CODE OF PRACTICES
Integrity. Transparency. Responsibility.
Responsible business principles
Based on the applicable provisions of the Responsible Jewellery Council Code of Practices
Version 1.0 | 2026
Our Commitment
TKC & Partners AG is an international trader and wholesaler of coloured gemstones. Integrity,
transparency and responsible sourcing are central to the way we conduct our business and build longterm relationships with suppliers, customers and other business partners.
This Code of Practices sets out our responsible business principles in relation to the RJC provisions
applicable to our certification scope. It is intended as a concise public statement of our approach. Our
internal procedures and records support the implementation of these principles in day-to-day business.
Our approach is proportionate to the nature, scale and risks of our activities as a specialised gemstone
trading company. Applicable law takes precedence where required.
GENERAL REQUIREMENTS
COP 1 - Legal Compliance
We conduct our business in accordance with applicable laws and regulations and maintain the
registrations, licences and permits required for our activities. Relevant legal requirements are considered
in the operation of our business and any identified non-compliance is addressed appropriately.
COP 2 - Policy and Management Systems
Management is responsible for the implementation of this Code and the RJC requirements applicable to
TKC & Partners AG. We maintain policies, procedures and records appropriate to the size and nature of
our business, communicate relevant responsibilities to personnel and provide channels through which
concerns or grievances can be raised without retaliation. The suitability of the RJC management system
is reviewed by management as required by the Code.
COP 3 - Reporting
We make information on our COP-relevant business practices publicly available at least annually in a
form proportionate to the size and nature of our business. Where required, relevant concluded legal
proceedings relating to COP compliance are communicated to affected people or groups.
COP 4 - Financial Accounts
We maintain financial accounts covering our business transactions in accordance with applicable law
and accounting requirements. Independent financial review or equivalent supporting documentation is
maintained in accordance with the RJC requirements applicable to our business.
RESPONSIBLE SUPPLY CHAINS AND HUMAN RIGHTS
COP 5 - Business Partners
We use our best endeavours, in proportion to our ability to influence, to promote responsible business
practices among significant business partners. Our approach is risk-based and may draw on information
already obtained through KYC and responsible sourcing due diligence. Contractors, workers and visitors
at our premises are expected to follow the policies and controls relevant to their activities.
COP 6 - Human Rights
We respect internationally recognised human rights and apply human rights due diligence appropriate to
our activities and business relationships. Where we identify that we have caused, contributed to or are
directly linked to an adverse human rights impact, we respond in accordance with our level of involvement, including appropriate prevention, mitigation or remediation. Information on our approach is communicated as required by the RJC Code.
COP 7 - Due Diligence for Responsible Sourcing
We exercise supply chain due diligence for coloured gemstones in accordance with the OECD Due
Diligence Guidance and the RJC requirements applicable to downstream gemstone traders. We
maintain and communicate a supply chain policy consistent with the OECD Annex II principles, seek to
establish that suppliers are legitimate and are not implicated in serious human rights abuses, money
laundering, terrorist financing, fraud or sanctions, and assess supply chain information for relevant risks
and red flags. Where risks are identified, we apply appropriate risk management measures. Our due
diligence process is reviewed periodically and at least annually, as required by COP 7.1f.
COP 8 - Sourcing Directly from Artisanal and Small-Scale Mining
TKC & Partners AG recognizes the importance of responsible practices throughout the gemstone supply
chain. Artisanal and small-scale mining (ASM) plays a significant role in the sourcing of colored
gemstones and supports the livelihoods of many mining communities. We therefore encourage our
suppliers and business partners to support safe working conditions and the well-being of miners, their
families and local communities, and to promote responsible practices throughout their own supply
chains.
COP 9 - Sourcing Post-Consumer Industrial Precious Metals Directly from Informal
Recyclers
Not applicable within the current RJC certification scope of TKC & Partners AG.
COP 10 - Community Development
We recognise the role responsible business can play in supporting sustainable economic and social
development. Where relevant to our activities and sphere of influence, we consider opportunities to
contribute positively to communities connected with our business and supply chain.
COP 11 - Bribery and Facilitation Payments
We do not tolerate bribery or corruption. Bribes and facilitation payments must not be offered, requested,
accepted or authorised in connection with our business. Gifts, hospitality and other benefits must not be
used to improperly influence a business decision or obtain an improper advantage.
COP 12 - Know Your Counterparty (KYC)
We apply risk-based Know Your Counterparty procedures to establish the identity and legitimacy of
relevant counterparties and to understand our business relationships. We consider risks relating to
money laundering, terrorist financing and sanctions and respond to suspicious or unusual circumstances
in accordance with applicable law and the RJC requirements.
COP 13 - Security
We apply security measures appropriate to the risks associated with our people, premises, gemstones,
transport and business activities. Where security providers or security-related arrangements are used,
we expect conduct consistent with applicable law and respect for human rights.
