RJC Membership
We are proud to be a Certified Member of the Responsible Jewellery Council (RJC). This means our business has been independently audited and certified against the RJC Code of Practices, covering human rights, ethical sourcing, environmental care, and responsible business practices. Our membership demonstrates our commitment to transparency, integrity, and sustainability across the jewellery and watch supply chain.
Commitment to RJC Code of Practices
- Setting the standard for ethical excellence.
We commit to operating in accordance with the RJC Code of Practices Standard. This means integrating ethical, human rights, social, and environmental considerations into our:
- Daily operations
- Business planning
- Long-term decision-making
Human and Labour Rights
- Respecting people, valuing diversity.
We uphold and respect internationally proclaimed human rights. Our commitments include:
- Providing equal employment opportunities
- Treating all employees with dignity and respect
- Ensuring a workplace free from discrimination and harassment
Environmental Responsibility
- Protecting the planet for future generations.
We are committed to minimising environmental impact by:
- Reducing waste in production and packaging
- Conserving natural resources
- Promoting sustainability across our supply chain
Product Integrity
- Authenticity and trust in every piece.
We ensure that our jewellery is:
- Responsibly sourced
- Transparent in supply chain origins
- Authentically represented in quality and craftsmanship
Community Engagement
- Giving back where we work and live.
We aim to positively impact communities by:
- Supporting local traditions and rights
- Contributing to social and economic development
- Building meaningful relationships with local people
Continuous Improvement
- Always evolving for a better tomorrow.
We are committed to continuous improvement through:
- Regular audits and assessments
- Aligning with evolving ethical standards
- Listening to stakeholder expectations
Policy and Management Systems
RJC Policy and Management Systems to Responsible Business Practices
Minar Jewellers and Pravin A Pattni Jewellers., trading as Pravin A Pattni Limited is committed to conducting its business in a responsible, transparent, and ethical manner.
· This policy is endorsed by top management.
· It is communicated to all employees and stakeholders through meetings, training sessions, and internal notices.
· It is made publicly available through company channels (https://www.minarjewellers.com/pages/ethical-policy, reception noticeboard, etc.).
Documented Management Systems
Minar Jewellers has developed and implemented management systems that:
· Align with all applicable requirements of the RJC Code of Practices (COP).
· Cover ethical sourcing, human rights, labour practices, health & safety, environmental responsibility, product integrity, and responsible business conduct.
· Are documented and reviewed periodically to ensure effectiveness.
Responsibility and Authority
A designated senior staff member is responsible for ensuring compliance with all applicable COP requirements.
· This individual has the authority to implement necessary processes, monitor adherence, and report directly to top management.
Communication and Training
· All relevant personnel receive training on their responsibilities under the COP.
· Regular awareness sessions are conducted to keep employees updated on company policies, ethical standards, and compliance requirements.
· Training records are maintained as evidence of competence and participation.
Records Management
· Minar Jewellers maintains records covering all applicable COP requirements.
· Records are securely stored and retained for a minimum of five years, or longer if required by national legislation.
· Records include policies, training logs, audit results, supplier assessments, and grievance reports.
Complaints and Grievance Mechanism
Minar Jewellers has established a rights-compatible grievance mechanism that is:
· Transparent, accessible, and confidential. (info@minarjewellers.co.uk, Address,181 Upper Tooting Road, Tooting London, SW17 7TG)
· Designed to address employee concerns, supplier disputes, and external stakeholder queries.
· Provides a fair process for submitting, reviewing, and resolving complaints.
· Managed by a designated grievance officer who ensures timely and effective resolution.
Monitoring, Review, and Continuous Improvement
a Performance Monitoring
· Management systems and grievance mechanisms are regularly monitored and reviewed.
· Performance indicators are evaluated to determine system effectiveness.
· Where gaps are identified, corrective actions are implemented promptly.
b Management Review
· Top management conducts annual reviews of policies, management systems, and business practices.
· Reviews assess the adequacy and effectiveness of systems in meeting RJC requirements.
· Review findings and outcomes are documented, and continuous improvements are implemented to address gaps.
Business Partners and Facility Compliance
Promotion of Responsible Business Practices
· Minar Jewellers is committed to using its best endeavours, commensurate with its ability to influence, to promote responsible business practices among significant business partners.
· Business partners, including suppliers, contractors, and service providers, are expected to uphold principles consistent with the RJC Code of Practices (COP).
· Supplier engagement, due diligence processes, and contractual clauses are used to encourage and strengthen compliance.
Compliance of Workers and Visitors
· All workers, contractors, and visitors entering Minar Jewellers’ facilities are required to comply with the company’s established policies, systems, and procedures relevant to the COP.
· Orientation, training, and awareness materials are provided to ensure compliance.
· Visitors must follow site-specific rules, including health, safety, and security measures.
