ETHICAL BUSINESS POLICY DOCUMENT - 2024
MANAGEMENT Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
Date: 26/02/2024 Place: India
DOCUMENT APPROVAL
The following is a description of the policies and approval of policies and procedures that apply to the business partners, internal and external stake older and employees. These are defined as group level policies and company level policy should not contradict with this policy document.
Applicability: Shimayra Jewellery
Scope of Materials: Diamonds/Coloured Gemstones/Gold/Silver/Platinum Group Metals
Effective Date: This policy document is applicable to all business-related activity and all employees of Shimayra Jewellery as defined above with effect from 26th February 2024.
This Policy Document (SJ-001) is to define rules and regulation and way of working for the operations and activities of the company Shimayra Jewellery in relation to the requirements of Responsible Jewellery council and ethical business practice. The contents of this document have been reviewed and approved by Director and subject to Annual review.
All internal and external stakeholders of Shimayra Jewellery 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.
The Company is committed to the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on the Company's behalf is responsible for maintaining the Company's reputation and for conducting company business honestly and professionally. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
Date: 26/02/2024 Place: India
RJC Compliance Policy
Shimayra Jewellery is a member of Responsible Jewellery Council – RJC CoP and CoC and committed for ethical business practices and compliance with Code of Practices in all its business activities.
The management of Shimayra Jewellery shall implement responsible ethical, social and environmental practices throughout the diamond supply chain, from mine to retail. We are being a responsible entity of diamond supply chain believe in consumer confidence in our trade and request our business partners to follow same. As a part of best endeavors and responsible business entity, we anticipate co-operation of our business partners in adopting the standard and ensuring that the entire diamond supply chain is compliant with respect to business, social and environmental responsibilities.
We strongly encourage all our business partners to follow and implement the various requirements of the RJC code of practice and other prevailing trade standards.
More information about the Compliance Program is available on thttp://www.responsiblejewellery.com.
Policy on Corporate social Responsibility
Social responsibility allows the company's business interests to be reconciled with the legitimate interests of the different stakeholders that may be affected, and also assumes the impact of the company's activities on the community in general and the environment.
Shimayra Jewellery maintains a high standards and ethical value when it comes to business. We only deal to those who abide the law and with a high ethical reputation in this industry. As a member of Responsible Jewellery Council (RJC), we follow the practical guidance on performing due diligence pertaining to responsible supply chain management of diamond when sourcing from conflict-affected and high risk areas. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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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 Shimayra Jewellery, 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
Shimayra Jewellery 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 surplus funds will be used in the development of CSR projects in the following year. It will be mandatory for (Shimayra Jewellery) to disclose its CSR Policy, programs/projects Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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undertaken, and the expenditure made towards CSR activity. Following activities shall be carries out in 2024;
Donation to Hospitals
Financial support for social and cultural activities.
Whistle-Blower Policy
The Shimayra Jewellery 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 involves 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 reports the 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 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 torture or threaten by any individual.
Business policies of 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 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.
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
Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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-Blower he/she can report to entity head and external lawyer on following Email.
info@shimayrajewellery.com
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 kept confidential to the fullest extent 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. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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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. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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ETHICAL BUSINESS POLICY STATEMENT
The Company is committed to the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on the Company's behalf is responsible for maintaining the Company's reputation and for conducting company business honestly and professionally.
This policy outlines the Company’s position on prohibiting and preventing bribery, fraud, dishonesty, and illegal activity. The Senior Management take a zero-tolerance approach and are committed to enforcing effective systems throughout the company to prevent, monitor and eliminate any form of dishonesty and consider that such activities have a detrimental impact on business by undermining good governance and distorting free markets.
This policy applies to all employees of the Company, and business partners and external stakeholders. Every employee and associated person acting for, or on behalf of, the Company is responsible for maintaining the highest standards of business conduct. Any breach of this policy will be treated as grounds for serious disciplinary action, and / or constitute a contractual and criminal matter for the individual concerned. The Company is committed to transparency and believes that fair conduct helps to foster deep relationships of trust between the Company and our business partners and customers and as such a breach of this policy may also cause serious damage to the reputation and standing of the Company.
