Corona Jewellery Company Ltd and the Responsible Jewellery Council
Corona Jewellery Co. is guided by our mission to manufacture consistently high-quality precious metal and gemstone jewellery, reasonably priced, for sale to retail jewellers in a global marketplace. We will strive to maintain a professional, conscientious and ethical approach to conducting each and every transaction. To that end Corona Jewellery Co. voluntarily joined the Responsible Jewellery Council (RJC) in 2009.
The RJC is a standards-setting organization established to advance responsible ethical, human rights, social and environmental practices throughout the gold, silver, platinum group metals, diamond, and coloured gemstones jewellery supply chain. For RJC audit purposes coloured gemstones refers specifically to ruby, blue sapphire and emerald gemstones.
The RJC has developed a benchmark standard for the jewellery supply chain and credible mechanisms for verifying responsible business practices through third-party auditing.
We encourage our suppliers and customers to be members of the RJC and for suppliers we encourage them to not only undertake the RJC audit but to follow the Organisation for Economic Co-operation and Development (OECD) aligned approach for due diligence for their own supply chains.
As an RJC member we commit to operating our business in accordance with the RJC Code of Practices Standard. Every day we commit to integrating ethical, human rights, social and environmental considerations into our operations, business planning activities and decision-making processes.
President of Corona Jewellery Co.
Reviewed June 24, 2021
Corona Jewellery Co. has embedded sustainable and responsible business practices into its day-to-day operations. As a member of the Responsible Jewellery Council (RJC), Corona Jewellery Co. is committed to implementation of the Code of Practices (COP) standard and as such we have developed a range of policies and procedures to ensure our ongoing compliance with its requirements.
We are also committed to developing and nurturing strong relationships with suppliers and other business partners to promote responsible business practices throughout our supply chain. This includes taking steps to identify and, where applicable, mitigate negative social and environmental impacts with a particular focus on addressing issues related to human rights, child labour and forced labour.
To achieve this, we carry out due diligence on all of our suppliers in alignment with the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance).
Developed internal control systems and processes for collecting and recording information on the origin of jewellery materials supplied to us and, where available, information relating to due diligence carried out by suppliers.
Reached out to all of our suppliers to communicate and to request information on a Know Your Supplier (KYS) and an Undertaking form.
Developed a system for identifying risks in our supply chain and ´red-flag locations’.
To understand the potential and/or actual human rights risks that might be present in our upstream supply chain, we asked all of our suppliers to sign a letter of undertaking and a revised Know Your Supplier (KYS) form. The two forms asked suppliers to provide information on their legal compliance, labour practices, controls to manage child and forced labour risks, how they manage their impacts to the environment, the controls they have in place to ensure adequate workplace health & safety and the due diligence processes they have in place to address risks related to minerals originating from Conflict-Affected and High-Risk Areas (CAHRAs).
We will continue to work with our supply chain throughout 2021 and into 2022 to build on these efforts which will include, where applicable, steps to appropriately manage identified risks in alignment with our policies and the requirements of the RJC Code of Practices (2019) standard.
In addition to the above we have also implemented processes and controls to manage the environmental impacts of our direct business operations. This has included implementing measure to minimize waste, increase recycling of paper and the implementation energy efficiency measures. During 2021-2022 we will continue to seek opportunities to improve our environmental performance.
Reviewed September 28, 2021
Human rights are the basic political, civil, economic, labour, social and cultural rights and freedoms to which all people are entitled, without discrimination (1). It is expected that businesses respect human rights throughout the value chain. We believe that respecting human rights and contributing to the realisation of rights is not only critical to the sustainable operation of our business, it is the right thing to do.
We see human rights as critical to our ability to contribute meaningful and ongoing social value to our stakeholders. Simply put, our success depends upon how well we respect the rights of individuals and groups who interact with and are impacted by our business operations and relationships. We demonstrate our commitment to respecting human rights by:
Respecting internationally recognised human rights as set out in the United Nations (UN) Universal Declaration on Human Rights.
Complying with applicable laws and regulations of the countries in which we operate, and where differences exist between Our Code of Conduct (Our Code) and local customs, norms, rules or regulations, we apply the higher standard.
Operating in a manner consistent with the UN’s Guiding Principles on Business and Human Rights, the 10 UN Global Compact Principles, the Voluntary Principles on Security and Human Rights and the International Council on Mining and Metals (ICMM) Indigenous Peoples Position Statement.
