Signet Responsible Sourcing Protocol (SRSP) 2019 ......• Signet has produced global guidance for...

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Signet Responsible Sourcing Protocol (SRSP) 2019 Compliance Reporting A Summary for Suppliers September 25, 2019 Confidential and Proprietary Property of Signet Jewelers

Transcript of Signet Responsible Sourcing Protocol (SRSP) 2019 ......• Signet has produced global guidance for...

Page 1: Signet Responsible Sourcing Protocol (SRSP) 2019 ......• Signet has produced global guidance for all suppliers of gold, tin, tungsten, tantalum (“3TG”) since 2013, diamonds in

Signet Responsible Sourcing Protocol (SRSP)2019 Compliance Reporting

• A Summary for Suppliers

• September 25, 2019

Confidential and Proprietary Property of Signet Jewelers

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Today’s Agenda

• Signet Responsible Sourcing Overview

• New Signet Responsible Sourcing Website

• Annual SRSP Compliance Reporting

– 2019 Warranty Statement Update

• SRSP Diamond Appendix

• SRSP Colored Gemstones Appendix

• Signet SRSP Audits - RJC Certification

• Responsible Jewellery Council

• Q&As

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• The objective of Signet’s Responsible Sourcing program is to ensure all Signet jewelry materials are responsibly sourced as defined by reference to the OECD Due Diligence Guidance (DDG) for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas.

Signet Responsible Sourcing

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• Signet has produced global guidance for all suppliers of gold, tin, tungsten, tantalum (“3TG”) since 2013, diamonds in 2017, and Silver and Platinum Group Metals (PGMs) from 2018.

• For 2019, the SRSP appendix for Colored Gemstones is included, which Suppliers are required to understand and acknowledge in 2019.

• Compliance with the SRSP for Colored Gemstones will be required in 2020.

• Irrespective of any future changes to the U.S. “Dodd-Frank” Act, Signet will maintain its commitment to responsible sourcing.

Compliance with the Signet Responsible Sourcing Protocol (SRSP)

Signet Responsible Sourcing

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Timeline of Development and Implementation

OECD Due Diligence Guidance – Applicable to All Minerals

Signet Responsible Sourcing Protocol (SRSP)

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2010 (July) Dodd-Frank

Wall Street Reform and

Consumer Protection Act

(Section 1502)

2011 2012 2013 2014 2015 2016 2017 2018

Diamonds

D-SRSP

2019 2020

Signet Jewelers – conducts 3 years

rigorous 3TG supply chain

due diligence

Silver & PGMsColored Gemstones

Appendix

Gold and 3Ts

SRSPs

2010

Legal Imperative

Formation of RJC

2005

Consolidated SRSP

With Appendices for

Gold, 3Ts, Diamonds,

Silver/PGMs, and

Human Rights

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Compliance with Signet’s Responsible Sourcing Protocol (SRSP) –Guideline

SRSP compliance criteria and requirements, include but are not limited to:

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Signet Responsible Sourcing Website• Signet is pleased to introduce a new re-designed modern

update to its Signet’s Responsible Sourcing website, signetresponsiblesourcing.com.

• The public “Resource Library” contains all relevant Signet Responsible Sourcing documents, webinars and training materials, as well as information on the Responsible Jewellery Council (RJC).

After your supplier log-in;

• “SRSP Report” will be where you access your SRSP compliance report.

• Under “FAQ” you’ll find a list of frequently asked SRSP-related questions.

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• Under the public “Resource Library,” you will find key resources for online viewing or downloading:

– Resource Overview

– SRSP Toolkit (includes 2019 SRSP, audit guidance, copy of this webinar).

– Responsible Jewellery Council information

The Resource Library:

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Signet Responsible Sourcing Website

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Signet Responsible Sourcing Website

• At the start of the SRSP report program (first week October), you will receive an e-mail notification from [email protected] to reset your password. Once you have established your password, you can login to complete your SRSP Report.

• On the “Edit Account Settings” page, you can view your primary account settings, request a “reset of your password,” or notify us of an update required to your vendor assignments, via the “request information edit” link.

Signet Supplier Access:

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Annual SRSP Compliance Reporting

• All Signet suppliers will be notified by email in the first week of October to complete the SRSP compliance report, available at signetresponsiblesourcing.com.

• Suppliers report compliance for the metals or minerals (Gold, 3Ts, Diamonds, and Silver / PGMs) they supply to Signet, covering the current calendar year.

• SRSP compliance reports must be completed every year to meet Signet’s due diligence and legal requirements.

• Online Compliance Reporting should be completed by the end of October 2019.

Timing and Process:

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Annual SRSP Compliance Reporting

• You must be familiar with the SRSP, its due diligence requirements, the appendices for Gold, 3Ts, Diamonds, Silver, PGMs and Human Rights to complete the SRSP report.

• Once logged in to the SRSP Report, select the Vendor Number(s) the reportis being completed for (Individual or multiple selections apply).

SRSP Compliance Report Guidance:

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Annual SRSP Compliance Reporting

• Suppliers identify the metals or minerals (Gold, 3Ts, Diamonds, Silver / PGMs) they supply to Signet, covering the current calendar year.

• If Gold, 3Ts, Diamonds, Silver or any of the PGMs are selected, you will be required to confirm whether you are “compliant” or “not compliant” with the protocol.

• If you report compliance with SRSP, you will need to identify your sources of supply, which should apply to all of your supply chain.

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SRSP Compliance Report Guidance:

Does your company currently supply or plan to supply products of any kind containing gold to Signet Jewelers' business units located in the USA, UK and Canada?

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Annual SRSP Compliance Reporting

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SRSP Compliance Report Guidance:

• For the minerals (gold, 3Ts, diamonds, silver, PGMs) you supply to Signet, you must select what supporting documentation you have toverify your claims, i.e.,:

o policies and/or terms of business and

o transaction documents such as invoices, delivery notes which demonstrate that these policies have been implemented.

Please note: If an independent third party audit of your SRSP report is requested, you will need supporting documentation to verify your claims with the auditor:

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• For diamond suppliers:

o Identify the category or categories your company supplies to Signet.

o If you source diamonds from Category 3 (Mixed Sources), you will need to state the percentage derived from identified sources and have a management process in place to demonstrate continuous improvement in the percentage of identified sources over time.

o Confirm you follow the requirements of the SRSP Diamond Appendix and have established processes and procedures to detect lab-grown diamonds.

Annual SRSP Compliance ReportingSRSP Compliance Report Guidance:

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7.04 Diamond Categories - Please select which category or categories of diamonds your company supplies to Signet. (Please select all that apply) • Category 1 (Single Stone Tracking)? Individual diamonds supplied by

or sourced from identified diamond producers which are independently certified under separate, relevant international standards (such as the RJC Code of Practices).

• Category 2 (Parcel Tracking)? Parcels of diamonds supplied by or sourced from identified diamond producers which are independently certified under separate, relevant international standards (such as the RJC Code of Practices

• Category 3 (Mixed Sources)? Diamonds are derived from a number of sources, with some percentage of the diamonds deriving from a known, identified and verified source.

• Category 4 (Other Identified & Verified Sources)? Diamonds deriving from small-scale or artisanal producers0

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• The SRSP Compliance Report includes a Grievanceand RJC Membership status sections. Suppliers can add any additional comments, grievances, or identify risks within their or others supply chains to Signet.

• Suppliers are asked about their current RJC status, if a Member, are they a Certified Member, whether the membership covers the supplies of all products supplied to Signet and whether the RJC Membership includes the SRSP for gold, diamonds, silver / PGMs, and/or colored gemstones as a Provenance Claim.

Annual SRSP Compliance Reporting

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SRSP Compliance Report Guidance:

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• At the conclusion of the report, you can upload any supporting documentation you have to verify your claims.

• Once you submit your report, the status will be pending review by the Signet Responsible Sourcing team.

Annual SRSP Compliance Reporting

Submitting your SRSP Compliance Report:

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Annual SRSP Compliance Reporting

SRSP Report Approval and Confirmation Number:

• If all is in order with your report, you will receive your 2019 SRSP Confirmation Number via e-mail from [email protected], with a pdf copy of your report for your records.

• Your SRSP Confirmation Number will be required for the 2020 VBA.

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SRSP Compliance Report Guidance:

Annual SRSP Compliance Reporting

• If you have any questions on the SRSP compliance report, please utilize the “Supplier Support” contact option.

• A member of our team will be happy to assist you.

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• The World Diamond Council (WDC) has revised their System of Warranties (SoW) this year, which is designed to extend the effect of the Kimberley Process to include polished diamonds.

• Signet will allow suppliers to use the previous WDC warranty statement for a transition period. Suppliers should try to use the new WDC warranty statement as soon as possible after reporting compliance with the 2019 SRSP. The new warranty statement will be a mandatory requirement by June 30, 2020.

Annual SRSP Compliance Reporting -2019 Warranty Statement Update

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“The seller warrants that these products have been supplied in compliance with the Signet Responsible Sourcing Protocol (‘SRSP’).”

“Any diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and in compliance with 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.”

“The seller hereby guarantees that any diamonds herein invoiced are exclusively of natural origin and untreated, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds. ”

No Change:

No Change:

WDC SoWUpdate:

Annual SRSP Compliance Reporting 2019 Warranty Statements for all suppliers

• Following reporting compliance to the SRSP, all suppliers are required to include the SRSP and diamond warranty statements on all invoices and delivery notes, even if you do not supply gold, 3Ts, diamonds, silver or PGMs.

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SRSP Diamonds Appendix – Minimum Compliance Requirements

• Written Terms of Business with all suppliers/contractors, including requirement for the provisionof original source information and stipulation that no LGDs are included in any parcel of natural diamonds.

• KYC policy and process for all suppliers/contractors.

• Supply chain map and due diligence process, identifying risk points – especially relating to potentialfor undisclosed LGDs to enter the Supplier’s natural diamond supply chain.

• Testing for ULGDs in house or through an external gemological laboratory.

• Documentary evidence to verify all the above.Confidential and Proprietary Property of Signet Jewelers

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Category 1 Single Stone

Tracking

Confidential & Proprietary Information of Signet Jewelers

SRSP Diamonds Appendix - Categories

• Suppliers must identify all diamonds supplied to Signet within each or any of these 4 categories:

• Documentation of your due diligence: invoices, delivery notes, and certifications, will be required should you be asked to undergo an independent third party audit.Confidential and Proprietary Property of Signet Jewelers 22

• Individual diamonds supplied by or sourced from identified diamond producers which are independently certified under separate, relevant international standards (such as the RJC Code of Practices).

• Parcels of diamonds supplied by or sourced from identified diamond producers which are independently certified under separate, relevant international standards (such as the RJC Code of Practices).

•This category allows for the mixing of diamonds deriving from a number of different sources, with some percentage of the diamonds deriving from identified and verified sources.

•This category applies to diamonds which derive from small-scale or artisanal producers.

Category 1

Single Stone Tracking

Category 2

Parcel Tracking

Category 3

Mixed Sources

Category 4

Other Identified &

Verified Sources

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Undisclosed Lab-Grown Diamonds

Supplier Requirements

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• Reference: SRSP. Diamond Appendix, “Requirements” section

• From Signet’s suppliers:– Obtain a written warranty that no ULGDs are included in parcels

of natural diamonds supplied from them to the Signet supplier.

