2.1 Legislation and Regulations

• SONI INTERNATIONAL shall operate in compliance with relevant national and international legislations / regulations as applicable in the countries in which they operate.
• All personnel are expected and directed to comply with all applicable laws and regulations as well as all internal SONI INTERNATIONAL rules and policies relating to their business activities.
• It is the responsibility of personnel to know and understand legal, regulatory and internal requirements as they apply to their jobs.
• Compliance team maintains the list of applicable legal and regulatory requirements and same is followed for compliance on day to day basis. Necessary records of requirements and its compliance is maintained.

2.2 Money Laundering, Terrorism Financing, Other Financial Offences

• SONI INTERNATIONAL recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
• SONI INTERNATIONAL shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations. Following acts and international guidelines is considered while establishing company level policies
  • Prevention of Money laundering Act 2002
  • FATF 40 Recommendations and 8 special recommendations
• It is the responsibility of concerned personnel to know and understand the relevant money laundering / financial offences related legal, regulatory and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious activity that appears to be questionable may also be considered as a violation of the Business Principles, depending on the seriousness of the non-conformance.
• Compliance officer ensure all the critical steps such as KYC(know your counter parties) Identification of suspicious transaction, reporting to management and record keeping as required by the local act and legislations are complied with.
• Compliance officer caries out periodic review of AML/CFT compliances and submits his report to management on Quarterly basis.

2.3 Kimberley Process and System of Warranties

• SONI INTERNATIONAL is dealing in polished diamonds and fully committed to complying with all the requirements specified in World Diamond Council’s (WDC) System of Warranties Declaration.
• We will not engage in business with the supply chain who deals in ‘conflict diamonds’ or not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, will be considered as a violation of the Business Principles.

2.4 Anti-Bribery and Facilitation Payment Policy:

• The SONI INTERNATIONAL shall ensure complete prohibition of Bribery and facilitation payment across organization and in all the entities.
• SONI INTERNATIONAL will not offer, accept or countenance any payment, gift in kind, hospitality, expense or promises as such that may compromise promises of fair competition.
• Entity shall prohibit bribery and facilitation payment and shall comply with various rules and regulations of the land.

2.5 Disclosure of Treated Diamonds, Synthetics and Stimulant

The following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and stimulant

• Full disclosure i.e. the complete and total release of all available information about a Diamond and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the diamond.
• We deal in diamond, precious and semi-precious gem stones, colour and synthetic stones, suitable declarations and disclosures are provided before execution of sales.

2.6 Diamond & Gemstone Sourcing Policy:

Conflict Minerals Policy Statement (Diamond & Gem Stone)

SONI INTERNATIONAL is committed to being a responsible corporate citizen and is opposed to human rights abuses.  As part of that commitment, SONI INTERNATIONAL seeks to source products, components and materials from companies that share our values around human rights, ethics and environmental responsibility. 

SONI INTERNATIONAL shall strive to ensure that all its supply of diamonds are not originating from CAHRA’s and where practically possible origin of diamonds is known to us. 

What Are “Conflict Diamonds"?

Blood Diamonds, also known as “Conflict Diamonds" are stones that are produced in areas controlled by rebel forces that are opposed to internationally recognized governments. The rebels sell these diamonds, and the money is used to purchase arms or to fund their military actions.

Blood Diamonds are often produced through the forced labor of men, women and children. They are also stolen during shipment or seized by attacking the mining operations of legitimate producers. These attacks can be on the scale of a large military operation.

The stones are then smuggled into the international diamond trade and sold as legitimate gems. These diamonds are often the main source of funding for the rebels; however, arms merchants, smugglers, and dishonest diamond traders enable their actions. Enormous amounts of money are at stake, and bribes, threats, torture, and murder are modes of operation. This is why the term “blood diamonds" is used.

CAHRAs area for Diamond.

Angola ,Coast, Democratic Republic of the Congo ,Liberia, Sierra Leone, Republic of the Congo & Zimbabwe Marange Diamond Fields

CAHRAs area for Gemstones.

Unlike diamonds, there have been relatively few documented cases of colored gems used to fund conflicts. There have certainly been conflicts over gems,

Emerald mafias who fought a war in Colombia.

