Governance and ethics
As an organisation whose product derives its value from the perception of its consumers, we are committed to supplying rough and polished diamonds to our clients that are produced and distributed in accordance with legal and ethical standards. To achieve this, we have fostered a strong culture of corporate integrity and good governance, which extends throughout the full business cycle.
Creating a safe and healthy working environment
Developing and retaining our people
Optimising community benefit
Minimising our environmental impact
OUR PERFORMANCE
Every rough diamond of ours is certified under the Kimberley Process.
Fully compliant
with all government regulations and relevant voluntary codes concerning product and service information labelling.
Zero significant cases of bribery, corruption or anti-competitive behaviour, have been brought against us to date (2016: zero).
Zero incidents
of potential breach of confidentiality of clients (2016: zero).
19 cases of whistleblowing (2016: ten).
OUR CHALLENGES
Incorporating human rights training as standard practice remains a challenge across the Group.
Applying the Group’s Anti-Bribery and Corruption Policy to ensure continued compliance with the UK Bribery Act requirements.
OUR FUTURE
Continued focus on raising standards across our supply chain to prevent modern slavery.
Improving human rights training.
Implementing a Group-wide Code of Ethics to support the management of governance and ethics in the Group.
RELATED UN SDGs
Material matters
Protecting human rights
Our context
Diamonds can have a beneficial impact on the areas in which we operate when mined and traded responsibly. We also acknowledge, however, that if diamonds are mined and sold irresponsibly, they may fuel conflict and contribute to human rights violations. We recognise the inherent worth of every human being involved in our value chain and are committed to working to the highest standards regarding the protection of their human rights.
Our approach
We continuously refine our policies and procedures relating to upholding the rights of our employees and Project Affected Communities (PACs). Our subsidiaries adhere to the host country’s legislation as a minimum standard, and applicable international best practice has been incorporated into all human rights-related policies and procedures, ensuring that we are respecting humanity and prioritising ethical care.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain. Our policies on sustainable development and human rights, as well as our code of ethics, reflect our commitment to acting ethically as well as implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chain.
Employees receive training and communication updates through which they are made aware of the content of various policies that underpin our ethics and values. In addition, we conduct training in human rights policies and practices based on the human rights risk profile for each operation. Beyond training, we enforce our policies on the fair treatment of employees both through negotiated remuneration policies and our stringent health and safety practices.
We are strongly against human rights violations, including gender, age and racial injustices in the workplace. Non-discrimination policies are implemented across the Group, and we adhere to stringent policies to prevent child and forced labour. We also ensure rigorous controls are in place throughout our supply chain to ensure no slavery or human trafficking occurs.
Our performance
- Conducted human rights training for 38 of our employees.
- Zero cases of child or forced labour involving Gem Diamonds have ever been reported (2016: Zero).
- None of our operations has engaged in the relocation or resettlement of any PACs during the reporting period (2016: No relocation).
Prioritising business integrity
Our context
The manner in which our diamonds are mined and distributed plays a significant role in our broader social licence by maintaining and enhancing a positive public perception. We aim to supply our clients with rough and polished diamonds of the highest standard while meeting our responsibilities as an ethical and accountable organisation.
Our approach
Throughout our diamonds’ journey, from rough to polished, responsible business practices are carried out each step of the way to ensure our diamonds live up to the beauty and promise they embody.
We are committed to upholding the highest ethical standards. This means ensuring that we are compliant with relevant government regulations and voluntary codes concerning labelling, as well as product and service information. To ensure that our diamonds reach the market through the correct channels, we apply strict controls concerning potential customers.
All Gem Diamonds’ clients undergo a screening process and trade with us is by invitation only. During the screening process, potential clients are vetted using internal anti-money laundering protocols and ‘know your client’ reviews to ensure compliance with regulatory requirements.
The diamond industry has traditionally employed strict requirements for security and confidentiality, and this has resulted in low levels of transparency. In an attempt to rectify this and build strong relationships, we ensure that all relevant information is continuously and transparently communicated to our stakeholders. For instance, following the conclusion of each rough diamond tender, a complete list of the winning bids is electronically circulated to all tender participants, thus ensuring a transparent sales process.
Our performance
- Zero instances of major or significant stakeholder complaints (2016: Zero).
- Fully compliant with the Kimberly process (2016: Fully compliant).
- Zero cases of potential breach of client confidentiality (2016: Zero).
Ensuring transparent governance and remuneration practices
Our context
We are fully committed to the highest standards of corporate governance which will support the long-term success of the Company. We believe that robust corporate governance is a tool to create and preserve value for the Group and our stakeholders, enabling us to provide attractive returns to our investors and actively contribute to the societies in which we operate.
Our approach
The Board is ultimately responsible to shareholders for the Group’s activities, its strategy and financial performance, for the efficient use of the Group’s resources and for health, safety, social and environmental matters. We regularly review our external reporting to ensure we align with industry best practice.
The Remuneration Committee considers and determines all elements of the remuneration of the Chief Executive Officer, the Chief Financial Officer and the senior executive team and determines the terms of any performance-related remuneration paid by the Company.
The Remuneration Committee comprises two independent non-Executive Directors and the Chairman and meets formally at least twice a year, and senior management and external advisers may be invited to attend meetings as the Remuneration Committee considers appropriate.
Our performance
See our Annual Report for more information.
Ensuring corporate governance is compliant with industry best practices
Our context
The Group’s commitment to robust corporate governance supports its ability to create sustainable returns for all stakeholders. We continue to monitor and align with industry best practice.
Our approach
The Group keeps abreast of any changes to the UK Corporate Governance Code and other relevant standards and ensures the implementation of the changes are done timeously. During 2017, we continued to evolve our governance to industry best practice.
Our performance
See our Corporate Governance Report in our Annual Report.
Raising standards across the pipeline
Our context
Our business processes are supported by our supply chain, which comprises the supply of goods and services throughout the various business cycles. Products are procured in respect of raw, direct and indirect materials and the various purchased services range from technical, legal, administrative and professional services to skilled labour services for operational purposes.
Our approach
As part of the Groups focus on identifying and mitigating risks, the Group has established a whistleblowing policy. The whistleblowing policy allows for employees to anonymously report any unethical activity taking place in the workplace. To ensure all those in the supply chain support the ethos of the Group, there are procurement policies in place, which drive rigorous vetting processes. The procurement policies ensure not only that all qualifying suppliers and service providers are given equal opportunity to compete and supply services, but it also promotes in-country procurement as far as practicable.
Potential risk areas are scrutinised, and goods and services are only procured from reputable companies. Suppliers are required to adhere to the Group’s ethical policies.
The Group has adopted a zero-tolerance approach to acts of bribery and corruption involving any of its staff and 3rd party representatives or associates and is committed to upholding and complying with the requirements of the UK Bribery Act. All customers and third parties with whom business is transacted are required to adopt the same zero tolerance approach to bribery and corruption as implemented by the Group. Group internal audit carries out regular reviews of the Group’s Anti-Bribery and Corruption Policy to ensure continued compliance with the UK Bribery Act requirements.
Our performance
- Whistleblowing policy in place.
- Goods and services are only procured from reputable companies and in line with our procurement policy.
- Representatives from several divisions within our Group’s operations are involved in the evaluation of suppliers.
- Suppliers are required to adhere to our ethical policies.