SUPPLY CHAIN POLICIES
Supplier Code of Conduct:
Objective
BJB has the objective to operate as a profitable and responsible jewellery wholesaler, delivering increasing value to shareholders whilst seeking to uphold Social, Ethical and Environmental Principles and considering the interests of other stakeholders: customers, employees, those with whom BJB does business, and society as a whole. In seeking to achieve its objective BJB recognises that there are indirect impacts generated by its activities, in particular through the supply chain. BJB seeks to use its influence with those with whom it does business, in particular agents and suppliers, to promote the achievement of Social, Ethical and Environmental Principles. As a customer BJB believes it has an opportunity to seek to influence the social, ethical, and environmental performance of its suppliers in a positive way. In order to do so it is necessary that suppliers, and in turn their suppliers, should understand BJB standards as set out in the Supplier Code of Conduct (“Code”). Therefore, BJB encourages suppliers to ensure that this Code is communicated throughout the supply chain.
BJB and its Commitment to Suppliers:
BJB aims to pursue its business activities in what it considers to be an ethical and professional manner. Specifically and subject to the needs of its business, it aims to promote stable, sustainable, long-term relationships with its suppliers and other business partners. BJB attempts to live by the principles of this Code within its own operations and has adopted Social, Ethical and Environmental Principles and policies to this effect.
Legal Compliance:
BJB expects all its suppliers to comply with local national laws and regulations and to respect fundamental International Labour Organisation (ILO) conventions and the Universal Declaration of Human Rights. Where the Code or national law addresses the same issue, the supplier is expected, as a minimum, to be in compliance with the applicable legal requirements of the country in which it operates.
Health and Safety:
BJB expects its suppliers to provide a safe and healthy environment for employees in accordance with applicable local laws and regulations. Appropriate procedures should be in place to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employer facilities. Suppliers are encouraged to have a nominated health & safety representative to monitor facility compliance with procedures.
Specifically, suppliers should ensure:
Safe alternatives to the use of hazardous substances are adopted.
The use of heavy metals is avoided.
Worker eyesight is protected by ensuring the availability and use of appropriate magnifying tools when working on jewellery, diamonds and gemstones, and by providing appropriate lighting.
Worker protection from repetitive strain injury as far as possible considering the ergonomics of their workplace.
Facilities have adequate ventilation from harmful fumes or dust.
Appropriate protective clothing is provided and use of protective clothing is ensured.
Facilities have adequate fire safety standards/procedures, including regular fire drills for all employees, appropriate fire fighting equipment, and easily accessible, and marked and open fire exits in case of emergency.
Residential facilities for workers are kept safe and healthy in accordance with local laws and regulations.
Facilities should have easily accessible, adequate and clean bathrooms.
Potable water should be available at all times.
Where HIV/AIDS is a significant issue in the supplier’s location of operations, suppliers should educate workers about the risk of HIV/AIDS and assist in providing access to treatment and medication as necessary.
Human Rights
Objective
BJB’s Human rights policy outlines our commitment to respect all human rights issues linked to our business. The policy seeks to align with the International Bill of Human rights, the International Labour Organisation (ILO) conventions as well as applicable law. Our aim is to continually improve our social, ethical, and environmental impact for the benefit of our customers, suppliers, and the wider society. This policy applies to all BJB entities and employees as well as all suppliers who provide goods/ services to BJB Limited.
Remuneration and Working Hours
BJB will fully comply with local laws in respect of minimum wages, working hours, employee benefits and overtime.
Normal working hours will not exceed 48 hours per week or local legal restrictions, whichever is more stringent.
This shall only be exceeded in exceptional circumstances.
We will abide by all legally mandated provisions for leaving including maternity, paternity and compassionate leave.
We require the same commitments from our business partners who provide us with products/ service.
Harassment and Abuse
BJB will not discriminate on race, caste, origin, religion, disability, gender, sexual orientation, union or political affiliation or age.
Further information can be found in the ‘Equal opportunities policy’ within Employee handbook.
We require the same commitments from our business partners who provide us with products/ services.
Forced Labour
BJB does not use any forced labour whether in the form of prison labour, indentured labour, bonded labour or otherwise.
We will adhere to applicable laws and regulations.
We will ensure work performed within our organization is based on recognized employment relationships.
We require the same commitments from our business partners who provide us with products/ services.
Child Labour
BJB objects to the employment of persons younger than 15 years of age (or 14 where the law of the country permits) or younger than the age for completing compulsory education where this is greater than 15 in the relevant country.
We require all business partners who provide us with products/ services to comply with all their local legal requirements for young workers, particularly those pertaining to hours of work, wages, health and safety and general working conditions.
