Responsible Trading Policy
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.
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 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.
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.
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.
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
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
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.
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.
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.
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.