Since commencing business in 2008 Isabella Jewellers & Refiners (Pty) Ltd has obtained a refinery
license. It is our company policy to be transparent with regards to business dealings with our
suppliers and clients.
In view of the role of the precious metals trade with regards to abuse of human rights, its
contribution to conflict, money laundering and combating terrorist financing, Isabella Jewellers &
Refiners (Pty) Ltd hereby commits itself to uphold the principles of The OECD Due Diligence Guide for
the Supply Chain of Minerals from Conflict-Affected and High-Risk Areas.
It is Isabella Jewellers & Refiners (Pty) Ltd policy to purchase precious metals from legitimate and
ethical sources and that the purchase of such precious metals has not been associated with
corruption, crime, armed conflict, misrepresentation of tax and royalty payments or human rights
abuse. We will continue to operate our corporation with honesty and the highest or moral standards
in all aspects of our business.
Isabella Jewellers & Refiners (Pty) Ltd has implemented the abovementioned policy with regards to
the purchasing of precious metals.
The Members and staff of Isabella Jewellers & Refiners (Pty) Ltd all commit to the following principles:
1. With regards to the serious abuses associated with the extraction, transport or trade of
minerals while sourcing precious metals we will not tolerate nor profit from, contribute to,
assist or facilitate the commission by any party of:
i) Any forms of torture, cruel, inhuman and degrading treatment.
ii) Any forms of forced or compulsory labour, which means work or service which is
exacted from any person under the menace of penalty and for which said person has
not offered himself voluntarily;
iii) The worst forms of child labour;
iv) Gross human rights violations and abuses such as widespread sexual violence.
v) War crimes, violation of international humanitarian laws, crimes against humanity or
genocide.

2. Regarding risk management of serious abuse, we will immediately terminate dealings with
suppliers that are identified as a risk that they are sourcing from or linked to, any party
committing or partaking in the crimes as mentioned above.
3. We will not deal with any suppliers or non-state armed groups that directly or indirectly
through the extraction, logistical support, trade, handling or export of minerals, but not
limited to procuring minerals from, making payment to or otherwise providing logistical
assistance or equipment to, non – state armed groups or their associates who:

i) Illegally control mine sites, transportation routes,points where minerals are traded and
suppliers;
ii) Illegally tax or extort money or minerals from mines, transportation routes or at trading
points
iii) Illegally tax or extort intermediaries, export companies, or traders.
4) Regarding risk management of direct or indirect support to non-state armed groups we
will immediately suspend suppliers that are identified as a high risk in that they are
sourcing from or supporting, either directly or indirectly, non-state armed groups as
defined in paragraph 3.
5) We agree to eliminate, in accordance with paragraph 10, direct or indirect support to public or
private security forces who illegally control mine sites, transportation routes and suppliers;
6) We recognize that the role of public or private security forces at the mine sites / or
surrounding areas and/or along transportation routes should be solely to maintain the rule of
law, including safeguarding human rights, providing security to mine workers, equipment and
facilities, and protecting the mine site or transportation routes from interference with
legitimate extraction and trade.
7) Where we or any company or suppliers must ensure that individuals or units of security
forces that are known to have been responsible for gross human rights abuses will not be
hired.
8) We will support efforts, or take steps, to engage with central or local authorities, international
organizations and civil society organizationsto contribute to workable solution s on how
transparency, proportionality and accountability in payments made to public security forces for
the provision of security to be improved.
9) We will support efforts, to engage with local authorities, international organizations and civil
society organizations to avoid or minimize the exposure of vulnerable groups, in particular,
artisanal miners where minerals are extracted through artisanal or small -scale mining, to
adverse impacts associated with the presence of security forces, public or private, on mine
sites.
10) In accordance with the specific position of the company, we will immediately devise, adopt and
implement a risk management plan with suppliers and other stakeholders to prevent or
mitigate the risk of direct or indirect support to public or private security forces, as identified
in paragraph 5, where we identify that such a reasonable risk exists. In such cases we will not
support such suppliers.
11) We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes
to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties
paid to governments for the purpose of mineral extraction, trade, handling, transport and
export.
12) We will takes steps to eliminate money laundering were we identify a reasonable risk of
money laundering resulting from, or connected to, the extraction, trade, handling,
transport or export of minerals derived from the illegal taxation or extortion of minerals at
points of access to mine site, along transportation routes or at points were minerals are
traded up suppliers
13) We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export
from conflict-affected and high-risk areas are paid to governments and, in accordance with the
company’s position in the supply chain, we commit to disclose such payments in accordance
with the principles Set forth under the Extractive Industry Transparency Initiative(EITI).

In accordance with the specific position of the company in the supply chain, we commit to
engage with suppliers, central or local governmental authorities, international organizations,
civil society and affected third parties, as appropriate to improve and track performance with
a view to preventing or mitigating risks of adverse impacts through measurable steps taken in
reasonable timescales. We will suspend or discontinue engagement with upstream suppliers
after failed attempts at mitigation.
15) GRIEVANCE/ COMPLAINTS POLICY / PROCEDURES
Isabella Jewellers & Refiners (Pty) Ltd has a grievance / complaints policy which states it is
normal for conflicts, complaints, grievances, disputes and disagreements to arise in business
practises and that their resolution may contain valuable lessons for the further
development of a business relationship that is fair to all and free of unfair discrimination
and harassment. This policy is in place at Isabella Jewellers & Refiners (Pty) Ltd to ensure
that business partners and employees who feel aggrieved shall have an opportunity to raise
those grievances / complaints and to have them resolved in a fair and expeditious manner.
Please request for grievance / complaints from HR department at Isabella Jewellers &
Refiners (Pty) Ltd.
The Members and staff of Isabella Jewellers & Refiners (Pty) Ltd will be required to confirm their
commitment and compliance to Isabella Jewellers & Refiners (Pty) Ltd Policy.
We will require that all suppliers conform and confirm their commitment and compliance to Isabella
Jewellers & Refiners (Pty) Ltd Policy.