What Can We Do?
The jewelry industry has a long history playing important roles in many cultures, international trade, iconic design, and more. While we cherish some traditional aspects of the trade – the decision to not evolve our sourcing practices will perpetuate the problems detailed in this toolkit to an unsustainable level. It is time to imagine and take part in a better way of doing things – not only to advance global goals on sustainable development and climate change – but also to safeguard the future of our businesses.
This section of the toolkit is an introduction to the core concepts central to what has become known as “responsible sourcing.” Opportunities to learn more, and go deeper are highlighted throughout. While this toolkit is clearly focused on gold, many of the recommendations can be applied to other practices and materials of the trade.
The Amazon rainforest is home to more plants and animals than any other place on earth.
- Look Closely At Your Own Business
- Evaluate Your Supply Chain
- Communicate Your Standards to Your Suppliers
- Change Your Sourcing Practices
- Manage and Monitor
- Engage Your Customers
- Be Careful Of The Claims That You Make
- Get Involved In Efforts To Engage The Industry
- Support Organizations Working To Address The Challenges
- Your Vote Matters
- Always Be Learning
Each of these high-level steps is detailed below.
The great amassing of trees in the Amazon makes its own rainfall, releasing approximately 20 billion TONS of moisture into the atmosphere daily, seeding the rain clouds that travel the earth.
Look Closely At Your Own Business
Innovation is crucial to a successful business and change scares us. Looking hard at our own businesses or the ones we work for is essential to being able to do things differently.
Things to check right away:
Do you ask the tough questions? Could any biases get in the way of innovating? Are your habits preventing you from trying something new? Are you curious about your materials and where they come from? Have you ever stepped back to consider the larger systems that your jewelry is part of? Are you offering products younger customers want? Have you been ignoring a nagging feeling that there’s probably more you could be doing? Have you set responsible sourcing goals for your team?
You are already taking the first step by taking the time to learn. In finding our role in the solution, we can first look at how our own actions may contribute to the problem and what we can do to start working towards a better gold supply chain.
In addition to helping you retain and gain customers and comply with government regulations, responsible sourcing programs can have other benefits for your business, including:
- Identification and Management of Risks
- Maintaining and Growing Market Access
- Reducing or Avoiding Costs
- Brand Reputation
Did you know that the trees and plants pull in toxic levels of carbon dioxide and release OXYGEN back into the atmosphere giving us 20% of the AIR that we breathe?
Evaluate Your Supply Chain
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.
Spotlight On OECD
At industry conferences, and in trade journals, the acronym OECD, is referred to consistently as something you should do. Why? What is it? How do you do OECD?
The OECD (Organisation for Economic Co-operation and Development) is an international organization which develops, recommends and guides due diligence policies that are aimed at “improving lives.” The OECD is currently made up of 36 member countries and has developed a number of useful guidelines that range from responsible business practices to specific guidelines for responsible gold sourcing.
For this toolkit, only a few details are shared, but links to additional OECD tools are provided in the resources section.
Why should jewelry businesses “do” OECD?
OECD is the acronym for the organization, that’s it. So what is really being asked is, “why should jewelry businesses conduct due diligence practices and how to engage in sourcing responsibly from artisanal and small-scale mining?” Putting the OECD guidelines into practice has become an industry norm because there is a clear need to be in the know about supply chains and work together to improve on-the-ground-realities. If the global jewelry industry is working to follow the same program, challenges can be addressed more easily – decreasing risks for all.
Specifically, following the OECD guidelines could,
- Improve your management systems
- Lead your business to a more transparent supply chain
- Uncover risks to your business, the industry, and to the most vulnerable in our supply chains
- Increase business opportunities
At the core of the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” is the task of establishing strong company management systems, which are defined as the following:
> Step One: Establish strong company management systems.
> Step Two: Identify and assess risks in the supply chain.
> Step Three: Design and implement a strategy to respond to identified risks.
> Step Four: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.
> Step Five: Report on supply chain due diligence.
See OECD’s specific recommendations for how to implement these guidelines (p. 15-17) The guidance goes on to outline specific recommendations depending on where your business falls within the gold supply chain.
