OUR POLICY
AND PROCEDURES
BROWSE THROUGH USING
OUR MENU
SOURCING FROM
CONFLICT- AFFECTED AND HIGH RISK AREAS POLICY
Introduction:
According to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (DDG), conflict-affected and high-risk areas (CAHRA’s) are characterized by “the presence of armed conflict, widespread violence or other risks of harm to people”.
Armed conflict may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of liberation, or insurgencies, civil wars, etc.
High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure and widespread violence. Such areas are often characterized by widespread human rights abuses and violations of national or international law.
And as we all know, diamonds are also minerals. That implicates that our industry is also responsible for all issues of minerals from conflict-affected and high-risks areas. The diamond industry has to look for viable solutions to ensure responsible and conflict-free sourcing through legitimate trade and positive development in the affected regions.
Statement from Dianco Group on sourcing of minerals from Conflict-Affected and High-Risk Areas
Group Dianco will always trying to avoid sourcing diamonds from Conflict-Affected and High-Risk Areas.
We also understand that in certain occasions or circumstances our suppliers sell diamonds to our group that may originate from CAHRA’s.
In those cases we rely on support from our suppliers to provide information on the origin and the sources of the diamonds.
We require our suppliers to have or establish effective due diligence processes, in line with the OECD Due Diligence Guidance for Responsible Supply chains of Minerals from Conflict-Affected and High-Risk Areas, when sourcing rough diamonds.
This enables the Group Dianco to improve our Pipeline Risk Assessment and can we better evaluate that our sourced diamonds did not originate from sources that indirectly or directly contribute to the finance of armed groups or otherwise cause or contribute to human rights violations.
In support of this statement relating to our efforts around responsible sourcing Group Dianco will:
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Continue to actively support industry-wide efforts to find solutions to improve the traceability of diamonds;
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Actively continue to improve our Code of Conduct for Business Partners and our Responsible Sourcing Policy;
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Exercise due diligence in relation to relevant suppliers.
Rules Determined for Sourcing
As reference we refer to our Policy Responsible Sourcing.
In support of the above, the Group Dianco wants that all relevant staff are directed to follow and be trained on procedures implement a conflict diamonds due diligence system to designed to:
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Exercise due diligence with relevant suppliers consistent with the OECD Guidance and encourage our suppliers to do the same.
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Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm diamonds in our supply chain do not contribute to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of OECD Guidance.
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Establish long-term relationships with our immediate suppliers and counterparties.
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Support suppliers and counterparties to improve performance and conform to Group Dianco’s supply chain policy.
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Suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
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Immediately discontinue engagement with suppliers who pose reasonable risk to be causing severe human rights abuses.
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To undergo an annual self-assessment to verify our conflict-free status as well as identify opportunities to continually improve our conflict diamonds due diligence management system.
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Commit to transparency in the implementation of this policy.
Any concerns about our policy or due diligence system should be reported through our Policy ‘Grievance Policy for Customers and Suppliers. For that reason we have to make sure that our customers and suppliers are surely aware of the existence of this policy.
Conclusion
This Policy forms part of the effort by the Group Dianco to develop a long-term ethical diamond business. In that aim we strive to maximize the possibilities to have no trade from Conflict-Affected and High-Risk Areas.
To realize this ultimate goal, the Group Dianco can only act in an open atmosphere of transparency between all Business Partners within the worldwide diamond industry.
FORM
COMPLAINT AND CONCERN
The Group Dianco encourages their suppliers and customers to contact them if there exists a complaint and / or concern, or experience a problem that affects their business with the Group Dianco. Only in that way we can improve our commercial effectiveness and / or global performance. Please feel free to download the form below and email it to dhaval.pipariya@diancogroup.com.
STATEMENT
OF INTENT
Group Dianco, as a worldwide oriented diamond company, is committed to adopting and complying with all local legislations where we are developing commercial activities.
We confirm that we are committed to implementing the following principles
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Leading our group by:
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Agreeing our vision, purpose and values and making sure that they remain relevant;
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Developing, resourcing, monitoring and evaluating a plan to make sure that our company achieves its stated purpose;
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Managing, supporting and holding to account staff and all who act on behalf of the company.
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Exercising control over our group and companies by:
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Identifying and complying with all relevant legal and regulatory requirements;
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Making sure that there are appropriate internal financial and management controls;
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Identifying major risks for our company and deciding ways of managing the risks.
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Being transparent and accountable by:
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Identifying those who have a legitimate interest in doing business with the Group Dianco and companies (stakeholders) and making sure that there is regular contact and effective communication with all of them;
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Responding to our stakeholders' relevant questions or views about our business and our company and how we run it;
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Encouraging and enabling the engagement of those who work for the Group Dianco and companies in the planning and decision-making of our business model.
