restrict the freedom of movement |the freedom of movement of employees. |Employee documentation |None | |Facility |(= Critical Breach) |

|of Employees. | |records to confirm not | | |None |Not Applicable |

| | |originals | | |Details: |Reason: |

| | |Loan and/or charging records | | | | |

| | |for accommodation and other | | | | |

| | |services | | | | |

| | |Wage payment procedures and | | | | |

| | |records | | | | |

| | |Mechanism for anonymously | | | | |

| | |reporting instances of | | | | |

| | |threats, violence or other | | | | |

| | |infringements of policy | | | | |

| | |Labour contractors’ and | | | | |

| | |security firms’ policies | | | | |

| | |and/or contracts | | | | |

|Members will not retain original |Confirm that the business does not |Policy and procedures | Documentation | | Head office | Conformance |

|copies of Employee personal |retain any original personal |Employee documentation |Observation | |Divisional/ Business |Minor NC |

|documentation, such as identity |documentation belonging to workers (such|records to confirm not |Testimonial | |unit |Major NC |

|papers, nor require any form of |as passports or other official proof of |originals |None | |Facility |Not Applicable |

|deposit, recruitment fee, or |identity) during the course of their |Discussions with workers | | |None |Reason: |

|equipment advance from Employees |employment, other than by specific legal|Interviews with management, | | |Details: | |

|either directly or through |requirement, nor require any form of |workers, contractors | | | | |

|recruitment agencies. |deposit, recruitment fee, or equipment |including security personnel | | | | |

| |advance from Employees either directly |and stakeholders | | | | |

| |or through recruitment agencies |Site visits and observations,| | | | |

| | |including any on-site worker | | | | |

| | |accommodation | | | | |

| | |Recruitment procedures for | | | | |

| | |migrant workers | | | | |

| | |Discussions with migrant | | | | |

| | |workers | | | | |

| | |Records of agency reviews | | | | |

|Code of Practices Provisions |

|Members will not prevent |Determine whether Employees are afforded|Processes in place for | Documentation | | Head office | Conformance |

|Employees from associating |the freedom and means to associate |workforce consultation |Observation | |Divisional/ Business |Minor NC |

|freely. Where laws prohibit these|freely through either unions or parallel|List of workers by employment|Testimonial | |unit |Major NC |

|freedoms, Members will support |means for independent and free |type and contract |None | |Facility |Not Applicable |

|parallel means for independent |association and bargaining. |Interviews with management, | | |None |Reason: |

|and free association and | |workers, and union | | |Details: | |

|bargaining. | |representatives | | | | |

|Members will not prevent |Determine whether workers are afforded |Collective agreement/s in | Documentation | | Head office | Conformance |

|collective bargaining and shall |the freedom and means to collectively |negotiation and/or in force |Observation | |Divisional/ Business |Minor NC |

|adhere to collective bargaining |bargain and to participate in collective|Interviews with management, |Testimonial | |unit |Major NC |

|agreements, where such agreements|bargaining agreements in place. |workers, and union |None | |Facility |Not Applicable |

|exist. | |representatives | | |None |Reason: |

| | | | | |Details: | |

| |Where collective agreements exist, |Records of grievance | Documentation | | Head office | Conformance |

| |confirm that they are adhered to. |procedures |Observation | |Divisional/ Business |Minor NC |

| | |Interviews with management, |Testimonial | |unit |Major NC |

| | |workers, and union |None | |Facility |Not Applicable |

| | |representatives | | |None |Reason: |

| | | | | |Details: | |

|Code of Practices Provisions |

|Members shall not practice or condone|Determine whether there is a system|Policy and procedures | Documentation | | Head office | Conformance |

|any form of discrimination in the |to prevent discrimination in the |Relevant job descriptions |Observation | |Divisional/ Business |Minor NC |

|workplace in terms of hiring, |workplace and a mechanism which |List of workers by gender (and|Testimonial | |unit |Major NC |

|remuneration, overtime, access to |ensures that all individuals who |other relevant diversity |None | |Facility |Not Applicable |

|training, promotion, termination or |are Fit for Work are accorded equal|issues), role and pay | | |None |Reason: |

|retirement based on race, ethnicity, |opportunities and are not |Site visits and observations | | |Details: | |

|caste, national origin, religion, |discriminated against on the basis |Interviews with management, | | | | |

|disability, gender, sexual |of factors unrelated to their |targeted selection of workers | | | | |

|orientation, union membership, |ability to perform their job. |and contractors | | | | |

|political affiliation, marital | |Records of training and | | | | |

|status, pregnancy status, physical | |awareness programs | | | | |

|appearance, HIV status, or age, or | |Procedure for confidential | | | | |

|any other applicable prohibited | |raising of grievances | | | | |

|basis, such that all individuals who | |associated with discrimination| | | | |

|are “Fit for Work” are accorded equal| |or harassment | | | | |

|opportunities and are not | | | | | | |

|discriminated against on the basis of| | | | | | |

|factors unrelated to their ability to| | | | | | |

|perform their job | | | | | | |

| |Confirm that the systems are |Site visits and observations | Documentation | | Head office | Conformance |

| |communicated to and understood by |Interviews with management, |Observation | |Divisional/ Business |Minor NC |

| |personnel, and are effectively |targeted selection of workers |Testimonial | |unit |Major NC |

| |implemented. |and contractors |None | |Facility |Not Applicable |

| | | | | |None |Reason: |

| | | | | |Details: | |

|Code of Practices Provisions |

|Members will provide safe and |Confirm that the workplace |Site visits and workplace | Documentation | | Head office | Conformance |

|healthy working conditions for |environment complies with Applicable |inspections |Observation | |Divisional/ Business |Minor NC |

|all Employees in accordance with |Law and relevant industry standards |Interviews with management, |Testimonial | |unit |Major NC |

|Applicable Law and other relevant|such that it is safe to conduct work |workers, contractors and |None | |Facility |Not Applicable |

|industry standards. These |related activities. Determine how |stakeholders | | |None |Reason: |

|conditions include: |effective systems and controls are to|Policy and procedures | | |Details: | |

| |ensure that legal requirements |Relevant job descriptions for | | | | |

| |relating to ambient workplace |health and safety, emergency, | | | | |

| |environment (chemical exposure, |and first aid personnel | | | | |

| |noise, air temperature, air quality, |Appropriately qualified senior | | | | |

| |lighting, ventilation, etc) are |manager responsible, for the | | | | |

| |adhered to. |health and safety of all | | | | |

| | |employees at work | | | | |

|minimising, so far as reasonably |Determine whether there is an |Risk assessments | Documentation | | Head office | Conformance |

|practicable, the causes of |effective method to identify and |Site visits and workplace |Observation | |Divisional/ Business |Minor NC |

|workplace Hazards. |minimise, so far as reasonably |inspections |Testimonial | |unit |Major NC |

| |practicable, workplace hazards. |Interviews with management, |None | |Facility |Not Applicable |

| | |workers, contractors and | | |None |Reason: |

| | |stakeholders | | |Details: | |

|appropriate safeguards and |Confirm that sufficient and |Policy and procedures | Documentation | | Head office | Conformance |

|isolation between Employees and |appropriate machine safety guards and|Machine guards |Observation | |Divisional/ Business |Minor NC |

|all machinery including mobile |isolation measures are installed and |Isolation methods including |Testimonial | |unit |Major NC |

|equipment. |used correctly. |permitting procedures |None | |Facility |Not Applicable |

| | |Inspections and audits. | | |None |Reason: |

| | | | | |Details: | |

|adequate and appropriate |Confirm that chemicals including |Manifest of all hazardous | Documentation | | Head office | Conformance |

|labelling and storage of all |cleaning materials have been |substances |Observation | |Divisional/ Business |Minor NC |

|chemicals and cleaning materials.|identified, and adequately labelled |Clear signage and labels on all |Testimonial | |unit |Major NC |

| |and stored. |containers |None | |Facility |Not Applicable |

| | | | | |None |Reason: |

| | | | | |Details: | |

|methods to protect Employees from|Determine whether workplaces are |Dust/fume extraction systems | Documentation | | Head office | Conformance |

|exposure to airborne particles |adequately constructed and |Masks and respirators (as |Observation | |Divisional/ Business |Minor NC |

|and chemical fumes. |maintained, with systems and controls|required) |Testimonial | |unit |Major NC |

| |in place to ensure that workers are |Dust suppression controls |None | |Facility |Not Applicable |

| |protected from chemical exposure, air| | | |None |Reason: |

| |borne particles and chemical fumes. | | | |Details: | |

|identifying and providing |Confirm that basic PPE is available |Gloves, safety footwear, | Documentation | | Head office | Conformance |

|appropriate Personal Protective |free of charge for employees and |goggles, helmets, hearing |Observation | |Divisional/ Business |Minor NC |

|Equipment (PPE) free of charge |on-site contractors, and that it is |protection, etc |Testimonial | |unit |Major NC |

|and verifying that it is current,|current, properly used and worn. |PPE compliance assessments |None | |Facility |Not Applicable |

|worn and used correctly. | |PPE storage facilities | | |None |Reason: |

| | | | | |Details: | |

|providing work stations that are |Confirm that all workspaces are fit |Workspace design codes and | Documentation | | Head office | Conformance |

