POLICIES

IMPORTANT POLICIES

1
POLICY STATEMENT
For Child Labour

2
POLICY STATEMENT
of Forced Labour

3
POLICY STATEMENT
of Freedom of association and Collective Bargaining, Discrimination and Discipline and Grievance Procedures

4
POLICY STATEMENT
General Employment, Working hours, Remuneration

5
POLICY STATEMENT
Health and Safety

6
POLICY STATEMENT
Environmental protection, Hazardous substances, waste and Emissions, Use of Energy and natural resources

7
POLICY STATEMENT
of Human Rights

8
POLICY STATEMENT
Bribery and Facilitation Payments

9
POLICY STATEMENT
Product Security

10
POLICY STATEMENT
Money Laundering and Finance of terrorism

11
POLICY STATEMENT
Kimberley Process

12
POLICY STATEMENT
of Product Integrity and Disclosure

13
POLICY STATEMENT
Community Engagement and Development

14
POLICY STATEMENT
Use of Security Personnel

15
POLICY STATEMENT
Use of Supply Chain

16
POLICY STATEMENT
on Social Compliance

17
POLICY STATEMENT
Bio-Diversity Policy

18
POLICY STATEMENT
on Right of Land

19
POLICY STATEMENT
Data Privacy Policy

CONTACT US

02240046863
02240042264

amit.sadiamonds@gmail.com

REACH US

S A Diamonds, DC 5020,
Bharat Diamond Bourse,
Bandra Kurla Complex(BKC),
Mumbai, Maharastra,
400051

OPENING HOURS

Monday – Friday
10AM – 6PM

Saturday – Sunday
10AM – 6PM

EXCEPTIONAL IS OUR STANDARD

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POLICY STATEMENT FOR CHILD LABOUR

No form of child labour should be employed at S A DIAMONDS.
The minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).
For authorized adolescents (persons below 18 years of age but above 15 years), the entity management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
If a child is found working at S A DIAMONDS either own or subcontracted, the responsibility of rehabilitation will be undertaken by the management.
The above policies will also be applicable to subcontracted labour.

Policy Statement of Forced Labour

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference:
The management of S A DIAMONDS are fully committed to ensuring that forced or involuntary, bonded, indentured or prison labour, is not practiced nor used in any form at any of its facilities. S A DIAMONDS shall ensure that there is no restriction in the freedom of movement of employees and dependents. Any reported incidents relating to forced labour will be considered as a serious violation of theBusiness Policies.
The following definitions will be applicable:
The Universal Declaration of Human Rights that states that ‘No one shall be held in slavery or servitude’
ILO Convention 29, which defines forced or compulsory labour as ‘all work or service which is extracted from any person under the menace of any penalty, and for which the said person has not offered himself voluntarily”

Policy Statement of Freedom of association and Collective Bargaining, Discrimination and Discipline and Grievance Procedures

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference:

S A DIAMONDS will not prevent employees from associating and collective bargaining.

Discrimination can mean distinction, exclusion or preference.

Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, ethnicity, caste, national origin, religion, age, disability, gender, marital status, physical appearance, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by S A DIAMONDS and any such reported incidents will be viewed as a serious violation of this Business Policies.

S A DIAMONDS will ensure that employees who have certain life threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.

Individuals who are “Fit for Work” shall be accorded equal opportunities and shall not be discriminated against on the basis of factors unrelated to their ability to perform their job.

S A DIAMONDS shall not use corporal punishment under any circumstances and will ensure that employees are not subjected to harsh or degrading treatment, sexual or physical harassment or other forms of mental or physical coercion, abuse or intimidation.

S A DIAMONDS encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, entity operation or practice is or will likely be in violation of any law, regulation or internal entity rule or policy, including this Business Policies. S A DIAMONDS assures all employees who come forward in good faith to reportIssues, that they will be treated fairly and respectfully. While all efforts will be taken to protect the anonymity of employees as far as practicable, any form of retaliation against any such individuals, assuming they have not been involved in the violation, will not be tolerated.

Policy Statement General Employment, Working hours, Remuneration

S A DIAMONDS complies with applicable national laws / regulations with respect to employment.

S A DIAMONDS is committed to maintaining appropriate records as stipulated by the regulatory authorities for all staff employed, whether on a full time, part time or seasonal basis.

S A DIAMONDS shall not require workers to work for more than the national limit of hours in a week on a regular basis, with overtime hours not to exceed the national permitted limit per week on a regular basis unless there are legal opt-outs.

S A DIAMONDS shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of workers.