Operating in a manner consistent with the terms of the ILO Declaration on Fundamental Principles and Rights at Work, including the four Core Labour Standards the subject of the ILO Conventions upon which the Declaration is based, concerning:
freedom of association and the effective recognition of the right to collective bargaining;
the elimination of all forms of forced or compulsory labour (2)
the effective abolition of child labour; and
the elimination of discrimination in respect of employment and occupation.
We are committed to respecting and contributing to the realisation of all human rights, prioritising those based on risk to the people, including vulnerable or marginalized groups, potentially impacted by our operations and business relationships and the related risk to Corona.
These include rights related to:
workplace health, safety and labour conditions;
freedom from discrimination based on personal attributes unrelated to job performance, such as race, ethnicity, gender identity, sexual orientation, intersex status, physical or mental disability, mental illness, relationship status, religion, political opinion, pregnancy, breastfeeding or family responsibilities;
the activities of security providers;
land access and use;
water and sanitation;
Indigenous peoples’ culture, identity, traditions and customs; and
communities / project affected stakeholders near our operations
We recognise we must continually assess the human rights context of our activities, including impacts that we may cause and those to which we may contribute or be directly linked. This determines the prevention, mitigation and remedy measures required, including using leverage in our business relationships.
As defined by the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights.
Forced or compulsory labour includes slavery or slave-like practices, various forms of debt bondage, and human trafficking.
Relationships
We seek opportunities to work with our employees, contractors and suppliers to develop and participate in knowledge-sharing and training, increasing our shared understanding of human rights and improving our collective performance. We seek to use our leverage, wherever possible, to encourage our non-operated joint ventures and minority interests to adopt similar practices and standards, aligned to international human rights best practice.
We recognise the potential for human rights risks in all jurisdictions and are committed to building an ongoing dialogue with stakeholders, including industry associations, civil society, governments and regulators to improve our understanding of these risks and promote respect through engagement, collaboration and public policy.
Our Code explains how to protect people who speak up. It applies to everyone. We encourage our employees, everyone who works with us, and all those affected by our business globally to promptly raise a concern about anything that they reasonably believe may be illegal, improper or involve misconduct. This includes a concern about a safety or environmental issue, a financial matter (including tax affairs), a breach of our core values or Our Code, including a human rights violation, or a concern about retaliation for speaking up.
We have a publicly available grievance mechanism at https://coronajewellery.com/policies.asp item #7. We will acknowledge, investigate as appropriate and document all concerns raised through this mechanism. Where concerns are investigated and substantiated, we take appropriate remedial actions, advise the reporter (where possible) and document the outcomes. We will provide, or cooperate in providing, appropriate remediation where we have caused or contributed to adverse human rights impacts.
Corona is committed to respecting the role of human rights defenders and we acknowledge the risks they face in upholding civic freedoms and their significant voice in understanding and addressing human rights challenges in the areas in which we operate. Under Our Code, Corona does not allow any form of punishment, discipline or retaliatory action to be taken against anyone for speaking up, or cooperating with an investigation. We have processes in place to monitor mandatory minimum human rights performance requirements across our operated activities, and develop improvement plans where necessary. We will report annually on our human rights performance and these findings will be made available on request by e-mailing compliance@coronacompany.com (please put human rights performance report as the subject line).
Reviewed September, 2021
Corona Jewellery Company Ltd seeks economic, social and environmental benefits from our business activities so that we contribute to Sustainable Development.
1. Business Ethics
We are committed to conducting our businesses to a high ethical standard, and to ensuring integrity, transparency and conformance with applicable law.
We will not engage in bribery and/or corruption.
We will not tolerate money laundering and/or financing of terrorism.
We will adhere to the Kimberley Process Certification System and the World Diamond Council voluntary System of Warranties.
We will fully and accurately disclose the material characteristics of the products that we sell.
We will take reasonable measures to ensure the physical integrity and security of product shipments.
We will respect commercial confidentiality and data privacy.
2. Human Rights and Social Performance
We believe in and will respect the fundamental human rights and the dignity of the individual, according to the United Nations Universal Declaration of Human Rights.
We will not tolerate the use of Child Labour.
We will not use any forced, bonded, indentured or prison labour, nor restrict the freedom of movement of employees and dependents.
We are committed to high standards of Health and Safety in our operations.