|designed as appropriate to the |for the job, and designed with |reviews |Observation | |Divisional/ Business |Minor NC |

|task performed, to minimise |appropriate safety measures, |Safety measures include lifting |Testimonial | |unit |Major NC |

|occupational Health Risks such as|particularly with regard to minimise |devices, ergonomic setup |None | |Facility |Not Applicable |

|repetitive strain. |occupational health risks such as |adequate space and storage, as | | |None |Reason: |

| |repetitive strain. |required | | |Details: | |

| | |Records of occupational illness | | | | |

| | |especially repetitive strains | | | | |

| | |and injuries | | | | |

| | |Site visits and workplace | | | | |

| | |inspections including | | | | |

| | |housekeeping checks | | | | |

|adequate lighting, ventilation |Determine whether workplace |Building approvals or regulator | Documentation | | Head office | Conformance |

|and air quality; safe noise |temperature, noise, light, |certifications |Observation | |Divisional/ Business |Minor NC |

|levels and temperatures. |cleanliness, vibration and |Site visits and workplace |Testimonial | |unit |Major NC |

| |ventilation levels are appropriate to|inspections including |None | |Facility |Not Applicable |

| |perform tasks safely (given the |housekeeping checks | | |None |Reason: |

| |requirements of the operation). |Facilities for extracting and or| | |Details: | |

| | |neutralising dust and fumes | | | | |

| | |Background and task lighting, as| | | | |

| | |appropriate | | | | |

| | |Functional, heating & cooling | | | | |

| | |equipment | | | | |

| | |System for identifying, | | | | |

| | |accessing and checking | | | | |

| | |compliance with regulatory | | | | |

| | |requirements | | | | |

|maintaining adequate workplace |Confirm that the entire workforce has|Cleaning regimes | Documentation | | Head office | Conformance |

|hygiene at all times by |access to an appropriate standard of |Site visits and workplace |Observation | |Divisional/ Business |Minor NC |

|conducting regular routine |hygiene by providing: |inspections |Testimonial | |unit |Major NC |

|cleaning, providing safe and |a regular and effective cleaning |Ablution facilities, |None | |Facility |Not Applicable |

|accessible potable drinking water|regime |Kitchens and food storage | | |None |Reason: |

|and sanitary facilities for food |safe drinking water and adequate |facilities | | |Details: | |

|storage, and clean and hygienic |means of safely storing food are |Potable water in work areas. | | | | |

|washing and toilet facilities |easily accessible to all employees; | | | | | |

|commensurate with the number and |and | | | | | |

|gender of staff employed. |sanitation facilities including | | | | | |

| |ablution and bathrooms that are clean| | | | | |

| |and well-maintained, and that these | | | | | |

| |are sufficient for the number and | | | | | |

| |gender of staff employed.. | | | | | |

|providing adequately constructed |Determine whether workplaces are |Building approvals or regulator | Documentation | | Head office | Conformance |

|and maintained workplaces that |adequately constructed and maintained|certifications |Observation | |Divisional/ Business |Minor NC |

|meet local building regulations. |to meet local building and |Site visits and workplace |Testimonial | |unit |Major NC |

| |occupational health & safety |inspections |None | |Facility |Not Applicable |

| |regulations. | | | |None |Reason: |

| | | | | |Details: | |

|ensuring that if Employees are |Confirm that on-site housing offered |Building approvals or regulator | Documentation | | Head office | Conformance |

|provided with on-site housing by |to employees are in a condition that |certifications |Observation | |Divisional/ Business |Minor NC |

|Members, such housing will be |is safe to occupy, clean and |Site visits and workplace |Testimonial | |unit |Major NC |

|maintained to a reasonable |hygienic, has potable water, |inspections |None | |Facility |Not Applicable |

|standard of Safety, repair and |sufficient and proper sanitation | | | |None |Reason: |

|hygiene; and provided with |facilities and adequate power supply.| | | |Details: | |

|sufficient and proper sanitation | | | | | | |

|facilities, potable water and | | | | | | |

|access to adequate power supply. | | | | | | |

|Members who are engaged in the |For processes engaged in the cutting |Material Data Safety Sheets | Documentation | | Head office | Conformance |

|cutting and polishing of Diamonds|and polishing of diamonds, ensure |Policies and Procedures |Observation | |Divisional/ Business |Minor NC |

|will use cobalt-free |that cobalt-free diamond-impregnated | |Testimonial | |unit |Major NC |

|Diamond-impregnated scaifes. |scaifes are used. | |None | |Facility |Not Applicable |

| | | | | |None |Reason: |

| | | | | |Details: | |

|Members will provide Employees |Determine whether there is a formal |Interviews with management, | Documentation |Site visits and workplace inspections| Head office | Conformance |

|with a mechanism, such as a joint|process for employees to discuss, |workers, contractors and |Observation |Material Safety Data Sheets for |Divisional/ Business |Minor NC |

|Health and Safety committee, by |review and manage health and safety |stakeholders |Testimonial |hazardous substances on site |unit |Major NC |

|which they can raise and discuss |issues, or to raise concerns with |Minutes of Health & Safety |None |Records relating to ozone depleting |Facility |Not Applicable |

|Health and Safety issues with |management, such as via a trade union|Committee meetings (or | |substances as defined in the Montreal|None |Reason: |

|management. |or a health and safety committee. |equivalent) showing employee and| |Protocol |Details: | |

| | |management participation | | | | |

|Members will make information |Determine whether personnel are aware|Interviews with management, | Documentation | | Head office | Conformance |

|about Health and Safety available|of specific work place hazards and |workers, contractors and |Observation | |Divisional/ Business |Minor NC |

|to Employees in an understandable|risks and the precautionary methods |stakeholders |Testimonial | |unit |Major NC |

|form and in an appropriate |in place to avoid such hazards. |Workplace inspections |None | |Facility |Not Applicable |

|language. Material Safety Data | | | | |None |Reason: |

|Sheets (or equivalent necessary | | | | |Details: | |

|information) will be accessible | | | | | | |

|where all Hazardous Substances | | | | | | |

|are in use, and the Risks | | | | | | |

|associated with use of Hazardous | | | | | | |

|Substances must be clearly | | | | | | |

|communicated to all Employees who| | | | | | |

|work with them. | | | | | | |

| |Determine whether information about |Interviews with management, | Documentation | | Head office | Conformance |

| |hazards and risks is available to all|workers, contractors and |Observation | |Divisional/ Business |Minor NC |

| |personnel and communicated in |stakeholders. |Testimonial | |unit |Major NC |

| |appropriate language. Confirm that |Procedures available in |None | |Facility |Not Applicable |

| |communication includes: |appropriate language. | | |None |Reason: |

| |clear lines of responsibility in |Posters in workplaces. | | |Details: | |

| |relation to management of hazards | | | | | |

| |information includes current | | | | | |

| |Materials Safety Data Sheets (or | | | | | |

| |equivalent necessary information), | | | | | |

| |and that these are available at the | | | | | |

| |place of work. | | | | | |

|Appropriate procedures must be in|Determine that there are effective |Site visits and workplace | Documentation | | Head office | Conformance |

|place to prevent accidents and |procedures or systems in place |inspections |Observation | |Divisional/ Business |Minor NC |

|injury to Health arising from, or|commensurate with the nature of |Interviews with management, |Testimonial | |unit |Major NC |

|linked to, the course of |work-related activities, to avoid |workers, contractors and |None | |Facility |(= Critical Breach) |

|work-related activities and |accidents, injury and illness, to |stakeholders | | |None |Not Applicable |

|operations at a Facility. |cover all activities in the workplace|Policy and procedures | | |Details: |Reason: |

| |environment. |Relevant job descriptions for | | | | |

| | |health and safety, emergency, | | | | |

| | |and first aid personnel | | | | |

| | |Appropriately qualified senior | | | | |

| | |manager responsible, for the | | | | |

| | |health and safety of all | | | | |

| | |employees at work | | | | |

| | |Risk assessments and controls | | | | |

|Members will provide access to |Determine whether there are clearly |Appropriately qualified first | Documentation | | Head office | Conformance |

|adequate on-site Health and |identifiable and sufficient first aid|aid personnel |Observation | |Divisional/ Business |Minor NC |

|medical facilities, including |provisions and equipment. |First aid equipment |Testimonial | |unit |Major NC |

|clearly marked first aid | |Compliance assessments |None | |Facility |Not Applicable |

|provisions, and develop | |Replenishment process | | |None |Reason: |

|procedures for transportation of | | | | |Details: | |

|more serious Health concerns to | | | | | | |

|local hospitals or medical | | | | | | |

|facilities. | | | | | | |

| |Determine whether there is |Policies and Procedures | Documentation | | Head office | Conformance |

| |information detailing how personnel |Maps and locations of nearest |Observation | |Divisional/ Business |Minor NC |

| |can make ready use of medical |medical facilities. |Testimonial | |unit |Major NC |

| |facilities either on or offsite. |Interviews with management, |None | |Facility |Not Applicable |

| | |workers, contractors and | | |None |Reason: |

| | |stakeholders | | |Details: | |

|Members will install appropriate |Confirm that sufficient, appropriate |Site visits and workplace | Documentation | | Head office | Conformance |

|alarms, warning devices and fire |and working fire safety devices are |inspections. |Observation | |Divisional/ Business |Minor NC |

