Our Policies
Human Rights
DEFINITION:
Human rights are universal rights and freedoms regarded as belonging to all people without discrimination based on internationally recognized standards. At a minimum, the RJC understands human rights to mean those rights articulated in the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and Applicable Law.
Human rights are relevant to all businesses, regardless of size, sector or country of operation. The kinds of rights which are regarded as human rights include:
• Social, cultural and economic rights – such as the right to participate in cultural activities, the right to food, the right to clean drinking water and sanitation, and the right to education;
• Labour rights – such as the right to freedom of association and effective recognition of the right to collective bargaining, and freedom from forced labor, child labour and discrimination;
• Civil and political rights – such as the right to life and liberty, freedom of expression, and equality before the law.
In 2011, the United Nations (UN) Human Rights Council released the Guiding Principles on Business and Human Rights, to elaborate the UN Framework for business and human rights adopted in 2008. The UN’s “Protect, Respect and Remedy”
Framework rests on three pillars:
• State duty (requirement) to protect against human rights abuses by third parties including business through appropriate policies, regulation, and adjudication;
• Business responsibility (expectation) to respect human rights, which means to act with due diligence to avoid infringing on the rights of others and to address adverse impacts that are linked to their activities; and
• Access by victims to effective remedy, both judicial and non-judicial.
The Universal Declaration of Human Rights is generally agreed to be the foundation of international human rights law. Adopted in 1948, the UDHR has inspired a rich body of legally binding international human rights treaties. It continues to be an inspiration to us all whether in addressing injustices, in times of conflicts, in societies suffering repression, and in our efforts towards achieving universal enjoyment of human rights.
It represents the universal recognition that basic rights and fundamental freedoms are inherent to all human beings, inalienable and equally applicable to everyone, and that every one of us is born free and equal in dignity and rights. Whatever our nationality, place of residence, gender, national or ethnic origin, colour, religion, language, or any other status, the international community on December 10 1948 made a commitment to upholding dignity and justice for all of us.
Supply Chain Due Diligence Policy
Since commencing business in 2019 Skomboys Refineries has obtained a refinery license. It is our company policy to be transparent with regards to business dealings with our suppliers and clients.
In view of the role of the precious metals trade with regards to abuse of human rights, its contribution to conflict, money laundering and combating terrorist financing, Skomboys Refineries hereby commits itself to uphold the principles of The OECD Due Diligence Guide for the Supply Chain of Minerals from Conflict-Affected and High-Risk Areas.
It is Skomboys Refineries policy to purchase precious metals from legitimate and ethical sources and that the purchase of such precious metals have not been associated with corruption, crime, armed conflict, misrepresentation of tax and royalty payments or human rights abuse. We will continue to operate our Company with honesty and the highest or moral standards in all aspects of our business.
Skomboys Refineries has implemented the abovementioned policy with regards to the purchasing of precious metals.
The Directors and staff of Skomboys Refineries all commit to the following principles:
1. With regards to the serious abuses associated with the extraction, transport or trade of minerals while sourcing precious metals we will not tolerate nor profit from, contribute to, assist or facilitate the commission by any party of:
i) any forms of torture, cruel, inhuman and degrading treatment;
ii) any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;
iii) the worst forms of child labour;
iv) gross human rights violations and abuses such as widespread sexual violence;
v) war crimes, violation of international humanitarian laws, crimes against humanity or genocide.
2. Regarding risk management of serious abuse, we will immediately terminate dealings with suppliers that are identified as a risk that they are sourcing from or linked to, any party committing or partaking in the crimes as mentioned above.
3. We will not deal with any suppliers or non-state armed groups that directly or indirectly through the extraction, logistical support, trade, handling or export of minerals, but not limited to procuring minerals from, making payment to or otherwise providing logistical assistance or equipment to, non-state armed groups or their associates who:
i) Illegally control mine sites, transportation routes, points where minerals are traded and suppliers;
ii) Illegally tax or extort money or minerals from mines, transportation routes or at trading points;
iii) Illegally tax or extort intermediaries, export companies, or traders.