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Working effectively. We do this by:
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Making sure that the management teams and staff (employees & workers) understand their:
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Role,
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Legal duties, and
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Delegated responsibility for decision-making;
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Making sure that the board of our group, companies and the management exercise our responsibility to suppliers, customers, employees, workers and third parties through board meetings that are efficient and effective;
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Making sure that there is suitable board recruitment, development and retirement processes in place;
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Recruiting the right male / female for the job(s).
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Behaving with integrity by:
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Making sure that our senior management committee, individual board members, and staff understand their role, legal duties, and delegated responsibility for decision-making.
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Making sure that as a board we exercise our collective responsibility through board meetings that are efficient and effective.
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Making sure that there is suitable board recruitment, development and retirement processes in place.
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Making sure that we work compliant to local legislations.
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Implementing the necessary policies, procedures and management systems.
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Auditing the commercial activities and financial figures of our company by independent auditor(s) and / or chartered accountant(s).
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Being honest, fair and independent;
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Understanding, declaring and managing conflicts of interest and conflicts of loyalties;
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Protecting and promoting the Group Dianco and companies business and reputation.
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Threat our suppliers, customers, staff and third parties with the necessary respect.
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We confirm that the Group Dianco is effectively committed to implementing the standards outlined in these principles.
COMPLAINT FORM
HUMAN RIGHTS
The Group Dianco encourages their suppliers and customers to contact them if there exists a complaint and / or concern, or experience a problem that affects their business with the Group Dianco. Only in that way we can improve our commercial effectiveness and/or global performance. Please feel free to download the form below and email it to dhaval.pipariya@diancogroup.com.
ANNUAL REPORT 2023 – 2024
BUSINESS RESPONSIBILITY
Section A: Group Profile:
The Group Dianco is a worldwide oriented diamond group with trading entities in Antwerp – Dubai – Hong Kong – Shanghai – New York During the years 2021 / 2022 we started two manufacturing units, one in Namibia and one in Botswana.
In that way we wanted to expand our range of products that we can offer to our customers and potential customers but also to contribute in the social performance of the lives of the community in both countries. Operation is temporarily on hold due to the market recession in.
As group Dianco, we deal in rough and polished natural diamonds and our supply is derived
from predominantly mining sources.
Depending on our needs and those from our customers we also attract diamonds from the open market and very exceptional from Conflict Affected and High Risk Area’s (CAHRA’s).
Sourcing from CAHRA’s is an element in our day-to-day business that we want to avoid at all times but sometimes there is no other alternative.
The group has also manufacturing units in India but these are outside the scope of this report given the specific requirements in this part of the overall diamond industry.
Section B: Compliance elements of the Group:
2.1 Money Laundering, Terrorism Financing, Other Financial Offenses
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The Group Dianco recognizes the fact that entities in the diamond industry are vulnerable to money laundering. They have to implement robust procedures and policies to protect themselves against abuses by criminals.
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In each entity is a Compliance Officer appointed and an AML/CTF policy implemented. The compliance officers reports internally to the senior management of Group Dianco in cases of possible compliance issues..
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In relation to AML/CFT, two reports are kept on a monthly basis. ‘Cash Transactions’ and ‘Suspicious Transactions’. HARD cash transactions are allowed (Belgium < EUR 3.000 / Other entities max. USD 10.000) only with the consent of the Compliance Officer of the entity. In case of any doubt, possible suspicious transactions are reported to the Financial Intelligence Unit of each country and to senior management of the group Dianco.
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Know Your Customer and other Due Diligence Compliance is followed in line with OECD guidance.
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Possible up-dates and/or changes on local AML/CTF legislations are annually followed up by the responsible person for the whole Group.
Area of concern & Remedial Measures
• There are no indications that the current AML/CTF methods needs to be changed or made more efficient.
2.2 Kimberley Process and System of Warranties
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The Group Dianco is fully committed to comply with all the requirements specified in the Kimberley Process Certification Scheme, the United Nations Resolutions and the WDC SoW guidelines.
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New Self-Assessment for the System of Warranties (SoW) is done for each entity
• Implemented ‘Responsible Sourcing Policy’ and ‘Policy on Sourcing from Conflict- Affected and High-Risk Areas’ must demonstrate that the Group Dianco has a zero tolerance policy on group level.
Area of concern & Remedial Measures
• Non. To date, no import or export has been blocked by the customs for any entity. 2.3 Anti-Bribery and Facilitation Payment Policy:
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2.4
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Nil As on Date. No complaints were received in writing or orally.
Ethical Sourcing of Diamonds:
Our Group is concerned about the environment and social impacts of irresponsible mining.
The Group Dianco has identified the risk of their supply chain with respect to Conflict Affected High Risk Area’s.
The Group Dianco ensures all supplies are in a process of being screened for conflict free supplies.
We have published the OECD based ethical sourcing policy and we are communicating our policies to all the supply chain partners and encourage them to adopt the same.
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For each entity of the Group Dianco any form of Bribery and/or Facilitation payments are prohibited.
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Staff members are encouraged by the senior management of the Group Dianco to report any form of Bribery if they believe so, as long as they are in good faith.
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The Group Dianco communicated the contact details on their website for customers and suppliers who has any complaint or grievance. Details can be obtained in each entity.
Area of concern & Remedial Measures
Area of concern & Remedial Measures
• Still not everybody is aware of the OECD regulations and requirements on Ethical Sourcing because there is no legal framework in all the different countries.
• We note that there is often a low level of cooperation in obtaining information related to due diligences on suppliers.
2.5 Social Compliance
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In relation to employment each entity of the Group Dianco follows strictly the local employment regulations. Reference is our ‘Statement of Intent’.
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No child labour, no forced labour, non-discrimination, non-retaliation etc. in any of the Group Dianco’s entities is allowed.
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As staff members are the most valuable assets of the Group Dianco, we try to do our best efforts to respect them in all different possible ways.
Area of concern & Remedial Measures
• Nobody made any complaint or grievance till today. It must be that all entities of Group Dianco acts in line with all social compliance expectations and regulations.
2.6 Health and Safety
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The Group Dianco is concerned about the health and safety of all its employees and are constantly studding about any adverse impact of our business processes are identified and eliminated..
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For those reasons we implemented a ‘Work Health & Safety Policy’ and ‘Policy Work Place Complaints’ in order to monitor our operations and if needed to make the necessary improvement for a more safety working environment.
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All workplaces are constructed to meet safety standards with local regulations and to offer our staff members a comfortable and pleasant working environment.
Area of concern & Remedial Measures
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Nil as on date. In the trading offices no machinery is installed and no hazardous substances are used.
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In the two manufacturing units, which can be seen as more dangerous places, we noted no workplace hazards, no complaints / concerns on the workplace(s) and / or general grievances.
2.7 Human Rights
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The Group Dianco and his entities are not and will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation
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The Group and his entities strongly discourages any form of sexual harassment, threatening, abusive or exploitative behaviour.
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There is an increase on interest and efforts in the Group Dianco’s entities for the welfare of our employed women. For that reason we became also a ’Watch and Jewellery Initiative 2030’ member. The pursuit of greater gender equality is a central point.
Area of concern & Remedial Measures
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No area of concern has been raised in the Human Rights for any of our trading offices and manufacturing units.
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If our suppliers respect all aspects of Human Rights is difficult to judge and to investigate. Only audits by independent organisations can be reliable and still there can be doubts. Who says that everybody can speak freely during an interview?.
2.8 Environment Protection
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Respecting the environment is a hot issue for the survival of our future generations . As Group Dianco and more specific its entities we strive to minimize our footprint on these aspects where we have an impact, even though it can be a limited effect.
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In order to reduce our Carbon footprint we co-operate at present with Carbon Footprint Consultancy S.L. – Malaga (Spain). Group Dianco does it step by step per entity. By collecting the necessary data and the feedback/suggestions of the company we try to implement measures per entity to reduce our footprint.
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Recycling procedures for waste generated are followed in line with the applicable national (and international) regulations.
Area of concern & Remedial Measures
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The Group’s management has suggested a step by step approach to grow in this direction (see supra).
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The start-up of manufacturing units has a bigger impact on the environment than the
trading offices. For that reason we may have to monitor these manufacturing units more closely in the near future.
2.9 Natural Diamonds versus Synthetic Diamonds
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Group Dianco’s entities has its commercial activities developed through the years in natural rough and natural polished diamonds.
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All implemented policies and procedures have a focus on the aspects of ‘Natural Diamonds’ and to avoid any contamination with synthetics during the whole process.
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We have to try to understand why a large group of consumers are only price sensitive in relation to the differences between natural diamonds and synthetic diamonds.
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To strongly defend our position in the market and to express our great faith in natural diamonds Group Dianco became member of “Natural Diamond Council”.
Area of concern & Remedial Measures
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If needed more traceability to implement on the origin of the diamonds (natural >< synthetic).
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Development of new marketing tools to convince consumers to choose for natural diamonds despite the price handicap.
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To re-consider the business model of Group Dianco if synthetic diamonds increasingly conquering a larger market share compared to natural diamonds.