Supply Chain Policy Report

Sol Savransky Diamonds, Inc. is a wholesaler of finished gold and platinum jewelry based in New York City. This policy confirms our commitment to respect human right, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws and abide by our commitment to the RJC Code of Practices.

We commit to proving through independent third-party verifications, that we are:

respect human rights according to the Universal Declaration of Human Rights and International Labor Organization Fundamental Rights at Word k
do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism.
support transparency of government payments and rights-compatible security forces in the extractives industry;
do not provide direct or indirect support to illegal armed groups; enable stakeholders to voice concerns about the jewelry supply chain; and;
enable stakeholders to voice concerns about the jewelry supply chain; and
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.

We also commit to using our influence to prevent abuses by others. If there is no significant measurable improvement to prevent or mitigate the risks of direct or indirect support to public or private security forces, bribery, and fraudulent misrepresentation of the origin of minerals, money-laundering and payment of taxes fees and royalties to governments as identified below, we will suspend or discontinue engagement with the supplier for a minimum of three months. Trade relationship will be resumed if there is progressive improvement.

Regarding serious abuses associated with the extraction, transport, or trade of minerals:

We will neither tolerate nor profit from, contribute to, assist, or facilitate the commission of:

torture, cruel, inhuman, and degrading treatment;
forced or compulsory labor.
the worst forms of child labor:
human rights violations and abuses; or
war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described above or are sourcing from, or linked to, any party committing these abuses.

Regarding direct or indirect support to non-state armed groups:

We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring minerals from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

control mine sites, transportation route, points where minerals are traded and upstream actors in the supply chain; and
tax or extort money or minerals at mine sites, along transportation routes or at points here minerals are traded, or from intermediaries, export companies or international traders.
We will only buy or sell diamonds that are fully compliant with the Kimberley Process Certification System and System or Warranties.

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 nonstate armed groups as described above.

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 above under “Regarding serious abuses associated with the extraction, transport or trade of minerals”, or that act illegally as described above under “Regarding direct or indirect support to non-state armed groups”.

Regarding bribery and fraudulent misrepresentation of the origin of minerals:

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport, and export of minerals.

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 minerals.

We also commit to using our influence to prevent abuses by others by informing our suppliers and stakeholders of our policies through emailings and online vehicles. SSDI will require KYC forms from vendors and relevant customers to prove legitimization in the diamond industry, as well as an acknowledgement letter that partnering companies will follow the points of interest of the RJC if not duly certified. Complaint mechanisms are in place through contacting our office and will be placed online. Companies that have proven to be blatant non-compliant with RJC policies will be removed from vendor/customer list until proof of correction can be shown. Companies suspected of abuses will be given up to 6 months to correct abuses and we will offer guidance to correct the abuse. If company has not changed practices, we will stop doing business with this company. If it is suspected that any upstream company (internally or externally) that any of our upstream suppliers are sourcing from an conflict-affected and high-risk areas they shall immediately alert the highest ranking company officer in confidentiality and will be investigated by compliance officer. Due diligence will be used to confirm or dismiss the presented alert. The alert will be evaluated against the RJC guidelines. Any questions or complaints should be direct to Eli Savransky at eli@savransky.com.

Eli Savransky

September 14, 2022