Novell Enterprises Inc. & Continental Jewellery USA

1. Novell Enterprise, INC is a Jewelry Manufacturing Company.  This policy confirms Novell Enterprise’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions, and laws.

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2. Novell Enterprises, INC is a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we: a. respect human rights according to the Universal Declaration of Human Rights and International Labor Organization Fundamental Rights at Work; b. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism; c. support transparency of government payments and rights-compatible security forces in the extractives industry; d. do not provide direct or indirect support to illegal armed groups; and e. enable stakeholders to voice concerns about the jewelry supply chain. f. 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.

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3. We also commit to using our influence to prevent abuses by others. We will be reporting any knowledge of abuse or non-compliance by our supplier to other members of RJC so collectively it can be remedied.  Any complaints about materials from CAHRAs can be send to our email NCC@novellglobal.com.

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4. Regarding serious abuses associated with the extraction, transport or trade of metal/diamonds/colored gemstones: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of: a. torture, cruel, inhuman and degrading treatment; b. forced or compulsory labor; c. the worst forms of child labor; d. human rights violations and abuses; or e. war crimes, violations of international humanitarian law, crimes against humanity or genocide.

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5. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in 4 or are sourcing from, or linked to, any party committing these abuses

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6. Regarding direct or indirect support to non-state armed groups: We only sell or purchase metal/diamonds/colored gemstones that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring metal/diamonds/colored gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally: a. control mine sites, transportation routes, points where metal/diamonds/colored gemstones are traded and upstream actors in the supply chain; or b. tax or extort money or metal/diamonds/colored gemstones at mine sites, along transportation routes or at points where metal/diamonds/colored gemstones are traded, or from intermediaries, export companies or international traders.

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7. 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 6.

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8. 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

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9. Regarding bribery and fraudulent misrepresentation of the origin of metal/diamonds/colored gemstones: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of metal/diamonds/colored gemstones, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport, and export of metal/diamonds.  We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.

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10. 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 metal/diamonds/colored gemstones.

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11. Regarding the payment of taxes, fees, and royalties due to governments: We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI)