Assurance status on Tracr

Diamonds registered by Participants on the Tracr platform may be classified as “Assured’ or, once the Assured Criteria (as defined below) have been fulfilled and the diamond has been graded and inscribed, it can be referred to and labelled as “Assured and Certified”. The applicable categorisation of a diamond is based on the level of checks and processes that the diamonds and/or the Participant submitting the diamond have undergone, as further outlined below.

Please note that Tracr does not guarantee the integrity of the information provided on the Tracr platform- the responsibility for this sits with the Participant submitting the information.

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Assured Criteria

In order for a diamond to be classified as “Assured” on Tracr the following minimum requirements and criteria as set out below must be met at each stage (the “Assured Criteria”):
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At Production:

1. The provenance of the diamond has been recorded at source during production by the Diamond Trading Company, see https://www.dtc.com/ (DTC). This means that:

• The diamonds have been recovered from Botswana, Canada, Namibia or South Africa and sourced in alignment with the Organisation of Economic Cooperation and Development’s (OECD) Due Diligence Guidance and are fully compliant with the Kimberley Process.
• All mines comply with the rigorous standards of the De Beers Best Practice Principles (BPPs) Assurance Programme, available at www.debeersgroup.com/sustainability-and-ethics/leading-ethical-practices-across-the-industry/best-practice-principles-assurance-programme, which covers business, human rights, social, environmental, and mining risks.
• All mines are subject to a self-assessment annually against the requirements and host regular audits by third-party verifiers.

2. As a minimum, the relevant Authorised Producer has provided Tracr with an auditable record of the lot numbers and lot weights for the diamonds registered on Tracr as well as the name of the recipient of each lot for traceability purposes.

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_{1 A “Participant” means any entity that has been approved by Tracr as a participant on the platform, has passed Tracr’s Know Your Customer (KYC) checks and has entered into the Participant Terms and Conditions with Tracr.
2 An “Authorised Producer” means the entity which mines the diamonds and is a Participant.}

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At Manufacture

1. The diamond has been manufactured by an approved Manufacturer on Tracr, which:

• is a member of the Responsible Jewellery Council;
• has committed to enforcing sustainable ethical, social, human rights and environmental practices;
• is compliant with the BPPs and registered on the BPP Assurance Programme; and or is a member of the RJC (Responsible Jewellery Council) and
• is part of the De Beers pipeline integrity programme (Pipeline Integrity) and is subject to regular Pipeline Integrity checks, including periodic third-party audits to ensure integrity of the supply chain.

2. Tracr has carried out spot checks on the data uploaded by Manufacturers to reconcile against the relevant lot information provided by DTC to within a tolerance of 0.1%+- by carat weight for aggregate box weight.
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Assured at Wholesale and/or Retail

Provided the above criteria have all been met, a diamond will be able to be referred to as “Assured” at wholesale and/or retail if:

1. The diamond has been verified as natural and inscribed by an Approved Laboratory.
2. The inscription number and (optionally) grading information has been recorded on Tracr by the Participant themselves and/or by the Approved Laboratory, as described below.
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Approved Laboratory checks

If the inscription for the diamond is provided directly to Tracr by the Approved Laboratory (rather than being declared on Tracr by the Participant), Tracr will check and confirm that the Approved Laboratory is providing information for the correct diamond by comparing six values: weight, total depth, crown angle, pavilion angle, table size average and girdle average, and will check that the relevant values for each diamond are within Tracr’s acceptable tolerance data points, as may be updated by Tracr from time to time.

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<sub>3. A “Manufacturer” means the entity which manufacturers the diamond and is a Participant.
4. An “Approved Laboratory” means a laboratory that has been approved by Tracr, has signed up to terms with Tracr and is engaged by a Participant to determine the value of the diamond and provide inscription services.</sub>

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Assured and Certified

As detailed above under the ‘Wholesale and/or Retail’ section, once a diamond fulfils the Assured Criteria at each of the relevant stages and has been graded by an Approved Laboratory and marked with an inscription, it can be referred to and labelled as “Assured and Certified”. The “Assured and Certified” status is achieved on the Tracr platform when the grading certificate is uploaded together with the diamond’s inscription number, and provided that the Participant has provided all the necessary information.  

Provided all the Assured Criteria have been met in the diamond’s journey up to inscription, once a diamond has been inscribed, it will maintain its “Assured” status. The inscription provides the ability to track back to the diamond’s original provenance, even if, following the inscription, there is a break in the chain of custody as registered on Tracr. The chain of custody refers to an unbroken and documented chain of legal ownership of a diamond, recorded on the Tracr platform. When all changes in legal ownership have been recorded on Tracr by the legal owners of the diamond, then there is no break in the chain of custody. Conversely, if there is a break in the chain of custody as registered on Tracr prior to inscription, the diamond will no longer have “Assured” status and the full transfer and status of legal ownership will not be reflected on the Tracr platform. In this case, the last transfer registered on the Tracr platform will be reflected. If there is a break in the chain of custody on the Tracr platform at any point before the diamond is inscribed by an Approved Laboratory, the Tracr platform will no longer be able to provide up to date details of the provenance of the diamond and any further reference to Tracr or to the diamond being “Assured” is not permitted going forward in relation to such diamond.

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⁵ Tolerance Table: