Provenance Claims

This page is designed to answer your questions on the requirements of provision 12 named ‘Provenance Claims’ of the Code of Practices (COP).

This provision allows members that make claims about the provenance of materials (source, origin or practices used when sourcing), to have these audited as part of their RJC COP audit. It does not require members to make provenance claims so it is only audited if it is applicable to your company, and you want to make a claim.

If you have any further questions on the provenance claim provision, please email our dedicated Training Manager, Maria Mursell on training@responsiblejewellery.com

What are provenance claims?

A provenance claim is a documented claim made by a member to a customer or consumer, about diamonds, gold and/or platinum group metals that are offered for sale (whether as stand-alone materials or set in jewellery) and specifically relate to their:

  • Origin – Geographical origin of material, for example country, region, mine; and/or
  • Source – Type of source, for example recycled, mined, artisanally mined, or date of production; and/or
  • Practices – Specific practices applied in the supply chain relevant to the Code of Practices, including but not limited to conflict-free status, or due diligence towards sources, including sourcing according to the Signet Responsible Sourcing Protocols (SRSPs), the Melee Assurance Protocol from the De Beers Best Practice Principles, or by using the OECD Due Diligence Guidance for Responsible Supply Chains for Minerals from Conflict-Affected and High-Risk Areas.

Such claims can serve to assure customers that the materials are sourced responsibly and specifically explain how, such as being recycled, or conflict-free.

If you have a provenance claim audited as part of your RJC audit, the claim will be included on your certificate which appears on your RJC webpage:

Do I have to make provenance claims?

No, members are not obliged to make claims. However if you do make a claim, this must be audited as part of your RJC audit. You can also add on a provenance claim as a ‘bolt-on’ to your RJC certification through a mid-term review audit, or a specific provenance claim bolt-on audit. Please see the section ‘I want to start making a claim but I’m already certified‘ below for more information.

If in doubt, review your advertising, marketing and other sales-related documentation to determine whether any provenance claims are made. Here’s an example which may not be written, but is telling your customers you will sell them diamonds from Canada:

Don’t forget to look at invoices to check if any statements that could be considered a provenance claim are included on these.

If you do make provenance claims, you must include this when completing your self-assessment, and you must highlight this to your audit firm so they can accommodate it into your audit.

What materials can I make a claim for?

You can make a claim on any materials covered by the RJC only. These are gold, platinum group metals (platinum and rhodium), and diamonds. Other materials used in jewellery cannot be audited.

How is it audited?

If you want the RJC to audit and certify your company’s provenance claim, you must be able to show the auditor that you have a system in place to ensure you do what the claim states. You need to provide evidence you can do this systematically, so on a continuous basis and not just a one-off purchase. Your auditor will need to understand and verify how you ensure your claim is truthful, which is why they need evidence.

For example, if you claim all your gold is conflict-free, your auditor will need to see evidence that it is and answer questions such as:

  • What policies do you have in place to source conflict-free material?
  • What criteria do you use to define conflict-free?
  • What requirements do you make on your suppliers so that they sell you conflict-free material?
  • What due diligence/checks do you perform on your suppliers and their sourcing of the materials they sell to you?
  • What systems does your company have in place to make sure your process happens with every purchase?

You will need to comply with and demonstrate through evidence how you meet all the requirements that are part of the provision:

Members that make a Provenance Claim(s) shall have systems in place to ensure that the Provenance Claims(s) is valid and supported by evidence. The systems shall include:

  1. Documented criteria or requirements that are compatible with the Provenance Claim(s); – what criteria or requirements do you have for your provenance claim?
  2. Procedures for record keeping and verification that the criteria or requirements are met; – what records and procedures have you established for sourcing your materials?
  3. Controls to maintain the integrity of the materials covered by the Provenance Claim(s); – this ensures you’ve covered all risks in your processes, and covers how the materials are handled within your system (more important if you have various sources of materials you buy)
  4. Training to ensure that employees who are responsible for responding to product inquiries understand the Provenance Claim(s) and can explain them accurately; – to make sure your employees know and understand the claim and how to manage it, so it works effectively
  5. A complaints or grievance mechanism appropriate to the nature, scale and impact of the business, to allow interested parties to voice concerns about the veracity of the Provenance Claim(s) – this is to ensure if someone identifies a risk in your claim, you have systems to address this. 

