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Déjà Vu diamond industry still failing to deliver on promises B ACKGROUND R EPORT TO GLOBAL WITNESS AND A MNESTY I NTERNATIONAL SURVEY O CTOBER 2004 .

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Page 1: d j vu plus 007x - Global Witness · Plus Survey and the $100 Million Supersellers survey, which together “constitute the most extensive summation of the retail jewelry business

Déjà Vudiamond industry still failing to deliver on promises

BACKGROUND REPORT TO GLOBAL WITNESS

AND AMNESTY INTERNATIONAL SURVEY

O C T O B E R 2 0 0 4 .

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1 ◊ background report to global witness and amnesty international survey

T his study follows up Global Witness’ survey andinvestigations carried out in January 2004evaluating the US diamond jewellery retail

sector’s implementation of the self-regulation. Theresults showed that major players in the US diamondjewellery retail sector were falling short inimplementing the basic measures of the self-regulation.1

It also showed that the diamond industry as a whole anddiamond industry trade associations like the WorldDiamond Council(the industry bodyresponsible forcoordinating thediamond industry’sefforts to combatconflict diamonds)have not adequatelymonitored andassessed how self-regulation isworking in practicethroughout all sectors of the diamond trade on a globallevel. The report concluded that a large proportion of thediamond industry is still not taking the issue seriouslyand instead has focused attention on a public relationscampaign to make the issue go away.

Given these alarming findings, Global Witness andAmnesty International carried out an extended survey insummer 2004. The aim of this survey was to furtherevaluate the effectiveness of the self-regulation in the

THE KIMBERLEY PROCESS CERTIFICATION SCHEME

The Kimberley Process Certification Scheme (KPCS),negotiated by governments, civil society organizations andthe diamond trade, in response to civil societycampaigning against the trade in conflict diamonds, is aninternational governmental certification scheme aimed atpreventing the trade in conflict diamonds. Launched inJanuary 2003, the scheme requires governments and thediamond industry to implement import/export controlregimes on rough diamonds to prevent conflict diamondsfrom fuelling conflict and human rights abuses. The KPCS,which is a political agreement and currently has 60countries as members, requires its participants to certifythat shipments of rough diamonds are free from conflictdiamonds. Countries that are members of the KimberleyProcess and export rough diamonds have put in placedomestic certification systems, and passed enablinglegislation, with varying degrees of effectiveness.

The system of warranties, which the diamond industryagreed to adopt to support the Kimberley Process, coversboth rough and polished diamonds. However, it can only beconsidered effective in assuring that conflict diamondshave not entered the legitimate trade if all sectors of thediamond industry effectively implement the system ofwarranties. More importantly, the system that the industryhas established must be audited or verified independently,and monitored by appropriate government agencies.Otherwise, unscrupulous traders will find loopholes,allowing conflict diamonds to enter the legitimate trade.

Déjà Vudiamond industry still failing to deliver on promises

BACKGROUND REPORT TO GLOBAL WITNESS

AND AMNESTY INTERNATIONAL SURVEY

This survey follows the

Global Witness report

Broken Vows, released in

March 2004, which

found that major US

and international

diamond jewellery

retailers were falling

short in implementing

the self-regulation.

O C T O B E R 2 0 0 4 .

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2 ◊ background report to global witness and amnesty international survey

diamond jewellery retail sector in the US but also tofocus on surveying the diamond jewellery retail sector inother countries, including the UK, Australia, Belgium,France, Germany, Italy, the Netherlands andSwitzerland.

The major question this survey aims to answer iswhether the self-regulation is being implementedeffectively in the diamond jewellery retail sector. Thesurvey should also give consumers important informationabout whether diamond companies can give assurancesthat diamonds are conflict free, how transparentcompanies are being about these efforts and what types ofquestions to ask when buying diamond jewellery.

How the survey was carried out in the UKand US

Company management surveyA total of 85 major diamond jewellery retailers werewritten to (21 companies in the UK, 64 companies inthe US) including department stores, specialty jewellerychains and TV shopping networks as well as companiesin the low-end, mid-range and luxury sectors of theindustry.