· Any breaches of these requirements are subject to corrective action in line with company procedures.
Human Rights
Respect for Human Rights
Minar Jewellers recognises and respects all internationally recognised human rights in alignment with the UN Guiding Principles on Business and Human Rights (UNGPs).
The company commits to identifying, preventing, mitigating, and accounting for potential and actual human-rights-related risks and impacts in its operations, business relationships, and communities.
At a minimum, Minar Jewellers shall:
a. Policy Commitment
· Maintain a human rights policy endorsed by top management.
· Implement procedures consistent with COP 2 (Policy and Management Systems) to integrate human rights throughout operations and supply chains.
b. Human Rights Due Diligence
· Establish a due diligence process, including human rights impact assessments, conducted by competent professionals.
· Assess risks based on reliable data and consultations with Affected People or Groups.
· Prevent, mitigate, and address adverse human rights impacts in the RJC Scope Material supply chain and other business activities.
c. Remedy of Adverse Impacts
· Provide or support legitimate mechanisms for remedying adverse human rights impacts caused, contributed to, or linked to the company.
d. Influence with Business Partners
· Use best endeavours to encourage and influence business partners to prevent or mitigate human rights risks and impacts.
e. Complaints and Grievance Mechanism
· Maintain a publicly accessible and effective grievance mechanism for raising human rights concerns and grievances.
f. Monitoring and Review
· Conduct annual reviews of the human rights policy, procedures, and due diligence process to assess effectiveness.
· Take corrective action to address identified gaps or improvement opportunities.
g. Communication and Reporting
· Communicate annually with Affected People or Groups on human rights due diligence activities.
· Publicly report on:
o Methods used to identify human rights issues.
o Identified human rights risks and impacts.
Community Development
Community Support and Development
Minar Jewellers recognises the importance of supporting the social, economic, and institutional development of the communities in which it operates. As a responsible business, we seek to strengthen local communities and contribute positively through active engagement and support of local initiatives.
Our commitment to community development is demonstrated by:
· Providing professional, high-quality services that build trust and loyalty among our clients.
· Supporting and participating in local projects, charities, and networks that improve social well-being and cultural identity.
· Encouraging staff to engage in community initiatives that reflect the company’s values of integrity and responsibility.
Examples of Community Initiatives Supported by Minar Jewellers
· Share: Supporting individuals with disabilities and long-term health conditions by backing their training, education, employability, and personal development programmes.
· Karamsad Samaj UK: Engaging with cultural and community events that preserve traditions while fostering youth involvement (ages 10–35) in combining Eastern culture with modern life in the UK.
· The Tooting Business Network: Contributing to a collaborative forum of small businesses across Tooting that addresses shared challenges and promotes local business resilience.
Through these initiatives, Minar Jewellers demonstrates its commitment to being an integral part of the community and ensuring that its business practices foster long-term social and economic benefits.
Bribery Risk Management Systems
To manage the risk of bribery and corruption, Minar Jewellers has implemented the following systems:
a. Risk Identification and Monitoring
· Regularly assess business operations, transactions, and relationships to identify areas that pose a high risk of bribery.
· Implement controls and monitoring mechanisms to reduce exposure.
b. Training
· Provide training for relevant managers and workers on anti-bribery policies and procedures.
· Reinforce awareness of zero tolerance towards bribery and corruption.
c. Gift Register
· Maintain a register to record all gifts offered and received, including details of value, source, and approval.
· Regularly review the register to ensure compliance with company policy.
d. Whistleblowing Mechanism
· Provide a confidential reporting channel for workers, suppliers, and other stakeholders to raise concerns related to bribery or facilitation payments.
· Ensure protection from retaliation for individuals reporting in good faith.
e. Investigation of Incidents
· Investigate all reported incidents of suspected bribery promptly and fairly.
· Document findings and take corrective measures.
f. Sanctions
Apply strict disciplinary measures, including termination of employment or contracts, against any individual or entity found guilty of bribery or attempted bribery.
Due Diligence for Responsible Sourcing, Know Your Counterparty (KYC), Anti-Money Laundering (AML), and Counter-Terrorism Financing (CTF)
Responsibility and Authority
· Minar Jewellers assigns Mr. Jaysal Pattni as the designated senior staff member responsible for implementing and overseeing the company’s supply chain due
diligence, KYC, AML, and CTF policy and procedures.
· Mr. Pattni shall have full authority to monitor compliance, report to top management, and ensure alignment with applicable laws and RJC Code of Practices requirements.
Due Diligence for Responsible Sourcing, KYC Policy and Procedures
Minar Jewellers maintains a robust and up-to-date Responsible Sourcing KYC policy that includes:
· Verification procedures for customers, suppliers, and other counterparties to ensure legitimate business relationships.
