​Ethical Business Policy

1. Legislation and Regulations

2. JEWEL NXT shall operate in compliance with relevant national and international legislations / regulations as applicable in the countries in which they operate.

3. All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal JEWEL NXT rules and policies relating to their business activities.

4. It is the responsibility of personnel to know and understand legal, regulatory and internal requirements as they apply to their jobs.

5. Compliance team maintains the list of applicable legal and regulatory requirements and same is followed for compliance on day to day basis. Necessary records of requirements and its compliance is maintained. 

   1. Money Laundering, Terrorism Financing, Other Financial Offences

6. JEWEL NXT recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.

7. JEWEL NXT shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations. Following acts and international guidelines is considered while establishing company level policies  

• Prevention of Money laundering Act 2002

• FATA 40 Recommendations and 8 special recommendations

1. It is the responsibility of concerned personnel to know and understand the relevant 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 Principles, depending on the seriousness of the non-conformance.

2. Compliance officer ensure all the critical steps such as KYC & KYS, Identification of suspicious transaction, reporting to management and record keeping as required by the local act and legislations are complied with.

3. Compliance officer caries out periodic review of AML/CFT compliances and submits his report to management on Quarterly basis.

 

1. Kimberley Process and System of Warranties

1. JEWEL NXT is dealing in polished diamonds and fully committed to complying with all the requirements specified in World Diamond Council’s (WDC) System of Warranties Declaration.

2. We will not engage in business with the supply chain who deals in ‘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 Principles.

   1. Anti-Bribery and Facilitation Payment Policy:

1. The JEWEL NXT shall ensure complete prohibition of Bribery and facilitation payment across organization and in all the entities.

2. JEWEL NXT will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.

3. Entity shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.

   1. Disclosure of Treated Diamonds, Synthetics and Stimulant

The following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and stimulant

• 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.

• We deal in real and natural diamonds only and any treatment of real and natural diamonds is disclose to customer prior to sales 

  1. Diamond & Gemstone Sourcing Policy:

Conflict Minerals Policy Statement (Diamond & Gem Stone) 

JEWEL NXT is committed to being a responsible corporate citizen and is opposed to human rights abuses.  As part of that commitment, JEWEL NXT seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility. 

JEWEL NXT shall strive to ensure that all its supply of diamonds are not originating from CAHRA’s and where practically possible origin of diamonds is known to us.  

What Are "Conflict Diamonds"? 

Blood Diamonds, also known as "Conflict Diamonds" are stones that are produced in areas controlled by rebel forces that are opposed to internationally recognized governments. The rebels sell these diamonds, and the money is used to purchase arms or to fund their military actions. 

Blood Diamonds are often produced through the forced labour of men, women and children. They are also stolen during shipment or seized by attacking the mining operations of legitimate producers. These attacks can be on the scale of a large military operation. 

The stones are then smuggled into the international diamond trade and sold as legitimate gems. These diamonds are often the main source of funding for the rebels; however, arms merchants, smugglers, and dishonest diamond traders enable their actions. Enormous amounts of money are at stake, and bribes, threats, torture, and murder are modes of operation. This is why the term "blood diamonds" is used. 

CAHRAs are. 

Angola ,Coast, Democratic Republic of the Congo ,Liberia, Sierra Leone, Republic of the Congo & Zimbabwe Marange Diamond Fields   

JEWEL NXT 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. 

1. Gold & Platinum Group Of Metal Sourcing Policy:

       Our Company is concerned about environment and social impacts of irresponsible mining.

        We at JEWEL NXT shall ensure that all our gold suppliers are in compliance with gold souring guidelines (Dodd- Frank rules, DRC & other applicable legislation).

         Further, we are committed to ensure that sourcing of gold and precious metal products and articles thereof, are under the highest Social, Human right and Environmental standard cautions of trade.

1. Supply Chain Management / Best Endeavours

The management of JEWEL NXT is committed to take appropriate action to use best endeavours to ensure that the suppliers and contractors are committed for compliance to International Social Standards such as RJC & SMETA etc.

1. Employment

2. Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.

3. The JEWEL NXT shall not require Staff  to work for more than  the national limit of hours  in a week  on a regular basis.                                                                                                                                                  

4. The JEWEL NXT shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards.

5. Health and Safety

JEWEL NXT recognizes the need to develop a sustainable, value creating business and is committed to the following:

• 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.

