Applicability of the Policies

This Policy is applicable to Marsala Manufacturing LLC (DBA Marsala Manufacturing Company and Trading Corporation of America) with effect from 2nd December 2020. Material under the scope of this policy is Diamond/Gold/Silver/Colored Gemstones and Platinum group metals. We request all business partners and employees of Marsala Manufacturing LLC to strictly adhere to the policies.

Policy – Supply Chain

Marsala Manufacturing LLC’s commitment and its expectations for its product suppliers regarding actions to address Conflict Minerals and compliance with procurement from conflict-affected and High-Risk Areas (CAHRA’s).

Marsala Manufacturing LLC believes its’ suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us contain conflict-free minerals and metals.

We being a responsible company, Marsala Manufacturing LLC supports the goal of the Dodd-Frank Act of preventing armed groups in the Democratic Republic of the Congo and adjoining countries from benefitting from the sourcing of Conflict Minerals from that region.

Marsala Manufacturing LLC is committed to working with its suppliers to educate them on these matters and concerning steps they can take to obtain increased transparency regarding the origin of minerals/metals contained in the products they manufacture and sell to Marsala Manufacturing LLC.

Marsala Manufacturing LLC reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this Policy and seize the business relationship upon violation of OECD requirements.

Marsala Manufacturing LLC reserves the right to request additional documentation from its suppliers regarding the origin of any Conflict Minerals included in any products sold to Marsala Manufacturing LLC.

Suppliers who do not reasonably comply with this Policy shall be reviewed by Marsala Manufacturing LLC for future business.

Policy – Sourcing

Marsala Manufacturing LLC is committed to ensuring that our supply chain is free of any metal/minerals which are procured for the support or benefit of armed and anti-social conflict groups or involving serious abuses of human rights and non-compliant with OECD Guidelines.

Marsala Manufacturing LLC clearly criticizes such activity and will reject any material which we believe was obtained involving serious human rights violations or which benefitted or supported armed rebels or terrorist groups through illegal finance or other activities.  This is in accordance with U.N. resolutions and Section 1502 of the Dodd-Frank Act.

The Company shall carry out due diligence to assess risks related to procurement from the Conflict-affected and high-risk areas – CAHRAs and shall always source from OECD/RJC compliant miners/refiners/traders.

We shall always set reasonable efforts to source Conflict-Free Minerals from smelters and refiners validated as being DRC Conflict Free and require their direct and indirect suppliers to do the same.

We strive to work supportively with our customers and supply chain partners in implementing conflict minerals compliance programs.

Policy – Due Diligence and Risk Assessment  

The company shall always undertake to ensure that the extraction and trade of mineral ores containing tin, tantalum, tungsten, silver, diamond, and gold support peace and development, not conflict.

Marsala Manufacturing LLC remains committed to enhancing its Supply Chain Due Diligence program through internal review and external assessments. We have a zero-tolerance policy for the supplier violating OECD due diligence guidelines and we shall immediately stop commercial relationships if any of our business associates are found non-compliant or High-Risk during our internal/external risk assessment.

Currently, Marsala Manufacturing LLC procures its precious metals from RJC CoP compliant miners/refiners/traders. However, we have established a strong due diligence process and we shall review it when we observed significant risk or upon receipt of any grievance or complaint but in the normal course, we shall carry our due diligence process on annual basis.

Grievance Mechanism

Our employees, suppliers, and other parties can report concerns and alleged violations of supply chain/sourcing/due diligence policy as follows:


Reports can be made anonymously and will be kept confidential to the fullest extent practicable and allowed by law.

We will not take any retaliatory action against our employees, suppliers, or other parties who make a report in good faith.

Our suppliers are encouraged to contact if they wish to seek guidance on the application of this Policy.

Date: 02/12/2020 (Version 2)

Place: USA

Due Diligence Supplier Risk Assessment

Marsala Manufacturing LLC has done the due diligence and risk assessment of all its suppliers and found “low” risk for the violation of OECD compliance requirements. All our suppliers are found complaint with the requirement. Details risk assessment and due diligence reports of each supplier are with the compliance team of Marsala Manufacturing LLC, and it is strictly confidential.