Diamond Best Practice Principles (BPP)

1
Welcome to the
Diamond Best Practice Principles (BPP) Training
2
Agenda
1) What is it?
2) Why is it?
3) Whats in it for SunDiamond?
4) What are the themes?
5) What is asked from you?
6) Presentations?

• Business Policy
• Health Safety
• Kimberley Process and AML
• Disclosure

3
What is it?

• A Code, a set of rules that aim at establishing a
  standard within the diamond industry on general
  themes like
• Business Responsibility
• Social Responsability
• Environmental Responsability

1. The BPP is edicted by the Diamond Trading Company
   (DTC) as a formal part of the Supplier of Choice
   Contract

3) The BPP is similar to auto-regulations in
other sectors (e.g. BRC)
4
Why is it?

1. It is a formal obligation for every DTC
   Sightholder under the Supplier of Choice contract
   to comply to the BPP

2) Stakeholders of the Diamond Industry
expressed a demand for Responsible Practices and
auto-regulations
3) The Industry must be able to indicate its
genuine efforts to eradicate previous existing
practices that tarnished its reputation
5
Whats in it for SunDiamond?

• Obligations
• Compliance to the BPP
• Training and information
• Audit internal/external
• Subcontractors and clients

• Opportunities
• Pioneering in Good Business Practices
• Accreditation of PurelyNaturalDiamond
• Differentiation by marketing exploitation

6
Whats in it for SunDiamond?

• 3) Expectations
• Increase Consumer Confidence
• Implement Best Business Practices
• Commitment from every actor of the Diamond
  Industry

• Consequences
• SunDiamond Business Policy
• Certification of Vietnam Factories ISO 9000,
  OHSAS 18000, SA 8000
• Local training on BPP
• PurelyNaturalDiamond

7
Themes?

• 1) Business Responsabilities
• Ethical standards gt Business Policy
• Anti Money Laundering and Terrorism Financing gt
  PPT presentation
• Kimberley Process gt PPT presentation
• Disclosure gt PPT presentation
• Pipeline Management

8
Themes?

• 2) Social Responsabilities
• Employees gt Business Policy
• Health and Safety gt PPT presentation
• Diversity gt Business Policy
• Non-discrimination gt Business Policy
• Child Labour gt Business Policy
• Forced Labour gt Business Policy
• Human Rights gt Business Policy
• Community gt Business Policy

3) Environmental Responsabilities gt Business
Policy
9
What is asked from you?

1. Listen carefully
2. Ask questions
3. Read the Business Policy
4. Remember the essentials
5. Be able to answer if questionned on any matter of
   the BPP

10
The SunDiamond Business Policy
11
In general the SunDiamond Group of
Companies Adheres to

• UN Global Compact (10 principles)
• The Universal Declaration of Human Rights
• The International Labour Organisation
• The United Nations Environment Programme
• The United Nations Development Programme
• The United Nations Industrial Development
  Organisation

12
In general the SunDiamond Group of Companies Is
committed to

• The Kimberley Process
• BPP
• FATF (40 recommendations)
• USA PATRIOT ACT
• The Canadian Diamond Code of Conduct
• The JA Code of Ethics and Standards of
  Professional Conduct, the JA Supplier Code of
  Conduct
• CIBJO and its many initiatives

13
Business Policy

• Specific themes
• Integrity
• People in the workplace
• Health and Safety
• Environment and Society

• Observance of the Business Policy

• Compliance Officer/ Chief Compliance Officer

• Purpose of the document

Read the BP (15 minutes) Sign it!
14
Health and Safety
15
Health Safety
Sources

• National Legislations
• SunDiamond Business Policy
• Rules and Regulations
• BPP

16
Health Safety
The Company Safety Manager

• Name
• How to contact him
• He will be responsible to keep the RECORDS of
  accidents, diseases, absentee
• Keep file on all accidents in order to learn and
  avoid them in the future

17
Health Safety
YOUR CONDITION
18
Health Safety

• Are you dizzy ?
• Light headed?
• Chilled and sweating?
• Shortness of breath ?
• Pain in center of chest spreading to neck,
  shoulder or arms?
• Something gets caught in your throat
• Sudden weakness/numbness of the face
• Loss of speech / trouble talking or understanding
  speech
• Sudden severe headache
• Are you diabetic? eating or checking you blood
  sugar?
• Are you allergic to certain things / been stung
  by a bee before?

