diamond best practice principles (bpp) training welcome to the

Diamond Best Practice Principles (BPP)

Training

Welcome

to

the

1) What is it?

Agenda

2) Why is it?

3) What’s in it for SunDiamond?

4) What are the themes?

5) What is asked from you?

6) Presentations?

-Business Policy-Health & Safety-Kimberley Process and AML-Disclosure

1) A Code, a set of rules that aim at establishing a standard within the diamond industry on general themes like

- Business Responsibility- Social Responsability- Environmental Responsability

What is it?

2) The BPP is edicted by the Diamond Trading Company (DTC) as a formal part of the Supplier of Choice Contract

3) The BPP is similar to auto-regulations in other sectors (e.g. BRC)

1) It is a formal obligation for every DTC Sightholder under the Supplier of Choice contract to comply to the BPP

Why is it?

2) Stakeholders of the Diamond Industry expressed a demand for Responsible Practices and auto-regulations

3) The Industry must be able to indicate its genuine efforts to eradicate previous existing practices that tarnished its reputation

1) Obligations- Compliance to the BPP- Training and information- Audit internal/external- Subcontractors and clients

What’s in it for SunDiamond?

2) Opportunities- Pioneering in Good Business Practices- Accreditation of PurelyNaturalDiamond™- Differentiation by marketing exploitation

What’s in it for SunDiamond?

3) Expectations- Increase Consumer Confidence- Implement Best Business Practices- Commitment from every actor of the

Diamond Industry

4) Consequences- SunDiamond Business Policy- Certification of Vietnam Factories: ISO 9000,

OHSAS 18000, SA 8000- Local training on BPP- PurelyNaturalDiamond™

Themes?

1) Business Responsabilities

- Ethical standards => Business Policy

- Anti Money Laundering and Terrorism

Financing => PPT presentation

- Kimberley Process => PPT presentation

- Disclosure => PPT presentation

- Pipeline Management

Themes?

2) Social Responsabilities- Employees => Business Policy- Health and Safety => PPT presentation- Diversity => Business Policy- Non-discrimination => Business Policy- Child Labour => Business Policy- Forced Labour => Business Policy- Human Rights => Business Policy- Community => Business Policy

3) Environmental Responsabilities => Business Policy

What is asked from you?

1) Listen carefully

2) Ask questions

3) Read the Business Policy

4) Remember the essentials

5) Be able to answer if questionned on any matter of

the BPP

The SunDiamond Business Policy

In general the SunDiamond Group of Companies

Adheres to

• UN Global Compact (10 principles)

• The Universal Declaration of Human Rights

• The International Labour Organisation

• The United Nations Environment Programme

• The United Nations Development Programme

• The United Nations Industrial Development Organisation

In general the SunDiamond Group of Companies

Is committed to

• The Kimberley Process

• BPP

• FATF (40 recommendations)

• USA PATRIOT ACT

• The Canadian Diamond Code of Conduct

• The JA Code of Ethics and Standards of Professional

Conduct, the JA Supplier Code of Conduct

• CIBJO and its many initiatives

Business Policy

• Specific themes:- Integrity- People in the workplace- Health and Safety- Environment and Society

• Purpose of the document

• Observance of the Business Policy

• Compliance Officer/ Chief Compliance Officer

Read the BP (15 minutes)Sign it!

Health and Safety

Sources

• National Legislations

• SunDiamond Business Policy

• Rules and Regulations

• BPP

Health & Safety

The Company Safety Manager

• Name

• How to contact him

• He will be responsible to keep the RECORDS of

accidents, diseases, absentee

• Keep file on all accidents in order to learn and avoid them

in the future

Health & Safety

YOUR CONDITION

Health & Safety

Get help as quickly as possible Be aware of your own condition

• Are you dizzy ?• Light headed?• Chilled and sweating?• Shortness of breath ?• Pain in center of chest spreading to neck, shoulder or arms?• Something gets caught in your throat• Sudden weakness/numbness of the face• Loss of speech / trouble talking or understanding speech• Sudden severe headache• Are you diabetic? eating or checking you blood sugar?• Are you allergic to certain things / been stung by a bee before?

Health & Safety

Time is critical - do what you can before the unexpected

happens

• Inform of your condition ahead of time and can prepare

• Taking medications? - keep a list in your pocket

• Let us know any special needs for your condition

• Update information and the emergency contact.

Health & Safety

Inform Immediately

• Call ….. In case of emergency

• If you aren’t needed - stay out of the way

• Keep others away - keep area clear

• Help direct emergency personnel

• Respect the privacy of others

Health & Safety

Use of alcohol drugs or tobacco is prohibited in SunDiamond workplaces

SunDiamond does not allow working under influence of any illegal substance, drug or alcohol

Alcohol-Drugs-Tobacco

Health & Safety

FIRE

Health & Safety

The Fire Triangle

Fire Safety, at its most basic, is based upon the principle of keeping fuel sources and ignition sources separate.

Health & Safety

Fuel ClassificationsClass A: Wood, paper, cloth, trash, plastics—solids that are not metals.

Class B: Flammable liquids—gasoline, oil, grease, acetone. Includes flammable gases.

Class C: Electrical—energized electrical equipment. As long as it’s “plugged in.”

Class D: Metals—potassium, sodium, aluminum, magnesium. Requires Metal-X, foam, and other special extinguishing agents.

Health & Safety

Fuel Classifications

Health & Safety

Most fire extinguishers will have a pictograph label telling you which types of fire the extinguisher is designed to fight.

For example, a simple water extinguisher might have a label like this…

…which means it should only be used on Class A fires.

How to Use a Fire Extinguisher

Health & Safety

It’s easy to remember how to use a fire extinguisher if you remember the acronym PASS:

Pull Aim Squeeze Sweep


Health & Safety

Pull the pin…

This will allow you to discharge the extinguisher


Health & Safety

Aim at the base of the fire…

Hit the fuel!If you aim at the flames... … the extinguishing agent will fly right through and do no good.


Health & Safety

Squeeze the top handle…

This depresses a button that releases the pressurized extinguishing agent.


Health & Safety

Sweep from side to side…

.. until the fire is completely out. Start using the extinguisher from a safe distance away, then slowly move forward.

Once the fire is out, keep an eye on the area in case it re-ignites.

Health & Safety

Rules for Fighting Fires

Fires can be very dangerous and you should always be certain that you will not endanger yourself or others when attempting to put out a fire.

For this reason, when a fire is discovered…

1. Assist any person in immediate danger to safety, if it can be accomplished without risk to yourself.

2. Call 911 or activate the building fire alarm. The fire alarm will notify the fire department and other building occupants and shut off the air handling system to prevent the spread of smoke.

If the fire is small (and Only after having done these 2 things), you may attempt to use an extinguisher to put it out. However . . . .

Health & Safety


. . . before deciding to fight the fire, keep these things in mind:

1. Know what is burning. If you don’t know what’s burning, you won’t know what kind of extinguisher to use.

2. Even if you have an ABC fire extinguisher, there may be something in the fire that is going to explode or produce toxic fumes.

Chances are you will know what’s burning, or at least have a pretty good idea, but if you don’t, let the fire department handle it.

Health & Safety


Do not fight the fire if:

You don’t have adequate or appropriate equipment. If you don’t have the correct type or large enough extinguisher, it is best not to try fighting the fire.

You might inhale toxic smoke. When synthetic materials such as the nylon in carpeting or foam padding in a sofa burn, they can produce hydrogen cyanide, acrolein, and ammonia in addition to carbon monoxide. These gases can be fatal in very small amounts.

Your instincts tell you not to. If you are uncomfortable with the situation for any reason, just let the fire department do their job.

Health & Safety


The final rule is to always position yourself with an exit or means of escape at your back before you attempt to use an extinguisher to put out a fire.

