JMD SILVER, S.L as a member of RJC, defines a series of ethical, human rights, social and environmental policies or principles that are integrated into daily activities and form part of business decision making, thus committing to implement and develop responsible business practices consistent with the RJC Code of Practice in an ethical and professional manner.
Our RJC policy is summarised in 10 general principles:
1. We are committed to conducting all our business activities in an ethical and professional manner, in accordance with all applicable national and international laws and regulations.
2. JMD SILVER, S.L. is committed to maintaining the highest standards of financial integrity for the benefit of all our stakeholders, rejecting corruption, bribery, financing of political parties, armed groups or money laundering.
3. All our activity will observe the most absolute respect for the Universal Declaration of Human Rights, as well as all the principles relating to the rights established in the Declaration of the International Labour Organisation and the Fundamental Principles and Rights at Work, extending this commitment to our suppliers and other business partners.
4. As far as possible, our company, our suppliers and their customers will avoid direct or indirect transactions with any country considered to be a conflict-affected and high-risk area (CAHRA), tax haven, risk country or country with a significant corruption index.
5. JMD SILVER, S. L undertakes to respect at all times the labour regulations in force, both national and international, and will require suppliers and third parties to comply with them, insisting especially on the development of overtime not exceeding the national limit allowed per week on a regular basis, in the establishment of measures for the prevention of occupational hazards, including consultation and participation of workers, equal opportunities, equity, diversity and inclusiveness, and rejecting discrimination on the grounds of sex, age, race, religion, origin or disability and other legally established circumstances.
6. The management of JMD SILVER, S.L, declares its policy of zero tolerance towards money laundering, terrorist financing, support for non-state armed groups, bribery, corruption, smuggling, embezzlement, fraud and organised crime.
7. All employees of JMD SILVER, S.L. will be treated with equality, respect and dignity. Child labour or forced labour will not be tolerated, neither in the premises of JMD SILVER, S.L. nor in those of its suppliers or customers.
8. JMD SILVER, S.L. rejects any form of sexually coercive, threatening, abusive or exploitative behaviour.
9. JMD SILVER, S.L is committed to the efficient use of natural resources, progressive reduction of discharges and emissions, as well as minimizing waste generation through efforts that include recycling, reuse and recovery; innovation, promoting the use of renewable energy or less polluting and pollution prevention.
10. In compliance with our commitment to the development of the communities in which we operate, JMD SILVER, S.L. will carry out all relevant actions and efforts to obtain a similar commitment from its business partners.
These general principles are developed below in our RJC policy.
Financial and compliance policy.
All personnel are expected and encouraged to comply with all applicable laws and regulations, as well as with all internal rules and policies of the entity related to its business and activities. It is also the responsibility of staff to know and understand the legal, regulatory and internal requirements that apply to their jobs.
JMD SILVER, S.L. undertakes to comply with all generally accepted accounting principles in the country where we operate. Thus, all accounting records, and the reports produced from those records, will be maintained and presented in accordance with the laws of each applicable jurisdiction.
JMD SILVER, S.L. will not finance political parties, their foundations, representatives or candidates, or sponsor any event whose sole purpose is political propaganda and this could lead to a benefit in their business transactions.
As far as possible, our company, our suppliers and their clients will avoid doing business directly or indirectly with any country considered a tax haven, risk countries or countries with a significant level of corruption. In the event of any relationship with suppliers or clients operating in these countries, they will be subject to intense vigilance to ensure compliance with the legislation and all the commitments included in the responsible practices policy.
The management of JMD SILVER, S.L. undertakes to carry out an annual review of its entire RJC system, evaluating the application criteria and its results and generating a report whose summary of the most relevant aspects will be published for the knowledge of all its business partners.
Business partner policy
JMD SILVER, S.L. will assess its business partners based on the OECD's five-step framework and its gold supplement for responsible supply chains of minerals from conflict-affected and high-risk areas (CAHRA), as well as on the practices and recommendations published by the WDC Sow and the regulations in force at any given time in relation to money laundering and terrorist financing, labour regulations and risk prevention and environmental regulations. It will disregard any business relationship that poses a risk to human rights or any of the principles included in this RJC policy.