Campbell Bridges, the Scottish geologist who discovered tsavorite garnet, was murdered in Kenya in 2009 in a conflict over mining rights.

Chanthaburi in Eastern Thailand is located very close to the Cambodian border, near to a town called Pailin. This town was once the stronghold of the Cambodian Communists known as the Khmer Rouge estimated 1.5 million innocent people, many of them in the notorious Killing Fields.

The Pailin region in Cambodia was once famous for blue sapphire. The Khmer Rouge used the proceeds from mining Pailin sapphire to fund their offensive. It is sad to say that Pailin sapphire was one of the first “blood gemstones".

SONI INTERNATIONAL shall ensure that none of its supplies are coming from above sources. Sight Holder shall communicate its sourcing policy to all the stakeholders and will ensure effective implementation among them.

2.7 Gold & Platinum Group Of Metal Sourcing Policy:

Our Company is concerned about environment and social impacts of irresponsible mining.

We at SONI INTERNATIONAL shall ensure that all our gold suppliers are in compliance with gold souring guidelines (Dodd- Frank rules, DRC & other applicable legislation).

Further, we are committed to ensure that sourcing of gold and precious metal products and articles thereof, are under the highest Social, Human right and Environmental standard cautions of trade

2.8 Supply Chain Management / Best Endeavours

The management of SONI INTERNATIONAL is committed to take appropriate action to use best endeavours to ensure that the suppliers and contractors are committed for compliance to International Social Standards such as RJC & SMETA etc.

2.9 Employment

• Compliance is required at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.
• The SONI INTERNATIONAL shall not require Staff to work for more than the national limit of hours in a week on a regular basis.
• The SONI INTERNATIONAL shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards.

2.10 Health and Safety

SONI INTERNATIONAL recognizes the need to develop a sustainable, value creating business and is committed to the following:

• Any adverse impact of our business processes on those who carry it out shall be 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.
• The review will lead to formulation of clearly described work practices and drills.
• All our staff will be trained in the manner required to adhere to these work practices and drills.
• All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable

2.11 Non Discrimination, Disciplinary Practices

• Discrimination can mean distinction, exclusion or preference.
• Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by the SONI INTERNATIONAL Any such reported incidents will be viewed as a serious violation of this Business Principles.
• We shall at no time condone the use of corporal punishment or other forms of mental or physical coercion.
• We encourages all personnel to voice concerns promptly, if they have a genuine reason to believe that a policy, SONI INTERNATIONAL operation or practice is or will likely be in violation of any law, regulation or internalrule or policy, including this Business Principles.

2.12 Child Labour

• No form of child labour should be employed at any of the facilities of the SONI INTERNATIONAL Unless local laws stipulate a higher age, the minimum age for employment that will be applicable is fifteen (As per ILO Convention No. 138).
• For authorized adolescents (persons below 18 years of age but above 15 years), the SONI INTERNATIONAL Management is responsible for providing working conditions, hours of work and wages in compliance with applicable local laws as a minimum.
• SONI INTERNATIONAL will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

2.13 Forced Labour

• The management of SONI INTERNATIONAL is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of this Business Principles
• The following definitions will be applicable:
  • The Universal Declaration of Human Rights that states that ‘No one shall be held in slavery or servitude’
  • ILO Convention 29, which defines forced or compulsory labour as ‘all work or service which is extracted from any person under the menace of any penalty, and for which they said person has not offered himself voluntarily”

2.14 Human Rights

• All employees in the SONI INTERNATIONAL facilities will be treated with equality, respect and dignity.
• SONI INTERNATIONAL 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 SONI INTERNATIONAL strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.

2.15 Environment Protection

SONI INTERNATIONAL is committed to effective environmental management as one of its important corporate priorities, and will focus on the following initiatives:

• Compliance with all applicable environmental laws and regulations
• The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards and reviewed periodically to mitigate or eliminate such impact.
• Disposal procedures for waste generated will be clearly defined and practiced in line with standards that are set by law and best practices of the industry.
• Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.

