Sams Watchmaker Jeweller Pty Ltd - Australia
Policy Document: Policies
Rev. No.: 01
Date: 12-05-2025
Doc. No.: SWJPL-001
Download the official Ethical Business Policies (PDF)
DOCUMENT APPROVAL
This Policy Document (SWJPL-001) is to define rules and regulations and ways of working for the operations and activities of the company in relation to the requirements of Responsible Jewellery council and ethical business practice.
Scope of Material: Polished Diamonds/Gold Color Gemstones (Sapphire)
Product: Diamonds/Jewellery and Watches
The contents of this document have been reviewed and approved by Partner and subject to Annual review.
All internal and external stakeholders of Sams Watchmaker Jeweller Pty Ltd are required to be familiar with this document and follow the risk mitigating measures identified in this document.
Management is responsible to make changes / revisions to this document, and all business partners and stake holders are advised to report any issues violating this document.
Raising Concern Policy
We shall strictly maintain confidentiality of an individual/the company/association/body bring any such information or reporting and assure that no retaliatory actions are taken against whistle blower unless it is found with the malafide intention.
The Sams Watchmaker Jeweller Pty Ltd has a set policy and Procedure document and firmly believes that it should be implemented in a true spirit with the involvement of all stake holders. Further, the company shall always involve all stake holder in the process of continues improvement and welcome reporting of any incident or observation of breach of policy and procedure from any third party of stake holder. At the same time company shall always believe that any person who reportsthe breach incident or observed any violation of policy should be provided adequate immunity against any adverse impact on his job or any threat to his/her life or any form of harassment and torture.
The company shall always maintain the confidentiality of the whistle blower and shall not disclose the identity of the whistle blower without written consent from the whistle blower. The company shall always ensure that the person who has reported incident of violation for policy and procedure shall not be penalized or harassed or tortured or threatened by any individual.
Business policies of the company assure that all employees or third party who comes forward in good faith to report issues, that they will be treated fairly and respectfully. While all efforts will be made to protect the anonymity of employees as far as practicable, any form of retaliation.
Against any such individuals, assuming they have not been involved in the violation will not be tolerated.
a. Company encourages employees or any third party to voice concerns promptly, if they have a genuine reason to believe that a policy, company operation or practice is or will likely be in violation of any law, regulation or internal company rule or policy, including this. In case of any incident with the Whistle-Blower he/she can report to the entity head through following link on website of company.
Contact – Sams Group Australia
Our employees, suppliers and other parties can report concerns and alleged violations of supply chain/sourcing/due diligence policy as follows:
Reports can be made anonymously and will be fully kept confidential practicable and allowed by law.
We will not take any retaliatory action against our employees,suppliers, or other parties who make a report in good faith.
Our suppliers are encouraged to contact if they wish to seek guidance on the application of this Policy.
Policy on Corporate social Responsibility
While we run our business based on the expectations of our diverse stakeholders, we also understand the importance of contributing to making the world a better place. At Sams Watchmaker Jeweller Pty Ltd, we strongly believe in the concept wherein the company contributes to building economic, social and environmental imperatives.
Corporate Social Responsibility (CSR) aims to contribute to societal goals of a philanthropic, activist or charitable nature or by engaging in or support volunteering or ethically oriented practices.
Our CSR Policy aims to the betterment of a sustainable society, and this commitment is ingrained in our core values. We aim to demonstrate these through our actions governed by the CSR policy. This policy applies to our Company and its all activities and may also refer to our suppliers and partners.
Policy on Business Ethics and Transparency
- We will conduct our operations in an open, honest and ethical manner.
- We will ensure that all our operations are legitimate.
- We undertake to keep every partnership and collaboration open and transparent.
- We recognize the importance of protecting all our human, financial, physical, informational, social, environmental and reputational assets
- We will advise our partners, contractors and suppliers of our CSR Policy and will work with them to achieve consistency with the policy
Governance
Sams Watchmaker Jeweller Pty Ltd will undertake its CSR activities as approved by the CSR Committee, through a registered trust or society. The Company will assist the CSR Committee to identify the areas of CSR activities, programs and execution of initiatives as per the guidelines defined. The surplus funds if any arising out of the CSR activities will not form part of the business profit of the Company. The surplusfunds will be used in the development of CSR projectsin the following year. It will be mandatory for (Sams Watchmaker Jeweller Pty Ltd) to disclose its CSR Policy, programs/projects undertaken, and the expenditure made towards CSR activity. Following activities shall be carried out in 2025.