Get help as quickly as possible Be aware of your
own condition
19
Health Safety

• Inform of your condition ahead of time and can
  prepare
• Taking medications? - keep a list in your pocket
• Let us know any special needs for your condition
• Update information and the emergency contact.

Time is critical - do what you can before the
unexpected happens
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Inform Immediately
Health Safety

• Call .. In case of emergency
• If you arent needed - stay out of the way
• Keep others away - keep area clear
• Help direct emergency personnel
• Respect the privacy of others

21
Health Safety
Use of alcohol drugs or tobacco is prohibited in
SunDiamond workplaces SunDiamond does not allow
working under influence of any illegal substance,
drug or alcohol Alcohol-Drugs-Tobacco
22
Health Safety
FIRE
23
Health Safety
The Fire Triangle
Fire Safety, at its most basic, is based upon the
principle of keeping fuel sources and ignition
sources separate.
24
Health Safety
Fuel Classifications
Class A Wood, paper, cloth, trash,
plasticssolids that are not metals. Class B
Flammable liquidsgasoline, oil, grease, acetone.
Includes flammable gases. Class C
Electricalenergized electrical equipment. As
long as its plugged in. Class D
Metalspotassium, sodium, aluminum, magnesium.
Requires Metal-X, foam, and other special
extinguishing agents.
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Health Safety
Fuel Classifications
Most fire extinguishers will have a pictograph
label telling you which types of fire the
extinguisher is designed to fight. For example, a
simple water extinguisher might have a label like
this
which means it should only be used on Class A
fires.
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Health Safety
How to Use a Fire Extinguisher
Its easy to remember how to use a fire
extinguisher if you remember the acronym PASS

• Pull
• Aim
• Squeeze
• Sweep

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Health Safety
How to Use a Fire Extinguisher
Pull the pin
This will allow you to discharge the extinguisher
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Health Safety
How to Use a Fire Extinguisher
Aim at the base of the fire
Hit the fuel! If you aim at the flames...
the extinguishing agent will fly right through
and do no good.
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Health Safety
How to Use a Fire Extinguisher
Squeeze the top handle
This depresses a button that releases the
pressurized extinguishing agent.
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Health Safety
How to Use a Fire Extinguisher
Sweep from side to side
.. until the fire is completely out.
Start using the extinguisher from a safe distance
away, then slowly move forward.
Once the fire is out, keep an eye on the area in
case it re-ignites.
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Health Safety
Rules for Fighting Fires
Fires can be very dangerous and you should always
be certain that you will not endanger yourself or
others when attempting to put out a fire. For
this reason, when a fire is discovered

1. Assist any person in immediate danger to safety,
   if it can be accomplished without risk to
   yourself.
2. Call 911 or activate the building fire alarm.
   The fire alarm will notify the fire department
   and other building occupants and shut off the air
   handling system to prevent the spread of smoke.

If the fire is small (and Only after having done
these 2 things), you may attempt to use an
extinguisher to put it out. However . . . .
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Health Safety
Rules for Fighting Fires
. . . before deciding to fight the fire, keep
these things in mind

1. Know what is burning. If you dont know whats
   burning, you wont know what kind of extinguisher
   to use.
2. Even if you have an ABC fire extinguisher, there
   may be something in the fire that is going to
   explode or produce toxic fumes.

Chances are you will know whats burning, or at
least have a pretty good idea, but if you dont,
let the fire department handle it.
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Health Safety
Rules for Fighting Fires
Do not fight the fire if

• You dont have adequate or appropriate equipment.
  If you dont have the correct type or large
  enough extinguisher, it is best not to try
  fighting the fire.
• You might inhale toxic smoke. When synthetic
  materials such as the nylon in carpeting or foam
  padding in a sofa burn, they can produce hydrogen
  cyanide, acrolein, and ammonia in addition to
  carbon monoxide. These gases can be fatal in
  very small amounts.
• Your instincts tell you not to. If you are
  uncomfortable with the situation for any reason,
  just let the fire department do their job.

