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FAQs for signetresponsiblesourcing.com

Diamond SRSP

Q1: What does my company need to do now to comply with the D-SRSP?

A: The D-SRSP is mandatory for all diamond suppliers as of January 2017. This means suppliers must ensure they have in place the appropriate policies, systems and processes to comply and to evidence compliance. The key requirements are:

  1. Comply with the Kimberley Process & System of Warranties.
  2. Have a documented and functioning Know Your Counterparty policy and process, maintaining KYC documents for all suppliers.
  3. Have procedures to avoid the inclusion of undisclosed laboratory-grown diamonds, undisclosed treated diamonds or undisclosed diamond simulants in parcels provided to Signet.
  4. Maintain records of diamond purchases which indicate the original source of the diamonds wherever possible.
  5. Map the company's diamond supply chain and undertake a pipeline risk analysis.
  6. Identify which of the 4 Categories in the D-SRSP apply to your business, and to what degree you are compliant with the D-SRSP in each category.
  7. Apply a due diligence test to your supply chain, checking for risks.
  8. Have a standard Terms of Business with your suppliers which includes a requirement for diamond origin information to be included in sale documentation wherever possible.

Q2: Will I have to report on my D-SRSP compliance in 2017?

A: Yes. The 2017 reporting cycle in September/October will require suppliers to report compliance with the D-SRSP along with the annual compliance report for the SRSPs for gold and 3Ts ("3TG").


Q3: I buy some diamonds from the open market and they don't have original source information.  What do I do?

A: The D-SRSP allows for the fact that some diamonds are not sold with original source information in Category 3 – Mixed Sources.  This allows for diamonds sold to Signet to have mixed origins, with some diamonds having original source information and others not.  However, Signet would prefer all diamonds sold to Signet to be of identified origin and would like to improve the level of original source information over time.

Suppliers should also note the requirement to undertake a pipeline risk analysis.  The analysis should reveal any points in their supply chain at which illicit diamonds or undisclosed laboratory-grown diamonds (ULDGs) could enter their inventory.  Any such risk must be mitigated effectively.


Q4: How does the D-SRSP address the issue of ULGDs?

A: Signet requires all Suppliers to take substantive and documented action to avoid the inclusion of undisclosed laboratory-grown/laboratory-created/synthetic diamonds, undisclosed treated diamonds or undisclosed diamond simulants in parcels provided to Signet.  The D-SRSP contains strict and detailed requirements on this matter, with key elements including:

  • Obtain a written warranty from their suppliers to the effect that no ULGDs are included in parcels supplied to them.

  • Include a warranty statement on all invoices to Signet with respect to diamonds whether loose contained in finished jewelry.

  • Comply with the De Beers Best Practice Principles Standard Guidance – Undisclosed Synthetic Diamonds (2016) and the related Disclosure Practice Note (May 2016). See D-SRSP Appendix D & E respectively.

  • Ensure they have appropriate policies, procedures and staff training to mitigate the risk of undisclosed laboratory-grown diamonds entering their natural diamond supply chain.

  • Conduct single stone or batch/percentage testing, depending upon the attributed risk. Testing may be conducted by the Supplier using relevant detection technology, or may be outsourced to a qualified gemological laboratory.
See below for further guidance with respect to the detection of undisclosed laboratory-grown diamonds.


Q5: How does the D-SRSP affect the costs of audit?

A: Any future audit of D-SRSP reports will be done in conjunction with other SRSP reports (e.g. 3Ts and Gold), where applicable.  Signet is conscious of audit fatigue and has harmonized the D-SRSP with existing standards, especially the DeBeers Best Practice Principles and the RJC Code of Practices.  When suppliers include compliance with the D-SRSP as a pre-audited Provenance Claim in their RJC certification they will not be required to have a separate Signet SRSP audit, nor Signet factory or social audits.  In addition, suppliers who are also De Beers Sightholders can have their BPP and RJC audits conducted simultaneously.


Q6: How can a Supplier ensure compliance with clause 3.4 with respect to Signet’s legal requirements not to source from entities subject to US / UK / Canadian or EU sanctions? Is there a reference list of such entities and how can this information be updated?