|Safety mechanisms. This includes|in place, including alarms and |Fire safety compliance audits |Testimonial | |unit |Major NC |

|fire fighting equipment; clearly |extinguishers, which are accompanied | |None | |Facility |Not Applicable |

|marked, unlocked and unblocked |with instructions understandable by | | | |None |Reason: |

|emergency exits and escape |the workforce. | | | |Details: | |

|routes; and emergency lighting in| | | | | | |

|all Facilities. | | | | | | |

|Members will establish emergency |Determine whether there are |Emergency Response Plans | Documentation | | Head office | Conformance |

|procedures and evacuation plans |sufficient and appropriately placed |Site visits and workplace |Observation | |Divisional/ Business |Minor NC |

|for all reasonably foreseeable |emergency exits, and that they are |inspections. |Testimonial | |unit |Major NC |

|emergencies. Members will ensure |clearly marked and are unlocked and |Interviews with management, |None | |Facility |Not Applicable |

|that the procedures and plans are|unblocked. |workers, contractors and | | |None |Reason: |

|accessible or clearly displayed | |stakeholders. | | |Details: | |

|throughout their Facilities, are | |Results of drills and emergency | | | | |

|maintained, regularly tested | |exercises. | | | | |

|including the conduct of | |Records of training, awareness | | | | |

|evacuation drills, and are | |programs and practice drills. | | | | |

|updated periodically. Mining | | | | | | |

|Facilities will develop and | | | | | | |

|maintain emergency response | | | | | | |

|plans, in collaboration with | | | | | | |

|potentially affected communities,| | | | | | |

|workers and their | | | | | | |

|representatives, and relevant | | | | | | |

|agencies, pursuant to guidance | | | | | | |

|provided by Awareness and | | | | | | |

|Preparedness for Emergencies at | | | | | | |

|the Local Level (APELL). | | | | | | |

| |Confirm that evacuation and emergency|Emergency Response Plans | Documentation | | Head office | Conformance |

| |response procedures are available to |Site visits and workplace |Observation | |Divisional/ Business |Minor NC |

| |respond to all reasonably foreseeable|inspections. |Testimonial | |unit |Major NC |

| |emergency scenarios, and that these |Interviews with management, |None | |Facility |Not Applicable |

| |plans are accessible to all |workers, contractors and | | |None |Reason: |

| |personnel, prominently displayed, |stakeholders. | | |Details: | |

| |understandable, regularly tested |Results of drills and emergency | | | | |

| |(including the conduct of drills) and|exercises. | | | | |

| |updated. |Records of training, awareness | | | | |

| | |programs and practice drills. | | | | |

| |Verify that for Members with Mining |Emergency Response Plans for | Documentation | | Head office | Conformance |

| |Facilities, emergency response plans |mining operations’ specific |Observation | |Divisional/ Business |Minor NC |

| |comply with APELL guidelines, and |emergency scenarios |Testimonial | |unit |Major NC |

| |have been developed and maintained in|Evidence that Emergency Response|None | |Facility |Not Applicable |

| |collaboration with potentially |Plans comply with APELL | | |None |Reason: |

| |affected communities, workers and |requirements | | |Details: | |

| |their representatives, and relevant |Site visits and workplace | | | | |

| |agencies. |inspections | | | | |

| | |Interviews with management, | | | | |

| | |workers, contractors and | | | | |

| | |stakeholders | | | | |

| | |Records of collaboration and | | | | |

| | |communication with potentially | | | | |

| | |affected communities, workers | | | | |

| | |and their representatives, and | | | | |

| | |relevant agencies (such as local| | | | |

| | |emergency response services, | | | | |

| | |police and/or local government).| | | | |

| | |Results of drills and emergency | | | | |

| | |exercises | | | | |

| | |Records of training, awareness | | | | |

| | |programs and practice drills | | | | |

|Members will provide training so |Confirm that the appropriate level of|Records of training and | Documentation | | Head office | Conformance |

|that Employees are aware of: |training is offered to all personnel |awareness programs. |Observation | |Divisional/ Business |Minor NC |

|specific role-related Health and |at commencement of employment (with |Qualifications and competencies |Testimonial | |unit |Major NC |

|Safety Risks and Hazards; and |the business or when reassigned) and |Inductions and refresher |None | |Facility |Not Applicable |

|methods for appropriate |that training records are maintained.|training programs | | |None |Reason: |

|protection from such Hazards, |Confirm that training covers: | | | |Details: | |

|including proper use of PPE and |Proper handling of hazardous | | | | | |

|appropriate action to take in the|substances | | | | | |

|event of an accident or |Use of Material Safety Data Sheets | | | | | |

|emergency. Training will include |Proper use of PPE | | | | | |

|first aid training to designated |Fire safety and evacuation procedures| | | | | |

|Employee representatives and |Emergency response in the event of an| | | | | |

|appropriate training in fire |accident, including special training | | | | | |

|Safety and emergency procedures |personnel with key responsibilities | | | | | |

|for all Employees. Training |(e.g. wardens, incident/emergency | | | | | |

|undertaken must be recorded and |response co-ordinators, etc) | | | | | |

|repeated for new and re-assigned |Specific job related hazards, risks | | | | | |

|Employees. |and the precautionary measures to | | | | | |

| |avoid these risks. | | | | | |

| |Confirm that sufficient numbers of |First aid provisions and | Documentation | | Head office | Conformance |

| |personnel are trained in first aid |equipment |Observation | |Divisional/ Business |Minor NC |

| |for the nature and scale of the |Site visits and workplace |Testimonial | |unit |Major NC |

| |business. |inspections. |None | |Facility |Not Applicable |

| | |First aid qualifications based | | |None |Reason: |

| | |on regulatory requirements or | | |Details: | |

| | |guidelines. | | | | |

| | |Ensure that all first aid | | | | |

| | |qualifications are current. | | | | |

|Members will ensure that serious |Determine whether there is a |Policies and procedures | Documentation | | Head office | Conformance |

|Health and Safety incidents, as |procedure or system for formally |Site visits and workplace |Observation | |Divisional/ Business |Minor NC |

|well as the business’ response |recording and investigating serious |inspections. |Testimonial | |unit |Major NC |

|and outcome from such incidents, |occupational accidents, incidents |Interviews with management, |None | |Facility |Not Applicable |

|are formally documented and |(including near misses), occupational|workers, contractors and | | |None |Reason: |

|investigated with the results of |diseases, and/or emergencies. |stakeholders. | | |Details: | |

|the investigation feeding into | | | | | | |

|regular Health and Safety reviews| | | | | | |

|and improvement plans. | | | | | | |

| |Confirm that results from incident |Monitoring trends and | Documentation | | Head office | Conformance |

| |investigations result in the |assessment |Observation | |Divisional/ Business |Minor NC |

| |implementation of effective |Corrective and preventive action|Testimonial | |unit |Major NC |

| |corrective actions and improvement |plans |None | |Facility |Not Applicable |

| |measures and that these are reviewed |Evidence of reviews based on | | |None |Reason: |

| |on a periodic basis. |incident trends | | |Details: | |

| | |Incident investigation reports | | | | |

|Members will ensure that | Determine whether employees |Policies and procedures | Documentation | | Head office | Conformance |

|Employees and Contractors |understand that they can stop work in|Site visits and workplace |Observation | |Divisional/ Business |Minor NC |

|understand that they have the |situations that may cause serious |inspections. |Testimonial | |unit |Major NC |

|right and responsibility to stop |harm or uncontrolled hazards, and |Interviews with management, |None | |Facility |Not Applicable |

|work or refuse to work in |that they have a responsibility to |workers, contractors and | | |None |Reason: |

|situations that have Uncontrolled|bring these situations to the |stakeholders. | | |Details: | |

|Hazards, and to immediately bring|attention of those at imminent risk |Training programs | | | | |

|these situations to the attention|and to management. | | | | | |

|of those at imminent Risk and to | | | | | | |

|management. | | | | | | |

|Diamond or Gold Jewellery |Demonstrate that the Member has |Product health & safety legal | Documentation | | Head office | Conformance |

|products sold by Members to end |effective systems in place to ensure |compliance register |Observation | |Divisional/ Business |Minor NC |

|consumers will be compliant with |that diamond and gold jewellery |Product information |Testimonial | |unit |Major NC |

|the applicable regulations for |products sold to end-consumers (i.e. |Interviews with management. |None | |Facility |Not Applicable |

|product Health and Safety. |retail consumers) comply with health | | | |None |Reason: |

| |and safety regulations applicable to | | | |Details: | |

| |the products. | | | | | |

|Code of Practices Provisions |

|Members will not use corporal |Ensure that the business does not use |Policy and procedures | Documentation | | Head office | Conformance |

|punishment under any |corporal punishment. |Interviews with Members and |Observation | |Divisional/ Business |Minor NC |

|circumstances, and will ensure | |Employees |Testimonial | |unit |Major NC |

|that Employees are not subjected | |Records of corporal |None | |Facility |(= Critical Breach) |

|to harsh or degrading treatment, | |punishment, including | | |None |Not Applicable |

|sexual or physical harassment, | |reports, CAR reports, etc | | |Details: |Reason: |

|mental, physical or verbal abuse,| |Past, current and future | | | | |

|coercion or intimidation in any | |legal proceedings | | | | |

|circumstances. | | | | | | |

| |Confirm that the business prohibits its |Policy and procedures | Documentation | | Head office | Conformance |

