General Information about the Company
In the last 10 years, RAM Jewelry as a family business, has earned the reputation of
being a trusted name in the jewelry industry, and is known for providing excellence
quality jewelry.
Our goal is always being a trusted partner for our clients by initiating original creations,
innovations, perfect product making & landmark jewelry.
It has always been our endeavor to run a transparent ethical business rooted in
traditional as well as modern values and to maximize customer satisfaction.
In RAM Jewelry, we are family of experienced jewelers, polishers and quality team.
RAM Jewelry is an environment where everyone works in tandem to rapidly make
effective decisions that will transform ideas into final products that our clients will love.
We are a team of not just dreamers, but doers, people who collaborate to achieve our
vision and build an organization that will create art in jewelry and make the tomorrow.
Financial compliance
Money Laundering, Terrorism Financing, Other Financial Offences
Current Status
1- RAM Jewelry recognizes the fact that entities in 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.
2- Strict compliance is ensured at all the entities and compliance officer has been
appointed who in turn reports to RAM. Management on compliance status on
annual basis.
3- Know Your Counter Party and other compliance of Due Diligence is followed in
line with OECD guidance.
4- Ongoing monitoring is carried out along with all stakeholders.
Area of concern & Remedial Measures
Nil As on Dat
System of Warranties:
We are fully committed to complying with all the requirements. Day to day monitoring
and compliance of SOW is done by compliance officer.
RAM Jewelry is committed towards conflict free sourcing and zero tolerance policy is
followed at our company.
Area of concern & Remedial Measures
Nil As on Dat
Anti-Bribery and Facilitation Payment Policy:
RAM shall ensure complete prohibition Bribery and facilitation payment across
organization and in all the entities.
RAM has published compliance team contact details on website to receive any
grievance or complaints.
Area of concern & Remedial Measures
Nil As on Dat
Ethical Sourcing:
Our company is concerned about the environment and social impacts of irresponsible
Gold and Platinum sources.
RAM has identified the risk of supply chain with respect to Conflict Affected High Risk
Area.
RAM ensures all its supplies are screened for conflict free supplies.
We have published the OECD based ethical sourcing policy and we are communicating
our policies to all the supply chain partners and pushing them to adopt the same.
Area of concern & Remedial Measures
Current concern is lack of awareness about OECD regulation and requirements
of
sourcing.
We have started creating awareness about our Ethical sourcing requirements for
our
supply chain.
We started Engagement with our supply chain for obtaining further supply chain
information to ensure ethical and conflict free sourcing in metal business.
Social Compliance
We ensure full compliance with all applicable national and, where
appropriate,
international laws / regulations with respect to employment and labor codes
in all our establishment.
We respect all regulation for child labor, forced labor, non-discrimination,
nonretaliations etc.
All work man rights are respected and adhere to freedom of association
and collective bargaining regulations.
Area of concern & Remedial Measures
No point has been reported in the social compliance of RAM remedial
measures at OUR COMPANY level is required.
Entity level remedial measures are taken based on internal and
external audits conducted by reputed agencies.
Health and Safety
We are concern about the health and safety of employees and are
constantly studding about any adverse impact of our business processes
are identified and eliminated. Towards this end, we will systematically
review our operations to identify sources of health and safety related risks.
This review will use appropriate standards as required by prevailing laws,
expert
opinion, and our knowledge of best practices.
All our staff will be trained in the manner required to adhere to these work
practices.
All workplaces are constructed to meet safety standards with local
regulations as the minimum standards that will be applicable.
Area of concern & Remedial Measures
Nil as on date, as no accidents are reported in last one year.
Human Rights
RAM is not and will 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.
The Company strongly discourages 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.
RAM ensures that none of its suppliers and stake holders have engaged in
any activity which can violate the Human Right Principles.
Area of concern & Remedial Measures
RAM shall carried out the Human Right Due Diligence of suppliers and
other Stake holders & based on risk assessment where necessary for 2024
and after.
Environment
RAM is Complying with all applicable environmental laws and regulations.
