Knowing your supply chain takes work. Luckily, there are rules, guidelines, and people willing to help. Why? Because the stakes are high.

• Do you know where your gold comes from?
• As you go up the supply chain, at what point do you lose control?
• Do you evaluate the sourcing practices of your supplier? Who does your supplier source from?
• When you purchase gold, who benefits, and who suffers? Are both the value and the cost of the material shared fairly?
• Do you know what expectations you should have of a “responsible” gold supplier? 

Turns out, these questions get difficult to answer very quickly, but asking probing questions is key to practicing “due diligence,” a requirement of any responsible gold sourcing practice. “Due Diligence” basically means do your homework more thoroughly than you’ve ever done before.

In the jewelry industry today, following OECD Due Diligence Guidance is likely something that you have heard before.

Once you have determined a baseline understanding of the knowns and unknowns in your supply chain and identified goals that align with your values and best practice, such as the OECD Due Diligence Guidance, you can create a formal statement to communicate your Responsible Sourcing Policy. A responsible sourcing policy should define your requirements for a responsible and sustainable supply chain to meet best practices as your capacity allows. It should be as informed as possible and continually evolving with the intention to detail the company’s rules on sourcing and how they are implemented, managed, and evaluated. The strongest responsible sourcing policies will be endorsed by senior management, publicly available, as well as include verified evidence for proof of claims, third-party auditing, and public reporting on performance.

A responsible sourcing policy can start with a supplier code of conduct. A Code of Conduct is a written document that outlines and communicates the business’ values, principles, rules, and standards for behavior. It informs your suppliers of your expectations and helps to protect your business.

Again, improving the jewelry industry is a process that is constantly evolving and requires continual improvement. It is likely that as transparency and traceability become more common, it will take some suppliers longer to make the transition depending on their size, location, years in business, or other factors. The goal is not to suddenly place unattainable standards on suppliers which they have never had to adhere to before. Instead, the goal to improve the industry by creating transparency so we can know the realities and then take steps to have a better impact. When considering suppliers with less capacity to immediately improve, reward those that are willing to be honest, have a desire to consistently make their businesses better, and can verify that action is being taken.

In evaluating your supply chain and identifying your standards for conduct, you may encounter the best scenarios where a supplier is also concerned about their supply chain and is doing what they can to gain more information and improve. You may also encounter worst case scenarios where you get responses that are meant to comfort you without providing meaningful information or your supplier might simply refuse to even engage in a conversation about responsible sourcing.

Imperfection is acceptable for now – but lying or failing to try is not. In those cases – it’s best to look for another supplier who is willing to work on responsible sourcing with you. 

Gold from certified small-scale, artisanal mining cooperatives

Using only recycled gold will also not prevent gold mining to stop all together. It is important to not shift away completely from newly mined gold but instead create a better gold supply chain that benefits rather than exploits vulnerable people and accounts for the environmental costs of its operations.

Several initiatives exist to create a traceable and responsible supply of gold through a set of audited standards which include measures to ensure safe and healthy labor practices, reduced or eliminated the use of mercury, recuperation of land after mining, and a premium for the gold to be invested in economic and social development of the surrounding areas, among other points.

FAIRMINED

Fairmined.org

Fairmined Gold Standard

A label applied to gold and silver that is sourced exclusively from artisanal and small-scale mining organizations that meet the requirements of the Fairmined Standard written by the Alliance for Responsible Mining (ARM). This standard attempts to improve trading conditions and environmental sustainability for producers in developing countries.^[46]

Organization: Alliance for Responsible Mining (ARM)

Product Label: Fairmined

Certification body: Alliance for Responsible Mining (ARM)

The FAIRMINED standard guarantees a minimum price to miners, supports small-scale operations with low environmental impact, a healthy and safe workplace for miners, and safe or reduced handling of chemicals or chemical-free extraction.

Contact Fairmined to learn more.