· Regular Training for relevant employees on AML/CTF risks, red flags, and reporting obligations.
· Documentation procedures to ensure complete and accurate records of counterparties are maintained.
· Regular reviews to ensure policies remain effective and reflect changes in legislation, regulations, and industry best practices.
As a jewellery manufacturer, Minar Jewellers are a ‘downstream company’. Therefore, we gather, record and regularly update information on the supply chain (supplier details, including KYC due diligence information; information on the origin, form, type, weight, fineness and physical description of diamonds/coloured gemstones and precious metals, as applicable; evidence of due diligence carried out by upstream suppliers etc.), based on which we conduct a risk assessment and respond to risks. Any CAHRA or other ‘red flag’identified in our supply chain are reported to the above-mentioned designated senior staff member. Further investigation is conducted into the matter (enhanced due diligence), and a plan for managing and responding to actual or potential risks is developed (including taking and monitoring appropriate measures), as applicable. We publicly report on our due diligence efforts once a year.
Red Flags and CAHRAs (Conflict-Affected and High-Risk Areas)
A red flag is a warning or indicator of potential risk or problem within our supply chain. In the context of due diligence, red flags may include concerns related to a supplier, location, or circumstance that require enhanced due diligence — that is, a deeper investigation to ensure responsible sourcing and compliance with international standards.
A Conflict-Affected and High-Risk Area (CAHRA) is defined as an area marked by one or more of the following characteristics:
Minar Jewellers recognizes the importance of identifying CAHRAs to ensure that materials are sourced responsibly and ethically. To support this process, Minar Jewellers consults reputable international resources and databases to identify CAHRAs and assess potential risks in our supply chain.
Resources Consulted for Identifying CAHRAs
Minar Jewellers uses the following sources for reference and verification:
CAHRA List – Official Database of Conflict-Affected and High-Risk Areas
UN Security Council Sanctions Lists
Global Witness – Reports on Conflict Minerals and Human Rights Risks
U.S. Department of State – Country Reports on Human Rights Practices
By regularly consulting these resources, Minar Jewellers ensures that its sourcing practices are aligned with international standards and that all materials are obtained responsibly, minimizing risks related to conflict financing, human rights abuses, and governance failures.
Recordkeeping and Reporting
· Records are maintained for all single or linked cash (or cash-like) transactions equal to or above €10,000 / USD 10,000, or the lower threshold required by applicable law.
· Where legally required, such transactions will be reported to the relevant designated authority in a timely and accurate manner.
· Records will be retained for at least the statutory minimum period or five years, whichever is longer, and will be made available to regulatory bodies upon request.
Commitment to Due Diligence for Responsible Sourcing, AML/CTF Best Practice
· Minar Jewellers is committed to preventing its operations, products, and services from being used for money laundering or the financing of terrorism.
Neither tolerate nor profit from, contribute to, assist or facilitate the
commission of serious abuses associated with the extraction, transport or
trade of diamonds/coloured gemstones (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).
support transparency of government payments and rights-compatible security
forces in the extractives industry; not provide direct or indirect support to illegal armed groups; and implementing the OECD 5-Step framework as a management process for risk-based due diligence for responsible supply chains of minerals, including from conflict-affected and high-risk areas.
· Employees are encouraged and obligated to report any suspicious activity in good faith without fear of retaliation.
SECURITY
Security Risk Assessment and Protection Measures
Minar Jewellers recognises the importance of maintaining strong security controls to safeguard its people, assets, and products. The company is committed to protecting workers, visitors, and personnel employed by business partners from risks associated with theft, damage, or substitution of products.
To achieve this, Minar Jewellers shall:
· Conduct regular security risk assessments to identify potential threats to operations, facilities, exhibitions, events, and shipments.
· Implement appropriate security measures, including surveillance systems, controlled access, secure storage, and tracking systems during product handling and transportation.
· Provide training for staff and relevant business partners on security protocols and procedures.
· Establish clear reporting procedures for any security incident, with prompt investigation and corrective action.
· Collaborate with law enforcement and regulatory authorities where necessary to mitigate risks and ensure compliance with legal requirements.
· Review security measures periodically to ensure their ongoing effectiveness and alignment with industry best practices.
CLAIMS
Management of Business and Product Claims
Minar Jewellers recognises that claims made to business partners, customers, consumers, or the public must be accurate, transparent, and supported by evidence. To uphold this principle, the company has established management systems that ensure:
a. Compliance and Truthfulness
· All claims comply with applicable laws, regulations, and industry standards.
· Claims are truthful and substantiated by reliable and verifiable evidence.
b. Training and Awareness
· Workers responsible for making or supporting claims are trained to understand the claims in detail.
· Staff can explain claims accurately and respond to enquiries with confidence and consistency.
c. Transparency to Stakeholders
· Information about claims will be provided upon request to suppliers, customers, end consumers, and members of the public.