Improvement is seen employee’s environmental awareness and
performance with the help of detailed policies and procedures, training, and
recognition of
Excellence.
Area of concern & Remedial Measures
Nil As on Dat
ANNUAL REPORTING TEMPLATE (RJC TOOL KIT VERSION 5.0
Company Name RAM Jewelry
Date Feb 14, 2024
Reporting Period Jan 2023 to Jan 2024
Step 1: Establish strong company management systems
1.A. Adopt and clearly
communicate to
suppliers and the public, a
company policy for
the supply chain of minerals
originating from
conflict- affected and high-risk
areas
We have published the policy at
group
level for easy accesses to stake holder.
OECD and Best Practice Annual
communication has been sent to all the
active customers and supplier
Awareness presentation on
Ethical
sourcing based on OECD guideline
has been circulated
1.B Structure internal
management systems to
support supply chain due
diligence.
Additional responsibility has been
assigned to VP to look over the
compliance of Ethical souring policy
Employees involved in souring of
precious metals have been trained on
our Ethical precious metal souring
policy. Refresher trainings are
provided.
List of Suppliers has been maintained
along with status of their social and
ethical compliance
1.C Establish a system of
controls and
transparency over the minerals
supply chain.
Supplier upstream information
collection
process started to obtained necessary
information and Ethical sourcing
compliance at supplier level.
1.D Strengthen company
engagement
with suppliers.
supplier questionnaire and KYC has
been circulated and we are in the
process of following up with them to
obtained the filed information from
them.
Step 2: Identify And Assess Risk In The Supply Chain
Identify And Assess Risks In We have established the detailed
The Supply
Chain And Assess Risks Of
Adverse Impacts.
policy
and procedure for identification of risk
at
entity level.
Step 3: Design And Implement A Strategy To Respond To Identified Risks
(If
Applicable)
Report Findings of The Supply
Chain Risk
Assessment To the Designated
Senior
Management Of the Company
Ongoing monitoring of each supplies is
being done by VP to confirm its
Free from Conflict, were required Red
Flags are been raised for seeking
additional information and closed after
receiving such information to our
satisfaction.
VP shall report all un-answered flags
to top management (president)
In worst situation where information is
half or not satisfactory management
starts engagement practice and
discussion and dialogue with suppliers
is
carried out to ensure full information in
further business
Devise and Adopt A Risk
Management Plan.
We have formulated the risk
management plans at entity level
considering individual entities position
in supply chain and position of supplier
in supply chain.
Our VP carries out monitoring of each
and every business transaction and
were required Red Flags are been
raised and further steps are followed
as mention above.
Implement The Risk
Management Plan And
Monitor Performance Of Risk
Mitigation
Efforts.
Entity level and group level monitoring
of Red Flags and its effective closure is
monitored.
Internal Training VP is responsible to make sure all
necessary trainings provided.
Communications Over and above Annual
communication
on Business policy and Awareness on
various best practices and expectation
from business partners is
communicated
OPTIONAL INFORMATION ON Step 4:Carry Out Independent Third-
Party Audit
RJC COP Audit RJC COP 2019 Audit Planned in Feb
2024
Grievances and Remediation No grievance of what so ever has been
reported till date.
RAM Jewelry
President
Robert Shakarov
Date: 2/15/24
RJC Compliance Policy
RAM Jewelry recognizes the fact that entities in jewelry industry must 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.
This policy applies to all RAM Jewelry suppliers, vendors and their employees, as well as to directors, officers and employees.
We are proud of the values with which it conducts business. It has and will continue to uphold the highest levels of business ethics and personal integrity in all types of transactions and interactions.
To this end, this policy aims to:
(1) Emphasize our commitment to ethics and compliance with the law;
(2) Set forth basic standards of ethical and legal behaviour;
(3) Provide reporting mechanisms for known or suspected ethical or legal violations; and
(4) Help prevent and detect wrongdoing
Legal Compliance: Laws, Rules, Regulations
RAM Jewelry developed RJC program in response to new regulatory and customer supply chain initiatives, regarding improving our manufacturing and sourcing marketplace.
