A. Of Custody - Responsible Jewellery Council

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RJC Chain‐of‐Custody (CoC) Certification for the diamond, gold and platinumjewellery supply chainCoC Standards Guidance – Draft 4 for commentIntroductiona. Introducing Chain‐of‐CustodyThe Responsible Jewellery Council (RJC) has developed Chain‐of‐Custody (CoC) Certification tosupport businesses which wish to provide their customers and stakeholders with independentassurance about conflict‐free, responsible sourcing.Box 1: At a GlanceA ‘Chain‐of‐Custody’ is a documented sequence ofcustody of material as it is transferred along thesupply chain. Chain‐of‐Custody systems canprovide an important point of differentiation andconfidence in the business practices involved inproduction. Certification of those systems providesrecognisable assurance to customers, consumersand stakeholders against a known standard. Thiscan add value to jewellery products and helpprotect and enhance jewellery brands.Depending on the type of business, CoC Certificationmay be of interest to:CoC Certification: Voluntary Requires RJC Membership to supportresponsible business practices in the supplychain Requires independent, third party auditing Controls for responsible sources of diamonds,gold and platinum group metals (platinum,palladium, rhodium) Supports implementation of Dodd‐FrankConflict Minerals legislation Support responsible mining practices Source legitimate recycled materials Identify the provenance of jewellery materials Avoid ‘conflict’ resources implicated in human rights abuses, illegal or criminal practices Enhance reputation through responsible sourcing Carry out due diligence of the supply chain

Draft 4 for comment – December 2011 2Respond to the requests of customers, both business to business and retail.CoC Certification is voluntary for RJC Members. While RJC Member Certification against the Code ofPractices is compulsory for businesses which choose to join the RJC, CoC Certification is optional forRJC Members because of the need for compliance with anti‐trust laws.b. Key elements of the CoC StandardThe CoC Standard establishes requirements for the Chain‐of‐Custody of Materials, and forconfirming that CoC Materials are only from known sources that are responsible and Conflict‐Free.The key elements of the CoC Standard therefore include systems for: material segregation, materialtransfers, document controls, and controls for responsible and ‐conflict‐sensitive sourcing.Requirements for each of these elements are found in different Provisions of the Standard, as shownin the following table.Table 1 – CoC Standard Provisions, by key elementMaterialSegregationCoC stems toConfirmEligibility ofMaterialIssuing sible,Conflict‐SensitiveSourcing1. ManagementSystems2. Internal MaterialControls3. OutsourcingContractors4. Eligible MinedMaterials5. Eligible RecycledMaterials6. EligibleGrandfatheredMaterials7. Eligible MaterialsDeclarations8. CoC TransferDocuments9. Consumer Claimsand IP10.1, 10.2 Supply chainpolicy10.3 ComplaintsMechanism10.4 Gold Refinerswww.responsiblejewellery.comThe Responsible Jewellery Council is the trading name of the Council for Responsible Jewellery Practices Ltd.The Council for Responsible Jewellery Practices Ltd, First Floor, Dudley House, 34‐38 Southampton Street, London, UK, WC2E 7HF.The Council for Responsible Jewellery Practices Ltd is registered in England and Wales with company number 05449042.

Draft 4 for comment – December 20113c. Eligibility of Material for Chain‐of‐CustodyThe CoC Standard sets out the management systems required to confirm that Material (Diamonds,Gold and Platinum Group Metals) can be declared as Eligible Material. Once Material is declared asEligible Material, it can it be processed and transferred as CoC Material.Figure 1 – Screening and Flow of CoC Materiald. Application of Provisions to different types of businessesThe following table provides a breakdown of the required, optional (where applicable) and non‐applicable provisions of the CoC Standard according to the type of business. This breakdown is notdefinitive, and exceptions may occur. The Entity’s Certification Scope will define which provisionsshall apply to the Entity seeking Certification.www.responsiblejewellery.comThe Responsible Jewellery Council is the trading name of the Council for Responsible Jewellery Practices Ltd.The Council for Responsible Jewellery Practices Ltd, First Floor, Dudley House, 34‐38 Southampton Street, London, UK, WC2E 7HF.The Council for Responsible Jewellery Practices Ltd is registered in England and Wales with company number 05449042.

