top of page

About

Responsible Sourcing Policy

Policy objective: 


The objective of this policy is to set out the commitments by Diaco regarding the responsible sourcing, procurement, trading, and use of key jewelry materials in its supply chain. The company aims to be a trusted and transparent supplier, making continuous progress towards responsible sourcing leading practices. This includes efforts to respect human rights, protect the environment, and ensure ethical business conduct. 


Scope and Definitions: 


This policy applies to Diaco Inc. and all its business relationships in the supply chain. It includes suppliers with whom the company has a contractual relationship, The policy covers the procurement and use of key materials used in the manufacture of jewelry, including diamonds, colored gemstones, precious metals, and other relevant materials. 


Key policy commitments: 

​

  1. The company will not knowingly sell, trade, or use jewelry raw materials that originate from sources involved in conflict, bribery, fraud, money laundering, or the funding of terrorism. This commitment will be disclosed in the company’s sales or purchase documentation and in signed agreements with business partners. 

  1. The company is committed to conducting business with respect for human rights and implementing human rights and environmental due diligence across its operations and value chain. It aims to raise awareness, share and expect compliance to its policies, procedures, and standards within its value chain. 

  1. The company will disclose the characteristics and any treatments on goods sold to customers. It will not engage in false marketing or communication of its products. 

  1. The company reserves the right to terminate commercial relationships with business partners that fail to meet its due diligence standards or breach its policies. However, the company will first engage with these partners to support and push them to improve their practices. 

  1. The company will make efforts to exclude materials originating from sources that carry severe risks to human rights and the environment. It will actively drive and support its supply chain partners to meet global and industry standards. 

  1. The company will not buy diamonds from sources that have violated government regulations restricting the trade of diamonds from conflict-affected or high-risk countries. 

  1. The company will not buy diamonds from regions subject to legal rulings or advisories indicating the presence of conflict diamonds, unless the diamonds have been exported in compliance with the Kimberley Process. 

  1. The company will provide comprehensive and repeated training and information to its employees regarding the sourcing of diamonds, trade resolutions, and government regulations. 

  1. The company will ensure that customer invoices include assurances related to the quality, provenance, and adherence to the Kimberley Process. 

  1. The company recognizes the risk of conflict diamonds in the supply chain and defines conflict diamonds based on relevant United Nations Security Council resolutions. It maintains an active risk-based exclusion list to mitigate these risks. 

  1. The company acknowledges the WDC-SOW as a voluntary system of industry self-regulation and commits to adhering to its guidelines in the sourcing of diamonds. 

Human Rights Policy

As a fundamental operating principle, we strive to respect human rights wherever we do business. We are committed to doing no harm, to avoiding infringing on the human rights of others, and to addressing adverse human rights impacts where they may be caused, contributed by, or linked to our activities. 

 

We will: 

​

● Seek to avoid causing or contributing to adverse human rights impacts through our own activities, and address such impacts if they do occur in a timely and appropriate manner;

● Seek to prevent or mitigate adverse human rights impacts that are directly related to our operations, products and services through our business relationships; 

● If we identify that we have caused or contributed to adverse human rights impacts, provide for or cooperate in their remediation through legitimate processes; and,

● Continue to look for ways to support the promotion of human rights within our operations and our sphere of influence.

 

Our commitment is guided by the principles set forth in laws of the United States of America governing human rights, as well as in the following international standards: 

● Universal Declaration of Human Rights;

● International Covenant on Civil and Political Rights;

● International Covenant on Economic, Social and Cultural Rights;

● International Labour Organization’s (ILO’s) Declaration on Fundamental Principles and Rights at Work;

● Guidelines for Multinational Enterprises of the Organization for Economic Cooperation and Development (OECD);

● United Nations (UN) Guiding Principles on Business and Human Rights;

 

Where national law and international human rights standards differ, we will follow the higher standard; where they are in conflict, we will adhere to national law, while seeking ways to respect international human rights to the greatest extent possible.

 

Assessing human rights risks and impacts

We recognise that we must take steps to identify and address any actual or potential adverse impacts with which we may be involved whether directly or indirectly through our own activities or our business relationships. We manage these risks by integrating the responses to our due diligence into our policies and internal systems, acting on the findings, tracking our actions, and communicating with our stakeholders about how we address impacts.