In compliance with statutory legislations and to embed commitment to integrity and honesty the Company will not sanction the following: –
Give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received, or to reward any business received.
Accept any offer from a third party that is known or suspected to be made with the expectation that the Company will provide a business advantage for their business or anyone else.
Give or offer any payment to a Government official in any country to facilitate or speed up a routine or necessary procedure. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Tangible assets and intangible assets such as computer systems, bespoke processes, software, intellectual property, trade secrets and confidential information shall not be used for unauthorised or unlawful purposes or for personal gain.
Engage in any business practice which is unethical or amounts to unfair competition.
Unlawfully or inadvertently acquire, use or disclose to any third party any proprietary information or intellectual property of another party.
Engage in any activity or business practice whether unilaterally or in conjunction with any other party which is in breach of any applicable competition and/or anti-trust law in the relevant jurisdiction.
Unlawfully induce any party to breach a contract with any third party.
Make false statements about a competitor’s products and/or services.
Engage in business with service providers, agents or representatives that do not support our ethical business objectives.
The success of the Company's measures depends on all employees, and those acting for the Company, playing their part in helping to detect and eradicate dishonesty. Therefore, all employees and others acting for, or on behalf of, the Company are encouraged to report any suspected dishonesty in accordance with the procedures. The Company will support any individuals who make such a report, if it is made in good faith.
Conducting Business Ethically, with Integrity and in Fairness/Complying Diamond Pipeline Integrity
This policy is applicable for Jasani India Private Limited and Supreme Gems Private Limited.
Ensuring that all business activities are conducted in an honest, ethical, professional and accountable manner is fundamental to the core philosophy of our group. Shimayra Jewellery committed to comply with best practice principal requirement/Diamond Pipeline Integrity System compliance requirements. The Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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senior management shall carryout at least annual review during and self-assessment and submit the report to the management team.
Shimayra Jewellery is committed to combating dishonesty and fraud in all business transactions in order to maintain and enhance consumer trust in, and the reputation of the diamond industry.
Shimayra Jewellery shall strive to get similar commitment from their business partners.
The company is committed to maintaining the highest standards of financial integrity for the benefit of all our stakeholders.
All accounting records, and reports produced from those records, must be maintained and presented according to the laws of each applicable jurisdiction.
Compliance with generally accepted accounting principles in the country where the entity is incorporated and the entity’s system of internal controls is required at all times.
It is the responsibility of Shimayra Jewellery to pursue its corporate value enhancement through sound business practices. Our business activities have direct and indirect impact on the societies in which we operate, and therefore sound business practice requires that business decisions give due consideration to the interests of its stakeholders including shareholders, customers, employees, suppliers, business partners, local communities.
All employees in all our entities must endeavor to conduct the business of Shimayra Jewellery accordingly.
In making business decisions, employees must act on an informed basis, in good faith, and in the honest belief that the action taken is in the best interest of the Group.
Provenance claim for DTC Diamonds shall be complied with all requirements. Management control systems are implemented and continuously monitored. Relevant employees are trained on requirements.
The company has put in place programmes that monitor the effectiveness of these commitments and hence supporting all workers in this endeavor. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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MODERN SLAVERY STATEMENT
This statement sets out the Company actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
Modern slavery takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person's liberty in order to exploit them for personal or commercial gain.
We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
As part of the diamond supply chain, we recognize that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic.
The senior management is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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QUALITY POLICY STATEMENT
It is the objective of the Company to succeed in business by delivering Client satisfaction and value for money.
To realise this policy objective, Directors and senior management are committed to:
Determining our clients’ needs through collaborative working, to understand their specific requirements and provide high quality products and services that will at least meet their expectations, if not exceed them.