Freedom of Association
BJB supports a person’s right to come together with others to promote, pursue, and defend common interests.
BJB respects national and local laws on freedom of association in the communities where we do business.
We strive to create a positive workplace with open lines of communication, making third-party representatives for its employees unnecessary.
We respect the right of all people to join or not join a trade union to bargain collectively. BJB does not discriminate against anyone because of their membership or non-membership in trade unions.
We require the same commitments from our business partners who provide us with products/ services.
Conflict Affected Areas
BJB recognises that in areas affected by conflict, the human rights issues can be heighted. Please refer to our Supply chain policy below for full details outlining our policy on this.
Supply Chain Policy
Our Values
1. BJB Limited is a responsible UK jewellery wholesaler. This policy confirms BJB’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions, and laws.
2. BJB is a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:
a. Respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work
b. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
c. support transparency of government payments and rights-compatible security forces in the extractives industry;
d. do not provide direct or indirect support to illegal armed groups;
e. enable stakeholders to voice concerns about the jewellery supply chain; and
f. are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.
3. We also commit to using our influence to prevent abuses by others. As a customer, BJB believes it has an opportunity to seek to influence the social, ethical, and environmental performance of its suppliers in a positive way. In order to do so it is necessary that suppliers, and in turn their suppliers, should understand BJB standards as set out in the Supplier Code of Conduct (Code). Therefore, BJB encourages suppliers to ensure that this Code is communicated throughout the supply chain.
4. Regarding serious abuses associated with the extraction, transport, or trade of minerals: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:
a. torture, cruel, inhuman and degrading treatment;
b. forced or compulsory labour;
c. the worst forms of child labour;
d. human rights violations and abuses; or
e. war crimes, violations of international humanitarian law, crimes against humanity or genocide.
5. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.
6. Regarding direct or indirect support to non-state armed groups: We only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:
a. control mine sites, transportation routes, points where diamonds are traded and upstream actors in the supply chain; or
b. tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders.
7. We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gold from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:
a. forced or compulsory labour;
b. the worst forms of child labour;
c. human rights violations and abuses; or
d. war crimes, violations of international humanitarian law, crimes against humanity or genocide.
8. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 7.
9. Regarding public or private security forces: We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment, and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally as described in paragraph 7.
10. Regarding bribery and fraudulent misrepresentation of the origin of minerals/ gold: We will not offer, promise, give, or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals/ gold, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of minerals/gold.
11. Regarding money laundering: We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport, or export of minerals.
Date: 01 August 2023
F I Porumb
Managing Director
Environmental Policy
BJB will conduct its business in a way that protects the environment within its respective spheres of influence. This includes supporting initiatives to promote greater environmental responsibility along the entire jewellery supply chain as well as complying with relevant locally applicable environmental law and regulations. More specifically BJB believes that natural resources should be developed in a manner that respects the needs of current and future generations. The jewellery industry uses metals and other minerals for a wide variety of purposes and it is therefore in the industry’s best interest to ensure that the minerals upon which it depends are obtained, produced, and used in environmentally and socially responsible ways.
We aim to be an environmentally friendly Company and it is our intention to promote a policy that is focused on being green aware. A culture will be fostered within the company that ensures all employees understand they can make a significant contribution to the Company being an environmentally friendly and green aware company. The Company's policy is to comply or exceed the requirements of environmental legislation and regulation.
Ethics and Integrity
BJB expects that its suppliers will conduct business with integrity and communicate honestly regarding the nature of the products they supply, disclosing accurately their weight, colour and clarity, treatments of gemstones, the standard of fineness and trademarks of articles of precious metals and other matters as required by applicable federal, state and local laws and regulations.
Gifts and Bribery
BJB expects that its suppliers will not offer or provide gifts, gratuities or entertainment designed to induce, support or reward improper conduct in connection with any business or anticipated future business or where such gift, gratuity or entertainment might be seen or expected to compromise the receiver's judgment and integrity. Likewise, BJB expects that its suppliers will comply with the requirements of the US Foreign Corrupt Practices Act and the UK Bribery Act in all its dealings, no matter where in the world. Such compliance includes prohibiting employees, officers, directors, agents, representatives, affiliates and their families from requesting, accepting, paying or offering any form of “under-the table” payment, “kickback,” bribe, rebate, or other improper payment or gratuity, whether directly or through a third party regardless of form, whether in money, property, or services (i) to obtain favourable treatment in securing business, (ii) to pay for favourable treatment for business secured, (iii) to obtain special concessions or for special concessions already obtained, for or in respect of either party or any affiliate of either party, or (iv) in violation of any legal requirement.