We will not prevent workers from associating freely. Where laws prohibit these freedoms, we will support parallel means of dialogue.
We will not discriminate based on race, ethnicity, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, marital status, physical appearance, age, or any other applicable prohibited basis in the workplace, such that all individuals who are “Fit for Work” are accorded equal opportunities and are not discriminated against on the basis of factors unrelated to their ability to perform their job.
We will not use corporal punishment under any circumstances and will prohibit the use of degrading treatment, harassment, abuse, coercion or intimidation in any form.
We will adhere to working hours and remuneration legislation, or, where no such legal requirements have been established by law, the prevailing industry standards.
We will support the development of communities where we operate, contributing to their social and economic welfare.
We will recognise and respect the rights of indigenous peoples and the value of their traditional, cultural and social heritage.
3. Environmental Performance
We will conduct our business in an environmentally responsible manner.
We will manage our environmental footprint by eliminating or minimising negative environmental impacts.
We will ensure the efficiency of our business operations by managing our use of resources and energy.
We will adopt practices to enhance Biodiversity and reduce negative impacts on Biodiversity.
4. Management Systems
We will comply with Applicable Laws and publicly state our commitment to the RJC Code of Practices.
We will assess our risks, including risks to our business from our business partners, and establish systems that manage and improve ethical, human rights, social and environmental business practices.
Reviewed June 24, 2021
Corona promotes sustainable development throughout its value chain and expects its suppliers to operate in the same manner. Corona requires that all its suppliers comply with the following sustainable principles. This is the starting point for entering into and maintaining all business relationships with Corona. The supplier shall ensure that all its employees, permanent and temporary, as well as its suppliers, and sub-suppliers, recognize and comply with the requirements set out in this policy.
The supplier is required, at a minimum:
Business ethics and legal compliance:
to comply with all applicable national and international laws, regulations and generally accepted practices;
not to participate in or support any form of corruption, bribery and money laundering, by, among others, not paying bribers or other illegal payments to obtain or retain business or to facilitate favorable decisions or services;
not to offer any lavish or excessive gifts, entertainment or invitations to Corona’s employees. Any gifts, entertainment or hospitality must be reasonable and suitable and reflect the national laws and business custom;
not to directly or indirectly provide or accept gifts in the form of cash or cash equivalent;
when requested, to provide information concerning this policy related to its business with Corona, as well as report actively any deficiencies that may appear in the information it provides;
to act with integrity in all business relationships. For Corona, integrity means honesty and strong moral principles.
Human and labour rights:
to comply with all applicable national laws and regulations regarding human rights and labour rights, as well as acknowledge changes in them;
to respect the protection of human rights and comply with the principles of the UN Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. These include the freedom of association, the effective recognition of the right to collective bargaining, the abolition of forced labor, and equality of opportunity and treatment;
to pay at least the minimum wage required by national laws for regular working hours, overtime hours and overtime differentials;
not to employ or do business with subcontractors or suppliers that employ persons under the minimum age, the age of 15 or the mandatory school age defined by national law, whichever is higher. Employing persons above the minimum age but below 18 may not interfere with their schooling or harm their health, safety or morals;
not to use forced labor in any form or do business with subcontractors or suppliers doing so;
not to retain government-issued identity documents, passports, work permits, or ask for any other unreasonable deposits or fees (e.g. recruitment or hiring fees) as a condition of employment;
not to discriminate in hiring, compensation, training opportunities, promotion, termination of employment, or retirement based on race, age, gender, social class, national origin, religion, disability, sexual orientation, marital or maternal status, union membership, political affiliation, or other comparable reasons;
not to perform or support physical punishment or physical, sexual, psychological or verbal harassment or abuse;
to ensure that contractors at site have adequate and decent accommodation.
Occupational health and safety:
to comply with all applicable national laws and regulations regarding occupational health and safety, as well as acknowledge changes in them;
to provide a safe, healthy and well-managed working environment; to prevent incidents, injuries and occupational disease;
to allocate enough resources and the required competence for providing a healthy and safe work place;
to have a process to identify and evaluate work-related hazards and relevant controls and based on this assessment then implement safe systems of work.