Ensuring we work in partnership with ethical supply chains to ensure the sustainability of our business, exercising social responsibility, whilst reducing, if not eliminating, any adverse impacts of our business on people or our environment.
Encouraging engagement with all staff to identify opportunities that improve our operating practices, involve them in process enhancements and embrace their enthusiasm to develop more efficient working methods and foster advancement.
Measuring and monitoring our processes and performance to ensure that we operate efficiently and economically and continually improve.
Providing adequate resources, including management representatives, to fulfil the Company’s commitments.
Maintaining and continually improving our Business Management System meeting the requirements of customers and other applicable standards we subscribe to.
Complying with all relevant legislation and where possible improving on these requirements.
Promoting a culture of quality awareness and responsibility, through effective leadership, communication and training.
Identifying the needs and expectations of our Interested Parties relevant to our Management Systems and considering how they affect our business.
This policy is communicated to all persons working for or on behalf of the Company and is made available to other interested parties upon request. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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INFORMATION SECURITY & DATA PROTECTION POLICY STATEMENT
The Company shall ensure appropriate technical and organizational measures are taken to prevent unauthorized or unlawful processing of personal data and commercially sensitive information, and to safeguard against accidental loss or destruction of, or damage to same.
To reassure our business partners and other interested parties of our commitment to protecting, securing and controlling systems and data, the company security controls are verified by independent experts and certified to the Government backed scheme ‘Cyber Essentials’.
The Company will act to ensure that measures are implemented to protect the integrity of information, such measures shall include:
Protecting computer networks, all desktop and portable computers and handheld devices with user log-in credentials, complex passwords and, where appropriate, biometrics.
Protecting networks from any damaging executables or scripts introduced by portable media, not limited to, but such as memory sticks and optical storage.
Utilisation of Anti-Virus, Anti-Malware and Anti-Adware programs that are updated to the latest database definitions.
Firewalls to protect against unwanted intrusion into networks, servers, computers and hand held devices.
Maintaining information to ensure that it is accurate and complete.
Copies of back-ups are kept off-site using controlled and secure procedures.
Adherence to contracts with our clients that contain strict no-publicity clauses and thus photographic media taken on clients’ premises and sites will not be used or displayed without explicit permission to do so. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Communicating Confidentiality Agreements and Non-Disclosure Agreements to relevant personnel.
Promoting good security practices and training those whom we employ, providing guidance, awareness and advice on the importance of protecting confidential and sensitive information.
Limited and monitored employee access to Social media and networking.
Enacting disciplinary action against any employee who jeopardises the security and confidentiality of information/data entrusted to the company.
Communication Logs that are only accessible by authorised personnel shall be retained for the purpose of fault diagnosis and user support.
By implementing the above security measures, we shall comply with business, contractual, and regulatory requirements, including those of the General Data Protection Regulation.
This policy is communicated to our supply chain, relevant interested parties and all those working for, or on behalf of, the company. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Policy Statement of Child Labour
No form of child labour should be employed at Shimayra Jewellery
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 Shimayra Jewellery 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.
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Policy Statement of Forced Labour
The policies relating to this section are part of the Business Policies adopted by Shimayra Jewellery and are presented below for reference:
The management of Shimayra Jewellery 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. Shimayra Jewellery shall ensure that there is no restriction in the freedom of movement of employees and dependents. Any reported incidents relating to forced labour will be considered as a serious violation of the Business Policies.
The Company do not engage or support the use of Forced / Bonded Labour in any of our manufacturing activities / allied activities whether in existence or to be opened in future.
Neither the company nor any entity supplying labour to the company shall engage in or support trafficking in human beings. All employees shall be informed of the terms of their employment i.e. job description, hours of work etc. The Company does not engage or support vendors & suppliers who resort to using forced labor in their operations.