Draft 4 for comment – December 20114Table 2 – Application of CoC Standard Provisions by SectorCoC stems toConfirmEligibility ofMaterialIssuing ners1. ManagementSystemsRequired2. Internal MaterialControls3. OutsourcingContractors4. Eligible MinedMaterials5. Eligible RecycledMaterials6. EligibleGrandfatheredMaterials7. Eligible MaterialsDeclarations8. CoC TransferDocuments9. Consumer Claimsand IP10.1 Supply chain policyRequired10.2 Policy non‐compliance10.3 ComplaintsMechanism10.4 Gold RefinersIf applicableRequiredNot applicableNot applicableRequiredNot applicableIf applicableIf applicableRequiredIf applicableRequiredIf applicableRequiredIf applicableRequiredRequiredNot applicableRequiredNot applicablewww.responsiblejewellery.comThe Responsible Jewellery Council is the trading name of the Council for Responsible Jewellery Practices Ltd.The Council for Responsible Jewellery Practices Ltd, First Floor, Dudley House, 34‐38 Southampton Street, London, UK, WC2E 7HF.The Council for Responsible Jewellery Practices Ltd is registered in England and Wales with company number 05449042.

Draft 4 for comment – December 20115Standards GuidanceThis GuidanceThe RJC CoC Standard outlines the requirements for CoC Certification. This CoC Standards Guidancehas been developed as a resource to assist RJC Members seeking CoC Certification, and for Auditorscarrying out independent third party audits. It is also available to businesses in the jewellery supplychain and stakeholders who wish to learn more about establishing Chain‐of‐Custody systems and theRJC’s standards.The RJC CoC Standard is structured into four sections. The first three set the basic framework formanaging robust Chain‐of‐Custody systems, while the fourth addresses additional conditions tosupport Conflict‐Sensitive sourcing.A. Provisions 1 – 3. Chain‐of‐Custody Management: Management system and responsibilities;Internal material controls; Outsourcing contractors and service companies.B. Provisions 4 – 6. Systems to Confirm Eligibility of Material: Eligible Mined Material; EligibleRecycled Material; Eligible Grandfathered Material.C. Provisions 7 – 9. Issuing Chain‐of‐Custody Documentation: Eligible Material Declarations;CoC Transfer Documents; Consumer claims.D. Provision 10. Conflict‐Sensitive Sourcing: Supply chain policy; Complaints Mechanism; GoldRefiners.The CoC Standards Guidance is similarly organised to address each of the above sections, providinggeneral guidance to businesses wishing to implement systems and procedures that can comply withthe RJC CoC Standard.Like the RJC’s Code of Practices, the CoC Standard sets out requirements for what a business mustbe able to do, but does not generally prescribe how systems and procedures are designed. The CoCStandards Guidance therefore offers general guidance only and is non‐prescriptive. The RJC CoCStandard is the final point of reference.www.responsiblejewellery.comThe Responsible Jewellery Council is the trading name of the Council for Responsible Jewellery Practices Ltd.The Council for Responsible Jewellery Practices Ltd, First Floor, Dudley House, 34‐38 Southampton Street, London, UK, WC2E 7HF.The Council for Responsible Jewellery Practices Ltd is registered in England and Wales with company number 05449042.

Draft 4 for comment – December 20116A. Chain‐of‐Custody Management1. Management system and responsibilitiesBackgroundThe CoC Standard begins with the requirement that a Member/Entity must have a ManagementSystem in place to address all applicable parts of the Standard, in all Facilities which have Custody ofCoC Material. A Management System is defined as:Management processes and documentation that collectively prove a systematic frameworkfor ensuring that tasks are performed correctly, consistently and effectively to achieve thedesired outcomes, and to drive continual improvement in performance.In basic terms, a Management System is made up of three elements – people, process, andpaperwork ‐ that interact with each other, as shown in the following diagram:Figure 2 – Management systems componentswww.responsiblejewellery.comThe Responsible Jewellery Council is the trading name of the Council for Responsible Jewellery Practices Ltd.The Council for Responsible Jewellery Practices Ltd, First Floor, Dudley House, 34‐38 Southampton Street, London, UK, WC2E 7HF.The Council for Responsible Jewellery Practices Ltd is registered in England and Wales with company number 05449042.