Conflict Diamonds
Procedure
Invoices and packing slips for diamonds and diamond jewellery shipped to any trading subsidiary must contain a proper warranty statement or, if applicable, be accompanied by a Kimberly Process Certificate. The KPCS warranty must be incorporated into each invoice submitted to BJB. The warranty is as follows:
“The seller warrants that these products have been supplied in compliance with the Responsible Jewellery Council Protocols (“RJC”).
“Any diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and in compliance with United Nations Resolutions. The seller hereby guarantees that these diamonds are conflict-free and that no diamonds (natural or lab grown) or precious metals of Russian origin purchased after 24 February 2022 are present in any BJB products, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.”
Halt to Purchases of All Precious Metals and Diamonds Originating from Russia
In 2022, the US Government imposed sanctions against certain Russian individuals, Russian-owned entities and products originating from Russia such as oil, seafood, and non-industrial diamonds. All suppliers are of course required to comply with all laws in the respective countries in which we operate, including all sanctions and requirements imposed by the US Department of the Treasury and its Office of Foreign Assets Control.
In accordance with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance and our own Protocols, policies and principles, BJB has halted all trade in precious metals and diamonds originating from Russia and had therefore requested from all its manufacturers to stop supplying the same to BJB even though the country(s) in which they operate may not have imposed sanctions on Russian precious metals and diamonds.
In addition, with each shipment we receive, we ask all suppliers to certify that no diamonds or precious metals of Russian origin purchased after 24 February 2022 are present in any BJB products.
Compliance to this new policy is subject to verification in accordance with the Responsible Sourcing Protocols audits and will remain in effect until an international consensus is reached that the human right violations have ceased.
Lab Grown Diamonds
Procedure
BJB requires that the procedures in this protocol are followed carefully, with the intention to ensure that no lab-grown diamonds (LGDs) are present in the natural diamond jewellery it purchases. If an external gemmological laboratory is used, full details are required including its full name, location, and procedures they have in place.
On receipt of loose stones from the diamond vendor
After preparation of flutes/bags prior to setting
Following setting and finishing
After final QC the fully checked jewellery item must be sealed in a bag that notes the item checked as free from LGDs. BJB also requires manufacturers to guarantee that ‘safe,’ (tested non-LGDs), are kept separate and securely so as not to be contaminated with other materials. BJB may require manufacturers to provide full details of their LGD testing procedures, including how ‘safe’ diamonds are kept separate and securely.
BJB requires manufacturers to include the warranty statement, shown below, on all invoices issued. Failure to include this declaration will result in the product being rejected and returned at the manufacturer’s expense.
“The seller hereby guarantees that any diamonds herein invoiced are exclusively of natural origin and untreated, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.”
BJB requires manufacturers have a thorough understanding of their diamond vendors LGD processes and be in a position to provide details and images to BJB if and as required.
Coloured Gemstones
Coloured gemstone suppliers must be fully compliant with the BJB Ltd Coloured Gemstones Policy. The supplier is responsible for full disclosure, testing and guaranteeing the correct supply. BJB Ltd are at liberty to undertake factory visits to ensure the terms of the BJB Ltd Gemstones Policy are being upheld. The supplier must ensure all information and documentation required to sufficiently assess compliance is made available to the BJB Ltd team.
Procedure
Suppliers must ensure that gemstones supplied to BJB Ltd are always accurately described to the buyer and in associated documentation.
Suppliers must ensure that natural gemstones are always segregated from LGGs.
Suppliers of natural gemstones must undertake testing to ensure the stones are natural and to detect treatments, prior to supplying BJB Ltd. Suppliers must have written testing protocols and maintain test records.
Where suppliers use a sample testing approach, testing must be undertaken in an Average Quality Limit (AQL) basis (reference IQO 2859-1) and must be performed by qualified gemmological personnel, in-house or outsourced to a gemmological laboratory.
All suppliers must employ a documented inventory management system which documents their chain of gemstone ownership and can be verified by audit.
The same obligations and criteria that apply to BJB’s direct suppliers, will also apply to any subcontractors.
Suppliers will therefore need to pass on the requirements of this document to all subcontractors.
All suppliers must always disclose all treatments.
All suppliers must disclose that a gemstone is laboratory grown/created, manufactured or composite product.
Suppliers should apply the treatments nomenclature set out in the American Gem Trade Association Gemstone Information Manual (15th Edition).
