Policy

JTS Inc.

• Responsible Jewellery Council Vendor Questionnaire (To download, please click the link).
• Vendor Questionnaire

JTS Inc. OECD Supply Chain Policy

1. JTS is a jewelry wholesaler. This policy confirms JTS’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.
2. JTS is a member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through third-party verification, that we:

• Respect human rights according to the Universal Declaration of Human Rights and International Labor Organization Fundamental Rights at Work;
• Do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
• Do not provide direct or indirect support to illegal armed groups; and
• Enable stockholders to voice concerns about the jewelry supply chain.
• Are implementing the OECD 5-step framework as a management process for risk based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

3. We will distribute our policy to our suppliers and work with suppliers who comply with our policy.
4. Regarding serious abuses associated with the extraction, transport or trade of precious metals we will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:
   • torture, cruel, inhuman and degrading treatment;
   • forced or compulsory labor;
   • the worst forms of child labor;
   • human rights violations and abuses; or
   • war crimes, violations of international humanitarian law, crimes against humanity or genocide.

5. Regarding direct or indirect support to non-state armed groups.

We only sell or purchase precious metals do not directly or indirectly support non-state armed groups, including, but not limited to, procuring precious metals from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

• control mine sites, transportation routes, points where precious metals are traded and upstream actors in the supply chain; or
• tax or extort money for precious metals at mine sites, along transportation routes or at points where precious metals are traded, or from intermediates, export companies or international traders.

6. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 5.

7. Regarding public or private security forces

We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally as described in paragraph 6.

8. Regarding bribery and fraudulent misrepresentation of the origin of precious metals such as gold, silver, or PGM.

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of precious metals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of precious metals.

9. Regarding money laundering

We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of precious metals.

JTS Inc. OECD Supply Chain Procedure

We, at JTS Inc., recognize our responsibility to identify and assess risks related to conflict-affected and high-risk areas (CAHRAs) as required by OECD. We take steps to identify risks in order to prevent or mitigate adverse impacts associated with our sourcing practices. Due diligence also enables supporting livelihoods and economic growth and prosperity if sourcing or using minerals from CAHRAs. Due diligence is an active process which results in a responsible sourcing program that is ongoing, proactive, reactive, risk based and allows for continuous improvement.

1. Establish management systems: establish a supply chain policy stating our policy on responsible sourcing from CAHRAs. The policy involves staff by consulting staff responsible for stone procurement, production, and communications. The policy is made publicly available, sent directly to immediate suppliers, and upon request may involve sending materials so that they can better understand and adhere to our policies.
   1. Structure management systems that support due diligence: our system allows us to identify suppliers and assess any associated risks relevant to our supply chain policy, assigning a senior staff member to lead the due diligence management system, recording any decisions made, and review the system regularly at least once a year.

2. Identify and assess risks: using the information gathered on our supply chain, we will identify red flags that are an indicator of a potential risk that require further investigation. Identifying location or supplier red flags is done by asking our immediate suppliers for their due diligence information, which is information from their suppliers. A record should be kept of any red flags and the evidence used to determine this.

3. Manage risks (grievance procedure): the next step is to design and implement a strategy to respond to identified risks. We will share the result of any risk assessment with senior management and outline a response to these risks. The severity and probability of and adverse impact is important in determining the scale and complexity of the response. Serious abuses with extraction, trade and transport of minerals as well as the direct or indirect support to non-state armed groups will result in immediately suspending or disengaging from suppliers and mitigating where possible. Direct or indirect support to public or private security forces who illegally control mine sites, transport routes, and upstream acts as well as bribery and fraudulent misrepresentation of the origin of minerals will result in continuing or temporarily suspending trade but also implementing measurable mitigative actions.

4. Verify due diligence: due diligence practices will be audited to verify reasonable and food faith efforts to implement them based on a continual improvement approach by showing effective management system processes and plans for improvement that can be demonstrated over time.

5. Report annually: regular public reports promote transparency and generate public confidence which will be done annually.

JTS Inc. Human Rights Policy

Section 1 – We, at JTS, Inc, recognize our responsibility to respect human rights. We believe that our business has a role to play in protecting and promoting human rights.

Section 2 – JTS Inc is committed to respect internationally recognized human rights throughout our operations and supply chains. In line with the UN Guiding Principles on Business and Human Rights, our Policy is based upon the international standards enshrined in the Universal Declaration of Human Rights and the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.

Section 3 – Human rights refer to a set of basic rights and freedoms that belong to every person in the world, regardless of where they are from, what they believe or how they choose to live their life. It is a broad concept, with economic, social, cultural, political and civil dimensions. For JTS Inc, respecting human rights means ensuring that any person involved in, or coming into contact with, our operations, supply chains and products is treated with dignity, respect, fairness and equality.

