Modern Slavery Act

Compliance statement

Diamond Manufacturers Limited Registered Office: 60 St Martins Lane, London, WC2N 4JS.
Registered in England. Company registration number: 6388524 (“Diamond Manufacturers”)

Diamond Manufacturers Ltd. is committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chain, and we impose the same high standards on our suppliers.


Structure

Diamond Manufacturers is a maker of fine jewellery selling to customers through our retail stores and workshops in London, England and via our website vashi.com. We employ over 200 people and have head office and business operations located in London and Manchester.

In order to manufacture and fulfil orders for our products and services, we work with a range of suppliers who advocate strong ethical and environmental tenets that mirror our own core values. We have two main suppliers based in Antwerp, Belgium but with an international footprint. In addition to this, we use a variety of smaller UK suppliers for specialist services and goods. Before partnering with a new supplier, we carefully review key practices relating to quality and sustainability, and ensure they are registered members of the recognised associations and governing bodies in their sectors. Owing to the nature of our industry we are always vigilant to sector reports, press and market data relating to our suppliers and ensure we only maintain relationships with those who adhere to the highest standards.


Policies

As part of our commitment to combating modern slavery, we have implemented the following policies within our company, and we ensure these policies are adhered to by all our suppliers:

  • Ethical Diamond Policy: https://www.vashi.com/ethical-diamonds
  • Our Equal Opportunities Policy, Anti-bribery Policy, Procurement Policy and Supplier Code of Conduct are all designed to combat modern slavery, and ensure our core values and the protection of all individuals are maintained

  • These policies have been developed in line with the Equality Act 2010 and are designed to ensure we have best practice and protection in place for all our staff. We positively support all diverse employment legislation, including the extensions and awareness into payroll and pension provision to ensure fair remuneration and recognition for all our staff. These policies were devised through consultation and market research and our HR and Procurement team continues to monitor and review in line with current dynamics to ensure we are aligned with current legislation.


    Due diligence

    Many of our suppliers are already members of professional bodies that conduct external audits to ensure compliance. All potential high-value goods are further supported by documentation supporting relevant UN resolutions. As such, any items that are non-compliant to DTC/ UN resolutions are returned immediately and the supplier is investigated and blacklisted if they have been found to be in breach of the required standards. In addition, suppliers must ensure fair payment of staff and denote this on their invoices. If we use agencies for staff, we require that they confirm all relevant information within guidelines of EAA 2010 in relation to any staff introduced to us.

    Our procedures are designed to:

  • Establish and assess areas of potential risk in our business and supply chains
  • Monitor potential risk areas in our business and supply chains
  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains
  • Provide adequate protection for whistleblowers


  • Risk and compliance

    We regularly evaluate the nature and extent of exposure to the risk of modern slavery occurring in the supply chain by reviewing all supplier documentation and info relating to purchase, interviewing new starters and reviewing essential payment policies such as gender pay gap and clarity on payments. In addition, we review third-party data and market information that is evaluated to formulate a risk conclusion to permit or cease trade. Our policies are also reviewed in line with markets to embrace positive impact and change.

    We operate a positive open communication policy to address Equal Opportunity and Anti-Bribery situations; we have a formal whistleblower policy to protect those who recognise potential breaches and positively encourage people to speak to their manager, HR, or someone in the company they who they feel comfortable talking to. If such an event occurred, the matter would be investigated by a senior member of the management team from a different business area to review, mediate and mitigate all activities through due diligence, improved procurement practices or industry collaboration. This would then be reported to the CEO and appropriate action would be taken.

    We ensure all our suppliers adhere to our Ethical Diamond Policy and Anti-Slavery Policy. We enforce a strict code of compliance and operate a zero-tolerance approach to slavery and human trafficking within our supply chains. As such, if we find evidence of a failure to comply with our policies we will immediately seek to terminate our relationship with the relevant supplier.


    Effectiveness and KPIs

    The following measures are used to ensure that neither slavery nor human trafficking is taking place in any part of our business or supply chains:

  • Use of robust supplier selection process including supplier questionnaires and compliance with Vashi’s supplier code of conduct
  • Continual review of current supplier practices and codes of conduct
  • Use of approved payroll systems
  • Regular staff training and awareness by our full-time internal team
  • We have appointed the Responsible Jewellery Council (RJC) to conduct an independent review of our businesses and supply chains, and to recommend actions we can take to combat slavery and human trafficking from within. The Responsible Jewellery Council uses external auditors to critically assess how successful we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains


  • Training

    Our full-time internal Training and Development team is focused on the education of all staff on key subjects including Equal Opportunities and Anti-Bribery Policies. Employees are encouraged to identify and report any potential breaches. In addition, we will be adding our Anti-Slavery and Human Trafficking Policy to this staff training. Employees will be taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

    Examples of training courses we have administered over the past year include:

  • Equal opportunities – interviewing for tomorrow
  • Ethical mining and history of the Kimberley Process


  • Further actions and sign-off

    We are committed to reviewing our practices around the prevention of slavery or human trafficking in our business or supply chains at the end of each financial year, and we intend to combat slavery and human trafficking through various new processes, e.g. with the introduction of new policies and procedures, the introduction of training modules on the risks of modern slavery and human trafficking, and the introduction of a compliance tracker to monitor all areas of our business.

    This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Diamond Manufacturers Limited’s slavery and human trafficking statement for the financial year commencing 2022 and ending 2023. This statement was approved by the Vashi Leadership on Friday 7th January 2022 and will be reviewed in December 2022.

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