- Donation to Hospitals
- Financial support for social and cultural activities.
Policy Statement on Morden Slavery and Anti Human trafficking
We are committed to ensuring that modern slavery and human trafficking do not occur in our workplace or within our supply chain. The company has a zero-tolerance approach to modern-day slavery. The company has instituted various policies and programs to establish the framework of our commitment to human rights and ethical behavior in our work environment.
Modern-day slavery is a crime and a violation of fundamental human rights. It takes various forms, such as forced labour, sex trafficking, involuntary servitude, and human trafficking, all which force persons to work against their will to exploit them for personal or commercial gain. The company is committed to continually reviewing and improving our efforts to combat slavery and human trafficking.
Human trafficking refers to the exploitation of individuals through threat or use of force, coercion, abduction, fraud, and/or deception. These terms also include the practices of forced labor, debt bondage, domestic servitude, forced marriage, sex trafficking, child sex trafficking, and the unwell full recruitment and use of individuals, retaining identity or travel documents against offering employment (Unlawful recruitment) among others.
Everyone in our work environment must be treated with dignity and respect. We do not tolerate any form of harassment, whethersexual, physical, verbal or psychological.
We do not use forced labour in any form. We do not confiscate personal documents of our employees or force them to make any payment to us or to anyone else to secure employment with us, or to work with us.
We shall respect the human rights and dignity of all our stakeholders.
We seek to work with suppliers and service providers who can demonstrate that they share similar values. We expect them to adopt ethical standards comparable to our own.
Policy Statement of Child Labour
Children are an asset for any society. According to the International Labour Organization, Child Labour is "work that deprives children of their childhood, their potential, and their dignity, and that is harmful to physical and mental development".
This policy refers to "children" as individuals who are under the age of 18 years. The company shall adhere to the following statements:
We shall not employ children under any circumstances.
The company is against all kinds of exploitation of children
The company will not do business with any organization that practices child labor and does not uphold similar standards.
No form of child labour should be employed at Sams Watchmaker Jeweller Pty Ltd
The minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).
For authorized adolescents (persons below 18 years of age but above 15 years), the entity management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
If a child is found working at Sams Watchmaker Jeweller Pty Ltd either own or subcontracted, the responsibility of rehabilitation will be undertaken by the management.
The above policies will also be applicable to all business partners.
The HR department is responsible for implementing this policy in all of Company's operations.
Policy Statement of Forced Labour
The policies relating to this section are part of the Business Policies adopted by Sams Watchmaker Jeweller Pty Ltd and are presented below for reference:
a. The management of Sams Watchmaker Jeweller Pty Ltd are fully committed to ensuring that forced or involuntary, bonded, indentured or prison labour, is not practiced nor used in any form at any of its facilities. Sams Watchmaker Jeweller Pty Ltd shall ensure that there is no restriction in the freedom of movement of employees and dependents. Any reported incidentsrelating to forced labour will be considered as a serious violation of the Business Policies.
b. The following definitions will be applicable:
- The Universal Declaration of Human Rights that states that 'No one shall be held in slavery or servitude'
ILO Convention 29, which defines forced or compulsory labour as 'all work or service which is extracted from any person under the menace of any penalty, and for which the said person has not offered himself voluntarily"
Policy Statement General Employment, Working hours, Remuneration
a. Sams Watchmaker Jeweller Pty Ltd complies with applicable national laws / regulations with respect to employment.
b. Sams Watchmaker Jeweller Pty Ltdis committed to maintaining appropriate records as stipulated by the regulatory authorities for all staff employed, whether on a full time, part time or seasonal basis.
c. Sams Watchmaker Jeweller Pty Ltd shall not require workers to work for more than the national limit of hoursin a week on a regular basis, with overtime hours not to exceed the national permitted limit per week on a regular basis unless there are legal opt-outs.