– Follow the recommended warranty statements in the WFDB Charter on Disclosure of Synthetic, Treated Natural and Natural Diamonds.

– Document your suppliers’ due diligence processes to ensure compliance with this requirement.

• Conduct an internal pipeline risk assessment covering all movement of product, identifying all possible points ULGDs could enter natural diamond supply chain.

• Test for ULGDs, in-house or via an external gemological laboratory.

• Policies, procedures and training must pay special attention to these risk points.

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Diamond Testing Technology

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• Signet, the DPA, De Beers and ALROSA have commissioned UL to develop an independent Standard and Test Protocols to test detection devices.

• Equipment manufacturers submit devices to UL for testing under the Assure Standard.

• A number of devices have already been tested and the results are available on the Assure website at Diamondproducers.com.

• Signet suppliers should use the Assure program to ensure they are using accurate and up-to-date detection technology.

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SRSP Colored Gemstones Appendix

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• Signet approached the development of this new SRSP appendix as it historically has done, through collaborative engagement withkey Signet suppliers.

• SRSP Colored Gemstone appendix applies to all natural colored ruby, sapphire and emerald gemstones supplied to Signet.

• The scope of the SRSP may be expanded in the future to include other natural gemstones.

• The SRSP also includes disclosure requirements for laboratory grown colored gemstones.

• In 2019, Colored gemstone suppliers will be required to acknowledge the new SRSP appendix and agree to work towards compliance by September 2020.

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Signet Responsible Sourcing

• Signet is a proud founding and Certified Member of the Responsible Jewellery Council (RJC), the leading jewelry industry standards and certification organization, with over 1,000 members globally.

• Signet has been very active in RJC committees, such as its Legal, Standards and Communications Committees, as well as serving as Chair (current).

• Signet requires all suppliers* to join the RJC, to provide assurance of the supplier’s responsible practices.

The Responsible Jewellery Council (RJC)

* Suppliers of Gold, Platinum, Diamonds, Silver and Colored GemstonesConfidential and Proprietary Property of Signet Jewelers 26

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Signet’s SRSP Audits – RJC certification

• Signet requires all suppliers to join RJC: around 95% of Signet’s purchases come from RJC member companies.

• From 2019 reporting, RJC certification audits with Provenance Claims for SRSP compliance (for gold, silver, diamonds etc.) will be Signet’s primary verification and assurance program.

• Certified RJC members with the relevant SRSP as a “ProvenanceClaim” are exempt from all Signet audits (SRSP and social/factory audits).

• Provenance Claims should refer specifically to the SRSP, for example: “[Company name] sources [relevant material: gold, diamonds, silver etc.] in accordance with the Signet Responsible Sourcing Protocol.”

• The Provenance Claim section of the audit will relate to the latest SRSP compliance report (keep a copy of your report and confirmation number).

• RJC provides members and auditors with audit guidance and training for the 2019 RJC Code of Practices and Signet’s requirements for Provenance Claims.

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Signet’s SRSP Audits – others

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• Suppliers who are not RJC members may be subject to Signet SRSP audits as well as social/factory audits, based on Signet’s risk assessment.

• Auditors will be provided with the list of suppliers requiring a SRSP audit.

• Suppliers will be asked to liaise with auditors to agree scope, timing and cost of audit.

• Ensure the SRSP compliance criteria and documentation requirements are met and ready for inspection.

• Maintain a copy of your SRSP 2019 Compliance Report answers, as well as the SRSP Confirmation Number.

• Ensure all information contained in your SRSP Compliance Report is accurate and can be validated by policy and transaction documentation.

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Signet Supplier Benefits – Audit Harmonization

Suppliers to Signet Who Are:

RJC Certification Audits Conducted Once Every Three Years (Upon First Certification)

RJC Certification and BPP Compliance Conducted TogetherConfidential and Proprietary Property of Signet Jewelers 29

Signet strongly recommends adding SRSP compliance as a RJC “Provenance Claim”.