· Minar Jewellers maintains open communication to ensure clarity and trust.
d. Revocation and Corrective Action
· Any claim found to be misleading, untruthful, or unverifiable will be revoked immediately.
· Corrective actions will be taken to prevent recurrence, and Affected People or Groups will be informed of both the revocation and the corrective measures implemented.
Provenance Claims
Minar Jewellers recognises that provenance claims are critical to maintaining consumer trust and confidence in the jewellery industry. The company is committed to ensuring that all provenance claims are accurate, transparent, and verifiable in line with RJC requirements.
Commitments
a. Clarity and Accuracy
· All provenance claims made by Minar Jewellers will be clear, unambiguous, and not misleading.
b. Transparency and Evidence
· Claims will be transparent and supported by verifiable documentation.
· Supporting evidence includes certification and verification from recognised hallmarking offices for the purity of metals and certification bodies for diamonds and laboratory-grown diamonds.
c. Independent Verification
· All provenance claims will be independently verified during an RJC audit and reviewed by the RJC.
· Claims will remain valid only if verified in accordance with applicable standards.
d. Revocation and Notification
· If a provenance claim becomes invalid or untruthful due to operational or external changes, Minar Jewellers will:
o Revoke the claim immediately.
o Take corrective action in line with COP 14.2(d).
o Notify its certification body and the RJC in writing within seven business days, providing details of the situation and evidence of actions taken.
e. New or Amended Claims
· Once certified to the COP, any new provenance claim, or material change to an existing claim, will be independently verified and reviewed in line with COP 14.3(c) before being communicated externally.
General Employment Terms
Legal Labour and Social Security Obligations
Minar Jewellers shall not engage in employment practices that undermine legal labour rights or obligations. Specifically, the company shall not:
· Avoid fulfilling labour and social security obligations, including those established by collective bargaining agreements or other legitimate worker-organising efforts, by using:
o Labour-only contracts,
o False apprenticeship schemes,
o Excessive consecutive short-term employment contracts,
o Zero-hour contracts, or
o Subcontracting or homeworking arrangements designed to evade obligations.
· Hire replacement workers in order to prevent, undermine, or cease a legal strike, support a lockout, or avoid negotiating in good faith.
o Replacement workers may only be hired to ensure that critical maintenance, health and safety, or environmental control measures are maintained during a legal strike.
Citation: Guidance is derived from international labour standards, collective bargaining protections, and Health & Safety and Employment Law Services recommendations.
Employee Records
Minar Jewellers maintains accurate and appropriate records for all employees, whether full-time, part-time, or seasonal.
Records include:
· Proof of identity and age,
· Piece-rate and wage payment records,
· Working hours relevant to the role type,
· Work permits and migration documentation (where applicable).
Records are retained in compliance with statutory requirements and made available for inspection by relevant authorities.
Retrenchment and Collective Dismissals
Prior to implementing any collective dismissals or retrenchments, Minar Jewellers shall:
· Conduct a thorough analysis to explore alternatives to retrenchment.
· Where no alternatives exist, develop a retrenchment plan grounded in the principle of non-discrimination (see COP 22: Non-Discrimination).
· Ensure, where practicable, that the plan minimises adverse impacts on retrenched workers.
· Engage in consultation with workers, their representatives, and, where appropriate, relevant official agencies.
Citation: Procedures for retrenchment are aligned with Health & Safety and Employment Law Services, ILO Convention 158, and RJC COP 22 Non-Discrimination requirements.
Working Hours
Compliance with Legal Standards
Minar Jewellers complies with all applicable national laws on working hours. The normal working week does not exceed 48 hours, excluding overtime. In cases where workers are employed in shifts, average working hours are monitored over a three-week period to ensure compliance with the 48-hour standard.
Overtime Management
Overtime at Minar Jewellers is managed under the following principles:
· Overtime is voluntary, unless specifically required by law or collective bargaining agreements.
· Workers are not forced, coerced, or threatened into overtime work. Refusal to work overtime does not result in penalties or retaliation.
· Overtime is limited to 12 hours per week. Where operational needs require, an average over three weeks ensures compliance with the 12-hour standard.
· Total working hours, including overtime, do not exceed 60 hours per week unless:
o Permitted by law or collective agreements allowing working-time averaging, including adequate rest periods.
o Exceptional circumstances such as production peaks, emergencies, or accidents occur.
o Risk assessments are carried out in consultation with workers (or representatives) to minimise impacts on health, safety, and welfare, in alignment with COP 24 (Health & Safety).
Rest Days
All workers are provided with at least one rest day in every seven consecutive days, in compliance with ILO Convention 14.