d. Sams Watchmaker Jeweller Pty Ltd shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of workers.
e. Wages shall be paid to employees on a regular and predetermined basis in a manner and location convenient to employees, accompanied by a wage slip detailing wage rates, benefits and deductions as applicable.
f. Sams Watchmaker Jeweller Pty Ltd shall ensure that due process of wage deductions shall be followed where applicable and it shall not be binding on employees to buy provisions from the company.
g. When required, due recognition will be given to the existence, membership and lawful activities of worker representative bodies, and worker representatives will be given access to carry out their responsibilities / functions.
h. Sams Watchmaker Jeweller Pty Ltd is committed to addressing the legitimate grievances of its employees.
i. Sams Watchmaker Jeweller Pty Ltd shall follow proper procedure as per law for dismissal of employees, in case the need for the same arises, and arbitrary dismissal procedures shall be avoided.
j. Information regarding applicable employment policies and working practices shall be communicated in a transparent manner to all employees.
k. Sams Watchmaker Jeweller Pty Ltd is fully committed to the pursuance of the provision of fair and conducive employment conditions, consistent with applicable laws and regulations.
Policy Statement Money Laundering and Finance of terrorism
The policies relating to this section are part of the Business Policies adopted by Sams Watchmaker Jeweller Pty Ltd is presented below for reference:
a. Sams Watchmaker Jeweller Pty Ltd recognizes the fact that entities in the gems and jewelry sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
b. Strict compliance is required at all times, with all applicable national and, where appropriate, international laws / regulations with respect to money laundering, terrorism financing, bribery, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.
c. Sams Watchmaker Jeweller Pty Ltd shall act in accordance with national laws and national / international accounting standards with respect to maintaining financial accounts of all business transactions and auditing of its financial accounts.
d. Sams Watchmaker Jeweller Pty Ltd ensures that concerned employees know and understand the relevant regulatory jurisdiction for national and international transactions, money laundering / financial offences related legal, regulatory and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious activity that appears to be questionable may also be considered as a violation of the Business Policies, depending on the seriousness of the non-conformance.
e. Sams Watchmaker Jeweller Pty Ltd implements a "Know your Customer" and "Know your Supplier" procedure that establishesthe identity of all organizations with which it deals, have a clear understanding of their business relationships and have a reasonable ability to identify and react to transaction patterns appearing out of the ordinary or suspicious.
Policy Statement of Freedom of association and Collective Bargaining, Discrimination and Discipline and Grievance Procedures
The policies relating to this section are part of the Business Policies adopted by Sams Watchmaker Jeweller Pty Ltd and are presented below for reference:
a. Sams Watchmaker Jeweller Pty Ltd will not prevent employees from associating and collective bargaining
b. Discrimination can mean distinction, exclusion or preference.
c. Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, ethnicity, caste, national origin, religion, age, disability, gender, marital status, physical appearance, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by Sams Watchmaker Jeweller Pty Ltd and any such reported incidents will be viewed as a serious violation of this Business Policies.
d. Sams Watchmaker Jeweller Pty Ltd will ensure that employees who have certain life-threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.
e. Individuals who are "Fit for Work" shall be accorded equal opportunities and shall not be discriminated against on the basis of factors unrelated to their ability to perform their job.
f. Sams Watchmaker Jeweller Pty Ltd shall not use corporal punishment under any circumstances and will ensure that employees are not subjected to harsh or degrading treatment, sexual or physical harassment or other forms of mental or physical coercion, abuse or intimidation.
g. Sams Watchmaker Jeweller Pty Ltd encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, entity operation or practice is or will likely be in violation of any law, regulation or internal entity rule or policy, including this Business Policies. Sams Watchmaker Jeweller Pty Ltd assures all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully. While all efforts will be taken to protect the anonymity of employees as far as practicable, any form of retaliation against any such individuals, assuming they have not been involved in the violation, will not be tolerated.
