SUSTAINABILITY

PACE GROUP OF COMPANIES has a heritage of responsibility and tradition. We continue to remain true to our Grandfather Kirtilal Mehta, the founder of Gembel Group’s vision of a responsible company where our employees are at the centre.
His vision is what inspires us to maintain our pioneering spirit.

We are committed to applying innovation and vigor to growing our business that respects people, our employee’s and the communities.
In today’s world, our business approach looks to create long-term value for our customers and our people by working in a way that takes consideration of every aspect of the social, cultural, economic and physical environment.

We ensure our business acts on purpose.

SUSTAINABILITY PACE GROUP TAKE CARE

100% NATURAL DIAMONDS

We are a family business committed to providing 100% natural diamonds and that each diamond is sourced 100% ethically. As a group, we act responsibly to ensure our company adheres to strict operating procedures.

Kimberley Process

We operate with “the Kimberley Process Certification Scheme which necessitates that a written guarantee accompanies every diamond to certify that it is not sourced illegitimately or from a conflict area.” We are committed to this approach. Providing jewellery ethically and 100% conflict free.

logo-kimberley-process

RJC

RJC COUNCIL

We are a certified member of the Responsible Jewelry Council – an international not for profit “organisation whose members are committed to promoting and protecting ethical, social and environmental practices.”

DISCIPLINE & GRIEVANCE POLICY

Discipline & Grievance Policy

Pace Diamonds NV hereby confirms that:

The company does not use corporal punishment and ensures that employees are not subjected to harsh or degrading treatment, sexual or physical harassment, mental, physical or verbal abuse, coercion or intimidation in any circumstances.

The company’s disciplinary process and related standards are in accordance to the stipulations of the Belgian legislation related to the matters.

Pace Diamonds NV has clearly communicated to all personnel the company’s disciplinary process and related standards on appropriate disciplinary procedures and employee treatment and that the process and standards apply equally to all management and staff.

Grievance procedures and investigation processes are clear and are clearly explained to all employees.

Records are maintained of employee grievances raised, investigation processes and outcomes.

Dinesh Ahuja

Director

HUMAN RIGHTS & SOCIAL POLICY

Pace Diamonds NV works to ensure that fundamental human rights and the dignity of individuals are respected at all times.

Pace Diamonds NV complies with the United Nations Universal Declaration of Human Rights and ensures that all personnel are made aware of the Declaration.

Pace Diamonds NV is aware of International Labour Organisation Conventions 138 & 146 and complies with all relevant Belgian legislation on Social Performance including but not restricted to:

  • Child labour
  • Forced labour
  • Freedom of association and collective bargaining
  • Anti-discrimination
  • Health & safety
  • Discipline & grievance procedures
  • Hours of work
  • Remuneration
  • General employment terms

We will provide training to all our personnel in matters relating to this policy.

Dinesh Ahuja

Director

https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_INSTRUMENT_ID:312484

SUPPLY CHAIN POLICY 

  • The company recognizes that sourcing from Conflict Affected and High Risk Areas should be in accordance with OECD framework.
  • Pace Diamonds NV is committed to adopt and implement sourcing policy in accordance with the OECD guidelines.
  • As a management process the company shall adopt a risk-based due diligence process for responsible sourcing of minerals from conflict-affected and high-risk areas.
  • It will neither tolerate nor profit from, contribute to, assist or facilitate violation from conflict-affected regions.
  • The company shall only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates
  • The company will immediately stop engaging with suppliers if we find a reasonable risk that they are committing abuses or are sourcing from, or linked to, any party committing violations or providing direct or indirect support to non-state armed groups
  • It will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of diamonds
  • The company will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of diamonds
https://www.oecd-ilibrary.org/sites/9789264252479-en/index.html?itemId=/content/publication/9789264252479-en

BRIBERY & FACILITATION PAYMENTS

Bribery & Facilitation Payments

Bribery

  • Bribery is offering, promising or giving, as well as demanding or accepting any undue advantage, whether directly or indirectly, to or from:
    • A public official
    • A political candidate, party or official
    • Any private sector employee (including a person who directs or works for a private sector enterprise in any capacity)

Facilitation Payment

  • Facilitation payments are paid to receive preferential treatment for something that the payment receiver is otherwise still required to do.

Control of Bribery & Facilitation Payment

  1. The company prohibits involvement in bribery in any form.
  2. No bribes or facilitation payments shall be offered, accepted or countenanced.
  3. No bribes, gifts in kind, sponsorship, political contributions, hospitality, expenses or promises shall be given to get any unfair business advantage.
  4. All gifts (given and received) shall be recorded.
  5. No bribes shall be given to wrongly influence the government decision making process or to get business advantages.
  6. The company does not indulge in facilitation payments.
  7. All accounts shall be annually audited as per the requirements of Belgian law.

Risk of Bribery

  1. Though Belgium isn’t a country with a high bribery risk, the areas where a risk of bribery exists, shall be identified in the Risk Register.
  2. Appropriate controls shall be identified to prevent such a risk from happening.
  3. The accounts shall be maintained for all cash expenses and the same shall be checked by bookkeepers.
  4. All employees shall be made aware that the company subscribes to anti-bribery policy.
  5. No employee shall pay any bribe directly or through any consultants, lawyers, etc.
  6. No employee shall face adverse consequences in case he/she refuses to pay any bribe.

Responsibilities of Employees

  1. All employees are encouraged to report instances of attempted bribery.
  2. The company supports prevention of bribery and no employee shall be penalized in any way for refusing to pay a bribe.
  3. No employee shall be penalized for refusing to indulge in facilitation payment, even if it means losing business.
  4. All cash expenses shall be maintained in a cash book and these shall be sent to bookkeepers for accounting purpose with bills / receipts.
  5. No employee shall receive any gifts from any business associate without first disclosing it to the senior management.
  6. All gifts either given or received shall be recorded.

Investigation

  1. The suspected potential incidents of bribery shall be investigated and the results will be used to update the Risk Assessment.
  2. The controls for the new potential risks will be implemented.
  3. There shall be no facilitation payments in cash or in kind.

Note: This “Procedure to Prevent Bribery” is an addition to our company’s AML policy (last updated on 15/06/2023) without restricting, limiting or contradicting the AML policy. In case such situation would occur, the AML policy always has the higher rank.

Bribery & Facilitation Payments

Bribery

  • Bribery is offering, promising or giving, as well as demanding or accepting any undue advantage, whether directly or indirectly, to or from:
    • A public official
    • A political candidate, party or official
    • Any private sector employee (including a person who directs or works for a private sector enterprise in any capacity)

Facilitation Payment

  • Facilitation payments are paid to receive preferential treatment for something that the payment receiver is otherwise still required to do.

Control of Bribery & Facilitation Payment

  1. The company prohibits involvement in bribery in any form.
  2. No bribes or facilitation payments shall be offered, accepted or countenanced.
  3. No bribes, gifts in kind, hospitality, expenses or promises shall be given to get any unfair business advantage.
  4. All gifts (given and received) shall be recorded.
  5. No bribes shall be given to wrongly influence the government decision making process or to get business advantages.
  6. The company does not indulge in facilitation payments.
  7. All accounts shall be annually audited as per the requirements of Belgian law.

Risk of Bribery

  1. Though Belgium isn’t a country with a high bribery risk, the areas where a risk of bribery exists, shall be identified in the Risk Register.
  2. Appropriate controls shall be identified to prevent such a risk from happening.
  3. The accounts shall be maintained for all cash expenses and the same shall be checked by bookkeepers.
  4. All employees shall be made aware that the company subscribes to anti-bribery policy.
  5. No employee shall pay any bribe directly or through any consultants, lawyers, etc.
  6. No employee shall face adverse consequences in case he/she refuses to pay any bribe.

Responsibilities of Employees

  1. All employees are encouraged to report instances of attempted bribery.
  2. The company supports prevention of bribery and no employee shall be penalized in any way for refusing to pay a bribe.
  3. No employee shall be penalized for refusing to indulge in facilitation payment, even if it means losing business.
  4. All cash expenses shall be maintained in a cash book and these shall be sent to bookkeepers for accounting purpose with bills / receipts.
  5. No employee shall receive any gifts from any business associate without first disclosing it to the senior management.
  6. All gifts either given or received shall be recorded.