| |employees from being subjected to harsh |Interviews with Members and |Observation | |Divisional/ Business |Minor NC |

| |or degrading treatment; sexual or |Employees |Testimonial | |unit |Major NC |

| |physical harassment; mental, physical or|Records of corporal |None | |Facility |(= Critical Breach) |

| |verbal abuse; coercion or intimidation |punishment, including | | |None |Not Applicable |

| |in any circumstances in the workplace. |reports, CAR reports, etc | | |Details: |Reason: |

| | |Past, current and future | | | | |

| | |legal proceedings | | | | |

|Members will clearly communicate |Confirm that the business has clearly |Interviews with employees and| Documentation | | Head office | Conformance |

|the business’ disciplinary |communicated to all personnel the |Human Resources department |Observation | |Divisional/ Business |Minor NC |

|process, and related standards on|business’ disciplinary process and |Incident/CAR reports |Testimonial | |unit |Major NC |

|appropriate disciplinary |related standards on appropriate |Meeting minutes |None | |Facility |(= Critical Breach) |

|procedures and Employee |disciplinary procedures and Employee |Past, current and future | | |None |Not Applicable |

|treatment, and apply these |treatment, and that the process and |legal proceedings | | |Details: |Reason: |

|equally to all management and |standards apply equally to all |Policy and procedures | | | | |

|staff. |management and staff. | | | | | |

|Members will provide clear |Confirm that grievance procedures and |Signed training register | Documentation | | Head office | Conformance |

|grievance procedures and |investigation processes are clear, and |Training Records |Observation | |Divisional/ Business |Minor NC |

|investigation processes and |that they are clearly explained to all |Internal memos |Testimonial | |unit |Major NC |

|clearly explain these to all |Employees. |Discipline and standards |None | |Facility |Not Applicable |

|Employees. Records of Employee | |widely available to all | | |None |Reason: |

|grievances raised, investigation | |management and staff | | |Details: | |

|processes and outcome will be | |Meeting minutes | | | | |

|maintained. | | | | | | |

| |Verify that records are maintained of |Interviews with management | Documentation | | Head office | Conformance |

| |Employee grievances raised, |(including HR Department) and|Observation | |Divisional/ Business |Minor NC |

| |investigation processes and outcomes. |staff |Testimonial | |unit |Major NC |

| | |Meeting minutes |None | |Facility |Not Applicable |

| | | | | |None |Reason: |

| | | | | |Details: | |

|Code of Practices Provisions |

|Members will apply normal working|Confirm that the business applies normal|Interviews with employees and| Documentation | | Head office | Conformance |

|hours that comply with Applicable|working hours that comply with |Human Resources department |Observation | |Divisional/ Business |Minor NC |

|Law. Where no specific laws and |Applicable Law. Where no specific laws |and Payroll departments where|Testimonial | |unit |Major NC |

|regulations exist, working hours |and regulations exist, confirm that |applicable |None | |Facility |Not Applicable |

|will not exceed, on a regular |working hours do not, on a regular |Policy and procedures | | |None |Reason: |

|basis, a maximum of 48 hours per |basis, exceed a maximum of 48 hours per |Rosters and timesheets, where| | |Details: | |

|working week in accordance with |working week. |applicable | | | | |

|ILO Convention 1. Where these | |Relevant legislation | | | | |

|limits are required to be | |accessible | | | | |

|exceeded in special circumstances| |Records of incidents caused | | | | |

|(for example on fly-in, fly-out | |by fatigue | | | | |

|sites), this should be in | |Budgets | | | | |

|compliance with Applicable Law | | | | | | |

|and should be planned so as to | | | | | | |

|provide safe and humane working | | | | | | |

|conditions | | | | | | |

|If overtime is required for |Confirm that the business has |Policy and Procedures | Documentation | | Head office | Conformance |

|business needs, Members will |compensated overtime (based on business |Interviews with employees |Observation | |Divisional/ Business |Minor NC |

|compensate overtime to their |needs) to their Employees according to |Interviews with Human |Testimonial | |unit |Major NC |

|Employees according to Applicable|Applicable Law and Sector regulations. |Resources and Payroll |None | |Facility |Not Applicable |

|Law. Overtime will be voluntary | |departments where applicable | | |None |Reason: |

|and except in special | |Financial records | | |Details: | |

|circumstances (for example on | | | | | | |

|fly-in, fly-out sites) be limited| | | | | | |

|to a maximum of 12 hours in a | | | | | | |

|week. | | | | | | |

| |Confirm that overtime is voluntary and |Policy and procedures (e.g. | Documentation | | Head office | Conformance |

| |except in special circumstances (for |defining what is meant by |Observation | |Divisional/ Business |Minor NC |

| |example on fly-in, fly-out sites), is |“non-regular”) |Testimonial | |unit |Major NC |

| |limited to a maximum of 12 hours in a |Interviews with employees |None | |Facility |Not Applicable |

| |week. |Interviews with Human | | |None |Reason: |

| | |Resources and Payroll | | |Details: | |

| | |departments where applicable | | | | |

| | |Previous timesheet data if | | | | |

| | |applicable | | | | |

|Members will provide Employees |Confirm that the business has provided |Policy and procedures | Documentation | | Head office | Conformance |

|with all legally mandated leave, |Employees with all legally mandated |Human resources/personnel |Observation | |Divisional/ Business |Minor NC |

|including maternity and |leave including maternity and paternity,|records |Testimonial | |unit |Major NC |

|paternity, compassionate and paid|compassionate and paid annual leave. |Interviews with employees |None | |Facility |Not Applicable |

|annual leave. Where no Applicable|Where no Applicable Law exists, paid |Interviews with Human | | |None |Reason: |

|Law exists, paid annual leave |annual leave shall be provided in |Resources and Payroll | | |Details: | |

|will be provided in accordance |accordance with ILO Convention 132. |departments where applicable | | | | |

|with ILO Convention 132. | | | | | | |

|Members will provide all |Confirm that appropriate weekly rest is |Policy and procedures | Documentation | | Head office | Conformance |

|Employees with at least one rest |provided in accordance with ILO |Interviews with Members, |Observation | |Divisional/ Business |Minor NC |

|day in seven consecutive working |Convention 14 (at least one rest day in |Employees and HR personnel |Testimonial | |unit |Major NC |

|days in accordance with ILO |seven consecutive working days). Where |Previous timesheet data if |None | |Facility |Not Applicable |

|Convention 14. Where these |no specific laws and regulations exist |applicable | | |None |Reason: |

|limits are required to be |the Member demonstrates compliance with |Records of incidents caused | | |Details: | |

|exceeded in special circumstances|prevailing Standards. Where this is not|by fatigue | | | | |

|(for example on fly-in, fly-out |possible (for example on fly-in, fly-out| | | | | |

|sites), this will be in |sites) the leave allocation complies | | | | | |

|compliance with Applicable Law, |with the relevant laws and is planned so| | | | | |

|or where no specific laws exist, |as to provide safe and humane working | | | | | |

|the prevailing industry |conditions. Ensure that all exceedances | | | | | |

|standards. All exceedances |of the minimum one rest day in seven | | | | | |

|should be planned so as to |consecutive working days are planned so | | | | | |

|provide safe and humane working |as to provide safe and humane working | | | | | |

|conditions |conditions. | | | | | |

|Code of Practices Provisions |

|Members will pay all Employees a |Confirm that employees are paid a wage |Interviews with employees | Documentation | | Head office | Conformance |

|wage based on the higher of |based on the higher of either the |Interviews with Payroll |Observation | |Divisional/ Business |Minor NC |

|either the applicable legal |applicable legal minimum wage or within |department |Testimonial | |unit |Major NC |

|minimum wage plus associated |the range of prevailing industry wages. |Policy and procedures |None | |Facility |Not Applicable |

|statutory benefits, or the | |Financial records | | |None |Reason: |

|prevailing industry standards. | | | | |Details: | |

|Members will make payment to the |Ensure that the business makes payment |Financial/ Accounting | Documentation | | Head office | Conformance |

|Employee on a regular and |to employees on a regular and |Management System |Observation | |Divisional/ Business |Minor NC |

|pre-determined basis. |pre-determined basis. |Interviews with employees |Testimonial | |unit |Major NC |

| | |Interviews with Payroll |None | |Facility |Not Applicable |

| | |department | | |None |Reason: |

| | |Policy and procedures | | |Details: | |

| | |Financial records (including | | | | |

| | |consecutive wage slips from | | | | |

| | |Employees if possible) | | | | |

|Members will provide payment by |Ensure that the business provides |Financial/ Accounting | Documentation | | Head office | Conformance |

|bank transfer or in cash or |payment by bank transfer or in cash or |Management System |Observation | |Divisional/ Business |Minor NC |

|cheque form, in a manner and |cheque form in a manner and location |Interviews with Members and |Testimonial | |unit |Major NC |

|location convenient to the |convenient to employees. |Employees |None | |Facility |Not Applicable |

|Employees. | |Policy and procedures | | |None |Reason: |

| | |Financial records | | |Details: | |

|Members will accompany all |Confirm that all payments are |Interviews with employees and| Documentation | | Head office | Conformance |