BJB Ltd will not accept any gemstones mined in Myanmar/Burma. Suppliers must take robust and documented action to ensure that no material mined in Myanmar/Burma is supplied to BJB Ltd. Suppliers must communicate this requirement in writing to their suppliers.
Suppliers must evidence compliance as follows:
An inventory management system
Sale & purchase documents
Documents KYC due diligence system
A written policy statement and standard terms of business with all suppliers
Quality Control
BJB staff will visit manufacturing sites to check that all procedures are being carried out and executed correctly. BJB local QC staff will also carry out random LGD tests as part of their standard QC procedure.
Training
BJB requires manufacturers to implement a training procedure for all staff required to operate LGD detection equipment to ensure the presence of any LGDs are correctly identified.
Reporting
BJB requires manufacturers to keep a record of the LGD testing carried out on BJB jewellery and to notify them when they encounter any problems relating to LGDs. Manufacturers are required to provide a report detailing the problems experienced and solutions to ensure that it is rectified and won’t occur again.
Monitoring
Suppliers are encouraged to institute a self-monitoring system based on this Code and move towards independent verification of Code compliance.
Communication
Suppliers are encouraged to take appropriate steps to ensure the provisions of this Code are communicated to their employees and their own supply chain. Suppliers are also encouraged to ensure that the Principles referred to above are adopted and applied by their employees, suppliers, agents and contractors so far as reasonably possible.
Grievance Mechanism
BJB Limited has established this complaints procedure to hear concerns about circumstances in the supply chain. Felix Porumb is responsible for implementing and reviewing this procedure. Concerns can be raised by interested parties via email info@bjbuk.com or telephone on +44 (0) 207 405 4523.
On receiving a complaint, we will aim to:
get an accurate report of the complaint;
explain our complaints procedure;
find out how the complainant would like it handled;
decide who is the appropriate person internally to handle the complaint, or help redirect the complaint to another entity, such as the relevant supplier, or a relevant industry body;
where the issue can be handled internally, seek further information where possible and appropriate;
identify any actions we should take, or monitor the situation;
advise the complainant of any decisions or outcomes; and keep records on complaints received, and the internal process followed, for at least five years.
Procurement Policy:
At BJB, our Procurement Policy governs the process of sourcing materials, products, and services. It outlines our commitment to fair, transparent, and responsible procurement practices:
Supplier Evaluation and Selection: BJB conducts a comprehensive evaluation of potential suppliers based on criteria such as quality, reliability, environmental practices, and adherence to ethical standards. We seek to build long-term relationships with suppliers who share our values.
Ethical Sourcing: We prioritize suppliers who demonstrate ethical practices in their operations, including respect for human rights, fair labour practices, and compliance with all applicable laws and regulations.
Competitive Bidding: BJB promotes fair competition among suppliers by inviting multiple bids for significant procurement projects. We select suppliers based on a combination of price, quality, and value for money.
Supplier Code of Conduct: Our suppliers are expected to adhere to our Supplier Code of Conduct, which outlines our expectations regarding ethics, social responsibility, and environmental practices. Compliance with this code is a prerequisite for engaging in business with BJB.
Sustainability Considerations: We give preference to suppliers who adopt sustainable practices, such as reducing their environmental impact, using renewable materials, and supporting responsible sourcing initiatives.
Risk Management: BJB assesses potential risks associated with suppliers, including financial stability, compliance, and reputational risks. We work to mitigate these risks through due diligence and ongoing monitoring.
Transparency and Accountability: We are committed to transparency and accountability in our procurement processes. Our team ensures that all procurement activities are well-documented and compliant with internal policies and industry standards.
By adhering to our Logistics and Transportation Policy, Quality Assurance Policy, and Procurement Policy, BJB aims to uphold the highest standards of efficiency, quality, and responsibility throughout our supply chain and operations.
Quality Assurance Policy:
BJB is dedicated to delivering products of the highest quality to our customers. Our Quality Assurance Policy outlines our commitment to maintaining strict quality control measures throughout our supply chain, manufacturing processes, and customer service:
Product Quality Standards: We set stringent quality standards for all our products, ensuring they meet or exceed industry benchmarks. Our suppliers are required to adhere to these quality standards, and we conduct regular audits to ensure compliance.
Inspection and Testing: BJB conducts rigorous inspections and testing of raw materials, components, and finished products to ensure they meet the desired quality specifications. Our quality control team is highly trained to identify and rectify any quality issues promptly.
Customer Feedback and Satisfaction: We value customer feedback and use it to continuously improve our products and services. Customer satisfaction is our priority, and we take all feedback seriously to address any quality concerns.