to instruct personnel in mitigation of hazards, risk controls and safe work methods;
to provide personnel with appropriate occupational health services, including statutory insurance coverage, and all necessary training required by applicable laws;
to report and investigate all health and safety incidents;
Environmental management:
To comply with all applicable national laws and regulations regarding environmental management, as well as acknowledge changes in them;
to provide resource-efficient, clean and well managed operations;
to prevent pollution and environmental incidents;
to allocate enough resources and the required competence for environmental management;
to have all valid environmental permits required by the operations and follow the operational and reporting requirements included in the permits;
to have a process to identify and evaluate environmental aspects and relevant operational controls and based on this assessment implement procedures to prevent pollution and minimize environmental impacts.
to instruct personnel in the environmental aspects, controls and procedures associated with their work tasks;
to appropriately sort and forward waste, according to applicable laws, for reusing or recycling to minimize the environmental impacts, and to appropriately process and dispose hazardous waste;
to identify substances that are hazardous to the environment or health and use, store and dispose the substances in a safe and controlled way;
to keep up-to-date safety data sheets and instructions for eventual accidents and apply a plan to replace hazardous substances with less hazardous alternatives;
to maintain emergency action plans to ensure all environmental accidents are managed to minimize consequences;
to strive towards continually reducing the use of energy, raw materials and water as well as minimizing waste and emissions to air, water and soil.
Products and services:
to maintain a proactive approach to product safety by, among others, ensuring that the products supplied to Corona meet mandatory product safety requirements and identifying, evaluating and managing all risks related to the use of the products;
not to use any restricted materials in its supply to Corona and to comply with the substance restrictions defined by the Organisation for Economic Co-operation and Development (OECD), European Union’s RoHS directive (Restriction of the uses of certain Hazardous Substances), REACH regulation (Registration, Evaluation, Authorization and Restriction of Chemicals), or other similar regulations in other countries, when applicable for the jewellery industry.
General requirements:
to designate a person within the company to be responsible for following and developing the principles set forth in this policy;
to have a remediation process in place in case of human rights, health and safety or environment violations;
to report any violations, grievances or breaches of this policy to Corona. The supplier and any personnel and stakeholders can report by e-mail their concerns through the e-mail address compliance@coronacompany.com. Please put your topic of discussion in the subject line and it will then be directed to the appropriate recipient. You can also view the Grievance Mechanism page on this web site https://coronajewellery.com/policies.asp item number 7.
If the supplier does not comply with this policy, Corona reserves the right to terminate the contract with the supplier without prejudice to any other rights, whether under contract or at general law, including already placed and future orders.
Reviewed September, 2021
Corona recognises that there are significant risks that have adverse impacts which may be associated with extracting, trading, handling and exporting gold, silver, platinum, diamonds and coloured gemstones (aa) from conflict-affected and high-risk areas, and recognising that we have the responsibility to respect human rights and not contribute to conflict, we commit to adopt, widely disseminate and incorporate in contracts and/or agreements with suppliers the following policy on responsible sourcing of gold, silver, platinum, diamonds and coloured gemstones from conflict-affected and high-risk areas, as representing a common reference for conflict-sensitive sourcing practices and suppliers’ risk awareness from the point of extraction until end user. We commit to refraining from any action which contributes to the financing of conflict and we commit to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.
If any public member, supplier, any personnel or stakeholders wish to report any violations, grievances or breaches of this policy to Corona they can report by e-mail their concerns using the e-mail address compliance@coronacompany.com . Please put your topic of discussion in the subject line and it will then be directed to the appropriate recipient. You can also view the entire Grievance Mechanism page on this web site https://coronajewellery.com/policies.asp item number 7.
Regarding serious abuses associated with the extraction, transport or trade of gold, silver, platinum, diamonds and coloured gemstones:
While sourcing from, or operating in, conflict-affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to, assist with or facilitate the commission by any party of:
any forms of torture, cruel, inhuman and degrading treatment;
any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;
the worst forms of child labour
other gross human rights violations and abuses such as widespread sexual violence;
war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
Regarding risk management of serious abuses:
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as defined in paragraph 1.
Regarding direct or indirect support to non-state armed groups:
We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of gold, silver, platinum, diamonds and coloured gemstones. “Direct or indirect support” to non-state armed groups through the extraction, transport, trade, handling or export of gold, silver, platinum, diamonds and coloured gemstones includes, but is not limited to, procuring gold, silver, platinum, diamonds and coloured gemstones from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:
illegally control mine sites or otherwise control transportation routes, points where gold, silver, platinum, diamonds and coloured gemstones are traded and upstream actors in the supply chain; and/or
illegally tax or extort money or gold, silver, platinum, diamonds and coloured gemstones at points of access to mine sites, along transportation routes or at points where gold, silver, platinum, diamonds and coloured gemstones are traded; and/or
illegally tax or extort intermediaries, export companies or international traders.