A: Lists of sanctioned individuals and entities are published by the US, UK, Canadian and EU administrations and are readily available through the official government websites.  Sanctions can change so the lists of sanctioned entities are only definitive on the date of search.  However, for the current purposes of the D-SRSP the US Office of Foreign Assets Control (OFAC) sanctions applicable to the Zimbabwe Mining Development Corporation (ZMDC) and certain entities in which the ZMDC holds a 50% or greater interest are relevant.

The practical effect of the OFAC sanctions is that diamonds originating from Zimbabwe cannot legally be imported into the US.
Therefore, Signet Suppliers must take responsibility to avoid supplying diamonds originating from Zimbabwe to Signet.


Q7: The D-SRSP requires Suppliers to undertake due diligence according to the OECD Due Diligence Guidance.  What should that process include?

A: The D-SRSP requires Suppliers to follow the OECD Due Diligence Guidance for Responsible Supply Chains, specifically steps 1 and 2.  Implementation of the Guidance should include the following process:

a) Implement company management systems including a written policy to the effect that you do not deal in conflict diamonds.  The policy should include maintaining a system of control on your inventory (see 1 above).

b) Maintaining a supplier map listing all your suppliers, and supported by KYC records for all suppliers.

Your risk assessment should include:

  • Document your diamond supply chain in accordance with the D-SRSP, recording your diamonds by category (1-4).

  • Diamonds originating from Zimbabwe cannot be legally imported into the US (OFAC sanctions apply) so your risk assessment should include an assurance that your suppliers don’t supply you with Zimbabwe diamonds.

  • Your supplier risk assessment must also include ensuring that all your suppliers have appropriate control systems, product security, and staff training so that any risks of inclusion of undisclosed lab-grown diamonds into the natural diamond supply chain are mitigated.

Q8: Suppliers will require guidance and training about the D-SRSP; how will Signet support them?

A: Suppliers are directed to the Signet SRSP website at www.signetresponsiblesourcing.com:  Suppliers may also seek advice from Signet's Responsible Sourcing Team at any time via the dedicated email helpline: info@signetsrsp.com.  The Team will support Suppliers to implement the D-SRSP, providing practical guidance about all aspects of the policy, including implementation, reporting, record keeping and audit.  The Responsible Sourcing Team also provides training on SRSP compliance, through the website, webinars and 1:1 meetings.


D-SRSP Requirements for Detection of ULGDs.

Q9: If a Supplier incurs additional costs to comply with the ULGD requirements, who will cover the added costs?

A: All Signet Suppliers are contractually bound (VBA) not to supply Signet with any undisclosed lab-grown diamonds, undisclosed treated diamonds, or undisclosed diamond simulants.  Signet expects that suppliers will enhance their systems to mitigate the risk of undisclosed material being included in diamonds supplied to Signet.  The additional sections of the D-SRSP set out the steps which a supplier should take in order to implement a thorough risk mitigation strategy.  See Clauses 3.5 – 3.5.12.  These requirements are based on the De Beers Best Practice Principles; the De Beers Melee Guidance is appended.  

However, where a supplier encounters particular issues, Signet will be prepared to discuss those issues constructively with the Supplier.



Q10: What if this leads to additional delays in my deliveries?

A: Signet appreciates that delivery schedules may be impacted by these requirements.  Where any Supplier anticipates delivery issues this should be notified immediately to the Suppliers’ Merchandising contact.


Q11: Are Suppliers required to purchase detection technology?

A: No, suppliers may outsource their diamond testing to an independent gemological laboratory. Tested goods should be returned to a supplier in secure containers accompanied by a report from the testing laboratory with a unique identifier relating the report to the material tested.



Q12: What detection technology or external laboratory should I use?

A: Signet is working with De Beers and the Diamond Producers Association (Project Assure) to develop an independent standard to assess diamond detection technology. Pending the development of the standard, we have determined that the detection technology leaders are technologies or services supplied by De Beers (IIDGR), the GIA and HRD. Signet also recommends gemological services by AGS, GSI and GSL. Detection processes conducted by technologies or services from other organizations may be subject to significantly stricter auditing and spot checks.