4) Regarding risk management of direct or indirect support to non-state armed groups we will immediately suspend suppliers that are identified as a high risk in that they are sourcing from or supporting, either directly or indirectly, non-state armed groups as defined in paragraph 3.
5) We agree to eliminate, in accordance with paragraph 10, direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and suppliers;
6) We recognize that the role of public or private security forces at the mine sites / or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.
7) Where we or any company or suppliers must ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired.
8) We will support efforts, or take steps, to engage with central or local authorities, international organizations and civil society organizations to contribute to workable solutions on how transparency, proportionality and accountability in payments made to public security forces for the provision of security to be improved.
9) We will support efforts, to engage with local authorities, international organizations and civil society organizations to avoid or minimize the exposure of vulnerable groups, in particular, artisanal miners where minerals are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.
10) In accordance with the specific position of the company, we will immediately devise, adopt and implement a risk management plan with suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, as identified in paragraph 5, where we identify that such a reasonable risk exists. In such cases we will not support such suppliers.
11) We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purpose of mineral extraction, trade, handling, transport and export.
12) We will takes steps to eliminate money laundering were we identify a reasonable risk of money laundering resulting from, or connected to, the extraction , trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine site, along transportation routes or at points were minerals are traded up suppliers.
13) Any visitors and contractors that work on the premises will abide by the above rules. A copy of the document to be signed and handed to Senior Management.
The Directors and staff of Skomboys Refineries confirm their commitment and compliance to this policy.
Materials from Conflict-Affected Areas
Skomboys Refineries was established in 2019. As a registered precious metals refiner Skomboys Refineries specialises in the recycling of precious metals.
1. PURPOSE
The purpose of this policy is to confirm Skomboys Refineries’s commitment to respect human rights, refrain from action which contributes to the finance of conflict, and to comply with relevant UN sanctions resolutions and laws.
2. GENERAL PRINCIPLES
Skomboys Refineries is a Member of the Responsible Jewellery Council (RJC).
RJC has to two standard platforms which provide the mechanism for RJC Members to support these commitments:
1. Code of Practice
2. Chain of Custody
As such, we commit to providing, through independent third party verification, that we:
• respect human rights according to the Universal Declaration of Human Rights and International Organisation Fundamental Rights at Work;
• do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
• support transparency of government payments and rights-compatible security forces in the extractives industry;
• do not provide direct or indirect support to illegal armed groups; and
• establish processes through which stakeholder can raise concerns about the jewellery supply chain.
3. We also commit to using our influence to prevent abuses by others.
4. REGARDING SERIOUS ABUSES ASSOCIATED WITH THE EXTRACTION, TRANSPOR OR TRADE OF GOLD
We will neither tolerate nor profit from, contribute to, assist of facilitate the commission of:
• torture, cruel, inhuman and degrading treatment;
• forced or compulsory labour;
• the worst from of child labour;
• human rights violations and abuses; and
• war crimes, violations of international humanitarian law, crimes against humanity or genocide.
5. 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.
6. REGARDING DIRECT OR INDIRECT SUPPORT TO ARMED GROUPS
We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to procuring gold from, making payments to or otherwise providing assistance or equipment to, non-state armed groups or their affiliates who illegally:
• control mine sites, transportation routes, points where gold is traded and upstream actors in the supply chain; and,
• tax or extort money or gold at mine sites, along, transportation routes or at points where gold is traded or from intermediaries, export companies or international traders.
7. We will not deal with, and will immediately discontinue engagement with, upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.
8. REGARDING PUBLIC OR PRIVATE SECURITY FORCES
We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. 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 6.
9. REGARDING BRIBERY AND FRAUDULENT MISREPRESENTATION OF THE ORIGIN OF GOLD
We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, or to misrepresent taxes, fees and royalties paid to governments for the purpose of extraction, trade, handling, transport and export of gold.