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Health Safety
Rules for Fighting Fires
The final rule is to always position yourself
with an exit or means of escape at your back
before you attempt to use an extinguisher to put
out a fire.
In case the extinguisher malfunctions, or
something unexpected happens, you need to be able
to get out quickly. You dont want to become
trapped.
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Health Safety
Rules for Fighting Fires

• Remember to keep an exit to your back
• Only fight a fire in the incipient stage

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Health Safety
Rules for Fighting Fires
NEVER fight a fire if any of the following apply

• Dont have the proper extinguisher or equipment
• Fire has spread beyond its point of origin
• Your instincts tell you GET OUT

37
Health Safety
Fundamentals of Electrical Hazards

• To flow electricity must have a complete path.
• Electricity flows through conductors water,
  metal, the human body
• Insulators are non-conductors
• The human body is a conductor.

38
Health Safety
Dos and Don'ts

• Do plug power equipment into wall receptacles
  with power switches in the Off position.
• Do unplug electrical equipment by grasping the
  plug and pulling. Do not pull or jerk the cord to
  unplug the equipment.
• Do not drape power cords over hot pipes,
  radiators or sharp objects.
• Do check the receptacle for missing or damaged
  parts.
• Do not plug equipment into defective receptacles.
• Do check for frayed, cracked, or exposed wiring
  on equipment cords.

39
Health Safety
Dos and Don'ts

• Employees should know the location of electrical
  circuit breaker panels that control equipment and
  lighting in their respective areas. Circuits and
  equipment disconnects must be identified.
• Temporary or permanent storage of any materials
  must not be allowed within 3 feet of any
  electrical panel or electrical equipment.
• Any electrical equipment causing shocks or with
  high leakage potential must be tagged with a
  Danger tag or equivalent.

40
Health Safety
Myths and Misconceptions

• Electricity takes the path of least resistance.
• Electricity wants to go to ground.
• If an electric tools falls into a sink or tub of
  water, the item will short out.
• AC reverse polarity is not hazardous.
• It takes high voltage to kill 120 volts is not
  dangerous.
• Double insulated power tools are doubly safe and
  can be used in wet and damp locations.

41
Health Safety
Fire Safety - On-the-Job

• Do not block fire extinguishers with equipment
• Do not block fire emergency exits and escape
  routes
• Utilize those with electrical expertise/installati
  ons/assistance
• Do not overload outlets - use a track plug
• Practice good housekeeping techniques in the work
  area
• Inspect wires for possible damage and replace as
  needed

42
Health Safety
Evacuation Planning

• Make sure that you know the escape routes .
• know how to notify the fire department, and when
  to call for help.
• Never open doors that are hot to the touch.
• Remember to stop, drop to the ground and roll if
  their clothes catch fire.
• Never re-enter a burning building
• Your life is more precious than the diamonds ...

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Health Safety
Machine Guarding
44
Health Safety
Machine Guarding
Many fatalities have resulted from employees
getting caught in rotating shafts such as well
boring drills lathes. Fixed guards

• A permanent part of the machine
• Not dependent on any other part to perform the
  function
• Usually made of sheet metal, screen, bars or
  other material which will withstand the
  anticipated impact
• Generally considered the preferred type of guard.
• Simple and durable

45
Health Safety
Machine Guarding
This shows a pulley system which has correct
guards to keep fingers and tools away from pinch
points.
46
Health Safety
Machine Guarding

• Robots can be deadly.
• Establish a system to keep humans from getting
  into the robots work area.
• Maintenance workers must use a lockout system.

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Health Safety
What Is Workplace Violence?

• Workplace violence
• Any act of physical violence
• overt aggression
• Homicide, physical and sexual assault

• Workplace aggression emotional toll
• Expressions of hostility
• Gestures, facial expressions and verbal assaults
• Threats of physical violence
• Harassment, intimidation, bullying
• Ostracism/shunning
• Obstructionism
• Passive/aggressive behaviors that impede job
  performance or achievement of organizational
  objectives

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Health Safety
Behavior Warning Signs of Potential Violence and
Their Probability of Occurrence (cont)

• Evidence of drug and/or alcohol dependence
• Evidence of depression and withdrawal
• A pattern of pathological blaming
• Evidence of impaired neurological functioning
• An elevated frustration level
• An interest/fascination in weapons
• Evidence of a personality disorder

