RJC Compliance

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

This website uses cookies.