Logo

Sustainable Development Report 2019

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.

RELATED SUSTAINABILITY PRINCIPLES

  • CREATING A SAFE AND HEALTHY WORK ENVIRONMENT
  • PRIORITISING THE DEVELOPMENT AND WELL-BEING OF OUR EMPLOYEES
  • OPTIMISING SOCIO-ECONOMIC BENEFIT
  • PRIORITISING ENVIRONMENTAL PROTECTION

A SNAPSHOT OF OUR PERFORMANCE

  • Every rough diamond recovered is certified through the Kimberley Process.
  • Fully compliant with all government regulations and relevant voluntary codes concerning product and service information labelling.
  • Zero cases of bribery, corruption or anti-competitive behaviour have been brought against us to date (2018: Zero). 
  • Zero incidents of breach of confidentiality and privacy of client information (2018: Zero).
  • 20 cases of whistleblowing (2018: 24).

Related UN SDGs



For more information on our approach to integrating the 17 SDGs into our business operations, please see our UN SDG Framework (Working towards global goals).

Our challenges

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

Our future

  • Continued focus on improving 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

Although diamonds mined in accordance with the requirements of the Kimberley Process have a positive impact on value, those that are not have large-scale negative consequences, including significant reputational damage, the fuelling of conflict and contributing to human-rights violations. Therefore, we ensure that we operate in a manner compliant with the Kimberley Process. Furthermore, we recognise the inherent worth of each stakeholder 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 strongly oppose any human rights violations, including gender, age and racial injustices in the workplace. Non-discrimination policies are implemented across the Group, and we also adhere to stringent policies to prevent child or forced labour.

Our performance

  • Human rights training included in the Letšeng induction programme.
  • 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 (2018: 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 mining 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 (2018: Zero).
  • Fully compliant with the Kimberly Process (2018: Fully compliant).
  • Zero cases of breach of client confidentiality (2018: 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 driving 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 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 2019, we updated our governance practices to ensure compliance with 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 that support our business processes. Products comprise raw, direct and indirect materials, and services include technical, legal, administrative and professional services, as well as skilled operational labour.

Our approach

As part of the Group's focus on identifying and mitigating risks, we established a whistleblowing policy that enables and encourages employees to anonymously report any unethical activity taking place in the workplace. 

The policy was reviewed and updated in 2019 and all incidents reported through the whistleblowing line were dealt with appropriately and with the necessary consequence management.

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 possible.

We ensure that goods and services are only procured from reputable companies, and 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 expanded, with 20 reports logged (2018: 24).
  • Goods and services procured during the year were all procured from reputable companies and in line with our procurement policy.
  • During 2019, 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 and anti-bribery and corruption policies.