49
Health Safety
Behavior Warning Signs of Potential Violence and
Their Probability of Occurrence (cont)

• Unexplained increase in absenteeism
• Noticeable decrease in attention to appearance
  and personal hygiene
• Has a plan to solve all problems
• Resistance and over reaction to changes in
  policies or procedures
• repeated violations of the organizations
  policies

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Health Safety
Preventing Workplace Violence (cont)

• Administrative/Organizational
• Programs
• Workplace Violence Plan
• Threat Assessment Team
• EAP
• Policies
• Harassment
• Workplace violence
• SOPs

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Health Safety
Health Issues

• Eating area should be kept clean
• Toilets clean and segregated
• Drinking water
• Noise level
• Environnemental awareness
• Harassement ...

52
Health Safety
The point is.

• TAKE THE EFFORT
• TAKE THE TIME
• DO WHAT IS RIGHT!
• CORRECT SITUATIONS ON-THE-SPOT to prevent a
  worse situation.

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Health Safety
You are IN CONTROL

• If you SEE SOMETHING that is NOT RIGHT
• REPORT IT IMMEDIATELY!
• DO SOMETHING ABOUT IT!
• TELL SOMEONE (ANYONE!)
• Choose to be PRO-ACTIVE!

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(No Transcript)
55
The Kimberley Process and Anti Money Laundering
56
Kimberley Process and AML
What is a Conflict Diamond?
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 insofar as they remain in effect, or
in other similar UNSC resolutions which may be
adopted in the future and as understood and
recognised in United Nations General Assembly
(UNGA) resolution 55/56, or in other similar UNGA
resolutions which may be adopted in the future.
57
Kimberley Process and AML
What is the Solution?

• The Kimberley Process rough diamond sector
  international regulation supervised by the UN.
• Only Rough Diamonds
• Only when movement from country to country
  (Import-Export) KP Certificate from exporting
  country authorized by UN
• Reconciliation by Company Auditor
• Record keeping for 5 years
• Statement (WDC) on invoice when internal movement

The diamonds herein invoiced have been purchased
from legitimate sources not involved in funding
conflict and in compliance with United Nations
Resolutions. The undersigned hereby guarantees
that these diamonds are conflict free, based on
personal knowledge and/or written guarantees
provided by the supplier of these diamonds.
58
Kimberley Process and AML
What is Money Laundering?

• Any type of conscious involvement with the
  transfer, holding, hiding, using, etc of monies
  and assets with an illegal origin. Also if one
  were reasonably aware of someone being in any way
  related to transactions with monies or assets
  with an illegal origin, one would already be
  involved in money laundering activities.
• The origin of money or assets is illegal when
  these originate from a series of crimes mentioned
  by name, such as terrorism or terrorism
  financing, organized crime, illegal drug traffic,
  exploitation of prostitution serious and
  organized tax fraud, for which extreme
  complicated mechanisms or procedures of
  international size are used swindle, abuse of
  trust, abuse of corporate assets, a hijacking, a
  theft or extortion with violence or threat or a
  crime connected with the state of bankruptcy.

59
Kimberley Process and AML
What is the Solution?

• Financial Action Task Force 40 Recommendations
• Belgian Anti Money Laundering Law
• USA P.A.T.R.I.O.T Act

• FOR DIAMOND TRADERS
• Obligation to identify clients and notification
  of suspicious transactions or facts
• Prohibition for cash payments in excess of 10.000

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Kimberley Process and AML
What are the Obligations?

• Identification of clients
• KYC
• 10.000
• Keeping of records
• To draw a written report
• To train and sensitize employees
• To appoint a Money Laundering Responsible and to
  set up a procedure for internal check-up (in
  doubt always refer to him)
• Duty to report to the Financial Cell
• Pledge of secrecy
• Immunity

61
Kimberley Process and AML
Examples of AML suspicious activities?

• Transactions with non-registered diamond dealers.
  Being non-registered indicates an irregular way
  of doing business which always seems SUSPICIOUS.
• Transactions that, without any specific reason,
  are split up in various separate transactions.
• Transactions of a large size that are executed in
  small bank notes (but of course less than
  10,000).
• Transactions of a large size where the client has
  not counted the bank notes up front or where
  large amounts are offered in different
  currencies handling cash in a sloppy way always
  leads to suspicious situations as do cases where
  fellow contractors offer a very complicated or
  surprising way of payment.

