Corporate Social Responsibility

Introduction

Houlden Jewellers Limited is a premium consortium of jewellers from across the UK and Ireland. We provide our strong community of elite, independent luxury jewellers with inspiration, advice, and support. This policy confirms our commitment to respect the fundamental rights and freedoms in accordance with The Human Rights Act 1998. Our support for these fundamental principles is reflected in our policies and practices regarding employees, suppliers, customers and the areas in which we operate.

Our Employees

We believe that our employees should be treated with respect and dignity and work in an environment that is free from harassment and unlawful discrimination. Our commitment to respect human rights is manifested in our Employee Handbook and HR Policies and procedures, specifically:

We will not employ workers under the legal minimum age for work as stipulated by the Employment Act 2008.
We will not make use of any forced labour or debt-bondage labour in accordance with the Modern Slavery Act 2015.
We will not discriminate against any person based on their protected characteristics and will uphold Article 14 of the Human Rights Act 1998 in respect of protection from discrimination.
Any disciplinary matter will be dealt with through formal procedures detailed in the Employee Handbook.
Working time directives will be adhered to as per the Working Time Regulations 1998 with opt-out clauses publicised to staff.
Wages paid for standard working hours will meet or exceed national minimum wage or living wage levels as appropriate.
All employees should be able to work in an environment that is free from discrimination, victimisation, harassment, bullying and that all employees should be treated fairly and with dignity.
There is a clear policy for dealing with grievances detailed in the Employee Handbook.

The Employee Handbook is periodically reviewed and amended where appropriate to ensure that it continues to reflect best practice and legal requirements. An external consultancy has been engaged to ensure the Company is updated as to any new legislation. Employees are expected to uphold these standards and are encouraged, via regular meetings, to raise issues and report suspected violations of applicable laws, regulations and policies.

Our Suppliers

We strive to promote adherence to Human Rights principles detailed above throughout our supply chain via our Supply Chain Policy. We see our relationships with our suppliers as an opportunity to share best practice and through open communication, to promote mutual, continual learning and improvement with respect to human rights.

Our Customers

We are continually working to build and maintain relationships with organisations that share our commitment to upholding and implementing the fundamental principles of Human Rights and strive to promote best practice within our sphere of influence. We openly welcome inspection and auditing processes to ensure we continue to develop a robust and transparent Human Rights Policy.

1.Houlden Jewellers Limited is a premium consortium of jewellers from across the UK and Ireland. We provide our strong community of elite, independent luxury jewellers with inspiration, advice, and support. This policy confirms Houlden Jeweller’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws. This is what we also expect to see being demonstrated from both our members and suppliers

2.As such, we commit to proving, through independent third-party verification, that we:

a. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;

b. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;

c. support transparency of government payments and rights-compatible security forces in the extractives industry;

d. do not provide direct or indirect support to illegal armed groups;

e. enable stakeholders to voice concerns about the jewellery supply chain; and

f. are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

3.We also commit to using our influence to prevent abuses by others. We carry out regular due diligence on our supply chain to ensure compliance with the Kimberley Process and WDC System of Warranties via Know Your Counterparty. Concerns regarding our supply chain can be raised by contacting helen.haddow@houldenjewellers.com

4.Regarding serious abuses associated with the extraction, transport or trade of diamonds: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

a. torture, cruel, inhuman and degrading treatment;

b. forced or compulsory labour;

c. the worst forms of child labour;

d. human rights violations and abuses; or

e. war crimes, violations of international humanitarian law, crimes against humanity or genocide.

5.We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.

6.Regarding direct or indirect support to non-state armed groups: We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally: a. control mine sites, transportation routes, points where diamonds is traded and upstream actors in the supply chain; or b. tax or extort money, or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders.

7.We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.

8.Regarding public or private security forces: We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4, or that act illegally as described in paragraph 6.

9.Regarding bribery and fraudulent misrepresentation of the origin of diamonds: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of diamonds, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of diamonds.

10.Regarding money laundering: We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of diamonds.

Objective

Operating responsibly builds consumer confidence in our product and business, supports our stakeholder relationships, and helps us to achieve our long- term development goals. It is our commitment to behave responsibly and contribute to economic development while improving the quality of life of the workforce and their families as well as of the local community and society at large.

Therefore, we have a commitment to maintaining the highest standards in the supply chain of the jewellery industry. We insist our business partners do the same. We aim to source products from suppliers who produce goods responsibly in a way that is considerate to people and planet .

We encourage the growth and adoption of responsible trading and sourcing in all aspects of our business.

Legal Compliance

We expect our business partners to comply with all current national laws and regulations. We conduct all our activities in strict compliance with the national laws of the countries where we operate and with all relevant international conventions where those are applicable in the country of operation. It is the responsibility of our directors, officers, and managers to know and keep abreast of changes to laws and regulations that affect our business.

Bribery and Facilitation

We are fully aware that corruption is a persistent problem in many countries. We do not tolerate bribery or facilitation payments of any kind. We routinely assess business activities which are most susceptible to corruption. We encourage and support our employees and business partners to report any incidence that might lead to or be perceived as corrupt. We respond appropriately any reported incident.

Money laundering

Money laundering is defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveller’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

We encourage our business partners to conduct thorough due diligence and follow the principles of “Know Your Counterparty” and maintain records of transactions to avoid working with organisations or individuals who are involved in the illicit movement of money. It is the policy of Houlden to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the UK Money Laundering Regulations 2017 and its implementing regulations.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable UK Money Laundering regulations will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

https://www.gov.uk/topic/business-tax/money-laundering-regulations

http://www.oecd.org/tax/automatic-exchange/common-reporting-standard/

People

Fair Labour Practices

We are committed to promoting a secure, safe, and healthy working environment, fair employment standards, based on merit and performance.

Health and Safety

We are committed to a safe and healthy workplace and incorporating health and safety into organisational culture for our employees by working to the highest international standards. We provide health and safety training programme for our employees and contractors on-site.

It is the duty of management to ensure all processes and operating systems have undergone health and safety risk assessments, are properly supervised at all times, and are designed and managed to enable employees to raise and to be consulted on issues of health and safety at any time. Houlden has two members of personnel trained in Adult First Aid.

It is the responsibility of all employees and contractors to co-operate to enable all statutory duties to be complied with and employees must ensure their own health and safety at work and the health and safety of anyone else who might be affected by their behaviour.

Non- Discrimination

We do not discriminate employees on the basis of race, caste, origin, religion, disability, gender, sexual orientation, marital status, union or political affiliation or age. We require our people to treat each other with dignity and respect.

Child and Forced Labour

We forbid child and forced labour.

Human Rights

Houlden is committed to ensure all human rights are upheld in line with the United Kingdom Equality and Human Rights Commission https://www.equalityhumanrights.com/en ; the Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights regarding all employees and any other people who interact with Houlden.

Houlden does not subject workers to inhumane or degrading treatment. We will not use any form of violence, sexual abuse, sexual harassment, corporal punishment, physical or verbal abuse towards employees.

We recognise and respect the rights of employees to freely associate, organize and bargain collectively in accordance with the Working, Jobs, and Pensions department guidelines. https://www.gov.uk/browse/working

Houlden complies with the UK government’s Working, Jobs and Pensions regarding minimum wages, standard working hours and employee benefits. Overtime is voluntary and compensated in full at rates in compliance with local law.

We have developed internal management systems to ensure respect for international standards of human rights. We ensure any incidents of non-compliance with international standards of human rights are investigated and addressed in an appropriate manner without compromising the confidentiality or placing at risk any individuals or groups involved. Employees found to be in breach of any of our policies could face disciplinary proceedings.

Grievance and Disciplinary Action

In the event of disciplinary action against an employee or a grievance raised by an employee, Houlden follows the Advisory, Conciliation and Arbitrations Service (ACAS) Code of Practice for Disciplinary and Grievance Procedures.

Anti-Slavery and Human Trafficking

We have a zero-tolerance approach to Human Trafficking and Acts of Slavery from occurring both within our business and our supply chains. We operate a strict procurement process and conduct due-diligence to ensure suppliers conform to all applicable laws and regulations, including those relating to the Modern Slavery Act 2015. Our recruitment and procurement procedures detail the steps we take to identify and mitigate the risks of slavery occurring in our business and supply chain.

We follow the Guidance issued on supply chains under section 54(9) of the Modern Slavery Act 2015

Environment

We encourage our suppliers to understand the challenges the industry faces and promote responsible environmental practices. Therefore, as a responsible member of the diamond and jewellery industry, we collaborate with our suppliers to ensure our consumers receive only the finest goods procured from sources that demonstrate a responsible approach in their operations, including environmental awareness.

We believe that a business should protect, and where possible, improve the environment, promote sustainable development, and prevent the wasteful use of natural resources.

We are committed to continual improvement of our environmental performance through prevention of pollution throughout our facilities. We recognise the imperative to manage the risks of our activities in relation to energy and waste management. We operate strict energy saving policy for all our electronic equipment and lighting, and a comprehensive recycling program

Supply chain

Conflict-Free Diamond Policy

Our Company has a zero-tolerance policy toward conflict diamonds. All suppliers must comply with the Kimberley Process (www.kimberleyprocess.com). We will not knowingly purchase or sell any products that originate from a group or a country which supports or engages in illegal, inhumane, or terrorist activities.

We expect our suppliers to regularly check for updates and alerts on: https://www.kimberleyprocess.com/en/enforcement

Our suppliers are required to warrant that they will take every possible measure to ensure they do not source diamonds that fund conflicts and to ensure that the aims and requirements of the Kimberley Process are achieved

Transparency and Product Disclosure

We practice complete honesty and transparency in our business and monitor CIBJO Diamond Commission and WDCs announcements about claims on synthetic-free diamonds.

Gold Sourcing

Responsible mining is important, and we aim to ensure that our gold and metals come from suppliers that meet human rights, social, and environmental best practice. We achieve this by using reputable and fully recognised responsible suppliers.

Gemstones

To the extent feasible under prevailing industry practices, suppliers shall ensure that gemstones are mined in a manner that respects human and labour rights, is conflict-free and does not inflict environmental damage. Suppliers shall respect applicable international sanctions related to the sourcing, trade, or sale of gemstones irrespective of where those stones have been cut and exported from.

Responsibility

The Chief Executive Officer has been designated as the director responsible for ensuring that the company adhere to our Responsible Trading policy, and reports to the Board on a regular basis.

Business Partners and Suppliers

We expect our business partners and suppliers to commit to upholding these principles in their own operations.