SUPPLY CHAIN POLICY
At IGC Group of Companies (IGC), we are committed to the topic of ethical diamond sourcing and we are dedicated to combating the scourge of conflict diamonds.
We assure that we comply with all requirements and regulations with regard to the Kimberly Process, the United Nations Resolutions, and the WDC System of Warranties (SoW), and we require the same assurances from our suppliers.
We have adopted and committed to a Supply Chain Policy that adheres to the OECD Due Diligence Guidance for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-risk Areas. This Supply Chain Policy is endorsed by the highest level of IGC’s Management and BoD.
A) RESPONSIBLE DIAMOND SOURCING
We procure our rough diamonds only from renowned large-scale mining companies, such as De Beers, and the open market. We do not source from conflict-affected and high risk areas, nor from artisanal and small-scale mining.
IGC is not involved in the production, manufacturing and trade of Lab-grown Diamonds, Treated Diamonds and simulants
Assurance:
As per the World Diamond Council SoW requirement, we mention the following clauses on every incoming and outgoing invoice or memo:
“The diamonds herein invoiced/on memo have been purchased from legitimate sources not involved in funding conflict, in compliance with United Nations Resolutions and corresponding with national laws. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WDC SoW Guidelines.
“The diamonds herein invoiced/on memo are exclusively of natural origin and untreated based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.”
Furthermore, we state on our invoice/memo that: “We guarantee that the diamonds herein invoiced do not originate from Russian rough diamonds procured after February 24th, 2022.”
Disclosure
IGC‘s employees need to know what are Lab-Grown Diamonds, Treated Diamonds, and Simulants (LTS). In case IGC would sell any LTS, it would need to be disclosed before the sales transaction takes place, as well as on all documents related to the transaction. It must be disclosed up to end-consumer level.
Sourcing:
We purchase our diamonds only from reliable and respected suppliers who abide by and impose the highest ethical standards throughout their entire value chain, and with whom we have a long-standing business relationship. We don’t procure diamonds form unknown sources, reducing the risk of dealing with conflict diamonds to practically non-existing.
B) INTEGRITY
- Ethical Sourcing
As we are committed to the trade of diamonds that are sourced in compliance with the highest ethical standards, free of conflict, and strictly adhering to the human rights, we are not purchasing diamonds that origin from prohibited sources such as the Marange Mines in Zimbabwe.
We provide the necessary provenance claims to our customers and require from our vendors the same.
- Pipeline Integrity – De Beers Code of Origin (COO)
We participate in De Beers’ Code of Origin (COO) program for eligible stones of 0,20 carats and up. De Beers COO is a trusted source program which is designed to assure consumers that De Beers COO diamonds have been discovered by natural and conflict-free sources and have been obtained from eligible sources that form the provenance commitment of De Beers COO diamonds We are assessed against the 2022 Diamond Pipeline Integrity Specification (DPIS) and clearly demonstrate compliance with De Beers Best Practice Principle (BPPs) through independent third-party audits. Only diamonds sourced form approved suppliers (as defined and regularly updated by de Beers) are used in De Beers COO activities.
Regular pipeline integrity assessments are performed at each pipeline entity, both by internal assessors and by an independent third-party auditor.
C) DUE DILIGENCE
At IGC, we undertake risk-based due diligence, which entails a reasonable investigation to identify, assess, prevent and mitigate risks in our supply chain where the level of supply chain analysis is proportionate with the identification of risks.
Within this investigation process, we aim to identify any and all potential red flags. A red flag is a warning or indicator of a potential risk, which can refer to a location, supplier or circumstance. If a red flag would be identified, we will proceed with enhanced due diligence and further investigation.
We will immediately suspend or discontinue engagement with upstream suppliers where we identify reasonable risk that they are sourcing from, or linked to, any party committing serious abuses against human rights or participate in money laundering practices.
Performing extensive due diligence is a complex, demanding process and requires adequate resources. Therefore, we have a full-time Compliance Officer at our headquarters in Antwerp, who is knowledgeable and dedicated to this process.. Regular review by and reporting to the Group Compliance Officer is done, at least annually.
An annual report to IGC’s BoD is done on any red flags or concerns that may have arisen during its due diligence processes for en ethical and integer pipeline.
D) DUE DILIGENCE TOOLKIT
IGC performs its due diligence for both its supply chain and customer base with a dedicated compliance officer. A detailed description of the due diligence process and tools can be found in IGC’s AML Policy and Procedures, which is published on our website.
E) SUPPLIER ENGANGEMENT
We request from both our rough and polished suppliers the same level of due diligence regarding their supply chains and require communication about it. As a De Beers Sightholder and RJC Certified Member, we expect form our suppliers that they sign an undertaking in which they declare to adhere to the De Beers BPPs and RJC CoP. We also request our suppliers to complete our due diligence questionnaire as part of our supply chain risk assessment.
We require our suppliers to provide additional information re the origin of the supplied diamonds to us. We request both our rough and polished suppliers to provide the provenance of the rough diamonds (country of origin and/or mining company) as well as the guarantee that the diamonds are sourced/produced ethically.
F) COMMUNITY DEVELOPMENT
IGC seeks to support the social, economic, and institutional development of the communities in which it operates and supports various community initiatives.
As a company, we develop programs and support projects with the goal to improve the economic and social welfare of the communities involved in our supply chain
We support our employees in their participation in community programs aiming at enhancing society and we assist them where relevant.
G) SUPPLY CHAIN GRIEVANCE MECHANISM
At IGC, we offer all parties (affected stakeholders or whistle-blowers) a way to raise concerns about the businesses, organizations, individuals or activities in our supply chain. This grievance mechanism serves as a tool for identifying and reacting to issues in the supply chain that may otherwise go unnoticed.
Concerns can be raised via email or telephone to:
IGC Group NV
Schupstraat 15 – 2018 BE Antwerp
Tel. +3232034567
Grievance Procedure:
When receiving a complaint, we:
- obtain an accurate report of the complaint
- allow for anonymous reporting of concerns or incidents
- undertake to protect reporting parties from retaliation and will treat all reports in a confidential and sensitive manner
- explain our complaint procedure
- learn how the appellant would like to see the complaint handled
- appoint the appropriate person internally to handle the complaint
- if needed, assist with redirecting the complaint to another entity such as the relevant supplier, or an institution such as a relevant industry body
- if the issue can be handled internally, seek further information where possible and appropriate
- identify any actions to be taken, or monitor the situation
- advise the appellant about any decisions or outcomes
- keep records on complaints received and the internal process followed for at least 5 years.
For further inquiries, please contact:
Anne-Marie De Scheemaecker
+32 3 203 45 67
Updated JULY 2022