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” Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Policy Statement Kimberley Process
The policies relating to this section are part of the Business Policies adopted by Shimayra Jewellery are presented below for reference:
Shimayra Jewellery is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and World Diamond Council’s (WDC) System of Warranties Declaration.
The definition of ‘Conflict Gemstone Diamonds’ as agreed by the Kimberley Process will be adopted i.e.
“Rough diamonds used by rebel movements or their allies to finance conflict aimed at undermining legitimate Governments, as described in relevant United Nations Security Council (UNSC) resolutions in so far as they remain in effect, or in other similar UNSC resolutions which may be adopted in the future, and as understood and recognized in United Nations General Assembly (UNGA) Resolution 55/56, or in other similar UNGA resolutions which may be adopted in the future.”
Wherever applicable, the following affirmative statement as recommended by the World Diamond Council’s System of Warranties should be printed on all the invoices:
“The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict, in compliance with United Nations Resolutions and corresponding national laws. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WDC SoW Guidelines.”
Entering into transactions involving ‘conflict diamonds’ or not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, will be considered as a violation of the Business Policies.
Shimayra Jewellery ensures that concerned personnel within the organization know about government restrictions on the trade in Conflict Diamonds, the Kimberley Process Certification Scheme and the World Diamond Council System of Warranties.
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Policy Statement General Employment, Working hours, Remuneration
Shimayra Jewellery complies with applicable national laws / regulations with respect to employment.
Shimayra Jewelleryis 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.
Shimayra Jewellery shall not require workers to work for more than the national limit of hours in 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.
Shimayra Jewellery 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.
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.
Shimayra Jewellery 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 group.
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.
Shimayra Jewelleryis committed to addressing the legitimate grievances of its employees.
Shimayra Jewellery 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.
Information regarding applicable employment policies and working practices shall be communicated in a transparent manner to all employees.
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Shimayra Jewellery is fully committed to the pursuance of the provision of fair and conducive employment conditions, consistent with applicable laws and regulations.
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Policy Statement Money Laundering and Finance of terrorism
The policies relating to this section are part of the Business Policies adopted by Shimayra Jewellery is presented below for reference:
Shimayra Jewellery 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.
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.
Shimayra Jewellery 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.
Shimayra Jewellery 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.
Shimayra Jewellery implements a “Know your Customer” and “Know your Supplier” procedure that establishes the 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.
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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 Shimayra Jewellery and are presented below for reference:
Shimayra Jewellery will not prevent employees from associating and collective bargaining
Discrimination can mean distinction, exclusion or preference.
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 Shimayra Jewellery and any such reported incidents will be viewed as a serious violation of this Business Policies.
Shimayra Jewellery 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.
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.
Shimayra Jewellery 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.
Shimayra Jewellery 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. Shimayra Jewellery assures all employees who
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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.
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Policy Statement of Product Integrity
Shimayra Jewellery is committed to complying with relevant trading standard legislation and specific national and local regulations applicable to its products.
The following essential Policies will be applicable in all transactions of Shimayra Jewellery involving diamonds, treated diamonds, synthetics and stimulant
Disclosure - Shimayra Jewellery 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 diamond or gold jewellery product.
Misrepresentation - No untruthful, misleading or deceptive statement, “representation” or material omission in the “selling”, “advertising” or distribution of any diamond, treated diamond, synthetic, or simulant, or any gold product, shall be made by the Group and its entities in any medium, including the internet
Diamond Quality - The weight, colour, clarity or cut of diamonds 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 Diamond 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 diamond.
No misuse of terminology or misrepresentations or attempts to disguise the product will be made in the selling, advertising and distribution of treated diamonds, synthetics and simulant.
The word ‘diamond’ will not be used in the case of names of firms, manufacturers or trademarks; in connection with treated diamonds or diamond simulant or synthetic Diamonds.
Shimayra Jewellery has adopted the following definitions:
Diamond: A diamond is a natural mineral consisting essentially of pure carbon
crystallized with a cubic structure in the isometric system. Its hardness in the Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Mohs scale is 10; its specific gravity is approximately 3.52; it has a refractive index of 2.42 and it can be found in many colours.