In each country, formal letters were sent from GlobalWitness and Amnesty International to each retailer’smanagement requesting information on the policies andsystem of warranties in place to ensure that thecompany is not dealing in conflict diamonds and is

supporting the Kimberley Process. The letter alsorequested samples of any policies, warranties,procedures and auditing measures along with examplesof practical measures for implementation. In somecases, questionnaires were attached to the letter, askingspecific questions about the company’s policy andimplementation of the self-regulation.

Global Witness and Amnesty International alsofollowed up with all companies by telephone to bringthe letter to their attention and to ask the status of theirefforts to respond. This was done to give companiesadequate opportunity to demonstrate what they aredoing to combat the trade in conflict diamonds.

Retail surveyThe survey also evaluated the level of awareness amongcompany salespeople about their companies’ policies onconflict diamonds. Amnesty International membersvisited diamond jewellery retailers to get a picture ofhow knowledgeable sales associates are about theconflict diamond issue and whether meaningfulassurances are given to consumers that diamonds arenot from conflict sources. In each store visited, AmnestyInternational members used a questionnaire to ask thesame questions about the company’s policy, whether thesystem of warranties was being used, and how thecompany could give consumers assurances thatdiamonds are conflict free. Amnesty Internationalmembers stated that they were conducting a survey onbehalf of the organization before asking the questions.

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Company management survey

Global Witness and Amnesty International sent lettersto a total of 85 major diamond jewellery companies inthe UK and the US.2

The results in the UK and the US found that somediamond jewellery retailers have policies to combatconflict diamonds, are implementing the self-regulationand have made efforts to be transparent about theirpolicies. However, the results overall are verydisappointing and show that a significant majority ofdiamond jewellery retailers continue to inadequatelydeliver on repeated promises made to stem the trade inconflict diamonds.

The results show the following:◊ A total of 37 companies out of 85 companies surveyed

(44%) informed Global Witness and AmnestyInternational in writing about their policy on conflictdiamonds. Forty eight companies failed to provideany information in writing about their policies,including Asprey, Boodle & Dunthorne, ChisholmHunter, Debenhams, and Theo Fennell Jewellers inthe UK and Finlay Fine Jewelry, Costco WholesaleCorporation, Kmart and T.J. Maxx in the US.3 For theUS, Global Witness and Amnesty Internationalsurveyed companies in the National Jeweler’s Top 40Plus Survey and the $100 Million Supersellerssurvey, which together “constitute the most extensivesummation of the retail jewelry business in theUnited States.”4 For example, in 2002 the top 40jewellery chains constituted a total of 6,603 storesand nine out of the top ten had combined annualsales of $5.275 billion.5

Many of these 85 companies are also members oftrade associations that have endorsed the self-regulation and it is likely that some have policies toimplement the self-regulation but did not respond tothe request for information. Those companies thatare not members may have adopted their ownpolicies. However, their failure to respond despitefollow up, even if they do have a policy, raises thequestion of how seriously they take commitments tocombating the trade in conflict diamonds and tosupporting the Kimberley Process.

◊ Thirty two out of 37 companies (86%) that respondedstate that they have a policy to combat conflictdiamonds and that they are implementing the system

of warranties, receiving warranties from suppliers, asrequired by the self-regulation. However, thirty out ofthe 37 companies (81%) that responded did notprovide adequate details on how the system ofwarranties is being implemented and what policies,procedures and auditing measures companies have inplace to back them up.

◊ As part of their written responses, 7 out of 37companies (19%) that responded provided samples todemonstrate their compliance, including copies ofinvoices with a warranty statement, samples ofagreements with suppliers that includedrequirements for implementing the system ofwarranties, and/or copies of educationalmemos/brochures prepared for staff and/orconsumers. It is encouraging that some companiesare being transparent about their efforts to complywith the self-regulation, which helps in givingconsumers meaningful assurances that diamonds areconflict free.

