Anti-Money Laundering Policy
We are fully committed to complying with all legislation and appropriate guidelines designed to prevent financial crimes and to combat money laundering activity and the funding of terrorist and criminal activity.
We are committed to fulfilling our duties and obligations to always ensure, with all applicable national and, where appropriate, international laws and regulations for the fight against money laundering, terrorism financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, transfer pricing and tax evasion.
We implemented our internal policies, procedures, and staff training to ensure full compliance. We conduct client due diligence at the beginning of the business relationship and this risk assessment is thereafter monitored on an ongoing basis for all transactions. We have defined procedures to ensure any suspicions that a money laundering offence has been or is being committed are reported to the appropriate authorities.
Ram Jewelry takes its core values seriously, responsibly, and ethically.
Customer Code of Conduct
RAM Jewelry must always its business activates with integrity and in full compliance with all laws and regulations that govern its business practices.
We conduct our business practices in compliance with RJC and other voluntary regulatory agencies.
This policy is applicable to all of our vendors and is incorporated into the Customer Code of Conduct (Customer Code).
RAM Jewelry expects customers to act within the spirit of the Customer Code and Ethics Code.
A “customer” refers to any individual, corporation, proprietorship, or firm that purchases or receives product from RAM Jewelry expects all customers to comply with the Customer Code when conducting business with or on behalf of RAM Jewelry.
Ram Jewelry takes its core values seriously, responsibly, and ethically.
Environment Policy
RAM Jewelry is committed to adhering to all laws regarding environmental impact. Additionally, the Company has invested in energy efficient LED lighting installed throughout the company. Employees are instructed to utilize the recycling bins located centrally in the office. We hold all of our suppliers to legal and RJC standards, whichever is more stringent in their local areas.
Reusing supplies, such as plastic Jewelry bags, is encouraged by the Company.
Ram Jewelry takes its core values seriously, responsibly, and ethically.
Vendor Code of Conduct
Successful vendor relationships are built on shared goals, trust and values.
A “vendor” refers to any individual, corporation, proprietorship, or firm that provides good or service to RAM Jewelry, its subsidiaries, or indirectly to our clients.
RAM Jewelry expects all vendors to comply with the Vendor Code when conducting business with or on behalf of RAM Jewelry.
RAM Jewelry conducts its business activates with integrity and in compliance with all laws and regulations that govern business practices.
Our Company conducts its business practices in compliance with RJC and other voluntary regulatory agencies.
Our policy is applicable to all our vendors and is incorporated into the Vendor Code of Conduct (Vendor Code).
RAM Jewelry expects all vendors to comply with their local laws. The local law governing a vendor’s business supersedes anything written in the Ethics Code. Vendor’s not adhering to local law or to the Company’s Ethical Code and Vendor Code of Conduct run the risk of no longer working with RAM Jewelry.
Our vendors are expected to pay regular and overtime wages as required by applicable laws. Vendors are expected to respect the basic rights of its employees when conducting business with RAM Jewelry.
Our vendors are expected to comply with all health and safety requirements. If local laws do not require, RAM Jewelry expects vendors to provide safety training, first aid supplies, and personal protective equipment (PPE) to its employees.
Under no circumstances does RAM Jewelry accept blackmail or similar behavior by vendors to its employees.
Ram Jewelry takes its core values seriously, responsibly, and ethically.
Grievance policy
1.0 OBJECTIVE
To conduct effective Grievance management with the requirements.
2.0 SCOPE
This procedure is applicable for handling of Grievances received from customer related to the
products manufactured in our company.
3.0 RESPONSIBILITIES
3.1 Managing director is responsible for handle all customer Grievances.
4.0 PRECAUTIONS
Ensure closure of the grievance within stipulated time based on the review of the corrective
and preventive actions from relevant departments such as assembly, polishing, tumbler, QC
and packaging.
5.0 SCHEDULE
Whenever Applicable
6.0 PROCEDURE
6.1 Receipt of the Grievance
6.1.1 Managing Director receives Grievances from the customer.
6.1.2 The mode of Grievance could be by telephone / e-mail / written / verbal.
6.1.3 If the Grievance is regarding the major client such as Costco, Managing Director shall
investigate and handle the issue immediately.
6.1.4 After receiving the Grievance, Managing Director shall log in the Grievance in the
Grievance record and assign a Grievance number for reference.
6.1.5 After the investigation, Managing Director shall send the result to Quality control
Manager for review.
6.1.6 Acknowledgement of receipt of Grievance shall be sent to customer within two working
days.
6.2 Investigation
6.2.1 Grievances shall segregate into 2 categories:
Product quality
Product quantity
6.2.2 Quality personnel shall jointly conduct the investigation, with Managing Director
depending upon the nature of the Grievance.