|payments by a wage slip which |accompanied by a wage slip that clearly |Payroll department |Observation | |Divisional/ Business |Minor NC |

|clearly details wage rates, |details wage rates, benefits and |Policy and procedures |Testimonial | |unit |Major NC |

|benefits and deductions where |deductions where applicable. |Wage slip that clearly |None | |Facility |Not Applicable |

|applicable. | |details wage rates, benefits | | |None |Reason: |

| | |and deductions where | | |Details: | |

| | |applicable | | | | |

|Members will not make deductions |Confirm that due process is being |Financial/ Accounting | Documentation | | Head office | Conformance |

|from wages without following due |followed if deductions from wages need |Management System |Observation | |Divisional/ Business |Minor NC |

|process. |to occur. |Interviews with employees |Testimonial | |unit |Major NC |

| | |Interviews with Human |None | |Facility |Not Applicable |

| | |Resources and Payroll | | |None |Reason: |

| | |departments where applicable | | |Details: | |

| | |Policy and procedures | | | | |

| | |Legislation or other | | | | |

| | |requirements from where “due | | | | |

| | |process” was derived. | | | | |

|Members will not force Employees |Confirm that Employees are not forced to|Interviews with employees, | Documentation | | Head office | Conformance |

|to buy provisions from the |buy provisions from the business or its |Interviews with Human |Observation | |Divisional/ Business |Minor NC |

|Member’s own business or |Facilities. |Resources and Payroll |Testimonial | |unit |Major NC |

|Facilities. | |departments where applicable |None | |Facility |Not Applicable |

| | |Policy and procedures | | |None |Reason: |

| | | | | |Details: | |

|Code of Practices Provisions |

|Obligations to Employees under |Confirm that all work performed for the |Recognised employment | Documentation | | Head office | Conformance |

|Applicable Law relating to labour|business is carried out under a |relationship |Observation | |Divisional/ Business |Minor NC |

|or social security arising from |recognised employment relationship |Employment contracts |Testimonial | |unit |Major NC |

|the regular employment |established through Applicable Law and | |None | |Facility |Not Applicable |

|relationship will not be avoided |practice, and includes obligations to | | | |None |Reason: |

|through the use of labour-only |Employees relating to labour or | | | |Details: | |

|contracting, sub-contracting, or |social-security. | | | | | |

|home-working arrangements; or | | | | | | |

|through apprenticeship schemes | | | | | | |

|where there is no real intent to | | | | | | |

|impart skills or provide regular | | | | | | |

|employment; or through the | | | | | | |

|excessive use of fixed-term | | | | | | |

|contracts of employment. | | | | | | |

| |Confirm that obligations to Employees |Obligations to Employees | | | | |

| |under Applicable Law relating to labour |under applicable Law relating| | | | |

| |or social security are not avoided |to labour or social-security | | | | |

| |through use of labour-only contracting, |arising from the regular | | | | |

| |sub-contracting, home-working |employment relationship | | | | |

| |arrangements, apprenticeship schemes or | | | | | |

| |the presence of any excessive use of | | | | | |

| |fixed-term contracts of employment. | | | | | |

|Members will maintain appropriate|Confirm the maintenance of appropriate |Employee records | Documentation | | Head office | Conformance |

|Employee records, including |Employee records (this includes records |Policy and procedures |Observation | |Divisional/ Business |Minor NC |

|records of piece rate and wage |of piece rate and wage payments as well |Interviews with HR Department|Testimonial | |unit |Major NC |

|payments as well as working |as working hours, for all staff | |None | |Facility |Not Applicable |

|hours, for all staff employed, |employed, whether full time, part time | | | |None |Reason: |

|whether on a full time, part time|or seasonal basis). | | | |Details: | |

|or seasonal basis. | | | | | | |

|Code of Practices Provisions |

|Members will seek to support the |Determine whether the business supports |Community Management Plan | Documentation | | Head office | Conformance |

|development of the communities in|the development of the community in |Interviews with management |Observation | |Divisional/ Business |Minor NC |

|which they operate through |which they operate through support of |Interviews with community (if|Testimonial | |unit |Major NC |

|support of community initiatives.|community initiatives. |possible) |None | |Facility |Not Applicable |

| | |Meeting minutes, Internal | | |None |Reason: |

| | |memos, etc | | |Details: | |

| | |Records of support of | | | | |

| | |community initiatives | | | | |

|Mining Facilities will have |Determine whether the Mining Facility |Training needs analysis and | Documentation | | Head office | Conformance |

|appropriate skills, resources and|has appropriate skills, resources and |resource management plans |Observation | |Divisional/ Business |Minor NC |

|systems in place for early and |implemented systems for early and |Community Management Plan for|Testimonial | |unit |Major NC |

|ongoing engagement with affected |ongoing engagement with affected |Mining projects |None | |Facility |Not Applicable |

|communities and stakeholders |communities and stakeholders throughout |Interviews with management | | |None |Reason: |

|throughout the project’s |the project’s lifecycle. |Interviews with community | | |Details: | |

|lifecycle, from earliest | |Records of communication with| | | | |

|exploration activities, | |affected communities | | | | |

|construction prior to | | | | | | |

|commencement of mining, during | | | | | | |

|mine operations, through to | | | | | | |

|closure and post-closure | | | | | | |

|monitoring. The interests and | | | | | | |

|development aspirations of | | | | | | |

|affected communities must be | | | | | | |

|considered in major mining | | | | | | |

|decisions in the project’s | | | | | | |

|lifecycle, and broad support for | | | | | | |

|proposals should be sought. | | | | | | |

|Engagement must be carried out in| | | | | | |

|an inclusive, equitable, | | | | | | |

|culturally appropriate and | | | | | | |

|rights-compatible manner. | | | | | | |

| |Verify that these systems include |Criteria and procedures for | Documentation | | Head office | Conformance |

| |mechanisms to consider the views and |project decision making |Observation | |Divisional/ Business |Minor NC |

| |aspirations of affected communities when|Interviews with management |Testimonial | |unit |Major NC |

| |developing the mine project. |Interviews with community |None | |Facility |Not Applicable |

| | | | | |None |Reason: |

| | | | | |Details: | |

| | Verify that broad support for major |Community Management Plan for| Documentation | | Head office | Conformance |

| |mining proposals is sought using |Mining projects |Observation | |Divisional/ Business |Minor NC |

| |engagement processes that are inclusive,|Policies and procedures. |Testimonial | |unit |Major NC |

| |equitable, culturally appropriate and |Interviews with management |None | |Facility |Not Applicable |

| |rights-compatible manner. |Interviews with community | | |None |Reason: |

| | |Records of communication with| | |Details: | |

| | |affected communities | | | | |

|Members with Mining Facilities |Determine how Members with Mining |Policies and procedures | Documentation | | Head office | Conformance |

|will seek to avoid or otherwise |Facilities avoid involuntary |regarding involuntary |Observation | |Divisional/ Business |Minor NC |

|minimise involuntary |resettlement, and verify that where it |resettlement |Testimonial | |unit |Major NC |

|resettlement. Where resettlement|is unavoidable, the extent is minimised |Community Management Plans |None | |Facility |Not Applicable |

|is unavoidable, its |and it is carried out (including |Interviews with community | | |None |Reason: |

|implementation should be |compensation) in accordance with the |Records of communication with| | |Details: | |

|consistent with International |International Finance Corporation (IFC) |affected communities | | | | |

|Finance Corporation (IFC) |Performance Standard 5. |Records of compliance with | | | | |

|Performance Standard 5. | |International Finance | | | | |

| | |Corporation (IFC) Performance| | | | |

| | |Standard 5 | | | | |

|Members with Mining Facilities |Ensure that Members with Mining |Policies and procedures | Documentation | | Head office | Conformance |

|must ensure that affected |Facilities have a system for dealing |regarding complaints and |Observation | |Divisional/ Business |Minor NC |

|communities have access to |with and resolving complaints and |grievances |Testimonial | |unit |Major NC |

|rights-compatible complaints and |grievances, and that this system is |Records of grievances raised,|None | |Facility |Not Applicable |

|grievance mechanisms at the |understood and accessible to affected |investigation processes and | | |None |Reason: |

|operational level for raising and|communities. |current outcomes and confirm | | |Details: | |

|resolving disputes and clearly | |that they have been | | | | |

|explain these to the affected | |maintained. | | | | |

|communities. Records of | |Interviews with community | | | | |

|grievances raised, investigation | |Records of communication with| | | | |

|processes and outcomes will be | |affected communities. | | | | |

|maintained. | | | | | | |

|Code of Practices Provisions |

|Members will use armed security |Determine that the business uses a |Interviews with management | Documentation | | Head office | Conformance |

|personnel only when there is no |rigorous system to evaluate the need for|and workers |Observation | |Divisional/ Business |Minor NC |

|acceptable alternative to manage |armed security personnel and that armed |Security Management System/ |Testimonial | |unit |Major NC |

|Risk or to ensure the personal |security personnel are used only when |Plan/ Program including |None | |Facility |Not Applicable |

|Safety of Employees, Contractors |there is no acceptable alternative to |policy and procedures | | |None |Reason: |

|and Visitors to the Facility. |manage risk or to ensure the personal |Meeting minutes, Internal | | |Details: | |

