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FOREVERMARK 001:2015 DIAMOND PIPELINE INTEGRITY SPECIFICATION

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Page 1: DIAMOND PIPELINE INTEGRITY SPECIFICATION - Rosy pipeline integrity... · Pipeline Integrity Specification (commonly known as the DPIS) has been developed by Forevermark in collaboration

FOREVERMARK 001:2015

DIAMOND PIPELINEINTEGRITY SPECIFICATION

Page 2: DIAMOND PIPELINE INTEGRITY SPECIFICATION - Rosy pipeline integrity... · Pipeline Integrity Specification (commonly known as the DPIS) has been developed by Forevermark in collaboration
Page 3: DIAMOND PIPELINE INTEGRITY SPECIFICATION - Rosy pipeline integrity... · Pipeline Integrity Specification (commonly known as the DPIS) has been developed by Forevermark in collaboration

1© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies. Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

C O N T E N T S

Foreword ................................................................................................................. 2

1 Introduction ....................................................................................................... 31.1 Forevermark ...................................................................................................... 3

1.2 Pipeline Integrity and Forevermark ........................................................... 3

1.3 How is Pipeline Integrity established? ..................................................... 3

1.4 Who will verify Pipeline Integrity? ............................................................ 4

1.5 When should Pipeline Integrity be implemented? ................................ 4

2 Terms and definitions ..................................................................................... 6

3 The Diamond Pipeline .................................................................................... 9Figure 1 – The Diamond Pipeline (the key Pipeline Entities) ................... 9

4 Scope.................................................................................................................... 10

5 Normative references ..................................................................................... 10

6 Forevermark Pipeline Integrity Requirements ...................................... 116.1 Forevermark Diamantaire purchases ........................................................ 11

6.2 Diamond manufacturers .............................................................................. 13

6.3 Forevermark Facility ..................................................................................... 14

6.4 Verified Intermediaries ................................................................................. 14

6.5 Jewellery manufacturers ............................................................................. 15

6.6 Forevermark Jewellers ................................................................................. 15

7 Qualifications of Internal Assessors and External Auditors ............. 167.1 General ............................................................................................................... 16

7.2 Internal Assessors .......................................................................................... 16

7.3 External Auditors ........................................................................................... 16

8 Pipeline Integrity Assessment – Internal Assessors ............................ 178.1 Pipeline Integrity Assessment procedures .............................................. 17

8.2 Pipeline Integrity Assessment .................................................................... 18

8.3 Corrective and preventative action .......................................................... 19

9 Pipeline Integrity Verification – External Auditors .............................. 209.1 Responsibilities of Forevermark ................................................................. 20

9.2 Responsibilities of the External Auditor ................................................. 20

9.3 Verification Report ........................................................................................ 20

9.4 Compliance with the requirements .......................................................... 21

9.5 Failure to meet the requirements ............................................................. 21

Annexes

Annex A De Beers Best Practice Principles (BPPs).................................... 22

Annex B The Forevermark Icon ........................................................................ 23

Figure B.1 The Forevermark Icon ...................................................................... 23

Annex C Forevermark DPIS: Changes in the 2015 edition ........................ 24

Bibliography .......................................................................................................... 26

Page 4: DIAMOND PIPELINE INTEGRITY SPECIFICATION - Rosy pipeline integrity... · Pipeline Integrity Specification (commonly known as the DPIS) has been developed by Forevermark in collaboration

2© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies.

Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

F O R E W O R D

PUBLISHING INFORMATION

This Private Standard, Forevermark 001:2015, Diamond

Pipeline Integrity Specification (commonly known

as the DPIS) has been developed by Forevermark

in collaboration with BSI Standards Limited.

All copyrights, trade secrets and all other rights

subsisting in this document are owned by The

De Beers Group of Companies. The Forevermark

intellectual property (IP), including the trade marks

“A Diamond is Forever”®, the Forevermark Icon ®

and “Forevermark”, also belong to The De Beers

Group of Companies.

This Standard is not to be regarded as a British

Standard.

SUPERSESSION

This Standard supersedes Forevermark 001:2011,

which is withdrawn.

INFORMATION ABOUT THIS DOCUMENT

Forevermark will only apply the Inscription to

Eligible Diamonds. Pipeline Integrity Requirements

set out in this Standard are designed to implement

checks that the integrity and distinctiveness of

Forevermark and the Forevermark IP, including its

trademarks, are maintained.

This Standard is only relevant to, and will only

be used for, the purposes of Forevermark and

Forevermark Activities. Compliance with this

Standard does not in itself automatically qualify a

Pipeline Entity for participation in any Forevermark

Activities, nor does it entitle a Participant to

continue to participate in Forevermark Activities,

or to use the Forevermark Icon or any other

Forevermark IP for any other purpose.

USE OF THIS DOCUMENT

It has been assumed in the preparation of this

Standard that the execution of its provisions will be

entrusted to appropriately qualified and experienced

people, for whose use it has been produced.

PRESENTATIONAL CONVENTIONS

The provisions of this Standard are presented in

roman (i.e. upright) type. Its requirements are

expressed in sentences in which the principal

auxiliary verb is “shall”.

Commentary, explanation and general informative

material is presented in italic type, and does not

constitute a normative element.

CONTRACTUAL AND LEGAL CONSIDERATIONS

This Standard does not purport to include all the

necessary provisions of a contract. Users are

responsible for its correct application.

Compliance with this Standard cannot confer

immunity from legal obligations.

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3© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies. Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

1 I N T R O D U C T I O N

1.1 FOREVERMARK

Everything that Forevermark, its Forevermark IP

and its approved Forevermark Activities stand for

is designed to promote consumer confidence in the

natural and responsible provenance of Forevermark

Diamonds. Only Participants who have been

assessed against the Forevermark 001:2015 Diamond

Pipeline Integrity Specification (referred to as “this

Standard” within this document) and who clearly

demonstrate compliance with the De Beers Best

Practice Principles (BPPs; see Clause 5 and Annex A)

are eligible to participate in Forevermark Activities,

and only diamonds sourced from Approved Suppliers

(as defined and updated on a regular basis by

Forevermark) may be used in Forevermark Activities.

This Standard is aimed specifically at diamantaires

and their subsidiaries.

1.2 PIPELINE INTEGRITY AND FOREVERMARK

Fundamental to Forevermark’s consumer proposition

is the assurance that the diamond bearing the

Inscription is:

a) natural and untreated;

b) responsibly sourced (see 2.31) from, and

traceable to, an Approved Supplier;

c) responsibly processed (see 2.30) in accordance

with the BPPs.

The Diamond Pipeline encompasses the flow of

diamonds from the date that a Rough Purchase is

delivered by an Approved Supplier (or Verified

Intermediary) to the intended Forevermark

Diamantaire, to the date of sale to the consumer at

a jewellery outlet. The Forevermark “Approved

Suppliers Matrix”, which, due to the sensitivity of the

information, is outside the scope of this Standard,

includes criteria and requirements for suppliers to

meet to become Approved Suppliers. This provides

reassurance that Forevermark Diamonds are

responsibly sourced from the outset of the supply

chain. It is important to note that the Approved

Suppliers Matrix is an immediate precursor to this

document. Any suppliers that wish to become an

Approved Supplier can only do so by approaching

Forevermark directly.

1.3 HOW IS PIPELINE INTEGRITY ESTABLISHED?

To implement requirements to check for the integrity

of Forevermark and all that it stands for, The De

Beers Group of Companies, in conjunction with BSI

Standards Limited, have developed this Standard.

This comprises a set of requirements on procedures

that enables Participants to demonstrate the

eligibility of, and authenticity of, diamonds used

for Forevermark Activities at any stage in the

Diamond Pipeline, from jewellery store back to

original Rough Purchase.

To verify that Forevermark Diamonds are natural

and untreated (see also A.1), diamonds will undergo

routine testing prior to the Inscription Process.

Eligible Diamonds are sent to the Forevermark

Diamond Institute to be inscribed with the

Forevermark Icon and unique serial number, as well

as Forevermark Diamond Grading. The legitimate

origin is established by sourcing from Approved

Suppliers, whilst adherence to the BPPs establishes

that they are responsibly processed and handled

through the downstream pipeline.

