1. Background
- We at GSI have a vision: to create a modern, state-of-the-art diamond grading lab that takes advantage of the latest breakthroughs in diamond grading. To do this, we reengineered the diamond grading process and founded it on foolproof cutting-edge technology and automation. The result is diamonds that are graded to the highest standards.
- The diamond grading industry is populated by GSI laboratories that are virtually indistinguishable. In this “alphabet soup” of grading labs, diamonds are graded by hand and eye – an ultimately subjective assessment. While this continues to be standard practice for all laboratories, GSI has enhanced this process by adding advanced technology and intelligent software.
- This Ethical Business policy, adopted by GSI sets forth the basic internal standards to be observed by all directors, officers and employees of the Company with respect to conducting business in a legal, ethical, professional and accountable manner.
- The company is required to take appropriate steps to ensure that the same is understood and put into practice by all of its directors, officers and employees.
- Also appropriate steps are taken to assure adherence to this Ethical business policy, including establishing appropriate disciplinary procedures where violations of this document will result in sanctions up to and including discharge.
2. Legislation and Regulations
- GSI shall operate in compliance with relevant national and international legislations/ regulations as applicable in the countries in which they operate.
- All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal Company rules and policies relating to their business activities.
- It is the responsibility of personnel to know and understand legal, regulatory and internal requirements as they apply to their jobs.
- The 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.
- Further detailed requirements under each act are mapped and its compliance is ensured by a compliance officer.
3. Money Laundering, Terrorism Financing, Other Financial Offences
- GSI recognizes the fact that entities in the gems and jewelry sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
- Strict compliance is required at all times, with all applicable national and, where appropriate, international laws / regulations with respect to money laundering, terrorism financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.
- GSI 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 group level policies of the company.
- Money Laundering Act / The Prohibition of Money Laundering Law / AML/CFT requirements
- FATF 40 Recommendations and 8 special recommendations
- 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 ethical business, depending on the seriousness of the non-conformance.
- 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.
- Compliance officer caries out periodic review of AML/CFT compliances and submits his report to management on Quarterly basis.
4. Anti Bribery and Facilitation Payment Policy:
- The GSI shall ensure complete prohibition of Bribery and facilitation payment across organization and in all the entities.
- Company will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.
- Entity shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.
- Periodic training and awareness shall be carried out to educate employees about various type and ways of bribery and facilitation payments.
5. Supply Chain Management / Best Endeavors
The management of GSI is committed to take appropriate action to use best endeavors to ensure that the suppliers and contractors are committed for compliance to Social Standards.
6. Employment
- Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labor.
- The Company shall not require Staff to work for more than the national limit of hours in a week.
- The Company shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of Staff and provide some discretionary income.
- It is the responsibility of concerned personnel to know and understand the relevant employment and labor related legal, regulatory and internal requirements as they apply to their jobs.
- When required, due recognition will be given to the existence, membership and lawful activities of staff representatives will be given access to carry out their responsibilities / functions.
- The procedures detailed in the Employee Manual should be followed for dismissal of employees, in case the need for the same arises, and arbitrary dismissal procedures should be avoided.
- Information regarding applicable employment policies and working practices should be communicated in a transparent manner to all employees
7. Health and Safety
GSI 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.
- The health of our staff, exposed to certain hazardous processes, will be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
- Staff shall not be under the influence of or abusing, drugs, alcohol and/ or other illegal substances.
- All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable
- Wherever requires and applicable, individual entities will nominate an Health, Safety and Environment Committee, headed by a senior management representative, which will have its fullest support in executing operational changes required to carry out these policies.
8. Non Discrimination & Disciplinary Practices
- Discrimination can mean distinction, exclusion or preference.
- 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 Company and any such reported incidents will be viewed as a serious violation of this Ethical Business Policy.
- GSI will ensure that employees who have certain life-threatening diseases or illnesses are not treated differently from other employees, and will continue to employ such personnel, as long as they are physically and mentally fit to attend to their normal job responsibilities.
- GSI shall at no time condone the use of corporal punishment or other forms of mental or physical coercion
- GSI encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, Company operation or practice is or will likely be in violation of any law, regulation or internal Company rule or policy, including this Ethical Business Policy. GSI assures all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully.
9. Child Labour
- No form of child labor should be employed at any of the facilities of GSI. Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).
- For authorized adolescents (persons below 18 years of age but above 15 years), the Company management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
- As per our company policy no child labor or adolescent child labor will be employed.
- Company will implement suitable policy and procedures to verify the age proof all new employees joining the organization.
10. Forced Labour
- The management of GSI is fully committed to ensuring that forced or involuntary labor 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 Ethical Business Policy.
- 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 the said person has not offered himself voluntarily”
11. Freedom of Association and collective Bargaining
Freedom of association is the right of workers and employers to freely form and join Workers Organizations such as trade unions, worker associations and worker councils or committees for the promotion and defense of occupational interests.
12. Human Rights
- All employees in the Company’s facilities will be treated with equality, respect and dignity.
- GSI 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 Company strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.
- Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company.
13. Environment Protection
GSI 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.
14. Product Security
Our company is currently not engaged in the business of diamond, gold & jewelry and, thus this does not apply, however we are providing diamond testing service to gem and jewelry industry in that case we are maintain our protocol related to testing. All GSI reports are backed by a commitment to the highest ethical standards. The company’s experience and reputation are well known in the industry and speak for themselves. Clients know they can rely on GSI for integrity and transparency.