Supplier Collaboration: BJB maintains open communication with our suppliers to foster collaboration and enhance quality control measures. We work together to resolve quality issues and implement preventive measures to maintain consistent product quality.
Continuous Training and Development: Our employees undergo regular training and development programs to stay updated on the latest quality control techniques and industry best practices. This ensures that our team is equipped to deliver products of the highest quality.
Logistics and Transportation Policy:
At BJB, we are committed to efficient and sustainable logistics and transportation practices to ensure timely delivery of our products while minimizing our environmental impact. Our Logistics and Transportation Policy outlines our guiding principles and strategies to achieve these objectives:
Efficient Supply Chain Management: We employ advanced logistics and supply chain management systems to optimize the movement of goods from suppliers to our distribution centres and ultimately to our customers. We strive to minimize lead times and maintain adequate inventory levels to meet customer demands promptly.
Transportation Efficiency: BJB is dedicated to choosing the most efficient transportation modes for our products, taking into account factors such as distance, delivery time, and environmental impact. We encourage the use of environmentally friendly transportation options, such as rail and sea freight, whenever feasible.
Packaging and Waste Reduction: We aim to minimize packaging waste and use sustainable packaging materials that are recyclable or biodegradable. Our suppliers are encouraged to adopt responsible packaging practices to reduce the environmental impact associated with logistics.
Compliance and Safety: BJB adheres to all transportation regulations and safety standards in each region where we operate. We work with reputable logistics partners that prioritize safety, reliability, and compliance in their operations.
Monitoring and Continuous Improvement: We regularly monitor our logistics and transportation processes to identify areas for improvement. Feedback from customers and stakeholders is valuable in enhancing our efficiency and sustainability in this aspect of our business.
Ethical, Responsible, and Sustainable Practices in the Jewellery Supply Chain Policy:
At BJB, we are committed to upholding ethical, responsible, and sustainable practices throughout our jewellery supply chain. We recognize the importance of conducting our business in a manner that respects human rights, promotes environmental stewardship, and supports the well-being of communities involved in the production and trade of jewellery. This policy outlines our principles and guidelines to ensure that our supply chain adheres to the highest standards of ethics and sustainability.
Human Rights and Fair Labour Practices: BJB is dedicated to respecting and promoting human rights as defined in the Universal Declaration of Human Rights and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. We do not tolerate any form of forced labour, child labour, or discriminatory practices within our supply chain.
Supplier Code of Conduct: We expect all our suppliers and business partners to adhere to our Supplier Code of Conduct, which outlines the ethical, social, and environmental standards we uphold. This code includes provisions related to labour practices, environmental responsibility, and transparency in business dealings.
Responsible Sourcing: BJB is committed to sourcing materials responsibly and with full consideration of their origins. We only procure diamonds that are compliant with the Kimberley Process Certification Scheme, ensuring they are conflict-free. Similarly, we ensure that all gemstones and metals used in our products are sourced from reputable and socially responsible suppliers.
Environmental Responsibility: We strive to minimize our environmental footprint throughout our supply chain. This includes promoting responsible mining practices, reducing waste and energy consumption, and implementing eco-friendly packaging solutions. We encourage our suppliers to adopt sustainable practices that minimize their environmental impact.
Transparency and Traceability: Transparency is essential to building trust with our stakeholders. BJB promotes transparency and traceability in our supply chain, providing customers with information about the origin and sourcing of our materials. We work closely with our suppliers to ensure that they can trace the origins of their products and adhere to strict chain-of-custody practices.
Support for Artisanal and Small-scale Miners: BJB recognizes the significance of artisanal and small-scale miners (ASM) in the jewellery supply chain. We actively support initiatives that promote responsible ASM practices, fair trade, and safe working conditions for miners. We aim to empower and uplift communities involved in ASM activities.
Community Engagement: We believe in engaging with the communities impacted by our supply chain. BJB supports initiatives that improve the social and economic well-being of these communities, including education, healthcare, and vocational training programs.
Continuous Improvement: BJB is committed to continuous improvement in our ethical and sustainable practices. We regularly review and update our policies and standards to align with industry best practices and evolving sustainability frameworks.
Collaboration and Partnerships: We actively seek collaborations and partnerships with like-minded organizations and industry stakeholders to collectively drive positive change in the jewellery supply chain. We believe that collaborative efforts are essential to achieving a sustainable and ethical industry.
By adhering to our Ethical, Responsible, and Sustainable Practices in the Jewellery Supply Chain Policy, BJB aims to lead by example in the industry, promoting a fair, responsible, and sustainable jewellery supply chain for the benefit of all stakeholders involved.