Some examples of evidence your auditor may review for the provision include:

  • Procedures – including identifying and documenting claims, ensuring they are valid – eg what requirements you make of your suppliers
  • Records of documented criteria or requirements that you have – eg your definition of conflict-free if that’s the claim you’re making
  • Evidence that you are implementing controls to maintain the integrity of materials covered by your provenance claims – eg checking all sources 
  • Evidence that your staff are trained in provenance claims – eg training materials, attendance sheets or certificates 
  • A complaints or grievance mechanism and information on how to access it
  • Records of complaints or grievances relating to your provenance claims
  • Employee interviews – to check whether your employees understand how your system works in practice.
Will it add time to my audit?

In most cases, yes. Provenance claims are an important provision that will need to be thoroughly audited if it’s applicable to your business. Depending on the number of audit days you will need to undergo more generally, as well as the provenance claim you’re making, a provenance claim could add half an audit day to your RJC audit. Please ask your chosen audit firm how a provenance claim will affect your RJC audit in terms of time.

I'm a Signet supplier, what do I have to do?

If your company supplies the retailer Signet, you are asked by them to comply with the Signet Responsible Sourcing Protocols (SRSP) for gold and the D-SRSP for diamonds. There are requirements for platinum group metals to be released in 2018 in another protocol for these metals. To access the SRSPs and to learn more about Signet’s requirements for their suppliers, please go to Signet’s dedicated website here.

Compliance with the SRSPs can be made through an RJC provenance claim (provision 12 in the COP). Your auditor will review your compliance through an SRSP audit as part of your RJC COP audit, and will also check your compliance with the requirements in provision 12.1a-e (see above) – these requirements make sure that your company has systems to continue to comply with the claim you make, for the length of your certification (usually three years).

SRSP Provenance claims

You will need to make a provenance claim that identifies that you source in accordance with the relevant SRSP:

  • “We source diamonds responsibly in accordance with the Signet Responsible Sourcing Protocol (D-SRSP) for diamonds” and/or  “We source gold responsibly in accordance with the Signet Responsible Sourcing Protocol (SRSP) for gold

    Please note: your warranty statement to Signet must read “The seller warrants that any products containing gold, tin, tungsten, tantalum or diamonds have been supplied in compliance with the Signet Responsible Sourcing Protocols (‘SRSPs’)”.

    However, your provenance claim must cover only the materials audited in your RJC audit. Ie, if you currently supply only diamonds to Signet, your RJC provenance claim will read:

    “We source diamonds responsibly in accordance with the Signet Responsible Sourcing Protocol (D-SRSP) for diamonds

    If after your RJC audit, you start to supply Signet with products containing gold, you will need to have a bolt-on provenance claim audit to check that you comply with the SRSP for gold (as previously you would have been audited only on the D-SRSP for diamonds).

    If you sell diamonds to Signet, you can also make a claim and be audited on how you ensure that you sell only natural origin diamonds:

  • “The diamonds herein invoiced are exclusively of natural origin, formed and grown under natural and geological processes, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.”

    Please note however, that it is not a requirement to have this secondary provenance claim made as part of your RJC audit as the sourcing of natural origin diamonds is covered under the requirements of the D-SRSP.

    Please note that Signet also requires suppliers to include the World Diamond Council (WDC) System of Warranties statements in invoices of diamonds to Signet. These are covered by a specific provision in the COP, provision 27, therefore cannot be made and audited as a provenance claim as the claims above can (see the section ‘Not acceptable claims’ below).

If you become a certified RJC member with a relevant SRSP claim included, Signet will only require you to be audited every three years, as part of your RJC requirements and you will be exempt from future Signet factory, social and SRSP audits. Please note you will still need to complete a SRSP compliance report to Signet every year. For more information, please email the Signet SRSP team on info@signetsrsp.com

Only audit firms that are accredited to audit the SRSPs are allowed to conduct SRSP provenance claim audits (these firms are identified on the RJC website under the ‘Standards’ scope of accreditation):

 

The RJC advises you to tell your audit firm if you have any specific customer requirements (such as the SRSPs) as part of your RJC audit, so this is made clear before the RJC audit is conducted.