In case the extinguisher malfunctions, or something unexpected happens, you need to be able to get out quickly. You don’t want to become trapped.

Health & Safety


• Remember to keep an exit to your back

• Only fight a fire in the incipient stage

Health & Safety


NEVER fight a fire if any of the following apply:

• Don’t have the proper extinguisher or equipment

• Fire has spread beyond its point of origin

• Your instincts tell you GET OUT

Health & Safety

Fundamentals of Electrical Hazards

• To flow electricity must have a complete path.

• Electricity flows through conductors: water, metal,

the human body

• Insulators are non-conductors

• The human body is a conductor.

Health & Safety

Do’s and Don'ts

• Do plug power equipment into wall receptacles with power switches in the Off position.

• Do unplug electrical equipment by grasping the plug and pulling. Do not pull or jerk the cord to unplug the equipment.

• Do not drape power cords over hot pipes, radiators or sharp objects.

• Do check the receptacle for missing or damaged parts.

• Do not plug equipment into defective receptacles.

• Do check for frayed, cracked, or exposed wiring on equipment cords.

Health & Safety

Do’s and Don'ts

• Employees should know the location of electrical circuit breaker panels that control equipment and lighting in their respective areas. Circuits and equipment disconnects must be identified.

• Temporary or permanent storage of any materials must not be allowed within 3 feet of any electrical panel or electrical equipment.

• Any electrical equipment causing shocks or with high leakage potential must be tagged with a Danger tag or equivalent.

Health & Safety

Myths and Misconceptions

• Electricity takes the path of least resistance.

• Electricity wants to go to ground.

• If an electric tools falls into a sink or tub of water, the item will short out.

• AC reverse polarity is not hazardous.

• It takes high voltage to kill; 120 volts is not dangerous.

• Double insulated power tools are doubly safe and can be used in wet and damp locations.

Health & Safety

Fire Safety - On-the-Job Do not block fire extinguishers with equipment

Do not block fire emergency exits and escape routes

Utilize those with electrical expertise/installations/assistance

Do not overload outlets - use a track plug

Practice good housekeeping techniques in the work area

Inspect wires for possible damage and replace as needed

Health & Safety

Evacuation Planning Make sure that you know the escape routes .

know how to notify the fire department, and when to call for help.

Never open doors that are hot to the touch.

Remember to stop, drop to the ground and roll if their clothes catch fire.

Never re-enter a burning building

Your life is more precious than the diamonds ...

Machine Guarding

Health & Safety

Health & Safety

Machine Guarding

Many fatalities have resulted from employees getting caught in rotating shafts such as well boring drills & lathes.

Fixed guards:

• A permanent part of the machine

• Not dependent on any other part to perform the function

• Usually made of sheet metal, screen, bars or other material which will withstand the anticipated impact

• Generally considered the preferred type of guard.

• Simple and durable

Health & Safety

Machine Guarding

This shows a pulley

system which has

correct guards to

keep fingers and

tools away from

pinch points.

Health & Safety

Machine Guarding

• Robots can be deadly.

• Establish a system to keep humans from getting into the robots work area.

• Maintenance workers must use a lockout system.

What Is Workplace Violence?

• Workplace violence• Any act of physical violence

- overt aggression- Homicide, physical and sexual assault

Health & Safety

• Workplace aggression – emotional toll– Expressions of hostility

• Gestures, facial expressions and verbal assaults – Threats of physical violence– Harassment, intimidation, bullying

• Ostracism/shunning

– Obstructionism• Passive/aggressive behaviors that impede job performance or

achievement of organizational objectives

Behavior Warning Signs of Potential Violence and Their Probability of Occurrence (con’t)

– Evidence of drug and/or alcohol dependence

– Evidence of depression and withdrawal

– A pattern of pathological blaming

– Evidence of impaired neurological functioning

– An elevated frustration level

– An interest/fascination in weapons

– Evidence of a personality disorder

Health & Safety

Behavior Warning Signs of Potential Violence and Their Probability of Occurrence (con’t)

Health & Safety

– Unexplained increase in absenteeism

– Noticeable decrease in attention to appearance and personal hygiene

– Has a plan to “solve all problems”

– Resistance and over reaction to changes in policies or procedures

– repeated violations of the organization’s policies

Preventing Workplace Violence (con’t)

Health & Safety

• Administrative/Organizational

– Programs

• Workplace Violence Plan

• Threat Assessment Team

• EAP

– Policies

• Harassment

• Workplace violence

• SOPs

Health Issues

Health & Safety

• Eating area should be kept clean

• Toilets clean and segregated

• Drinking water

• Noise level

• Environnemental awareness

• Harassement ...

Health & Safety

The point is….

• TAKE THE EFFORT

• TAKE THE TIME

• & DO WHAT IS RIGHT!

• CORRECT SITUATIONS “ON-THE-SPOT” to prevent a worse situation.

Health & Safety

You are IN CONTROL

• If you SEE SOMETHING that is NOT RIGHT

– REPORT IT IMMEDIATELY!

– DO SOMETHING ABOUT IT!

– TELL SOMEONE (ANYONE!)

• Choose to be PRO-ACTIVE!

The Kimberley Process and

Anti Money Laundering

Rough Diamonds used by rebel movements or their

allies to finance conflict aimed at undermining legitimate

governments, as described in relevant United Nations

Security Council (UNSC) resolutions insofar as they

remain in effect, or in other similar UNSC resolutions

which may be adopted in the future and as understood

and recognised in United Nations General Assembly

(UNGA) resolution 55/56, or in other similar UNGA

resolutions which may be adopted in the future.

Kimberley Process and AML

What is a Conflict Diamond?

The Kimberley Process: rough diamond sector international regulation supervised by the UN.-Only Rough Diamonds-Only when movement from country to country (Import-Export): KP Certificate from exporting country authorized by UN-Reconciliation by Company Auditor-Record keeping for 5 years

Statement (WDC) on invoice when internal movement:


What is the Solution?

“The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and in compliance with United Nations Resolutions. The undersigned hereby guarantees that these diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.”


What is Money Laundering?

• Any type of conscious involvement with the transfer, holding, hiding, using, etc of monies and assets with an illegal origin. Also if one were reasonably aware of someone being in any way related to transactions with monies or assets with an illegal origin, one would already be involved in money laundering activities.

• The origin of money or assets is illegal when these originate from a series of crimes mentioned by name, such as terrorism or terrorism financing, organized crime, illegal drug traffic, exploitation of prostitution; serious and organized tax fraud, for which extreme complicated mechanisms or procedures of international size are used; swindle, abuse of trust, abuse of corporate assets, a hijacking, a theft or extortion with violence or threat or a crime connected with the state of bankruptcy.


What is the Solution?

• Financial Action Task Force 40 Recommendations

• Belgian Anti Money Laundering Law

• USA P.A.T.R.I.O.T Act

FOR DIAMOND TRADERS

Obligation to identify clients and notification of suspicious transactions or facts

Prohibition for cash payments in excess of $10.000


What are the Obligations?

• Identification of clients– KYC– $10.000

• Keeping of records• To draw a written report• To train and sensitize employees• To appoint a Money Laundering Responsible and to set up a

procedure for internal check-up (in doubt always refer to him)

• Duty to report to the Financial Cell• Pledge of secrecy• Immunity


Examples of AML suspicious activities?

• Transactions with non-registered diamond dealers. Being non-registered indicates an irregular way of doing business which always seems SUSPICIOUS.

• Transactions that, without any specific reason, are split up in various separate transactions.

• Transactions of a large size that are executed in small bank notes (but of course less than $10,000).

• Transactions of a large size where the client has not counted the bank notes up front or where large amounts are offered in different currencies: handling cash in a sloppy way always leads to suspicious situations as do cases where fellow contractors offer a very complicated or surprising way of payment.