FAIRTRADE CERTIFIED GOLD

Fairtradegold.org

Fairtrade Standard for Gold and Associated Precious Metals for Artisanal and Small-Scale Mining

A label applied to products that are third-party certified against standards created by FLOcert (Fairtrade Labeling Organizations International), the certification body of Fairtrade International. This standard attempts to improve trading conditions and environmental sustainability for producers in developing countries. As of 2019, gold and silver are the only Fairtrade jewelry-related products.^[47]

Organization: Fairtrade International

Product Label: Fairtrade/FAIRTRADE

Certification body: FLOCert (Fairtrade Labeling Organizations International)

The Fairtrade standard guarantees a minimum price to miners, supports small-scale operations with low environmental impact, a healthy and safe workplace for miners, and safe or reduced handling of chemicals or chemical-free extraction.

Contact Fairtrade to learn more

JUST GOLD  – IMPACT

Impacttransform.org

Just Gold Report

Just Gold is a project by nonprofit organization, IMPACT. The Just Gold project aims to create incentives for artisanal gold miners to channel their product to legal exporters by providing capacity building, training on better extraction techniques, and connections to legal trade outlets. The project was piloted in the Democratic Republic of Congo (DRC) in 2017 and marks the first time any consumer good has been made from conflict-free artisanal gold from DRC that is fully traceable from mine site to consumers.

CRAFT CODE

Do you have the capacity to create a new supply of responsibly sourced artisanally mined gold? Start with the CRAFT CODE.

Sourcing from artisanal miners can be an opportunity to improve mining practices and their impacts. Not all miners or mining organizations are mining in ways that meet market expectations for responsible sourcing. The CRAFT CODE: Code of Risk-mitigation for artisanal and small-scale mining engaging in Formal Trade is a basic standard to help public and private entities identify and work toward better artisanal and small-scale mining practices.

RECYCLED GOLD

Using recycled gold should be part of your responsible sourcing strategy, but keep the following points in mind. Recycling does not guarantee that recycled gold has a clean supply chain nor does it mean that we are all using the same definition for recycled gold. The definition matters because it determines 1) what material qualifies as recycled, and 2) it reveals where potential sourcing risks could cast doubt on the supply chain and require additional research.

Illicit gold has been tied to major refiners and found to be mixed with recycled gold.  While some suppliers work hard to maintain a tight supply chain, cycle out any new gold, and have strict management and auditing procedures in place and are essentially doing their best to keep illicit gold out of their company – others take a more relaxed approach.

Things to keep in mind when considering recycled gold:

• It is important to support and source responsible artisanally mined gold.
• Recycling gold is not preventing new mining.
• There are certified recycled gold options available from select refiners.
• Make sure you agree with the definition of “recycled” the refiner is using.
• Not all refiners offer certified recycled gold and for those that do, you can review the standard and then ask your own due diligence questions.
• Many refiners combine newly mined and recycled sources into their refined products, and also meet a variety of “responsible sourcing” standards – make sure you get all the information you can.
• All refiners should make their sourcing policies and certifications public.
• Gold refiners are not required to publicly disclose if/when they identify illicit gold in their supply chain.
• Keep in mind that gold is very easy to move, melt down, re-shape, etc. making it a target for illicit material.

Solving this problem requires a collective effort. You play an important role in driving the demand for responsibly produced materials and creating awareness amongst consumers.

• Source post-consumer recycled gold
• Encourage your customers to recycle their old or unused gold pieces
• Recycle your gold dust and scraps
• Be sure to keep certified responsibly sourced artisanally mined gold separate from other gold supplies in your studio

 

Ethical Metalsmiths’ List of Recommended Suppliers

In order to maintain your responsible sourcing policy and track potential risks and impacts of your supply chain, you will need a management plan.  Some questions to consider are:

• Who will be responsible for implementing the policies, training staff, recording data, monitoring the policy, and reporting back?

• When and how will you implement the policies?

• What training is required for staff to implement policies?

• How often will you reevaluate suppliers?

