Grunberger Diamonds complies with the World Diamond Council’s System of Warranties (WDC SoW). Purchase invoices must include the WDC SoW statement:
“The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict, in compliance with the United Nations resolutions and corresponding national laws. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WDC SoW Guidelines.”
Each purchase invoice is reviewed by a member of Grunberger Diamonds to ensure it includes the WDC SoW statement. To ensure that every sales invoice to customers includes the warranty, our accounting software automatically includes it on every invoice generated.
Additionally, every year, a member of Grunberger Diamonds independent of purchasing spot checks purchase and sales invoices to ensure compliance. This is done by taking a representative sampling of invoices from the previous year: six sales invoices per month. These sales invoices are matched up to the purchase invoices. And each is checked for the WDC SoW.
Grunberger Diamonds requires its supply chain to adhere to OECD guidance on responsible sourcing and supply chain due diligence. If possible human rights violations are suspected, we require members of our supply chain to report immediately. Members can lodge concerns by phone (516-482-6212), email (email@example.com), or by using our anonymous contact portal at the bottom of this page.
Human Rights Principles
We hold these principles for our office, and we require our supply chain to comply with the following human rights principles:
1. We believe in and will respect the fundamental human rights and the dignity of the individual, according to the United Nations Universal Declaration of Human Rights.
2. We will not tolerate the use of Child Labor. We will not employ any persons under the age of 15, the age for completing compulsory education, the legal minimum age for employment in the country, or the minimum age permitted under ILO conventions, whichever standard is greatest.
3. We will not use any forced, bonded, indentured or prison labor, nor restrict the freedom of movement of employees and dependents.
4. We are committed to high standards of Health and Safety in our operations. We will comply with local legislation on Work Place Health and Safety.
5. We will not prevent workers from associating freely. Where laws prohibit these freedoms, we will support parallel means of dialogue.
6. We will not discriminate based on race, ethnicity, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, marital status, physical appearance, age, or any other applicable prohibited basis in the workplace, such that all individuals who are “Fit for Work” are accorded equal opportunities and are not discriminated against on the basis of factors unrelated to their ability to perform their job.
7. We will not use corporal punishment under any circumstances and will prohibit the use of degrading treatment, harassment, abuse, coercion or intimidation in any form.
8. We will adhere to working hours and remuneration legislation. If no legislation exists in our jurisdiction, we will ensure that wages are at least equal to the average minimum in our sector and that overtime pay is at least the same as the usual hourly compensation. Working hours will not exceed the maximum set by internationally recognized standards such as the International Labour Organization. Workers must have at least one day off in every seven-day period.
9. We will strive to minimize our impact on the environment and work toward a greener supply chain. We will respect local and international environmental laws, regulations, and best professional standards; and obtain all requisite environmental permits.
Human Rights Due Diligence
Grunberger Diamonds makes an annual assessment of its impact on human rights. In the event that any deficiencies are found within the company or our supply chain, an action plan will be enacted that sets a timeline and course of action to correct the issue. Any employee or business partner who raises an issue of human rights violations will not be penalized. The issue will be taken seriously, and an action plan will be set in place to correct the issue.
Annually, David Grunberger has one-on-one interviews with each employee to discuss their concerns and to address any issues. Additionally, employees are always free to anonymously raise concerns using an anonymous suggestion box. Grunberger Diamonds will never retaliate against whistleblowers. The goal is to correct any deficiencies. If an employee raises a concern relating to human rights, David will address it by investigating the issue and conducting interviews with relevant employees. At the end of the assessment, an action plan will be made to correct the issue.
Grunberger also assesses its significant partners’ commitment to human rights. An assessment is made based on the documentation provided by the business partner, and all publicly available information, on the risk of human rights violations that the business partner poses (including OFAC and sanctions lists). We never source from conflict-affected and high-risk areas (CAHRAs). Additionally, we require our supply chain to make a commitment to these principles. In assessing red flags, we also check the beneficial ownership to make sure they are not involved in CAHRAs or sanctions lists.
David Grunberger, Daniel Grunberger, and Dave Enkosky meet annually to discuss our supply chain’s commitment to human rights. If human rights violations are discovered among any of our significant business partners, we will contact them immediately. They will be given three months to enact a corrective action plan addressing all issues. Once the action plan is set in place, the business partner will be given another six months to correct the issue. Grunberger Diamonds is free at any time during this period to sever the relationship with the business partner if it is apparent that they are not acting in good faith.
Human Rights Grievance Mechanism
Grunberger Diamonds strives for transparency and a commitment to human rights within the organization and the supply chain. We welcome all parties to voice their concerns if they suspect possible human rights problems within our company or in our supply chain. Please use this form to raise any concerns anonymously. We will investigate the claim and make an update on the finding. If a problem is substantiated, we will develop an action plan to address the issue and fix any deficiencies.