March 2018

Responsible Jewelry Council Policy

Sabelli S.A. de C.V.  is a member of the RJC (Responsible Jewellery Council). The RJC has developed a benchmark standard for the jewelry supply chain and credible mechanisms for verifying responsible business practices through third party auditing.

Sabelli S.A. de C.V. is committed to operating its business in accordance with the RJC Code of Practices. It is committed to integrating ethical, human rights, social and environmental considerations into its day-to-day operations, business planning activities and decision making processes.

Responsible Business Practices

Anti-Money Laundering and Countering the Financing of Terrorism 

Sabelli S.A. de C.V.  is committed to preventing the use of its operations for money laundering or any activity that facilitates money laundering or the funding of terrorist or criminal activities. Accordingly, Sabelli S.A. de C.V. complies with all applicable laws and regulations designed to combat money laundering activity and terrorist financing connected to the government in the regions where Sabelli S.A. de C.V. operates and abides by all international laws that may apply.

Anti-Bribery and Facilitation Payment Policy 

Sabelli S.A. de C.V. shall ensure complete prohibition of bribery and facilitation payment across the organization and in all the entities.

Sabelli S.A. de C.V. will not offer, accept or countenance any payment, gift, in kind, hospitality, and expense or promises as such that may compromise promises of fair competition.

Periodic training and awareness shall be carried out to educate employees about various types and ways of bribery and facilitation payments.

Employment

Compliance is ensured at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.

Sabelli S.A. de C.V. shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of workers and provide some discretionary income.

Health and Safety 

Sabelli S.A. de C.V. is committed to the following:

• Any adverse impact of our business processes shall be identified and eliminated. We will systematically review our operations to identify sources of health and safety related risks.
• This review will use appropriate standards as required by prevailing laws, expert opinion and our knowledge of best practices.
• The review will lead to formulation of clearly described work practices and drills.
• All our staff will be trained in the manner required to adhere to these work practices and drills.
• The health of our staff, exposed to certain hazardous processes, will be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
• Workers shall not be under the influence of or abusing, drugs, alcohol and/or other illegal substances.
• All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable.

Non Discrimination, Disciplinary Practices

Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, HIV status, migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by Sabelli S.A. de C.V. and any such reported incidents will be viewed as a serious violation of these business principles.

Sabelli S.A. de C.V. shall assure all employees who come forward in good faith to report issues that they will be treated fairly and respectfully.

Child Labour

No form of child labour shall be employed at any of the facilities of Sabelli S.A. de C.V.

Sabelli S.A. de C.V. will implement suitable policy and procedures to verify the age of all new employees joining the organization.

Forced Labour

The management of Sabelli S.A. de C.V. is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of these business principles.

Human Rights

All employees in the Sabelli S.A. de C.V. facilities will be treated with equality, respect and dignity.

Sabelli S.A. de C.V. 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.

Sabelli S.A. de C.V. strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.

Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company.

Kimberly Process and System of Warranties 

Sabelli S.A. de C.V. follows the Kimberley Process Scheme to ensure that all diamonds it supplies to its customers are conflict-free and only use suppliers that can provide guarantees to such effect.  Sabelli S.A. de C.V. ensures that all of its diamond vendors provide a system of warranties to ensure that the diamonds they are supplying are conflict-free.

Gold Sourcing Policy

It is the policy of Sabelli S.A. de C.V. not to use any metals in its products that come from conflict areas as outlined in the “Dodd Frank Act”. The company is able to trace the source of its metals from suppliers and only use those that comply with the Signet Responsible Sourcing Protocols (SRSP).

Environmental Policy 

Sabelli S.A. de C.V. is committed to managing environmental impact as an integral part of its operations. In particular, it is company policy to assure the environmental integrity of its processes and facilities at all times.

Provenance claims

The policies relating to this section are part of the Business Principles adopted by Sabelli SA de CV and are presented below for reference:

“The company shall ensure all its Provenance Claims made will be fully valid along with available evidence to support the Claim(s)”.

The company shall ensure that all claims and statements (made to consumers or other businesses) on practices in the supply chain and the origin or source of Diamonds, Synthetics, Gold and / or Platinum through the use of both descriptions and symbols are valid.

The company shall ensure that there will be no attempt to mislead consumers through illustrations, descriptions, expressions, words, figures, depictions or symbols relating to the Provenance Claim(s). The company implements suggestion/complaint/grievance procedure and publically display contact details of compliance officer/promoters where anyone can register their concerns. Further the company set mechanism of internal audit at regular interval to ensure compliance with respect to provenance claim.

The company shall ensure that all the relevant employees are aware about the provenance claim and it procedures.

 The seller warrants that any product containing gold, silver tin, tungsten, tantalum or diamonds and conflict free minerals not sourced from CAHRAs. 

The diamonds are neither recycled nor sourced from artisanally mined and it is exclusive of natural origin, Synthetic free, earth mined and untreated except otherwise stated. The diamonds are ethically processed, responsibly sourced and complied with the applicable law and relevant WFDB guideline.

Complaints procedure

In case of any query/complaints/grievances/suggestion pertaining to provenance claim please contact on  info@sabelli.com.mx or call +52 33 3669 0848.

On receiving a complaint, we will aim to:

• Get an accurate report of the complaint.
• Explain our complaint procedure.
• Find out how the complainant would like it handled.
• Decide who is the appropriate person internally to handle the complaint, or assist with redirecting the complaint to another entity, such as the relevant supplier, or an institution, such as 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.
• Keep records of complaints received.

Juan Antonio de la Cerda

Commercial Director