Wages shall be paid to employees on a regular and predetermined basis in a manner and location convenient to employees, accompanied by a wage slip detailing wage rates, benefits and deductions as applicable.

S A DIAMONDS shall ensure that due process of wage deductions shall be followed where applicable and it shall not be binding on employees to buy provisions from the group.

When required, due recognition will be given to the existence, membership and lawful activities of worker representative bodies, and worker representatives will be given access to carry out their responsibilities / functions.

S A DIAMONDS is committed to addressing the legitimate grievances of its employees.

S A DIAMONDS shall follow proper procedure as per law for dismissal of employees, in case the need for the same arises, and arbitrary dismissal procedures shall be avoided.

Information regarding applicable employment policies and working practices shall be communicated in a transparent manner to all employees.

S A DIAMONDS is fully committed to the pursuance of the provision of fair and conducive employment conditions, consistent with applicable laws and regulations.

Issues will be treated fairly and respectfully by them. While all efforts will be taken to protect the anonymity of employees as far as practicable, any form of retaliation against any such individuals, assuming they have not been involved in the violation, will not be tolerated.

Policy Statement Health and Safety

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference:
S A DIAMONDS recognizes the need to develop a sustainable, value creating business and is committed to the following in the areas of workplace health and safety:
Providing safe and healthy working conditions for all employees in accordance with applicable law and other relevant industry standards.
Any adverse impact of our business processes on those who carry it out shall be identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.
We will provide adequate and appropriate labeling and storage of all chemicals and cleaning materials and adopt methods to protect employees from exposure to airborne particles and chemical fumes
Our review of our processes will use appropriate standards as required by prevailing laws, expert opinion, feedback from workers and our knowledge of best practices. The review will lead to formulation of clearly described work practices and safety drills and appropriate safeguards and isolation from mobile equipment. All our staff will be trained in the manner required to adhere to these work practices and drills.
Workers shall not be under the influence of or abusing, drugs, alcohol and/ or other illegal substances. We will seek to substitute the use of material, which are known to cause an adverse impact on the health of workers or health of consumers in the course of its use.
All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable. We will take adequate measures to safeguard our employees from fire and other workplace injuries.
All products sold by S A DIAMONDS to consumers shall comply with applicable regulations of product health and safety.

Policy Statement Environmental protection, Hazardous substances, waste and Emissions, Use of Energy and natural resources

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference:
S A DIAMONDS is committed to effective environmental performance and will focus on the following initiatives:
Conduct business in an environmentally responsible manner.
Compliance with all applicable environmental laws and regulations
The impact of our operations on the environment will be assessed and reviewed periodically to mitigate or eliminate such impact.
Disposal procedures for waste generated will be clearly defined and practiced in line with standards that are set by law.
Improvement of employee environmental awareness and performance through training.
Efficient use of energy and natural resources to minimize waste generation through efforts that include recycling and prevention of pollution.
Commitment to a continual improvement process in environmental management

Policy Statement of Human Rights

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference:

All employees in S A DIAMONDS will be treated with equality, respect and dignity.
S A DIAMONDS believes in and respects the fundamental human rights according to the United Nations Universal Declaration of Human Rights.
S A DIAMONDS will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation
S A DIAMONDS strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.
Any reported incidents relating to direct or indirect physical, sexual, racial, religious,
psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the Group.
Security personnel, if employed by S A DIAMONDS, are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat.

Policy Statement Bribery and Facilitation Payments

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference:
S A DIAMONDS is committed to prohibit bribery in all business practices and transactions that are carried out by the company or on its behalf by business partners. The company will not offer, accept or countenance any payments, gifts in kind, hospitality, expenses or promises as such that may compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with, or direct business to, any person; to influence the course of the business or governmental decision – making process.
S A DIAMONDS considers Bribery Risk as it applies to its organization (including agents) to identify which areas pose high risks. S A DIAMONDS has developed appropriate methods to monitor conduct of employees and agents and eliminate bribery based on this understanding.
The management of S A DIAMONDS facilitates the reporting of incidences of attempted bribery or inappropriate gifts within their organization and shall apply appropriate sanctions for bribery and attempted bribery in all forms.
S A DIAMONDS ensures that no employee will suffer demotion, penalty or other adverse consequences for voicing a concern, or for refusing to pay a bribe or facilitation payment even if this action may result in the enterprise losing business.

Policy Statement Product Security

S A DIAMONDS is committed to establish and implement product security measures within the premises and during shipments to protect against product theft, damage or substitution.
The security and well-being of employees, visitors and other relevant business partners is prioritized when establishing product security measures.

Policy Statement Money Laundering and Finance of terrorism

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS is presented below for reference:
S A DIAMONDS recognizes the fact that entities in the gems and jewelry sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
Strict compliance is required at all times, with all applicable national and, where appropriate, international laws / regulations with respect to money laundering, terrorism financing, bribery, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.
S A DIAMONDS shall act in accordance with national laws and national / international accounting standards with respect to maintaining financial accounts of all business transactions and auditing of its financial accounts.
S A DIAMONDS ensures that concerned employees know and understand the relevant regulatory jurisdiction for national and international transactions, money laundering / financial offences related legal, regulatory and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious activity that appears to be questionable may also be considered as a violation of the Business Policies, depending on the seriousness of the non-conformance.
S A DIAMONDS implements a “Know your Customer” and “Know your Supplier” procedure that establishes the identity of all organizations with which it deals, have a clear understanding of their business relationships and have a reasonable ability to identify and react to transaction patterns appearing out of the ordinary or suspicious.

Policy Statement Kimberley Process

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS is presented below for reference:

S A DIAMONDS is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and World Diamond Council’s (WDC) System of Warranties Declaration.

The definition of ‘Conflict Gem Stone Diamonds’ as agreed by the Kimberley Process will be adopted i.e.
“Rough diamonds used by rebel movements or their allies to finance conflict aimed at undermining legitimate Governments, as described in relevant United Nations Security Council (UNSC) resolutions in so far as they remain in effect, or in other similar UNSC resolutions which may be adopted in the future, and as understood and recognized in United Nations General Assembly (UNGA) Resolution 55/56, or in other similar UNGA resolutions which may be adopted in the future.”
Wherever applicable, the following affirmative statement as recommended by the World Diamond Council’s System of Warranties should be printed on all the invoices:
“The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict, in compliance with the United Nations resolutions and corresponding national laws. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WDC SoW Guidelines.”
Entering into transactions involving ‘conflict diamonds’ or not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, will be considered as a violation of the Business Policies.

S A DIAMONDS ensures that concerned personnel within the organization know about government restrictions on the trade in Conflict Diamonds, the Kimberley Process Certification Scheme and the World Diamond Council System of Warranties.

Policy Statement of Product Integrity and Disclosure

S A DIAMONDS is committed to complying with relevant trading standard legislation and specific national and local regulations applicable to its products.

The following essential Policies will be applicable in all transactions of S A DIAMONDS involving diamonds, treated diamonds, synthetics and stimulant

Disclosure – S A DIAMONDS shall fully and accurately disclose the material characteristic of their products. All reasonable efforts shall be made to properly disclose all relevant information on the physical characteristics, such as mass/weight, cut, cut, colour, clarity or fineness, of a diamond or gold jewellery product.

Misrepresentation – No untruthful, misleading or deceptive statement, “representation” or material omission in the “selling”, “advertising” or distribution of any diamond, treated diamond, synthetic, or simulant, or any gold product, shall be made by the Group and its entities in any medium, including the internet

Diamond Quality – The weight, colour, clarity or cut of diamonds will be described in accordance with the recognized guidelines appropriate to the particular jurisdiction.

Full disclosure i.e. the complete and total release of all available information about a Diamond and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the diamond.

No misuse of terminology or misrepresentations or attempts to disguise the product will be made in the selling, advertising and distribution of treated diamonds, synthetics and simulant.

The word ‘diamond’ will not be used in the case of names of firms, manufacturers or Trademarks, in connection with treated diamonds or diamond simulant or synthetic Diamonds.

S A DIAMONDS has adopted the following definitions:

Diamond: A diamond is a natural mineral consisting essentially of pure carbon crystallized with a cubic structure in the isometric system. Its hardness in the Mohs scale is 10; its specific gravity is approximately 3.52; it has a refractive index of 2.42 and it can be found in many colours.

Synthetic: A synthetic is any object or object that has been either partially or wholly crystallized or re-crystallized due to artificial human intervention such that, with the exception of being non-natural, the product meets the requirements specified in the definition of the word ‘diamond’ above.

Treated Diamond: A treated diamond is any object or product that meets the requirements specified in the definition of the words ‘diamond’ and ‘synthetic’ above, but has been subject to some form of treatment i.e. any process, enhancement changing, interfering with and/or contaminating the natural appearance or composition of a diamond other than historically accepted practices of cutting and polishing. This includes colour and decolourisation treatment, fracture filling, laser and irradiation treatment and coating.