◊ In the majority of responses, companies state thatthey would only purchase diamond jewellery ordiamonds from companies that provided a warrantystating that the diamonds are conflict free. However,in most cases companies did not provide details onhow the system of warranties is being implementedand what policies, procedures and measurescompanies have in place to back them up. A warrantysimply stating that diamonds are not from conflictsources is meaningless unless it is backed up byconcrete policies and monitoring to ensure thatdiamonds come from legitimate sources. Majorretailers have a responsibility to carefully selectsuppliers and require them to demonstrate that theyare taking adequate measures to ensure that they arenot dealing in conflict diamonds. In addition, veryfew of the responses mentioned any type of auditingprocedures in place, another requirement of the self-regulation, which is crucial to monitor whether acompany’s policies on conflict diamonds are beingimplemented effectively.

◊ Four major retailers, De Beers LV, Signet, Tiffany &Co. and Zale Corporation, outline detailed measuresto implement the self-regulation, includingstrengthening sourcing procedures and control overits suppliers, auditing procedures to ensure that theyare not dealing in conflict diamonds and education of

3 ◊ background report to global witness and amnesty international survey

RESULTS AND ANALYSIS OF THE SURVEY

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staff about the issue. These companies’ responsesindicate that they have some concrete policies andother measures in place to back up the warrantystatements. For example, Tiffany & Co. stated that ithas applied strict criteria for selecting suppliers, andhas implemented a chain of custody for its diamondswhich has been certified to ISO (InternationalOrganization for Standardization) 9001:2000 qualitymanagement system standards. De Beers has awarranty and verification process and its compliancewith the Kimberley Process and self-regulation hasbeen audited by Deloitte and Touche, its financialauditors. Deloitte and Touche carried out a stockaudit, reconciling stocks at the start and end of theyear by carat weight, and reviewing all sales invoicesto check compliance with the Kimberley Process.While recognizing that large corporations like DeBeers and Tiffany & Co. have significant resources tocomply with the self-regulation, deal in roughdiamonds and should be industry leaders on theseissues, all retailers should apply consistent standardsfor screening suppliers and auditing procedures tomake sure their policies are being effectivelyimplemented.

Zale Corporation provides a copy of its VendorCode of Conduct which outlines that suppliers mustcomply with warranties and keep records ofwarranties for at least five years. The Vendor Code ofConduct also specifies that Zale has the right toconduct internal investigations on implementation ofthe code and that vendors must cooperate by makingrecords available. Sterling Jewelers (a subsidiary ofSignet) also outlines its policy for suppliers’complying with the warranties and an internal auditprogram to review how policies are working. BothSterling and Zale outline staff education programsand Sterling included copies of educational materialsprepared for staff in its response.6

Shop survey

Amnesty International members visited diamondjewellery retailers in the UK and US, to assess whetherretailers are able to give meaningful assurances thatdiamonds are conflict free.

The survey of salespeople in jewellery stores showedthat the diamond jewellery retail sector is largely unableto provide consumers with meaningful assurances thatdiamonds are conflict free. A total of 579 diamondjewellery retailers were visited in the UK and US atrandom, including department stores, specialistjewellery stores and small independent jewellers.Although at 59% of shops surveyed salespeople said that

they were aware of conflict diamonds, only 42 per centof shops surveyed said they had a policy.

Below is a breakdown by country.

United KingdomA total of 333 retail shops were visited by AmnestyInternational members, across the UK, from Belfast toCanterbury and from the Orkneys to Jersey, includingdepartment stores such as Debenhams and John Lewis,as well as specialist jewellery stores including HSamuel, Fraser Hinds, and smaller independentjewellers. There appears to be a high level of awarenessamongst retail staff about conflict diamonds, with 75%stating they were familiar with the term. However, therewas a lower level of awareness regarding theircompanies’ policy on conflict diamonds. Fifty fourpercent of stores visited stated they had a writtencompany policy, with a further 13% saying they had anunwritten policy. However, only 18% of shops surveyedwere able to produce a copy of this policy. Many of thesewere from retailers such as Ernest Jones and H Samuel.