10. REGARDING MONEY LAUNDERING
We will support efforts and contribute to the effective elimination of money laundering where we identify a reasonable risk of money laundering resulting from, or connected to, the extraction, trade, handling, transport or export of gold.
Supply Chain
Since commencing business in 2019 Skomboys Refineries has obtained a refinery license. It is our company policy to be transparent with regards to business dealings with our suppliers, customers and contractors.
In view of the role of the precious metals trade with regards to abuse of human rights, its contribution to conflict, money laundering and combating terrorist financing, Skomboys Refineries hereby commits itself to uphold the principles of The OECD Due Diligence Guide for the Supply Chain of Minerals from Conflict-Affected and High-Risk Areas.
It is Skomboys Refineries policy to purchase precious metals from legitimate and ethical sources and that the purchase of such precious metals have not been associated with corruption, crime, armed conflict, misrepresentation of tax and royalty payments or human rights abuse. We will continue to operate our closed corporation with honesty and the highest or moral standards in all aspects of our business.
Skomboys Refineries has implemented the abovementioned policy with regards to the purchasing of precious metals.
The Directors and employees of Skomboys Refineries all commit to the following principles:
1. With regards to the serious abuses associated with the extraction, transport or trade of minerals while sourcing precious metals we will not tolerate nor profit from, contribute to, assist or facilitate the commission by any party of:
i) Any forms of torture, cruel, inhuman and degrading treatment;
ii) any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;
iii) the worst forms of child labour;
iv) gross human rights violations and abuses such as widespread sexual violence;
v) war crimes, violation of international humanitarian laws, crimes against humanity or genocide.
2. Regarding risk management of serious abuse, we will immediately terminate dealings with suppliers that are identified as a risk that they are sourcing from or linked to, any party committing or partaking in the crimes as mentioned above.
3. We will not deal with any suppliers or non-state armed groups that directly or indirectly through the extraction, logistical support, trade, handling or export of minerals, but not limited to procuring minerals from, making payment to or otherwise providing logistical assistance or equipment to, non- state armed groups or their associates who:
i) Illegally control mine sites, transportation routes, points where minerals are traded as suppliers;
ii) Illegally tax or extort money or minerals from mines, transportation routes or at trading points
iii) Illegally tax or extort intermediaries, export companies, or traders.
5) We agree to eliminate, in accordance with paragraph 10, direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and suppliers;
6) We recognize that the role of public or private security forces at the mine sites / or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.
7) Where we or any company or suppliers must ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired.
8) We will support efforts, or take steps, to engage with central or local authorities, international organizations and civil society organizations to contribute to workable solutions on how transparency, proportionality and accountability in payments made to public security forces for the provision of security to be improved.
9) We will support efforts, to engage with local authorities, international organizations and civil society organizations to avoid or minimize the exposure of vulnerable groups, in particular, artisanal miners where minerals are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.
10) In accordance with the specific position of the company, we will immediately devise, adopt and implement a risk management plan with suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, as identified in paragraph 5, where we identify that such a reasonable risk exists. In such cases we will not support such suppliers.
11) We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purpose of mineral extraction, trade, handling, transport and export.
12) We will takes steps to eliminate money laundering were we identify a reasonable risk of money laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine site, along transportation routes or at points were minerals are traded up suppliers.
13) We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with the principles
Set forth under the Extractive Industry Transparency Initiative (EITI).
14) In accordance with the specific position of the company in the supply chain, we commit to engage with suppliers, central or local governmental authorities, international organizations, civil society and affected third parties, as appropriate to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
The Members and staff of Skomboys Refineries will be required to confirm their commitment and compliance to Skomboys Refineries Policy.
Suppliers and Customers confirm their commitment and compliance to Skomboys Refineries Policy through the signature of the Supplier and Customer Application Form.