External Grievance Policy
Purpose
Chemgold is committed to responsible and ethical business practices, consistent with the Responsible Jewellery Council (RJC) Code of Practices and other international standards.
This policy establishes a clear and transparent process for external stakeholders to raise grievances about our operations, supply chain, or business practices, and to have them addressed promptly, fairly, and without fear of retaliation.
Scope
This policy applies to all external stakeholders who may be directly or indirectly affected by our business activities, products, or services, including:
• Customers and consumers
• Suppliers and contractors
• Business partners
• Local communities and other interested parties
Principles
Our grievance mechanism is guided by the following principles:
• Accessibility – Open to all stakeholders, with multiple reporting channels.
• Confidentiality – All matters are handled with respect for privacy. Complainants may remain anonymous if they wish.
• Non-retaliation – No stakeholder will face retaliation for raising a grievance in good faith.
• Fairness & Impartiality – All grievances are considered objectively and without bias.
• Timeliness – We commit to acknowledging, investigating, and resolving grievances within reasonable timeframes.
• Transparency – Complainants will be kept informed of the process and outcomes (unless anonymous).
• Continuous Improvement – We use outcomes and lessons learned to strengthen our policies and practices.
What Can Be Raised as a Grievance
External stakeholders may raise concerns about, but not limited to:
• Human rights impacts within our operations or supply chain
• Environmental impacts or unsafe practices
• Unethical, fraudulent, or corrupt behaviour
• Product safety or misrepresentation
• Labour rights or workplace issues within the supply chain
• Breaches of our Code of Conduct, policies, or RJC requirements
Options for Raising a Grievance
You have three main options:
1. Deal with the matter informally
If you feel comfortable, raise the issue directly with the person or representative involved. This allows for quick resolution at the source.
2. Contact the Grievance Officer
If you prefer not to approach the person directly, you may contact our Operations Manager (Grievance Officer). They will listen, advise you on options, and may attempt informal resolution. Serious issues will be escalated to the Company Directors.
3. Make a formal complaint
Submit in writing and include:
• A description of the incident or concern
• Dates, times, and names of those involved
• Supporting evidence or witness details (if available)
• Your name and contact details (optional if you wish to remain anonymous)
Reporting Channels
Grievances can be submitted through any of the following:
• Email: [email protected]
• Telephone: 1300 984 751
• Mail: Attn Compliance Manager, PO Box 6397, Alexandria NSW 2015, Australia
• Online form: chemgold.com/grievance-form
• In person: By appointment with the Grievance Officer
We will acknowledge all grievances within five (5) business days.
How Your Grievance Will Be Handled
1. Acknowledgement – Confirm receipt within five (5) business days.
2. Assessment – Review the nature, scope, and risk of the grievance.
3. Investigation – Conduct an impartial fact-finding process. You may be asked to provide more details.
4. Escalation – Serious matters (e.g., human rights, bribery, severe environmental impacts) will be escalated to the Company Directors.
5. Resolution – Corrective or remedial actions will be taken, and outcomes communicated (unless anonymous).
6. Closure & Recordkeeping – The matter will be formally closed, with records securely stored for a minimum of five (5) years.
7. Review – We periodically review grievances and outcomes to improve business practices.
Possible Outcomes
If your grievance is substantiated, actions may include:
• Written explanation or apology
• Corrective or remedial action (e.g., supplier contract review, process improvement)
• Training, monitoring, or policy revision
• Escalation to senior management for formal action
If unsubstantiated, we will explain our findings. If found to be vexatious or fabricated, we may take appropriate steps, including disengagement from the complainant or supplier.
Roles & Responsibilities
The following roles apply in managing grievances:
• Grievance Officer (Operations Manager / Head of Compliance Team): First point of contact, responsible for managing the process.
• Company Directors: Review and decide on serious or escalated grievances.
• Compliance Team: Assists with recordkeeping, monitoring, and reporting.
What If You Are Not Satisfied?
If you are not satisfied with the way your grievance was handled, you may:
• Request a review by the Company Directors.
• Raise the matter with an external authority (e.g., regulator, RJC grievance process, or legal authority where applicable).
Review of Policy
This policy will be reviewed annually, or sooner if required, to ensure its effectiveness and alignment with best practices, RJC requirements, and stakeholder expectations.