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DUE DILIGENCE

POLICY ON MATERIALS ORIGINATING FROM CONFLICT ZONES

As part of its commitment to guaranteeing a responsible supply chain of materials manufactured from gold and precious metals originating from a platinum mine, Pibor ISO SA has adopted the policy outlined below:

1) Pibor ISO SA is a family-owned manufacturing business, founded in Glovelier in 1952. It currently employs around 135 persons. Pibor ISO SA specialises in watchmaking and complex parts.

2) Pibor ISO SA is a certified member of the Responsible Jewellery Council (RJC COP & RJC CoC). We consequently undertake to prove, on the basis of an independent verification by third parties, that we:

a) respect human rights in accordance with the International Labour Organisation' s human rights conventions on fundamental principles and rights at work;

b) are not involved in any form of corruption, money laundering or financing of terrorism and do not tolerate such activities;

c) maintain transparency of payments originating from governments and security forces in accordance with the rights in the mining industry;

d) do not provide direct or indirect assistance to illegal armed groups;

e) allow stakeholders to express their concerns about the supply chain in the jewellery sector.

3) We also undertake to use our influence to prevent potential abuse by other parties. We know and work with a small number of suppliers of gold and metals originating from platinum mines and all the refiners with whom we work are RJC CoC certified.100% of the gold and platinum supplied by Pibor ISO SA is guaranteed RJC CoC. We continually strive to remain vigilant with regard to the risks associated with the supply of materials in conflict zones. We ensure that our refiners also fulfil their due diligence obligations in accordance with the OECD guidelines. If doubts or harm were to arise, we have made prior arrangements, as a result of the standardisation of the products that we purchase, to freeze the supplies from one of our refiners with no negative effects on our business. We are ready to respond rapidly to any loopholes or riskst hat are identified by suspending our business relationship with a supplier and stopping or segregating the deliveries of the impacted materials. Lastly, in the event of fears by the parties concerned about materials originating from conflict zones, we also undertake to accept and handle complaints in accordance with our procedure. An annual report will include a report on the exercise of due diligence with regard to the supply chain.


4) With regard to serious violations during the extraction, transport or trade in minerals, we will not tolerate, assist or facilitate in any manner whatsoever the perpetration of the following acts, nor will we generate any profit from them or contribute to them:

a) torture or cruel, inhuman and degrading treatment;

b) forced or compulsory labour;

c) the worst forms of child labour;

d) violations and infringements of human rights;

e) war crimes and other flagrant violations of international human rights law, crimes against humanity and genocide.

5) We will suspend all relations with upstream suppliers if we identify a risk and have reason to believe that they are committing the abuses stated in paragraph 4, that they are supplying third parties who are committing these serious violations or they are associated with such third parties.

6) With regard to direct or indirect support of non-state armed groups, we will not tolerate any direct or indirect support of non-state armed groups or their affiliated entities, in particular by supplying gold, paying money or providing logistical, material or other assistance for the purpose of committing the following illegal acts :

a) illegal control of mining sites or transportation routes, points where minerals are traded and upstream buyers in the supply chain;

b) illegal taxation or extortion of money or gold on the mining sites, transportation routes or points where gold is traded, or from intermediaries, export companies or international traders.

7) We will immediately suspend all relations with upstream suppliers if we identify a reasonable risk of them supplying third parties who are directly or indirectly supporting non-state armed groups such as those specified in paragraph 6 or who are linked to such non-state armed groups.

8) With regard to public or private security forces, we affirm that the role of public or private security forces is to ensure the safety and security of workers, facilities, equipment and property in accordance with the rule of law, including human rights legislation. We will not provide any direct or indirect support to public or private security forces that commit the violations defined in paragraph 4 or that act illegally as defined in paragraph 6.

9) With regard to corruption and false declarations on the origin of the gold, we will refrain from offering, promising or giving kickbacks and we will refuse requests for kickbacks that are designed to conceal or mask the origin of the gold, and from making false declarations about the taxes, duties and licence fees paid to governments for the extraction, trade, handling, transportation and exportation of the gold.

10) With regard to money laundering, we will make every effort to eliminate money laundering in the situations where we identify a reasonable risk of resultant money laundering or money laundering linked to the extraction, trade, handling, transportation or exportation of gold.

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