Dominion Diamond’s Board of Directors and senior management team share the belief that good governance supports the company’s strong performance and long-term success. Good governance provides oversight and accountability, strengthens internal and external processes, and builds trust with stakeholders.
The Board is responsible for the management of the business affairs of the company. It fulfills its responsibility directly as well as through four working committees:
- Audit Committee
- Nominating and Corporate Governance Committee
- Human Resources and Compensation Committee
- Health, Safety and Environmental (HSE) Committee
Board members have multifaceted professional experience, skills, knowledge and other attributes that are essential for achieving the company’s plans and objectives. Recognizing the benefits that variety brings to the company, we have a Board Diversity Policy and we strive to achieve diversity both on the Board and in senior management.
Social and Environmental Development
The Nominating and Corporate Governance Committee and the HSE Committee assist the Board in fulfilling its responsibilities related to social and environmental development.
Within the company, the CEO is responsible for:
- Ensuring the implementation of standards and systems to ensure compliance with all applicable regulations and safety standards
- Providing overall leadership to management in support of the company’s commitment to social and environmental development and business sustainability
- Ensuring that employees, consultants and contractors address, in a respectful and transparent fashion, issues and concerns of Aboriginal people
- Setting the ethical tone for the company and its management
Ethics and Business Conduct
Our Code of Ethics and Business Conduct (the Code) is written to ensure that directors, officers, suppliers and employees understand the importance we place on ethical conduct. All employees must read the Code and confirm in writing that they have done so, and must agree to abide by the terms as a condition of employment. As per section 6.2 of the Code, they have a duty to report any suspected violations to their supervisor, to a member of the Senior Leadership Team or to members of the Ethics and Compliance Committee, or to follow the procedures set out in our Whistleblower Protection Policy.
Supply Chain Integrity
Dominion Diamond employees work to ensure that suppliers and contractors understand and comply with our Code of Ethics and Business Conduct.
Our supply chain systems and processes are designed to add value to our business and reduce risk. We recently developed a supply chain policy, rolled out in May 2016, which gives preference to northern and Impact Benefit Agreement (IBA) affiliated businesses, with a specific focus on those vendors affiliated with groups that are party to an IBA. The policy confirms our commitment to working only with suppliers that demonstrate safe operating practices, ethical business conduct, responsible environmental management practices, and more.
For small businesses looking to grow, participation in competitive bidding can be complex. We are prepared to offer support and advice to northern and IBA-affiliated business with our proposal submission process to make it accessible for all businesses to compete and to meet our submission requirements.
We are in the process of formalizing many of our procedures to increase transparency and ensure fair and equitable treatment for all groups. This will include:
- Publishing quarterly business opportunity summaries for IBA partners and local communities
- Engaging with IBA partners through expressions of interest processes before issuing a formal Request for Proposals to the public
- Developing an online repository where companies can see the relevant standards and procedures, the minimum requirement for working with Dominion Diamond (e.g., CORTM certification, etc.), training requirements, vendor pre-selection criteria and more
Customers wishing to purchase rough diamonds from Dominion Diamond are required to confirm in writing, on their own letterhead, that all efforts will be taken by their management to implement the requirements of the Responsible Jewelry Council (RJC) 2013 Code of Practices. They must also confirm the following:
- They will not employ children who are less than the age of completion of compulsory schooling. In any case, they will not employ children who are less than 15 years of age. They will maintain proof of age for their employees.
- They will not indulge in practices like withholding important original documents from employees, restricting employee movements, etc., which can result in forced labour.
- They will pay at least the minimum wages required by law (as applicable) to all employees.
- They will attend to employee safety issues so that serious injury or death does not result.
- They will respect human rights of all employees and ensure no abuse of such rights.
- They will ensure that no significant adverse effect is caused to the environment.
- They will only trade in ethically sourced diamonds.
- They will always disclose any treatment that may be carried out on diamonds.
- They will not engage in money laundering or financing of terrorism.
- They will not be involved in any action that may bring disrepute to the gems and jewelry industry.
We revived the CanadaMark™ hallmark program, a strategic initiative to assure the integrity of the supply chain of Canadian diamonds from mine to retail. The CanadaMark program offers both certified and melee diamonds which are:
- Responsibly mined in Canada’s Northwest Territories
- Natural and untreated
- Tracked through audited processes at every stage, from country of origin to polished stone
CanadaMark certified diamonds are polished to meet specific quality standards, and are laser inscribed with the CanadaMark logo and a unique serial number. This number is recorded on a certificate card, which accompanies the diamond on the rest of its journey to customers.
Dominion Diamond is also a member of the Responsible Jewellery Council, which promotes responsible, ethical environmental and social practices throughout the diamond chain. In 2015, we participated in various board activities. Dominion Diamond’s Sustainable Development Policy, Code of Ethics and Business Conduct and our corporate social responsibility activities illustrate our commitment to the RJC’s responsible business practice standards.
Canada’s subscription to the Kimberley Process Certification Scheme (KPCS) and the System of Warranties further ensures that all diamonds the company sells are of known country of origin and are ethically sourced.