Draft 4 for comment – December 20117For a Management System to work effectively: people must be trained, competent, and understandtheir responsibilities; processes must be established to define what tasks and work activities need tobe carried; and paperwork is required to ensure consistency, measure results, and maintain records.ImplementationExample: Managing CoC DiamondsManagement Systems can take many differentforms, depending on the nature and scale of thebusiness, the level of automation and use ofinformation technology, the types of Materialshandled, the points where Material couldbecome mixed, etc. For example, aManagement System necessary for segregationof CoC Material from non‐CoC Material will lookvery different at a mine site from that for a smallretail business. However, in each case an auditorwill look to verify that the Management System– in the form of people, processes and relevantpaperwork – can fulfil the requirements of theStandard.To recommend CoC Certification, an auditorwould typically look for the following generaltypes of objective evidence of conformance: A diamond cutting and polishing Facility is likely to sourceboth CoC and non‐CoC diamonds. To achieve CoCCertification, the Facility’s management system will needto be able support a chain‐of‐custody approach. To putthis in place, the Facility could take the following generalsteps: Designate a responsible manager to oversee CoCsystems and the responsibilities of relevant staff Establish or adapt internal systems so that they cantrack all CoC Materials in Custody Identify all points in the Facility where there is a riskof Eligible and/or CoC Diamonds becoming mixedwith non‐Eligible and/or non‐CoC Diamonds and putcontrols in place to ensure segregation Consider other risks of mixing and take steps toaddress them Put procedures in place and communicate them toall relevant staff Keep records that can verify CoC claims and that canshow that the controls are effective.Efforts to identify and control risks of non‐conformance (1.1)Adequate resources (financial, human, equipment, information technology, etc.) to carry outthe relevant tasks and activities (1.1)Policies and procedures (which may or may not be documented) that are understood andconsistently followed (1.1)Clear designation of a responsible manager (1.2)Training of relevant staff and communication processes to ensure critical informationreaches relevant customers and suppliers (1.3)CoC records and documentation to support all applicable parts of the Standard and retainedfor at least 5 years (1.4)Systems to verify CoC Transfer Documents the business has issued (1.5)RJC Membership status (1.6).Getting startedWhere possible, consider embedding the management requirements of the CoC Standard into thebusiness’ existing management systems as this will be more efficient and help implementation.More specific guidance on sections 2‐10 of the CoC Standard can be found in the subsequentsections.www.responsiblejewellery.comThe Responsible Jewellery Council is the trading name of the Council for Responsible Jewellery Practices Ltd.The Council for Responsible Jewellery Practices Ltd, First Floor, Dudley House, 34‐38 Southampton Street, London, UK, WC2E 7HF.The Council for Responsible Jewellery Practices Ltd is registered in England and Wales with company number 05449042.

Draft 4 for comment – December 20118Review: Entities seeking CoC Certification must ensure an effective Management System is in place tomeet each of the applicable requirements of the CoC Standard. How each Entity’s management system is designed will be different, depending on the nature oftheir business. The three main dimensions of management systems are people, processes and paperwork.Check:9 Who has overall responsibility for implementing and maintaining CoC systems?9 Are all relevant staff trained and aware of they what they need to do with CoC Material?9 Is there a record‐keeping system that will enable the business to respond to requests for moreinformation on CoC Material it has transferred?2. Internal Material ControlsBackgroundThe CoC Standard supports the “Bulk Commodity” Chain‐of‐Custody model, which prevents themixing of Eligible Material with non‐eligible Material but does not require tracing to origin. The CoCStandard can also support a “Track and Trace” model, which does trace to origin. 1 Businesses candecide how they wish to use the CoC Standard to support either or both of these models.Both models are underpinned by internal Material controls that provide for the segregation ofmaterial that is eligible for inclusion in the Chain‐of‐Custody, from Material that is not Eligible. Thisis the essence of a “Bulk Commodity” model. However the same controls could also be applied, ifdesired, to prevent the mixing of Eligible/CoC Material with certain characteristics, such as origin,with Eligible/CoC Material that does not have those characteristics. This represents a “Track andTrace” model.A Chain‐of‐Custody is managed through a business’ internal control of the material it sources andsupplies. Where a business has both CoC and non‐CoC Material, the key internal controls involvetracking individual, physically separated lots or parcels of CoC Material that are assigned uniqueidentification numbers. Many businesses in the jewellery supply chain already have systems in placethat record most or all of this information. These are used to facilitate effective inventorymanagement and work flow, and support the business’s financial accounting system. In many cases,such inventory systems can be readily adapted for CoC Material controls.Implementation1See RJC CoC Discussion Paper 1 for more discussion of these models, and examples of their use:http://www.responsiblejewellery.com/files/RJC Chain custody discn paper 19 04 2010.pdfwww.responsiblejewellery.comThe Responsible Jewellery Council is the trading name of the Council for Responsible Jewellery Practices Ltd.The Council for Responsible Jewellery Practices Ltd, First Floor, Dudley House, 34‐38 Southampton Street, London, UK, WC2E 7HF.The Council for Responsible Jewellery Practices Ltd is registered in England and Wales with company number 05449042.

Draft 4 for comment – December 20119The simplest situation for a business is to source and/or supply only CoC Material. This would not beunusual for mines, for example, where CoC Certified mines could sell all of their Eligible productionas CoC Material. However, businesses further downstream in the supply chain frequently havemultiple suppliers and complex supply chains. Therefore most businesses in the Jewellery supplychain seeking to transition to CoC Materials will need to manage both CoC and non‐CoC Material intheir custody. The CoC Standard requires CoC and non‐CoC Material to be kept segregated, if anyCoC claims are to be passed onto another Entity orBox 3: Segregation in refineriesconsumer.Internal controls to prevent any mixing of CoCMaterial with non‐CoC Material (provision 2.1) maybe provided through: physical measures, such as separateprocessing lines, identification andinventory storage, to differentiate CoC andnon‐CoC Materials handled in the sameFacility at the same time. temporal measures, such as batchprocessing on the same process line orworkspace, to allow CoC Material to beseparately handled and processed atcertain periods of time.Note that components of a Jewellery Product caninclude CoC and non‐CoC Material, as long as theCoC components are separately identifiable. Anynon‐CoC Material must be recorded and accuratelydescribed in the CoC Transfer Document for theJewellery Products. For example, a Gold chain witha Gold pendant, could be comprised of a CoC Goldchain with a non‐CoC Gold pendant. In this case,the separate components are physicallyidentifiable. However CoC and non‐CoC Gold couldnot be mixed to cast a ring, for example, as the twosources can no longer be differentiated.In addition to physical and/or temporal controls,tracking of CoC Material in the Custody of an Entityshould be supported by record‐keeping orinventory management. Inventory records shouldbe maintained that can uniquely identify discreteIndustrial scale gold and platinum group metals refininguse complex production lines and metallurgical processesto produce high purity metal. Refiners will play a key rolein the supply of CoC precious metals to the jewellerysupply chain. Under the RJC CoC Standard, refiners mustimplement conflict‐sensitive sourcing practices for allsources of gold, such as is outlined in the OECD DueDiligence Guidance for Responsible Supply Chains ofMinerals from Conflict Affected and High Risk Areas (seeCoC provision 10).Refiners regularly source and mix mined, recyclable andgrandfathered metals. Working with CoC and non‐CoCsources may thus present unique challenges insegregation. One way to minimize these challenges is tosegregate by batch, using the same equipment for CoCand non‐CoC materials, but at different times. This canreduce segregation costs, as long as the changeover fromnon‐CoC to CoC is not unreasonably difficult.To facilitate that changeover, the RJC will allow minormixing that might occur between separate batches,such as of process residues in crucibles or intermediateprocess fluids. For example, electrolytic gold refining isused to produce 999.9 fineness. Anodes cast fromimpure gold are immersed in a gold‐bearing electrolyte inan electrolytic cell, usually for several days. The anodesdissolve into the electrolyte and high‐purity gold isdeposited on cathodes, which are then pulled from thecell and their gold recovered at the end of the process.The electrolyte can be re‐used, but will contain some goldfrom the past batch. A complete change of reusableelectrolyte between non‐CoC and CoC material would betime‐consuming, expensive and wasteful, and the RJCbelieves that this minimum amount of mixing does notdefeat the goals or purposes of the CoC Standard.Accordingly the RJC will permit the same electrolyte to beused for both CoC and non‐CoC batch refining. This aimsto minimise unnecessary refining costs in the productionof CoC gold.www.responsiblejewellery.comThe Responsible Jewellery Council is the trading name of the Council for Responsible Jewellery Practices Ltd.The Council for Responsible Jewellery Practices Ltd, First Floor, Dudley House, 34‐38 Southampton Street, London, UK, WC2E 7HF.The Council for Responsible Jewellery Practices Ltd is registered in England and Wales with company number 05449042.

Draft 4 for comment – December 201110physical lots, batches, components or parcels, with an accurate weight recorded for each lot orparcel. For businesses using continuou

The Responsible Jewellery Council is the trading name of the Council for Responsible Jewellery Practices Ltd. The Council for Responsible Jewellery Practices Ltd, First Floor, Dudley House, 34‐38 Southampton Street, London, UK, WC2E 7HF.

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