Subject: File No. DF Title XV - Specialized Disclosures
From: Michael L Rae, Chief Executive Officer
Affiliation: Responsible Jewellery Council

October 13, 2010

Dear Sir/Madam,

Re: Dodd-Frank Wall Street Reform and Consumer Protection Act 2010 - Disclosures on Conflict Minerals in or near the Democratic Republic of Congo

The Responsible Jewellery Council (RJC) is an international not-for-profit organisation whose mission is to promote responsible ethical, human rights, social and environmental practices throughout the jewellery supply chain. Membership of the RJC is open to all businesses and associations participating in the diamond, gold and platinum metals jewellery supply chain and / or engaged in activities that have a potential impact on consumer confidence in diamond, gold or platinum metals jewellery. RJC Membership now exceeds 250 companies and trade associations.

In December 2009, the RJC formally launched its system for Member Certification applicable to businesses operating in the diamond and gold jewellery supply chain. Businesses that become RJC Members are required to achieve Certification within two years. Certification is based on independent, third party auditing against the RJC Code of Practices, the RJC's standard for responsible business practices. The RJC Code of Practices defines the Council's ethical, social, human rights and environmental commitments for RJC Members, covering a wide range of supply chain issues. Beginning in 2010, companies operating in the Platinum Metals jewellery supply chain have been able to join the RJC. The RJC Code of Practices and supporting documents for Member certification will be reviewed and expanded to formally include Platinum Metals in 2012.

RJC is now investigating the feasibility of developing a Chain-of-Custody Certification initiative, as an optional complement to the existing RJC Member Certification of responsible business practices. The RJC has recently released its second discussion paper, attached, on this topic for a four month public comment period. An overview is provided in the attached press release. The paper is also available to download from:

The proposed RJC Chain-of-Custody Certification system aims to enable businesses to voluntarily demonstrate rigorous assurance for responsible supply chains. Importantly, it would allow for on-product RJC certification of tracked diamonds, gold and/or platinum metals in jewellery products for consumer sale. It is hoped that the Chain-of-Custody Certification system can be launched in 2012.

The gold supply chain is complex and non-linear and presents significant challenges to the development of chain-of-custody systems. RJC's discussion paper seeks feedback on proposals to define 3 separate categories of tracked gold - 'freshly' mined, above-ground stocks in the form of bullion produced before a certain date, and recycled.

We are aware that the SEC is also tasked with addressing disclosure in the gold supply chain as it relates to conflict minerals in or near the Democratic Republic of Congo. RJC would appreciate the opportunity to dialogue its proposed approach with the SEC, with a view to harmonising the two initiatives wherever possible

Please do not hesitate to contact me or Dr Fiona Solomon, RJC Director Standards Development for any further information or to provide feedback.

We look forward to your interest in this work.

Kindest regards,

Michael L Rae
Chief Executive Officer

Responsible Jewellery Council
PO Box 409, Vermont, VIC 3133 AUSTRALIA

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