Forevermark Diamantaires that participate in

Forevermark Activities are contractually required to

meet the requirements of Forevermark. Forevermark

Diamantaires have sole responsibility for ensuring

that they are compliant with Forevermark’s

requirements. This responsibility is both when the

Forevermark Diamantaire makes an eligible Rough

Purchase and also prior to delivery of a diamond for

the Inscription Process. Failure to do so undermines

the integrity of Forevermark and all that it stands for

and might result in the termination of Forevermark

Diamantaire status.

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4© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies.

Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

1.4 WHO WILL VERIFY PIPELINE INTEGRITY?

An important feature of the consumer proposition is

that an independent body, known as the External

Auditor, is able to verify the eligibility and

authenticity of diamonds used for Forevermark

Activities. To this end, Forevermark has engaged the

services of Société Générale de Surveillance (SGS)

who are among the world’s leading inspection,

verification, testing and certification companies and

are recognised as a global benchmark for quality and

integrity. The Pipeline Integrity Assessment process

itself does not simply result in a “pass” or “fail”; it

is designed to enable Participants to develop and

maintain systems in line with this Standard that,

initially, might need new development or require

ongoing modifications as the business develops.

1.5 WHEN SHOULD PIPELINE INTEGRITY BE IMPLEMENTED?

Forevermark Diamantaires are required to implement

this Standard before the diamonds are first

submitted for the Inscription Process. Part

of this implementation will include successful

independent verification by SGS in the form of a

Pipeline Integrity Verification.

If a Forevermark Diamantaire wishes to use

diamonds manufactured prior to the date of their

Pipeline Integrity Verification and confirmed

eligibility to participate in Forevermark Activities,

they will need to provide clear evidence that, at

the very least, the required control systems (i.e.

traceability and records) were in place at the date

of first processing of these diamonds.

The aim of this Standard is not to change or inhibit

Forevermark Diamantaires’ existing operations but to

help them satisfactorily demonstrate that Eligible

Diamonds and Forevermark Diamonds are traceable

and kept separate from all other diamonds.

Page 7: DIAMOND PIPELINE INTEGRITY SPECIFICATION - Rosy pipeline integrity... · Pipeline Integrity Specification (commonly known as the DPIS) has been developed by Forevermark in collaboration

5© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies. Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

Page 8: DIAMOND PIPELINE INTEGRITY SPECIFICATION - Rosy pipeline integrity... · Pipeline Integrity Specification (commonly known as the DPIS) has been developed by Forevermark in collaboration

6© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies.

Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

For the purposes of this Standard, the following

terms and definitions apply.

2.1 APPLICANT DIAMANTAIRE

Diamantaire that applies to Forevermark to

participate in Forevermark Activities.

2.2 APPROVED SUPPLIER

Supplier whose corporate social responsibility (CSR)

and despatch control systems have been accepted

as meeting the requirements of the Consumer

Promise.

NOTE Verification that a supplier meets the

requirements of the Consumer Promise will be by an

External Auditor.

2.3 ASSOCIATED ENTITIES

Either:

a) Diamond manufacturers in a Forevermark

Diamantaire’s Diamond Pipeline that are selected

as an eligible part of the Forevermark

Diamantaire’s Diamond Pipeline for participation

in Forevermark Activities; or

b) other third parties undertaking activities in which

Eligible Diamonds or Forevermark Diamonds pass

into their control and custody at any stage prior

to delivery to the consumer.

NOTE Diamond manufacturers include

subcontractors engaged to carry out any of the

Diamond Pipeline operations.

2.4 BEST PRACTICE PRINCIPLES (BPPS)

Principles that are designed to implement checks

that best practice standards are observed in the gem

diamond industry (see Clause 5 and Annex A).

2.5 CONSUMER PROMISE

Promise to the consumer that diamonds bearing the

Inscription are natural and untreated, responsibly

sourced and responsibly processed.

NOTE Further information regarding the Consumer

Promise can be found at: www.Forevermark.com.

2.6 DIAMOND

Natural diamond gemstone which has not been

subject to treatment, with a hardness of 10 Mohs,

a specific gravity of approximately 3.52 and a

refractive index of 2.42.

2.7 DIAMOND PIPELINE

Flow of diamonds from the date the Rough Purchase

that is received by the Forevermark Diamantaire, or

purchased from a Verified Intermediary, through to

the date of sale to the consumer by a Forevermark

Jeweller.

NOTE The operations in question might include

rough diamond sorting, diamond manufacture,

jewellery manufacture and Forevermark Jewellers,

including transfer, transportation and storage

(whether or not the diamonds remain the property

of the same entity/person or ownership is

transferred to another entity/person during such

operations).

2.8 ELIGIBLE DIAMOND

Rough diamond purchased either:

a) Directly from Approved Suppliers; or

b) Indirectly, as provided for in this Standard; that

are eligible for the Inscription Process (subject to

meeting the Pipeline Integrity Requirements and

any other criteria specified by Forevermark).

2.9 EXTERNAL AUDIT TEAM

Group comprising any individuals appointed as

External Auditors within a single Pipeline Integrity

Verification and also any individuals assigned tasks

relating directly to the Pipeline Integrity Verification.

2.10 EXTERNAL AUDITOR

Independent third party (individual or entity)

appointed by Forevermark that is responsible for

verifying the Pipeline Integrity Assessments and

Internal Assessors of a Forevermark Pipeline Entity.

NOTE 1 See also, Pipeline Integrity Verification.

NOTE 2 In the previous publication of the DPIS

(2011), External Auditor was referred to as the

Verifier. The External Auditor is responsible for the

Pipeline Integrity Verification and producing the

Verification Report.

2.11 FOREVERMARK

Part of The De Beers Group of Companies.

2.12 FOREVERMARK ACTIVITY

Any business or activity conducted by, or expressly

permitted by, Forevermark.

2 TERMS AND DEFINITIONS

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7© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies. Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

2.13 FOREVERMARK CRITERIA

Criteria for Forevermark Diamantaires and their

downstream partners to satisfy in order to qualify

for participation in Forevermark Activities.

2.14 FOREVERMARK DIAMANTAIRE

Any person, firm or company, or other trading

organization making Rough Purchases and

manufacturing polished stones, which have satisfied

the Forevermark Criteria and which have applied and

been accepted to be part of Forevermark Activities.

NOTE The Rough Purchases or manufacturing of

polished stones may be made by using owned or

subcontracted manufacturing units.

2.15 FOREVERMARK DIAMOND

Eligible Diamond that has been inscribed with

the Inscription.

2.16 FOREVERMARK FACILITY

Forevermark facility responsible for the Inscription

Process whereby Eligible Diamonds are inscribed

with the Inscription.

2.17 FOREVERMARK ICON

Small diamond-shaped inscription on the table facet

of a polished diamond, invisible to the naked eye and

measuring only 1/20th of a micron in depth.

NOTE A unique identification number is also

inscribed beneath the icon. Together they signify

that the diamond has been responsibly sourced,

tracked from rough through to polished and, before

inscription, that it has been assessed by the

Forevermark Diamond Institute as meeting the

Forevermark quality criteria. See also Annex B.

2.18 FOREVERMARK JEWELLER

Jeweller, authorized by Forevermark on the basis of

Forevermark Criteria to participate in Forevermark

activities.

2.19 INSCRIPTION

The Forevermark Icon, together with the serial

number.

NOTE See Annex B.

2.20 INSCRIPTION PROCESS

Process of inscribing Eligible Diamonds with the

Inscription.

2.21 INTERNAL ASSESSMENT REPORT

Written report prepared by the Internal Assessor,

following Pipeline Integrity Assessment of a

Pipeline Entity.

2.22 INTERNAL ASSESSMENT TEAM

Group comprising any individuals appointed as

Internal Assessors within a single Pipeline Integrity

Assessment and also any individuals assigned tasks

relating directly to the Pipeline Integrity Assessment.

NOTE This group might include, for example,

management team representatives.

2.23 INTERNAL ASSESSOR

Individual, independent from the assessed

department nominated by the Forevermark Pipeline

Entity, that is responsible for assessing the Pipeline

Integrity of that Pipeline Entity.

NOTE An Internal Assessor may be an employee of,

or an independent entity engaged by, the Pipeline

Entity to carry out a Pipeline Integrity Assessment.

