Business Policy

1.    Legislation and Regulations

a.     STECKBECK JEWELERY PVT. LTD. shall operate in compliance with relevant national and international legislations / regulations as applicable in the countries in which they operate.

b.     All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal STECKBECK JEWELERY PVT. LTD. rules and policies relating to their business activities.

c.     It is the responsibility of personnel to know and understand legal, regulatory and internal requirements as they apply to their jobs.

d.     Compliance team maintains the list of applicable legal and regulatory requirements and same is followed for compliance on day-to-day basis. Necessary records of requirements and its compliance is maintained.

2.    Money Laundering, Terrorism Financing, Other Financial Offences

a.     STECKBECK JEWELERY PVT. LTD. recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.

b.     STECKBECK JEWELERY PVT. LTD. shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations. Following acts and international guidelines is considered while establishing company level policies

·         Prevention of Money laundering Act 2002

·         FATF 40 Recommendations and 8 special recommendations

c.     It is the responsibility of concerned personnel to know and understand the relevant 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 Principles, depending on the seriousness of the non-conformance.

d.     Compliance officer ensure all the critical steps such as KYC & KYS, Identification of suspicious transaction, reporting to management and record keeping as required by the local act and legislations are complied with.

e.     Compliance officer caries out periodic review of AML/CFT compliances and submits his report to management on Quarterly basis.

3.    Kimberley Process and System of Warranties

a.     STECKBECK JEWELERY PVT. LTD. is dealing in polished diamonds and fully committed to complying with all the requirements specified in World Diamond Council’s (WDC) System of Warranties Declaration.

b.     We will not engage in business with the supply chain who deals in ‘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 Principles.

4.    Anti-Bribery and Facilitation Payment Policy:

a.     The STECKBECK JEWELERY PVT. LTD. shall ensure complete prohibition of Bribery and facilitation payment across organization and in all the entities.

b.     STECKBECK JEWELERY PVT. LTD. will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.

c.     Entity shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.

5.    Disclosure of Treated Diamonds, Synthetics and Stimulant

The following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and stimulant

§  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.

§  We deal in real and natural diamonds only and any treatment of real and natural diamonds is disclose to customer prior to sales

6.    Diamond & Gemstone Sourcing Policy:

Conflict Minerals Policy Statement (Diamond & Gem Stone) 

STECKBECK JEWELERY PVT. LTD. is committed to being a responsible corporate citizen and is opposed to human rights abuses.  As part of that commitment, STECKBECK JEWELERY PVT. LTD. seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility.

STECKBECK JEWELERY PVT. LTD. shall strive to ensure that all its supply of diamonds are not originating from CAHRA’s and where practically possible origin of diamonds is known to us.

What Are “Conflict Diamonds”? 

Blood Diamonds, also known as “Conflict Diamonds” are stones that are produced in areas controlled by rebel forces that are opposed to internationally recognized governments. The rebels sell these diamonds, and the money is used to purchase arms or to fund their military actions.

Blood Diamonds are often produced through the forced labor of men, women and children. They are also stolen during shipment or seized by attacking the mining operations of legitimate producers. These attacks can be on the scale of a large military operation.

The stones are then smuggled into the international diamond trade and sold as legitimate gems. These diamonds are often the main source of funding for the rebels; however, arms merchants, smugglers, and dishonest diamond traders enable their actions. Enormous amounts of money are at stake, and bribes, threats, torture, and murder are modes of operation. This is why the term “blood diamonds” is used.

CAHRAs are. 

Angola ,Coast, Democratic Republic of the Congo ,Liberia, Sierra Leone, Republic of the Congo & Zimbabwe Marange Diamond Fields   

STECKBECK JEWELERY PVT. LTD. shall ensure that none of its supplies are coming from above sources. Sight Holder shall communicate its sourcing policy to all the stakeholders and will ensure effective implementation among them.

7.    Gold & Platinum Group Of Metal Sourcing Policy:

Our Company is concerned about environment and social impacts of irresponsible mining.

We at STECKBECK JEWELERY PVT. LTD. shall ensure that all our gold suppliers are in compliance with gold souring guidelines (Dodd- Frank rules, DRC & other applicable legislation).

Further, we are committed to ensure that sourcing of gold and precious metal products and articles thereof, are under the highest Social, Human right and Environmental standard cautions of trade.

8.    Supply Chain Management / Best Endeavours

The management of STECKBECK JEWELERY PVT. LTD. is committed to take appropriate action to use best endeavours to ensure that the suppliers and contractors are committed for compliance to International Social Standards such as RJC & SMETA etc.

9.    Employment

a.     Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.

b.     The STECKBECK JEWELERY PVT. LTD. shall not require Staff  to work for more than  the national limit of hours  in a week  on a regular basis.

c.     The STECKBECK JEWELERY PVT. LTD. shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards.

10.  Health and Safety

STECKBECK JEWELERY PVT. LTD. recognizes the need to develop a sustainable, value creating business and is committed to the following:

§  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.

§  This review will use appropriate standards as required by prevailing laws, expert opinion and our knowledge of best practices.

§  The review will lead to formulation of clearly described work practices and drills.

§  All our staff will be trained in the manner required to adhere to these work practices and drills.

§  All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable

11.  Non Discrimination, Disciplinary Practices

a.     Discrimination can mean distinction, exclusion or preference.

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

c.     We shall at no time condone the use of corporal punishment or other forms of mental or physical coercion.

d.     We encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, STECKBECK JEWELERY PVT. LTD. operation or practice is or will likely be in violation of any law, regulation or internal rule or policy, including this Business Principles.

12.  Child Labour

a.     No form of child labour should be employed at any of the facilities of the STECKBECK JEWELERY PVT. LTD. Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).

b.     For authorized adolescents (persons below 18 years of age but above 15 years), the STECKBECK JEWELERY PVT. LTD. Management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.

c.     As per our STECKBECK JEWELERY PVT. LTD. policy no child labour or adolence child labour will be employed.

d.     STECKBECK JEWELERY PVT. LTD. will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

13.  Forced Labour

a.     The management of STECKBECK JEWELERY PVT. LTD. is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of this Business Principles.

b.     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 they said person has not offered himself voluntarily”

14.  Human Rights

–  All employees in the STECKBECK JEWELERY PVT. LTD. facilities will be treated with equality, respect and dignity.

–  STECKBECK JEWELERY PVT. LTD. 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

–  The STECKBECK JEWELERY PVT. LTD. strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.

15.  Environment Protection

STECKBECK JEWELERY PVT. LTD. is committed to effective environmental management as one of its important corporate priorities, and will focus on the following initiatives:

·         Compliance with all applicable environmental laws and regulations

·         The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards 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 and best practices of the industry.

·         Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.

16.  Product Security

STECKBECK JEWELERY PVT. LTD. is committed to provide safety of product throughout its supply chain by following precaution as mentioned below

·         Each and every stage of product processing it is covered through blanket insurance

·         Suitable safe guarding and storage is ensured at all stage with the help of safes

·         We are taking at most care to ensure safety of visitors, Customers and interested parties, suitable arrangements such as CCTV, Multi level entry doors and other electronic intelligence.

·         All the concern persons are trained on relevant safety and security procedures to be followed at all time.

Public Grievances against social & Ethical compliance of the STECKBECK JEWELERY PVT. LTD.

If you come across any instance of non compliance or specific deviation from our ethical policy , please feel free to reach us.

Further in case if you are interested to obtained the copy of our sourcing annual compliance report based on OECD guidelines. Please send an email communication to below mentioned email address.