Novell Enterprises Inc. & Continental Jewellery USA
Responsible Jewelry Council (RJC)
Novell recognizes the need to establish and continually improve good business practices as set by Responsible Jewelry Council's international compliance standards on responsible practices for diamonds, colored gemstones, gold, silver and platinum group metals. The Code of Practices encompasses but is not limited to the areas of human rights, labor rights, environmental impact, mining practices, and product disclosure. Novell continues to engage in responsible business practices through annual training, due diligence, and cooperation with the various compliance members in the jewelry industry. Novell is committed to adhering to the RJC's Code of Practices as well as submitting to routine audits that are performed to ensure compliance. For more information about the RJC, please visit: www.responsiblejewellery.com
Provenance and Grievance
Novell is an "eco-friendly" company and all of our metals and stones are responsibly sourced. At Novell we take recycling, environment concerns and natural resource sustainability very seriously and are always aiming to improve. We have been committed to supply chain due diligence and make sure that our supply chain is free of any metal which were gathered for the support or benefit of armed conflict groups, terrorist groups or anyone involved in serious human rights abuse. Novell strongly condemns and refuses any material and diamonds that are sourced, that violate human rights and are committed to perform due-diligence protocol in accordance with Responsible Jewelry Council and agree and cooperate to be audited by them every term.
Novell makes every attempt to ensure that our customers are treated with consideration and that their concerns are recognized in a timely manner. Our goal is always to create a clear process of any concerns and to improve on constructive criticism. It is the right of any of our stakeholders/business partners to raise concerns about our processes on any provenance claims and file a grievance. Please email any concern to NCC@novellglobal.com for review, assessment and response. Please include all relevant documents or any questions or concerns. All communication will be directly submitted to our compliance officers for further investigation and review.
COP 7: Due Diligence
Our Sourcing Policy
To support supply chain due diligence, Novell has implemented internal measures where it sends vendors a questionnaire to fill out yearly to ensure that precious metals and stones come from legitimate, ethical sources. The senior managers responsible for overseeing supply chain due diligence are Batool Esmael – COO, Daniel Berry – CFO, Ramila Patel – Stone sourcing, and Jerry Raimondi – IT. To view: Supply Chain Policy
Novell has established a system of controls and transparency over its supply chain process, which includes our approach of creating a long-term relationship with our suppliers based on openness and trust. This method has strengthened our efforts by creating better relations. Novell also expects its suppliers to perform due diligence of their supply chain and aim to buy minerals from companies that source responsibly.
How we identify and assess risks in the supply chain
Due diligence is an ongoing process, hence we have gathered and will continue to gather information from our suppliers to see if there are any risk of human rights, forced labor, child labor, hazardous substances, waste, money laundry, bribery, and corruption. We perform enhanced due diligence and do not accept any conflict minerals that originate from or transits via a conflict affected area or human rights abuse high risk area. However, we do provide an opportunity to rectify any potential issues.
We assess our suppliers' due diligence practices by asking them to fill out KYC forms with relevant information. This process is now a formal requirement before entering any business relationship with us. During our assessment, we have identified potential risks within our supply chain from two suppliers. Both are RJC certified. One supplier has strict policies in place which shows that they are committed to fixing the issue. The other supplier has also committed to following up on potential risks by performing due diligence to confirm any infractions and rectify them as soon as possible.
Our risk plan includes first identifying risk within our supply chain and then taking the steps to design and implement risk management. Our risk management plan consists of working with the supplier by making them understand what the risk are and their impact to the supply chain. Objective of doing this is to eliminate risk completely by working closely with the vendor and track the effectiveness of the risk mitigation measures every six months. Novell has communicated to our stakeholders regarding our due diligence activities. This communication is posted online and is available externally through our website. Since our last report no grievances have been raised.
COP 6: Human Rights Policy
Novell Enterprises, Supply Chain policy establishes Human Rights commitment detailing our responsibility to adhere to it. Novell endorses this policy along with grievance mechanism and communicates it to our suppliers, and stakeholders by distributing it via email. This policy can also be accessed by our internal stakeholders via our RCJ communication board, and Paylocity app, as well as externally via our website. The senior manager responsible for overseeing our human rights impacts and grievance mechanism is our COO Batool Esmael.
As a company, we communicate our expectations regarding human rights by asking our suppliers to look at their supply chain along with us. This is accomplished by us asking them tough and thorough questions and looking at the policies they have in place to combat human right issues.
We have assessed our suppliers practice relating to human rights by looking at their responses of the supply chain, country of origin and their policies in place. During our assessment, we have identified only one risk of human rights red flag on country of origin. The vendor is RJC certified and has provided Human Right policies they have in place and are committed to upholding them.
Novell has provided training regarding human rights to our employees and communicated to our stakeholders regarding our due diligence activities, and efforts to prevent human rights risks. This communication is in the form of a meeting and face to face conversations.