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Kimberley Process and AML
Examples of AML suspicious activities?

• Transactions where, without any reason,
  intermediaries are used. It can either be about
  intermediaries who, without any plausible reason,
  execute large transactions for a third party or
  it is assumed that they are executed for a third
  party, or it can be about individuals accompanied
  by a third who supervises the transaction and
  refuses to make his identity known. Such
  practices with these kinds of puppets always lead
  to a suspicious situation.
• Transactions where pieces of dubious origin or
  even fake identity cards are used or where
  problems rise while identifying a client.
• Transactions that are executed with or for the
  account of post office box companies, usually
  situated in tax havens are suspicious.

63
Kimberley Process and AML
Examples of AML suspicious activities?

• Transactions which have no apparent economic
  reason for being executed in your country.
• Uncommon transactions in the light of the
  client's common activities of which the
  background and its goal are not being explained.
• Transactions where the client behaves
  suspiciously and shows little interest in the
  charged selling margin or commissions, even
  though it concerns large amounts.

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Disclosure
65
Disclosure
What is Disclosure?
Only a natural diamond can be called and sold as
a Diamond.

• Natural the stone is of natural origin, not man
  made, not synthetic, not a simulant.
• Diamond a natural mineral consisting essentially
  of pure carbon crystallised 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.

66
Disclosure
Why?

1. To restore and build up Consumer Confidence.
2. To combat Synthetics.

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Disclosure
General Rules

• ALL facts ALWAYS
• Regardless of effect on value
• No exception
• Verbal AND written on ALL documents in plain
  English
• always immediatly preceeding or succeeding the
  description of the Diamond
• Misuses of Terminology prohibition in ALL
  circum-stances (Flawless, perfect, blue white,
  properly cut, modern cut)
• No mis-representation of weight

68
Disclosure
Synthetics

• Definition any object or product that has been
  either partially or wholly crystallised or
  re-crystallised due to artificial human
  intervention such that, with the exception of
  being non-natural, the products meet the
  requirements specified in the above mentioned
  definition of diamond

• Rules
• 1-Always disclose as SYNTHETIC -MAN MADE-LAB
  CREATED-ARTIFICIAL
• 2-Never use misleading terms as CULTURED
• 3-Never use names of firms , manufacturers or
  trademarks without the terms of point 1(e.g.
  ACME DIAMONDS)

69
Disclosure
Treated Diamonds

• Definition any process, treatment or enhancement
  changing, interfering with and/or contaminating
  the natural appearance or composition of a
  diamond other than the historically accepted
  practices of cutting and polishing. It includes
  colour (and decolourisation) treatment, fracture
  filling, laser and irradiation treatment and
  coating.

• Rules
• 1-All treatments other than historically accepted
• 2-Colour (and decolourisation ) treatments,
  Fracture filling, Laser, HTHP, Irradiation coating

70
Disclosure
Treated Diamonds
3-Always Disclose all treatments , and their
effect on Diamond value the special care
requirements 4-Never disguise the term used
e.g. IMPROVED 5-Never use names of firms ,
manufacturers or trademarks alone with DIAMOND
(e.g. ACME DIAMONDS in stead of ACME DIAMOND
treated by HPHT)
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Disclosure
Diamond Simulants

• Definition any object or product used to imitate
  diamond or some or all of its properties and
  includes any material which does not meet the
  requirements specified in the above mentioned
  definition of diamond.

• Rules
• 1- Always disclose as the mineral (Zircon) or
  compound (Cubic Zirconia) or as FAKE IMITATION or
  SIMULANT Diamond
• 2- Never use names of firms , manufacturers or
  trademarks alone with DIAMOND(ACME DIAMONDS in
  stead of ACME DIAMOND SIMULANT , SWISS DIAMOND)

72
Disclosure
SunDiamond Efforts

• Business Policy
• Supply Chain Management
• Traceability Management Process is designed to
  authenticate that the diamonds, which carry the
  label PurelyNaturalDiamondTM, that are sold by
  the SunDiamond Group of Companies are natural,
  not treated, conflict free, legal and processed
  in compliance with the strictest ethical codes of
  the industry.
• PurelyNaturalDiamond

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thanks you for your attention!