Q13: I have already purchased detection technology from a manufacturer which is not included in Signet’s recommended list.  Am I now required to purchase a new machine?

A: Suppliers must ensure that the detection technology they employ accurately and reliably distinguishes between natural diamonds and stones which may be lab-grown, treated or simulant.  If the technology is not 100% reliable, the Supplier is at risk of supplying diamonds which many not be natural.


Q14: What is the timing for the implementing the new LGD requirements?

A: Signet expects that all diamond Suppliers will implement the requirements by end-September 2017 and will report accordingly in their SRSP compliance reports.

The following warranty statements will be required by all Suppliers following successful reporting of compliance with the D-SRSP”. The warranty statements must appear on all sales documents such as invoices and delivery notes.

Signet Warranty Statement

"The seller warrants that any products containing gold, tin, tungsten, tantalum or diamonds have been supplied in compliance with the Signet Responsible Sourcing Protocol ("SRSP")."

"The seller hereby guarantees that the diamonds herein invoiced are exclusively of natural origin, formed and grown under natural and geological processes, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds."

Kimberley Process/WDC System of Warranties Statement (Statement already required)

The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and in compliance with United Nations Resolutions. The seller hereby guarantees that these diamonds are conflict-free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.




Q15: Why are some products subject to 100% testing and others only random sampling?

A: The testing requirements follow a risk-based approach. It is acknowledged that the diamond supply chain will require sufficient time for testing to become fully integrated, and that there is a manufacturing lead-time for the acquisition of detection technology.

  • Loose Polished: Screening should be implemented according to the sizes/% indicated in the De Beers Guidance. However, ideally Suppliers should screen 100% of loose polished. Mounted: Diamond set jewelry should also be screened according to the sizes/% indicated in the De Beers Guidance. Suppliers will need to calculate the number of finished pieces to be screened based on the number and sizes of stones in each piece. (See D-SRSP appendix E: DE BEERS - DISCLOSURE PRACTICE NOTE (MAY 2016), pages 4 and 7)


Q16: What happens if a LGD is found in one of the products I deliver, despite my best efforts?

A: The matter would be discussed between the Supplier and Signet.  If appropriate, an audit would be requested. The Supplier’s policies, procedures, staff training and testing protocols would be reviewed to check compliance with the D-SRSP requirements.  Where deficiencies are detected, Signet would consider a range of options based on the severity of the failures, including cessation of business.



Q17: How will Signet be checking compliance?

A: Compliance will be checked through the SRSP reporting and audit cycle.  Each year a range of suppliers are selected for audit and notified accordingly by the Signet SRSP Team.



Q18: How is Signet ensuring that diamonds supplied by Signet are free of ULGDs?

A: Signet Assay protocols include testing of all SKUs containing diamonds to verify that the diamonds are natural.  Signet is also enhancing its QA process so that all Signet diamonds of 1/5 carats (≥0.18 carats) or larger are individually tested using the IIDGR Diamond Sure. The frequency of assay for diamonds smaller than 1/5 carats (<0.18 carats) is also being increased. 

Where Signet supplies loose diamonds to Suppliers/contractors for setting into finished jewelry, Signet guarantees that all diamonds have been tested as natural.



Q19: I receive all my diamonds from Signet and set them into finished jewelry for Signet.  Do I need to test the diamonds before I return the finished jewelry to Signet?

A: Yes, you need to test finished jewelry prior to consignment to Signet, on a representative sample basis. This requirement is necessary because of the risk of switching LGDs for natural diamonds during the jewelry production process.



Q20: In the case of a Signet Supplier who outsources jewelry manufacture to a contractor, what is the responsibility of the Supplier to ensure that the diamonds contained in the jewelry are natural?

