COP 7: DUE DILIGENCE 

Contact Information 

COMPANY NAME: Pyrrha 

DATE: October 18th, 2023

REPORTING PERIOD: August 1st, 2022 to July 31st, 2023 (last Fiscal Year) 

CONTACT: purchasing@pyrrha.com

STEP 1: ESTABLISH STRONG COMPANY MANAGEMENT SYSTEMS

Our Policies 

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 (https://pyrrha.com/pages/responsible-business-practices-policy and https://pyrrha.com/pages/supply-chain-policy).

To support supply chain due diligence we commit to apply our 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.

To ensure that Pyrrha is capturing any changes to our suppliers’ business practices, we have made the decision this year to ask suppliers to review and re-sign our Code of Conduct and Code of Conduct Questionnaire every two years. In addition to this new measure, we will be internally reviewing these documents on an annual basis to make sure that we are continuing to represent Pyrrha’s Responsible Business Practices policy, as well as capturing relevant information as we continue to improve our Due Diligence processes.

While we have always conducted research into new business partners to ensure we are values aligned, over the past year we have continued to strengthen our due diligence efforts with this internal documentation.

Our Grievance Mechanism 

Our grievance mechanism for Our grievance mechanism for internal stakeholders (ie, employees) can be accessed via our website (https://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 (https://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. Any gaps in our database are investigated and filled in at this time. This process acts as a final check that we have all of the relevant information to be able to identify risks during our due diligence process.

Next, we update a list of Conflict And High Risk Areas that, 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.

The vast majority of Pyrrha’s purchasing is done with one major supplier of recycled gold and silver, and one supplier of silver chains. The first supplier is in good standing with the LBMA, and the second is a member of the Responsible Jewellery Council. Our due diligence efforts confirmed that the raw metals we purchase are 100% recycled, and originate in Canada and the US. This makes the majority of our supply chain very low risk.

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 in 2022 that there is some political instability in the country, and will continue to watch the situation carefully.

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. All identified risks are reported to the Director of Operations, and 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 Risk Management Plan tailored to each risk identified. Pyrrha’s main strategy is to stop purchasing from supply chains we identify as carrying risk if we cannot assess the supply chain back to the source. Mitigation efforts before this decision include speaking with our suppliers to gather more information about the source and movement of supplies as far up the supply chain as possible, and conducting risk assessments on upstream suppliers where possible.

Training 

Pyrrha provided the training regarding our due diligence activities to our Purchasing Manager throughout summer 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.

Reporting

We commit to publishing an annual update to this report each year going forward.

CARRY OUT A THIRD PARTY AUDIT (OPTIONAL INFORMATION)

Pyrrha joined the RJC in November 2021 and received a 3 Year Certification April 6, 2023. Our latest third-party RJC audit was conducted in September 2022 in order to achieve this certification.