 

Due diligence process to identify, prevent, mitigate, account and remediate human rights impacts

We understand that human rights due diligence is an ongoing process that requires particular attention at certain stages in our business activities, such as when we form new partnerships or our operating conditions change, as these changes may create new potential or actual impacts on human rights. We understand that this means that we must put in place additional due diligence measures to assess these risks and address them effectively, where appropriate, using our leverage to work either in one-to-one relationships or in broad-based partnerships. We recognise the importance of dialogue with our employees, workers and external stakeholders who are or could potentially be impacted by our actions. We pay particular attention to individuals or groups who may be at greater risk of negative human rights impacts due to their vulnerability or marginalization and recognise that women and men may face different risks. 

 

Remedy 

​

We place importance on the provision of effective remedy wherever human rights impacts occur through company-based grievance mechanisms. We continue to build the awareness and knowledge of our employees and workers on human rights, including labour rights, by encouraging them to speak up, without retribution, about any concerns they may have, including through our grievance channels. We are committed to increasing the capacity of our management to effectively identify and respond to concerns. We also promote the provision of effective grievance mechanisms by our suppliers.

 

Monitoring human rights impacts

​

We seek to establish relationships with entities that share the same principles and values. We promote human rights awareness and respect along our value chain, including the adoption of legal contractual clauses. We will seek to monitor our human rights performance and the performance of our suppliers through audits.

Social Impact Annual Report 2024

Diaco Inc. is a jewelry wholesale company. This policy reconfirms our commitment to respect human rights, avoid contributing to the finance of conflicts and compliance with all relevant UN sanction s, resolutions and laws.

 

Diaco Inc. is a member of the Responsible Jewellery Council (RJC) and are currently going through the initial assessment process.

This is expected to be completed during the last quarter of 2024.

 

As such, we committed to demonstrating, through independent third-party verification, that we respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Fundamental Rights at Work and as such we:

 

- do not engage in or support 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 enable stakeholders to voice concerns about the jewellery supply chain.

- have implementing the OECD 5-Step framework within our management system that addresses due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

 

We shall send out yearly our information gathering forms to our suppliers.

We commit to working with uncompliant suppliers who are committed to changing their business practices to adhere to our compliance standards in a reasonable and timely manner. If non-compliant suppliers are unwilling or unable to meet our standards

we will discontinue further business with them. Any concerns any person has with Diaco Inc. or any of our business partners can address them anonymously through our grievance system and process.

 

Regarding serious abuses associated with the extraction, transport or trade of diamonds/colored gemstones We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

- torture, cruel, inhuman and degrading treatment

- forced or compulsory labour

- the worst forms of child labour

- human rights violations and abuses; or war crimes, violations of international humanitarian law, crimes against humanity or genocide.

 

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described above or linked to any party committing these abuses.

 

Regarding direct or indirect support to non-state armed groups, our suppliers only purchase diamonds or that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

- control mine sites, transportation routes, points where diamonds/colored gemstones are traded and upstream actors in the supply chain; or

- tax or extort money or diamonds/colored gemstones at mine sites, along transportation routes or at points where diamonds and colored gemstones are traded, or from intermediaries, export companies or international traders.

We shall 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 nonstate armed groups.

Regarding bribery and fraudulent misrepresentation of the origin of diamonds or colored gemstones we will not of fer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of diamonds or coloured gemstones, or to mis represent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of diamonds.

 

Money laundering :

We shall support and contribute to ef forts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of diamonds or coloured gemstones.

 

Employment :

Compliance is ensured at all times, with applicable national and, where appropriate, international laws and regulations with respect to employment and labour. We 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 workers and provide some discretionary income.

 

Health & Safety

Diaco Inc.  recognizes the need to develop 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. 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.

 

 

Human Rights

All employees in Diaco Inc.’s facilities will be treated with equality, respect and dignity. Diaco Inc. shall 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.

We strongly discourage 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. Annual sexual harassment trainings will be given to all employees.

 

Non-Discrimination & Disciplinary Practices

Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, gender, 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 Business Principles. We shall assure all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully.

 

Child Labor

Diaco Inc. do not engage in, or support the use of child labour and as such no child labour shall be employed at our organization.