2.24 PARTICIPANT

Applicant Diamantaire selected by Forevermark,

including Forevermark Diamantaires, on the basis of

the Forevermark Criteria, to participate in

Forevermark Activities.

2.25 PIPELINE ENTITY

Forevermark Diamantaires’ and their Associated

Entities’ individual facilities or units involved in

the Diamond Pipeline, Verified Intermediaries and

the Forevermark Facility.

2.26 PIPELINE INTEGRITY (PI)

Physical separation and/or traceability of Eligible

Diamonds from all other diamonds and the

authentication of Forevermark Diamonds throughout

the Diamond Pipeline.

2.27 PIPELINE INTEGRITY ASSESSMENT

Process of investigating a Pipeline Entity’s process

flow and control systems to check Pipeline Integrity

and the verification of Eligible Diamonds and

Forevermark Diamonds.

NOTE Pipeline Integrity Assessment is carried out by

a Forevermark Diamantaire’s/Verified Intermediary’s

Internal Assessor, whose assessment is also subject

to verification by the External Auditor. See Clause 8.

2.28 PIPELINE INTEGRITY REQUIREMENTS

Conditions for achieving and maintaining Pipeline

Integrity (see Clause 6).

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8© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies.

Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

2.29 PIPELINE INTEGRITY VERIFICATION

Process carried out by the External Auditor of

verifying Pipeline Integrity Assessments by:

a) reviewing all Internal Assessment Reports; and/or

b) carrying out random third-party Pipeline Integrity

Assessments; and/or

c) investigating alleged breaches of Pipeline

Integrity.

NOTE See Clause 9.

2.30 RESPONSIBLE PROCESSING

Management of Sustainable Development in the

progression of diamonds through the Diamond Pipeline.

2.31 RESPONSIBLE SOURCING

Management of Sustainable Development in the

provision or procurement of a product.

2.32 REVIEW AUDITOR

Independent auditor appointed by Forevermark to

review and evaluate the performance of the External

Auditor.

2.33 ROUGH PURCHASE

Individual and defined purchase of rough diamonds

containing Eligible Diamonds for Forevermark Activities.

2.34 SPOT CHECK

Unannounced inspection of the Pipeline Integrity

and/or specific diamonds and/or diamond parcels

that can occur at short notice.

NOTE Spot Checks are carried out by External Auditors.

2.35 SUPERVISOR

Any employee with overall responsibility for a

particular stage of Forevermark Activities.

NOTE Examples of Forevermark Activity stages include

stock control or, in the case of diamond manufacturing,

the cleaving, sawing or bruting processes.

2.36 SUSTAINABLE DEVELOPMENT

Enduring, balanced approach to economic activity,

environmental responsibility and social progress.

2.37 SYSTEMS OPERATIVE

Any employee working with diamonds or involved in

the transfer of loose or mounted diamonds between

departments or individuals within a Pipeline Entity’s

operations.

2.38 TREATED DIAMOND

Diamond that has been subjected to any process,

treatment or enhancement changing, interfering

with, and/or contaminating, the natural appearance

or composition of diamonds.

NOTE This includes colour (and decolourization)

treatment, fracture filling, laser and irradiation

treatment and coating.

2.39 VERIFICATION REPORT

Written report prepared by the External Auditor,

following Pipeline Integrity Verification of a

Pipeline Entity.

NOTE The Verification Report is confidential to

Forevermark and the relevant Forevermark

Diamantaire or Verified Intermediary, and is the basis

for issuing certificates to provide evidence of a

Forevermark Diamantaire or Verified Intermediary

meeting the Pipeline Integrity Requirements.

2.40 VERIFIED INTERMEDIARY

Reseller (including a broker) of Eligible Diamonds

who, according to objective Pipeline Integrity

Assessment and Pipeline Integrity Verification, meets

the requirements of this Standard.

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9© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies. Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

3 THE DIAMOND PIPELINE

COMMENTARY ON CLAUSE 3

Figure 1 represents a typical Diamond Pipeline and illustrates instances where the different Pipeline Entities

can overlap or divide into more than one unit.

Figure 1 – The Diamond Pipeline (the key Pipeline Entities)

Forevermark

Diamantaire

Forevermark

Facility

Verified

Intermediary

Approved Suppliers

Jewellery

manufacturer

Forevermark

Jeweller

Non-Verified

Intermediary

(Check with

Forevermark)

Third party

grading option

Pipeline

Integrity

Assessment by

an Internal

Assessor,

or, External

Auditor, where

applicable.

Pipeline

Integrity

Verification by

an External

Auditor –

Spot Checks

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10© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies.

Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

4 SCOPE 5 NORMATIVE REFERENCES

This Standard specifies the requirements for

achieving and maintaining Pipeline Integrity for the

processing of Eligible Diamonds, i.e. diamonds

intended for use in Forevermark Activities.

This Standard outlines the responsibilities of:

• Forevermark Diamantaires;

• Associated Entities of Forevermark Diamantaires;

• Verified Intermediaries;

• Pipeline Integrity Internal Assessors of Verified

Intermediaries; and

• the External Auditor involved in Forevermark

Activities, in addition to Forevermark itself.

It is applicable to all Participants.

The following listed documents, in whole or in part,

are normatively referenced in this document and are

indispensable for its application. For dated references,

only the edition cited applies. For undated references,

the latest edition of the referenced document

(including any amendments) applies.

5.1 DE BEERS PUBLICATIONS

• De Beers Best Practice Principles (BPPs), including

the following documents:

a) De Beers, The Best Practice Principles –

The Assurance Programme Requirements;

b) De Beers, The Best Practice Principles –

The Disclosure Practice Notes;

c) De Beers, The Best Practice Principles –

The Manual;

d) De Beers, The Best Practice Principles –

The Workbook.

NOTE 1 See also, Annex A for further information

regarding the Best Practice Principles.

NOTE 2 The De Beers Best Practice Principles

documents are updated every year. The latest

version as published by The De Beers Group of

Companies should be used.

• De Beers, The Standard Guidance on Undisclosed

Synthetics.

5.2 FOREVERMARK PUBLICATIONS

• Forevermark, Diamond Pipeline Integrity Guidance

Notes.

• Forevermark, Integrity Requirements.

• Forevermark, Management System for Forevermark:

The Pipeline Integrity Check List.

NOTE This document is more commonly referred to

as the “Pipeline Integrity Check List”.

• Kimberley Process System of Warranties Statement.

5.3 OTHER SOURCES

NOTE Further information regarding the

Kimberley Process can be found online, at

http://www.kimberleyprocess.com, or through

the World Diamond Council website,

http://www.worlddiamondcouncil.com/.

• Terms and definitions (see Clause 2) – a glossary

of terms and definitions which are used in this

Standard to clarify meaning and avoid

misunderstanding.

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6 FOREVERMARK PIPELINE INTEGRITY REQUIREMENTS

COMMENTARY ON CLAUSE 6

This clause specifies the requirements that are to be

met to establish Pipeline Integrity in the Diamond

Pipeline.

Diamantaires and intermediaries, who wish to participate

in Forevermark Activities, will need to meet the

requirements of this Standard, including independent

verification by the appointed External Auditor, Société

Générale de Surveillance (SGS), of each and every

Pipeline Entity that will be used for Forevermark

Activities, before diamonds are first received for the

Inscription Process. (This includes units and/or

contractors used for single operations, such as sawing

or boiling, for example, which might not form part of

the main operation.) This verification is in the form of

two “dummy runs” where diamonds are processed

through the diamantaire’s system with Internal

Assessors and then External Auditors verifying the

process as a whole and reporting the results to

Forevermark. Once accepted into the Forevermark

scheme, each Forevermark Diamantaire is assessed

against this document on a yearly basis.

For ease of use, the different activities and stages that

occur in the Diamond Pipeline have been divided into

the following sub–clauses:

• 6.1 Forevermark Diamantaire purchases

• 6.2 Diamond manufacturers

• 6.3 Forevermark Facility

• 6.4 Verified Intermediaries

• 6.5 Jewellery manufacturers

• 6.6 Forevermark Jewellers

6.1 FOREVERMARK DIAMANTAIRE PURCHASES

COMMENTARY ON 6.1

This sub–clause applies to Forevermark Diamantaires

who purchase diamonds for the purpose of

Forevermark Activities.

