Section A: General Information about the Company:

Ours is a story of creative perseverance, 75 years in the making. It is the story of a single-minded vision: to elevate jewels to veritable treasures that hold pride of place, both in your heart, and on your dresser. This vision comes to life with a knowhow of the industry that runs generations deep and a passion for pushing the envelope constantly. We deviate from convention while paying homage to the past, and honour timeless traditions while fostering innovation.


Business Model :

Supply of diamond and studded jewellery.


The jewellery Moksh creates reflects the originality, culture and inspiration that our designers and artisans surround themselves with. Unusual combinations of precious raw materials, in a variety of creative settings in jewellery that’s functional and wearable.

All our diamonds are conflict free and natural. The diamonds go through a stringent process of assortment which ensures that they are matched for colour, quality and cut.

The jewellery is BIS Hallmarked, a guarantee of gold purity. The gemstones and pearls used in our jewellery is all natural and untreated.

Moksh is a member of the Responsible Jewellery Council. The RJC is the global membership and standards body for responsible jewellery throughout the entire supply chain – from mine to retail.

Moksh is also a member of the Gem and Jewellery Export Promotion Council. The GJEPC is the apex body driving India export led growth

in the gem and jewellery sector, since 1966.

Following company and Brand covered in this report : Company fall under Downstream.


  1. Tanvirkumar & Co.

Jewellery Brand Name : Moksh Jewellery


Section B: Financial compliance of the TANVIRKUMAR & CO.:

  • Money Laundering, Terrorism Financing, Other Financial Offences

Current Status

  • TANVIRKUMAR & CO. recognizes the fact that entities in the gems and jewellery sector have to take on the onus of analysing their potential vulnerabilities to money laundering and implement specific steps that are required for protection against abuse by criminals.
  • Strict compliance is ensured at all the entities and compliance officer has been appointed who in turn reports to TANVIRKUMAR & CO. Management on compliance status on annual basis.
  • Know Your Counter Party and other compliance of Due Diligence is followed in line with OECD guidance.
  • Ongoing monitoring is carried out along with all stakeholders.


Area of concern & Remedial Measures

  • Nil As on Date.
    • Kimberley Process and System of Warranties
  • TANVIRKUMAR & CO. is fully committed to complying with all the requirements specified in the Kimberley Process Certification Scheme of World Diamond Council’s (WDC) System of Warranties Declaration.
  • Day to day monitoring and compliance of SOW is done by compliance officer.
  • TANVIRKUMAR & CO. is committed towards conflict free sourcing and zero tolerance policy is followed at TANVIRKUMAR & CO. level.

Area of concern & Remedial Measures

  • Nil As on Date.


  • Anti-Bribery and Facilitation Payment Policy:
  • The TANVIRKUMAR & CO. shall ensure complete prohibition Bribery and facilitation payment across organization and in all the entities.
  • TANVIRKUMAR & CO. has published compliance team contact details on website to receive any grievance or complaints.


Area of concern & Remedial Measures

  • Nil As on Date.
    • Ethical Sourcing of Loose Diamonds Policy:
  • Our company is concerned about the environment and social impacts of irresponsible mining.
  • TANVIRKUMAR & CO. has identified the risk of supply chain with respect to Conflict Affected High Risk Area.
  • TANVIRKUMAR & CO. ensure all its supplies are screened for conflict free supplies.
  • We have published the OECD based ethical sourcing policy and we are communicating our policies to all the supply chain partners and pushing them to adopt the same.

Area of concern & Remedial Measures

  • Current concern is lack of awareness about OECD regulation and requirements of sourcing.
  • We have started creating awareness about our Ethical sourcing requirements for our supply chain.
  • We started Engagement with our global supply chain for obtaining the further supply chain information to ensure ethical and conflict free sourcing in metal business.
    • Social Compliance
  • We ensure full compliance with all applicable national and, where appropriate, international laws / regulations with respect to employment and labour codes in all our establishment.
  • We respect all regulation for child labour, forced labour, non-discrimination, non-retaliation etc.
  • All work man rights are respected and adhere to freedom of association and collective bargaining regulations.


Area of concern & Remedial Measures

  • No point has been reported in the social compliance of the TANVIRKUMAR & CO. where remedial measures at TANVIRKUMAR & CO. level is required.
  • Entity level remedial measures are taken based on internal and external audits conducted by reputed agencies.


  • Health and Safety
  • We at TANVIRKUMAR & CO. are concern about the health and safety of employees and are constantly studding about any adverse impact of our business processes are identified and eliminated. Towards this end, we will systematically review our operations to identify sources of health and safety related risks.
  • This review will use appropriate standards as required by prevailing laws, expert opinion, and our knowledge of best practices.
  • All our staff will be trained in the manner required to adhere to these work practices and drills.
  • The health of our staff, exposed to certain hazardous processes, is be monitored periodically through appropriate medical checks, and reviewed using expert inputs for improvements.
  • All workplaces are constructed to meet safety standards with local regulations as the minimum standards that will be applicable.

Area of concern & Remedial Measures

  • Nil as on date, as no accidents are reported in last one year.
  • Organization has been blessed and we did not have any fire or any other incidents leading to dangerous circumstances.
    • Human Rights
  • TANVIRKUMAR & CO. is not and will not interfere in the right of employees to observe tenets or practices based on caste, race, national origin, gender, religion, disability, union membership, or political affiliation.
  • The Company strongly discourages any form of sexually coercive, threatening, abusive or exploitative behaviour.
  • Any reported incidents relating to direct or indirect physical, sexual, racial, religious, psychological, verbal, or any other form of harassment or abuse, or any other form of intimidation or degrading treatment will not be tolerated by the company.
  • TANVIRKUMAR & CO. ensures that none of its suppliers and stake holder have engaged in any activity which can violate the Human Right Principles.
  • We have carried out the Human Right Due Diligence of suppliers and other Stake holders & based on risk assessment where necessary.


Area of concern & Remedial Measures

  • No Area of concern & Remedial Measures has been raised in the Human right for any of our operating units.
  • Supplier’s further upstream compliance with respect to Human Right compliance for conflict free sourcing is a new development, where company is heading and would require more focus on the same.
    • Environment Protection
  • TANVIRKUMAR & CO. is Complying with all applicable environmental laws and regulations.
  • Improvement is seen employee’s environmental awareness and performance with the help of detailed policies and procedures, training, and recognition of excellence.

Area of concern & Remedial Measures

  • Nil, mainly Sales office and no manufacturing activity.



Company Name:



9th September, 2023

Reporting Period :

Financial Year 2022-23

Step 1: Establish strong company management systems

1.A.  Adopt and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict­ affected and high-risk areas

·        We have published the policy at company level for easy accesses to stakeholder.

·        OECD and Best Practice Annual communication has been sent to all the active supplier.

·        Awareness presentation on Ethical sourcing based on OECD guideline has been circulated.

·        Detailed policy and procedure at entity level has been established based on risk of CAHRA’s  is done.

1.B Structure internal management systems to support supply chain due diligence.

·        Additional responsibility has been assigned to Compliance officer to look over the compliance of Ethical souring policy.

·        All key employees involved in souring and procurement of precious metals have been trained on our Ethical precious metal souring policy. Refresher trainings are provided.

·        List of Suppliers has been maintained along with status of their social and ethical compliance.

·        On going monitoring of each supplies and associated suppliers is carried out with the help of tools such as digital media, web search, review of supply documents, declaration and market intelligence etc.

1.      C Establish a system of controls and transparency over the minerals supply chain.

·        Supplier Downstream & Midstream information collection process started and to  obtained CAHRA’s information and Ethical sourcing compliance at supplier level.

·        Currently 75% and more supply from law risk and balance 25% is from non-regular suppliers.

1.      D Strengthen company engagement with suppliers.

·        As mentioned above supplier questionnaire has been circulated and we are in the process of following up with them to obtained the filed information from them.

·        Further we are also obtaining the vital information about suppliers from social platforms and social compliance registration such as BPP & RJC,  Approved ASM programs etc

·        We are in the process of compiling filled supplier questionnaire data , after analysis we will be formulate supplier engagement practices based on risk  reported at each supplier level (if any)

1.E Establish A Company-Level, Or Industry Wide, Grievance Mechanism As An Early Warning Risk-Awareness System.


·        We have established the grievance  handling policy and procedure at company level, contact details of  compliance head provided  in our Group Social and Ethical policy on our Web site under Business Principle Section ( which is publicly available)

Step 2: Identify And Assess Risk In The Supply Chain

Identify And Assess Risks In The Supply Chain And Assess Risks Of Adverse Impacts.


·        We have established the detailed policy and procedure for identification of risk at entity level.

·        Each entity has appointed and trained compliance officer to oversee the financial and ethical sourcing compliances.

·        We have categorized supply chain in to 2 major segments that its Secondary supplier and Open market suppliers.

·        All suppliers are bifurcated in to this category and open market supplies are considered as potential risk for supplies from CAHRA’s and thus step by step information are gathered from this category of supplier as mentioned in point 1.B & 1.C.

Step 3: Design And Implement A Strategy To Respond To Identified Risks (If Applicable)

Report Findings Of The Supply Chain Risk Assessment To The Designated Senior Management Of The Company.

·        Ongoing monitoring of each supplies is done by compliance officer to confirm its free from Conflict, were required Red Flags are been raised for seeking additional information and closed after receiving such information to our satisfaction.

·        Entity level compliance officer shall report all un-answered flags to local management and Group compliance officer.

·        In worst situation were information is half or not satisfactory management starts engagement practice and discussion and dialogue with suppliers is carried out to ensure full information in further business.

Devise And Adopt A Risk Management Plan.


·        We have formulated the risk management plans at entity level considering individual entities position in supply chain and position of supplier in supply chain.

·        Entity compliance officer carries out monitoring of each and every business transactions and were required Red Flags are been raised and further steps are followed as mention above.

·        Brief of companies Risk Management Practices has been mentioned in communication of Business policy on our website. 

Implement The Risk Management Plan And Monitor Performance Of Risk Mitigation Efforts.


·        Entity level and group level monitoring of Red Flags and its effective closure is monitored.

·        Compliance officer provides period status reports of OECD compliance to the management.

Internal Training


·        Each entity of the Group provides period training to all the concern employee involved in buying and selling and compliance monitoring team.



·        Business principle has been published on the website covering all the COP wise policy including Ethical Precious Metal souring policy of the group.

·        Over and above Annual communication on Business policy and Awareness on various best practices and expectation from business partners is communicated

OPTIONAL INFORMATION ON Step 4:Carry Out Independent Third-Party Audit


·        Recently Our office has finalised the RJC COP 2019 certification audit and same is scheduled in the month of  October 2023

Grievances And Remediation

·        No grievance of what so ever has been reported till date.


Prepared By & Approved by  : Partner / Top Management

Date : 9th September, 2023

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