When asked whether they have had any training onthe issue of conflict diamonds, only 38% said they had,with a further 21% stating that although they had had noformal training on the issue, they maintained theirawareness of it from reading company and industryassociation literature and briefings. However, just undera third claimed that neither they, nor their colleagueshad had any training on the issue.

When asked how customers could be sure that theirproducts do not contain conflict diamonds, only at 45%of shops surveyed did salespeople state that theassurance would come from the fact that the company orshop only deals with suppliers that guarantee diamondsare conflict free through use of warranties. Others statedthat they had a company or shop policy, which eitherstated that they only bought from ‘reputable sources’ oronly bought ‘conflict free’ diamonds. Finally, AmnestyInternational members found that 7% of the storessurveyed provide, as standard, a warranty certificate forcustomers confirming the origin of all diamonds sold inthe store, 5% provide a warranty for larger/moreexpensive stones, 13% only provide one on request frompurchaser, 10% said it was unnecessary becausecompany buys ‘conflict free’ diamonds or sourcesdiamonds from suppliers who provide warranty on theirinvoices and 7% had no comment or refered activists totheir company head office.

The high level of awareness about conflict diamondsmay partially be due to the active education programscarried out by diamond jewellery associations like theNational Association of Goldsmiths and the BritishJewellers Association.

4 ◊ background report to global witness and amnesty international survey

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United StatesA total of 246 stores were visited by AmnestyInternational USA members on Amnesty’s National Dayof Action on Conflict Diamonds on 18 September 2004.Activists visited diamond jewellery stores, includingdepartment stores, specialty jewellery retailers and smallindependent jewellers, across the US to ask about theirpolicies on conflict diamonds and the self-regulation.Amnesty International members visited a range ofdiamond jewellery stores, including Costco, Hecht’s,Kay Jewelers, Macy’s, Zales and Fred Meyers Jewelers,with varying results.

In preparation for the day of action, Jewelers ofAmerica (JA), the major diamond jewellery tradeassociation that has endorsed the self-regulation and has10,000 members, sent out an advisory to its membersto: “remind all jewelers that it is imperative to respondpromptly to questions from NGOs, media or consumersabout conflict diamonds, as well as other social, ethical,and environmental issues should they be asked.” Itrecommended that stores: “should emphasize theirsupport of the Kimberley Process Certification Schemefor rough diamonds. Retailers should also explain that,in order to provide consumers with added confidence intheir merchandise, they require written assurances ofadherence to the Kimberley Process warranty systemfrom their diamond and diamond jewelry suppliers.”7

This warning by JA, which has more than 10,000members across the US, was publicized in the tradepress and is likely to have reached retailers that are notJA members as well. Despite this warning, the surveyresults show a low level of awareness among salespeopleabout conflict diamonds and their companies’ policies tohelp prevent dealing in conflict diamonds. Thirty sevenpercent of stores visited claimed to be aware of theconflict diamond issue. Of those stores wheresalespeople said they knew about conflict diamonds,54% reported an inaccurate definition of the crisis. Only66 (27%) of stores visited stated that they had a policyon conflict diamonds. Twenty seven stores (11%)indicated that they had no policy at all. One hundredand forty five stores (59%) were unwilling to discusswhether or not their company had a policy on conflictdiamonds. Of the 246 shops visited, only 13% providedwarranties to demonstrate implementation to the self-regulation to their customers as a standard practice.

Even for some of the chains that claim to have staffeducation programs, there was little evidence ofstandardized education. Many retailers refused toparticipate in the survey, and others offered theorganization’s prepared statement as the sole answer tothe survey and would not go any further. Many activistsencountered resistance and resentment from retailers,

and were met with angryobjections to theirinquiries. One activistdescribed resistance in oneshop as follows: “[W]ewent in very respectfullyand they told us to get the‘hell’ out of their store, andsaid we should bespending our time on more useful things… This reallybothered me because one of the employees said theydidn’t care about what happened in Africa.” In anotherinstance, an activist was told by an owner that, “ourmission was not important and a pointless waste oftime.”

Survey of diamond trade associations

Global Witness and Amnesty International alsosurveyed international and national diamond andjewellery trade associations that have made repeatedpromises to ensure adoption of the self-regulationthroughout the diamond trade. Letters were sent tomajor trade associations on the international andnational levels (primarily in the US and UK) to assesswhat activities they are carrying out to monitorimplementation of the self-regulation.

The survey found that the World Diamond Council(WDC), the association formed to coordinate thediamond industry’s efforts to combat the trade inconflict diamonds, continues to fail to adequatelymonitor the diamond industry’s efforts to comply withthe self-regulation on a global level. In a letter dated 21September 2004 to Global Witness and AmnestyInternational, the WDC states that it has worked todevelop and promote adoption of the self-regulation andhas carried out an educational campaign, including thedevelopment and dissemination of a brochure outliningthe Kimberley Process and the system of warranties,placing articles in trade associations’ publications,giving presentations and seminars at jewellery tradeshows and industry meetings and working to get itsmembers to pass resolutions in support of the system ofwarranties.8 However, the letter does not outlineactivities it has carried out to monitor whether itsmembers are implementing the self-regulation. Theletter only states that the “constituent membershiporganizations that adopted these provisions into theirstandards for membership all have methods to ensurecompliance with these provisions as well as all othermembership requirements.”9 The letter does notoutline what these methods are and what the WDC isdoing to ensure that they are being implemented. It

5 ◊ background report to global witness and amnesty international survey

“They told us to get the

‘hell’ out of their store, and

said we should be spending

our time on more useful

things…one of the

employees said they didn’t

care about what happened

in Africa.”

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should also be noted that, to our knowledge based onthis letter, the WDC has taken little action to addressthis problem since the release of Global Witness’ reportin March 2004 which found that the WDC had failed toadequately monitor the self-regulation.

The International Diamond ManufacturersAssociation (IDMA) and the World Federation ofDiamond Bourses (WFDB), two major internationaldiamond trade organizations that are members of theWDC, have also not taken adequate measures tomonitor their members’ compliance. In its letter, IDMAoutlined educational activities it has carried out,including the development of the WDC guide. The letterstates that its member organizations “have workeddiligently in their home countries to ensure that wherepossible appropriate legislation is passed and theirmembers are compliant” and that “it is ourunderstanding that our member associations and theirmembers have implemented the voluntary system ofself-regulation.”10 The letter also states that its memberorganizations can expel any members found to be inviolation of the resolution but that no members havebeen found to be in violation to date. It states that“IDMA as an association does not have legally vestedinvestigative powers”.11 However, the letter does notoutline any concrete mechanisms for activelymonitoring its member associations on implementationof the self-regulation. Such measures still can be donewithout having legal investigative powers, throughreporting, establishing and promoting a commonstandard for demonstrating compliance with the self-regulation and promoting reviews of policies andprocedures.

The WFDB’s response to Global Witness andAmnesty International’s letter states that it has asked itsmembers (23 Diamond Bourses) to report on theimplementation of the system of warranties at theWorld Diamond Congress meeting being held inOctober 2004 in New York and that a full report will bepresented after this meeting.12 While it is encouragingthat the WFDB has asked for a report from its members,it should go farther and take concrete measures toensure monitoring as was discussed above instead ofonly relying on general reports at annual or bi-annualmeetings.

The WDC, IDMA and WFDB have all been deficientin developing a systematic way of monitoring thediamond trade’s implementation of the self-regulation;without such monitoring the self-regulation lackscredibility and will not be effective in keeping conflictdiamonds out of the legitimate diamond trade.

Global Witness and Amnesty International also sentletters to national jewellery trade associations in the US

and UK that have endorsed the self-regulation and claimto be promoting adoption among their members.Responses from these associations show that most ofthe jewellery trade associations have focused oneducational programs which have played an importantrole in promoting adoption of the self-regulation.However, most of these associations have not yet takenthe next crucial step to monitor whether companies areeffectively implementing the self-regulation.