6.1.1 Sources of supply

Forevermark Diamantaires shall source diamonds for

inclusion in Forevermark Activities that originate

only from Approved Suppliers.

NOTE A list of Approved Suppliers will be

maintained and regularly renewed and updated

by Forevermark. See also, Introduction, 1.2.

6.1.2 Rough Purchases direct from Approved Suppliers

Forevermark Diamantaires shall maintain accurate

records of each Rough Purchase containing Eligible

Diamonds which are intended for use in Forevermark

Activities, including:

a) original invoice and original Rough Purchase

details (including any unique reference number

and shipment details);

b) identification of diamonds eligible for use in

Forevermark Activities (Eligible Diamonds) in

terms of carats;

c) details of diamonds considered not eligible for

use in Forevermark Activities and therefore

removed from Forevermark Activities (non-

Eligible Diamonds) in terms of carats.

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12© Forevermark 2015. Forevermark™ and ™ are Trade Marks of The De Beers Group of Companies.

Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

6.1.3 Rough Purchases indirect from Approved Suppliers

COMMENTARY ON 6.1.3

Forevermark recognises the rough diamond dealing

activities that Forevermark Diamantaires might

perform as a part of their various business models

and distribution channels.

Nonetheless, in order to preserve the integrity of

Forevermark and all that it stands for (including

its Forevermark IP and Forevermark Activities),

Forevermark Diamonds have to be sourced from

and traceable back to Approved Suppliers. All

Forevermark Diamantaires should log Forevermark

Diamonds accordingly on their internal IT systems.

Regular research is performed into all rough

diamond mining suppliers and their suitability of

being a Forevermark Approved Supplier. This

suitability is measured against strict Forevermark

Criteria, which among other requirements, requires

publicly available best practice measures being

undertaken in all business, social and environmental

commitments taken by the diamond mining supplier.

Their compliance with the Forevermark Approved

Supplier criteria (see 1.2) leads their diamond

production to be classed as “Forevermark-eligible”.

Sub-clauses 6.1.3.1 and 6.1.3.2 cover the two options

for indirect Rough Purchases from Approved

Suppliers.

6.1.3.1 Rough Purchases from a Verified Intermediary

Where a Forevermark Diamantaire purchases

diamonds from a Verified Intermediary for the

purpose of Forevermark Activities, the Forevermark

Diamantaire shall:

a) check and confirm in writing that diamonds are

purchased only from Verified Intermediaries;

b) check and confirm in writing that diamonds are

purchased either as complete Rough Purchases in

their original packaging, or with relevant

traceability to the original Rough Purchase;

c) allow the External Auditor to assess the origin

(Approved Supplier) of these diamonds while

keeping the identity of all parties in the transaction

confidential;

d) maintain accurate records of each indirect Rough

Purchase containing Eligible Diamonds, including:

1) copy of the invoice from the Verified

Intermediary giving reference details that can

be traced to the original Rough Purchase

details (including any unique reference

number and shipment details);

2) identification details of diamonds eligible for

use in Forevermark Activities (Eligible

Diamonds) in terms of carats;

3) details of diamonds considered not eligible for

use in Forevermark Activities and therefore

removed from Forevermark Activities (non-

Eligible Diamonds) in terms of carats.

6.1.3.2 Rough Purchases from a non-Verified Intermediary

Where a Forevermark Diamantaire purchases

diamonds from a non-Verified Intermediary, for the

purpose of Forevermark Activities, this shall be

limited to Rough Purchases that are traceable, in

their entirety, to the Approved Supplier.

The Forevermark Diamantaire shall:

a) check and confirm in writing that traceability

exists to an Approved Supplier; and

b) invite SGS to verify the origin (Approved

Supplier) of all Rough Purchases; or

c) obtain written approval from Forevermark

directly by providing all relevant documents and

photographs of the Diamonds as they are

purchased and received by the Forevermark

Diamantaire in their rough parcels; and

NOTE Written approval should be obtained from the

Forevermark Commercial Team through the

Forevermark Account Manager.

d) maintain accurate records of each Rough

Purchase containing Eligible Diamonds, including:

1) carat weight, Rough Purchase description and

any unique reference number;

2) date of purchase and receipt, and evidence

of provenance;

3) identification details of diamonds eligible for

use in Forevermark Activities (Eligible

Diamonds) in terms of description, numbers

and carats;

4) details of diamonds considered not eligible for

use in Forevermark Activities and therefore

removed from Forevermark Activities (non-

Eligible Diamonds) in terms of carats.

6.1.4 Diamond purchases from a Forevermark Diamantaire

Where a Forevermark Diamantaire purchases

diamonds from another Forevermark Diamantaire

for use in Forevermark Activities, the Forevermark

Diamantaire shall, in addition to maintaining

accurate records:

a) purchase only Eligible Diamonds; or

b) purchase only Forevermark Diamonds.

A Forevermark Diamantaire shall sell only

Forevermark Diamonds to a Participant in

Forevermark Activities.

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6.2 DIAMOND MANUFACTURERS

COMMENTARY ON 6.2

This sub–clause applies to Forevermark Diamantaires

and their Associated Entities in the Diamond Pipeline

involved in the manufacture and processing of

diamonds, from receipt of original Rough Purchases

to delivery into the control of the Forevermark

Facility.

Forevermark Diamantaires and their Associated

Entities shall:

a) maintain a visible and comprehensive method of

identifying Eligible Diamonds and distinguishing

them from all other diamonds to be verified by

an External Auditor;

b) maintain either:

1) a tracking and control system for the

manufacture of Eligible Diamonds; or

2) a system of segregation of Eligible Diamonds

and non-Eligible Diamonds;

c) maintain documented control procedures for the

manufacture of Eligible Diamonds;

d) maintain accurate records of all Rough Purchases

that contain Eligible Diamonds, including:

1) source of diamonds used in Forevermark

Activities back to the Approved Supplier;

2) carat weight, Rough Purchase description and

any unique reference number;

3) identification and traceability of Eligible

Diamonds;

4) identification details of diamonds removed

from Forevermark Activities as being not

eligible (non-Eligible Diamonds) in terms of

carats;

e) reconcile and retain reconciliation records of each

batch used for Forevermark Activities, including:

1) reconciling Eligible and non-Eligible Diamonds

to the original Rough Purchase, in terms of

carats;

2) reconciling the resultant polished diamonds

from the Eligible Diamonds manufactured, in

terms of carats, colour, clarity and yield;

3) storing these records effectively, securely and

in line with the retention requirements for

business documents in the relevant country

and for a minimum of 7 years;

4) sending completed reconciliations to the

External Auditor, upon request, for validation;

f) correct errors and anomalies in the transfer of

diamonds between operations in the Diamond

Pipeline promptly and undertake root cause

analysis to check and confirm in writing that

corrective and preventative actions are taken;

g) appoint an Internal Assessor to perform regular

Pipeline Integrity Assessments to maintain the

integrity of the Diamond Pipeline and the

requirements of this Standard (see 8.1);

h) request Pipeline Integrity Verification when

satisfied that Pipeline Integrity Requirements

have been met;

i) allow the External Auditor access to their

respective operations and records to verify

Pipeline Integrity conformity;

j) allow the External Auditor to assess the ability

and independence of its chosen Internal Assessor;

k) immediately inform Forevermark of changes or

potential changes that could affect the integrity

of Forevermark and/or the integrity of Eligible

Diamonds in the Diamond Pipeline;

l) at all times consistently uphold De Beers BPPs

(see Clause 5 and Annex A);

m) where Associated Entities are used for the

purpose of Forevermark Activities, check and

confirm in writing that the Associated Entities

uphold De Beers BPPs (see Clause 5 and

Annex A).

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6.3 FOREVERMARK FACILITY

COMMENTARY ON 6.3

This sub–clause applies to the Forevermark Facility,

from delivery of Eligible Diamonds to its control, to

the point at which Forevermark inscribed diamonds

(Forevermark Diamonds) are returned to the relevant

Forevermark Diamantaire.