• This review will use appropriate standards as required by prevailing laws, expert opinion and our knowledge of best practices.

• The review will lead to formulation of clearly described work practices and drills.

• All our staff will be trained in the manner required to adhere to these work practices and drills.

• All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable

  1. Non Discrimination, Disciplinary Practices

1. Discrimination can mean distinction, exclusion or preference.

2. Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by the JEWEL NXT Any such reported incidents will be viewed as a serious violation of this Business Principles.

3. We shall at no time condone the use of corporal punishment or other forms of mental or physical coercion. 

4. We encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, JEWEL NXT operation or practice is or will likely be in violation of any law, regulation or internal rule or policy, including this Business Principles.

   1. Child Labour

1. No form of child labour should be employed at any of the facilities of the JEWEL NXT Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).

2. For authorized adolescents (persons below 18 years of age but above 15 years), the JEWEL NXT Management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.

3. As per our JEWEL NXT policy no child labour or adolence child labour will be employed.

4. JEWEL NXT will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

   1. Forced Labour

1. The management of JEWEL NXT is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of this Business Principles.

2. 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 they said person has not offered himself voluntarily”

  1. Human Rights

1. All employees in the JEWEL NXT facilities will be treated with equality, respect and dignity.

2. JEWEL NXT 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

3. The JEWEL NXT strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.

   1. Environment Protection

JEWEL NXT is committed to effective environmental management as one of its important corporate priorities, and will focus on the following initiatives:

• Compliance with all applicable environmental laws and regulations

• The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards 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 and best practices of the industry.

• Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.

  1. Product Security

JEWEL NXT is committed to provide safety of product throughout its supply chain by following precaution as mentioned below

• Each and every stage of product processing it is covered through blanket insurance

• Suitable safe guarding and storage is ensured at all stage with the help of safes

• We are taking at most care to ensure safety of visitors, Customers and interested parties, suitable arrangements such as CCTV, Multi level entry doors and other electronic intelligence.

• All the concern persons are trained on relevant safety and security procedures to be followed at all time.

Public Grievances against social & Ethical compliance of the JEWEL NXT

 

If you come across any instance of non compliance or specific deviation from our ethical policy, please feel free to reach us.

 

Further in case if you are interested to obtain the copy of our sourcing annual compliance report based on OECD guidelines. Please send an email communication to below mentioned email address.

Contact: Mr. Pradeep Agrawal (Compliance Officer)

accounts@jewelnxt.com
 

Prepare by : Pradeep Agrawal                            Approved By : Pushpak Desai

Date:1st September, 2024

​

Annual Business Responsibility and OECD Compliance Report

 

Section A: General Information about the Company:

Jewel NXT operates from SEEPZ Special Economic Zone in Mumbai, India, and is a manufacturer of fine jewellery. With a workforce of 300 employees, we specialize in crafting studded jewellery made from gold & silver. Our management team, with over 40 years of experience in the gems & jewellery industry, brings a wealth of expertise to the company.

Core Goals

• Customer Satisfaction and Service: Prioritize exceptional customer experiences through personalized service, prompt communication, & reliable after-sales support.

• ​Quality and Craftsmanship: Create impeccably crafted jewelry pieces that exude exceptional quality and attention to detail.

• ​Design Innovation & Creativity: Embrace cutting-edge designs that captivate customers with originality & reflect the latest fashion trends.

Our Expertise

• Men's Jewellery

• Fine Jewellery

• Wedding Jewellery

• Hip-Hop/Custom

​

Section B: Financial compliance of the JEWEL NXT:

1. Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

• JEWEL NXT recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.

• Strict compliance is ensured at all the entities and compliance officer has been appointed who in turn reports to JEWEL NXT Management on compliance status on annual basis.

• Know Your Counter Party and other compliance of Due Diligence is followed in line with OECD guidance.

• Ongoing monitoring is carried out along with all stakeholders.

Area of concern & Remedial Measures

• Nil As on Date.

 

1. Kimberley Process and System of Warranties

• JEWEL NXT is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme of World Diamond Council’s (WDC) System of Warranties Declaration.

• Day to day monitoring and compliance of SOW is done by compliance officer.

• JEWEL NXT is committed towards conflict free sourcing and zero tolerance policy is followed at JEWEL NXT level.