| |safety of Employees, Contractors and |memos, etc | | | | |

| |Visitors. |Incident/CAR reports | | | | |

|Members will ensure that all |Ensure that all armed personnel respect |Interviews with managers, | Documentation | | Head office | Conformance |

|security personnel respect the |the human rights and dignity of all |workers, security personnel |Observation | |Divisional/ Business |Minor NC |

|human rights and dignity of all |people and use the minimum force |and stakeholders |Testimonial | |unit |Major NC |

|people and use the minimum force |proportionate to the threat. |Security Management System/ |None | |Facility |Not Applicable |

|proportionate to the threat. | |Plan/ Program including | | |None |Reason: |

| | |policy and procedures | | |Details: | |

| | |Meeting minutes, Internal | | | | |

| | |memos, etc | | | | |

| | |Incident/CAR reports | | | | |

|Members with Mining Facilities |Ensure that security personnel working |Interviews with Security | Documentation | | Head office | Conformance |

|will ensure that, security |for Members with Mining Facilities |personnel and Training |Observation | |Divisional/ Business |Minor NC |

|personnel receive training in, |receive appropriate training to ensure |Coordinator/HR (where |Testimonial | |unit |Major NC |

|and operate in accordance with, |they operate in accordance with |applicable) |None | |Facility |Not Applicable |

|the standards and principles |standards and principles defined in the |Signed training attendance | | |None |Reason: |

|defined in the Voluntary |Voluntary Principles on Security and |Training register | | |Details: | |

|Principles on Security and Human |Human Rights (2000). |Code of Practices and the | | | | |

|Rights (2000).Members will ensure| |Voluntary Principles on | | | | |

|that, in situations of ongoing | |Security and Human Rights | | | | |

|unrest or conflict, security | |(2000) readily available | | | | |

|personnel will receive | | | | | | |

|appropriate training in, and | | | | | | |

|operate in accordance with, the | | | | | | |

|standards and principles defined | | | | | | |

|in the Voluntary Principles on | | | | | | |

|Security and Human Rights (2000).| | | | | | |

|Code of Practices Provisions |

|Mining Facilities will respect |Verify that Members with Mining |Applicable Law regarding | Documentation | | Head office | Conformance |

|the rights of Indigenous Peoples |Facilities respect the rights of |Indigenous Peoples |Observation | |Divisional/ Business |Minor NC |

|as articulated and defined in |Indigenous Peoples as defined in |Polices and procedures |Testimonial | |unit |Major NC |

|applicable provincial, national |Applicable Law. |Interviews with community |None | |Facility |Not Applicable |

|and international laws and their | |Records of communication with| | |None |Reason: |

|social, cultural, environmental | |affected Indigenous Peoples | | |Details: | |

|and economic interests, including| | | | | | |

|their connection with lands and | | | | | | |

|waters. | | | | | | |

|Mining Facilities will seek to |Verify that Members with Mining |Communication policies and | Documentation | | Head office | Conformance |

|obtain broad-based support of |Facilities obtain formally documented |procedures |Observation | |Divisional/ Business |Minor NC |

|affected Indigenous Peoples and |broad based support from affected |Communication Management |Testimonial | |unit |Major NC |

|to have this support formally |Indigenous Peoples for mining |Plans |None | |Facility |Not Applicable |

|documented, including the |operations. Ensure that this |Records of broad based | | |None |Reason: |

|partnerships and/or programs to |documentation includes any partnerships |support. | | |Details: | |

|provide benefits and mitigate |and/or programs to provide benefits and |Community partnership | | | | |

|impacts. |mitigate impacts benefits to the |programs and initiatives | | | | |

| |affected Indigenous Peoples. |Interviews with community (if| | | | |

| | |possible) | | | | |

| | |Records of communication with| | | | |

| | |affected Indigenous Peoples | | | | |

|Code of Practices Provisions |

|Mining Facilities will assist any|Verify that Members with artisanal and |Funding or other support from| Documentation | | Head office | Conformance |

|stakeholder’s initiative, |small-scale mining within their areas of|the mining facility for |Observation | |Divisional/ Business |Minor NC |

|including multi-stakeholder |operation provide assistance to |stakeholder initiatives. |Testimonial | |unit |Major NC |

|initiatives that enable the |initiatives that enable the |Interviews with personnel |None | |Facility |Not Applicable |

|professionalisation and |professionalisation and formalisation of|from the mining facility | | |None |Reason: |

|formalisation of artisanal and |artisanal and small-scale mining. |Interviews with ASM workers | | |Details: | |

|small-scale mining (ASM), where | | | | | | |

|it occurs within their areas of | | | | | | |

|operation. | | | | | | |

|Where ASM operate on or around a |Verify that Members with Mining |Meeting minutes comprising | Documentation | | Head office | Conformance |

|concession, Mining Facilities |Facilities include artisanal and |the mining facility being one|Observation | |Divisional/ Business |Minor NC |

|will engage directly with them as|small-scale miners operating on their |of the attendants |Testimonial | |unit |Major NC |

|part of their Social and |(the Members) concession, in Social and |Interviews with Member and |None | |Facility |Not Applicable |

|Environmental Impact Assessment |Environmental Impact Assessment (SEIA) |ASM workers | | |None |Reason: |

|and community engagement |and community engagement processes. |Records of communications | | |Details: | |

|processes. | |regarding SEIA and community | | | | |

| | |engagement processes. | | | | |

1.

|Code of Practices Provisions |

| Members will, wherever |Determine whether the business has |Environmental impact | Documentation | | Head office | Conformance |

|appropriate, introduce management|introduced appropriate management and |assessments |Observation | |Divisional/ Business |Minor NC |

|and operating systems to minimise|operating systems that: |Environmental management |Testimonial | |unit |Major NC |

|the detrimental environmental |Identify and assess detrimental |systems (e.g. ISO14001) |None | |Facility |Not Applicable |

|impacts of its business |environmental impacts resulting from its|Environmental factors in new | | |None |Reason: |

|practices. |business practice |developments, design and | | |Details: | |

| |Factor appropriate environmental |purchasing | | | | |

| |considerations into new developments, |Policies and procedures | | | | |

| |processes and business practices. |Site visits and workplace | | | | |

| |Manage and minimise significant |inspections. | | | | |

| |detrimental environmental impacts |Interviews with managers, | | | | |

| |commensurate with the nature and scale |buyers, contracting personnel| | | | |

| |of the Members business. |and other relevant staff | | | | |

| | |Process improvement | | | | |

| | |suggestion schemes | | | | |

| | |Records of training and | | | | |

| | |awareness programs | | | | |

| | |Environmental monitoring | | | | |

| | |program and associated | | | | |

| | |records | | | | |

|Code of Practices Provisions |

|Members will not manufacture, |Confirm that the business does not |Site visits and workplace | Documentation | | Head office | Conformance |

|trade, and/or use chemicals and |manufacture, trade and/or use chemicals |inspections. |Observation | |Divisional/ Business |Minor NC |

|Hazardous Substances subject to |or hazardous substances that have been |Current Material Safety Data |Testimonial | |unit |Major NC |

|international bans due to their |banned (locally or internationally) due |Sheets for hazardous |None | |Facility |(= Critical Breach) |

|high toxicity to living |to their high toxicity, environmental |substances on site. | | |None |Not Applicable |

|organisms, environmental |impact, persistence, potential for |Records relating to ozone | | |Details: |Reason: |

|persistence, potential for |bioaccumulation or potential for |depleting substances as | | | | |

|bioaccumulation, or potential for|depletion of the ozone layer. |defined in the Montreal | | | | |

|depletion of the ozone layer. | |Protocol. | | | | |

| | |Risk assessments for use of | | | | |

| | |hazardous substances. | | | | |

|Members will employ alternatives |Confirm that where technically and |Reviews of alternatives less | Documentation | | Head office | Conformance |

|to other Hazardous Substances |economically viable the business |hazardous substances. |Observation | |Divisional/ Business |Minor NC |

|used in production processes |substitutes hazardous substances used in|Risk assessments |Testimonial | |unit |Major NC |

|wherever technically and |production processes with alternatives |Site visits and workplace |None | |Facility |Not Applicable |

|economically viable. |that as less hazardous. |inspections. | | |None |Reason: |

| | | | | |Details: | |

|All mining Members with Mining |For Members with mining Mining |International Cyanide | Documentation | | Head office | Conformance |

|Facilities using cyanide in the |businesses Facilities using cyanide in |Management Code compliance |Observation | |Divisional/ Business |Minor NC |

|recovery of Gold will comply with|the recovery of gold, determine whether |audits and certification, if |Testimonial | |unit |Major NC |

|the International Cyanide |the applicable site(s) is certified to |applicable. |None | |Facility |Not Applicable |

|Management Code, 2005 and will |and complies with the International |Site visits and workplace | | |None |Reason: |

|ensure applicable sites are |Cyanide Management Code (2005) within 3 |inspections. | | |Details: | |

|certified to the International |years of joining the RJC. |Interviews with management, | | | | |

|Cyanide Management Code within 3 | |workers, contractors and | | | | |

|years from the date of joining | |stakeholders. | | | | |

|the RJC. | |Procedures and plans; | | | | |

|Code of Practices Provisions |

|Members will dispose of waste substances in compliance with Applicable Law. Where Applicable Law does not exist, prevailing international standards will be adopted. |

