Ethical Policy


INTRODUCTION TO COMPANIES AND COMMITMENT

Nineteen48 is a UK-based company selling coloured gemstones from carefully selected, fully traceable sources around the world, primarily Sri Lanka and Tanzania. Gemstones sourced by the company include sapphire, ruby, aquamarine, garnet, spinel, amethyst, tourmaline, moonstone, citrine, zircon, opal, peridot and topaz. Nineteen48’s sources are all artisanal or small-scale (ASM) mines which employ local people and demonstrate responsible and ethical business practices.

Many of the stones sold by Nineteen48 are sourced from Crown Gems, a British-Sri Lankan joint venture engaged in responsible, artisanal gemstone mining and ethical gemstone dealing. Crown Gems has its own cutting facilities in Sri Lanka and employs miners and cutters with years of professional experience and a strong relationship with the company. Crown Gems has been in close partnership with Nineteen48 since the company was founded and the companies were formed with the intention of having a fully integrated supply chain.

Nineteen48 and Crown Gems are commercial enterprises with a social conscience. We are committed to sourcing and supplying responsibly mined and fully traceable coloured gemstones and working with artisanal and small-scale mines to bring affordable and ethically produced stones to the market. Both companies were established to actively contribute to local development in their source countries and to support charitable and community projects.

The Nineteen48 and Crown Gems ethos is encapsulated in the following four values:

  • Ethical - to treat everyone with whom we engage in a fair, honest and responsible manner.
  • Inspirational - to inspire our industry to change for the better.
  • Knowledgeable - to maintain a high level of expertise within our business and to share that knowledge with others.
  • Social - to help the people and communities with whom we work to prosper and benefit fully from their efforts.

This Ethical Business Policy is a commitment by both Nineteen48 and Crown Gems to responsible business practices. Nineteen48’s and Crown Gem’s Ethical Business Policy and company reporting approach integrates an assessment on the United Nations’ Sustainable Development Goals (UNSDGs).



The UNSDGs are an internationally recognised set of targets that define global sustainable development priorities and aspirations for 2030. We have indicated the goals that relate to our commitments below.

We are committed to liaising with our contractors to help raise their awareness of the ethical issues associated with their work and build their capacity through the experience of working with us, so they can embed ethical practices into their own work and procedures.

Our Ethical Business Policy is subject to annual review and is communicated publicly on our company website.


RESPONSIBLE SOURCING AND SUPPLIER ENGAGEMENT
UNSDG

We use our leverage with suppliers whenever possible to promote responsible business practices through regular communication, engagement and by performing supply chain due diligence.

We largely source from micro-enterprises and see our supply chain as an opportunity to demonstrate how to source responsibly from small businesses. We build their capacity to operate sustainably according to international best practice and facilitate access to the global market for their products. We form long-term relationships with the mining and cutting facilities that we source from, building trust in the quality of their product and the sustainability of their operations.

We advocate a continuous improvement approach by working together with our suppliers to improve their practices.

In line with our ethical policy, we expect our suppliers to:

  • Assess and address actual/potential adverse human rights impact within their operations;
  • Provide fair working conditions and act to prevent and/or address risks of labour rights violations;
  • Assess and address actual/potential adverse environmental impacts;
Run their business with integrity and have relevant systems in place to prevent corruption and bribery risks.

FAIR LABOUR PRACTICES
In accordance with the United Nations Guiding Principles on Business and Human Rights, as a business we work to ensure that human rights are respected in all areas of our business activities, and act through due diligence to avoid infringing on the rights of others, as well as address any adverse impacts that they might be linked to. We are committed to identifying, preventing and mitigating adverse human rights impacts resulting from or caused by our business activities.


NON-DISCRIMINATION

We believe in equality in the workplace and do not discriminate on the basis of race, sex, colour, national or social origin, religion, age, disability, sexual orientation, political opinion or any other status protected by applicable law. We recruit based on qualifications, performance, skills and experience. Harassment is unacceptable in the workplace and in any work-related circumstance outside the workplace. These principles apply to company employees and any subcontractors and business partners we work with.