COP 14 - Claims
Any claim we make about our business practices, sourcing, provenance or products must be truthful,
substantiated and not misleading. We only make claims that can be supported by appropriate
information or evidence and provide further information on such claims where required. If a claim is
found to be inaccurate or no longer valid, it is corrected or withdrawn as appropriate.
LABOUR RIGHTS AND WORKING CONDITIONS
COP 15 - General Employment Terms
We provide employment on lawful and clearly communicated terms and respect applicable labour and
social security obligations. Employment relationships are not structured for the purpose of avoiding legal
obligations to workers.
COP 16 - Working Hours
Working hours, overtime, rest periods and leave are managed in accordance with applicable law and the
RJC requirements. Overtime is not used in a manner that undermines workers' health, safety or legal
rights.
COP 17 - Remuneration
Workers are paid in accordance with applicable law and agreed employment terms. Wages, overtime
and legally required benefits are paid accurately and without unlawful deductions.
COP 18 - Harassment, Discipline, Grievance Procedures and Non-Retaliation
We are committed to a workplace free from harassment, abuse, degrading treatment and inappropriate
disciplinary practices. Workers may raise workplace concerns through an accessible grievance process
and must not face retaliation for raising a concern in good faith.
COP 19 - Child Labour
We do not use child labour. Employment of young persons, where legally permitted, must comply with
applicable age, education, working-hour and hazardous-work restrictions.
COP 20 - Forced Labour
We prohibit forced, bonded, indentured, trafficked or involuntary labour. Workers must be free to enter
and leave employment in accordance with lawful notice requirements, and recruitment or employment
practices must not restrict a worker's freedom through coercion, retention of identity documents, deposits
or other prohibited means.
COP 21 - Freedom of Association and Collective Bargaining
We respect workers' rights to freedom of association and collective bargaining in accordance with
applicable law. Workers must not be discriminated against or disadvantaged for exercising these rights.
COP 22 - Non-Discrimination
Employment decisions are made without unlawful discrimination. We provide equal opportunity and do
not discriminate on the basis of characteristics protected by applicable law.
COP 23 - Diversity, Equity and Inclusivity
We support a workplace culture based on dignity, fairness and inclusion. We seek to provide equitable
opportunities and an environment in which different backgrounds and perspectives are respected.
HEALTH, SAFETY AND ENVIRONMENT
COP 24 - Health and Safety
We provide and maintain a safe and healthy working environment appropriate to our activities.
Workplace risks are identified and controlled, relevant information and instruction are provided, and
incidents or hazards are addressed in accordance with applicable requirements.
COP 25 - Environmental Management
We manage environmental matters in a manner proportionate to the nature and scale of our activities.
Relevant environmental impacts and legal requirements are considered in our operations, and
appropriate controls are applied where environmental risks are identified.
COP 27 - Wastes and Emissions
We identify and manage waste and emissions arising from our activities in accordance with applicable
law and in a manner proportionate to their significance. As a trading business, our principal waste
streams are limited, but relevant waste is handled and disposed of responsibly.
COP 28 - Use of Natural Resources
We use natural resources in a manner appropriate to the scale of our operations and consider practical
measures to avoid unnecessary consumption of energy, water and materials. Where relevant
environmental impacts are identified, they are addressed proportionately.
COP 29 - Product Disclosure
We represent coloured gemstones accurately and do not make untruthful, misleading or deceptive
statements or material omissions. Product information is disclosed in accordance with applicable law and
recognised industry standards. Where relevant, we disclose material information concerning whether a
gemstone is natural or laboratory-grown, treatments or enhancements, composite or reconstructed
construction, simulants, and other physical characteristics required for an informed transaction. Origin is
stated only where it can be supported and is not presented in a misleading manner. Product
descriptions, invoices, certificates and marketing communications are expected to use clear and
appropriate terminology. We take reasonable measures to prevent laboratory-grown or simulant stones
from being represented as natural gemstones.
Closing Statement
This Code reflects the responsible business principles applicable to the current RJC certification scope
of TKC & Partners AG. It is supported by internal procedures and records and may be updated where
the certification scope, applicable law or RJC requirements change.
Grievance Policy
TKC & Partners AG is committed to conducting business responsibly, ethically and transparently.
Employees, suppliers and customers are encouraged to report any concerns regarding our activities or supply chain. This may include concerns related to human rights, child or forced labour, working conditions, discrimination, bribery, corruption, environmental matters or responsible sourcing.
All concerns will be treated seriously, fairly and as confidentially as possible. Where necessary, we will investigate the matter and take appropriate corrective or remedial action.
No person raising a concern in good faith will face retaliation.
Grievances can be submitted directly to TKC & Partners AG through our official contact channels.
TKC & Partners AG
Approved by: Tobias Kempf, Managing Director
Version: 1.0 | 2026