To meet our responsibility to respect human rights and not to contribute to potential conflicts in the countries of origin of our products, we commit to the following policy for the responsible sourcing of high-valued gemstones. We commit to refraining from any action which contributes to the financing of conflict, and we commit to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

1. We will neither tolerate nor by any means contribute to or facilitate one of the following acts performed by any party:
   • Any forms of torture, cruel, inhuman, and degrading treatment,
   • Any forms of forced or compulsory labour,
   • Worst forms of child labour,
   • Gross Human Rights violations or abuses,
   • War crimes or other serious violations of international humanitarian law or crimes against humanity on genocide
2. We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from or linked to any party committing serious abuses as defined in paragraph 1.
3. We will not tolerate any direct or indirect support to non-state armed groups. This includes making payments as well as providing logistical assistance or supply of equipment to non-state armed groups or their affiliates who:
   • Illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain,
   • Illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded,
   • Illegally tax or extort intermediaries, export companies or international traders.
4. We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined in paragraph 3.
5. We agree to eliminate direct or indirect support to public or private security forces who illegally control mine sites.
6. We recognize that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law.
7. We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport, and export.
8. We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport, or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.
9. The supplier data collection and Risk assessment is reviewed at least on an annual basis.

Source:          OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas © OECD 2016

Updated:        13.01.2023

Reviewed:      12.01.2024