Note: this policy is signed and filed in official Leibish & Co Ltd. records after being communicated to all employees, and is part of a set of policies presented to new employees.
Although Leibish & Co Ltd. aim to provide and promote a harmonious working environment, occasionally problems and grievances may arise. Sometimes these problems can be magnified by misunderstandings or poor communications and it is therefore essential that they be addressed as quickly as possible.
An employee should, before invoking the formal grievance procedure, discuss the grievance with the person to whom they are accountable. The procedure is not intended to replace the usual practice whereby an employee raises any grievance quickly and informally with their immediate manager.
A grievance is a situation where an employee considers that the effect of action taken or proposed by management, or of failure by management to take action, is detrimental to them.
Issues, which are covered by separate procedures, are excluded from the grievance procedure. These include disciplinary matters, grading appeals, complaints from customers, capability code matters and harassment matters.
Matters where they are no identifiable outcomes within the remit of managers to grant will be precluded from the grievance process and dealt with informally.
As a Leibish & Co Ltd. employee you have the right to seek redress of an individual grievance. To achieve a satisfactory and speedy solution to problems Leibish & Co Ltd. has drawn up a Grievance Procedure which should be followed to allow us to deal with such claims.
If you have a grievance you must raise it within 10 days of the event occurring, Management should respond to the grievance
At all stages of the procedure you may be accompanied by a fellow employee of your choice or a Trade Union Official and should feel free at any time to talk to a member of the Personnel Department who will be happy to provide assistance and counsel whenever required.
In the event of grievance you should discuss the situation with your immediate supervisor/manager as soon as possible who will investigate the facts and then make every effort to achieve a solution satisfactory to both parties within five working days of the grievance being raised.
If however after a through discussion you felt that the problem had not been handled to your satisfaction you may raise the matter with the next level of Management. This should be done in writing through your immediate Supervisor/ Manager within five working days of the first stage being concluded.
If you still felt that the problem had not been satisfactorily resolved. The grievance should be referred in writing explaining the grounds of the grievance and why it has not been possible to resolve the issue at stage 1 of the procedure, through your Manager to the next level of Management within five working days.
Management will arrange for a meeting to take place as soon as possible, but within 5 working days of receipt of the written statement. If the matter cannot be resolved at the meeting, Leibish & Co Ltd. will respond within 5 working days of the meeting.
If an agreement is reached the basis of that agreement will be recorded in writing, given to both parties and a copy will be placed on the staff member’s personnel file.
If the matter is not resolved, the staff member may refer it to the next stage of the procedure.
In the unlikely event that a mutually satisfactory understanding is still not reached then you may resort to the Appeals Procedure where the Managing Director or their nominee within ten working days of the appeal will make a final decision. The grievance should be referred in writing through the level of Management involved in the preceding second stage within five working days. Explaining the grounds of the grievance and why it has not been possible to resolve the issue.
The time limits mentioned in the procedure will be adhered to wherever possible however variations may occur through the absence or non-availability of the appropriate staff and the complexity of the investigation.
The procedure is discretionary and does not form part of your terms and conditions of employment.
Note: this policy is signed and filed in official Leibish & Co Ltd. records after being communicated to all employees, and is part of a set of policies presented to new employees.
Leibish & Co Ltd. pride themselves on their reputation for honesty, integrity and excellence. We hold our Suppliers to the same high standards to which we hold ourselves.
Leibish & Co Ltd. therefore expects and requires that its goods and services are procured from Suppliers that share our commitment to and meet certain criteria with respect to human rights, fair and safe labor practices, environmental protection and ethical business conduct.
We not only expect our Suppliers to operate in full compliance with all applicable laws, rules and regulations, we expect each Supplier to go beyond legal compliance and strive to meet internationally recognized standards for the advancement of human rights, business ethics, and social and environmental responsibility. Suppliers shall align with the United Nations Guiding Principles on Business and Human Rights and work conscientiously to operate within its framework.
Business Integrity: The highest standards of integrity are to be upheld in all business interactions. Supplier shall conduct business ethically and all business dealings should be transparently performed and accurately reflected on Supplier’s business books and records. Supplier shall have a policy that describes its commitment to business integrity and corporate responsibility.
Suppliers will not support or source from conflict affected & high-risk areas.