Know Your Counterparty and Anti-Money Laundering Programs
A major driver behind governments’ and international organizations’ work to eliminate opacity from jewelry supply chains is tied to money laundering. Money laundering refers to a wide range of practices that are designed to “clean” money from illicit sources. Profits from illicit activities are transferred through a series of channels in order to obscure the source of money funding illicit activities. Money laundering can happen anywhere and as the jewelry industry trades high value good with little oversight – it is at risk for money laundering and funding criminal activity.
The Financial Action Task Force (FATF) is a multi-stakeholder group which put out a series of recommended measures in 2012 for governments’ to implement in order to prevent money laundering. In response to this risk, most countries have implemented legal regulations around anti-money laundering programs. In any country that you operate, it is crucial to know its anti-money laundering laws and ensure your business is not inadvertently tied to criminal activity.
In the United States, jewelers are recognized as part of the financial system which can be exposed to money laundering and therefore, any business that buys and sells in excess of $50,000 of precious metals, precious gemstones, and jewelry “for which 50% of the value is derived from precious stones or precious metals” must comply with Anti-Money Laundering laws by creating and implementing an anti-money laundering program.
In addition to anti-money laundering programs, the jewelry industry has also started implementing the principles of Know Your Counterparty (KYC). KYC principles help companies to establish the identity of all other companies with which they do business, clearly understand the nature of their partners’ businesses, and help identify suspicious activity. These principles, as described by RJC guidance, include:
- Establishing the identity, the ownership, and principles of the supplier or customer;
- Maintaining an understanding of the nature of their business
- Monitoring transactions for unusual or suspicious activity and reporting suspicions of money laundering or finance of terrorism to the relevant designated authority
Services like the Jewelers Vigilance Committee can help you develop your anti-money laundering program.
The Amazon keeps the earth cool.
Communicate Your Standards to Your Suppliers
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.
Change Your Sourcing Practices
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.
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.
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
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.
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
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.
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.
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
Manage and Monitor
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.
Engage Your Custormers
While the jewelry industry lags behind on sustainability, other industries are not – and consumers are becoming more discerning about almost all the products that they buy. Today more than ever, consumers want to know that the way in which they spend their money – at the very least – does not contribute to human and environmental harm. As this trend continues, it is likely more and more customers will be asking about the source of your gold, who and where it has impacted, and how you can guarantee that their purchase supports a responsible jewelry industry. Taking the first step now will help you prepare to answer to your customers. Eventually, you can expect questions such as:
- Where does your gold come from? Can you verify the source?
- Is it from a certified responsible source like Fairmined or Fairtrade Gold? If yes, can you verify this? If not – what can you tell me about your gold?
- Is it recycled gold? If yes, can you verify this? If not – what can you tell me about your gold?
- Do you take any steps to verify that your gold does not come from an illicit or illicit source? If yes, what are they?
Taking the steps to know your supply chain can help prepare you to answer these questions authentically, share information about the state of the industry with your customers, and reflect to them that you are informed and conscientious in your sourcing practices.
Be Careful Of the Claims You Make
When working to become a jewelry company with a responsible and sustainable supply chain, make sure that any public claims you make can be authenticated. Sharing your responsible jewelry journey can educate your customers and the public, encourage buying from sources that support people and the planet, and advance the changes needed in the industry. On the other hand – greenwashing responsible jewelry practices is not only wrong – it can also hurt transparency efforts, further perpetuating the problem.
Many companies are already engaged in the practice of greenwashing – marketing their business as “ethical jewelry” or “sustainable jewelry” without any tangible proof that they take actions to ensure their supply chains do not contribute to harming the environment or people. While it may attract some customers for now, this type of greenwashing perpetuates damage by continuing to hide the abuses of the industry and takes business away from companies working to do the right thing. Furthermore, it is possible that legal regulations will eventually extend to greenwashing jewelry marketing – making false claims illicit.
Claims related to responsible sourcing, responsible practices, ethics, and sustainability in marketing and advertising materials should be created with caution and made exceedingly clear.
“The Invisible River in the Sky”, carries more moisture in the atmosphere above the Amazon than waters in the Amazon Rivers.
Get Involved In Efforts to Engage the Industry
You are not alone in your journey to a better jewelry business. Join the growing community of designers, suppliers, retailers, businesses, NGOs, governments, and individuals working towards our shared goal for a responsible jewelry industry. Creating a network of individuals aligned with your responsible sourcing goals can reduce the stress of and help facilitate shifting your business practices, help you learn and stay up to date on the industry’s changes, and support your ideas for a better industry.
Attend annual conferences, educational events, and networking opportunities like the Chicago Responsible Jewelry Conference, the Jewelry Industry Summit, or the Fair Luxury Conference. The Gold Conference is also an informative event on issues related specifically to gold sourcing. If you attend the major industry trade shows such as AGTA Tucson and JCK Las Vegas, look for informational sessions related to responsible sourcing and sustainability.
Join the jewelry industry’s community for responsible jewelry – Ethical Metalsmiths.
You may already be part of professional groups looking to also learn more about responsible sourcing. Try creating conversations in your local Women’s Jewelry Association and Gemological Institute of America Alumni chapters – or even host a screening of River of Gold!
According to the United Nations Environment Programme artisanal and small-scale gold mining is now the number one release of mercury in the world.
Support Organizations Working to Address the Challenges
If you want to deepen your impact and transform your business into a force for good – there are endless ways to infuse yourself and your business into this important work. Deepen your work to improve your supply chain by supporting projects that help move the jewelry industry forward through education, innovation, and economic opportunities for miners and their communities.
- Work with Amazon Aid on our River of Gold Project– Host a screening of River of Gold or engage with our menu of initiatives that range from being an Artist for the Amazon to learning how you can protect the Amazon though being a be a better consumer.
- Collaborate on a project with nonprofits and NGOs working to improve reforestation and mercury cleanup at mining sites, such as Better Without Mercury or the Mercury Free Mining Challenge.
- Channel philanthropic giving to organizations supporting formalization for artisanal mining groups like the Alliance for Responsible Mining, Artisanal Gold Council, Pact’s Mine to Markets program or Solidaridad.
- Donate your time, experience, knowledge, or data to initiatives like the Delve Database or the Gemstones and Sustainable Development Knowledge Hub
The Amazon river delivers approximately 55 million gallons of water onto the Atlantic Ocean every second.
Always Be Learning
The facets of a responsible jewelry business touch on a multitude of issues worth learning about, from culture and politics to design and studio practices. We are in a period of transformation and the state of the industry is continually evolving. Creating a network, joining a community, and attending events can help you maintain a key awareness of supply chain risks and opportunities to improve. Much of the learning that will help shift practices can also come from conversations with our business partners and better understanding how we can collectively solve these issues. Beyond education – continually learning also means keeping an open mind, employing critical thinking, rethinking what we already know, and digging deeper.
Your Vote Matters!
Solving this problem requires action from all stakeholders and government officials play a major role in the implementation and oversight of environmental protections, enforcement of trade regulations, and policies affecting the rights of people.
The number of indigenous people within Brazil was estimated to be over 6 million in the 15th century. Today there are roughly 310,000. Brazil is home to more uncontacted peoples than anywhere on the planet.
Evaluating Your Progress
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
 Jewelers Vigilance Committee. “About AML.” JVC, https://jvclegal.org/about-aml/.
Responsible Jewelry Council. “Standard Guidance (COP 10) Money Laundering and Finance of Terrorism .” Responsible Jewelry Council Code of Practices Guidance, https://www.responsiblejewellery.com/files/Money-Laundering-and-Finance-of-Terrorism-RJC-Guidance-draftv1.pdf
Phillippy, Emily, et al. “Jewelry Glossary Project.” Jewelry Glossary Project, 2019, https://jewelryglossaryproject.com.
Phillippy, Emily, et al. “Jewelry Glossary Project.” Jewelry Glossary Project, 2019, https://jewelryglossaryproject.com.