For example, we are currently part of a project in Tanzania, working with an NGO (Pact) to form a channel to market for the Tanzanian Womens’ Miners Association (TaWoMA).

WORK HOURS AND WAGES


We operate in full compliance with applicable wage, work hours, overtime and benefits laws. We commit to workers being paid equal to or above the national living wage. We leverage our position as traders in the supply chain to support economic development in the countries we source from by working with native suppliers, ensuring that they are paid fairly for their product, and that their workers are fairly compensated.

ZERO TOLERANCE OF CHILD LABOUR

We have a zero tolerance of child labour within our supply chain. We are committed to sourcing materials from suppliers that do not recruit individuals below 18 years of age. We require our suppliers to make a written commitment that they adhere to this policy.


ZERO TOLERANCE OF FORCED LABOUR AND THE ABUSE OF LABOUR

We have a zero tolerance of all forms of forced labour, including prison labour, indentured labour, bonded labour, military labour, slave labour and any form of human trafficking within our supply chain. We require our suppliers to make a written commitment that they adhere to this policy.


FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

We respect the right of employees to join, form, or not join a labour union without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognised union, we are committed to establishing constructive dialogue with their chosen representatives.


GRIEVANCE POLICY AND PROCEDURE

We are committed to the resolution of individual grievances fairly and promptly whenever possible. Employees who have a grievance are encouraged to raise the problem formally or informally as appropriate.


SAFE AND HEALTHY WORKPLACE

We are committed to maintaining a workplace that is free from violence, harassment and intimidation. We treat our employees and subcontractors with dignity and respect. We value open and honest communication among employees and are committed to following all applicable labour and employment laws.

We conduct regular assessments of our workplaces to make sure that we offer a safe, clean working environment and provide all appropriate personal protective equipment to employees. Employees are aware that they should report any incident, and should an accident occur in the workplace, we compensate the employee to cover any health care or other expenses related to the accident.

ENVIRONMENTAL PROTECTION

As a company, we conduct our business in such a way as to prevent pollution, minimise as far as is appropriate the adverse impact on the environment of our activities and continually improve on our practices with regards to sustainability and environmental protection.

We comply with all local and national environmental laws and expect our suppliers to adopt relevant measures to mitigate and address adverse environmental impact.

For example, the Sri Lankan government conducts a compulsory assessment prior to granting permission for mining operations to commence including environmental elements, with which Crown Gems has complied. We are committed to ensuring the safe disposal of water and waste materials at the mine sites and cutting facilities in our supply chain and engage with our suppliers to monitor this.

BUSINESS INTEGRITY
It is our policy to conduct our business in a manner that is honest and ethical. We have a zero-tolerance approach to bribery and corruption and uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We pay all relevant taxes within national requirements. All payments or gifts provided for services, advice or as hospitality should be reasonable, justifiable and proportionate.
PRODUCT DISCLOSURE

We commit to providing truthful, reliable and relevant information about all our products.

Traceability information is provided to the fullest extent known and information of the physical characteristics of our products is available in compliance with relevant national laws. We also commit to answering additional enquiries about the operations of suppliers to the best of our ability.


We are passionate about making ethical products more easily available to consumers and we founded the UK Ethical Gem Fair in partnership with other UK suppliers, which markets gemstones that have full provenance and ethical sourcing, with assurance around mining and production.

PUBLIC REPORTING ON PROGRESS
We are committed to monitoring our business practices in alignment with this policy and the SDGs and publicly reporting on our progress.

As of 2019, we will conduct an annual internal review of our policies and management systems, and from this determine priority areas to improve and/or monitor. Our priorities are determined through assessing the level of risk to people and the environment, and through the extent of beneficial impact which we could have as a business.

PARTNERSHIP WITH ORGANISATIONS PROMOTING ETHICAL PRACTICES

Partnerships 

Nineteen48 is a member of the National Association of Jewellers and part of the Fair Luxury communityMore information about Nineteen48’s involvement in these initiatives and associations is outlined below.

The National Association of Jewellers (NAJ) is the UK’s leading jewellery trade association. It represents over 2000 members that operate in every aspect of the jeweller industry. As an industry-leading education provider, it delivers internationally recognised qualifications, exciting short courses and bespoke business mentoring.

