Our Policies

What Is a CAHRA

This document’s purpose is intended to explain how M. Geller Ltd. determines if some of the relevant materials used in the supply chain may be sourced from Conflicted-Affected and High-Risk Areas (CAHRAs).  Access our Supply Chain policy here. ­­­­

The identification of ‘Conflict-affected and high-risk areas’ (CAHRAs) is a critical early step in the responsible sourcing of minerals and metals. Significant and growing numbers of companies operating in minerals and metals supply chains are impacted by regulatory or market compliance requirements that require companies to establish processes for determining whether minerals and metals have originated from, or transited through, CAHRAs.

The concept of CAHRA identification is not new, having been defined by the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas which was first published in 2011. Nevertheless, for many companies it remains an elusive and ambiguous topic.

How does M. Geller Ltd. determine if our current suppliers comply with CAHRA guidelines?

1. all suppliers are required to sign our “Code of Practice” policy agreement at the start of each new business relationship.  Our Code of Practices documents are in full compliance with the requirements of the Responsible Jewelry Council and are updated regularly. All four key factors in identifying CAHRAs are addressed within this document.  If you wish to review this document in full, please access it here.
2. we state in all our memos and invoices the following verbiage with all our natural diamonds to be compliant with the Responsible Jewelry Council Code of Practices.  The statement is as follows: “The diamonds herein invoiced have been {sourced}* purchased from legitimate sources not involved in funding conflict, in compliance with United Nations Resolutions and corresponding national laws {where the invoice is generated} **. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WDC SoW Guidelines.”  Furthermore, we require all our natural diamond suppliers to adhere to the same policies in their memos and invoices to us.  We manually inspect all natural diamond invoices to ensure that the Kimberly statement is present.
3. we have partnered with WD Diamonds to offer our customers 100% lab grown, climate neutral & sustainability diamonds with full US origin traceability. For further information on sustainable Lab Grown diamonds, please access it here.
4. we require all our suppliers and/or vendors to certify in writing that the diamonds supplied to M. Geller Ltd were not manufactured in Russia to the best of their knowledge.  Access our Russian policy here. 
5. we are certified members of the Responsible Jewelry Council (RJC) which is an industry-led group of jewelers that sets standards for everyone in the industry–from miners to retailers–so that consumers can be confident that a purchase from an RJC member has met the highest standard for ethical practices on both a product and management level. To gain and maintain our RJC membership we’re subject to regular 3rd party audits of our management and production processes.
6. we search the OFAC sanctions list when we establish a new business relationship with a supplier. OFAC is a government agency within the U.S. Department of the Treasury. OFAC stands for Office of Foreign Assets Control, which administers and enforces economic sanctions based on U.S. foreign policy. OFAC helps enforce financial crimes like anti-money laundering (AML)   regulations. https://sanctionssearch.ofac.treas.gov/

In addition, we also have our own AML policy established and require all suppliers to fill out the mandatory AML paperwork.  The AML compliance is audited independently by our Bank. Patriot Act letters are stored on site and recorded within the accounting program QuickBooks.  The AML paperwork requests the basic information on our suppliers, such as name of officers, business’ Federal Tax identification number, State Resale number, the business address, website and email information, banking details and whether the supplier also participates with an AML program of their own.

M. Geller Ltd. studies relevant websites to make sure that we are complying with changes in policies concerning Supply Chains, CAHRAs and Due Diligence.  We follow the guidelines of Due Diligence as set by European Commission, you can review the website thru this link:  https://single-market-economy.ec.europa.eu/sectors/raw-materials/due-diligence-ready/due-diligence-explained_en.  

M. Geller has conducted a Supply chain review per the OECD (Organization for Economic Co-operation and Risk Development) standards to meet due diligence guidelines for responsible supply chains of minerals for CAHRAs based on answers provided by our suppliers. https://www.oecd.org/.  We use the OECD website for information, updates and news of what is happening around the world.  We also subscribe to multiple newsletters from the OECD to keep informed on world economic issues.  https://www.oecd-ilibrary.org. Our suppliers have been asked to fill out a “Supply Chain” questionnaire. We require our suppliers to provide additional information re the origin of the supplied diamonds to us. We request both our rough and polished suppliers to provide the provenance of the rough diamonds (country of origin and/or mining company) as well as the guarantee that the diamonds are sourced/produced ethically. Their responses of their diamond sources will be compared to regions of Conflict by using the website, “Geneva Academy Rule of Law in Armed Conflict” or RULAC.org.  This website is a database and analysis reporting of armed conflicts around the world.  It shows global coverage that pinpoints areas of active conflict sites. You can view this website thru this link: https://www.rulac.org/browse/map.  An addition resource for determining Severity level and risk levels in the world is the ACAPS.org website. https://www.acaps.org/en/countries.

Any other materials, such as gold/PGM/colored gemstones that are supplied to M. Geller Ltd. will be compared using the same criteria.

Supply risk can take many forms and can manifest anywhere in the supply chain process. So, to be effective, supply risk management must be built around a framework that evaluates and assesses risk at every level – from overall risk exposure across the value chain, right down to the individual supplier level. But by monitoring above mentioned websites, M. Geller Ltd. strives to assess these risks of our upstream suppliers. 

In cases of Supply Chain complaints or if a risk is identified, M. Geller Ltd. reserves the right to terminate the business relationship of our suppliers if we find evidence of breaches of our “Code of Practice” or “Supply Chain” policy.  If that occurs, we have established a Grievance Mechanism policy by which senior management will hear all concerns or complaints about suspicious circumstances in the supply chain.  Upon compliant, we will seek out further information when possible and appropriate.  We will identify any actions that need to be taken after hearing from all parties concerned. We reserve the right to cancel orders and disengage in case of evidence of breaches and a lack of commitment to improve.  Non-compliant suppliers will be advised of our decision and the outcome in a timely fashion.  All confidential records of complaints received, and outcome will be kept on site for 5 years. Access our Grievance Policy here.

Our Supply Chain policies are annually reviewed by senior management which over 40 years of experience in the diamond industry.  The business office is responsible for storing the signed “Code of Practices” documents, Due Diligent letters, Supply Chain Questionnaire, Russian Policy, Grievances and AML compliances.  We believe in establishing strong relationships with our suppliers, that’s why you can expect a personal visit from the owner from time to time.  We will also be emailing new correspondence or questionnaires as the compliance requirements of the RJC change.  We believe in empowering our team by having annual meetings that discuss the Kimberly Process, AML procedures and Due Diligence policies.