Regarding risk management of direct or indirect support to non-state armed groups:
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined in paragraph 3.
Regarding public or private security forces:
We agree to eliminate, in accordance with paragraph 10, direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or gold, silver, platinum, diamonds and coloured gemstones at point of access to mine sites, along transportation routes or at points where gold, silver, platinum, diamonds and coloured gemstones are traded; or illegally tax or extort intermediaries, export companies or international traders.
We recognise that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.
Where we or any company in our supply chain contract public or private security forces, we commit to or we will require that such security forces will be engaged in accordance with the Voluntary Principles on Security and Human Rights. In particular, we will support or take steps, to adopt screening policies to ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired.
We will support efforts, or take steps, to engage with central or local authorities, international organisations and civil society organisations to contribute to workable solutions on how transparency, proportionality and accountability in payments made to public security forces for the provision of security could be improved.
We will support efforts, or take steps, to engage with local authorities, international organisations and civil society organisations to avoid or minimise the exposure of vulnerable groups, in particular, artisanal miners where gold, silver, platinum, diamonds and coloured gemstones in the supply chain are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.
Regarding risk management of public or private security forces:
In accordance with the specific position of the company in the supply chain, we will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, as identified in paragraph 5, where we identify that such a reasonable risk exists. In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan.
Regarding bribery and fraudulent misrepresentation of the origin of gold, silver, platinum, diamonds and coloured gemstones:
We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.
Regarding money laundering:
We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport or export of gold, silver, platinum, diamonds and coloured gemstones derived from the illegal taxation or extortion of gold, silver, platinum, diamonds and coloured gemstones at points of access to mine sites, along transportation routes or at points where gold, silver, platinum, diamonds and coloured gemstones are traded by upstream suppliers.
Regarding the payment of taxes, fees and royalties due to governments:
We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI).
Regarding risk management of bribery and fraudulent misrepresentation of the origin of minerals, money-laundering and payment of taxes, fees and royalties to governments:
In accordance with the specific position of the company in the supply chain, we commit to engage with suppliers, central or local governmental authorities, international organisations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
(aa) For the purposes of RJC the term gemstones should be read as ruby, blue sapphire and emerald.
Reviewed September, 2021
At Corona Jewellery we understand there may be a time when a grievance mechanism is absolutely necessary and in order to maintain transparency, we have undertaken a formal grievance mechanism for the public, upstream and downstream stakeholders.
A grievance mechanism enables community members or other stakeholders to register concerns, either real or perceived, with the aim of resolving challenges before they escalate. This helps demonstrate our genuine concern and support, promotes ‘buy-in’ and reinforces a respectful relationship-based relationship based upon communication and trust.
For Corona this mechanism is especially formulated to address possible issues you may have with our business practices, our supply chain and our provenance claims for Canadian Gold and Diamonds. It is however not exclusive and can be used to cover other areas that you may have concerns over. This is not a grievance policy for employee relations, and while we have one it is an internal policy.
Our Grievance Mechanism is based upon communication and trust
Step Guide
STEP 1 – We receive your grievance – we will enter this into a complaints log or stakeholder engagement database.
STEP 2 - We will assess the issue – assign the grievance to a relevant person in the company and classify it into a category such as environmental, supply chain, origin, health and safety etc.
STEP 3 – We will respond – we will write back to you about the grievance within two business days, acknowledge your position and provide information of future steps and timings for resolution.
STEP 4 – We will investigate and resolve – we will discover the underlying causes and develop actions to prevent similar incidents occurring in the future.
STEP 5 - Conclusion – A senior manager will follow the investigation procedure to help prevent the grievance from reoccurring. Once the grievance has been resolved, the senior manager will ask you (complainant) to sign-off.
STEP 6 - Further action – if the complainant is not satisfied, the Senior manager assigned to the grievance must initiate further investigation. The grievance may need to be passed on to a third party for mediation.
STEP 7 – We will continue to monitor and evaluate any situation that a grievance has been raised for.
To execute your grievance, send an e-mail to compliance@coronacompany.com . Please put your topic of the grievance in the subject line and it will then be directed to the appropriate recipient. You will have a response to your e-mail within two business days.