Policy Statement of Product Integrity and disclosure
a. Sams Watchmaker Jeweller Pty Ltd is committed to complying with relevant trading standard legislation and specific national and local regulations applicable to its products.
b. Any heat treated gemstone will be considered as unnatural gemstone.
c. A color gemstone is a mineral or organic material that is distinguished by its color, which is determined by its chemical composition
d. The following essential Policies will be applicable in all transactions of Sams WatchmakerJeweller Pty Ltd involving color gemstone,synthetics and stimulant
- Disclosure - Sams Watchmaker Jeweller Pty Ltd shall fully and accurately disclose the material characteristic of their products. All reasonable efforts shall be made to properly disclose all relevant information on the physical characteristics, such as mass/weight, cut, cut, colour, clarity or fineness, of a color gemstone product.
- Misrepresentation - No untruthful, misleading or deceptive statement, "representation" or material omission in the "selling", "advertising" or distribution of any color gemstone, treated gemstone,synthetic, orsimulant, or any product,shall be made by the company and its entitiesin any medium, including the internet
- Color Gemstone Quality - The weight, colour, clarity or cut of gemstone will be described in accordance with the recognized guidelines appropriate to the particular jurisdiction.
- Full disclosure i.e. the complete and total release of all available information about a color gemstone and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the color gemstone.
- No misuse of terminology or misrepresentations or attempts to disguise the product will be made in the selling, advertising and distribution of treated gemstones, synthetics and simulant.
e. Sams Watchmaker Jeweller Pty Ltd has adopted the following definitions:
Synthetic: A synthetic is any object or object that has been either partially or wholly crystallized or re-crystallized due to artificial human intervention such that, except for being non-natural, the product meets the requirements specified in the definition of the word 'nature Gemstone'.
Treated Gemstone: A treated gemstone is any object or product that meets the requirements specified in the definition, but has been subject to some form of treatment i.e. any process, enhancement changing, interfering with and/or contaminating the natural appearance or composition of a gemstone other than historically accepted practices of cutting and polishing. This includes colour and decolourisation treatment, fracture filling, laser and irradiation treatment and coating. Any heat-treated gemstone will be considered as unnatural gemstone.
Simulants: A simulant is any object or product used to imitate some, or all the properties associated with a color gemstone and includes any material, which does not meet the requirements specified in the definition.
Policy Statement Product Security
a. Sams Watchmaker Jeweller Pty Ltd is committed to establish and implement product security measures within the premises and during shipments to protect against product theft, damage or substitution.
b. The security and well being of employees, visitors and other relevant business partners is prioritized when establishing product security measures.
Disclosure of Treated Color Gemstones, Synthetics and Stimulants Policy Statement
The policies relating to this section are part of the Business Principles adopted by Sams Watchmaker Jeweller Pty Ltd. and are presented below for reference:
The following essential principles will be applicable in all the entity's transactions involving treated color Gemstones, synthetics and stimulants.
- Full disclosure i.e. the complete and total release of all available information about a color Gemstone and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the color Gemstone.
- Full disclosure to the purchaser will take place when offered for sale, such that
- Full verbal disclosure will clearly take place during sale.
- Full written disclosure will be conspicuously included on each bill of sale or receipt in plain language and readily understandable to the purchaser. Written discloser will normally be in English language
- No misuse of terminology or mis-representations or attempts to disguise the product will be made in the selling, advertising and distribution of treated color Gemstones, synthetics and stimulants.
- The word 'color Gemstone' will not be used in the case of names of firms, manufactures or trademarks; in connection with treated color Gemstones or color Gemstone stimulants or synthetic color Gemstones."
Policy Statement Bribery and Facilitation Payments
The policies relating to this section are part of the Business Policies adopted by Sams Watchmaker Jeweller Pty Ltd and are presented below for reference:
a Sams Watchmaker Jeweller Pty Ltd is committed to prohibit bribery in all business practices and transactions that are carried out by the company or on its behalf by business partners. The company will not offer, accept or countenance any 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.
b. Sams Watchmaker Jeweller Pty Ltd considers Bribery Risk as it applies to its organization (including agents) to identify which areas pose high risks. Sams Watchmaker Jeweller Pty Ltd has developed appropriate methods to monitor conduct of employees and agents and eliminate bribery based on this understanding.
c. The management of Sams Watchmaker Jeweller Pty Ltd facilitates the reporting of incidences of attempted bribery or inappropriate gifts within their organization and shall apply appropriate sanctions for bribery and attempted bribery in all forms.
d. Sams Watchmaker Jeweller Pty Ltd ensures that no employee will suffer demotion, penalty or other adverse consequences for voicing a concern, or for refusing to pay a bribe or facilitation payment even if this action may result in the enterprise losing business.