The Forevermark Facility shall:

a) keep Eligible Diamonds delivered to it for the

Inscription Process physically separate from all

other diamonds, including those of other

Forevermark Diamantaires;

b) maintain a tracking and control system to identify

the location of a diamond within the Inscription

Process at all times;

c) maintain documented control procedures for the

processing of Eligible Diamonds;

d) maintain accurate records of diamonds delivered

by each Forevermark Diamantaire for the

Inscription Process, including:

1) name and address of the Forevermark

Diamantaire;

2) all operations carried out in the Inscription

Process;

3) all product integrity checks (e.g. checks for

synthetic or Treated Diamonds).

e) correct anomalies in the transfer of diamonds

between operations within the Inscription

Process promptly;

f) reconcile records and store these effectively,

including:

1) each delivery of diamonds from a Forevermark

Diamantaire to the Forevermark Facility;

2) each return delivery, diamonds which were

inscribed with the Inscription;

3) each return delivery, diamonds determined

by the Forevermark Facility not to be Eligible

Diamonds and therefore not inscribed with

the Inscription.

g) appoint an Internal Assessor to perform regular

Pipeline Integrity Assessments to maintain the

integrity of the Diamond Pipeline and the

requirements of this Standard (see Clause 7);

h) allow the External Auditor access to its facility

and relevant records, to verify Pipeline Integrity

conformity;

i) allow the External Auditor to assess the ability

and independence of its chosen Assessor;

j) immediately inform Forevermark management

team of changes or potential changes within

Forevermark Facility that could affect the

integrity of Forevermark and/or the integrity

of Eligible Diamonds in the Diamond Pipeline;

k) at all times, and consistently, uphold De Beers

BPPs (see Clause 5 and Annex A);

l) where Associated Entities are used for the purpose

of Forevermark Activities, check and confirm in

writing that the Associated Entities uphold De

Beers BPPs (see Clause 5 and Annex A).

6.4 VERIFIED INTERMEDIARIES

COMMENTARY ON 6.4

This sub–clause applies to Verified Intermediaries

involved in the supply of indirect Rough Purchases

to Forevermark Diamantaires who intend to use

these in Forevermark Activities.

The Verified Intermediary shall:

a) verify any documentation accompanying Rough

Purchases and investigate and correct any

anomalies promptly;

NOTE Such documentation may be in the form

of a delivery note that refers to a sealed Rough

Purchase, complete with description and carats

but omitting reference to the financial transaction

relevant to the diamonds.

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b) maintain the integrity of the original contents;

c) maintain accurate records of indirect Rough

Purchases traceable to the original Approved

Supplier, including:

1) original packaging and seals;

2) original invoice and original Rough Purchase

details (including unique reference number,

shipment details, and relevant dates).

d) clearly segregate individual Rough Purchases;

e) sell with documentation to demonstrate integrity

of the contents, including a clear statement of:

1) total caratage;

2) Rough Purchase description;

3) coding traceable to original Rough Purchase;

4) certification of the completeness and integrity

of the contents of the diamonds being supplied;

NOTE This may be equated to the Kimberley

Process Warranties Statement relating to the

origin of diamonds. See also Clause 5.

f) appoint an Internal Assessor to perform regular

Pipeline Integrity Assessments to maintain the

integrity of the systems and the requirements of

this Standard (see 7.1);

g) request verification when satisfied that Pipeline

Integrity Requirements have been met;

h) allow the External Auditor access to their

respective operations and records to verify their

systems and facilitate access to information

requested by the External Auditor in the course

of their verification of the Participants in

Forevermark Activities;

i) allow the External Auditor to assess the ability

and independence of their chosen Internal

Assessor;

j) at all times consistently uphold De Beers BPPs

(see Clause 5 and Annex A).

6.5 JEWELLERY MANUFACTURERS

COMMENTARY ON 6.5

This sub–clause applies to jewellery manufacturers

in Forevermark Activities.

The jewellery manufacturer shall:

a) maintain and store accurate records of

Forevermark Diamonds used in the manufacture

of jewellery, including records of each delivery of

Forevermark Diamonds from each Forevermark

Diamantaire;

b) allow the External Auditor access to its facility

and relevant records to verify Pipeline Integrity

conformity;

c) immediately inform all their relevant Forevermark

Diamantaires and Forevermark of changes or

potential changes that could affect the integrity

of Forevermark and/or the integrity of

Forevermark Diamonds in the Diamond Pipeline;

d) at all times consistently uphold De Beers BPPs

(see Clause 5 and Annex A);

e) where Associated Entities are used for the

purpose of Forevermark Activities, check and

confirm in writing that the Associated Entities

uphold De Beers BPPs (see Clause 5 and

Annex A).

6.6 FOREVERMARK JEWELLERS

COMMENTARY ON 6.6

This sub–clause applies to authorized Forevermark

Jewellers participating in Forevermark Activities to

which Forevermark Diamonds or jewellery containing

Forevermark Diamonds are supplied.

The Forevermark Jeweller shall:

a) maintain and store accurate records of

Forevermark Diamonds or jewellery containing

Forevermark Diamonds, including records of each

delivery of Forevermark Diamonds or jewellery

containing Forevermark Diamonds;

b) permit access to the External Auditor to allow

authenticity tests to be carried out on loose

Forevermark Diamonds or jewellery claimed to be

manufactured using Forevermark Diamonds;

c) immediately inform Forevermark of changes or

potential changes that could affect the integrity

of Forevermark and/or the integrity of

Forevermark Diamonds in the Diamond Pipeline;

d) at all times consistently uphold De Beers BPPs

(see Clause 5 and Annex A);

e) where Associated Entities are used for the

purpose of Forevermark Activities, check and

confirm in writing that the Associated Entities

uphold De Beers BPPs (see Clause 5 and

Annex A).

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7 QUALIFICATIONS OF INTERNAL ASSESSORS AND EXTERNAL AUDITORS

COMMENTARY ON CLAUSE 7

This clause applies to Internal Assessors and

External Auditors.

7.1 GENERAL

Internal Assessors or External Auditors shall be either

appropriate internal personnel or qualified external

auditors.

Where there is more than one Internal Assessor, one

of the Internal Assessors shall be placed in overall

charge of the Internal Assessment Team carrying out

the Pipeline Integrity Assessment and process, as the

lead Internal Assessor.

Where there is more than one External Auditor, one

of the External Auditors shall be placed in overall

charge of the External Audit Team carrying out the

Pipeline Integrity Verification and process, as the lead

External Auditor.

7.2 INTERNAL ASSESSORS

The Internal Assessor shall:

a) be independent of the assessed department and

free from bias and influences;

b) not be involved in supervising the assessed

department; and

c) be an effective communicator.

Evidence of the Internal Assessor’s experience and

qualifications shall be provided to the External

Auditor.

7.3 EXTERNAL AUDITORS

The External Auditor shall:

a) be independent of the assessed Pipeline Entity

and free from bias and influences;

b) possess internationally recognized qualifications

and a background in a relevant field

(e.g. ISO 9001).

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COMMENTARY ON CLAUSE 8

The purpose of a Pipeline Integrity Assessment is

to determine whether the system of traceability

and/or segregation implemented (including

documented control procedures) meet the

Pipeline Integrity Requirements detailed in

Clause 6. A Pipeline Integrity Assessment should

not be viewed as a “pass” or “fail” exercise, rather

it is an ongoing process that maintains and

validates Pipeline Integrity.

8.1 PIPELINE INTEGRITY ASSESSMENT PROCEDURES

8.1.1 General

Pipeline Integrity Assessments shall be performed

by the appointed Internal Assessor, following the

procedures in 8.1.2 to 8.1.4.

8.1.2 Responsibilities of Forevermark Diamantaires, their Associated Entities and Verified Intermediaries

Forevermark Diamantaires and their Associated

Entities and Verified Intermediaries shall:

a) either appoint one or more employees or appoint

an independent external party as its Internal

Assessor (subject to 8.1.4);

b) requisition the External Auditor to develop a

Pipeline Integrity Assessment plan that meets the

requirements of this Standard;

NOTE See also the Management System for

Forevermark: The Pipeline Integrity Check List.

c) on completion of a Pipeline Integrity Assessment,

decide what follow-up action is necessary as a

result of the Internal Assessment Report and

check and record that such action is taken;

d) provide all resources needed by the Internal

Assessor to help create an effective and efficient

Pipeline Integrity Assessment process;

e) appoint a management team representative to

liaise with the Internal Assessor in the event of

incidents of non-conformity;

f) co–operate with the Internal Assessor to achieve

the objectives of the Pipeline Integrity

Assessment, including access to all Pipeline

Entities that are part of, or relevant to, the

Diamond Pipeline; and

g) determine and initiate corrective and preventative

action based on the Internal Assessment Report.