Simulants: A diamond simulant is any object or product used to imitate some or all of the properties associated with a diamond and includes any material, which does not meet the requirements specified in the definition of the word ‘diamond’ above.

Policy Statement Community Engagement and Development

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference:
S A DIAMONDS is committed to the development of communities where it operates, contributing to their social and economic welfare.

Policy Statement Use of Security Personnel

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference:

Security personnel, if employed by S A DIAMONDS are trained to respect the human rights and dignity of all people and use of minimum force proportionate to the perceived threat.

Policy Statement Use of Supply Chain

The company shall complete the due diligence process prior to initiate business relationship. The company shall purchase/sale diamonds that are fully compliant with Kimberly Process Certification Scheme (KPCS).
The company shall ensure that all of its respective activities are in line with the OECD Due Diligence Guidelines, and as per Universal Declaration on Human Rights laid down by United Nations.
The company shall prohibit any procurement from Conflict-Affected & High-Risk areas and adhere to compliance with standards on Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT).
Relevant Employees shall be trained on the Supply Chain & Due Diligence Requirement and OECD guideline at regular interval. We shall also provide support to our business partners and stakeholder for the same.
The company shall carry out risk assessment for its supply chain and shall not enter into any business relationship or if may require then shall suspend/discontinue the engagement with any such supplier involved in dealing with Conflict-Affected and High-Risk areas, Any form of Human Right Violation; Torture, Cruel, In-Human and Degrading Treatment; Forced/Compulsory Labour; Child Labour; Abuses such as widespread Sexual Violence; War Crimes; other serious violations of International Humanitarian Law, Crime against Humanity; Genocide and/or To Bribe or To be Bribed. We strictly condemn and prohibit any Direct/Indirect support to public/private security forces which illegally Control, Tax or Extort money from Mining Sites, Transportation Routes and Upstream Sectors.
The company shall verify counterparty details, including the Know Your Customer (KYC) for any precious metals supplying Counterparties at regular interval. The company shall carry out risk-based assessment, set appropriate verification control and monitoring of all such commercial activities and transactions.
The company shall assign responsibility of Supply Chain Integrity and due diligence compliance to senior personnel of the organization to prevent any risk of illegal activities or breach of it. The company shall implement the management strategy to respond to identified risks. For the same, Compliance Officer shall report to Senior Management in case of any such violation of this policy.
The company has established a risk assessment module and any business partners with high risk rating shall be red flagged and report to be submitted to senior management.
Grievance Mechanism
The purpose of this document is to outline a process through which any stakeholder can understand due diligence and supply chain integrity policy of the organization. The identity of the person who so ever has registered a concern shall be kept confidential and no retaliatory action shall be taken against any whistle blower. For anonymous submissions, you may refrain to provide your contact information.
Please share your Complaint/Grievance/Suggestion

Policy Statement on Social Compliance

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference. We, S A DIAMONDS, accomplishment of Social compliance through below commitments:
Comply with legal and customer code of conduct requirements.
All employees will be treated with equality, respect and dignity.
Respecting employee’s freedom and not interfering their rights.
Prohibiting or not supporting the use of forced or compulsory labor in our products
Prohibiting the use of child labor in our products
Providing safe and healthy working environment.
Fulfilling basic needs by paying minimum wages. Ensure working hours continuously meets legal requirements. Promoting the regular employment to our employees
Adopting fair labor practice without any discrimination. Prohibiting the use of harsh or inhumane treatment in our products.
Promoting awareness to suppliers or sub-contractors to comply with Social Compliance requirements
Conduct business in an ethical and environmentally responsible manner.
Ensuring development of communities where it operates, contributing to their social and economic welfare.
Constantly endeavor for continual improvements in Social Compliance Management System

This policy has been reviewed annually for continual improvement.
The copy of this policy is available for the entire visitor / public / interested parties’ reference.