Policy Statement Community Engagement and Development
- The policies relating to this section are part of the Business Policies adopted by Sams Watchmaker Jeweller Pty Ltd and are presented below for reference:
- Sams Watchmaker Jeweller Pty Ltd is committed to the development of communities where it operates, contributing to their social and economic welfare.
Policy Statement Environmental protection, Use of Energy and natural resources
The policies relating to this section are part of the Business Policies adopted by Sams Watchmaker Jeweller Pty Ltd and are presented below for reference:
Sams Watchmaker Jeweller Pty Ltd is committed to effective environmental performance and will focus on the following initiatives:
- Conduct business in an environmentally responsible manner.
- Compliance with all applicable environmental laws and regulations
- The impact of our operations on the environment will be assessed and reviewed periodically to mitigate or eliminate such impact.
- Disposal procedures for waste generated will be clearly defined and practiced in line with standards that are set by law.
- Improvement of employee environmental awareness and performance through training.
- Efficient use of energy and natural resources to minimize waste generation through efforts that include recycling and prevention of pollution.
- Commitment to a continual improvement process in environmental management
Policy Statement Health and Safety
The policies relating to this section are part of the Business Policies adopted by Sams Watchmaker Jeweller Pty Ltd and are presented below for reference:
Sams Watchmaker Jeweller Pty Ltd recognizes the need to develop a sustainable, value creating business and is committed to the following in the areas of workplace health and safety:
- Providing safe and healthy working conditions for all employees in accordance with applicable law and other relevant industry standards.
- Any adverse impact of our business processes on those who carry it out shall be identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.
- We will provide adequate and appropriate labeling and storage of all chemicals and cleaning materials and adopt methods to protect employees from exposure to airborne particles and chemical fumes
- Our review of our processes will use appropriate standards as required by prevailing laws, expert opinion, feedback from workers and our knowledge of best practices. The review will lead to formulation of clearly described work practices and safety drills and appropriate safeguards and isolation from mobile equipment. All our staff will be trained in the manner required to adhere to these work practices and drills.
- Workers shall not be under the influence of or abusing, drugs, alcohol and/ or other illegal substances.
- We will seek to substitute the use of material, which are known to cause an adverse impact on the health of workers or health of consumersin the course of its use.
- All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable.
- We will take adequate measures to safeguard our employees from fire and other workplace injuries.
- All products sold by Sams Watchmaker Jeweller Pty Ltd to consumers shall comply to applicable regulations of product health and safety.
Policy Statement of Human Rights
The policies relating to this section are part of the Business Policies adopted by Sams Watchmaker Jeweller Pty Ltd and are presented below for reference:
a) All employees in Sams Watchmaker Jeweller Pty Ltd will be treated with equality, respect and dignity.
b) Sams Watchmaker Jeweller Pty Ltd believesin and respectsfundamental human rights according to the United Nations Universal Declaration of Human Rights.
c) Sams Watchmaker Jeweller Pty Ltd will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation
d) Sams Watchmaker Jeweller Pty Ltd strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior. Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company.
e) Security personnel, if employed by Sams Watchmaker Jeweller Pty Ltd are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat. Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated.
f) Security personnel, if employed by the company are trained to respect the human rights and dignity of all people and use minimum force proportionate to the perceived threat. Wherever the any violation of human rights are observed, the company shall take mitigation action and if needed hire an external nongovernmental organization for the implementation.
g) Human rights risk assessment shall be done annually covering internal and external stakeholders. The company shall conduct human right risk assessment and upon any violation observed internal or external stake holders, company shall develop and implement risk mitigation plan according to severity of incident. The company may seek assistance from external NGO's or experts to develop and implement mitigation plan and monitoring.
h) The company shall provide support and consultation to external stakeholders upon written request by the business partners.