8.1.3 Pipeline Integrity Assessment frequency

To maintain Pipeline Integrity, Forevermark

Diamantaires and their Associated Entities and

Verified Intermediaries shall perform regular Pipeline

Integrity Assessments at each Pipeline Entity.

The timing or schedule of Pipeline Integrity

Assessments along its Diamond Pipeline shall be at

the discretion of Forevermark Diamantaires,

Associated Entities and Verified Intermediaries,

provided that each entity is internally assessed at

least once during a six–month period by an Internal

Assessor.

8.1.4 Responsibilities of Internal Assessors

Internal Assessors shall:

a) carry out Pipeline Integrity Assessments twice

per year, in accordance with 8.1.3;

b) implement checks and document that the Internal

Assessment Team does not disclose or share

commercial documents and information with

anyone who is not a member of the team, unless

strictly necessary for the purposes of the

Verification Report to Forevermark;

c) check and document that, where it is necessary

to disclose such information, it remains at all

times in a confidential and secure place, not

accessible to any individual who does not require

access to it for the purposes of Forevermark

Activities;

d) check and document that those individuals to

whom such data is disclosed, are instructed not

to discuss it with, or divulge it to, anyone who

does not strictly require it for the express

purposes of Forevermark Activities;

e) confirm and document that they are free from

bias and influences that could affect their

independence and objectivity;

f) immediately report incidents of actual or

suspected non-conformity with the requirements

to the relevant management team representative;

g) take appropriate action where Pipeline Integrity

is not achieved or maintained to remedy the

position as soon as is reasonably practicable.

8 PIPELINE INTEGRITY ASSESSMENT – INTERNAL ASSESSORS

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8.2 PIPELINE INTEGRITY ASSESSMENT

8.2.1 General

Forevermark Diamantaires and their Associated

Entities’ operations, termed Pipeline Entities and

Verified Intermediaries, shall conduct Pipeline

Integrity Assessments using their appointed Internal

Assessors, following the procedure outlined in 8.2.2

to 8.2.10.

8.2.2 Review of control documentation

The Internal Assessor shall check for:

a) documented control procedures for all relevant

stages in the Diamond Pipeline, which are

understood and used by relevant personnel; and

b) the ability to update and improve such

procedures for all stages in the Diamond Pipeline,

as being current approved practice.

8.2.3 Review of traceability and segregation systems

The Internal Assessor shall check for:

a) systems to check that all diamonds used in

Forevermark Activities have been sourced from

Approved Suppliers;

b) types of production and stock control systems

in use;

c) acceptable methods and techniques used to

identify Eligible Diamonds and Forevermark

Diamonds, as determined by the Internal Assessor

and the External Auditor;

d) the effectiveness of production and stock control

systems to monitor, control and track the flow

of diamonds [see 6.2 f), 6.2 e), and 6.3 f) and

6.3 e)]; and

e) the ability to trace Eligible Diamonds and

Forevermark Diamonds to the original Rough

Purchase.

8.2.4 Review of records and reconciliation reports

The Internal Assessor shall check for the:

a) accuracy, content and security of data and

records produced;

b) accuracy, content and security of reconciliations;

and

c) ability to retain Pipeline Integrity records and

reconciliation reports and to store these records

effectively, securely and in line with the retention

requirements for business documents in the

relevant country and for a minimum of 10 years.

8.2.5 Review of personnel

8.2.5.1 Systems Operatives

The Internal Assessor shall check that Systems

Operatives:

a) test for understanding and adherence to the

correct control procedures, as defined by the

Pipeline Entity; and

b) have authority and use of passwords, system data

changes and control system overrides only as

necessary for carrying out their work.

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8.2.5.2 Supervisors

The Internal Assessor shall check that Supervisors:

a) understand and adhere to correct control

procedures as defined by the Pipeline Entity;

b) understand this Standard;

NOTE See also the Management System for

Forevermark: the Pipeline Integrity Check List.

c) have a sufficient level of understanding of the

production and stock control system capabilities;

and

d) have authority and use of passwords, system data

changes and control system overrides only as

necessary for carrying out their work.

8.2.6 Review of diamond stock and work in progress

The Internal Assessor shall test diamond control and

tracking systems by making random physical checks

of the location and content of diamond parcels, and

compare these results with system records.

NOTE See 6.2 f) and 6.3 e).

8.2.7 Review of Diamond Pipeline security

The Internal Assessor shall review and document

the security measures in place to protect Eligible

Diamonds and Forevermark Diamonds, including

the following:

a) ability of personnel (including management and

company directors) to maintain a secure Diamond

Pipeline;

b) controls to check that diamonds originating from

suppliers other than Approved Suppliers cannot

enter Forevermark Activities;

c) opportunities for personnel (including

management and company directors) to change

control system data that could affect the

integrity of Eligible Diamonds to be inscribed

with the Inscription;

d) security measures for the protection of Eligible

Diamonds and Forevermark Diamonds;

e) security measures for the protection of control

system data and records, including in the case of

electronic data, effective back-up and disaster

recovery measures.

8.2.8 Review of packaging, transport and delivery

The Internal Assessor shall review and document the

packaging, transportation and delivery of Eligible

Diamonds and Forevermark Diamonds to and from

the Forevermark Diamantaire and their Associated

Entities, including the following:

a) control of packing, packaging and labelling

processes (including materials used) to the

extent necessary to maintain Pipeline Integrity;

b) protection of the integrity of the diamonds after

final inspection and testing, through to delivery

to their destination, including compliance with

import/export procedures and/or the Kimberley

Process requirements.

NOTE See Clause 5.

8.2.9 Post-Pipeline Integrity Assessment briefing and feedback

On completion of each Pipeline Integrity

Assessment, the Internal Assessor shall inform the

Pipeline Entity’s management team representative

whether the requirements of Clause 6 have been met

or not, in addition to relevant observations.

If corrective action is required, this shall be agreed

between management team representatives and the

Internal Assessor in the form of an action plan with

agreed dates for completion.

NOTE See also the Diamond Pipeline Integrity

Guidance Notes regarding the consequences of

compliance and non-compliance.

8.2.10 Internal Assessment Report

The Internal Assessor shall provide copies of an

Internal Assessment Report on the Pipeline Integrity

Assessment to:

a) the Pipeline Entity;

b) the Forevermark Diamantaire and, where

applicable, its Associated Entities;

c) the External Auditor (within 14 days of

completion of the post-assessment briefing).

The Internal Assessment Report shall confirm

whether the Pipeline Integrity Requirements (see

Clause 6) have been met or not, for each Pipeline

Entity, and make appropriate recommendations to

improve systems to help maintain conformity.

NOTE The Pipeline Integrity Assessment is

considered completed on submission of the Internal

Assessment Report to the relevant Forevermark

Diamantaire or Verified Intermediary.

8.3 CORRECTIVE AND PREVENTATIVE ACTION

If corrective and preventative action and subsequent

follow-up assessments are necessary, the Pipeline

Entity shall either:

a) in the case of a Forevermark Diamantaire or

Verified Intermediary, check and document that

such action or follow-up is completed within a

time period determined in consultation with the

Internal Assessor; or

b) in the case of an Associated Entity, check and

document that such action or follow-up is

completed within a time period agreed between

the relevant Pipeline Entity, the Forevermark

Diamantaire and the Internal Assessor.

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9.1 RESPONSIBILITIES OF FOREVERMARK

To maintain the integrity of Forevermark,

Forevermark shall appoint an independent External

Auditor to verify Pipeline Integrity Assessments

carried out by Forevermark Diamantaires’ and

their Associated Entities’, Verified Intermediaries’

appointed Internal Assessors, or its own

Forevermark Facility.

Forevermark shall be responsible for:

a) contracting the services of a reputable company

to act as the External Auditor that is capable of

carrying out Pipeline Integrity Assessments of the

different stages of the Diamond Pipeline,

including process control systems and

maintenance of records, as well as assessing the

competence of Internal Assessors used by

Pipeline Entities;

b) appointing the Review Auditor to review and

evaluate the performance of the External Auditor;

c) reviewing routine high–level verification and non-

compliance reports submitted by the External

Auditor in the form of a Verification Report; and

d) sending a formal written notification to the

Forevermark Diamantaire or Verified Intermediary

requiring it to implement the recommendations

of the Verification Report if the Diamantaire or

Verified Intermediary fails to act on the

recommendations of the Verification Report

within the required timeframe.