For example, the National Association of Goldsmiths(NAG) which represents 1,200 retail jewellers in the UK,states that it has sent letters to all members about howto comply with the self-regulation, created a brochure onthe subject and carried out media and educationalactivities about the conflict diamond issue.13 In itsresponse, the British Jewellers’ Association (BJA,represents 600 members) states that it has carried outsimilar activities. It states that it has incorporated theKimberley Process and self-regulation requirements intoits membership rules and can investigate all complaintsand any member that is found in non-compliance withthe Kimberley Process.14 However, this falls short ofproactive monitoring.

In the US, the Jewelers of America (JA), a jewellerytrade association with more than 10,000 membersacross the US, and the Jewelers Vigilance Committee(JVC) have carried out some educational activities aboutthe self-regulation, including disseminating informationabout the self-regulation and giving presentations andseminars at trade shows, conferences and meetings.15 Inresponse to growing concern expressed by NGOs inMarch 2004 about the US diamond jewellery retailsector’s inadequate implementation of the self-regulation, JA issued a statement outlining its additionalactivities to monitor implementation of the self-regulation, including the development of self-assessment and training tools, mystery shoppers,training for sales professionals, and policy andprocedure reviews.16 Global Witness and AmnestyInternational welcome this initiative, one of the fewinitiatives underway to develop and implement concretemonitoring measures, but urges JA to proceed quicklywith implementation and in working to develop acommon standard for evaluating suppliers’ compliancewith the self-regulation.

In addition, CIBJO, the World JewelleryConfederation, recently announced the creation of aConsumer Confidence Commission to develop a code ofethical business practices for the international jewellerysector. The WDC, IDMA, WFDB, CIBJO, and nationaljewellery trade associations in other countries shouldfollow JA’s example and proactively work with theirmembers to monitor the self-regulation.

6 ◊ background report to global witness and amnesty international survey

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7 ◊ background report to global witness and amnesty international survey

W hile some progress has been made sinceMarch 2004 in the US, the results of thesurvey overall show that some major players

in the diamond jewellery retail sector continue to fallshort on implementing basic measures of the self-regulation or have failed to inform Global Witness andAmnesty International of efforts to do so. The continuedlack of systematic monitoring by the diamond industrymeans that there is no assessment of whethercompanies are meeting the basic requirements and thatthere are no consequences for inaction.

While the self-regulation continues to bevoluntary, only those withgood intentions willimplement it. In order tobe effective and to fullysupport the aims of the

Kimberley Process, the self-regulation should movebeyond being voluntary. Global Witness and AmnestyInternational therefore make the followingrecommendations:

To governments participating in theKimberley Process:

◊ Monitor the diamond industry’s compliance with theself-regulation and report back to the KimberleyProcess about these efforts in 2005.

◊ Carry out rigorous auditing and inspections ofcompanies’ implementation of the self-regulation andcompliance with the Kimberley Process, in order toensure that diamonds do not fund conflict or humanrights abuses, and report back to the KimberleyProcess about these efforts in 2005.

To the diamond jewellery retail sector:

◊ Fully implement the self-regulation and system ofwarranties in a manner that goes far beyond simplyrequiring a warranty from suppliers. Strict criteriashould be applied in the selection of suppliers andthird-party auditing procedures should be adopted toensure that policies are working effectively.

◊ Provide written assurances to consumers stating thatthe diamonds they purchase are conflict free so thatthe system of warranties covers the entire supply

chain from point of mine to point of sale to theconsumer.

◊ Carry out education and training on conflictdiamonds and the Kimberley Process and require itas a condition of employment so that salespeople arefully informed about policies and communicate thisto consumers in a transparent manner.

◊ Proactively work to promote adoption of the self-regulation throughout the retail sector and thediamond trade as a whole. Major industry leadershave a particular responsibility to exhibit leadershipon this issue.