As far as possible, our company, our suppliers and their customers will avoid direct or indirect transactions with any country considered to be a tax haven, risk country or country with a significant corruption index. In the event of any relationship with suppliers or customers operating in these countries, they will be subject to intense vigilance to ensure compliance with the legislation of all commitments included in the responsible practices policy. In the event that our business partners are forced to work with third parties resident in these countries, they must justify this decision and / or demonstrate that despite being located in these geographical areas, there is no risk to the violation of any of the principles included in our policy. being JMD SILVER, S.L. empowered to, at any time, terminate the business relationship with the third party.
JMD SILVER, S.L. undertakes to disseminate this policy to its suppliers and customers, as well as employees, thus promoting the development of good practices.
Human rights policy
All activities carried out by JMD SILVER, S.L., directly or indirectly through its business partners, will always conform to the strict respect of the fundamental rights included in the Universal Declaration of Human Rights, as well as all the principles relating to the rights set out in the Declaration of the International Labour Organisation and the Fundamental Principles and Rights at Work.
The company should always obtain its material from legitimate sources and ensure compliance with the OECD guideline on Conflict-Affected and High-Conflict Risk Areas - CAHRAs.
Regarding abuses associated with the extraction, transport or trade of gold, our suppliers and customers will not tolerate or take advantage in any way of: torture, forced labour, any form of child labour, human rights violations and abuses and war crimes.
JMD SILVER, S.L. supports and promotes initiatives aimed at improving the quality of life of the communities and groups in which it operates through sponsorship and/or through awareness-raising or other forms of collaboration, thus contributing to their social and economic well-being, respecting the environment in all our activities and opting for local growth, thus guaranteeing our commitment to the development of the communities in which we operate.
Labour policy
JMD SILVER, S.L. undertakes to:
- Respect their fundamental rights in compliance with the Royal Legislative Decree 2/2015, of 23 October, which approves the revised text of the Law of the Statute of Workers.
- Respect at all times the labour regulations in force, both national and international, and shall require Suppliers and third parties to comply with the regulations relating to Occupational Risk Prevention, identifying, through assessments of business partners, irresponsible practices that may lead to the termination of commercial collaboration.
- Not require employees to work more than the national limit of hours in a week on a regular basis, with overtime not exceeding the national limit allowed per week on a regular basis, unless there are legal exceptions.
- Promote equal opportunities for all employees in the organisation by equally providing the necessary means for professional development.
- Prevent harassment in the workplace by having a whistle-blowing channel and a harassment protocol.
- Ensure the diversity, equity and inclusiveness of the workforce and the elimination of all types of discrimination based on gender, age, race, religion, origin or disability and other legally established circumstances.
- Guarantee healthy working spaces and conditions for employees, complying at all times with the regulations on occupational risk prevention.
- Guarantee gender equality and the rights of people with disabilities in all its actions.
- To facilitate the reconciliation of work and family life.
- Efficiently manage the organisation's knowledge and provide its employees with the necessary training to carry out their work.
- Guarantee decent salaries in accordance with the different jobs, with no differences between salaries based on gender.
- Support freedom of association and the effective recognition of the right to collective bargaining for our workers, and facilitate the necessary actions leading to compliance with national legislation. Where required, give due recognition to the existence, membership and lawful activities of workers’ representative bodies, and give workers’ representatives access to carry out their responsibilities/functions.
- Guarantee equal treatment to all employees without any discrimination, distinction or exclusion based on race, colour, sex, religion, political opinion, nationality of origin, social background, physical or mental disability.
We will promote at all times a respectful and egalitarian work environment, applying JMD SILVER, S.L. the appropriate disciplinary measures if it verifies the existence of any situation of harassment, intimidation or any other form of humiliation, also reporting the facts to the competent authorities.
Money laundering prevention policy
Money laundering is the crime of concealing the origin of illicitly obtained proceeds. It is a crime that is often related to other serious crimes, such as drug trafficking, robbery with violence or extortion. In Spain, Law 10/2010 of 28 April 2010 regulates the prevention of money laundering.
The management of JMD SILVER, S.L, determines and subscribes to its policy of prevention of money laundering and terrorist financing for which it establishes the following principles and commitments:
● We are committed to rigorous compliance with all national and international laws and regulations relating to money laundering, terrorist financing, bribery, corruption, smuggling, embezzlement, fraud, organised crime, transfer pricing and tax evasion in all locations in which we operate.
● We strongly reject and disassociate ourselves from any direct or indirect association with non-state armed groups.