In this set of policy, a new vendor profile that requires enhanced documentation of compliance with socially responsible labor and environment laws as well as certified satisfaction of other Ethical Sourcing requirements.
Specifically, we now require ourselves and our Vendor Partners, are compliant with regulatory laws that govern current labor and environmental practices plus full compliance with the following national Regulations”
· Patriot Act Anti-Money Laundering Program
· Foreign Corrupt Practices Act (FCPA)
· Health and Safety Laws
Additionally, each Vendor will be audited, on a regular basis. Vendor/Supplier Compliance and Auditing Process
· labor and human rights
· health and safety
· environmental responsibility
· business ethics
· management system monitoring and assessment
RAM Jewelry does not tolerate or make any untruthful, misleading, or deceptive representation, or make any material omission in the selling, buying, advertising, or marketing of any gold, platinum, jewelry products, or any related material.
Labor and Human Rights
RAM Jewelry and its Vendors are required to uphold the human rights of workers. All workers must be treated with dignity and respect as recognized by the international community. Work environments must be free of harassment. No employee should endure harsh or inhuman treatment. RAM Jewelry considers the below forms of treatment as harsh or inhuman:
· Sexual Harassment
· Sexual, Physical, Mental, and Verbal Abuse
· Mental/Physical Coercion
· Corporal Punishment
· Child Labor
· Unnecessary Restriction of Entering or Exiting Provided Facilities
Antidiscrimination
Vendors shall implement policies that prohibit any discrimination considered unlawful under federal, state or local laws, including but not limited to age, race, religion, color, national origin, citizenship, disability, sex, marital status, sexual orientation, pregnancy or liability for governmental service. Vendors shall fulfill of this policy with respect to hiring, placement, promotion, transfer, demotion, layoff, termination, recruitment, advertising, rate of pay, other forms of compensation, selection for training and general treatment during employment. This includes making reasonable accommodations for known physical and/or mental limitations of otherwise qualified applicants and employees with disabilities, unless the accommodation would impose an undue hardship on the operation of your business.
In addition, vendors shall not require employees or potential employees to undergo medical testing that could be considered discriminatory expect where required by applicable laws, regulations or prudent for workplace safety.
Involuntary Labor
Our company has zero tolerance policy on any form of forced, bonded, indentured, or prison labor. All workers employed by our Vendor must be awarded an “employee at will” status, granting the ability to leave or terminate their employment with due notice. Vendors must accurately communicate the workers employment commitment and rights in a manner understood by each individual. Any outside or third party contractors used by the Vendor, must also conform to the statements above. It is the responsibility of the vendor to ensure that its subcontractors comply with this policy.
Child Labor
Our vendors are strictly prohibited from using the labor of minors. The minimum age for employment shall be 18. Juveniles who are older than the applicable legal minimum age as per local country law, for employment but are under the age of 18 can be employed. These juveniles must not perform or be required to work under conditions that may jeopardize their health.
Working Hours
A general work week shall be restricted to 60 hours per week inclusive of all voluntary overtime. All workers must be provided as least one day of rest within a seven day period. Without exception, workweeks will not exceed the amount allowed by applicable laws and regulations. All paid time off, sick days, and vacation time awarded or stipulated under local laws and regulations must be offered.
Wages and Benefits
Vendors are required to compensate all employees consistent with applicable laws and regulations. This compensation includes but is not limited to minimum wage rates and legally mandated benefits. Overtime pay must be paid at the legal rate established by local legislation and laws. Wage garnishments being used as disciplinary actions are strictly prohibited. In addition to the above statements, every employee must be paid wages and benefits in a fair, timely manner.
Freedom of Association
All Vendors must respect the right of workers to associate freely. Workers shall be free to form and join workers organizations of their choosing, seek representation and collective bargaining where legal under local laws and regulations. Vendors must not discriminate based on association or membership. Equal opportunity employment must be offered to all potential workers.