To the World Diamond Council, WFDB, IDMAand other trade associations:

◊ Develop a common standard for verifying whetherretailers and suppliers are complying with the self-regulation and develop monitoring mechanisms toensure that these standards are being met. Jewelers ofAmerica’s recent initiative to develop a monitoringprogram that includes self-assessment, mysteryshoppers, staff training and policy and procedurereviews, offers some ideas of what can be done in theretail sector in the UK and in other countries. Furtherwork must ensure its adoption by all sectors of theindustry.

◊ The World Diamond Council, WFDB, IDMA shouldactively monitor implementation of the self-regulation throughout the diamond pipeline and takegreater measures to require their memberorganizations to systematically report on how they aremonitoring companies’ implementation and auditingof the system of warranties.

◊ National diamond trade associations should adoptmonitoring programs, including self-assessments,spot checks, and policy and procedure reviews tomonitor what its members are doing and help ensurethat the warranties are backed up by concrete policiesand measures.

◊◊◊

CONCLUSION AND RECOMMENDATIONS

In order to be effective and

to fully support the aims of

the Kimberley Process, the

self-regulation should move

beyond being voluntary.

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8 ◊ background report to global witness and amnesty international survey

1 ‘Broken Vows: Exposing the “Loupe” Holes in the Diamond Industry’s Effortsto Prevent the Trade in Conflict Diamonds’, Global Witness, March 2004.

2 Tables 1 and 2 outline company responses to the survey in the UK and the US.

3 Department stores that were sent letters may have kiosks with vendors sellingdiamond jewellery and they may have a variety of different relationships withsuch vendors. These vendors may or may not have policies to combat conflictdiamonds. These companies did not refer Global Witness or AmnestyInternational to their vendors.

4 ‘Top 40 Plus,’ A Supplement to National Jeweler, 16 May 2003.

5 Ibid. www.hoovers.com

6 Letter dated 22 September 2004 from Linda Buckley, Vice President MediaRelations to Amnesty International, letter dated 18 February 2004 from MichaelKowalski Chairman & CEO of Tiffany & Co. to Global Witness. Letter dated 17September 2004 from Mark Light, President & CEO of Sterling Jewelers toAmnesty International. Letter dated 17 September 2004 from Hilary Molay, VicePresident General Counsel Zale Corporation, to Amnesty International andGlobal Witness.

7 “JA issues advisory on ‘Conflict Diamonds Day of Action’, JCK-Jewelers CircularKeystone, 12 September 2004

8 Letter dated 21 September 2004 from Cecilia Gardner, General Counsel, WorldDiamond Council to Global Witness and Amnesty International.

9 Ibid.

10 Letter dated 16 September 2004 from Sean Cohen, President of IDMA, toGlobal Witness.

11 Ibid.

12 Letter dated 28 September 2004 from Michael Vaughan, Secretary-General ofWFDB to Global Witness.

13 Letter from Michael Hoare, Chief Executive, National Association ofGoldsmiths to Amnesty International.

14 Letter dated 27 August 2004 from Geoffrey Fields, Chief Executive, BritishJewellers’ Association to Amnesty International.

15 Global Witness, Broken Vows, March 2004, p 14,http://www.globalwitness.org/reports/index.php?section=diamonds

16 Jewelers of America Press Release, 16 September 2004, ‘JA Moves Forwardwith Corporate Responsibility Initiative’.

ENDNOTES

The summary report can be found online at: www.globalwitness.org/reportshttp://web.amnesty.org/pages/ec-index-engwww.amnestyusa.org/businesswww.amnesty.org.uk

© 2004 Global Witness andAmnesty International UK and USASections

Amnesty International UK

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London EC1R 4RE

www.amnesty.org.uk/business

Amnesty International USA

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New York, NY 10001

www.amnestyusa.org/business

Global Witness Publishing Inc.

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Washington DC 20036

email: [email protected]

www.globalwitness.org

déjà vu /,dayzhah 'vooh/

nnoouunn ... 2 something

excessively or unpleasantly

familiar. [French déjà vu

already seen]

—the new penguin

english dictionary

Global Witness’ earlier report,Broken Vows, released in March2004, can be found at:www.globalwitness.org/reports/