RJC Members commit to and are independently audited against the RJC Code of Practices – an international standard on responsible business practices for diamonds, gold and platinum group metals. The Code of Practices addresses human rights, labor rights, environmental impact, mining practices, product disclosure and many more important topics in the jewelry supply chain. More …
It is the policy of Kubér Mfg. to prohibit the use of our business or services for money laundering or terrorist financing. This AML Program and Policy has been developed in conformance with the requirements of rules promulgated by the U.S. Department of Treasury, Financial Crimes Enforcement Network, 31 CFR Part 103, Section 130.140 c, under the Bank Secrecy Act as amended by the USA PATRIOT Act of 2001 (Pub.L.107-56) and is based on Kubér Mfg.’s assessment of the money laundering and terrorist financing risks associated with Kubér Mfg.’s transactions pertaining to covered goods. This Program and Policy will be made available to the U.S. Department of Treasury or any other duly authorized government agency upon request. Both AML Program/Policy and Risk Assessment have been reviewed by (The Board of Directors) (Senior Management) of Kubér Mfg.. Both this Program and the Risk Assessment may be updated from time to time. This Program and Policy applies only to the purchase and sale of covered goods defined as precious metals (of an assay in excess of 500 parts per thousand), precious stones and jewels, and finished goods of which 50% of the value is derived from the precious metal, precious stones or jewels contained in or attached to such goods.
For any product fabricated from rough diamonds mined from January 1, 2003, onward the seller warrants that the diamonds have been purchased from legitimate sources not involved in funding conflict and are in compliance with the United Nations resolutions. The seller hereby guarantees that the diamonds are conflict-free, based on personal knowledge and/or written guarantees provided by the seller of these diamonds. For any product fabricated from rough diamonds mined prior to January 1, 2003, the seller warrants that conflict diamonds will not knowingly be sold and that to the best of their ability, will undertake reasonable measures to help prevent the sale of conflict diamonds in this country.
Consistently Supply Fine Jewelry using Cutting Edge Technology & High Degree of Precision To Fine Jewelers all over the World
Conduct the Business Ethically and Responsibly for Mutual benefit of all Stakeholders
Supply Chain Policy & Procedure
1. Kuber MFG is a Jewelry Trading Company. This policy confirms Kuber MFG’s commitment to
respect human rights, avoid contributing to the finance of conflict and comply with all relevant USA /
UN sanctions, resolutions and laws.
2. Kuber MFG is a member of the Responsible Jewelry Council (RJC). As such, we commit to
proving, through independent third-party verification, that we:
a. respect human rights according to the Universal Declaration of Human Rights and International
Labour Organization Fundamental Rights at Work;
b. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
c. support transparency of government payments and rights – compatible security forces in the
extractives industry;
d. do not provide direct or indirect support to illegal armed groups; and
e. enable stakeholders to voice concerns about the jewelry supply chain.
f. are implementing the OECD 5 -Step framework as a management process for risk based due
diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.
3. We also commit to using our influence to prevent abuses by others. Our supplier is not from
CAHRA and we do not procure goods from CAHRA. Many of our Suppliers are RJC Certified
member and hence is compliant to OECD Guidelines.
4. Regarding serious abuses associated with the extraction, transport or trade of Gold, diamonds /
colored gemstones
We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:
a. torture, cruel, inhuman and degrading treatment;
b. forced or compulsory labor;
c. the worst forms of child labor;
d. human rights violations and abuses; or
e. war crimes, violations of international humanitarian law, crimes against humanity or genocide.
5. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they
are committing abuses described in 4 or are sourcing from, or linked to, any party committing these
abuses.
6. Regarding direct or indirect support to non-state armed groups
We only sell or purchase jewelry including precious metals, Diamonds / Colored Gemstones that are
fully compliant with the Dodd Frank Act, WDC SoW and, as such, will not tolerate direct or indirect
support to non-state armed groups, including, but not limited to, procuring jewelry from, making
payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:
a. control mine sites, transportation routes, points where gold, diamonds/colored gemstones are
traded and upstream actors in the supply chain; or
b. tax or extort money or gold/diamonds/colored gemstones at mine sites, along transportation
routes or at points where gold/diamonds/colored gemstones are traded, or from
intermediaries, export companies or international traders.
7. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they
are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed
groups as described in paragraph 6.
8. Regarding public or private security forces
We affirm that the role of public or private security forces is to provide security to workers, facilities,
equipment and property in accordance with the rule of law, including law that guarantees human
rights. We will not provide direct or indirect support to public or private security forces that commit
abuses described in paragraph 4 or that act illegally as described in paragraph 6.
9. Regarding bribery and fraudulent misrepresentation of the origin of diamonds/colored gemstones
We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal
or disguise the origin of diamonds/colored gemstones, or to misrepresent taxes, fees and royalties
paid to governments for the purposes of extraction, trade, handling, transport and export of diamonds.
10. Regarding money laundering
We will support and contribute to efforts to eliminate money laundering where we identify a
reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of
diamonds/colored gemstones.
REPORTING
COP3 Human Rights
We conduct a Human Rights Due Diligence in our operation of Trading, manufacfturing as well as in our
supply chain. We promote the RJC CoP as responsible Business Practices amongst our Business Associates
through discussions and through our website recommendation. We have not found any Human Rights impacts
in our operations or supply chain.
We find that RJC Membership has contributed to improved efficiency and enhanced compliance with the
Responsible Business Practice requirements. Ove the years, we have seen the industry improve.
It is also an Industry wide initiative to improve the Credibility of the Diamond and Jewellery Supply Chain
amongst the consumers. We recommend that all our Business Associates support the RJC and become
Certified Members.
Kuber MFG has not identified any adverse human rights issues during our due diligence activities. We have
also provided training using RJC Modules to our staff. We shall conduct the due diligence annually.
COP 6 & 7: HUMAN RIGHTS & DUE DILIGENCE
COMPANY MANAGEMENT SYSTEMS
Kuber MFG have Ethical Business Policy and Supply Chain Policy in place, detailing our commitment to
respect human rights throughout our supply chain and our supply chain due diligence on the following
minerals, gold, diamonds & Coloured gemstones. We do not source from conflict affected or high risk
areas.These policies can also be accessed by our internal stakeholders Display in the Office and externally on
our website on the compliance page.
To support supply chain due diligence, we have implemented the following internal measures. We have
mapped pur supply chain and engaged with the suppliers.We have e-mailed our supply chain policy to all our
suppliers and have asked a confirmation from them that they have understood it and comply with the
requirements. The process is managed by the President.
Kuber MFG have established a system of controls and transparency over our supply chain, which include our
approach for identifying suppliers who are able to give a warranty as per the requirements of the Doodd Frank
Act & World Diamond Council.
As a company we communicate our expectations regarding human rights and supply chain due diligence by We
engage with out suppliers at every order. The outcome of doing so has been that there are no Red Flags in our
supply chain.
Grievance can be raised on
[email protected] about any Human Rights Issues and it shall be
investigated by President. No grievances have been raised.
IDENTIFIED & ASSESSED RISKS
We have not identified any Human Rights Risks related to any supplier in our supply chain.All our suppliers are
known and verified and we have long term relationship with them. No actions are currently planned.
None of our suppliers are from CAHRAs.
STRATEGY
Our risk assessment findings are received by Compliance Officer.
All the identified risks are adequately controlled. We have used the RJC Template for Risk Assessment and the
controls are identified.
We have used the RJC Training modules for Trainings.
This declaration is made available on the website.
CARRY OUT A THIRD PARTY AUDIT
Kuber MFG has joined the RJC and this is the third audit cycle. The system has been upgraded in conformance
wioth RJC CoP 2019. Third party audit will be conducted along with the RJC CoP 2019 audit by the auditor. The
audit is scheduled in January 2023
COP 27: NATURAL RESOURCES
Kuber MFG have identified no issues regarding our use of natural re-sources. As a business we monitor our use
of energy and water and we have identified that all the use is for domestic purpose.
We switch off the lights when not required and use water only as and when required. The trading process does
not use any water.
