National Jeweler Network

Public Policy & Issues

JVC offering Dodd-Frank compliance kit

January 10, 2014

The Jewelers Vigilance Committee created the Supply Chain Assurance Kit to help businesses that have to be compliant with the Dodd-Frank Act and show that the gold and tungsten in their products are conflict-free.

New York--The Jewelers Vigilance Committee (JVC) has created a kit to help jewelry companies provide assurance that the gold and tungsten in their products are “conflict-free,” in accordance with the Dodd-Frank Act.

The Dodd-Frank Wall Street Reform and Consumer Protection Act requires that companies listed with the Securities and Exchange Commission disclose through a filing if any of the products they sell made with gold or tungsten are not conflict-free, meaning they benefitted armed groups in the Democratic Republic of the Congo or one of its nine neighboring countries.

This means that every company in the direct or indirect supply chain of SEC-listed companies will need a supply chain assurance system to make this determination, which the Supply Chain Assurance Kit will help them to do, the JVC said.

In addition, these companies will need to communicate their commitment to a responsible supply chain, as well as details about their assurance system, to their customers. JVC has provided forms in the kit for this purpose as well.

JVC said the assurance kit was created based on standards issued by the Organisation of Economic Co-operation and Development (OECD) for responsible supply chains.

The assurance system consists of several elements, including creating strong management systems to control the supply chain for these minerals, a risk assessment and a management strategy to address any identified risks.

Since system requirements differ depending on where a company is in the supply chain and whether it is supplying tungsten or gold, JVC’s assurance kit offers customized guidance and templates to help meet various obligations created by the Dodd-Frank Act. It also includes an explanation and examples to help companies figure out where they are in the supply chain and which materials they need to use.

“Like JVC’s USA Patriot Act Compliance Kit, JVC’s new Supply Chain Assurance Kit will become the industry standard to implement a system that assures that the gold and tungsten you supply is ‘conflict free,’” said CEO and President Cecilia Gardner.
“Although the kit is designed as a ‘do-it-yourself’ tool, JVC’s experts are available to help you implement the system for your supply chain to assure that you can continue to supply these products to any company in the supply chain of a publicly held company. JVC experts are also available for staff training and consulting,” she said.

The kit costs $100 for JVC members and $250 for non-members. The JVC is now taking orders at 212-997-2002 and expects to enable online ordering soon.