Section 4 – Our Policy sets out overarching principles for how we conduct business at JTS Inc. Together with our employees and business partners, we are committed to drive forward the implementation of this Policy throughout our operations and supply chains. We recognize unique challenges to these standards may arise and we will work to address these challenges in partnership with relevant partners and stakeholders.

Section 5 – Our policy upholds human rights related to employment so that employees labor rights, working conditions and health & safety are protected. JTS Inc is committed to ensuring the following:

1. Employment is freely chosen
2. Freedom of association
3. Working conditions are safe and hygienic
4. Child labor shall not be used
5. Living wages are paid
6. Working hours are not excessive
7. No discrimination is practiced
8. Regular employment is provided
9. No harsh or inhumane treatment is allowed

Section 6 – JTS Inc will continuously work to embed this Policy throughout the relevant processes and procedures of the company to ensure its effective implementation.

We recognize that we must take steps to identify and address any actual or potential adverse impacts, whether they are directly or indirectly linked to our business activities or relationships. We understand that human rights due diligence is a dynamic, on-going process which requires acting on the findings, tracking our actions, and communicating to our stakeholders how we address impacts.

As our human rights risks and impacts may vary over time, this policy will be subject to review if proven inadequate by our human rights due diligence process.

JTS Inc. Human Rights Procedure

JTS Inc’s human rights due diligence procedure enables us to identify, prevent, mitigate, and account for adverse human rights impacts and risks that are connected to our business activities and relationships.

1. Identify and assess human rights risks and impacts: The first step is to understand how our company’s activities and business relationships may pose risks to human rights and identify areas where the risk of adverse impacts is most significant. This is done by mapping our supply chain and identifying and knowledge gaps, increasing the visibility of our supply chain, carrying out research on salient human rights issues, and registering our risks and impacts in order to prioritize them.

2. Integrate assessment findings and respond to address risks: The second step is about deciding on the necessary actions to cease, prevent and mitigate specific negative human rights risks and impacts and ensuring that these are embedded into our business. We will assign responsibility for addressing impacts to the appropriate level and function, ensure internal decision-making, budgets and oversight enable effect responses to such impacts, define appropriate action depending on our relationship to the impacts and the extend of our leverage to influence change over these impacts.

3. Track the actions taken to prevent and mitigate human rights risks and impacts: The next step is to regularly monitor performance in preventing and mitigating adverse human rights impacts to achieve the desired result and adapt processes to ensure this. A company’s response to risks and impacts may be measured by looking at inputs and outputs (financial human and material resources used for an action, what is being produced and how it is being used), incidents, outcomes, and impacts.

1. To measure performance, we will track KPIs (inputs and outputs) and tracking methods that are internal facing (complaint box) and external facing (self-assessments)
2. Communicating our actions to stakeholders is done in a way suited to their circumstance, and done annually.

4. Provide for or support access to remedy for affected people: Next, is to provide for or support grievance mechanisms to ensure a process for systemically receiving, investigating, and responding to complaints and remediating them. These mechanisms include channels for communicating a grievance such as a complaints box, self-assessments, and general meetings.
5. Communicate how risks and impacts are being addressed: The next step is to ensure reporting efforts to prevent and address human rights impacts are completed at once a year, and shared internally and externally in a way that is accessible to the intended audiences. This reporting is aimed to reach affected stakeholders who have raised grievances or concerns, providing enough information for them to evaluate our response.
6. Pursuant to the human rights supplier code of ethics as required in COP 6-1b, JTS has been sending the code of ethics to its vendors for them to follow and put into practice. To further the effectiveness of this procedure, a system of due diligence is instituted and followed on a regular basis.
7. The due diligence procedure involves mailing the questionnaire and getting the completed answers from the vendors. The management of JTS after reviewing the answers calls the vendors and explains the procedure in full and gets the assurance of their conformity. A phone call log is kept detailing the date, vendor called, who at JTS called them, the points of the questionnaire discussed, comments made by the vendors, and any further remarks.

JTS Inc. Human Rights Grieving Mechanism

JTS has established this grievance procedure to hear concerns about circumstances for adverse human rights impacts and risks that are connected to our business activities and relationships.

Isaiah Thompson is responsible for implementing and reviewing this procedure.

Concerns can be raised by interested parties via email or telephone to:

Isaiah Thompson

212.239.4520

isaiah@jtsjewelry.com

On receiving a complaint, we will aim to:

• Get an accurate report of the complaint.
• Explain our complaint procedure.
• Find out how the complainant would like it addressed/ resolved.
• Assess the eligibility of the complaint and, where applicable, decide who should handle it internally. In cases where we are unable to address the complaint internally (e.g. where our company is too far removed from the origin of the issue raised in the complaint), we may redirect it to a more appropriate entity or institution, such as the relevant supplier or industry body.
• Where the issue can be handled internally, seek further information where possible and appropriate.
• Identify any actions we should take including hearing from all parties concerned, and monitoring the situation.
• Advise the complainant of our decisions or outcomes.
• Keep records on complaints received and the internal process followed, for at least five years.