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, with the exception of being non-natural, the product meets the requirements specified in the definition of the word ‘diamond’ above.
Treated Diamond: A treated diamond is any object or product that meets the requirements specified in the definition of the words ‘diamond’ and ‘synthetic’ above, 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 diamond other than historically accepted practices of cutting and polishing. This includes colour and decolourisation treatment, fracture filling, laser and irradiation treatment and coating.
Simulants: A diamond simulant is any object or product used to imitate some or all of the properties associated with a diamond and includes any material, which does not meet the requirements specified in the definition of the word ‘diamond’ above. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Policy Statement Product Security
a. Shimayra Jewellery 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. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Disclosure of Treated Diamonds, Synthetics and Stimulants
Policy Statement
The policies relating to this section are part of the Business Principles adopted by Shimayra Jewellery. and are presented below for reference:
The following essential principles will be applicable in all the entity's transactions involving treated diamonds, synthetics and stimulants.
• Full disclosure i.e. the complete and total release of all available information about a diamond 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 diamond.
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 diamonds, synthetics and stimulants.
The word 'diamond' will not be used in the case of names of firms, manufactures or trademarks; in connection with treated diamonds or diamond stimulants or synthetic diamonds."
" Shimayra Jewellery” has adopted the following definitions:
Diamond: A diamond is a natural mineral consisting essentially of pure carbon crystallized with a cubic structure in the isometric system. Its hardness in the Mohs scale is 10; its specific gravity is approximately 3.52; it has a refractive index of 2.42 and it can be found in many colours.
Synthetic: A synthetic is any object that has been either partially or wholly crystallized or re-crystallized due to artificial human intervention such that, with Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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the exception of being non-natural, the product meets the requirements specified in the definition of the word 'diamond' above.
Treated Diamond: A treated diamond is any object or product that meets the requirements specified in the definition of the words 'diamond and synthetic' above, but has been subject to some from of treatment i.e. any process, enhancement changing, interfering with and/or contaminating the natural appearance or composition of a diamond other than historically accepted practices of cutting and polishing. This includes color and decolourisation treatment, fracture filling, laser and irradiation treatment and coating.
Stimulants: A diamond stimulant is any object or product used to imitate some or all of the properties associated with a diamond and includes any material, which does not meet the requirements specified in the definition of the word 'diamond' above. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Policy Statement Bribery and Facilitation Payments
The policies relating to this section are part of the Business Policies adopted by Shimayra Jewellery and are presented below for reference:
a Shimayra Jewellery 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. Shimayra Jewellery considers Bribery Risk as it applies to its organization (including agents) to identify which areas pose high risks. Shimayra Jewellery has developed appropriate methods to monitor conduct of employees and agents and eliminate bribery based on this understanding.
c. The management of Shimayra Jewellery 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. Shimayra Jewellery 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. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Policy Statement Community Engagement and Development
▪ The policies relating to this section are part of the Business Policies adopted by Shimayra Jewellery and are presented below for reference:
▪ Shimayra Jewellery is committed to the development of communities where it operates, contributing to their social and economic welfare.
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Policy Statement Environmental protection, Use of Energy and natural resources
The policies relating to this section are part of the Business Policies adopted by Shimayra Jewellery and are presented below for reference:
Shimayra Jewellery 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
Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Policy Statement Health and Safety
The policies relating to this section are part of the Business Policies adopted by Shimayra Jewellery and are presented below for reference:
Shimayra Jewellery 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 consumers in 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 Shimayra Jewellery to consumers shall comply to applicable regulations of product health and safety.
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Policy Statement of Human Rights
The policies relating to this section are part of the Business Policies adopted by Shimayra Jewellery and are presented below for reference:
• All employees in Shimayra Jewellery will be treated with equality, respect and dignity.
• Shimayra Jewellery believes in and respects fundamental human rights according to the United Nations Universal Declaration of Human Rights.
• Shimayra Jewellery 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
• Shimayra Jewellery 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 Group.
• Security personnel, if employed by Shimayra Jewellery are trained to respect the human rights and dignity of all people and use of 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 non-governmental organization for the implementation.
• Human rights risk assessment shall be done annually covering internal and external stakeholders.
• The group 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 plans and monitoring.
• The group shall provide support and consultation to external stakeholders upon written request by the business partners.
• Bullying is usually seen as acts or verbal comments that could psychologically or
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• involve negative physical contact as well.
• Bullying usually involves repeated incidents or a pattern of behaviour that is intended to intimidate, offend, degrade or humiliate a particular person or group of people. It has also been described as the assertion of power through aggression.
• No form of bullying shall be acceptable at work place in the group and victim can directly contact to supervisor or facility head or HR manager or Senior management in case of any such incident.
Policy Statement Use of Security Personnel
The policies relating to this section are part of the Business Policies adopted by Shimayra Jewellery and are presented below for reference:
Security personnel, if employed by Shimayra Jewellery are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Ethical business Practice and Supply chain compliance
The Policy promote the standards that we expect all of our suppliers to comply with when producing and supplying Diamonds/Gold/Silver/Platinum/coloured gemstone/findings to Shimayra Jewellery, no matter where they operate in the world. We request all our business partners to disclose first mine of origin and source to comply with ethical business practice. We also request to provide us refinery certificate in case of any metal supplied. We request our suppliers not to supply any material that is subject to EU. Reg. 833/2014.
The senior management of Shimayra Jewellery advocate 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.
Shimayra Jewellery 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 Diamond 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. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Policy – Supply Chain and Ethical Sourcing
At Shimayra Jewellery, we take Ethical business practice, social and environmental factors into consideration in making decisions on the procurement of Rough or polish diamonds.
This Policy shows company’s commitment and its expectations for its product suppliers regarding actions to address Conflict Diamonds.
Shimayra Jewellery expects it's suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that diamonds supplied to us containing conflict free diamonds are not belongs to Conflict-affected and high-risk areas – CAHRAs .
We being a responsible company, Shimayra Jewellery 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 diamonds from that region.
Shimayra Jewellery 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 diamonds mined or manufacture and sell to Shimayra Jewellery. Shimayra Jewellery reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy.
Shimayra Jewellery reserves the right to request additional documentation from its suppliers regarding the origin/source of diamonds sold to Shimayra Jewellery.
Suppliers who do not reasonably comply with this Policy shall be reviewed by Shimayra Jewellery ’s for future business.
Shimayra Jewellery is committed to ensuring that our supply chain is free of any diamonds 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. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Shimayra Jewellery 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 assess risks related 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 Diamonds 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 Diamond/Jewellery Supply chain.
Policy – Due Diligence and Risk Assessment
The company shall always undertake to ensure that the extraction and trade of diamond/coloured gemstone/gold/silver/pgm support peace and development, not conflict. Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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Shimayra Jewellery 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 Shimayra Jewellery procure it’s diamonds/gold/silver/pgm/coloured gemstone 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 Shimayra Jewellery Policy Document Policies Rev. No. 01 Date: 26-02-2024 Doc. No. SJ-001
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We the senior management of Shimayra Jewellery 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)
http://www.responsiblemineralsinitiative.org/minerals-due-diligence/risk-management/conflict-affected-and-high-risk-areas/
Publication (Detailed report is with Compliance team and may produce to concerned parties upon request)
Compliance team of Shimayra Jewellery has completed the due diligence and Risk assessment of all its metals and Minerals supplier with respect to latest RJC/OECD guideline and we found all our supplier are complying with requirements not found any risk pertaining to their business involvement in Conflict Affected and high risk Areas’ (CAHR’s) or any other human right violation.
Date: 26/02/2024
Place: India