NOTE See the Diamond Pipeline Integrity Guidance

Notes regarding complaints and appeals.

9.2 RESPONSIBILITIES OF THE EXTERNAL AUDITOR

9.2.1 General

The External Auditor shall verify Pipeline Integrity

Assessments carried out by, or on behalf of, Pipeline

Entities.

The External Auditor shall:

a) send a summary of Forevermark Diamantaires’

(or their Associated Entities and Verified

Intermediaries’) Internal Assessor’s formal

Internal Assessment Reports to Forevermark;

b) undertake Pipeline Integrity Verification of all

Forevermark Diamantaires in accordance with

the procedures detailed in Clause 8 and Clause 9 and a timetable discussed and agreed with

Forevermark;

c) undertake verification of potential suppliers’

dispatch control systems where requested by

Forevermark Diamantaires;

d) circulate to Forevermark, the Forevermark

Diamantaire or Verified Intermediary, and the

relevant Pipeline Entity the formal Verification

Report of findings following the Pipeline

Integrity Verification;

e) maintain confidentiality on all confidential

and commercially sensitive information and

documentation obtained in the Pipeline

Integrity Verification;

f) where required by any parties, provide a formal

confidentiality agreement to cover either specific

or all interventions;

g) perform validation checks on Forevermark

Diamantaires’ completed reconciliations, as and

when required;

h) review Pipeline Integrity Assessments and carry

out Pipeline Integrity Verifications and Spot Checks.

9.2.2 Frequency of verification

The External Auditor shall, subject to giving

reasonable prior notice to the Forevermark

Diamantaire or Verified Intermediary:

a) review Internal Assessment Reports within 14 days

of submission by the Forevermark Diamantaire or

Verified Intermediary to the External Auditor; and

b) carry out a Pipeline Integrity Assessment and

a Pipeline Integrity Verification once a year in

accordance with a timetable to be discussed and

agreed with Forevermark.

NOTE In the event of an alleged and/or suspected

breach of Pipeline Integrity, the External Auditor

may immediately, and without prior notice, enter

onto the Forevermark Diamantaire’s or Verified

Intermediary’s premises and carry out

investigations at the request of Forevermark.

9.2.3 Review of the Internal Assessor

The External Auditor shall make an assessment of a

Pipeline Entity’s Internal Assessor in terms of their

independence, suitability and performance with

respect to Pipeline Integrity (see 7.2).

9.3 VERIFICATION REPORT

Within 14 days of the completion of any Pipeline

Integrity Verification, the External Auditor shall

prepare a formal written Verification Report detailing

9 PIPELINE INTEGRITY VERIFICATION – EXTERNAL AUDITORS

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its findings. The Verification Report shall:

a) clearly state whether the Forevermark

Diamantaire or Verified Intermediary and its

Internal Assessor have complied with the

requirements set out in this Standard;

b) clearly state whether the Pipeline Entities have

complied with the requirements set out in 8.2;

c) be circulated to the Forevermark Diamantaire or

Verified Intermediary;

d) make clear which type of Pipeline Integrity

Verification was undertaken (see 9.2.1);

e) provide Forevermark with a Verification Report

and recommendations.

If, following the Pipeline Integrity Verification

conducted by the External Auditor, the Forevermark

Diamantaire or Verified Intermediary is determined

to be non-compliant, the External Auditor shall

notify Forevermark within 48 hours (see 9.5.3).

9.4 COMPLIANCE WITH THE REQUIREMENTS

9.4.1 General

If the External Auditor has verified that a

Forevermark Diamantaire and its Associated Entities

or Verified Intermediaries have met the requirements

of this Standard, the Forevermark Diamantaire or

Verified Intermediary shall be deemed to have met

the Pipeline Integrity Requirements (see Clause 6).

9.4.2 Certification

Subject to signing the Forevermark Diamantaire

Agreement, when a Forevermark Diamantaire or

Verified Intermediary is deemed by the External

Auditor to have met the requirements of this

Standard, the External Auditor shall issue the

relevant Pipeline Entity with a certificate of

compliance. The certificate shall:

a) list the Forevermark Diamantaire’s or Verified

Intermediary’s Pipeline Entities that meet the

requirements of this Standard; and

b) be valid for the remaining duration of the

Forevermark Diamantaire Agreement subject to

satisfying the annual Pipeline Integrity

Verification (see 9.2.2).

The certificate shall include the following details:

1) brief description of Forevermark Activities;

2) name of the Forevermark Diamantaire or Verified

Intermediary;

3) name and address of the External Auditor (issuer

of certificate) and name of the person signing on

behalf of the External Auditor;

4) period of validity of the certificate;

5) name and address of each Associated Entity in

the Diamond Pipeline; and

6) date of issue of the certificate.

9.5 FAILURE TO MEET THE REQUIREMENTS

9.5.1 General

If the External Auditor determines that the

Forevermark Diamantaire and/or its Associated

Entities and/or Verified Intermediaries do not meet

the requirements of this Standard, the Forevermark

Diamantaire or Verified Intermediary shall be deemed

to have not met the Pipeline Integrity Requirements.

NOTE Forevermark has a flexible process in place to

address and respond to issues of non–compliance on

a case-by-case basis. Deadlines within which

corrective action are to be taken operate on a similar

basis, but typically, major non-compliance issues are

addressed within a month (including a Pipeline

Integrity Verification visit) and minor issues within

six months.

9.5.2 Non-compliance prior to participation in Forevermark Activities

If the Forevermark Diamantaire and/or its Associated

Entities and/or Verified Intermediary do not meet

the requirements of this Standard prior to

participation in Forevermark Activities, they shall

agree with the External Auditor a date for another

Pipeline Integrity Verification visit.

NOTE This date will depend on the time required by

the Forevermark Diamantaire or Verified

Intermediary to implement corrective action, and on

the availability of the Verifier.

9.5.3 Non-compliance during participation in Forevermark Activities

If the Forevermark Diamantaire and/or its Associated

Entities and/or Verified Intermediary does not meet

or maintain the requirements of this Standard during

participation in Forevermark Activities, the External

Auditor shall report these findings in writing, within

48 hours of completing the verification exercise, to:

a) Forevermark; and

b) the Forevermark Diamantaire or Verified Intermediary.

NOTE Further information can be found in the Diamond

Pipeline Integrity Guidance Notes, see 5.2.

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Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

DE BEERS BEST PRACTICE PRINCIPLES (BPPs)

This annex contains a brief overview of the principles

that are designed to provide a basis for checks that

best practice is observed in the gem diamond

industry. See also Clause 5.

NOTE Further information and BPP documents (such

as the BPP workbook) can be found on the De Beers

BPP SMART extranet.

A.1 CONSUMER CONFIDENCE

We are committed to operating our businesses with

a view to ensuring that consumers buying diamond

jewellery are able to rely with confidence on the

professional and responsible standards and technical

skills of the gem diamond industry, taking account of

the following:

a) natural diamonds are objects of prestige, a luxury

good, generally acquired for sentimental reasons and

are regarded as items of value by the consumer;

b) diamonds are a unique item about which the

consumer has limited expertise and consequently,

in order to make an informed choice, the consumer

is reliant on:

1) the standards and integrity of the diamond

industry; and

2) information from the diamond industry as to

cut, colour, clarity and carat weight and other

attributes, including the application of any

treatment1).

c) the highest professional and responsible standards

and technical skills are necessary to check that

consumer trust is not misplaced and that the

reputation of the gem diamond industry is maintained

and enhanced;

d) consumers expect to purchase diamonds in their

natural state, without any treatment, beyond the

accepted skills of craftsmanship associated with their

cutting and polishing and therefore the danger of non

disclosure of treatment of natural diamonds, and the

passing off of partly or wholly synthetic diamonds and

simulants as natural diamonds, is contrary to the

interests of consumers;

e) the injury and hardship suffered by local populations

(and the potential for it) when conflicts arise in

diamond producing areas are unacceptable, as is

seeking to profit from such conflicts.

