Governance and Ethics

The value of our diamonds is inextricably linked to the manner in which they are mined. As such, we are committed to supplying rough and polished diamonds to our clients that are produced and distributed in accordance with the highest ethical and legal standards. We continue to entrench robust governance throughout our business, to ensure we continue to operate with ethics and integrity.




  • Every rough diamond of ours is certified through 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 (2017: Zero).

  • Zero incidents of potential breach of confidentiality of clients (2017: Zero).

  • 24 cases of whistleblowing (2017: 19).

Related UN SDGs

Our challenges

  • Ensuring full compliance with the amendments and additions to the UK Corporate Governance Code.
  • Ensuring all employees, from diverse backgrounds, understand and abide by our code of conduct is an ongoing challenge.
  • The impact of any perceived ethical breach has the potential to cause reputational damage and subsequently impact on product value.

Our future

  • Continued focus on raising standards across our supply chain to ensure compliance with our standards relating to human rights, ethics and bribery and corruption prevention.
  • Improving human rights training
  • Continued management of compliance with the Group-wide Code of Ethics.

Material matters

Protecting human rights

Our context

Diamonds mined in accordance with the requirements of the Kimberley Process can have a positive impact, while those that are not can have large scale negative consequences, including fuelling conflict and contributing to human rights violations. This is why we ensure we operate in a manner compliant with the Kimberley Process. Furthermore, we recognise the inherent worth of every person in our value chain and work to the highest standards to ensure their human rights are protected.

Our approach

As a minimum, we adhere to the legislation and regulations of our host countries and incorporate applicable international best practice into all human rights-related policies and procedures. We continuously refine our policies and procedures relating to upholding the rights of our employees and Project Affected Communities (PACs).

Our sustainable development framework and our code of ethics have been aligned to reflect our commitment to working ethically. In addition, we have implemented systems and controls in our supply chain management to ensure our suppliers have eliminated the potential in their business for slavery and human trafficking.

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.

Our performance

  • Conducted human rights training for 858 of our employees (2017: 38).
  • Zero cases of child or forced labour involving Gem Diamonds have ever been reported.
  • None of our operations have engaged in the relocation or resettlement of any PACs during the reporting period (2017: None).

Our context

Our regulatory and social licences to operate are dependent on the manner in which our diamonds are mined and distributed. We aim to supply our clients with rough and polished diamonds of the highest quality while meeting our responsibilities as an ethical and accountable organisation.

Our approach

From liberation to sale, throughout our diamonds' journey, we ensure that responsible business practices are incorporated 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 recognised legal and ethical channels, 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.

To enhance transparency, we ensure that all relevant information is continuously and clearly 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 (2017: Zero).
  • Fully compliant with the Kimberly process (2017: Fully compliant).
  • Zero cases of potential breach of client confidentiality (2017: Zero).

Our context

We are committed to entrenching world-class governance throughout our business, enabling us to provide returns to our investors while positively contributing 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, as well as for the efficient use of the Group's resources and improving its health, safety, social and environmental performance. 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. The Remuneration Committee also determines the terms and conditions of performance-related remuneration paid by the Company.

The Remuneration Committee comprises two independent non-Executive Directors and the Chairman, and it meets formally at least twice a year. Executive and senior management, as well as external advisers, may be invited to attend meetings as the Remuneration Committee considers appropriate.

Our performance

See our Annual Report for more information.

Our context

The Group's commitment to robust corporate governance supports our 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 2018, we embarked upon the process of aligning our governance practices to the amendments to the Code.

Our performance

For our performance, refer to our Corporate Governance Report in our Annual Report.

Our context

We rely on supply chains that are multi-layered and our business processes are supported by these chains. 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 Group's focus on identifying and mitigating risks, we established a whistleblowing policy. The whistleblowing policy enables and encourages employees to anonymously report any unethical activity taking place in the workplace.

Our procurement policies drive rigorous vetting processes, ensuring that all qualifying suppliers and service providers are given equal opportunity to compete and supply services while also promoting in-country procurement as far as practicable.

We ensure that goods and services are only procured from reputable companies; suppliers are required to confirm their adherence to the Group's ethical policies.

The Group enforces a zero-tolerance approach to acts of bribery and corruption involving any of its staff, third-party representatives or associates and is committed to upholding and complying with the requirements of the UK Bribery Act. All parties with whom we do business are required to confirm the same zero-tolerance approach to bribery and corruption. 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, with 24 reports logged.
  • Goods and services procured during the year were all procured from reputable companies and in line with our procurement policy.
  • During 2018, new suppliers were evaluated by a diverse team, including representatives from several divisions within our Group's operations.
  • All of our suppliers have signed and agreed to adhere to our ethical policies.