Boodles recognises that mining of gold, diamonds and gemstones on which it relies is a major contributor to economic growth and development for many countries across the world.  However, mining of gold, diamonds and gemstones can take place in countries where conflict, corruption and/or poor governance might risk legitimate sourcing.  Mining and trading of these minerals in some countries might incidentally or intentionally infringe on human rights, be subjected to corrupt or unethical practices, and in some cases even fuel conflict.  Boodles endeavours to monitor these country-level risks and may, from time to time, exclude countries from its sourcing.

 

In the same way that Boodles monitors for exclusion, if the situation should change for the better, Boodles may remove a country from the exclusion list.

Boodles uses as reference points international organisations and leverages other information sources and insights from suppliers and stakeholders to assess country risk.  Grounds for exclusion are explained as follows.

  • Grounds for exclusion are sanction targets and regulations imposed by the United Nations Security Council, the European Union, and the UK government.
  • Any country where there is declared conflict will be excluded.
  • Any country where there may be documented (but not declared) armed conflict may be excluded.
  • Any place where Boodles has serious concerns about the conditions that would enable proper due diligence, adherence to basic human rights, and/or application of acceptable practices may be subject to exclusion.

 

Boodles will refer to the following sources to help assess countries.

https://www.gov.uk/guidance/sanctions-embargoes-and-restrictions

https://www.transparency.org

https://www.business-anti-corruption.com

http://www.oecd.org/dac/conflict-fragility-resilience/

Boodles Exclusion List

As of September 1, 2019

This list has been developed in accordance with Boodles Exclusion policy.  It is subject to change at Boodles’ discretion.

Boodles will not accept product sourced from the following countries, as of the date of this policy, which are known to be significant sources of diamonds, gold and/or gemstones (subject to review in the future if circumstances should change).

  • Afghanistan
  • Central African Republic
  • Democratic Republic of Congo
  • Myanmar (Burma) - December 2017 to present
  • Zimbabwe

Boodles is monitoring risks in other countries where conditions may pose a risk to human rights, where diamond, gold or gemstones trading may be subjected to corrupt or unethical practices, and in some cases even fuel conflict as per its Exclusion Policy.

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