[De Beers has] a mandatory, third party assured, code of ethical business conduct – the Best Practice Principles Assurance Programme...[and works] with sectoral initiatives such as the Responsible Jewellery Council, and comply with and promote the Kimberley Process and the Extractive Industries Transparency Initiative protocols...While accepting that the KP faces significant challenges, De Beers remains deeply committed to the initiative and its positive development...[De Beers' business model is also committed to]...ensuring the health, safety and wellbeing of our employees through effective safety management systems, respecting their right to associate freely and bargain collectively, and meeting or exceeding all relevant global labour standards...and engaging proactively with priority concerns such as HIV/Aids, Black Economic Empowerment (BEE), and gender equity...While De Beers continues to have good relationships with local communities, there is not sufficient continuity between operations in terms of how...community relations functions are organised.