6.2.3 Grievances regarding product quality
6.2.3.1 Grievances regarding product quality shall be categorized as follows:
Grievance regarding physical parameter of the product.
Out of Specification (OOS).
6.2.4 Grievance regarding physical parameter of the product
6.2.4.1 Managing Director and quality control department shall investigate the Grievances
regarding physical parameter of the product.
6.2.4.2 Machines including tumbler and polishing machines which are used for particular batch,
shall be checked during investigation.
6.2.4.3 The investigation may extend to the comparison with the previous Lots and records.
6.2.4.4 After completion of investigation, ‘Investigation report’ shall be recorded in Grievance
management log.
6.2.6 Grievance regarding product quantity
6.2.6.1 Managing Director shall investigate the Grievance with packing department
6.2.6.2 Managing Director shall check the packing details.
6.2.6.3 Managing Director and Quality personnel shall check for the reconciliation of the batch
quantities.
6.2.6.4 After completion of investigation ‘Investigation report’ shall be recorded in Grievance
management log.
6.2.6.5 In case of incorrect packaging, Quality personnel shall check whether the packaging
material is in accordance with the customer requirements.
6.2.6.6 After completion of investigation on packaging ‘Investigation report’ shall be recorded
in Grievance management log.
6.3 Findings of the investigation
6.3.1 A preliminary finding report shall be recorded in Grievance management log within five
working days, which shall be forwarded to the customer.
6.3.2 After the completion of the investigation, detailed findings of the investigation shall be
recorded and forwarded to quality department.
6.3.3 Depending upon the investigation report, if the Grievance is not found be genuine, Quality
personnel shall give adequate justification.
6.3.4 If the Grievance is found to be genuine, find out the root causes and take corrective and
preventive actions on the Grievance.
6.4 Action plan
6.4.1 Managing Director shall evaluate the investigation report and decide the action plan
depending on the nature of the Grievance.
6.4.2 Managing Director shall suggest the corrective actions and preventive actions to be taken
in consultation with the concerned department.
6.5 Corrective actions
6.5.1 Managing Director shall provide additional evidence for justification if any.
6.5.2 Managing Director shall provide any additional information required to the customer in
the case of Grievances is regarding documents.
6.5.3 The corrective action plan may conclude for the part quantity or total recall of the
product.
6.5.4 The corrective action plan may conclude for the joint analysis with the customer.
6.5.5 The corrective action plan may conclude for the replacement of the product meeting
customer specified requirements.
6.6 Preventive actions
6.6.1 Managing Director shall facilitate the preventive actions to avoid discrepancies in future.
6.6.2 Preventive actions shall be intimated to the customer through marketing department /
Sales.
6.7 Closure of the Grievance
6.7.1 Managing Director shall close the Grievance after receiving the feedback from customer
by taking necessary action.
6.7.2 If there is no feedback from the customer with in sixty days, then the Grievance shall be
considered as closed.
6.7.3 All Grievances shall be reviewed by top management at least once a year.
Please contact Robert Shakarov (212) 768-9155, ramjewelry.nyc@gmail.com, complains box is available in main office. grievances can and should be reported anonymously
Human Rights Policy
Respect for human rights is a fundamental value of Ram Jewelry. We are committed to
supporting, respecting, and protecting human rights in our relationships with our
employees, suppliers, and business partners.
Ram Jewelry’s goal is to support, respect and protect human rights—both in our own business
activities and in our business relationships with other parties. Ram Jewelry expects the same
of its suppliers. This policy, combined with those referenced below that address human
rights within their respective scopes, reflects our commitment to human rights and
ongoing efforts to protect human rights through our operations.
Child Labor
Ram Jewelry does not employ any person below the age of 18 years at the workplace.
Forced Labor
Ram Jewelry must not use, be knowingly complicit in, or knowingly benefit from the use of
forced or involuntary labor whether bonded, imprisoned, or indentured, including debt
servitude and human trafficking.
Freedom of Association and Collective Bargaining
The National Labor Relations Act (the “Act”) provides that employees, as defined by the
Act, have the right to choose whether to form and join trade unions. Ram Jewelry, its
employees, and its suppliers must ensure that the rights of eligible employees to choose
whether to be a member of a trade union and to bargain collectively as permitted by the
Act are not unlawfully interfered with or restricted.
Anti-Discrimination and Harassment
Ram Jewelry is committed to a work environment free from discrimination, harassment, and
retaliation, and to providing equal employment opportunities to all applicants and
employees regardless of race, color, religion, gender, age, national origin, ethnicity,
marital status, sexual orientation, gender identity or expression, disability, or military
status.
Ram Jewelry , its employees, and its suppliers strive to:
• Provide equal employment opportunities to all applicants and employees.
