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Mastoloni Pearls

Sustainability and Responsible Business Practices

Policy Commitments

Responsible Jewellery Council (RJC) policy

Mastoloni Pearls is a member of the Responsible Jewellery Council (RJC).

The RJC is a standards-setting organisation established to advance responsible ethical, human rights, social and environmental practices throughout the gold, silver, platinum group metals, diamond and coloured gemstone jewellery supply chain.

The RJC has developed a benchmark standard for the jewellery supply chain and credible mechanisms for verifying responsible business practices through third-party auditing.

As an RJC member we commit to operating our business in accordance with the RJC Code of Practices Standard. We commit to integrating ethical, human rights, social and environmental considerations into our day-to-day operations, business planning activities and decision-making processes.

Human and Labour Rights

We are committed to respecting all human rights in our own operations and business relationships in accordance with the Universal Declaration of Human Rights (UDHR), the UN Guiding Principles on Business and Human Rights and relevant conventions of the International Labour Organization (ILO). Our human rights policy covers the following key commitments:

  • All forms of violence and harassment in the workplace are prohibited, including but not limited to corporal punishment; harsh or degrading treatment; sexual or physical harassment; mental, physical, verbal or sexual abuse; retaliation; coercion; and intimidation. Both direct and indirect harassment in any form is not acceptable in workplace facilities. We commit to ensuring that our employees are not subjected to harassment or violence, or threatened with these towards themselves, their family or colleagues.
  • To never engage in or knowingly support child labour (including the worst forms of child labour) as defined by International Labour Organisation (ILO) conventions 138 and 182;
  • To never engage in or knowingly support forced labour as defined by International Labour Organisation (ILO) convention 29, including bonded labour, deceptive recruitment, human trafficking and indentured or involuntary prison labour.
  • To provide a safe and healthy working environment for all employees;
  • To treat employees with dignity and respect, which includes:
    • Ensuring fair and transparent discipline and grievance procedures.
    • Recognising and respecting the right of all employees to associate freely and enter into collective bargaining.
    • To provide all employees with fair terms of employment and legally mandated benefits.
    • To prohibit all forms of discrimination, including but not limited to discrimination based on race, colour, ethnicity, caste, national origin, religion, disability or genetic information, gender, sexual orientation, union membership, political affiliation, marital status, parental or pregnancy status, physical appearance, HIV status, age or any other personal characteristic unrelated to the inherent requirements of the work.
  • To promote human rights in our dealings with business partners and other relevant stakeholders.
  • Mastoloni Pearls expects all of its employees, suppliers and sub-contractors to take steps to ensure that this policy is adhered to.

Bribery and Corruption

 

We prohibit bribery and corruption in all business practices and transactions carried out by employees and by agents acting on our behalf. For the purpose of this policy, bribery is defined as giving, offering or receiving any undue advantage to or from:

  • A public or government official;
  • A political candidate, party or official; or
  • Any private sector employees, directors or officers, or their agents or representatives.

Anti-Money Laundering and Finance of Terrorism

We commit to not engaging in or contributing to money laundering or the finance of terrorism. Mastoloni Pearls has implemented Anti-Money Laundering (AML) and Know Your Counterparty (KYC) procedures to:

  1. Establish the identify of all counterparties;
  2. Verify that counterparties and, if applicable, beneficial owners are not named on relevant government lists for individuals or organisations implicated in money laundering, fraud or involvement with prohibited organisations and/or those financing conflict;
  3. Maintain an understanding of the nature and legitimacy of the businesses operated by counterparties and;
  4. Monitor transactions for unusual or suspicious activity.

Environmental Management

 

We commit to reducing and managing the environmental impacts of our business operations through the implementation of an Environmental Management System (EMS). This includes:

  • The responsible management of all wastes and emissions to air, water and land.
  • Establishing energy and water efficiency measures.
  • Seeking to ensure the responsible and efficient use of other natural resources, where applicable.

Product Disclosure

 

We will not knowingly make any untruthful, misleading or deceptive representation, or make any material omission in the selling, advertising or marketing of jewellery products and materials. We further commit to disclosing information on the physical characteristics of jewellery products and materials in accordance with the Responsible Jewellery Council (RJC) Code of Practices Standard.

 

Conflict Diamonds

 

We will not knowingly buy or sell Conflict Diamonds[1] and require that all of our suppliers of diamonds comply with the requirements of the Kimberly Process Certification Scheme (KPCS) and World Diamond Council System of Warranties (SoW).

Supply Chain Policy – Conflict-Affected and High-Risk Areas

Mastoloni Pearls expects all of its employees, suppliers and sub-contractors to do their due diligence in all areas of the supply chain process.

  1. This policy confirms our commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.
  2. As a member of the Responsible Jewellery Council (RJC), we commit to proving, through independent third-party verification, that we:
    1. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;
    2. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
    3. support transparency of government payments and rights-compatible security forces in the extractives industry;
    4. do not provide direct or indirect support to illegal armed groups;
    5. enable stakeholders to voice concerns about the jewellery supply chain; and
    6. 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.
  3. We also commit to using our influence to prevent abuses by others.
  4. Regarding serious abuses associated with the extraction, transport or trade of gold and diamonds: 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.
  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 non-state armed groups: We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gold and diamonds 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 gold and diamonds are traded and upstream actors in the supply chain; or
    2. tax or extort money, or minerals at mine sites, along transportation routes or at points where gold and diamonds are traded, or from intermediaries, export companies or international traders.
  7. 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.
  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 and diamonds: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold and diamonds, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold and diamonds.
  10. 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 gold and diamonds.

 

Raymond Mastoloni, Partner and Co-owner is responsible for supply chain compliance.

raymond@mastoloni.com

Date: 03/11/2022

Grievance procedure

Mastoloni Pearls has established this procedure to hear any concerns or complaints from interested parties and stakeholders regarding its supply chain, human rights practices and business practices.

Concerns can be raised by interested parties via email using the following contact information:

Name: James Mayer

Email: jmayer@mastoloni.com

 

On receiving a complaint, we will aim to:

-- contact you as soon as possible to gather more information regarding your grievance, where applicable;

-- decide who is the appropriate person internally to handle the grievance, or help redirect you to another entity, such as a relevant company, industry body or other organisation;

-- identify any actions we should take (if any), or monitor the situation;

-- advise you of any decisions or outcomes; and;

-- keep records on grievances received and the internal process followed to address such grievances, for at least five years.

 

Name: James Mayer

Position: Controller, Mastoloni Pearls

Date approved: 03 March 2022

Return Policy and Warranty

Consumers – Returns

1. Mastoloni is a wholesale jewelry manufacturer and cannot sell directly to consumers; as such, Mastoloni cannot accept returns directly from consumers.

2, Returns must be made to the authorized Mastoloni retailer from which the consumer purchased their Mastoloni merchandise. It is dependent upon the retailer and the retailer’s return policy as to whether the consumer’s Mastoloni merchandise is eligible for return.

 

Retailers – Returns

Mastoloni accepts wholesale merchandise returns from retailers up to 30 days from the date the merchandise was received. A return authorization is not required.

Wholesale merchandise that does not fall within the 30-day period is not eligible for return unless a return authorization has been issued. Retailers must contact their Mastoloni sales representative to request an RA number.

Return Authorizations are dependent upon the below factors:

-- Account balance must be current

-- Only current merchandise is eligible for return

-- RAs must be accompanied by a non-cancelable sales order for at least 3 times the dollar amount of the requested credit / return

-- Proof of purchase required

 

Warranty – Consumers

Mastoloni offers a one-year manufacturer's warranty for defective merchandise. Mastoloni cannot accept or replace defective merchandise directly from consumers.

Replacement or repair of defective merchandise must be facilitated through the authorized Mastoloni retailer from which the consumer purchased the merchandise. Proof of purchase required.

Normal wear-and-tear or defects caused by the consumer such as improper storage or cleaning of the merchandise does not fall under the manufacturer’s warranty, and replacement or repair of the merchandise is subject to charge.

Mastoloni will determine, upon receipt of defective merchandise, whether the merchandise is eligible for replacement or repair under the one-year manufacturer’s warranty.

 

Warranty – Retailers

Mastoloni offers a one-year manufacturer's warranty for defective merchandise. Proof of purchase required.

Normal wear-and-tear or defects caused by the consumer such as improper storage or cleaning of the merchandise does not fall under the manufacturer’s warranty, and replacement or repair of the merchandise is subject to charge.

Mastoloni will determine, upon receipt of defective merchandise, whether the merchandise is eligible for replacement or repair under the one-year manufacturer’s warranty.

 

Repairs and Restringing – Consumers

Mastoloni cannot accept merchandise for repair or restringing directly from consumers. The authorized Mastoloni retailer from which the merchandise was purchased must facilitate the repair or restringing on the consumer’s behalf. The cost associated with the repair or restringing is up to the discretion and policies of the retailer.

 

Repairs and Restringing – Retailers

Repairs and restringing not covered under the one-year manufacturer’s warranty are subject to charge. Repairs and restringing require proof of purchase; Mastoloni does not restring pearl strands that are not Mastoloni pearls. Mastoloni does not restring imitation pearls.

Mastoloni will determine, upon receipt of the merchandise, the cost associated with the repair or restringing. Repair and restringing estimates are provided prior to the completion of the repair.