Grievance Mechanism Form

United Precious Metal Refining, Inc. (“UPMR”) makes every attempt to ensure that our customers are treated with courtesy and that their concerns are acknowledged and addressed in a timely manner. Our goal is to create a clear and coherent process to respond to any issues, and it is our policy to consider constructive comments as an opportunity for improvement.

UPMR has integrated a grievance mechanism in line with the guidance of the Responsible Minerals Initiative (RMI), the Responsible Jewellery Council (RJC), and the foundational principles of the UN Guiding Principles on Business and Human Rights (UNGPs). This policy establishes clear and effective channels for our stakeholders to raise concerns about human rights, labor, and environmental issues throughout the supply chain and ensures that legitimate grievances are addressed and remedied.

With regard to the RMI, the Responsible Minerals Assurance Process (RMAP) and the Office of the High Commissioner for Human Rights (OHCHR ), UPMR acknowledges the right of any individual or organization relevant to UPMR (customers, business partners, service providers, or their representatives) to be able to raise any concerns about our process, and to file a grievance about our decision-making methodology.

UPMR Principles and Commitments

Our policy’s foundation is built upon core principles derived from the UNGPs.

UPMR commits to:

  • Respect for human rights: We commit to respecting all internationally recognized human rights, as detailed in the UNGPs, across our operations and supply chain.
  • Access to remedy: We recognize our responsibility to provide or cooperate in the remediation of any adverse human rights impacts we may cause or to which we may contribute.
  • Engagement and dialogue: We will engage with affected stakeholders for their comments on the design and operation of this mechanism, and we will foster an environment of dialogue and continuous learning.
  • Non-retaliation and confidentiality: We will protect individuals from retaliation for any reporting concerns made in good faith and will ensure confidentiality, when requested and legally permissible.

Scope of the Mechanism

This grievance mechanism is designed to receive and address concerns related to our company’s precious metals supply chain, including our operations and those of our suppliers, business partners, and affiliates. Grievances may relate to a wide range of issues, such as:

  • Human and labor rights violations
  • Environmental damage and non-compliance
  • Health and safety risks
  • Conflict financing or other Annex II risks identified in the OECD Due Diligence Guidance.
  • Corruption or other illicit activities

Our website allows for the anonymous reporting of such incidents. In the event a “whistleblower” chooses to disclose information about potential wrongdoing or human rights related violations about our supplier or their practices, UPMR will ensure the confidentiality of the provider of the information, barring any disclosure is required by law. Although providing contact information better allows UPMR to further follow up with the information given during the investigation and resolution process, anonymous submissions which disclose information in good faith will be investigated in the same manner as other submissions. Anonymous submissions can also be made through the RMI website or RJC website.

Process for Handling Grievances

All grievances are handled through a defined and transparent process that aligns with the UNGPs’ effectiveness criteria (legitimate, accessible, predictable, equitable, transparent, rights-compatible, a source of continuous learning, and based on engagement and dialogue).

1. Submission

A grievance is submitted through our designated channel below. All submissions are logged and reviewed by the designated Grievance Management Team (GMT). Our GMT will be comprised of members of the Board of Director and Senior Management within the organization.

2. Review and assessment

UPMR’s GMT will assess the submission to confirm it is within the mechanism’s scope, including the entity involved, the subject matter, and the timeliness of the issue.

3. Investigation

UPMR’s GMT will conduct a thorough and fair investigation that is launched for all valid grievances.

  • The investigation will engage with all relevant parties, including the complainant and the respondent, while respecting each entity’s confidentiality.
  • The process can involve internal teams, external experts, or collaboration with industry initiatives like the RMI for allegations involving cross-recognized facilities.

4. Remediation and action

When grievance is found to be legitimate, UPMR will take appropriate corrective and preventative action to remedy the uncovered harm. This may include:

  • Modifying business conduct.
  • Offering fair compensation or other forms of remedy.
  • Engaging with the supplier to develop and implement a corrective action plan, with consequences for non-compliance.

5. Communication and closure

UPMR’s GMT will communicate with the complainant about the process and outcome, respecting confidentiality. Grievances will be formally closed in the internal log once resolved.

6. Continuous Improvement

On an annual basis, UPMR will review trends, analyze lessons learned from resolved cases, and recommend changes to its policies, standards, and procedures. UPMR will publicly report on grievance data, such as the number of complaints received and addressed as part of our Summary Annual Report on Supply Chain Due Diligence. This will be to demonstrate accountability and aid in continuous improvement.

Grievance Mechanism Form

This form allows any person or customer to submit a concern or grievance to UPMR for review, assessment and response in accordance with the Guiding Principles on Business and Human Rights, published by the OHCHR. Any issues about UPMR policy should be factual and evidence based. Please include all relevant documentation and detail all known events with your submission. All comments about our processes or criteria will be taken seriously and submitted to our compliance officer for further investigation and review. All relevant submissions will be recorded and maintained as a record in our files for a period of at least five years. If the issue does not directly impact UPMR, or should you have broader concerns or comments, you may also contact the RBA (Responsible Business Alliance) directly through their own grievance page of the Responsible Minerals Initiative website https://www.responsiblemineralsinitiative.org/ or the Responsible Jewellery Council (RJC) through their grievance compliance mechanism via their website https://www.responsiblejewellery.com/.