A.2 BUSINESS PRACTICES

We are committed to operating our businesses in such

a way that we neither engage in, nor encourage in any

manner, the following practices which are regarded as

unacceptable and against the public interest and that of

the diamond industry:

a) buying and trading rough diamonds from areas where

this would encourage or support conflict and human

suffering;

b) the use of child labour;

c) practices which intentionally or recklessly endanger or

harm the health or welfare of individuals;

d) conduct which conflicts with the principles set out

in A.1, thereby bringing the diamond industry into

serious disrepute.

A.3 COMMITMENT

We are committed to the following:

a) action to address concerns arising out of the misuse

of rough diamonds in support of conflict and regular

discussions on other issues relevant to the gem

diamond industry to enable appropriate and timely

industry responses;

b) the provision of proper working conditions (including

the health, safety and well-being of workers);

c) the dignity of individuals and best practices and the

fair treatment of individuals;

d) full compliance with international best practice and

the related regulatory framework with respect to the

environment;

e) full disclosure at all levels of the diamond distribution

chain and, most importantly, to consumers, of all

treatments to natural diamonds and with respect

to wholly or partly synthetic stones and compliance

with the rules, regulations and guidelines published

from time to time by the diamond industry’s

governing bodies.

ANNEX A – DE BEERS BEST PRACTICE PRINCIPLES (BPPs)

1) “Treatment” means any process, treatment or enhancement changing, interfering with and/or contaminating the natural appearance or composition of diamonds. It includes colour (and decolourisation) treatment, fracture filling, laser and irradiation treatment and coating.

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Figure B.1 illustrates the Forevermark Icon which is

inscribed on Eligible Diamonds along with a serial

number that is unique to the diamond.

Figure B.1 –The Forevermark Icon and serial number

8189832

ANNEX B – THE FOREVERMARK ICON

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Forevermark Limited (Reg. no. 06501918), 17 Charterhouse Street, London EC1N 6RA, UK.

ANNEX C – FOREVERMARK DPIS: CHANGES IN THE 2015 EDITION

The following lists the key changes that have

been made between the previous version of

the Forevermark Diamond Pipeline Integrity

Specification, published in 2011, and the current

2015 edition.

Please note that minor editorial changes are not

listed.

GENERAL

• References to “the De Beers Group” are now

“The De Beers Group of Companies”.

• References to “BSI” are now “BSI Standards

Limited”.

• “Guarantee” has been replaced with “Promise”.

• The word “ensure” has been removed from

requirements in the Standard and replaced with

text that requires the DPIS user to make checks

and retain written records instead.

• A clear distinction has been drawn between

“Internal Assessors” undertaking Pipeline Integrity

Assessments and “External Auditors” undertaking

Pipeline Integrity Verification activities.

• Appropriate internal and external references have

been added throughout the text.

CLAUSE 1: INTRODUCTION

Sub-clause 1.3

• Text has been introduced to explain the role of the

Forevermark Diamond Institute.

• The final paragraph has been edited for

clarification.

Clause 2: Terms and Definitions

The following terms and definitions have been

modified:

• “Applicant” is now “Applicant Diamantaire”.

• “Consumer Guarantee” is now “Consumer Promise”.

• The definition for “Associated Entities” has been

edited for clarity.

• “Assessment Report” has been modified to,

“Internal Assessment Report”.

• “Assessor” has been removed as it is now covered

by “Internal Assessor” and “External Auditor”.

• “External Assessor” has been modified to “External

Auditor”.

• “Verifier” has been removed as it is now covered by

“External Auditor”.

• The definition for “Forevermark Diamantaire” has

now been edited for clarity.

• A note has been added to “Internal Assessor” for

clarification.

• “Pipeline Integrity Review” has been removed as it

is covered by “Pipeline Integrity Assessment”.

• The term “Responsible Processing” has been

added.

• “Pipeline” has been modified to “Diamond

Pipeline”.

• The term “External Audit Team” has been defined.

• The term “Internal Assessment Team” has been

defined.

• “Systems Operative” has been given a subclause

number.

• “The Icon” has been modified to the “Forevermark

Icon” and a definition added.

• The term “Treated Diamond” has been defined.

• The term “Spot Check” has been defined.

• The term “Forevermark Jeweller” has been defined

and incorporated into the text.

The text throughout the DPIS has been modified to

align with changes made to the terms and definitions

in Clause 2. The clause numbering in Clause 2 has

also been updated.

Clause 3: The Diamond Pipeline

• Non-Verified Intermediary has been added to

Figure 1.

• Responsible parties for the Pipeline Integrity

Assessment and Pipeline Integrity Verification have

been added to the right-hand side of Figure 1.

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Clause 5: Normative References

• References to specific Best Practice Principle

documents have been added for clarification.

• References to specific Forevermark documents

have been added for clarification.

• A weblink to further information regarding the

Kimberley Process has been added.

Clause 6: Forevermark Pipeline Integrity Requirements

• Hanging text under 6.1.3 has been reformatted as

commentary text.

• A new bullet point, 6.1.3.2c) has been inserted as

an alternative to 6.1.3.2b).

• The storage of records in 6.2e) 3) has been

reduced from 10 years to a minimum of 7 years.

Clause 7: Qualifications of Internal Assessors and External Auditors

• Subclause 7.1.1 has been renumbered as 7.2.

• Subclause 7.1.2 has been renumbered as 7.3.

• The date to the ISO 9001 reference (2000) has

been removed as it was out of date and the

example is intended to reference the latest version

of the standard.

Clause 8: Pipeline Integrity Assessment – Internal Assessors

• The term “robustness” in 8.2.4a) and 8.2.4b) has

been modified to “security”.

• Subclause 8.2.3c) has additional text to indicate

who is responsible for determining which methods

and techniques used to identify Eligible Diamonds

and Forevermark Diamonds are acceptable.

• Subclause 8.2.5.1a) has additional text to indicate

the party responsible for determining the correct

control procedures.

• Subclause 8.2.5.2a) has additional text to indicate

the party responsible for determining the correct

control procedures.

Clause 9: Pipeline Integrity Verification – External Auditors

• List item h) has been added to subclause 9.2.1.

ANNEX A – DE BEERS BEST PRACTICE PRINCIPLES (BPPS)

• The initial paragraph has been modified to indicate

that the annex is “a brief overview” of the BPPs,

and to clarify that it is not the BPPs in full.

• A note has been added to the end of the first

paragraph to indicate where the BPP documents

can be found.

ANNEX B – THE FOREVERMARK ICON

• Text was added to the initial paragraph to indicate

that the serial number is unique to the diamond.

• The title for Figure B.1 was modified to indicate

that the Forevermark Icon and the serial number

were both being shown.

• An example of a serial number, mirroring that

shown in the photograph on page 2 has been

added to Figure B.1.

BIBLIOGRAPHY

• A bibliography has been added to list relevant

standards and documents for the DPIS user and

other useful sources of information.

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BIBLIOGRAPHY

STANDARDS PUBLICATIONS

For dated references, only the edition cited applies.

For undated references, the latest edition of the

referenced document (including any amendments)

applies.

ISO 9001,2) Quality management systems –

Requirements

DE BEERS PUBLICATIONS

De Beers, The Best Practice Principles –

The Assurance Programme Requirements

De Beers, The Best Practice Principles –

The Disclosure Practice Notes

De Beers, The Best Practice Principles –

The Manual

De Beers, The Best Practice Principles –

The Workbook

De Beers, Standard Guidance on Undisclosed

Synthetics

FOREVERMARK PUBLICATIONS

Forevermark, Diamantaire Agreement and Entity

Schedule

Forevermark, Diamond Pipeline Integrity Guidance

Notes

Forevermark, Integrity Requirements

Forevermark, Management System for Forevermark:

The Pipeline Integrity Check List

Forevermark, Management System for Forevermark:

The Pipeline Integrity Check List Example

2) A revision of ISO 9001 is currently in development. At the time of publication this is scheduled to publish in late 2015.

OTHER SOURCES OF INFORMATION

Forevermark – http://www.forevermark.com

The Diamond Glossary –

http://www.debeersgroup.com/en/diamonds-

explained/glossary.html

The Kimberley Process –

http://www.kimberleyprocess.com

The World Diamond Council –

http://www.worlddiamondcouncil.com

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BSI, 389 Chiswick High Road London W4 4AL United Kingdom

www.bsigroup.com