Health and Safety
Creating and sustaining a healthy, safe work environment for everyone within the our supply chain is one of our very important goals. Vendors must be committed to upholding the below guidelines in order to insure safe and healthy working conditions for all their employees.
Vendors must make sure:
· Injury Prevention
Vendors must implement the appropriate
controls to identify, evaluate, and limit their employee’s exposure to hazardous chemicals and gasses.
· Emergency Planning and Response
Vendors must implement management systems which anticipate, identify, and assess the risk of emergency situations.
Sufficient first aid, fire detection, and fire extinguishing equipment must be present. Emergency plans and procedures should be documented and communicated. Employee training and fire drills must be conducted on a quarterly basis.
· Health and Safety Committees
Vendors are strongly encouraged to create an employee health and safety committee. This committee should have a representative from each department in different employment levels.
A business relationship is significant if the partner is a major customer or supplier (in terms of volume or value), or if association with it could impact our reputation.
RAM Jewelry has implemented a process to select particular business partners including suppliers and monitor them in order to make sure they follow RJC requirements and expectations. RAM implemented a risk assessment in order to identify and address the level and nature of risks that come with our most significant relationships.
Also RAM Risk assessment members, identify those business partners that our company can potentially influence.
RAM uses results of risk assessment and monitoring, to engage significant business partners to raise awareness of responsible business practices.
Copy of our responsible business policy should be attached to all contract with business partners.
As a general rule, a business relationship with our company will not be established until the identity of potential customer or supplier is satisfactorily established.
If a potential customer or supplier refuses to provide any of the requested information, the relationship will not be established. Likewise, if requested follow-up information is not forthcoming, any relationship already begun will be terminated. The following is an overview of general principles to follow:
· Business Partners do not include end consumers
· No cash purchase or sale or cash transaction of any kind is acceptable in our company.
· Business partners including suppliers and customers should ensure they are aware of the Applicable Law for all relevant jurisdictions.
· A risk assessment will be carried out for the business to identify vulnerability to involvement in money laundering or the finance of terrorism. High risk indicators or ‘red flags’ will be established for screening of new customers or suppliers prior to initial transactions, and for ongoing monitoring of transactions.
Our company do not implement any relationship with higher risk supplier. However, in case if necessary, higher-risk suppliers or customers would include those who show any of the following characteristics:
· Lack of knowledge of the industry
· Requests for unusual financial terms and conditions
· Lack of an established place of business, or an unusual location
· Proposing a transaction that makes no sense
· Use of banks that are unusual or distant
· Use of non-bank financial institutions for no apparent legitimate business purpose
· Frequent and unexplained changes in bank accounts
· Frequent and unexplained changes in accounting personnel
· Use of companies that do seem to have any legitimate fiscal, legal or commercial reason to be used
· Unusually complex organizational structure
· Offices located in higher risk jurisdictions
· Involvement of third parties in transactions
· Refusal to identify beneficial owners or controlling interests, where this would be commercially expected
· Seeking of anonymity by conducting ordinary business through accountants, lawyers, or other intermediaries
· Use of cash in a nonstandard manner
· Involve politically exposed persons.
Environmental Responsibility
We are commitment to sound environmental programs and practices, and encourages the reduction and recycling of waste. Vendors must comply with all applicable laws relating to the environment and dispose of hazardous materials in a controlled and safe manner. RAM Jewelry encourages vendors to be equally dedicated to pursuing continuous efforts to improve the compatibility of its operations with the environment
Waste and Emissions
Vendors are required to dispose of waste substances in compliance with applicable laws and regulations.
Hazardous Substance
Vendors are responsible for the correct labelling, storage, and usage of chemicals and hazardous substances in
accordance to applicable laws and regulations.
Bribery, Facilitation Payments, and the Foreign Corrupt Practices Act
RAM Jewelry and vendors are responsible for prohibiting bribery and facilitation payments throughout all of their business transactions. Suppliers are required to consider bribery as a risk and take the appropriate steps to monitor and vet possible vulnerabilities. Vendors are required to adopt and communicate a zero tolerance policy on these practices.