• How will others notify you of perceived risks?

• What system will be used to record data? How often will it be analyzed?

• What information will you share publicly?

Having a strong management plan in place can help you maintain accountability and regularly assess your progress to ensure that your responsible sourcing policy is working.

Your management system should:

• Enable and support the company’s sourcing policies and supplier expectations through internal structuring, staff training, and investment in any additional tools required for data capturing, supplier communications, or other needs.
• Aim to meet a transparency chain-of-custody for materials
• Strengthen supplier relationships
• Evaluate policies and performance regularly
• If you are making any claims on the content of your materials, develop an internal mechanism to track materials and keep them separate. For example, if you use recycled gold and Fairmined gold that you make claims on, these should be kept separate.
• Having a process for communication of grievances and perceived risks

The jewelry industry currently relies on written and verbal assurances. These have very clearly failed to prevent the ongoing harm created by the industry and a growth in false claims known as “greenwashing.”

We must capture more fact-based, accurate, verifiable evidence of the claims suppliers make. Suppliers should be able to provide you with verifying evidence for any claim they are making.

The goal is to create a transparent supply chain for the jewelry industry, so claims of origin are especially important. You should also capture verifying evidence for facets of your responsible sourcing policy related to points other than origin, including environmental and social responsibility-related practices.

Even a seemingly simple “recycled gold” claim should be verified. Jewelers, manufacturers and refiners should disclose the supplier, and the supplier’s credential for being a trustworthy supplier of recycled gold. What definition does the supplier use for recycled gold? What qualifies as source material for the recycled gold? Does it include customer bench sweeps and scrap, manufacturing scraps, dental industry scrap, or e-waste, investment bullion? Finally, how far up the supply chain does the supplier go to verify their source material.

In the process of establishing your responsible sourcing policy,  you may reach the point where you’d like to share your progress. There are different avenues to communicate your responsible sourcing work. While some companies may choose to pursue certification, such as the RJC or B-Corp, others might hire independent auditors and create their own report. Establishing a strong management system can help you prepare for this next step. Although attaining these certifications is not the right step for every business, your management system will be integral to communicating your policies and progress by other means.

Some companies may monitor their own business and report out on findings. In these instances, the company should be transparent about its methodology for assessing its policies or seek outside help to ensure accuracy and an additional layer of accountability. Companies that choose to monitor their own business and report out alone, without sharing their methodology, may be subject to  greater scrutiny.

Some companies find it helpful to work with a service that can assist in designing, implementing, monitoring, and reporting out on your plan, such as Christina T. Miller Sustainable Jewelry Consulting or Levin Sources.

The recommendations outlined in this toolkit are all significant steps to improving your company’s approach to responsible sourcing. Creating policies and management systems may not be the flashiest part of jewelry – but in an industry where so much is hidden, these steps in your business are critical to ending the exploitation of miners, their communities, and the environment; and building supply chains that create benefit.

In evaluating your progress, you can consider some questions:

• What have you learned about you business that you didn’t know before?

 

• How have your conversations and relationships with your suppliers changed?

 

• Can you map your supply chain? How has it changed?

 

• Who benefitted from your material purchases?

 

• How much of your material is traceable to the source?

 

• How many suppliers have signed your code of conduct, acknowledging they understand and agree to your policy?

 

• How has having a responsible sourcing program impacted your business? E.g. conversations with consumers, sales, revenue

 

• How has your relationship to your business and jewelry changed?

 

• What’s next?

You can also consider your progress through a broader lens – the United Nations Sustainable Development Goals (SDGs). Adopted by all 193 Member States of the United Nations, the SDGs are a plan to combat global poverty and inequality and protect the planet over the next decade through a series of goals and targets. These global goals engage everyone from individuals to businesses to governments to take action on a range of issues, including climate change, clean water, and consumption, inequality, economic development, and peace. The UN Global Compact provides guidance specifically for incorporating the SDGs into your business. Check out the SDGs for Business