Legal Compliance: Supplier shall comply with all applicable laws and regulations currently in effect and as they become effective. Supplier shall have systems in place that maintain awareness of and ensure compliance with all applicable laws and regulations, including but not limited to, laws concerning labor, health and safety, human rights, environmental protection and corruption and bribery.
Anti-Corruption and Bribery: Supplier shall not engage in any form of corrupt practices, including bribery, extortion, embezzlement, or fraud. Supplier represents and warrants that it shall not violate or cause Leibish & Co Ltd. to violate any applicable anti-corruption or bribery law (including without limitation the United States Foreign Corrupt Practices Act).
Security: Supplier shall ensure the safety and security of its employees, contractors, and visitors. Supplier shall assess security risks and establish measures that protect against product or intellectual property theft, unauthorized access to or loss of employee or customer personal information, and damage or substitution of products within the premises and off-site or in-transit.
Child Labor: Supplier shall not employ children. Children refer to any person under the age of 15, or under the age for completing compulsory education, or under the legal minimum age for employment in the country, whichever is greatest.
Working Hours: Employees shall not be required to work more than 60 hours per week, including overtime, except in extraordinary business circumstances with their consent.
Health and Safety: Supplier shall provide a safe and healthy work environment and fully comply with all applicable safety laws, regulations and industry standards. Supplier shall regularly assess the workplace for hazards and implement appropriate programs and engineering controls to minimize the risks of work related accidents.
Leibish & Co Ltd. is a Tier 2 midstream and downstream company. We prepared a Supply Chain policy. This policy has been communicated to all employees and made it publicly available on our website. A senior executive has been appointed to be responsible for the due-diligent program. He is responsible for collecting the information from all suppliers and
keeping the records for analyzing continuous improvements. Risk assessment has been done and presented to the company's top management.
From: RJC consultant Mr. Jacob Laor (IIA Internal Auditor)
To: Mr. Yossi Polnauer- CEO
I am pleased to inform you that I have completed the internal audit pertaining to the Leibish & Co Ltd. Anti Money Laundering / Combating Financial Terrorism program. The audit has been carried out as required by the company policy as per RJC requirements. Below please review the findings:
The company introduced a written policy and procedures to verify the identity of its diamond suppliers and clients. This policy is based on best past experience used by the company during the previous years of business.
The business records, such as invoices and other business records, are kept five years at the company. There are no cash transactions at the company.
The company has prepared a procedure on how to identify unusual and suspicious transactions.
Training on how to comply with company’s policy and AML/CFT legislation has been imparted to employees by the RJC consultant Mr. Jacob Laor.
The company’s financial accounts are audited annually by a certified chartered accountant firm as per local accounting standards.
The Certified Public Accountants firm Bombach, Schiff & Co. CPA, Issued a declaration letter to state that their auditors are free of any bias or influence relating to financial or other inducements.
Up to now there was no such case, which required informing the relevant authorities of any suspicious transactions that may be linked to money laundering, terrorism financing or other financial or non-financial offences. Company procedures provide necessary guidance to employees.
1. This policy confirms Leibish & Co Ltd. commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.
2. Leibish & Co Ltd. is a member of the Responsible Jewelry Council (RJC). As such, we commit to proving, through independent third-party verification, that we:
3. We also commit to using our influence to prevent abuses by others.
4. Regarding serious abuses associated with the extraction, transport or trade of minerals:
We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:
5. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.
6. Regarding direct or indirect support to non-state armed groups:
We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:
7. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.
8. Regarding public or private security forces:
We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally as described in paragraph 6.
9. Regarding bribery and fraudulent misrepresentation of the origin of minerals:
We 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 minerals.
10. Regarding money laundering:
We 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 minerals.
The RJC Code of practices policy defines the Leibish & Co Ltd. standards on business ethics, human rights, social performance and environmental performance against which Leibish & Co Ltd. are to be certified. A key feature of RJC certification is the requirement for independent third party auditing of Leibish & Co Ltd. management systems and performance. The RJC certification system also establishes mechanisms for early identification of issues, corrective action, and enforcement methodology.
The Leibish & Co Ltd. Code of practices covers a wide range of sustainable development issues, and is applicable throughout the supply chain, from rough gemstone to jewellery retail to the final consumer.
As Members of the Responsible Jewellery Council, Leibish & Co Ltd. seeks economic, social and environmental benefits from its business activities so that the company contribute to sustainable development following the guidelines: