• 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 ROYAL DIAM, either own or subcontracted, the responsibility of rehabilitation will be undertaken by the management.
• The above policies will also be applicable to subcontracted labour.
The policies relating to this section are part of the Business Policies adopted by ROYAL DIAM and are presented below for reference:
• The management of ROYAL DIAM are fully committed to ensuring that forced or involuntary, bonded, indentured or prison labour, is not practiced nor usedin any form at any of its facilities.
• ROYAL DIAM 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 ofthe Business Policies.
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 whichis extracted from any person under the menace of any penalty, and for which the said person has not offered himself voluntarily
Conflict Minerals Policy Statement (Diamond & Gem Stone)
ROYAL DIAM is committed to being a responsible corporate citizen and is opposed to human rights abuses. As part of that commitment, ROYAL DIAM seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility.
ROYAL DIAM shall strive to ensure that all its supply of diamonds are not originating from CAHRA’s and where practically possible origin of diamonds is know to us.
Angola, Coast, Democratic Republic of the Congo, Liberia, Sierra Leone, Republic of the Congo & Zimbabwe Marange Diamond Fields
ROYAL DIAM shall ensure that none of its supplies are coming from above sources. Sight Holder shall communicate its sourcing policy to all the stakeholders and will ensure effective implementation among them.
• ROYAL DIAM complies with applicable national laws / regulations with respect to employment.
• ROYAL DIAM is 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
• ROYAL DIAM 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.
• ROYAL DIAM shall ensure that wages and benefits for a standard workingweek 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 amanner and location convenient to employees, accompanied by a wage slip detailingwage rates, benefits and deductions as applicable.
• ROYAL DIAM shall ensure that due process of wage deductions shall be followed where applicable and it shall not be binding on employees to buy provisionsfrom 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
• ROYAL DIAM is committed to addressing the legitimate grievances of its employees.
• ROYAL DIAM shall follow proper procedure as per law for dismissal of employees, in case the need for the same arises, and arbitrary dismissal proceduresshall be avoided.
Information regarding applicable employment policies and working practices shall be communicated in a transparent manner to all employees.
• ROYAL DIAM is fully committed to the pursuance of the provision of fair and conducive employment conditions, consistent with applicable laws and regulations.
The policies relating to this section are part of the Business Policies adopted by
ROYAL DIAM is presented below for reference:
• ROYAL DIAM 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.
• ROYAL DIAM shall act in accordance with national laws and national / international accounting standards with respect to maintaining financial accounts ofall business transactions and auditing of its financial accounts.
• ROYAL DIAM 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 tobe questionable may also be considered as a violation of the Business Policies, depending on the seriousness of the non-conformance.
• ROYAL DIAM 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.
The policies relating to this section are part of the Business Policies adopted by ROYAL DIAM and are presented below for reference:
• ROYAL DIAM 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 ofemployees on the basis of race, ethnicity, caste, national origin, religion, age, disability, gender, marital status, physical appearance, sexual orientation, HIV status, Migrantstatus, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by ROYAL DIAM and any such reported incidents will be viewed as a serious violation of this Business Policies
• ROYAL DIAM will ensure that employees who have certain life threatening diseases or illnesses are not treated differently from other employees, and will continueto 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.
• ROYAL DIAM 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
• ROYAL DIAM 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. ROYAL DIAM 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.
1. ROYAL DIAM is committed to complying with relevant trading standard legislation and specific national and local regulations applicable to its products.
2. The following essential Policies will be applicable in all transactions of ROYAL DIAM involving diamonds, treated diamonds, synthetics and stimulant
• Disclosure – ROYAL DIAM 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, color, clarity or fineness, of a diamond or gold jewelry product.
• Misrepresentation – No untruthful, misleading or deceptive statement, “representation” or material omission in the “selling”, “advertising” or distributionof 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 informationabout 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, manufacturersor trademarks; in connection with treated diamonds or diamond simulant orsynthetic Diamond
3. ROYAL DIAM 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 colors.
• 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 allof 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.
• ROYAL DIAM is committed to establish and implement product security measures within the premises and during shipments to protect against product theft, damage or substitution.
• The security and wellbeing of employees, visitors and other relevant business partners is prioritized when establishing product security measures
The policies relating to this section are part of the Business Principles adopted by ROYAL DIAM 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.
1. 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.
• RFull 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.
2. 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
3. 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.
4. 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.”
• 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 colors.
• 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 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 color and decolorisation 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.
The policies relating to this section are part of the Business Policies adopted by ROYAL DIAM and are presented below for reference:
• ROYAL DIAM 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 principlesof 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.
• ROYAL DIAM considers Bribery Risk as it applies to its organization (including agents) to identify which areas pose high risks. ROYAL DIAM has developed appropriate methods to monitor conduct of employees and agents and eliminate bribery based on this understanding.
• The management of ROYAL DIAM 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.
• ROYAL DIAM ensures that no employee will suffer demotion, penalty orother 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.
The policies relating to this section are part of the Business Policies adopted by ROYAL DIAM and are presented below for reference:
• ROYAL DIAM is committed to the development of communities where it operates, contributing to their social and economic welfare.
The policies relating to this section are part of the Business Policies adopted by ROYAL DIAM and are presented below for reference:
ROYAL DIAM 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 reviewedperiodically 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 throughtraining.
• 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
The policies relating to this section are part of the Business Policies adopted by ROYAL DIAM and are presented below for reference:
ROYAL DIAM recognizes the need to develop a sustainable, value creating business and is committed to the following in the areas of workplace healthand safety:
1. Providing safe and healthy working conditions for all employees in accordance with applicable law and other relevant industry standards.
2. 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.
3. 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
4. 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. Thereview 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
5. Workers shall not be under the influence of or abusing, drugs, alcohol and/ or other illegal substances.
6. 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.
7. All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable.
8. We will take adequate measures to safeguard our employees from fire and other workplace injuries.
9. All products sold by ROYAL DIAM to consumers shall comply to applicable regulations of product health and safety.
The policies relating to this section are part of the Business Policies adopted by ROYAL DIAM and are presented below for reference:
1. All employees in ROYAL DIAM will be treated with equality, respect and dignity.
2. ROYAL DIAM believes in and respects the fundamental human rights according to the United Nations Universal Declaration of Human Rights.
3. ROYAL DIAM 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
4. ROYAL DIAM strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior
5. 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 ofintimidation or degrading treatment will not be tolerated by the Group.
6. Security personnel, if employed by ROYAL DIAM are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat.
The policies relating to this section are part of the Business Policies adopted by ROYAL DIAM and are presented below for reference: Security personnel, if employed by ROYAL DIAM are trained to respect the human rights and dignity of all people and use minimum force proportionate to the perceived threat
The policies relating to this section are part of the Business Policies adopted by ROYAL DIAM and are presented below for reference:
All employees in ROYAL DIAM will be treated with equality, respect and dignity.
ROYAL DIAM create and ensure a safe environment that is free of sexual harassment, including safety from persons/visitors coming into contact at the workplace
ROYAL DIAM will not tolerate any sexual advances, requests for sexual favours, and verbal or physical conduct of a sexual nature are, implicitly or explicitly, made a term or condition of teaching/guidance, employment, participation, or evaluationof a person’s engagement in any activity.
ROYAL DIAM will not tolerate any sexual advances, and verbal, non-verbal and/or physical conduct such as loaded comments, remarks or jokes, letters, phone calls or emails, gestures, exhibition of pornography, lurid stares
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.
ROYAL DIAM will take cognizance of complaints about sexual harassment, conduct enquiries, provide assistance and redressal to the victims, recommend punitive action or take immediate action against the harasser, if necessary.
Security personnel, employed by ROYAL DIAM are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat.
ROYAL DIAM group recognizes that sourcing from conflict Affectedand High-Risk Areas should be in accordance with OECD Framework
The Company shall procure natural rough diamonds from trusted supplier. The company shall complete the due diligence process prior to initiate business relationship. The Company shall purchase/sale diamonds that are fully compliant with KPCS.
ROYAL DIAM group are committed to adopt and implement supplychain in accordance with the OECD guidelines.
As a management process the group shall adopt a risk-based due diligence process for responsible sourcing of minerals from conflict-affected and highrisk areas
ROYAL DIAM group will neither tolerate nor profit from, contributeto, assist or facilitate violation while sourcing from conflict affected regions.
ROYAL DIAM group shall only buy or sell diamonds that are fully compliant with the Kimberley Process certification Scheme and, as such willnot tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates.
ROYAL DIAM group will immediately stop engaging with supplies ifwe find a reasonable risk that they are committing abuses or are sourcing from, or linked to, any party committing violations or providing direct or indirect support to non-state armed groups.
ROYAL DIAM group shall train relevant employees on supply chain& Due Diligence Requirement and OECD guidelines at regular intervals. We shall also provide support to our business partners and stakeholders for the same
ROYAL DIAM group will not offer, promise, give or demand bribes,and will resist the solicitation of bribes, to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purpose of extraction, trade, handling, transport and export of diamonds.
ROYAL DIAM group will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport and export ofdiamonds.
The company shall assign the responsibility of Supply Chain and due diligence compliance to senior personnel of the organization to prevent any risk of illegal activities or breach of it. The company shall implement the management strategy to respond to identified risk if any. Compliance officer shall report to senior management in case of any such violation of this policy.
ROYAL DIAM keeping in view of the increasing importance of public grievances, have introduced the common grievance cell under the group complianceofficer to look in to matter of reporting noncompliance against any of the company policy or raising red flag against any of its business entity or individual involved in activities which will bring industry in disrepute.
1. Compliance Officer: Mr. Ajit Dugar (Partner) / Mr. Alok Dugar (Partner)
2. Communication by Address: DC 4220, Bharat Diamond Bourse, BKC, Bandra (E) Mumbai -400051, India.
3. Contact Number: +91 9820210372 / +91 9825111119
4. Email address: royaldiam.ajit@gmail.com / alok@royaldiam.co.in