Policy Statement Use of Security Personnel
The policies relating to this section are part of the Business Policies adopted by Sams Watchmaker Jeweller Pty Ltd and are presented below for reference:
Security personnel, if employed by Sams Watchmaker Jeweller Pty Ltd are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat.
Equality, Diversity & Inclusion Policy Statement
The Company recognises that we are all unique, whether in terms of our background, personal characteristics, experience, skills or motivations, and the Company value its people for the differences they bring. These differences, this diversity is powerful.
The Company is committed to building a culture that values openness, fairness, and transparency with a workforce that is truly representative of communities in which it operates and where employees feel respected and able to achieve their potential. Fostering an inclusive culture helps everyone to benefit from a wider range of different perspectives, experiences, and skills. The Company believes that this creates a happier, more productive working environment for all.
This policy statement applies to anyone working for the Company. This includes employees, workers, contractors, and apprentices. The policy also relates to job applicants and is relevant to all stages of the employment relationship.
Supply Chain compliance Policy
The Policy promotes the standards that we expect all our suppliers to comply with when producing and supplying Color Gemstones to Sams Watchmaker Jeweller Pty Ltd, no matter where they operate in the world. We hereby inform all our suppliers to provide the first mine of origin for the material they supply to us. We request all our suppliers not to supply any material that is subject to restriction as per EU Reg. 833/2014.
The senior management of Sams Watchmaker Jeweller Pty Ltd advocates this policy, and we shall review as and when changes in the process or compliance requirement or any violation of sourcing policy or Changes in risk and due diligence criteria. We shall carry out review of this entire document at least annually.
We recognise that full compliance with these criteria may take time for some suppliers, and we are committed to working with our suppliers to implement improvement plans and help them achieve compliance.
Sams Watchmaker Jeweller Pty Ltd is committed to working in partnership with its suppliers to help achieve compliance with this Policy.
All the supplier should comply with national and international law and trade requirement like RJC with respect to Bribery and Corruption, Financial Offence, Labour Rights, Kimberley process and World Color Gemstone Council – SoW, Product disclosure, Labour Rights, Working Condition, Child labour, Forced labour, Human rights, Discrimination, Fair wages and working hours, Environment compliance, Health and safety of the employees and visitor.
Policy – Supply Chain and Ethical Sourcing
At Sams Watchmaker Jeweller Pty Ltd, we take Ethical business practice, social and environmental factors into consideration in making decisions on the procurement of Rough or polish color Gemstones.
This Policy shows company's commitment and its expectations for its product suppliers regarding actions to address Conflict Color Gemstones.
Sams Watchmaker Jeweller Pty Ltd expectsit'ssuppliersto have in place policies and due diligence measures that will enable us to reasonably assure that color Gemstones supplied to us containing conflict free color Gemstones are not belongs to Conflict-affected and high-risk areas – CAHRAs .
We being a responsible company, Sams Watchmaker Jeweller Pty Ltd supports the goal of the Dodd-Frank Act of preventing armed groups in the conflict affected and high risk countries from benefitting from the sourcing of Conflict color Gemstones from that region.
Sams Watchmaker Jeweller Pty Ltd is committed to working with its suppliers to educate them on these matters and concerning steps they can take to obtain increased transparency regarding the origin of color Gemstones mined or manufacture and sell to Sams Watchmaker Jeweller Pty Ltd. Sams Watchmaker Jeweller Pty Ltd reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy.
Sams Watchmaker Jeweller Pty Ltd reserves the right to request additional documentation from its suppliers regarding the origin/source of color Gemstones sold to Sams Watchmaker Jeweller Pty Ltd.
Suppliers who do not reasonably comply with this Policy shall be reviewed by Sams Watchmaker Jeweller Pty Ltd 's for future business.
Sams Watchmaker Jeweller Pty Ltd is committed to ensuring that our supply chain is free of any color Gemstones which was procured for the support or benefit of armed and anti-social conflict groups or involving serious abuses of human rights and non-compliant with OECD Guidelines.
