RJC Member policies-

The RJC Code of practices policy defines the Novel Collection standards on business ethics, human rights, social performance and environmental performance against which Novel Collection are to be certified. A key feature of RJC certification is the requirement for independent third party auditing of Novel Collection management systems and performance. The RJC certification system also establishes mechanisms for early identification of issues, corrective action, and enforcement methodology.

The Novel Collection Code of practices covers a wide range of sustainable development issues, and is applicable throughout the supply chain, from rough diamonds to jewellery retail to the final consumer.

As Members of the Responsible Jewellery Council, Novel Collection seeks economic, social and environmental benefits from its business activities so that the company contribute to sustainable development following the guidelines:

1. We are committed to conducting our businesses to a high ethical standard, and to ensuring integrity, transparency and conformance with applicable law.

2. We will not engage in bribery and/or corruption.

3. We will not tolerate Money laundering and/or financing of terrorism.

4. We will adhere to the Kimberley process Certification system and the world Diamond Council voluntary system of warranties.

5. We will take reasonable measures to ensure the physical integrity and security of product shipments.

6. We will  implement a complaints mechanism appropriate to the nature, scale and impact of the business, to allow interested parties to voice concerns about our product.

7. We will collect information for proper identification of customers / suppliers in line with the RJC / AML requirements.

8. We will respect the fundamental human rights and the dignity of the individual, according to the United nations Universal Declaration of Human Rights. 

9. We are committed to high standards of health and safety in our operations.

10. We will adhere to working hours and remuneration legislation, 

11. We will conduct our business in an environmentally responsible manner.

Human rights policy

 Policy statement

• Novel Collection Ltd. is committed to equal opportunities and to the human rights of all her employees. This is emphasized amongst others through policies on “freedom of association”, “child labor”, “forced labor”, “nondiscrimination” and “non retaliation and working hours”. • Subsequently Novel Collection Ltd. will address all relevant issues of human rights raised to her attention by both internal (employees) and external stakeholders. Management and control • The management of Novel Collection Ltd. takes full responsibility for this policy and for its distribution and implementation throughout the organization. • The management of Novel Collection Ltd. declares that the hiring, discharge, pay, promotion and retirement procedures of the company will be reviewed without regard to issues of race, national origin, religion, age, disability, physical appearance, gender, marital/parental status, sexual orientation, HIV status, migrant status, membership of worker representative bodies or political affiliation – or any other criteria that are related to the above-mentioned policy this in order to make them all compliant. • The management of Novel Collection Ltd. will encourage employees to bring any breach in human rights to the attention of the management • The management of Novel Collection Ltd. will do it’s best to promote awareness to human rights through co-operations with relevant (external, human rights oriented) non-governmental entities. Note: this policy is signed and filed in official Novel Collection Ltd. records after being communicated to all employees, and is part of a set of policies presented to new employees.

Novel Collection Ltd. due diligent report

Novel Collection Ltd. pride themselves on their reputation for honesty, integrity and excellence. We hold our Suppliers to the same high standards to which we hold ourselves.

Novel Collection Ltd. therefore expects and requires that its goods and services are procured from Suppliers that share our commitment to and meet certain criteria with respect to human rights, fair and safe labor practices, environmental protection and ethical business conduct.

We not only expect our Suppliers to operate in full compliance with all applicable laws, rules and regulations, we expect each Supplier to go beyond legal compliance and strive to meet internationally recognized standards for the advancement of human rights, business ethics, and social and environmental responsibility. Suppliers shall align with the United Nations Guiding Principles on Business and Human Rights and work conscientiously to operate within its framework.

REQUIREMENTS FOR ALL SUPPLIERS

Business Integrity: The highest standards of integrity are to be upheld in all business interactions. Supplier shall conduct business ethically and all business dealings should be transparently performed and accurately reflected on Supplier’s business books and records. Supplier shall have a policy that describes its commitment to business integrity and corporate responsibility.

Conflict Diamonds

Suppliers will not support or source from conflict affected & high-risk areas.

Legal Compliance: Supplier shall comply with all applicable laws and regulations currently in effect and as they become effective. Supplier shall have systems in place that maintain awareness of and ensure compliance with all applicable laws and regulations, including but not limited to, laws concerning labor, health and safety, human rights, environmental protection and corruption and bribery.