|Members will seek to ensure the |Determine whether the business has |Environmental management | Documentation | | Head office | Conformance |

|efficiency of their business |identified and quantified the energy and|system or programs including |Observation | |Divisional/ Business |Minor NC |

|operations in terms of |natural resources (including but not |specific targets and |Testimonial | |unit |Major NC |

|consumption of natural resources |limited to water) used, and set |objectives related to |None | |Facility |Not Applicable |

|including, but not limited to, |initiatives to manage their business so |energy/natural resources | | |None |Reason: |

|water and energy. |as to use these resources efficiently. |Energy/Natural resources | | |Details: | |

| | |audit reports | | | | |

| | |Site visits and workplace | | | | |

| | |inspections | | | | |

| | |Interviews with management | | | | |

| | |and staff | | | | |

| | |Capital and human resources | | | | |

| | |(including job descriptions | | | | |

| | |of competent staff) allocated| | | | |

| | |to energy/natural resources | | | | |

| | |projects | | | | |

| | |Participation in | | | | |

| | |local/National energy | | | | |

| | |reporting and reduction | | | | |

| | |schemes/ programs | | | | |

|Where transportation of people, |Determine how the Member has identified |Risk assessment | Documentation | | Head office | Conformance |

|goods and materials is a |and implemented practices that reduce |Greenhouse gas abatement and |Observation | |Divisional/ Business |Minor NC |

|significant business impact, |fossil fuel usage greenhouse gas |reduction plans Environmental|Testimonial | |unit |Major NC |

|Members will seek to identify and|emissions from its business practices, |management system or programs|None | |Facility |Not Applicable |

|implement practices that reduce |including the transportation of people, |including specific targets | | |None |Reason: |

|use of fossil fuels and |goods and materials. |and objectives related to | | |Details: | |

|associated greenhouse gas | |energy/natural resources | | | | |

|emissions from transportation. | |Energy/Natural resources | | | | |

| | |audit reports | | | | |

| | |Site visits and workplace | | | | |

| | |inspections | | | | |

| | |Interviews with management | | | | |

| | |and staff | | | | |

|Code of Practices Provisions |

|Members with Mining Facilities |Verify that Members with Mining |Policies and procedures | Documentation | | Head office | Conformance |

|will not explore or mine in World|Facilities do not carry out exploration |Register of Applicable Law |Observation | |Divisional/ Business |Minor NC |

|Heritage Sites and will ensure |or mining activities in World Heritage |including a list of nearby |Testimonial | |unit |Major NC |

|that their activity does not |Sites, nor have negative impacts on |World Heritage Sites |None | |Facility |Not Applicable |

|negatively impact on adjacent |World Heritage Sites adjacent to |Interviews with management | | |None |Reason: |

|World Heritage Sites. |exploration or mining activities. |Interviews with community (if| | |Details: | |

| | |possible) | | | | |

|Members with Mining Facilities |Determine how Members with Mining |Policies and procedures. | Documentation | | Head office | Conformance |

|will respect legally designated |Facilities identify and keep informed |Register of Applicable Law |Observation | |Divisional/ Business |Minor NC |

|protected areas by ensuring that:|about legally designated protected |including a list of nearby |Testimonial | |unit |Major NC |

|a. Members have a process to |areas. |legally designated protected |None | |Facility |Not Applicable |

|identify any surrounding legally | |areas. | | |None |Reason: |

|designated protected areas. | |Interviews with management | | |Details: | |

| | |Interviews with community (if| | | | |

| | |possible) | | | | |

|Members with Mining Facilities |Verify that Members with Mining |Policies and procedures. | Documentation | | Head office | Conformance |

|will respect legally designated |Facilities comply with Applicable Laws, |Register of Applicable Law |Observation | |Divisional/ Business |Minor NC |

|protected areas by ensuring that:|covenants and other commitments given in|including a list of nearby |Testimonial | |unit |Major NC |

|b. Members comply with any |relation to legally designated protected|legally designated protected |None | |Facility |Not Applicable |

|regulations, covenants or |areas. |areas | | |None |Reason: |

|commitments attributed to these | |Interviews with management | | |Details: | |

|areas. | |Interviews with community (if| | | | |

| | |possible) | | | | |

|Members with Mining Facilities |Determine how Members with Mining |Policies and procedures | Documentation | | Head office | Conformance |

|will respect legally designated |Facilities consider and assess the |Register of Applicable Law |Observation | |Divisional/ Business |Minor NC |

|protected areas by ensuring that:|actual and potential impacts of |including a list of nearby |Testimonial | |unit |Major NC |

|c. Decisions to proceed with |exploration, development, operational |legally designated protected |None | |Facility |Not Applicable |

|exploration, development, |and closure activities on legally |areas | | |None |Reason: |

|operation and closure activities |designated protected areas. |Interviews with management | | |Details: | |

|take into account the presence | |Interviews with community (if| | | | |

|and impact on any legally | |possible) | | | | |

|designated protected areas. | | | | | | |

|Members with Mining Facilities |Determine how Members with Mining |Register or list of key | Documentation | | Head office | Conformance |

|will identify Key Biodiversity |Facilities identify key biodiversity and|biodiversity areas |Observation | |Divisional/ Business |Minor NC |

|Areas within their operating |implement measures to mitigate impacts. |Baseline biodiversity |Testimonial | |unit |Major NC |

|boundaries and implement action | |assessment |None | |Facility |Not Applicable |

|plans to deliver measurable | |Biodiversity management plans| | |None |Reason: |

|biodiversity benefits | |including controls to reduce | | |Details: | |

|commensurate with the level of | |impacts including | | | | |

|biodiversity impacts. | |consideration of biodiversity| | | | |

| | |offsets | | | | |

| | |Biodiversity risk assessments| | | | |

| | |Site visits and workplace | | | | |

| | |inspections | | | | |

| | |Interviews with management | | | | |

| | |and workers | | | | |

|Members with Mining Facilities |Determine how Members with Mining |Assessment of IUCN threatened| Documentation | | Head office | Conformance |

|will not undertake an activity |Facilities ensure exploration, |species. |Observation | |Divisional/ Business |Minor NC |

|that will, or is likely to, lead |development, operational or closure |Baseline biodiversity |Testimonial | |unit |Major NC |

|to the extinction of a species |activities do not result in or present a|assessment. |None | |Facility |Not Applicable |

|listed by the IUCN as threatened |risk to the extinction or of a species |Biodiversity management plans| | |None |Reason: |

|with extinction. |listed by the IUCN Red List. |including controls to reduce | | |Details: | |

| | |impacts including | | | | |

| | |consideration of biodiversity| | | | |

| | |offsets | | | | |

| | |Biodiversity risk | | | | |

| | |assessments. | | | | |

| | |Site visits and workplace | | | | |

| | |inspections | | | | |

| | |Interviews with management | | | | |

| | |and staff | | | | |

|Land disturbed or occupied by |Verify that Members with Mining |Mine closure and reclamation | Documentation | | Head office | Conformance |

|Mining Facilities shall be |Facilities adopt recognised good |plans |Observation | |Divisional/ Business |Minor NC |

|rehabilitated by adopting |rehabilitation practices. |Recognised rehabilitation |Testimonial | |unit |Major NC |

|recognised good practice | |standards and practices |None | |Facility |Not Applicable |

|rehabilitation techniques. The | | | | |None |Reason: |

|rehabilitation objective should | | | | |Details: | |

|aim to establish a sustainable | | | | | | |

|native ecosystem, in accordance | | | | | | |

|with post-mining land uses | | | | | | |

|developed through engagement with| | | | | | |

|key stakeholders in the mine | | | | | | |

|closure planning process. | | | | | | |

| |Determine how Members with Mining |Mine closure and reclamation | | | | |

| |Facilities establish post mining land |plans | | | | |

| |use during mine closure planning. Verify|Consultation meeting minutes | | | | |

| |that closure planning involves key |and/or engaging activities | | | | |

| |stakeholders and consideration is given |that have occurred regularly | | | | |

| |to establishing a sustainable native |with local communities | | | | |

| |ecosystem once the mine operations |Site visits and workplace | | | | |

| |cease. |inspections | | | | |

| | |Interviews with management | | | | |

| | |and workers | | | | |

| | |Interviews with community (if| | | | |

| | |possible) | | | | |

| | |Records of communication with| | | | |

| | |affected communities | | | | |

|Code of Practices Provisions |

|Members will be aware of and |Confirm that the business is aware of |Legal compliance register | Documentation | | Head office | Conformance |

|comply with Applicable Law. |and complies with Applicable Law |Legal compliance audits |Observation | |Divisional/ Business |Minor NC |

| |relating to its business conduct, human |Subscriptions to sources of |Testimonial | |unit |Major NC |

| |rights, social and environmental |legal information |None | |Facility |Not Applicable |

| |performance. Applicable Law includes | | | |None |Reason: |

| |but is not limited to: | | | |Details: | |

| |Bribery and facilitation payments; | | | | | |

| |Money laundering and finance of | | | | | |

| |terrorism; | | | | | |

| |Corruption, smuggling, embezzlement, | | | | | |

| |fraud, racketeering, transfer pricing | | | | | |

| |and tax evasion; | | | | | |

| |Trading practices and consumer rights; | | | | | |

| |Human rights; | | | | | |

| |Child labour; | | | | | |

| |Employment terms and conditions | | | | | |

| |including occupational health & safety; | | | | | |

| |Environmental management; | | | | | |

| |Community and social impact; | | | | | |

| |Consumer health safety and environmental| | | | | |

| |product information. | | | | | |

|Code of Practices Provisions |

|Members must adopt a policy that |Confirm that the business has developed |Policy documentation | Documentation | | Head office | Conformance |