Certified membership with SRSP as a Provenance Claim = no Signet audits

RJC Certified Member

No Future Factory / Social Audits Required

RJC Certified Member and...

Include a Provenance Claim Referencing the

SRSP in RJC Certification

No Third PartyAudit of SRSP

Reports Required

RJC Certified Member who...

Maintains Up-to-Date

RJC Certification and Provenance Claims

No Subsequent Signet Audits

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Chinelo Etiaba – Director, Membership Services

SRSP and the Responsible Jewellery Council

[email protected]

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The Responsible Jewellery Council (RJC) is a standards and certification organisation that helps companies of all sizes, throughout the jewellery supply chain, meet the rising ethical demands of peers, consumers, financial institutions and civil society.

It does so by providing two clear set of standards, the RJC 'Code of Practices’ (COP) and the RJC Chain of Custody (CoC), both of which are verified through a third party, independent, certification process.

Adoption and adherence with the RJC’s standards presents a pathway for companies to address sustainability best practices and align with the 17 United Nations Sustainable Development Goals (SDGs).

RJC is a gateway to sustainable growth for businesses.

What is the RJC ?

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Why is RJC relevant to your business?

Demonstrate a leadership commitment to responsible business

practices

Gain a competitive edge Manage risk and protect business reputation

Improve internal and external business

relationships

Achieve operational excellence

Join a community of confidence

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COP 2019 Changes

• Scope: include coloured gemstones (rubies, emeralds, sapphires) and silver

• Aligning COP with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

• New requirements for detection of undisclosed synthetic diamonds

• New guidance on working hours variations, in alignment with International Labour Organisation (ILO) standards

• More guidance on human rights in alignment with the UN Guiding Principles on Business and Human Rights

• Stronger requirements and guidance on environmental issues like climate change, water use, and waste, and for mining, on tailings, biodiversity and cumulative and indirect impacts

• Better inclusion of gender and vulnerable groups throughout the COP

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These are claims made by RJC members about the way they source their materials, or what kind of material they can provide to customers. They can take many different forms depending on how a business operates, and what commitment it wants to make. We’ve identified four main, but not exhaustive or mutually exclusive, scenarios for making provenance claims.

Provenance Claims

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SRSP Provenance ClaimCompliance with the SRSP can be made through an RJC provenance claim (provision 14 in the COP).

Your auditor will review your compliance through an SRSP audit as part of your RJC COP audit, and will also check your compliance with the requirements in provision 14–these requirements make sure that your company has systems to continue to comply with the claim you make, for the length of your certification (usually three years)

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Changing a provenance claim post-audit If you change a verified provenance claim, or start making a new, unverified, claim, you must get the relevant claim audited as soon as reasonably practical. If your next audit deadline is more than a year away, you should ask for a ‘bolt-on’ audit specifically to verify the new or altered provenance claim and add it to your RJC certificate. If you cannot, or do not want to, undergo an additional audit, you will have to stop making the claim.

AuditsOnly audit firms that are accredited to audit the SRSP are allowed to conduct SRSP provenance claim audits (these firms are identified on the RJC website under the ‘Standards’ scope of accreditation).

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RJC Resources

RJC Website : https://www.responsiblejewellery.com/rjc-certification/

RJC Provenance Claim Training: https://www.responsiblejewellery.com/rjc-certification/code-of-practices-certification13-2-2/training-2/provenance-claims/

RJC Videos: https://www.youtube.com/channel/UC6g86jYsgHHhQ1g5rUT8b9Q

RJC Team: [email protected]

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Summary and Q&A

• SRSP questions, contact [email protected]

• RJC questions, contact [email protected]

Confidential and Proprietary Property of Signet Jewelers

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Thank You!

• For additional questions or information, please contact: [email protected]

• Website: signetresponsiblesourcing.com from first week October 2019

Confidential and Proprietary Property of Signet Jewelers