Sams Watchmaker Jeweller Pty Ltd clearly criticizes such activity and will reject any material which we believe was obtained involving serious human rights violations or which benefitted or supported armed rebels or terrorist groups through illegal finance or other activities.
The company shall carry out risk assessment for its supply chain and shall not enter into any business relationship or if may require then shall suspend/discontinue the engagement with any such supplier involved in dealing with Conflict-Affected and High-Risk areas, Any form of Human Right Violation; Torture, Cruel, In-Human and Degrading Treatment; Forced/Compulsory Labour; Child Labour; Abuses such as widespread Sexual Violence; War Crimes; other serious violations of International Humanitarian Law, Crime against Humanity; Genocide and/or To Bribe or To be Bribed. We strictly condemn and prohibit any Direct/Indirect support to public/private security forces which illegally Control, Tax or Extort money from Mining Sites, Transportation Routes and Upstream Sectors.
The Company shall carry out due diligence to assessrisksrelated to procurement from the Conflict-affected and high-risk areas – CAHRAs and shall always source from compliant miners/traders.
We shall always set reasonable efforts to source Color Gemstones from miners and traders validated as being Conflict Free and require their direct and indirect suppliers to do the same;
We strive to work supportively with our customers and supply chain partners in implementing conflict free compliance programs for Color Gemstone Supply chain.
Policy – Due Diligence and Risk Assessment
The company shall always undertake to ensure that the extraction and trade of color Gemstone support peace and development, not conflict.
Sams Watchmaker Jeweller Pty Ltd remains committed to enhance its Supply Chain Due Diligence program through internal review and external assessments. We have zero tolerance policy for the supplier violating OECD due diligence guideline and we shall immediately stop commercial relationship if any of our business associates found non-compliant or High-Risk during our internal/external risk assessment.
All the suppliers are also requested to carry our risk assessment and due diligence for their suppliers and products they are sourcing.
Currently Sams Watchmaker Jeweller Pty Ltd procure it's color Gemstones from RJC CoP/Ethical business practice compliant miners/traders. However, we have established a strong due diligence process and we shall review it as an when we observed significant risk or upon receipt of any grievance or complaint but in normal course, we shall carry our due diligence process on annual basis.
Identify red-flags and Risk
The company has checked transaction methods and name and individuals of company on SDN list of USA treasury and EU sanction list. All the suppliers are found low in risk and in compliance with OECD requirement of CAHRA's.
Risk mitigation plan
- Company shall always deal with legitimate company.
- Always complete due diligence and risk assessment before establishing commercial relationships.
- Make sure that do transaction shall be carried out with business sense.
- Immediately stop commercial relationship upon any violation observed an report to concerned internal and external reporting authority.
- Continuously monitor suspicious transactions and red flag records
- Communication and awareness to suppliers
Supplier Risk Assessment /Due Diligence Report
We the senior management of Sams Watchmaker Jeweller Pty Ltd and compliance officer has verified all our supplier with respect to following ;
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
US OFAC Sanctions
EU Sanctions
Global Peace Index
Know Your Country
Transparency International (TI)
The Office of the United Nations High Commissioner for Human Rights (OHCHR)
Publication (Detailed report is with Compliance team and may produce to concerned parties upon request)
RJC CoP Annual Compliance - 2024: The company has carried our ethical business practice and carried out policy and procedure review with respect to its implementation. The company has complied with latest RJC Code of Practice and all itsrequirements. Ethical Standard/Commitment-- No practice or conduct observed during the assessment period that brings the diamond industry into disrepute. All businesses practices have adhered to national laws and applicable rules and regulation during the assessment period.
Compliance team of Sams Watchmaker Jeweller Pty Ltd has completed the due diligence and Risk assessment of all its Color Gemstone supplier with respect to latest RJC/OECD guideline, and we found all our supplier are complying with requirements did not find any risk pertaining to their business involvement in Conflict Affected and high-risk Areas' (CAHR's). No Business partners classified under US OFAC Sanctions/EU Sanctions. We deal with all legitimate companies and all business practice including transportation and sourcing materials. No business counter parties are observed in violation of any form of Human rights.