• Maintain workplaces free from harassment or discrimination toward employees,
applicants for employment, customers, or any other individuals who visit or
conduct business with Ram Jewelry or its suppliers.
• Provide reasonable accommodations to a qualified employee or applicant with a
disability, to a pregnant employee or applicant, or to an employee or applicant for
their sincerely held religious beliefs or practices, where the reasonable
accommodation would enable the employee or applicant to perform the essential
functions of their job or to have an equal opportunity to be considered for a job.
Diversity, Equity and Inclusion
At Ram Jewelry, diversity, equity, and inclusion are fundamental values. Our commitment to
human rights is reinforced by our diversity, equity, and inclusion practices because a
diverse, equitable and inclusive culture values human rights and empowers our
employees to protect human rights and report concerns.
Safe and Healthy Workplace
At Ram Jewelry, dedication to health and safety is a fundamental value; our efforts to ensure a
healthy and safe workplace reinforce our commitment to human rights. Ram Jewelry , its
employees, and its suppliers strive to:
• Operate all aspects of business in a manner that protects the safety and health of
employees, contractors, customers, and the general public.
• Provide and use the resources needed to maintain safe and healthy workplaces.
• Identify and take reasonable measures to eliminate or mitigate potential
workplace hazards.
• Provide safety information to all employees to educate, train, and protect them
from workplace safety hazards.
• Ensure all employees are trained and empowered to stop work anytime that
unsafe conditions or behaviors are observed until the job can be completed
safely.
• Take action to prevent acts of violence, threats, and physical intimidation in the
workplace.
Implementation
Trust, transparency, and accountability support Ram Jewelry’s commitment to human rights.
Transparency and Governance
Ram Jewelry seeks to identify, manage, and prevent violations of this policy. Anyone can
report a human rights concern through the options listed below:
• Management Robert Shakarov 212-768-9155
Ram Jewelry will do its part in reviewing and conducting a risk assessment on human rights,
Labor, transparency and grievance policies.
Many of Ram Jewelry ’s commitments to human rights as described in this policy are
embedded into other relevant policies and statements, which are instrumental in
managing our overall approach to human rights, including:
• Code of Business Conduct
• Supplier Code of Conduct
• Safety Policy
• Workplace Accommodations Policy
• Policy Against Discrimination, Harassment and Retaliation
• Policy Against Sexual Harassment
• Anti-Bribery and Anti-Corruption
• Child Labor Policy
Supply Chain Policy
RAM Jewelry is a jewelry company based in New York City with the capability of polishing, setting and finishing Gold and Platinum jewelry.
RAM Jewelry implementing due diligence within own operations and its supply chain and other business relationships in respect to Labor and Human rights, Environment, Combating Bribery, Solicitations and Extortion, avoid contributing to the Finance of conflict and comply with all relevant Sanctions, Resolutions, and Laws.
RAM Jewelry will be a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:
a. Our company performs due diligence by ongoing communication with the supply chain regarding our policies, performing risk assessment, monitoring and auditing on supply chain and tracking all purchased material, Gold and Platinum from suppliers.
We will immediately stop engaging if Ram Jewelry identifies whether supply chain has activity or from high-risk or conflict-affected areas. All trades and relations will be Immediately stopped and terminated.
b. Top management approves and reviews due diligence process, policies, and procedures continuously or at least once a year.
c. All our policies, including this policy and our RJC compliance policy are publicly available and are communicated through our supply chine. Also, top management ensure suppliers due diligence practices comply with RAM supply chain policy.
Suppliers are informed that:
· Risk assessments are performed and Risk of non-compliances by our suppliers will be measured and evaluated in our risk assessment system and will be reviewed at least once a year.
· We are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains and conflict-affected and high-risk areas.
· Ram expects all suppliers respect human rights according to the Universal Declaration of Human Rights and International Labor Organization Declaration on Fundamental Principles and Rights at Work. We do not tolerate human rights violations and abuses. We also commit to using our influence to prevent abuses by others. Our complaints mechanism will be investigated, and mitigations, corrective actions and preventive measures will be taken to make sure they will be completely addressed regarding serious abuses.
· As our policy, our supply chain shall not engage in or tolerate bribery, corruption, money laundering or finance of terrorism.
· We will support and our supply chain shall contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction or trade.
· We do not provide direct or indirect support to illegal armed groups.
· We enable our stakeholders to voice concerns about the jewelry supply chain; and
· We only buy Gold and Platinum and sell our jewelry for those companies that are potentially compliant with the RJC requirements and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring golds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:
· Our suppliers shall have process and control on gold sources, and points where gold and platinum are traded and upstream actors in the supply chain.
all policies approved and endorsed by Shoshana Abramov, vp , Dated 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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