Money Laundering, Terrorism Financing, Other Financial Offences / AML-CFT

  • Kim International Manufacturing, L.P. recognizes the fact that entities in the gems and jewelry sector have to take on the onus of analyzing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.

  • Strict compliance is ensured at all times, with all applicable national and, where appropriate, international laws / regulations with respect to money laundering, terrorism financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, racketeering, transfer pricing and tax evasion.

  • Kim International Manufacturing, L.P. shall act in accordance with national laws with respect to auditing of its financial accounts and maintaining internal controls as guided by various regulations.

  • Compliance officer ensure all the critical steps such as KYC& KYS, identification of suspicious transaction and other compliances for ensuring anti money laundering compliances.

Kimberley Process and System of Warranties

  • Kim International Manufacturing, L.P. is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme and World Diamond Council’s (WDC) System of Warranties Declaration.

  • The definition of ‘Conflict Gem Stone Diamonds’ as agreed by the Kimberley Process has been adopted and declaration are received from suppliers and issued to all the customers.

Anti-Bribery and Facilitation Payment Policy:

  • The Group shall ensure complete Prohibition of Bribery and Facilitation payment across organization and in all the entities.

  • Kim International Manufacturing, L.P. will not offer, accept or countenance any payment, gift, in kind, hospitality, and expense or promises as such that may compromise promises of fair competition.

  • Periodic training and awareness shall be carried out to educate employees about various type and ways of bribery and facilitation payments.

Disclosure of Treated Diamonds, Synthetics and Stimulant

  • The following essential principles will be applicable in all the transactions involving treated diamonds, synthetics and stimulant.

  • Full disclosure i.e. the complete and total release of all available information about a Diamond and all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the information is specifically requested and regardless of the effect on the value of the diamond.

  • No misuse of terminology or mis-representations or attempts to disguise the product will be made in the selling, advertising and distribution of treated diamonds, synthetics and simulant.

  • The word ‘diamond’ will not be used in the case of names of firms, manufacturers or trademarks; in connection with treated diamonds or diamond simulant or synthetic diamonds.

  • Compliance with MAP of De Beers in entire supply chain and ensure trust of retail customer is maintained.

Note:Necessary declaration is provided on invoice incase CZ or Stimulants are used and Same is communicated verbally prior to execution of trade.

Gold Sourcing Policy:

  • Kim International Manufacturing, L.P. is concerned about the environment and social impacts of irresponsible mining.

  • We at Kim International Manufacturing, L.P. will ensure that all our gold suppliers comply with gold sourcing guidelines.

  • Further we are committed to ensure that sourcing of gold and precious metals products and articles are under the highest Social, Human right and environmental standard of trade such as Dodd Frank and Signet SRSP

Supply Chain Management / Best Endeavors

  • The management of Kim International Manufacturing, L.P. is committed to taking appropriate action to use best endeavors to ensure the commitment of business partners and associated manufacturing units complying with the same.


  • Compliance is ensured at all times, with applicable national and, where appropriate, international laws / regulations with respect to employment and labour.

  • Kim International Manufacturing, L.P. shall ensure that wages and benefits for a standard working week shall meet at least national minimum standards and shall be sufficient to meet the basic needs of workers and provide some discretionary income.

  • Information regarding applicable employment policies and working practices has been communicated in a transparent manner to all employees.

Health and Safety

Kim International Manufacturing, L.P. recognizes the need to develop a sustainable, value creating business and is committed to the following:

  • Any adverse impact of our business processes on those who carry it out shall be identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.

  • This review will use appropriate standards as required by prevailing laws, expert opinion and our knowledge of best practices.

  • The review will lead to formulation of clearly described work practices and drills.

  • All our staff will be trained in the manner required to adhere to these work practices and drills.

  • The health of our staff, exposed to certain hazardous processes, will be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.

  • Workers shall not be under the influence of or abusing, drugs, alcohol and/ or other illegal substances.

  • All workplaces will be constructed to meet safety standards with local regulations as the minimum standards that will be applicable

Non Discrimination, Disciplinary Practices

  • Any form of discrimination relating to the hiring, discharge, pay, promotion and training of employees on the basis of race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, HIV status, Migrant status, membership of worker representative bodies, political affiliations, or any criteria that are unlawful is strongly discouraged by the Kim International Manufacturing, L.P. and any such reported incidents will be viewed as a serious violation of this Business Principles.

  • Kim International Manufacturing, L.P. shall assure all employees who come forward in good faith to report issues, that they will be treated fairly and respectfully.

Child Labour

  • No form of child labour should be employed at any of the facilities of Kim International Manufacturing, L.P.

  • Kim International Manufacturing, L.P. will implement suitable policy and procedures to verify the age proof all new employees joining the organization.

Forced Labour

  • The management of Kim International Manufacturing, L.P. is fully committed to ensuring that forced or involuntary labour is not practiced in any form at any of its facilities. Any reported incidents relating to forced labour will be considered as a serious violation of these Business Principles.

  • The following definitions will be applicable:

    • The Universal Declaration of Human Rights that states that ‘No one shall be held in slavery or servitude’.

    • ILO Convention 29, which defines forced or compulsory labour as ‘all work or service which is extracted from any person under the menace of any penalty, and for which the said person has not offered himself voluntarily”.

Human Rights

  • All employees in the Kim International Manufacturing, L.P.’s facilities will be treated with equality, respect and dignity.

  • Kim International Manufacturing, L.P. will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation.

  • Kim International Manufacturing, L.P. strongly discourages any form of sexually coercive, threatening, abusive or exploitative behavior.

  • Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company.

  • HSE & Anti sexual harassment committees are formed and committee shall review the compliance at regular intervals.

Environment Protection

Kim International Manufacturing, L.P. is committed to effective environmental management as one of its important corporate priorities, and will focus on the following initiatives:

  • Compliance with all applicable environmental laws and regulations

  • The impact of each of our operations on the environment will be systematically assessed for compliance with appropriately defined standards and reviewed periodically to mitigate or eliminate such impact.

  • Improvement of employee environmental awareness and performance through detailed policies and procedures, training, and recognition of excellence.

  • Measurement of environmental performance through auditing with employee accountability and reporting to senior management.

Product Security

Kim International Manufacturing, L.P. is committed to provide safety of product throughout its supply chain by following precaution as mentioned below.

  • Each and every stage of product processing is covered through blanket insurance.

  • Suitable safe guarding and storage is ensured at all stage with the help of safes.

  • All the manufacturing, sales and retailing units are guarded by security agency and monitored by close circuit cameras.

  • All the concern persons are trained on relevant safety and security procedures to be followed at all time.

Synthetic Diamonds

Kim International Manufacturing, L.P. is committed to fight against undisclosed synthetic diamonds. Following methodology has to be adopted for ensuring compliance to undisclosed synthetic Diamonds.

  • Access to effective detection system

  • Buying from trusted suppliers

  • Reporting of un-disclosure synthetics to supplier and interested parties whenever detected.

  • Record the incidents of contamination reported and implement suitable corrective and preventive measures for effective controls.

  • Classify contamination of points into different category (High, Medium & Low)

  • Identify the policy, procedure and test mechanism to implement test mechanism in the organization.

  • Necessary declaration of compliance is obtained from the supply chain and chain of assurance is passed on the customers by printing synthetic declarations on all our invoices.

I acknowledge that Kim International Manufacturing, L.P. adheres to and practices these policies and statements.

C. Mike Kim