IBB RESPONSIBLE SOURCING POLICY:

IBB requires that all its business dealings are consistent with best practice and at the highest standards of ethical conduct. IBB is a certified member of the Responsible Jewellery Council (“RJC”). RJC members commit to and are independently audited against RJC codes of practice which address matters including human rights, labour rights, environmental issues, mining practices and a responsible jewellery supply chain. This document outlines the core minimum standards and expectations IBB requires of all our suppliers and parties with whom we transact business.

GENERAL CODES OF BUSINESS PRACTICE

IBB is committed to conducting business to the highest ethical standards and to ensuring integrity, transparency and conformance with all applicable legislation. Please note the following:

• IBB will not tolerate money laundering and/or the financing of terrorism.
• Suppliers must maintain proper financial accounts of all business transactions as required by local laws and in accordance with national and international accounting standards. Accounts must be independently certified by a properly qualified auditor who is appointed free of any bias or influence.
• Suppliers will comply with the provisions in the Financial Action Task Force (“FATF”) 40 Recommendations and 9 Special Recommendations as applicable to dealers in precious metals and gemstones. Cash transactions should always take place in accordance with applicable law and where they occur above relevant thresholds, records need to be lodged with relevant financial authorities.
• Suppliers must operate according to principles of “know your customer” to establish the identity of organisations with which they deal, have a clear understanding of their business relationship and have a reasonable ability to identify and react to transaction patterns appearing out of the ordinary or suspicious.
• IBB will fully and accurately disclose the material characteristics of the products that it sells and accordingly suppliers will always comply with relevant trading standards legislation applicable to jewellery products and suppliers must make all reasonable effort to properly disclose the physical characteristics such as mass/weight, fineness, cut, colour, clarity etc. Suppliers must not make any untruthful, misleading or deceptive statements concerning their products. Regarding gold products suppliers will accurately disclose the fineness of the gold used and apply any marks in a manner authorised by applicable law and international standards.
• IBB encourages the use of recycled precious metals as far as possible in the manufacture of jewellery products that it purchases.
• IBB takes all reasonable measures to ensure the physical integrity and security of product shipments and suppliers must do the same.
• IBB will always respect commercial confidentiality and data privacy and suppliers must ensure that they have adequate controls in place to ensure the same in respect of its business and customers.
• IBB respects fundamental human rights and dignity of the individual according to the United Nations Universal Declaration of Human Rights and suppliers must do the same. 
• IBB is committed to high standards of health and safety in its operations. Suppliers will provide safe and healthy working conditions for all employees in accordance with applicable law and other industry standards. 
• Finished jewellery products must be compliant with applicable legislation for product health and safety.
• Suppliers are expected to support the development of communities where they operate and respect the rights of indigenous peoples and their values. 
• IBB will not engage in bribery and/or corruption. Suppliers must prohibit bribery and corruption in all business practices and develop methods to monitor this amongst their staff and organisations generally. 

ENVIRONMENTAL ISSUES

IBB prides itself on conducting business in an environmentally responsible manner and requires that suppliers:

• Introduce wherever possible management and operating systems to minimise the detrimental environmental impacts of its business practices.
• Not manufacture, trade in, or use chemicals and hazardous substances subject to international bans or phase-outs.
• All mining suppliers using cyanide in the recovery of gold will comply with the International Cyanide Management Code 2005 and will ensure that applicable sites are certified to the International Cyanide Management Code as soon as possible.
• Dispose of waste substances in compliance with all applicable laws or prevailing international standards. 
• Will take steps to reduce the quantity of waste produced through the principles of reduce, recover, re-use, recycle.
• Will seek to decrease emissions to air, water and land relative to production output.