Holidays and Leave
Minar Jewellers provides all workers with legally mandated public holidays, annual leave, parental leave, compassionate leave, and sick leave. Where laws do not specify, paid annual leave is provided in line with ILO Convention 132 and parental leave in line with ILO Convention 183. Flexible working arrangements are offered to workers with family responsibilities, regardless of gender.
Breaks and Meal Times
All workers are entitled to breaks for meals and rest periods in line with applicable law. Where law does not exist, workers working more than six hours receive at least one uninterrupted meal break of reasonable duration.
Records Management
Minar Jewellers maintains accurate records of working hours, overtime, and all types of leave (annual, parental, compassionate, and sick leave). These records are securely stored in line with COP 2.5 requirements and retained for at least five years.
Remuneration
Fair Wages and Equal Pay
Minar Jewellers ensures that all workers are paid fairly and in compliance with the law.
· Wages for normal hours worked are based on the higher of:
o The applicable legal minimum wage,
o Collective bargaining agreement minimum wage,
o Prevailing industry standards, or
o A living wage, where possible.
· Workers on performance-based pay receive no less than the above standards for a normal working week.
· Processes are in place to monitor pay equity, ensuring that comparable wages are provided for work of equal value. Any identified wage disparity is promptly assessed and remedied to prevent discrimination against any category of workers.
Overtime Compensation
All overtime hours are compensated at a rate no less than that required by applicable law or collective agreements.
· Where the law does not stipulate overtime premiums, Minar Jewellers applies a minimum of 1.25 times the base wage or aligns with prevailing industry standards.
· Overtime pay is clearly documented in payroll systems and payslips.
Wage Payments and Transparency
Wage payments are carried out in accordance with the following principles:
· Wages are regular, predetermined, and never delayed or deferred.
· Payments are made by bank transfer to an account controlled by the worker, or, where appropriate, in cash or cheque at a location and time convenient to the worker.
· Every worker receives a wage slip that clearly itemises base wages, overtime, deductions, and statutory benefits, presented in a format that is easy to understand.
· For agency, migrant, contingent, or temporary workers, payments are made through systems that guarantee equitable compensation and confirm that wages are effectively received by the worker.
Wage Deductions
Deductions from wages are only permitted where:
· They comply with applicable law or are covered under collective agreements.
· They follow a documented due process that is communicated clearly to workers.
· They do not result in the worker receiving less than the minimum wage.
No Disciplinary Deductions
Minar Jewellers does not make any deductions from wages for disciplinary purposes.
Provisions and Services
Workers are not forced to buy provisions or services from Minar Jewellers.
Where no alternative exists, goods or services are provided at fair and non-excessive rates.
Wage Advances and Loans
Where wage advances or loans are provided, repayment terms and any interest are:
· Transparent,
· Fair, and
· Clearly communicated, ensuring no deception or exploitation of workers.
Statutory Benefits
All workers receive legally mandated benefits in line with national requirements. These include, but are not limited to, health coverage, pension contributions, paid leave entitlements, and social security contributions.
Compensation for Work-Related Injuries
Workers and their dependents are compensated for work-related injuries, illnesses, and fatalities in accordance with:
· Applicable laws and collective agreements, or
· Where such legal instruments are absent, in line with ILO Standard 102 on employment injury benefits or comparable internationally recognised standards.
Harassment, Discipline, Grievance Procedures and Non-Retaliation
Prohibition of Violence and Harassment
Minar Jewellers strictly prohibits all forms of workplace violence and harassment, both direct and indirect.
· This includes physical, verbal, psychological, or sexual harassment.
· Intimidation and inappropriate conduct during disciplinary actions are also prohibited.
· Any violation of this policy is investigated and may result in disciplinary action, including termination.
Dignity and Respect at Work
Measures are in place to ensure that all workers are treated with dignity and respect at all times.
· Employees must not be subjected to harassment, bullying, or threats directed towards themselves, their family, or their colleagues.
· Policies reinforce a culture of mutual respect, inclusivity, and professionalism.
· Managers are trained to intervene promptly in cases of inappropriate behaviour.
Training on Harassment Prevention
Key personnel, including managers, medical professionals, and security staff, undergo regular training to:
· Recognise signs of violence, harassment, and intimidation.
· Understand relevant laws and company policies.
· Respond sensitively and appropriately to potential incidents.
Records of training sessions are maintained for audit and compliance purposes.
Disciplinary Process and Records
Minar Jewellers has a documented disciplinary process that:
· Is clearly communicated to all staff.
· Outlines fair and appropriate procedures for disciplinary actions.
· Applies equally to all levels of management and staff, without bias.
· Ensures confidentiality and anonymity when disciplinary actions are recorded and reviewed.
Grievance Mechanism and Non-Retaliation
In addition to the requirements of COP 2.6, Minar Jewellers has established a grievance mechanism that ensures workers can raise concerns freely:
a. All workers, including new hires at the time of recruitment, are informed about the grievance mechanism and how to access it.
b. Workers may submit complaints individually or collectively without fear of penalty, retaliation, or negative consequences.
c. Workers have the right to involve a representative of their choice when submitting or pursuing grievances.