A: Suppliers should follow the requirements set out in the D-SRSP which are designed to establish a robust risk mitigation process.  Suppliers must:

  • Obtain a written warranty statement from their suppliers to the effect that no undisclosed laboratory-grown diamonds are included in parcels supplied to them (Cl 3.5.1)
  • Document their own and their suppliers’ due diligence processes to ensure compliance with this requirement. (Cl 3.5.3)
  • Comply with the De Beers BPP Standard Guidance on Undisclosed Synthetic Diamonds and the Disclosure Practice Note. Cl 3.5.4)
  • Conduct an internal pipeline risk assessment, covering all movement of product, identifying all possible points at which undisclosed laboratory-grown diamonds could enter the suppliers’ natural diamonds supply chain. (Cl 3.5.5)
  • Test diamonds according to the attributed risk. (Cl 3.5.6)
  • Implement policies, procedures, security, monitoring and training to avoid the possibility of switching during the production process. (Cl 3.5.8)
  • Where a supplier deals in laboratory-grown diamonds, implement specific policies and procedures to ensure that natural diamonds are segregated. (Cl 3.5.9)
  • Implement handling, storage and transportation procedures. (Cl 3.5.10)
  • Implement training for staff involved in handling, movement or security of product. (Cl 3.5.11)

Suppliers must also review the procedures followed by their suppliers/sub-contractors to ensure compliance with the D-SRSP, and especially those requirements relating to undisclosed laboratory-grown diamonds.


Q21: If I supply diamonds, which I have tested as natural, to a contractor for manufacture into jewelry, what is my responsibility to ensure that the finished product contains only natural diamonds?

A: It is the responsibility of Signet Suppliers to ensure that their suppliers/contractors follow the D-SRSP.  Therefore, Suppliers must thoroughly review the standards and processes applied by their suppliers/contractors and ensure that improvements are implemented where necessary.

See Q15 for screening requirements.




Q22: What specific documentation is considered adequate?

A: Adequate documentation would include:

  • Delivery notes
  • Invoices
  • KP Certificates
  • Copies of letters from Supplier to their supplier/contractor requiring adherence to the D-SRSP, ideally with a corresponding letter from the supplier/contractor acknowledging same.
  • KYC records
  • Copies of the terms of business between a Supplier and their suppliers
  • Documented review of contractors’ factory standards designed to mitigate the potential for natural diamonds to be switched for ULDGs, including security of goods, policies and staff training.


Q23: How can I test diamonds in set jewelry?

A: Signet acknowledges that testing set diamonds can be challenging and sometimes time-consuming.  However, screening can be accomplished using an accurate instrument such as the IIDGR Diamond Sure with Mount.



Q24: How can I be certain that the jewelry supplied by a contractor is 100% natural?

A:It is not possible to devise a 100% failsafe system. There is always the possibility of deliberate switching of stones, the falsification of documentation or accidental mixing of natural diamonds with lab-grown diamonds.  However, if a Supplier follows the steps set out in the D-SRSP the risks can be considerably mitigated.  Signet expects Suppliers to take these steps seriously and professionally, and an auditor will seek evidence that the Supplier has carried out the steps diligently.  For screening requirements see Q15.




Q25Does a Supplier have to be concerned about customers’ jewelry being sent in for repair?  Will Signet test the piece first then send it to the supplier for repair?  Who would be responsible if the diamond was determined to be synthetic after a repair?

A: Signet stores have a take-in process that includes several diamond checks including plotting and/or imaging of primary stones. Testing for LGD is not one of them. Any stones supplied to the repair process (new stones) need to be checked before setting.



Q26How can large quantities of loose melee be tested cost effectively?

A: Loose melee can be tested easily, quickly and in quantity with technology such as the IIDGR AMS2 or the HRD M Screen.




Q27Currently, all suppliers of polished diamonds provide a declaration in their invoices that the diamonds are of natural origin. Will this declaration serve the purpose of “Due Diligence”?

A: A declaration contained in an invoice could not be regarded as evidence of due diligence in the absence of additional enquiries.  Evidence of due diligence would include, but not necessarily be limited to:

  • Copies of correspondence between the Signet Supplier and their suppliers/contractors evidencing that the D-SRSP has been provided to those suppliers/contractors with a requirement that the D-SRSP must be followed.
  • Copies of correspondence between the Signet Supplier and their suppliers/contractors evidencing that supplier/contractor has systems, policies and training designed to mitigate the risk of undisclosed lab-grown diamonds, treated diamonds or simulants.
  • Evidence that the Supplier had visited the premises of the supplier/contractor to review the systems, policies and training in place.



Q28Will sub-contractors be subject to D SRSP audits?