WORKPLACE ISSUES

• No forced or involuntary labour is to be used and workers must be free to leave their employment on reasonable notice. Workers should not be compelled to lodge deposits or identity papers. Workers should be free to leave once their shift ends. Workers have a right to form or join trade unions of their choosing and to bargain collectively. Employers should adopt an open attitude to legitimate activities of trade unions. 
• A safe and hygienic working environment shall be provided having special regard to the manufacture of jewellery and any specific hazards relating thereto. Adequate steps are to be taken to prevent accidents and injury at work and first aid facilities must be provided. Workers shall receive due health and safety training. Hazardous materials are to be properly controlled and workers must be provided with appropriate protective equipment. Unfettered access to drinking water is to be available and clean toilet facilities must be offered. Accommodation (where provided) shall be clean, safe and meet basic needs. 
• There shall be no recruitment of child labour. Employers shall participate in programmes which provide for the transition of any child found to be performing labour to enable them to attend and remain in quality education until they are no longer a child. Anyone under the age of 18 shall not be employed at night or under hazardous conditions.
• Wages and benefits paid for a standard working week must, as a minimum, meet national legal standards. In any event wages should always be high enough to meet basic needs and provide some discretionary income. All workers should be given written and understandable information concerning their employment terms and deduction from wages as a disciplinary measure shall not be permitted. All compensation, benefits and deductions or withholdings must be properly calculated and documented.
• Working hours must comply with national laws and benchmark industry standards whichever afford greater protection. Workers should be provided with at least one day off for every seven-day period on average. Overtime working should be voluntary and compensated for at a premium rate.
• There should be no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, gender, marital status, sexual orientation, union membership or political affiliation. Maternity and paternity rights must be respected in accordance with national legislation. There should be no inappropriate medical testing used in determining employment.
• Physical abuse or discipline, the threat of such, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. Only workers with a legal right to work shall be employed and employers are expected to validate such legal right by reviewing original documentation of employees (including that of any agency staff).
• COVID-19 – IBB expects all supplier facilities to be made as Covid-19 secure as possible having regard to all local requirements in that regard.

GOLD AND PRECIOUS METAL SOURCING: CONFLICT MINERALS 

IBB is concerned about the environment and social impact of mining practices and seeks only to

source gold and other precious metals produced under the highest standards and it does not 

knowingly purchase any materials from conflict areas. In certain African countries

(including Democratic Republic of Congo (DRC), Sierra Leone, Angola and Liberia)

rebel forces have control of mineral mines and proceeds of the sale of gold and the 3T’s (tin,

tungsten and titanium) are used to finance weapons. Such minerals are known as “conflict

minerals”). The Dodd- Frank Act enacted in USA requires companies to disclose whether 

products are free from conflict minerals. As a condition of doing business with IBB the supplier 

must work to ensure that gold and other precious metals supplied to IBB are free from conflict 

minerals and come from sources that meet the following criteria at all stages of the supply

chain. IBB suppliers must agree to do the following:

• Certify that gold and other precious metals used in their products did not originate in DRC or adjoining countries and that such metals used in their products are sourced from refineries on LBMA or DMCC “good delivery” list, from banks using metals from LBMA or DMCC “good delivery” refineries or from metal trading company or refinery otherwise certified as conflict free. 
• Not source gold and other precious metals from areas of armed or militarized conflict where there is a higher risk of human rights violations or from mines that have been responsible for the forced displacement of communities.
• Not source gold and other precious metals from areas that are designated as protected or of high conservation/ecological value.
• Source gold and other precious metals from mines that have provided full financial guarantees to cover the costs of clean-up and mine closure.
• Commit to increasing the sourcing of gold and other precious metals from recycled and secondary sources. 
• Implement policies generally that promote more responsible production of gold and precious metals.

DIAMONDS: CONFLICT DIAMONDS AND KIMBERLEY PROCESS

In certain African countries where rebel forces have control of some diamond mines, proceeds from the sale of diamonds are used to finance the purchase of weapons which in turn deepens conflict. These countries include the Democratic Republic of Congo, Sierra Leone and Liberia – these diamonds are often known as “conflict diamonds”. IBB adheres to the Kimberley Process Certification System and World Diamond Council voluntary system of warranties and accordingly:

• Suppliers must not knowingly buy or sell conflict diamonds or assist others to do so.
• Where involved in the international trade of rough diamonds, suppliers must apply the rough trade diamond export and import verification system and controls as laid down by the Kimberley Process Certification Scheme and relevant national legislation. Suppliers must keep records of such certificates which must be independently audited and reconciled by an auditor on an annual basis. 
• Where involved in the buying and selling of diamonds (whether rough, polished or set in jewellery), suppliers must fully adhere to the principles of the World Diamond Council Resolution on Industry Self-Regulation. Members are required to have systems in place so that all invoices for diamonds either bought or sold contain the World Diamond Council warranty statement: “The diamonds herein invoiced have been purchased for legitimate sources, not involved in the funding of conflict in conformance with United Nations resolutions. The seller hereby guarantees that these diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds”. Suppliers must keep records of all such invoices and have systems in place so that they do not purchase from sources that do not provide this warranty statement on their invoices.