Our Anti-Money Laundering
Our Company and our vendors shall adopt a zero-tolerance approach towards bribery and corruption. Top managements affirm their commitment towards compliance with all relevant laws by making sure relevant training implemented, policy reviewed and proper monitoring system is in place.
No any sort of cash transaction is accepted in our company.
Gifts and Entertainment
Great care must be taken to ensure that no gifts or entertainment could be interpreted as bribes or improper forms of
compensation or payment.
Money Laundering and Financing of Terrorism
Money laundering and the financing of terrorism are strictly prohibited. Vendors must maintain financial accounts of all business transactions. These records must comply with national and international accounting standards. Vendors are strongly encouraged to conduct a self-audit annually.
Sanctions and Trade Embargoes
Trade with countries and territories is severely restricted. U.S. law has instituted trade sanctions that may restrict or prohibit certain imports, exports, offshore transactions and financial transactions by U.S. companies and U.S. nationals (collectively, "U.S. Persons") with certain designated countries, groups or persons in those countries, including the Balkans, Belarus, Cote d'Ivoire, Cuba, the Democratic Republic of the Congo, Iran, Iraq, Liberia, Myanmar, North Korea, Somalia, Sudan, Syria, Venezuela and Zimbabwe.
Risk assessment on Bribery
RAM manages bribery and corruption risk through a mix of internal processes, certification requirements, and basic good practices throughout their operations including with suppliers and vendors. Bribery risk assessment is implemented to identify those parts of our business that are potentially exposed to bribery risk. The assessment should identify all relevant types of bribery risk and distinguish between different parts of company, according to their level of risk. This differentiation will help us target anti-corruption programmes, controls, training and monitoring at the areas at greatest risk.
Business relationships
RAM expects its business partners to approach issues of bribery and corruption in a manner that is consistent with the principles setout in this policy. This requirement applies to agents, vendors, and other business associates. In cases where the Company is unable to ensure these requirements, it will reconsider the business relationship.
Anti-bribery Due diligence
The execution of the anti-bribery due diligence allows us to identify and mitigate (pre-closing) specific risks associated with the target entity.
Communication & Training
RAM Jewelry implemented Anti-Bribery act policy that should be communicated to all stakeholders and employees. This Policy is intended to outline the Company’s risks related to bribery and corruption, to highlight responsibilities under both the relevant anti-corruption laws and Company policies, and to provide tools and support necessary to identify and combat those anti-corruption risks. Training for all employees will be performed annually.
Personal conflicts of interest
Employees must avoid situations or transactions in which their personal interests could conflict-or be seen to be in conflict-with the interests of the Company. This includes acting on any client information gained through their employment with the Company for personal gain: passing such information to a third party: or acting in any way that could be construed as Insider Trading.
Conflicts of interest can arise if individuals have a personal interest in business dealings involving the Company. Personal interest can be direct or indirect and refers not only to personal interests but to those of family members and friends. If there is a potential for conflict, the interests of the Company must take priority.
Monitoring and investigating bribery
Necessary steps will be employed by managing director to ensure that corruption and bribery do not take root. RAM has defined a process for monitoring, recording, and investigating of bribery.
Here are the steps regarding our monitoring and investigation:
· Recording the case in bribery incident register.
· Having meeting with relevant supervisor for investigation.
· Perform the investigation and report within 5 working days in following meeting.
· Take proper action.
Records of any bribery incidents.
Records of sanctions will be implemented for bribery or attempted bribery, including internal management reports, communications with managers or, meeting minutes.”
Third party gift register
RAM has a ‘third party gift register’ and use it to record any gifts that employees including managers give receive or accept. This includes large charitable contributions or sponsorships, as well as community payments and hospitality expenses.
Any gift from company to employees or external parties, will be integrated into payment system. Any external or internal employee or business partner that do not follow this policy, will be sanctioned and proper actions including discontinuing working will be subjected.
Shoshana Abramov
Vp/compliance officer
Feb 15, 2024
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