The grievance mechanism is designed to be:
· Accessible, transparent, and fair.
· Confidential, ensuring protection for those who raise concerns.
· Supported by a clear process for review, investigation, and resolution.
Child Labour
Minimum Age for Employment
Minar Jewellers strictly prohibits the use of child labour in any part of its operations or supply chain.
· The company complies fully with ILO Convention 138 and Recommendation 146, which set a minimum working age of 15 years.
· This ensures that children are able to complete their compulsory education before entering the workforce.
· Contracts and recruitment procedures require proof of age (e.g., birth certificates, government-issued IDs, school leaving certificates) for all employees.
Compliance with Compulsory Schooling Laws
· In line with RJC requirements, Minar Jewellers does not employ any worker below the age of 15 years, regardless of local laws where compulsory schooling may end earlier.
· Employment is only offered to individuals who have reached the legal working age and completed their basic education.
· Suppliers and contractors are also required, through contracts and agreements, to confirm compliance with these requirements.
Prohibition of Worst Forms of Child Labour
Minar Jewellers has a zero-tolerance policy towards the worst forms of child labour as defined in ILO Convention 182 and Recommendation 190. This includes:
a. Hazardous Work – No person under the age of 18 is permitted to undertake work that is unsafe, harmful to their health, or morally inappropriate.
b. Exploitation – The company explicitly forbids all forms of child slavery, including debt bondage, trafficking, forced labour, and the use of children in armed conflict.
Implementation and Monitoring:
· Regular supplier audits and due diligence checks are carried out to ensure compliance with child labour standards.
· A supplier code of conduct is in place, requiring all partners to confirm in writing that they do not engage in child labour practices.
· If any violations are identified, immediate corrective actions are taken, including disengagement from non-compliant suppliers.
Forced Labour
Prohibition of Forced Labour
Minar Jewellers strictly prohibits the use of forced labour in any part of its operations or supply chain.
The company complies fully with ILO Convention 29, which forbids bonded, indentured, or involuntary prison labour.
All employment at Minar Jewellers is based on the free and informed consent of workers, with no coercion or threats involved.
Voluntary Employment Practices
Minar Jewellers ensures that all employees work in voluntary conditions.
· Workers’ freedom of movement is never restricted, whether in the workplace or in company-provided accommodation.
· Employees retain possession of their personal documents (e.g., passports, IDs, work permits). Only certified copies are kept on file where legally required.
· Recruitment practices are transparent and fair. No deposits, recruitment fees, or equipment advances are charged. If a worker is ever found to have paid such fees, they are reimbursed in full.
· Wages, benefits, and entitlements are paid in full, and nothing is withheld to force employees to remain.
· All employees are free to terminate their employment by giving reasonable notice in line with national labour laws and employment contracts.
Prohibition of Human Trafficking and Deceptive Recruitment
Minar Jewellers has a zero-tolerance policy against human trafficking and deceptive recruitment practices.
· All labour recruiters, agencies, and providers working with the company must commit in writing to fair recruitment and employment practices.
· Recruiters and agencies are regularly monitored to ensure compliance.
· If violations are discovered, Minar Jewellers takes immediate corrective action, including termination of contracts.
· Impacted workers are supported through remediation measures such as reimbursement of illegal fees, access to legal aid, counselling, and the guarantee of safe, fair employment.
This approach forms part of Minar Jewellers’ broader Human Rights Due Diligence process under COP 6.1.
Freedom of Association and Collective Bargaining
Right to Association
Minar Jewellers fully respects the right of workers to freely associate and join organisations of their choice, including trade unions and worker committees.
The company complies with the ILO Declaration on Fundamental Principles and Rights at Work (1998), which protects the right of workers to organise and engage in collective action without interference.
Workers are free to form or join unions, participate in lawful strikes, or engage in representative activities without fear of retaliation, harassment, or discrimination.
Good Faith Engagement in Collective Bargaining
Where collective bargaining structures exist, Minar Jewellers is committed to engaging in good faith negotiations with worker representatives.
All discussions and agreements are conducted with transparency, mutual respect, and fairness.
If collective agreements are reached, they are documented, communicated to employees, and fully implemented.
In cases where unions or formal bargaining structures are absent, Minar Jewellers provides alternative consultation mechanisms, such as regular staff meetings, anonymous feedback systems, and direct dialogue with management.
Protection of Worker Representatives
Minar Jewellers ensures that worker representatives can perform their roles without interference.
· Representatives are provided with the time, resources, and facilities needed to carry out their responsibilities.
· The company strictly prohibits any form of harassment, intimidation, or discrimination against worker representatives or employees engaged in collective activities.