Anti-Corruption and Bribery: Supplier shall not engage in any form of corrupt practices, including bribery, extortion, embezzlement, or fraud. Supplier represents and warrants that it shall not violate or cause Novel Collection Ltd. to violate any applicable anti-corruption or bribery law (including without limitation the United States Foreign Corrupt Practices Act).

Security: Supplier shall ensure the safety and security of its employees, contractors, and visitors. Supplier shall assess security risks and establish measures that protect against product or intellectual property theft, unauthorized access to or loss of employee or customer personal information, and damage or substitution of products within the premises and off-site or in-transit.

Child Labor: Supplier shall not employ children. Children refer to any person under the age of 15, or under the age for completing compulsory education, or under the legal minimum age for employment in the country, whichever is greatest.

Working Hours: Employees shall not be required to work more than 60 hours per week, including overtime, except in extraordinary business circumstances with their consent.

Health and Safety: Supplier shall provide a safe and healthy work environment and fully comply with all applicable safety laws, regulations and industry standards. Supplier shall regularly assess the workplace for hazards and implement appropriate programs and engineering controls to minimize the risks of work related accidents.

Summary

Novel Collection Ltd.  is a Tier 2 midstream and downstream company. We prepared a Supply Chain policy

. This policy has been communicated to all employees and made it publicly available on our website. A senior executive has been appointed to be responsible for the due-diligent program. He is responsible for collecting the information from all suppliers and keeping the records for analyzing continuous improvements. Risk assessment has been done and presented to the company’s top management.

Supply chain policy

  1. This policy confirms Novel Collection Ltd. commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.
  2. Novel Collection Ltd. is a member of the Responsible Jewelry Council (RJC). As such, we commit to proving, through independent third-party verification, that we:
  3. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;
  4. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
  5. support transparency of government payments and rights-compatible security forces;
  6. do not provide direct or indirect support to illegal armed groups;
  7. enable stakeholders to voice concerns about the jewellery supply chain; and
  8. are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.
  9. We also commit to using our influence to prevent abuses by others.
  10. Regarding serious abuses associated with the extraction, transport or trade of minerals:

We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

  1. torture, cruel, inhuman and degrading treatment;
  2. forced or compulsory labour;
  3. the worst forms of child labour;
  4. human rights violations and abuses; or
  5. war crimes, violations of international humanitarian law, crimes against humanity or genocide.
  6. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.
  7. Regarding direct or indirect support to non-state armed groups:

We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

  1. control mine sites, transportation routes, points where gemstones are traded and upstream actors in the supply chain; or
  2. tax or extort money or gemstones at mine sites, along transportation routes or at points where gemstones are traded, or from intermediaries, export companies or international traders.
  3. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.
  4. Regarding public or private security forces:

We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally as described in paragraph

5. Regarding bribery and fraudulent misrepresentation of the origin of minerals:

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of minerals.

6. Regarding money laundering:

We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of minerals.

 Internal Audit report

From: RJC consultant Mr. Jacob Laor (IIA Internal Auditor)                                      

I am pleased to inform you that I have completed the internal audit pertaining to the Novel Collection Ltd. Anti Money Laundering / Combating Financial Terrorism program. The audit has been carried out as required by the company policy as per RJC requirements. Below please review the findings:

The company introduced a written policy and procedures to verify the identity of its diamond suppliers and clients. This policy is based on best past experience used by the company during the previous years of business.

The business records, such as invoices and other business records, are kept five years at the company. There are no cash transactions at the company.

The company has prepared a procedure on how to identify unusual and suspicious transactions.

Training on how to comply with company’s policy and AML/CFT legislation has been imparted to employees by the RJC consultant Mr. Jacob Laor.

The company’s financial accounts are audited annually by a certified chartered accountant firm as per local accounting standards.

The Certified Public Accountants firm Godsi, Turgeman& Co. CPA, Issued a declaration letter to state that their auditors are free of any bias or influence relating to financial or other inducements.

Up to now there was no such case, which required informing the relevant authorities of any suspicious transactions that may be linked to money laundering, terrorism financing or other financial or non-financial offences. Company procedures provide necessary guidance to employees.

Jacob Laor