If you’ve had an SRSP audit conducted within 12 months prior to your RJC audit, the auditor must do an overview of SRSP compliance (but not a whole SRSP audit), as well as ensure you have management systems in place to continue your compliance with the relevant SRSP, for the length of your RJC certification (usually three years). More information on provenance claims being ‘bolted-on’ to an RJC certification can be found in the information provided below.

RJC certification can include SRSP statements of compliance with the SRSP for gold and D-SRSP for diamonds. Platinum group metals will be covered in a new SRSP being released from 2018. Tin, tungsten, tantalum, coloured stones and silver are not covered by the RJC’s scope, and so would not be able to be included to any RJC certificate (see the question on materials covered above).

I want to start making a claim but I’m already certified
  • This can be done through a bolt-on provenance claim audit and it can be done at any time of the year, outside of your RJC audit cycle
  • The bolt-on audit will need to be done by an RJC accredited audit firm, but doesn’t need to be the audit firm that has audited you previously for the COP. If you use a different audit firm for a provenance claim bolt-on, you need to provide them with a copy of your previous audit report
  • The audit will assess you on how you verify the claim you make, and ensure you have the systems in place to audit it – this might take longer as part of a bolt-on audit than if it was part of your ‘original’ audit
  • Your re-issued RJC certificate will clearly state on it the date of all audits (including the bolt-on) as well as the names of all audit firms and audit teams who’ve audited you as part of your certification
  • Please note your certificate with a bolted-on provenance claim will be valid until the same date as when originally issued (so the validity period is not extended in any way).

 

Let’s look at some example claims:

Clear acceptable claimsNot acceptable claims

When provenance claims are certified by the RJC through an audit, these appear on your certificate. To encourage transparency as to what you (the member) does to verify the claim it is best practice to include reference to the criteria and/or systems you are using within the wording of the claim itself. This means external stakeholders will understand better what it is you do to make sure you source in accordance to your claim.

Here are some examples to explain, with the system and/or criteria behind the claim in green:

  1. “We source conflict-free gold in accordance with the Signet Responsible Sourcing Protocol.

  2. Based on written assurance from our suppliers, our diamonds have not originated from the Mbada and Marange regions of Zimbabwe”.

  3. “We source all our gold responsibly from only LBMA Good delivery list refiners.

  4. “We source conflict-free gold in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains for Minerals from Conflict-Affected and High-Risk Areas.

  5. “All our diamonds are natural origin, all having been checked in a synthetic diamond testing machine to ensure this.”

  6. “All our diamonds are sourced from Canada, as part of the CanadaMark program which tracks the diamonds from the mine of origin.

  7. “We comply with the World Federation of Diamond Bourses (WFDB) Charter on Disclosure of Synthetic, Treated Natural origin and Natural origin Diamonds.

Please note:

We do not want to restrict members’ ability to summarise claims for marketing purposes, so while claims that are audited and certified by the RJC should include how they are implemented/verified as explained below, this does not mean that members must use the wording exactly as written on their certificate every time the claim is made or referred to. 

These are some examples of claims that are not considered provenance claims, and so cannot be audited as part of the provision:

  1. “All our diamonds comply with the Kimberley Process Certification Scheme and World Diamond Council System of Warranties” – these requirements are covered under a separate provision (Kimberley Process Certification Scope and World Diamond Council System of Warranties, provision 27) and so are not considered provenance claims

  2. “The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and in compliance with United Nations resolutions. The seller hereby guarantees that these diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds” – these requirements are covered under a separate provision (Kimberley Process Certification Scope and World Diamond Council System of Warranties, provision 27) and so are not considered provenance claims, even though you may be asked by Signet to make this statement. You can still include this statement on your invoices and it’s covered in your RJC audit, but under provision 27, and not as a provenance claim (provision 12).

  3. “Our jewellery is made to the best quality on the market” – this relates to product quality which is not covered by the provision which focuses on sourcing and provenance

  4. “Our watches are made in France” – this relates to location of manufacture and not sourcing practices or systems

  5. “We source all our materials responsibly.” – By encouraging claims that refer to the systems behind them, we hope to discourage open-ended and vague claims which can be left open to interpretation. This additional information makes transparent how the member sources responsibly, and those who wish to source from them are clear what ‘responsible’ means.

 


Need some help?

 

The RJC has a dedicated Training Manager, Maria Mursell who is on-hand to help you. Simply call the RJC London office on +44 (0)207 321 0992 or click the button below to get in touch with her via email.


 

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