 

Forced & In-Human Labour

The management of Diaco Inc. is fully committed to ensuring that forced or involuntary labor is not practiced in any form at any of its facilities or facilities it does business with. Any reported incidents relating to forced labour shall be considered as a serious violation of this policy and against US law. Examples of behavior that falls into the category of Forced and inhuman labour are:

- any forms on f torture

- cruel, inhuman or degrading treatment

- other gross human rights violations and abuses, such as widespread sexual violence and war crimes

 

Environmental

Diaco Inc. are 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.

 

Product Security

Diaco Inc. are committed to provide safety of product throughout its supply chain by following precautions as mentioned below:

- there is blanket insurance on our facility

- suitable safeguarding and storage is ensured at all stages with

the help of safes and security personnel.

All personnel connected with product safety have been trained on documented procedures.

 

Metal Sourcing Policy

Diaco Inc. are concerned about the environment and social impacts of irresponsible mining. We ensure to the best of our ability that all our suppliers comply with sourcing guidelines. Further we here by certify that all Gold is Fair mined.

Certify and independently audit that all gold supplies are in accordance with the RJC Chain of Custody Standard for precious metals, OECD due diligence guidance for responsible supply chains of minerals from conflict-affected and high-risk areas, or world gold council conflict free standard. That none of the metal in our product is being sourced from Conflict Affected and High-Risk Areas.

 

Anti-Money Laundering & Terrorism Financing

Diaco Inc. recognizes that the fact that entities in the gem 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 ensured at all times, with all applicable national and, where appropriate, international laws and regulations with respect to money laundering, terrorism financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing, and tax evasion. We follow a documented due diligence system and process.

 

Diamond Sourcing - Kimberley Process & System of Warranties

Diaco Inc. are fully committed to complying with all the requirements specified in the Kimberly process certification scheme and world Diamond Council’s System of Warranties Declaration. The definition of “Conflict Gemstone Diamonds” as agreed by the Kimberly Process has been adopted and declarations are received from suppliers and issued to all Customers.

 

Gemstone Sourcing

Diaco Inc. are concerned about the environment and social impacts of irresponsible gemstone mining. We ensure to the best of ourability that all our suppliers with responsible sourcing guidelines. We conduct due diligence on our suppliers to ensure that no gemstones are being supplied from Conflict Affected and High-Risk Areas

 

Anti-Bribery & Facilitation Payments

Diaco Inc. shall ensure complete Prohibition of Bribery Facilitation payment across organization and in all entities and this is also not allowed under IS law.

We shall not offer, accept or countenance any payment, gift, in kind, hospitality, and expense or promises as such that may compromise promises of fair competition. Periodic training and awareness shall be carried out to educate employees about various types of bribery and facilitation payments.

 

OECD Due Diligence

Our KYC supplier information form is combined with our Supply Chain Due Diligence, Human Rights Policy, Precious Metal and diamond ethical sourcing policy.

We have integrated the 5 step process into our management system and as such are normal and routine processes that are adhered to.

Supply Chain Policy

Diaco Inc. is a Importer- exporter and Traders of Diamonds. This policy confirms Diaco Inc.’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

 

Diaco Inc. commit to proving, through independent third-party verification, that we:

  1. respect human rights according to the Universal Declaration of Human Rights and International Labor 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 jewelry 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.

 

We also commit to using our influence to prevent abuses by others.

 

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 labor;

  3. the worst forms of child labor;

  4. human rights violations and abuse; or

  5. war crimes, violations of international humanitarian law, crimes against humanity or genocide.

 

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.

 

Regarding direct or indirect support to non-state armed groups: We only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring 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 diamonds are traded and upstream actors in the supply chain; or

  2. tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders.

 

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.

 

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.

 

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.

 

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.

 

Grievance Reporting Person: Mr. Minesh Shah

Email - ID: minesh @ diaco.ca 

Note: Interested parties, including affected stakeholders and whistle-blowers can raise concerns about the business, organisations, individuals or activities in its supply chains. Management will extend full support to employees / associates who report and themselves does not participate in bribery, human right violation or any unethical practices.

© 2025 by Diaco Inc.

​

bottom of page