As a member of the NAJ, which works diligently with its membership with a common end goal towards a clear policy of transparency and sustainability, Nineteen48 strictly abides by the NAJ’s Code of Conduct which is as follows:

  • To maintain the highest level of personal integrity, honesty and business ethics.
  • Abstain from making false or misleading statements about any member of the jewellery industry.
  • Refrain from public criticism of any NAJ member, unless all reasonable steps have been taken to resolve the relevant issues without satisfaction.
  • Provide full and accurate disclosure regarding any merchandise offered or sold (nature, quality, characteristics and origin (if known)).
  • Abstain from engaging in any conduct or business practice that may directly or indirectly mislead or deceive customers.
  • Honour all guaranties, warranties and service policies as represented to customers as well as provided by law.
  • Implement the procedure provided by the CIBJO Blue Books and the World Diamond Council’s “System of Warranties” to prevent trade in conflict diamonds.
  • Implement procedures to prevent trade in conflict gemstones and precious metals.
  • Ensure all relevant items are appropriately Hallmarked as required by UK law.
  • Make every effort to deal only with companies that do not exploit children or use child labour in accordance with the UN Global Compact and provide adequate occupational health and safety conditions and respect the environment within your own business.

Nineteen48 participates in Fair Luxury, an independent group of changemakers in the jewellery industry. Fair Luxury organised the UK’s first responsible jewellery conference in 2016. It represents all tiers of the jewellery supply chain (including miners, refiners, manufacturers, traders, designers, makers, traders and retailers), all of whom aim to set a positive example of how ethics can be better incorporated into the jewellery sector. 

The group runs events throughout the year to discuss various aspects of the jewellery supply chain and how to approach provenance and sustainability. It encourages sustainable practices in the sourcing, making and selling of jewellery both in the UK and globally.

Nineteen48 has been part of the Fair Luxury team since its inception and takes an active role in the group, including in the preparations for events and being part of the speakers’ programme. The work of Fair Luxury is at the heart of Nineteen48’s mission, providing an opportunity for businesses of all sizes to work together, promoting ethical practices and bringing about positive change in the industry.

Charitable work by Nineteen48 and Crown Gems 

Kandy Kids

Kandy Kids is a small, UK-based charitable organisation that cares for orphans and underprivileged children in Sri Lanka. Nineteen48 and Crown Gems support Kandy Kids financially and the directors of Nineteen48 and Crown Gems have also taken part in fundraisers to raise awareness and promote the charity.

Kandy Kids supports several orphanages in the Kandy area with food and equipment (both general and educational), as well as providing support in the form of scholarships to individual children from underprivileged families from the Kandy area.

Emerge Global 

Emerge Global is a charitable organisation helping girls who have suffered abuse through providing shelter, art therapy and business training.

Emerge Global works with its Sri Lanka-based sister entity, Emerge Lanka Foundation (Company Number: GA2247), to implement the Emerge Beads-to-Business, Life Skills and Mentorship programmes. The programmes equip Sri Lankan teenage girls with skills and resources for their futures, using comprehensive curricula that emphasise leadership, life skills, and business knowledge, whilst simultaneously generating savings through jewellery design. Emerge currently works in three homes with a total of around 70 teenage girls at a time.

Emerge has four main programs:

  • Beads-to-business- the girls are taught to make high quality jewellery and other skills relevant to establishing their own businesses such as budgeting, inventory management, product development, marketing, branding and financing.
  • Life Skills- the girls are taught skills around goal-setting, reproductive health, job-readiness and money management through a curriculum which includes external speakers and participatory activities.
  • Mentorship- the girls are paired with an adult role model who covers a curriculum including topics such as mental health, body image, childcare, social responsibility and goal-setting.
  • Reintegration- the girls are established in a halfway home to help them adapt in the transition from the youth shelter to normal adult life, and connected with local resources and service providers.
Nineteen48 is assisting Emerge to find new sales channels for their jewellery, particularly in the UK. This will raise awareness and promote the good work of the charity, whilst simultaneously generating more money for the young girls they are helping.

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