Responsible Supply Chain Policy
1. Purpose and Scope
Chemgold is committed to responsible sourcing and full transparency throughout our supply chain. We recognise our responsibility to respect human rights, uphold fair labour practices, protect the environment, and ensure that the materials we source are conflict-free, ethical, and sustainable.
This policy applies to all Chemgold employees, contractors, suppliers, and business partners providing precious metals, components, services, or any other materials used in the production and distribution of our products.
Our approach is aligned with:
- The Responsible Jewellery Council (RJC) Code of Practices.
- The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Gold Supplement and Annex II.
- The Kimberley Process Certification Scheme (KPCS) and the World Diamond Council (WDC) System of Warranties, where relevant.
2. Policy Commitments
Chemgold commits to:
- Human Rights and Labour Standards
• Prohibit forced, bonded or involuntary labour.
• Prohibit child labour and comply with ILO Conventions.
• Ensure fair wages, working hours, and benefits in line with law and industry standards.
• Provide safe and healthy workplaces, free from discrimination, harassment, or abuse.
• Respect workers’ rights to freedom of association and collective bargaining.
- Responsible Sourcing
• Avoid sourcing from suppliers involved in human rights abuses, war crimes, or support to armed groups.
• Ensure all sourced materials are conflict-free and legally traded.
• Prohibit bribery, corruption, and fraudulent misrepresentation of mineral origin.
• Comply with all applicable tax obligations and disclosure requirements.
- Environmental Responsibility
• Comply with environmental laws and regulations.
• Strive to reduce waste, emissions, and energy use.
• Handle and dispose of hazardous materials safely and responsibly.
- Ethics and Transparency
• Maintain accurate supply chain records and traceability systems.
• Require suppliers to complete Know Your Counterparty (KYC) and due diligence questionnaires.
• Support independent audits and provide transparent reporting.
3. Due Diligence Process
Chemgold applies a due diligence process appropriate to our size and operations, consistent with the OECD Guidance. This includes:
1. Strong governance systems – compliance policies, training, and grievance mechanisms.
2. Risk identification and assessment – especially for conflict-affected and high-risk areas (CAHRAs).
3. Risk mitigation – designing and implementing strategies to address identified risks.
4. Independent third-party audits of supply chain due diligence, where applicable.
5. Annual reporting on our due diligence findings, risks identified, and actions taken.
4. Supplier Requirements
All Chemgold suppliers are required to:
- Acknowledge and comply with this policy.
- Complete Chemgold’s Supplier Questionnaire and KYC/Declaration Form.
- Provide accurate information on material origin and due diligence processes.
- Notify Chemgold of any potential risks, non-conformances, or sourcing concerns.
- Cooperate with Chemgold’s audits and assessments as required.
5. Grievance and Reporting
Chemgold maintains an open and confidential grievance mechanism for employees, suppliers, and external stakeholders. Concerns can be reported by email, phone, or in writing. All grievances will be investigated fairly, with protection against retaliation for good-faith reporting.
6. Implementation and Governance
- The Compliance Team, led by the Operations Manager, is responsible for implementing this policy, conducting supplier reviews, and maintaining records.
- The Director provides oversight, approves updates, and is ultimately accountable for this policy.
- The policy will be reviewed annually, with updates recorded in the Policy Review Log and communicated to all suppliers and stakeholders.