• Transactions where, without any reason, intermediaries are used. It can either be about intermediaries who, without any plausible reason, execute large transactions for a third party or it is assumed that they are executed for a third party, or it can be about individuals accompanied by a third who supervises the transaction and refuses to make his identity known. Such practices with these kinds of puppets always lead to a suspicious situation.

• Transactions where pieces of dubious origin or even fake identity cards are used or where problems rise while identifying a client.

• Transactions that are executed with or for the account of post office box companies, usually situated in tax havens are suspicious.



• Transactions which have no apparent economic reason for being executed in your country.

• Uncommon transactions in the light of the client's common activities of which the background and its goal are not being explained.

• Transactions where the client behaves suspiciously and shows little interest in the charged selling margin or commissions, even though it concerns large amounts.

Disclosure

Disclosure

What is Disclosure?

Only a natural diamond can be called and sold as a Diamond.

Natural: the stone is of natural origin, not man made, not synthetic, not a simulant.

Diamond: a natural mineral consisting essentially of pure carbon crystallised with a cubic structure in the isometric system. Its hardness in the Mohs scale is 10; its specific gravity is approximately 3,52; it has a refractive index of 2,42 and it can be found in many colours.

Disclosure

Why?

1) To restore and build up Consumer Confidence.

2) To combat Synthetics.

Disclosure

General Rules

• ALL facts ALWAYS

• Regardless of effect on value

• No exception

• Verbal AND written on ALL documents in plain English

• always immediatly preceeding or succeeding the description of the Diamond

• Misuses of Terminology prohibition in ALL circum-stances (Flawless, perfect, blue white, properly cut, modern cut)

• No mis-representation of weight

Disclosure

Synthetics

• Definition: any object or product that has been either partially or wholly crystallised or re-crystallised due to artificial human intervention such that, with the exception of being non-natural, the products meet the requirements specified in the above mentioned definition of diamond

• Rules:

1-Always disclose as SYNTHETIC -MAN MADE-LAB CREATED-ARTIFICIAL

2-Never use misleading terms as CULTURED

3-Never use names of firms , manufacturers or trademarks without the terms of point 1(e.g. ACME DIAMONDS)

Disclosure

Treated Diamonds

• Definition: any process, treatment or enhancement changing, interfering with and/or contaminating the natural appearance or composition of a diamond other than the historically accepted practices of cutting and polishing. It includes colour (and decolourisation) treatment, fracture filling, laser and irradiation treatment and coating.

• Rules:

1-All treatments other than historically accepted

2-Colour (and decolourisation ) treatments, Fracture filling, Laser, HTHP, Irradiation coating

Disclosure

Treated Diamonds

3-Always Disclose all treatments , and their effect on Diamond value the special care requirements

4-Never disguise the term used e.g. “IMPROVED”

5-Never use names of firms , manufacturers or trademarks alone with DIAMOND (e.g. ACME DIAMONDS in stead of ACME DIAMOND treated by HPHT)

Disclosure

Diamond Simulants

• Definition: any object or product used to imitate diamond or some or all of its properties and includes any material which does not meet the requirements specified in the above mentioned definition of diamond.

• Rules:

1- Always disclose as the mineral (Zircon) or compound (Cubic Zirconia) or as FAKE IMITATION or SIMULANT Diamond

2- Never use names of firms , manufacturers or trademarks alone with DIAMOND(ACME DIAMONDS in stead of ACME DIAMOND SIMULANT , SWISS DIAMOND)

Disclosure

SunDiamond Efforts

• Business Policy

• Supply Chain Management

• Traceability Management Process is designed to authenticate that the diamonds, which carry the label PurelyNaturalDiamondTM, that are sold by the SunDiamond Group of Companies are natural, not treated, conflict free, legal and processed in compliance with the strictest ethical codes of the industry.

• PurelyNaturalDiamond™

thanks you for your attention!

diamond best practice principles (bpp) training welcome to the

Documents

business policy community

bpp slide

business policy human

business policy child

reputation slide

brc slide

aml disclosure slide

bpp training