· Training is provided to managers and supervisors to reinforce the importance of respecting workers’ rights to association and collective bargaining.
Citation: Health & Safety and Employment Law Services
Non-Discrimination
Equal Opportunity and Fair Treatment
Minar Jewellers is committed to maintaining an inclusive workplace based on the principles of equal opportunity, fairness, and respect.
Employment relationships are built on merit, skills, qualifications, and performance, not on irrelevant personal characteristics.
The company fully complies with the ILO Declaration on Fundamental Principles and Rights at Work (1998), ensuring that no form of discrimination is tolerated in hiring, promotion, remuneration, training, or termination practices.
Prohibited Grounds of Discrimination
Minar Jewellers prohibits any form of discrimination, including but not limited to:
· Race, ethnicity, colour, or caste.
· National origin, religion, or political affiliation.
· Gender, pregnancy, or parental status.
· Sexual orientation, disability, genetic information, or HIV status.
· Age, marital status, or physical appearance.
· Union membership, participation in lawful strikes, or other legally protected activities.
Every employee who is fit and qualified for work is guaranteed equal opportunities to contribute and grow within the organisation.
Implementation and Monitoring
· Employment policies and procedures clearly define the company’s commitment to non-discrimination.
· Regular training sessions are provided to management and staff to raise awareness about equality, fairness, and unconscious bias.
· HR practices include periodic audits to ensure equal pay for equal work and the absence of discriminatory practices in recruitment, promotions, or benefits.
· Employees are encouraged to use the grievance mechanism (COP 2.6) to raise concerns related to discrimination, with assurances of confidentiality and non-retaliation.
Diversity, Equity, and Inclusivity
Policy Commitment
Minar Jewellers has established a publicly available Diversity, Equity, and Inclusivity (DEI) Policy, endorsed by top management.
This policy commits the company to:
· Promoting diversity and equal representation across all levels and functions.
· Ensuring equitable treatment in recruitment, promotions, professional development, and employment conditions.
· Creating a workplace where inclusivity is embedded in the culture and where everyone feels valued and respected.
Supporting Processes and Implementation
To support the DEI policy, Minar Jewellers has implemented procedures that:
· Provide fair recruitment practices, ensuring opportunities for candidates from diverse backgrounds.
· Monitor pay equity and advancement opportunities to prevent disparities.
· Offer inclusive career development programs, training, and mentoring opportunities to underrepresented groups.
· Encourage employee feedback and participation in shaping a fair and inclusive workplace.
Training and Awareness
All staff, including management, receive regular DEI training designed to:
· Promote awareness of unconscious bias and its impact on decision-making.
· Reinforce respectful behaviour, fairness, and equal opportunity.
· Build a culture of inclusivity, where diversity is seen as a strength that drives innovation and success.
Monitoring and Review
· The DEI policy and related processes are reviewed annually to ensure their ongoing effectiveness.
· Progress is tracked using key indicators such as workforce diversity data, pay gap analysis, and employee satisfaction surveys.
· Where gaps are identified, corrective measures are taken to strengthen inclusivity and equity.
Health and Safety
Commitment to Safe and Healthy Workplaces
Minar Jewellers is committed to providing a safe and healthy working environment for all employees, contractors, and visitors.
The company complies with all applicable health and safety laws and aligns with recognised international industry standards.
Our health and safety policy prioritises the well-being of workers over operational or financial considerations.
Health and Safety Policy and Systems
Minar Jewellers has established an Occupational Health and Safety (OHS) Policy that includes:
· Preventing work-related injuries and ill health.
· Providing safe workplaces, equipment, and processes.
· Continual improvement in health and safety performance.
This policy is communicated to all workers, displayed in the workplace, and made publicly available.
Supporting systems include:
· Hazard identification and risk assessment procedures.
· Controls to minimise risks of accidents, injuries, and exposure to hazards.
· Documented OHS management systems that are regularly reviewed and improved.
Worker Participation
Minar Jewellers ensures active worker participation in health and safety management through:
· A joint health and safety committee, where employees can raise concerns and collaborate with management.
· Consultation in risk assessments and development of workplace safety procedures.
· Open communication channels to report hazards without fear of retaliation.
Training and Awareness
All workers and visitors are provided with health and safety training and information in an understandable format. This includes:
· Training on role-specific hazards and safe work practices.
· Instruction on emergency procedures and responses.
· Clear communication of the right to refuse unsafe work without penalty.
Safety Equipment and Emergency Preparedness
· Personal protective equipment (PPE) is provided free of charge, maintained, and enforced where required.
· Adequate first-aid provisions and trained staff are available on-site.
· Emergency procedures, including evacuation plans, are displayed, regularly tested through drills, and updated when necessary.