● We have a zero tolerance policy towards bribery, misrepresentation of the origin of materials and precious stones and money laundering.
● JMD SILVER, S.L. refrains from supporting security forces involved in abuses or illegal activities, encouraging compliance with ethical standards and responsible practices.
● All JMD SILVER, S.L. customers will be subject to admission criteria linked to our KYC, which involves obligations of identification, origin and declaration of business practices, allowing us to detect warning signs and qualify potential high-risk customers.
● We are committed to training and mentoring all our staff in the prevention of money laundering and the financing of terrorism.
● JMD SILVER, S.L. is committed to collaborating with authorities, reporting any suspicious money laundering operation.
● As part of our process, JMD SILVER, S.L. will carry out periodic reviews (at least annually), checking its policy, procedures and transactions and money movements, analysing operations that are considered suspicious and informing the authorities of these, where appropriate.
Policy on equality, harassment, child and forced labor
JMD SILVER, S.L. rejects any form of discrimination related to hiring, firing, pay, promotion and training of employees on the basis of race, ethnicity, caste, national origin, religion, age, disability, gender, marital status, physical appearance, sexual orientation, HIV status, migrant status, membership in workers' representative bodies, political affiliations or any criteria that is unlawful. Any reported incident will be viewed as a serious violation of these Corporate Responsibility Policies.
JMD SILVER, S.L. rejects any form of sexually coercive, threatening, abusive or exploitative behavior. Any reported incident related to physical, sexual, racial, religious, psychological, verbal or any other form of direct or indirect harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by JMD SILVER, SL.
Where necessary, the existence, membership and legitimate activities of workers' representative bodies will be duly recognized, and workers' representatives will be given access to carry out their responsibilities/functions.
Under no circumstances, child labor will be tolerated, nor forced or involuntary labor, both in the development of its activity and by any of its suppliers or customers, as well as JMD SILVER, S.L. will not tolerate or benefit from the abuses associated with the extraction, transport or trade of gold, immediately ceasing to collaborate with any supplier or customer that is considered a risk with respect to the above abuses. The knowledge that any of the business partners supports these practices directly or indirectly as, for example, by establishing business relationships with those who practice or allow them, will result in the immediate interruption of all types of business relationships.
Environmental policy
JMD SILVER, S.L. will annually carry out the activities of identification and evaluation of environmental aspects and direct and indirect impacts generated by all its processes, products and services.
JMD SILVER, S.L. is committed to the efficient use of natural resources, progressive reduction of discharges and emissions, as well as minimizing waste generation through efforts that include recycling, innovation, promoting the use of renewable or less polluting energy and pollution prevention.
We encourage the education and training of all employees to promote legal compliance, participation in continuous environmental improvement and the transfer of these principles to the communities in which we operate.
Provide human, economic, structural and organizational resources to carry out environmental management based on international standards, as well as compliance with this Policy.
Information and Communication
The designation of items shall be clear and unambiguous, following the recommendations of the CIBJO Blue Books and the World Diamond Council in all its advertising documents, web, invoice, receipts, certificates or other documentation related to the sale. Neither JMD SILVER, S.L. nor any of its employees shall make any misuse of terminology or misleading representations in the materials or items.
JMD SILVER, S.L. undertakes to make through its various communication channels its best efforts to contribute to the awareness of business partners and the general public of good practices related to our RJC policy.
COMMUNICATION CHANNEL
JMD SILVER, S.L. provides through its website and postal mail a whistleblower channel through which anyone can express their suggestions, complaints or concerns regarding any aspect of this RJC policy and linked to our company or its supply chain, as well as report situations of harassment, suspected money laundering, bribery attempts, facilitation payments or inappropriate gifts, any of these situations may be grounds for termination of any professional relationship.
No employee who reports a situation such as any of those described, suffer retaliation, demotion or penalty of any kind for expressing a concern or for refusing to pay or receive a bribe or facilitation payment or obtain a gift or similar, even if this action may result in loss of business for JMD SILVER, SL.
Anonymous reporting will be allowed when desired, ensuring confidentiality and reserved treatment.
The enabled channels are:
Through e-mail: contabilidad@jmdsilver.com
or by post to our address:
JMD Silver S.L.U. ®
C/ Esmeralda, E9, Módulo 2, 14014, Córdoba, Spain
All information received through it will be collected by the RJC Coordinator and treated with the utmost confidentiality.