2.16 Product Security

SONI INTERNATIONAL is committed to provide safety of product throughout its supply chain by following precaution as mentioned below

• Each and every stage of product processing it is covered through appropiate insurance
• Suitable safe guarding and storage is ensured at all stage with the help of safes
• We are taking at most care to ensure safety of visitors, Customers and interested parties, suitable arrangements such as CCTV, Multi level entry doors and other electronic intelligence.
• All the concern persons are trained on relevant safety and security procedures to be followed at all time.

Public Grievances against social & Ethical compliance of the SONI INTERNATIONAL

If you come across any instance of non compliance or specific deviation from Sourcing Policy, Ethical Policy, Financial, Non-Financial And Human Right Violationif any. Please feel free to reach us.

Further in case if you are interested to obtain the copy of our sourcing annual compliance report based on OECD guidelines. Please send an email communication to below mentioned email address.

ANNUAL BUSINESS RESPONSIBILITY & OECD COMPLIANCE REPORT FOR THE YEAR 2023-24

Section A: General Information about the Company:

SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY is an ISO 9001-2015,14001:2015 certified company, founded in the year 1997 with a vision of becoming market leader by delivering best quality products to its esteemed customers.

We are located in Special Economic Zone, Jaipur (India) and are the leading manufacturer of fine quality jewelry in Gold, Silver and various base metals using precious, semi-precious stones, cubic zirconia and synthetic stones as well as manufacturing of loose gemstones.

Being the generations old business since 1917, we are enriched in experience of producing all kinds of jewelry with stringent quality and stipulated delivery schedules. Our Quality Management system is well focused and directed to achieve its objective of utmost customer satisfaction by producing internationally recognised products at competitive prices at the global level.

We are totally committed to safeguard our employees’ interest by providing them best working environment and adhering to social responsibility in all respect.

Section B: Financial compliance of the SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY:

2.1 Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

• SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
• Strict compliance is ensured at all the entities and compliance officer has been appointed who in turn reports to SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY Management on compliance status on annual basis.
• Know Your Counter Party and other compliance of Due Diligence is followed in line with OECD guidance.
• Ongoing monitoring is carried out along with all stakeholders.

Area of concern & Remedial Measures

• Nil As on Date.

2.2 Anti-Bribery and Facilitation Payment Policy:

• The SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY shall ensure complete prohibition Bribery and facilitation payment across organization and in all the entities.
• SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY has published compliance team contact details on website to receive any grievance or complaints.

Area of concern & Remedial Measures

• Nil As on Date.

2.3 Ethical Sourcing of Gold, Silver, Platinum (Precious Metal) Policy:

• Our company is concerned about the environment and social impacts of irresponsible mining.
• SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY has identified the risk of supply chain with respect to Conflict Affected High Risk Area.
• SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY ensure 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

• We have started creating awareness about our Ethical sourcing requirements for our supply chain through email communication.
• We started Engagement with our global supply chain for obtaining the further supply chain information to ensure ethical and conflict free sourcing in metal business.

2.4 Social Compliance:

• We ensure full compliance with all applicable national and, where appropriate, international laws / regulations with respect to employment and labour codes in all our establishment.
• We respect all regulation for child labour, forced labour, non-discrimination, non-retaliation 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 the SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY where remedial measures at SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY level is required.
• Company level remedial measures are taken based on internal and external audits conducted by reputed agencies.

2.5 Health and Safety

• We at SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY 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 and drills.
• The health of our staff, exposed to certain hazardous processes, is be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
• 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.
• Organization has been blessed and we did not have any fire or any other incidents leading to dangerous circumstances.

2.6 Human Rights:

• SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY 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 behaviour.
• 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.
• SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY ensures that none of its suppliers and stake holder have engaged in any activity which can violate the Human Right Principles.
• We have carried out the Human Right Due Diligence of suppliers and other Stake holders & based on risk assessment where necessary.

Area of concern & Remedial Measures

• No Area of concern & Remedial Measures has been raised in the Human right for any of our operating units.
• Supplier’s further upstream compliance with respect to Human Right compliance for conflict free sourcing is a new development, where company is heading and would require more focus on the same.

2.7 Environment Protection:

• SONI INTERNATIONAL JEWELRY MANUFACTURING COMPANY 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, mainly Sales office and no manufacturing activity.