A: No.  Suppliers are responsible for ensuring that sub-contractors are aware of the requirements of the D-SRSP.




Q29I am an RJC Member so do I need to complete the Signet SRSP report annually?

A: Yes, all Signet Suppliers must complete an SRSP report annually and indicate their compliance with all relevant Signet SRSPs.  Once a Supplier has completed their SRSP report they are issued with a unique confirmation number which will be required to complete their VBA.




Q30Whom do I contact if I have questions about how to implement the requirements?

A: Please contact the Signet SRSP Team via info@signetsrsp.com




3TG SRSP and Compliance reporting.

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Q31: I completed a SRSP report last year. Must I do it again?

A: Yes, reporting against the SRSP is an annual requirement, in accordance with Signet's legal obligations to the SEC.

 

Q32: I am unable to log in to the website SRSP compliance report using the username and password provided.

A: New usernames and passwords are issued each reporting year and are case sensitive so please enter both exactly as shown in the email you received. If you are still unable to log in please email the SRSP project team at info@signetsrsp.com.

 

Q33: Not all my vendor numbers appear when I log in to complete my SRSP report. What is my next step?

A: Please email the SRSP project team at info@signetsrsp.com and provide the vendor number(s) that are missing along with the vendor name(s) associated with the vendor number(s).

 

Q34: How can I get a copy of my 2017 SRSP Compliance Report?

A: Please email the SRSP project team at info@signetsrsp.com and provide your vendor name and vendor number for which you are requesting a copy.

 

Q35: I received the username and password but someone else in my organization is responsible for completing this report. What should I do?

A: Please email the SRSP project team at info@signetsrsp.com and provide the name and email address of the person in your organization who should receive this information. We will amend our records accordingly and send the related information to that individual.

 

Q36: I have not received my log-on and password for the SRSP reporting section of the website: how do I get it?

A: Please email the SRSP project team at info@signetsrsp.com with your vendor name and number, and we will send you another log-on and password.

 

Q37: Why do I need the SRSP compliance report confirmation number?

A: The confirmation number is needed so Signet knows which suppliers have completed the report; you also need it to complete your annual supplier contract (or "Vendor Buying Agreement") so please forward this number to the person in your organization who is responsible for this document.

 

Q38: I can't remember my confirmation number and I need it for my VBA: how can I get it?

A: If you log on to the SRSP section of the website, your confirmation number is listed next to the status of your report.

 

Q39: What is the best way to ensure my gold is conflict-free?

A: One of the easiest ways is to ask all your suppliers to ensure they only use LBMA good delivery gold. The list of current LBMA "good delivery" gold refiners is available at the LBMA website (www.lbma.org.uk/the-good-delivery-list ).

 

SRSP Audit Process

 

Q40: Why does Signet ask for audits of SRSP reports?

A: In accordance with OECD guidance, Signet asks a representative sample of its suppliers to validate that compliance claims are accurate and valid, through independent accredited auditors. As a Signet supplier, you should expect to be audited at least every 3 years.

 

Q41: How do I choose an auditor?

A: The accredited auditors are listed in the SRSP audit guidance along with their geographical coverage. Most are specialist supply chain auditors, and are also accredited with the RJC. If you need help in choosing an auditor, contact the project team at info@signetsrsp.com.

 

Q42: I am a member of the RJC. Do I need to provide an audit of my SRSP compliance?

A: If you are a certified member of the RJC, and if that certification includes the SRSP as a Provenance Claim, Signet will accept your RJC certification instead of a Signet audit, and this will remain in the future as long as your RJC certification is current. Importantly, you will also not be required to undertake Signet factory and social audits.


RJC Membership

 

Q43: Do all Signet suppliers have to join RJC?

A: Signet has a requirement that all suppliers of gold, platinum or diamonds should join the RJC.

 

Q44: Why does Signet expect all suppliers to join RJC?

A: In addition to the SRSPs, having RJC members through Signet's supply chain provides an assurance to Signet and to its suppliers that it is doing business with reputable and responsibly managed companies.

 

Other


Q45: I have other questions – whom do I contact?

A: Please email the SRSP project team at info@signetsrsp.com with your questions, and one of the team will contact you.​​​​