Area of concern & Remedial Measures

• Nil As on Date.

 

1. Anti-Bribery and Facilitation Payment Policy:

• The JEWEL NXT shall ensure complete prohibition Bribery and facilitation payment across organization and in all the entities.

• JEWEL NXT has published compliance team contact details on website to receive any grievance or complaints.

Area of concern & Remedial Measures

• Nil As on Date.

 

1. Ethical Sourcing of Loose Diamonds Policy:

• Our company is concerned about the environment and social impacts of irresponsible mining.

• JEWEL NXT has identified the risk of supply chain with respect to Conflict Affected High Risk Area.

• JEWEL NXT ensure all its supplies are screened for conflict free supplies.

• We have published the OECD based ethical sourcing policy and we are communicating our policies to all the supply chain partners and pushing them to adopt the same.

Area of concern & Remedial Measures

• Current concern is lack of awareness about OECD regulation and requirements of sourcing.

• We have started creating awareness about our Ethical sourcing requirements for our supply chain through email communication.

• We started Engagement with our global supply chain for obtaining the further supply chain information to ensure ethical and conflict free sourcing in metal business.

  1. Social Compliance

• We ensure full compliance with all applicable national and, where appropriate, international laws / regulations with respect to employment and labour codes in all our establishment.

• We respect all regulation for child labour, forced labour, non-discrimination, non-retaliation etc.

• All work man rights are respected and adhere to freedom of association and collective bargaining regulations.

Area of concern & Remedial Measures

• No point has been reported in the social compliance of the JEWEL NXT where remedial measures at JEWEL NXT level is required.

• Company level remedial measures are taken based on internal and external audits conducted by reputed agencies.

 

1. Health and Safety

• We at JEWEL NXT are concern about the health and safety of employees and are constantly studding about any adverse impact of our business processes are identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.

• This review will use appropriate standards as required by prevailing laws, expert opinion, and our knowledge of best practices.

• All our staff will be trained in the manner required to adhere to these work practices and drills.

• The health of our staff, exposed to certain hazardous processes, is be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.

• All workplaces are constructed to meet safety standards with local regulations as the minimum standards that will be applicable.

Area of concern & Remedial Measures

• Nil as on date, as no accidents are reported in last one year.

• Organization has been blessed and we did not have any fire or any other incidents leading to dangerous circumstances.

  1. Human Rights

• JEWEL NXT is not and 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.

• The Company strongly discourages any form of sexually coercive, threatening, abusive or exploitative behaviour.

• 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.

• JEWEL NXT ensures that none of its suppliers and stake holder have engaged in any activity which can violate the Human Right Principles.

• We have carried out the Human Right Due Diligence of suppliers and other Stake holders & based on risk assessment where necessary.

Area of concern & Remedial Measures

• No Area of concern & Remedial Measures has been raised in the Human right for any of our operating units.

• Supplier’s further upstream compliance with respect to Human Right compliance for conflict free sourcing is a new development, where company is heading and would require more focus on the same.

  1. Environment Protection

• JEWEL NXT is Complying with all applicable environmental laws and regulations.

• Improvement is seen employee’s environmental awareness and performance with the help of detailed policies and procedures, training, and recognition of excellence.

Area of concern & Remedial Measures

• Nil, mainly Sales office and no manufacturing activity.

​

ANNUAL REPORTING TEMPLATE (RJC TOOL KIT VERSION 5.0)

Company Name:

JEWEL NXT

Date:

14th September 2024

Reporting Period:

Financial Year 2023-24

Step 1: Establish strong company management systems

1.A.  Adopt and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict­ affected and high-risk areas

• We are pleased to inform our stakeholders that our updated policy has been published on our company website for easy access. We are committed to transparency and ensuring that all relevant information is readily available.

• In addition, we have conducted our annual communication in line with OECD guidelines and best practices. This communication has been sent via email to all active suppliers to ensure they are informed and aligned with our standards.

1.B Structure internal management systems to support supply chain due diligence.

• To further enhance our commitment to ethical practices, we have recently assigned additional responsibilities to our Compliance Officer. This role now includes overseeing adherence to our Ethical Sourcing Policy, ensuring robust compliance across all facets of our operations.