Signed/endorsed: Isaiah Thompson

Date of effect: 8/23/23

Anti-Money Laundering Policy

Policy Statement

JTS Inc is a legal, ethical, and transparent company, and it takes the responsibility to ensure and maintain that its assets and resources are not being used for corruption, regularities, or money laundering. The company has taken it upon itself to detect frauds, irregularities, abuse of position, and institutional gains. JTS is committed to ensuring that it has adequate controls to counter money-laundering activities and terrorist financing activities, in line with the Money Laundering Regulations 2007 and the Patriot Act.

Risk assessment have been carried out to develop appropriate policies and procedures to help prevent money laundering and terrorist financing. This risk-based approach is where businesses assess the risk of whether a customer is laundering money through their business by identifying criteria that would indicate a higher risk of money laundering. An example of this is where the business does not meet the client face-to-face at any point during the transaction.

Purpose & Scope

The purpose of this policy is to ensure that the company’s financial processes and procedures are in accordance to the anti-money laundering laws.

This policy applies to every entity related to JTS and its employees, directors, officers, contractors, or any third party working on behalf of the company.  The policy is for internal use, and the administration is required to convey it to every concerned person or entity.

Money Laundering

Money laundering refers to those assets that are money that is acquired in exchange for money or assets gained unlawfully. It also includes money spent for terror purposes, regardless of the means it was obtained.

Under this policy, money earned by using the following means is considered money laundering, and it is prohibited:

1. Money or assets received in exchange for criminal or unlawful acts. Money whose origin is not explicit or earned by assisting any activity in evading lawful means.
2. Property gained after any criminal activity and its origin, location, and disposition are not transparent.
3. Property which is promoting any unlawful activity.
4. Terrorism financing.
5. Acquiring, using, or possessing any criminal property.

Procedure

The company will carry out the following procedure to identify any irregularity on behalf of any stakeholder under this policy.

The company will establish a body responsible for the implementation of this policy. Our nominated compliance officer is Isaiah Thompson, whose responsibility is to receive internal reports. Our compliance officer is then responsible for deciding whether further due diligence is needed, or whether a report should be made to the authorities. If the compliance officer or any staff notices or suspects that any transaction related to money laundering is noticed and does nothing about it, then they will be also complicit in such actions.

Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risks of the business being used to launder money or fund terrorism. The procedure is as follows:

1. Proper identification will be collected from the company. Business registration and beneficial owner’s approved identification will also be kept on file.
2. We recognize that under the regulatory guidance we will take paper documentation or run an appropriate electronic anti-money laundering check.
3. The website to check is https://www.treasury.gov/resource-center/terrorist-illicit-finance/Pages/Money-Laundering.aspx

Mitigation

As part of mitigating the risk, JTS recognizes that it is essential for all staff to receive training in anti-money laundering legislation and as such all staff are trained to understand the company’s responsibilities and how to identify risk. Each member of staff is also provided with a copy of this Anti-Money Laundering Policy as a reminder of their responsibilities and where/how to report suspicious circumstances.

To further mitigate the risks:

1. JTS has a policy of not accepting or making any cash transactions with any customer or any vendor.
2. Transfers are made only through the customer or vendor’s business account.
3. No monies will be accepted from or transferred to any unknown or new businesses without confirming it is the customer/vendor’s business account.
4. Only customers approved by the Jewelers Board of Trade will be accepted for business.

Grievance Mechanism

All parties, including stakeholders of JTS or any whistle-blowers (whether internal or external to JTS), are free to raise concerns about potential money-laundering activity of customers and vendors that JTS does business with. These concerns include but are not limited to, improper identification of customers and vendors, money paid to JTS or assets sold to JTS that originate from criminal or unlawful acts, and money paid to JTS or assets sold to JTS that promote any unlawful activity.

These parties may convey their concerns by approaching the compliance officer directly in-person, by e-mail, or telephone. In order to protect whistle-blowers, parties may also send an anonymous message to the compliance officer.

JTS keeps an accurate and updated log of all grievances and follow-up actions, and to ensure transparency this log is publicly accessible in the JTS office. Grievances are responded to in a timely and efficient manner of one business week. The compliance officer reviews grievances and recommends a verifiable corrective action that can be monitored and assessed. If a grievance is dismissed without any follow-up action, then full justification and details of any investigation is accurately logged and recorded.