Incident Investigation and Continuous Improvement
All workplace incidents are promptly investigated to determine root causes.
· Findings are used to update hazard controls and prevent recurrence.
· Annual reviews of health and safety systems ensure they remain effective and suitable for evolving risks.
Environmental Management
Environmental Risk Assessment
Minar Jewellers is committed to minimising its environmental footprint and integrating responsible environmental practices into its operations.
In compliance with COP 25.1, the company has conducted an environmental risk assessment of its business activities and products to identify significant environmental impacts, including:
· Climate change contributions, such as energy usage and carbon emissions.
· Biodiversity impacts, including responsible sourcing of precious metals and gemstones.
· Waste management and recycling, to minimise landfill and promote sustainable practices.
· Water usage and efficiency, ensuring conservation and responsible disposal.
Implementation of Environmental Practices
Following the risk assessment, Minar Jewellers has implemented measures to reduce environmental impacts, such as:
· Energy efficiency initiatives (LED lighting, energy-efficient equipment, minimising unnecessary consumption).
· Waste segregation and recycling programmes.
· Preference for suppliers that follow sustainable and ethical sourcing practices.
· Annual monitoring of water and energy usage to identify opportunities for improvement.
Monitoring and Review
· Environmental performance is monitored regularly to ensure objectives are met.
· Reviews are carried out annually, with corrective actions taken where needed.
· Results and improvement plans are shared with management to maintain accountability.
Hazardous Substances
Use of Alternatives
Minar Jewellers is committed to minimising the use of hazardous substances in all aspects of its operations.
Wherever technically feasible and economically viable, the company replaces hazardous substances with safer, environmentally friendly alternatives to protect workers, customers, and the environment.
Safe Handling and Compliance
· Where the use of hazardous substances cannot be avoided, Minar Jewellers ensures they are handled, stored, and disposed of safely in compliance with national laws and international best practices.
· Material Safety Data Sheets (MSDS) are available for all relevant substances.
· Employees handling such materials receive specialised training on safe use, protective equipment, and emergency procedures.
Monitoring and Review
· Regular assessments are conducted to identify opportunities for substitution with non-hazardous alternatives.
· Hazardous substance use and disposal are tracked, documented, and reviewed annually.
· Continuous improvement processes are in place to reduce risks and safeguard both human health and the environment.
Natural Resources
Water Management and Protection
Minar Jewellers recognises that water is a critical natural resource and is committed to managing its use responsibly.
In line with COP 28.2, the company:
· Manages water at its facilities effectively by monitoring usage, efficiency, and discharge.
· Uses water balance and water quality monitoring data to track consumption and ensure compliance with environmental standards.
· Considers cumulative and legacy impacts of water use, ensuring operations do not harm current or future community water needs.
· Implements actions to mitigate significant adverse impacts on water quantity, water quality, and availability.
Annual Review and Continuous Improvement
· Minar Jewellers conducts an annual review of water usage, which is formally documented and stored.
· These reviews are scheduled in the company calendar to ensure accountability and consistency.
· Any identified inefficiencies or risks are addressed through corrective actions, such as improved water conservation measures or investment in efficient technologies.
Product Disclosure
Disclosure of Physical Characteristics
Minar Jewellers is committed to transparency in product representation and complies with all applicable laws regarding product disclosure.
· Information on the physical characteristics of all materials (gold, silver, platinum group metals, diamonds, and coloured gemstones) is provided clearly and accurately.
· For plated items, the company ensures that the plating type (e.g., gold, silver, platinum) and fineness or content are disclosed in a manner equally as conspicuous as the word “gold,” “silver,” or the PGM abbreviation.
· Customers are informed with full accuracy to avoid misleading claims about product composition or treatment.
Avoidance of Undisclosed Materials
Minar Jewellers has implemented strict systems to prevent undisclosed materials from entering its supply chain. This includes:
· Due Diligence Process
o The company employs a documented due diligence process to identify and mitigate risks of undisclosed materials.
o This includes supplier vetting, written warranties, and formal supplier declarations.
o All items over 1g are hallmarked in compliance with UK Hallmarking Law, ensuring traceability, quality, and product integrity.
· Risk-Based Testing and Certification
o Minar Jewellers, purchases loose and polished diamonds, over half of one carat, whenever possible, that are accompanied by certificates from IGI, GIA, or another recognised laboratory.
o Suppliers are notified by email of the specific materials required, ensuring clarity and accountability.
o Where required, testing is conducted in line with industry-accepted protocols to confirm the authenticity of diamonds and gemstones.
About the RJC
The Responsible Jewellery Council (RJC) is the leading standards organisation for the global jewellery and watch industry. With over 2,000 members worldwide, the RJC works to promote responsible business practices and sustainability. Its standards help companies support people, communities, and the environment, while contributing to the United Nations Sustainable Development Goals.