COP 6 & 7 Report

Company Management Systems

Clark Diamonds Ltd have Human Rights, Modern Slavery, Supply Chain, CSR and Kimberley Process policies in place, detailing our commitment to respect human rights throughout our supply chain and our supply chain due diligence on the following minerals: diamonds, gold and platinum group medals originating from conflict-affected and high-risk areas. Clark Diamonds Ltd endorse these policies to our suppliers and stakeholders by distributing them via email using Mailchimp to track deliveries and engagement. These policies can also be accessed by our internal stakeholders via the Company Intranet at Company/AA Policies and Procedures and externally via our website –

To support supply chain due diligence, we have integrated the OECD 5 step framework into all new supplier relationships and formalised this in our New Accounts Policy, available internally to all staff via the Company Intranet at Company/AA Policies and Procedures, and in hard copy openly available. To aid us in identifying our human rights impacts we have developed and implemented an ongoing CSR Policy, Supply Chain Policy, internal Human Rights Risk Assessment and Human Rights Policy, Modern Slavery Policy, which can all be accessed internally as described above and via our website.  The senior manager responsible for overseeing supply chain due diligence is Michael Barrows, Director, who has attended RJC training on COP 6 &7.

Clark Diamonds Ltd has a small supply chain consisting of long standing relationships that in many cases span 40 years.  All new supplier relationships are established by word of mouth and recommendations, and the OECD 5 step due diligence process is carried out as part of our process for opening new supplier accounts, as per the New Account Policy. 

As a company we communicate our expectations regarding human rights and supply chain due diligence by email, using Mailchimp to track delivery and open rates. In addition to this, we engage at least weekly and often daily with our key suppliers and plan to resume in person visits several times throughout the year after Covid interrupted our usual travel calendar; the outcome of doing so has been solid, long term, mutually trusting supplier relationships, many dating back decades.

Our grievance mechanism for internal stakeholders can be accessed via the Company Intranet at Company/AA Policies and Procedures, our external grievance mechanism is available via our website and has been commincated via email. No grievances were raised in the reporting period. The employee responsible for the grievance mechanisms is Michael Barrows, Director.

Identified & Assessed Risks

Our risk assessment findings are received by Michael Barrows, Director.  No red flags were identified in our due diligence, however a significant number of suppliers were not conducting due diligence on their own supply chains, and some didn’t respond despite numerous chases via email and Whatsapp.  We shall continue to communicate on the importance of due diligence to encourage supplier engagement.

Clark Diamonds Ltd provided the training regarding human rights to employees on 30th June 2022; this training included information on all the previously mentioned policies and procedures.  As a small business our due diligence is carried out by the responsible person, Michael Barrows, Director, who has attended relevant RJC training on 19th July 2022.

Clark Diamonds Ltd communicate to our stakeholders regarding our due diligence activities and efforts to prevent human rights risks. This communication is in the form of email and pubishing on our website externally, and internally by the methods previously describd, via our intranet. If a human rights risk were to be identified we communicate the risk and how we are addressing it to potentially affected stakeholders by the same methods.

Carry Out A Third Party Audit

Clark Diamonds Ltd joined the RJC in 2018 and has since achieved 1 3 year certification against the 2013 COP.

In support of our continuous improvement journey, our first third-party RJC audit against the RJC COP 2019 is booked for 21st February 2023.