VENDOR AUDITING. Vendor compliance with “RRP” and its standards is essential to Richline’s ethical sourcing throughout its supply chain. Regular audits are conducted on both internal and external vendors to verify compliance with the Richline Responsible Vendor Code of Conduct (“RRVCoC”). These audits ensure all applicable responsible, ethical and requirements are being adhered to. The “RRP” offers a vendor the chance to strengthen and improve upon everyday business practices and their position within the global market.
CONFLICT FREE SUPPLY
DODD FRANK ACT. Section 1502 of the Wall Street Reform and Consumer Protection Act, known as the Dodd Frank Act, is a significant law sure to have a wide ranging impact on the jewelry industry. The legislation, passed in 2010, addresses “conflict minerals,” identified as tin, tantalum, tungsten and gold. In particular, the law focuses on conflict minerals that originated in a region of Africa where violence is associated with the production and transportation of these natural resources. Pursuant to Dodd Frank, companies that are listed with the Securities and Exchange Commission (SEC), and that use these minerals in the products they manufacture, or “contract to manufacture,” must provide specific information to the public concerning the minerals. To do this, they must conduct an inquiry regarding the source of the minerals. Depending on the results of the inquiry, the companies may also be required to conduct “supply chain due diligence” to determine whether any of the minerals benefitted armed groups in the region, and to report if any of their products are not “conflict free.” Two of the conflict minerals, gold and tungsten, are, of course, very important to the jewelry industry. A third mineral, tin, while less common, is increasingly used in jewelry products.
Richline Group, Inc. fully supports the SEC’s final rulings and is positioned properly to supply gold raw materials, components and finished goods which are fully compliant with SEC guidelines. We remain committed and focused on our leadership role in working with stakeholders and industry peers to develop sustainable, practical solutions that create transparency in the supply chain and promote responsible sourcing of minerals. The Richline chain-of-custody process will be the continued basis of our sustainability and accountability efforts and programs.
In support of our responsible sourcing policy, Richline and Suppliers will:
- Only accept gold from refiners on the LBMA good delivery list, EICC/GeSI conflict –free compliant smelter list, certified members of the Responsible Jewellery Council or refiners which certify and independently audit that all gold supplies are conflict free, in accordance with one of the following standards: RJC chain of custody standard, OECD Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas Supplement or the World Gold Council Conflict-Free Standard.
- Only accept gold from Banks which certify and independently audit that all gold is supplied from Refineries which adhere to the refinery compliance requirements listed above.
- Only accept gold from Precious Metals Trading Companies which certify and independently audit that all gold from Refineries and/or Banks which adhere to the Refinery and Bank compliance requirements listed above.
- Only accept scrap and / or recycled gold from customers or suppliers which certify and independently audit that all scrap and recycled gold is identifiable as its own production and supply, i.e. scrap gold is returned product from customers, faulty inventory or scrap generated during the production process.
KIMBERLEY PROCESS. Vendors are strictly prohibited from intentionally purchasing, selling, or distributing diamonds originating from conflict areas. Organizations whom are engaged in the buying, selling, and exporting of rough diamonds must fully comply with the systems and controls set out by the ‘Kimberly Process Certification Scheme.’ Suppliers engaged in any type of diamond purchasing or sales must comply with the guidelines of the ‘World Diamond Council Resolution on Industry Self-Regulation.’ Employees involved in the activities mentioned in this paragraph are required to be knowledgeable and aware of all local and international restrictions on the trade of conflict diamonds, including the ‘Kimberly Process Certification Scheme,’ and the ‘World Council Systems of Warranties.’