COP 7: DUE DILIGENCE
COMPANY NAME: Pyrrha
DATE: September 20th, 2022
REPORTING PERIOD: August 1st, 2021 to July 31st, 2022 (last Fiscal Year)
STEP 1: ESTABLISH STRONG COMPANY MANAGEMENT SYSTEMS
Pyrrha has the following Responsible Business Practices Policy and Supply Chain Policy in place with regard to our supply chain of gold, silver, diamonds, and coloured gemstones. These policies are communicated via email with suppliers when setting up new supplier relations and can be accessed via Pyrrha’s website (www.pyrrha.com/pages/responsible-business-practices-policy and https://pyrrha.com/pages/supply-chain-policy).
To support supply chain due diligence, in our 2021 Fiscal Year we have implemented a new annual due diligence process that is aligned with the code of practice requirements of the Responsible Jewellery Council. The senior manager responsible for overseeing supply chain due diligence is Laura Ward, Purchasing Manager, and the process is detailed in the Purchasing Manual.
Our Code of Conduct & KYC Questionnaire
Pyrrha has established a system of controls and transparency over our supply chain for precious metals, diamonds and coloured gemstones that align with the Code of Practice guidelines from the Responsible Jewellery Council and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
When we identify a new supplier, we start by sending them our Supplier Code of Conduct for review and signature. The Supplier Code of Conduct outlines Pyrrha’s expectations for our business partners with respect to human rights (e.g. working conditions and prohibition of child labour, harassment and discrimination) and the environment. We also share a questionnaire (the Code of Conduct Questionnaire and the KYC Questionnaire), which requests information specific to the supplier’s business practices and ownership. All responses are kept on Pyrrha’s internal drive in unique supplier folders, and these efforts are summarized in our Supplier Database.
While we have always conducted research into new business partners to ensure we are values-aligned, these new methods have strengthened our due diligence efforts by improving internal reporting and documentation.
Our Grievance Mechanism
Our grievance mechanism for internal stakeholders (ie, employees) can be accessed via our website (www.pyrrha.com/pages/responsible-business-practices-policy). It is also found in our Employee Handbook and in our Policy Binder, which is in the common area of our Vancouver Studio.
Our external grievance mechanism is available via the Pyrrha website (www.pyrrha.com/pages/responsible-business-practices-policy). The employee responsible for these grievance mechanisms is the Director of Operations, who will work closely with the Purchasing Manager to address any concerns that come from Pyrrha’s supply chain.
STEP 2: IDENTIFY AND ASSESS RISK IN THE SUPPLY CHAIN
We assess our supplier’s due diligence practices upon initial contact with suppliers, and review and update our records each year. Initial screening of suppliers includes reviewing their website for information about the provenance of their materials and the due diligence efforts they undertake, as well as third-party certifications (e.g. RJC) that lend credence to these claims. Especially in the case of diamonds and coloured gemstones, we enquire directly with our main contacts about the location of origin of specific stones we are interested in purchasing, and ask for proof where available. All this information is noted in our Supplier Database and in individual supplier folders.
Our annual Due Diligence process starts by first confirming who our major suppliers were in the last fiscal year, based on spend. We then review documentation for all those suppliers to ensure we have signed Code of Conducts, completed questionnaires, and up-to-date information on the origin of their metals and stones.
Next, we develop a list of Conflict And High Risk Areas, in alignment with OECD guidance. We compare our list of CAHRAs to the point of origin for our metals and gemstones, and identify and document any potential red flags using the RJC Risk Assessment Toolkit.
Our diamonds and coloured gemstones have been purchased from three to five different suppliers, who source the stones from India and the US. Melee diamonds are cut in India, and many of the coloured gemstones we’ve purchased in the past are cut in Sri Lanka. Although Sri Lanka is not currently defined by Pyrrha as a CAHRA, our Purchasing Manager identified that there is some political instability in the country, and will watch the situation carefully over the next few months. The last time Pyrrha purchased gemstones that passed through Sri Lanka was in 2018.
Our due diligence process also confirmed that all diamonds Pyrrha purchased in the last year come with a World Diamonds Council System of Warranties and are from suppliers that are part of the Kimberley Process.
STEP 3: DESIGN AND IMPLEMENT A STRATEGY
TO RESPOND TO IDENTIFIED RISKS (if applicable)
The senior manager who receives the findings our risk assessment is our Director of Operations. Since no risks were identified this year, there was no formal follow up, however if any major risks were identified in the future, they would be discussed and followed up on in alignment with the RJC Code of Practice guidelines. We have downloaded and saved the RJC Due Diligence Toolkit, which means we have templates in place to create a Risk Management Plan.
Pyrrha provided the training regarding our due diligence activities to our Purchasing Manager throughout the summer (June to September, 2022). This training included reviewing the RJC Guidance Document, completing the COP 7 Walk Through, and reviewing OECD Due Diligence guidance. We now have a Training Checklist and an updated Purchasing Manual that includes training resources.
We have also provided training regarding our due diligence activities to all of our employees at our All Hands meeting on September 12th; this training included information on the steps Pyrrha has taken to prepare for the RJC Audit, including the implementation of a Supply Chain Due Diligence process.
We commit to publishing an annual update to this report each year going forward.
CARRY OUT A THIRD PARTY AUDIT (OPTIONAL INFORMATION)
Pyrrha has joined the RJC in November 2021 and is in the process of achieving a 3 Year Certification (audit results pending). In support of our continuous improvement journey, our latest third-party RJC audit took place within our organisation against the RJC COP 2019 on September 13th and 14th, 2022.