Investigation

  1. The suspected potential incidents of bribery shall be investigated and the results will be used to update the Risk Assessment.
  2. The controls for the new potential risks will be implemented.
  3. There shall be no facilitation payments in cash or in kind.

Note: This “Procedure to Prevent Bribery” is an addition to our company’s AML policy (last updated on 15/06/2023) without restricting, limiting or contradicting the AML policy. In case such situation would occur, the AML policy always has the higher rank.

Feedback and grievances

Pace is committed to adhering to the highest standards of conduct. If our stakeholders have any concerns surrounding our ability to meet these standards, or if they believe there have been incidents where we should have done better, we would welcome the feedback. All feedback and grievances will be kept confidential and Pace will safeguard reporting parties from retaliation. After receiving a report, Pace may seek further information and clarification from reporting parties before investigating the grievance. Please contact us anonymously or non-anonymously by e-mail at dinesh@pacegems.net.

Bribery & Facilitation Payments

Bribery

  • Bribery is offering, promising or giving, as well as demanding or accepting any undue advantage, whether directly or indirectly, to or from:
    • A public official
    • A political candidate, party or official
    • Any private sector employee (including a person who directs or works for a private sector enterprise in any capacity)

Facilitation Payment

  • Facilitation payments are paid to receive preferential treatment for something that the payment receiver is otherwise still required to do.

Control of Bribery & Facilitation Payment

  1. The company prohibits involvement in bribery in any form.
  2. No bribes or facilitation payments shall be offered, accepted or countenanced.
  3. No bribes, gifts in kind, hospitality, expenses or promises shall be given to get any unfair business advantage.
  4. All gifts (given and received) shall be recorded.
  5. No bribes shall be given to wrongly influence the government decision making process or to get business advantages.
  6. The company does not indulge in facilitation payments.
  7. All accounts shall be annually audited as per the requirements of Belgian law.

Risk of Bribery

  1. Though Belgium isn’t a country with a high bribery risk, the areas where a risk of bribery exists, shall be identified in the Risk Register.
  2. Appropriate controls shall be identified to prevent such a risk from happening.
  3. The accounts shall be maintained for all cash expenses and the same shall be checked by bookkeepers.
  4. All employees shall be made aware that the company subscribes to anti-bribery policy.
  5. No employee shall pay any bribe directly or through any consultants, lawyers, etc.
  6. No employee shall face adverse consequences in case he/she refuses to pay any bribe.

Responsibilities of Employees

  1. All employees are encouraged to report instances of attempted bribery.
  2. The company supports prevention of bribery and no employee shall be penalized in any way for refusing to pay a bribe.
  3. No employee shall be penalized for refusing to indulge in facilitation payment, even if it means losing business.
  4. All cash expenses shall be maintained in a cash book and these shall be sent to bookkeepers for accounting purpose with bills / receipts.
  5. No employee shall receive any gifts from any business associate without first disclosing it to the senior management.
  6. All gifts either given or received shall be recorded.

Investigation

  1. The suspected potential incidents of bribery shall be investigated and the results will be used to update the Risk Assessment.
  2. The controls for the new potential risks will be implemented.
  3. There shall be no facilitation payments in cash or in kind.

Note: This “Procedure to Prevent Bribery” is an addition to our company’s AML policy (last updated on 15/06/2023) without restricting, limiting or contradicting the AML policy. In case such situation would occur, the AML policy always has the higher rank.

Feedback and grievances

Pace is committed to adhering to the highest standards of conduct. If our stakeholders have any concerns surrounding our ability to meet these standards, or if they believe there have been incidents where we should have done better, we would welcome the feedback. All feedback and grievances will be kept confidential and Pace will safeguard reporting parties from retaliation. After receiving a report, Pace may seek further information and clarification from reporting parties before investigating the grievance. Please contact us anonymously or non-anonymously by e-mail at dinesh@pacegems.net.

RJC FILES