• We are also dedicated to equipping our team with the necessary knowledge and skills. All key employees involved in the sourcing and procurement of precious metals have undergone comprehensive training on our Ethical Precious Metal Sourcing Policy. Refresher training sessions are regularly provided to maintain high standards and up-to-date awareness.

• In our ongoing efforts to uphold ethical standards, we maintain a comprehensive list of suppliers, including their social and ethical compliance status. This enables us to ensure that all our partners adhere to our rigorous ethical guidelines.

• Our monitoring process is thorough and continuous. We utilize various tools such as digital media, web searches, review of supply documents, declarations, and market intelligence to track and evaluate the compliance of each supplier and their associated networks..

1.C Establish a system of controls and transparency over the minerals supply chain.

• Supplier upstream information collection process started and to obtained CAHRA’s information and Ethical sourcing compliance at supplier level.

• Currently Jewel NXT 75% and above supply from law risk and balance 25% is from non-regular suppliers.

1.D Strengthen company engagement with suppliers.

• the supplier questionnaire has been circulated as part of our due diligence process. We are actively following up with the suppliers to ensure that we obtain the completed information required for further evaluation.

• Further we are also obtaining the vital information about suppliers from social platforms and social compliance registration such as BPP & RJC, Approved ASM programs etc

• We are in the process of compiling filled supplier questionnaire data, after analysis we will be formulate supplier engagement practices based on risk reported at each supplier level (if any)

1.E Establish A Company-Level, Or Industry Wide, Grievance Mechanism as An Early Warning Risk-Awareness System.

 

• We have established a comprehensive grievance handling policy and procedure at the company level. For any concerns or issues, please refer to the contact details of our Compliance Head, which are provided in the Social and Ethical Policy available on our website under the Business Principles section. This information is publicly accessible to ensure transparency and facilitate communication.

Step 2: Identify And Assess Risk In The Supply Chain

Identify And Assess Risks in The Supply Chain and Assess Risks of Adverse Impacts.

 

• We have established the detailed policy and procedure for identification of risk at our Company level.

• Company has appointed and trained compliance officer to oversee the financial and ethical sourcing compliances.

• We have categorized supply chain in to 2 major segments that its Secondary supplier and Open market suppliers.

• All suppliers are bifurcated in to this category and open market supplies are considered as potential risk for supplies from CAHRA’s and thus step by step information are gathered from this category of supplier as mentioned in point 1.B & 1.C

• Step 3: Design And Implement a Strategy to Respond to Identified Risks (If Applicable)

Report Findings of The Supply Chain Risk Assessment to The Designated Senior Management of The Company.

• Ongoing monitoring of each supply is done by compliance officer to confirm its free from Conflict, were required Red Flags are been raised for seeking additional information and closed after receiving such information to our satisfaction.

• Compliance officer shall report all un-answered flags to Top management.

• In worst situation where information is half or not satisfactory management starts engagement practice and discussion and dialogue with suppliers is carried out to ensure full information in further business.

Devise And Adopt a Risk Management Plan.

 

• We have formulated the risk management plans at company level considering in supply chain and position of supplier in supply chain.

• Company compliance officer carries out monitoring of each and every business transaction and were required Red Flags are been raised and further steps are followed as mention above.

• Brief of companies Risk Management Practices has been mentioned in communication of Business policy on our website. 

Implement The Risk Management Plan and Monitor Performance of Risk Mitigation Efforts.

 

• At the organizational level, we have been actively monitoring for any red flags. During the review period, no red flags were identified.

• The Compliance Officer provides periodic status reports on OECD compliance to the management.

Internal Training

 

• The organization provides periodic training to all employees involved in buying, selling, and compliance monitoring.

Communications

 

• Business principle has been published on the website covering all the COP wise policy including Ethical Precious Metal souring policy of the organisation.

• In addition to our annual communication on business policies, we also provide ongoing awareness on various best practices and expectations for our business partners through email.

OPTIONAL INFORMATION ON Step 4: Carry Out Independent Third-Party Audit

RJC COP Audit

• The company has scheduled a re-certification audit for the RJC Code of Practices (COP) 2019 on September 23rd and 24th, 2024. This audit is part of our ongoing commitment to maintaining certification standards and ensuring compliance with the RJC guidelines.

Grievances And Remediation

• No grievance of what so ever has been reported till date.

 

Prepared by : Mr. Pradeep Agrawal                

 

Date: 14th September, 2024