Bio-Diversity Policy

Certainly, here’s a biodiversity policy that could be tailored for S A DIAMONDS:
Commitment: S A DIAMONDS is committed to protecting and conserving biodiversity in all of its business operations. We recognize that biodiversity is essential for maintaining healthy ecosystems and supporting the natural resources that our business relies on.
Compliance: S A DIAMONDS will comply with all applicable laws and regulations related to biodiversity conservation, as well as any voluntary commitments that we make related to
Impact Assessment: Before undertaking any new business activities, S A DIAMONDS will assess the potential impact of the activity on biodiversity. This assessment will be used to identify potential risks and develop appropriate measures to mitigate these
Habitat Protection: S A DIAMONDS will take appropriate measures to protect and conserve habitats that are critical for biodiversity conservation. This may include avoiding activities that damage critical habitats, implementing restoration measures to improve degraded habitats, and supporting conservation efforts that protect
Species Protection: S A DIAMONDS will take appropriate measures to protect and conserve species that are important for biodiversity This may include avoiding activities that harm species, supporting conservation efforts that protect species, and implementing measures to mitigate the impacts of business activities on species.
Stakeholder Engagement: S A DIAMONDS will engage with stakeholders, including local communities, conservation organizations, and government agencies, to ensure that our biodiversity conservation efforts are effective and responsive to local
Continuous Improvement: S A DIAMONDS will continually review and improve its biodiversity conservation efforts to ensure that we are meeting our commitments and making a positive impact on biodiversity.
By implementing a comprehensive biodiversity policy, S A DIAMONDS can ensure that its business operations are conducted in a manner that is environmentally sustainable and respectful of the natural resources that we depend on.

Policy Statement on Right of Land

The policies relating to this section are part of the Business Policies adopted by S A DIAMONDS and are presented below for reference:
Purpose:
This policy is to ensure the Right of the land of any individual or Society at large while purchasing or acquiring land for the activity related to our production. This shall be communicated and ensured throughout our supplier chain.
Our organization will follow all applicable national laws and respect international human rights standards relating to the Rights to Land and Natural Resources.
Organization shall not involve, encourage or support any form of coercion, intimidation or manipulation in the acquisition of land for the establishment of the business or in its expansion activities.
Organization respects the right of indigenous peoples who have the right to the lands, territories and resources. Also, we support the principles contained within the United Nations Declaration on the Rights of Indigenous Peoples.
We are committed to follow Free Prior Informed consent (FPIC) So that, Indigenous people participation and consultation always there in decision making process.
Our organizational activity shall not become a reason for obviously affecting the rights of housing, food, or water for any people or society at large.
Prior to commencing any operation in the hired or rented lands, consent will be sought sufficiently in advance for any authorization from the existing land owner.
Organization will not tolerate any Gender discrimination in the land purchase or hiring activities among those who have the right of the land through inheritance, purchase, occupied, otherwise used.
Our organization is strictlyrefrainingfrom any kinds of forced evictions. We will provide and ensure fair and prompt compensation for any loss of revenue, real or other property or goods, including rights or interests in the property.
Our organization mitigate adverse social and economic impacts from land acquisition or restrictions on affected persons use of land by: (i) providing compensation for loss of assets at replacement cost; and (ii) ensuring that resettlement activities are implemented with appropriate disclosure of information, consultation, and the informed participation of those affected.
Our organization aims to improve or at least restore the livelihoods and standards of living of displaced persons as per IFC performance standard “Land Acquisition and Involuntary Resettlement”.

Data Privacy Policy

Certainly, here’s a data privacy policy that could be tailored for S A DIAMONDS:
Collection and Use of Personal Data: S A DIAMONDS will only collect personal data that is relevant to the business purposes for which it is needed. Personal data may include names, addresses, phone numbers, email addresses, and other data necessary to fulfill business transactions. The data will be used for the purposes it was collected for, and will not be disclosed to third parties unless necessary for the business purpose or required by law.
Data Protection Measures: S A DIAMONDS will implement appropriate technical and organizational measures to protect personal data from unauthorized access, use, or disclosure. These measures may include encryption, access controls, and regular security audits.
Data Retention: Personal data will only be retained for as long as necessary to fulfill the business purpose for which it was collected, unless there is a legal or regulatory requirement to retain it for a longer period.
Data Subject Rights: Individuals have the right to know what personal data is being collected, how it is being used, and to request that the data be corrected, updated, or deleted. S A DIAMONDS will respond to these requests in a timely manner and in accordance with applicable laws.
Data Breach Response: In the event of a data breach, S A DIAMONDS will take immediate steps to mitigate the impact of the breach and notify affected individuals and authorities as required by applicable laws.
Employee Training: Employees who handle personal data will receive training on data privacy and security policies and procedures to ensure they understand their responsibilities and obligations.
Third-Party Service Providers: S A DIAMONDS may use third-party service providers that process personal data on its behalf. S A DIAMONDS will only engage with service providers who have appropriate data protection measures in place.
By implementing a comprehensive data privacy policy, S A DIAMONDS can ensure that personal data is collected, processed, and stored in a responsible and secure manner, and that the privacy rights of individuals are respected.

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