|is endorsed by senior management,|a Policy suitable for the nature, scale | |Observation | |Divisional/ Business |Minor NC |

|supports achievement of this Code|and impacts of its business practices | |Testimonial | |unit |Major NC |

|of Practices and make the policy |that supports the achievement of the | |None | |Facility |Not Applicable |

|publicly available. |Code of Practices. | | | |None |Reason: |

| | | | | |Details: | |

| |Confirm that this Policy is made |Interviews with management, | Documentation | | Head office | Conformance |

| |available to the public. |workers, contractors and |Observation | |Divisional/ Business |Minor NC |

| | |stakeholders. |Testimonial | |unit |Major NC |

| | |Available on websites or |None | |Facility |Not Applicable |

| | |other public forums. | | |None |Reason: |

| | | | | |Details: | |

|Code of Practices Provisions |

|Members will consider Risks |Verify that the Member has identified |List of Business Partners | Documentation | | Head office | Conformance |

|related to business ethics, human|those Business Partners that have the |Risk assessment |Observation | |Divisional/ Business |Minor NC |

|rights, social and environmental |potential to constitute a significant | |Testimonial | |unit |Major NC |

|business practices of significant|risk to the Members. | |None | |Facility |Not Applicable |

|Business Partners in the Gold and| | | | |None |Reason: |

|Diamond Jewellery supply chain, | | | | |Details: | |

|which have the potential to | | | | | | |

|impact the Members’ own practices| | | | | | |

|arising from such business | | | | | | |

|relationships. Based on this | | | | | | |

|Risk Assessment, Members will use| | | | | | |

|their best endeavours, | | | | | | |

|commensurate with their ability | | | | | | |

|to influence, to promote | | | | | | |

|responsible business practices | | | | | | |

|among their Business Partners. | | | | | | |

| |Determine whether the Member has |Risk assessment | Documentation | | Head office | Conformance |

| |conducted a risk assessment to | |Observation | |Divisional/ Business |Minor NC |

| |understand the risks associated with | |Testimonial | |unit |Major NC |

| |these significant Business Partners. | |None | |Facility |Not Applicable |

| | | | | |None |Reason: |

| | | | | |Details: | |

| |Determine how the business encourages |Records of communication | Documentation | | Head office | Conformance |

| |Business Partners to establish and |between Members and their |Observation | |Divisional/ Business |Minor NC |

| |maintain practices consistent with the |Business Partners |Testimonial | |unit |Major NC |

| |Code of Practices. |Contractual documents |None | |Facility |Not Applicable |

| | |Training records | | |None |Reason: |

| | |Discussions with Business | | |Details: | |

| | |Partners working at the | | | | |

| | |facility. | | | | |

|Contractors working on Member’s |Verify that relevant Business Partners |Interviews with contractors | Documentation | | Head office | Conformance |

|Facilities and Visitors to these |(Contractors) working at the Facility, |on site. |Observation | |Divisional/ Business |Minor NC |

|Facilities will be required to |and visitors to the Facility, are aware|Site workplace inspections |Testimonial | |unit |Major NC |

|comply with the Member’s |of and follow the business’ management | |None | |Facility |Not Applicable |

|management and operating systems |policies, procedures and systems | | | |None |Reason: |

|relevant to the Code of |established to meet the Code of | | | |Details: | |

|Practices. |Practices that relate to the Member’s | | | | | |

| |certification scope. | | | | | |

|Code of Practices Provisions |

|Members will engage with affected|Determine how Members with Mining |Environmental and social | Documentation | | Head office | Conformance |

|communities and stakeholders to |Facilities consult and engage |impact assessment policies |Observation | |Divisional/ Business |Minor NC |

|complete an environmental and |communities and stakeholders affected by|and procedures |Testimonial | |unit |Major NC |

|social impact assessment, and |exploration activities, new Mining |Community Management Plan for|None | |Facility |Not Applicable |

|associated environmental and |Facilities or significant changes to |Mining projects | | |None |Reason: |

|social management plans, for |operations at existing Facilities. |Environmental and social | | |Details: | |

|exploration and new Mining | |management plans | | | | |

|Facilities or significant changes| |Interviews with management | | | | |

|to operations at existing | |Interviews with community | | | | |

|Facilities. | |Records of communication with| | | | |

| | |affected communities | | | | |

|Code of Practices Provisions |

|Mining Facilities will prepare |Verify that Members with Mining |Up to date mine closure and | Documentation | | Head office | Conformance |

|and regularly review a mine |Facilities including new and proposed |reclamation plan. |Observation | |Divisional/ Business |Minor NC |

|closure plan and ensure that |Mining Facilities, develop and maintain |Closure polices and |Testimonial | |unit |Major NC |

|adequate resources, including |a closure plan with a defines the end of|procedures |None | |Facility |Not Applicable |

|financial resources, are |mine life closure criteria. |Applicable Law for closure | | |None |Reason: |

|available to meet closure and | |criteria and establishment of| | |Details: | |

|reclamation requirements. New | |financial provisions. | | | | |

|Facilities require a closure plan| | | | | | |

|from start-up and existing | | | | | | |

|Facilities need to put in place a| | | | | | |

|comprehensive plan as early as | | | | | | |

|possible. | | | | | | |

| |Confirm that the plan includes the |Up to date mine closure and | Documentation | | Head office | Conformance |

| |capacity and resources to achieve the |reclamation plan |Observation | |Divisional/ Business |Minor NC |

| |criteria. |Closure cost estimates |Testimonial | |unit |Major NC |

| | |(probabilistic or |None | |Facility |Not Applicable |

| | |deterministic) | | |None |Reason: |

| | |Financial provision for | | |Details: | |

| | |closure | | | | |

|Mining facilities will engage |Verify that Members with Mining |Consultation meeting minutes | Documentation | | Head office | Conformance |

|regularly with local communities,|Facilities engage regularly with local |and/or engaging activities |Observation | |Divisional/ Business |Minor NC |

|including ASM, Indigenous Peoples|communities, including ASM, Indigenous |that have occurred regularly |Testimonial | |unit |Major NC |

|and workers, regarding mine |Peoples and workers, regarding mine |with local communities |None | |Facility |Not Applicable |

|closure and reclamation plans. |closure and reclamation plans and |Mine closure and reclamation | | |None |Reason: |

| |workers. |plans | | |Details: | |

| | |Interviews with community (if| | | | |

| | |possible) | | | | |

| | |Records of communication with| | | | |

| | |affected communities | | | | |

|Code of Practices Provisions |

|Members with Mining Facilities |Verify that Members with Mining |Annual Sustainability | Documentation | | Head office | Conformance |

|will report annually on their |Facilities annually prepare and publish |Performance report, that is |Observation | |Divisional/ Business |Minor NC |

|sustainability performance, using|a sustainability report of the mines |externally assured |Testimonial | |unit |Major NC |

|the Global Reporting Initiative |performance, using the Global Reporting |Policies and procedures for |None | |Facility |Not Applicable |

|(GRI) Guidelines and GRI Mining |Initiative (GRI) Guidelines and GRI |external reporting. | | |None |Reason: |

|and Metals Sector Supplement. |Mining and Metals Sector Supplement. |Record of applicable Global | | |Details: | |

|The reports must have external |Confirm that the sustainability report |Reporting Initiative (GRI) | | | | |

|assurance as defined under the |includes an external assurance statement|and GRI Mining and Metals | | | | |

|GRI. |as defined under GRI. |Sector Supplement performance| | | | |

| | |indicators. | | | | |

| | |Methods for sustainability | | | | |

| | |performance measuring an | | | | |

| | |monitoring. | | | | |

Please provide the following details as appropriate.

|Please note any additional general findings made during the Self Assessment. |

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|Please Provide Details of Planned Changes to the Member’s business that may occur in 2008 – 2010. |

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|Please Provide Details of Suggested Business Improvements. |

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Based on the results of the Self Assessment, the Member(s) requests a Verification Assessment from an Accredited Auditor(s) to verify the information contained herein. This request is made acknowledging:

The information is provided is true and accurate to the best knowledge of the Member(s) preparing the Self Assessment.

If identified, all Critical Breaches have been brought to the attention of the RJC Management Team and have been rectified.

A Corrective Action Plan is established to address all identified Major and Minor Non-conformances. The Corrective Action Plan details the corrective & preventive actions, and the means, resources and timeframe for their implementation.

The information in the Assessment Workbook, Corrective Action Plan (if applicable) and accompanying documentation is authorised for use by the Auditor to establish a Verification Scope.

|Authorised Person: | |

|Position: | |

|Member Name: | |

|Signature: | |

|Date: | |

When the Self Assessment is complete, it should be forwarded to the Accredited Auditor(s) engaged by the Member.

DO NOT send your Self Assessment to the RJC Management Team.

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To advance responsible ethical, social and environmental practices, which respect human rights, throughout the diamond and gold jewellery supply chain, from mine to retail.

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