JOHN HARDY GROUP OF COMPANIES’ CODE OF CONDUCT
Our commitment: This Code of Conduct expresses our commitment to ethical and responsible practices in all aspects of our business operations. We conduct our business with respect for human rights and for the environment. We require that all our business partners, companies and persons which we are doing business with follow the same standards.
Our business partners: All of our business partners will adhere to the same commitments as we do and apply the standards stated in our Code of Conduct (in addition to complying with laws, regulations and practices applicable in their country). These requirements and those further stated in our Code of Conduct bind our partners and constitute a condition of conducting business with John Hardy. It is the responsibility of our business partners to communicate and explain these standards to their employees and to ensure that all subcontractors involved in the production and distribution of our products approve our Code of Conduct in writing and comply with the principles stated therein. In order to ensure that they comply with our Code of Conduct, our business partners must authorise us and our designated agents to inspect their premises. Any partner who is found to not to adhere and implement our Code of Conduct will be in breach of their commitments. We may therefore, at our sole discretion and without any compensation, immediately cancel any existing orders and terminate all existing agreements with such a partner.
Our Code of Conduct Standards:
Standard 1: Compliance with Laws and Regulations We are committed to complying to all applicable laws and regulations, including local and national codes, rules and regulations, applicable treaties and industry standards.
Standard 2: Child Labour We are committed to preventing the employment of children. We adhere to the United Nations’ and the International Labour Organisation’s Conventions and Recommendations. We recognize in particular the right of children to be protected from economic exploitation and from performing work that is likely to be hazardous or to interfere with their education, or to be harmful to their health or physical, mental, spiritual, moral or social development. We will only employ young persons (below the age of 18 and older than 15 years) in specific circumstances (such as internship or vocational training) and in accordance with the International Labour Organisation Convention on Minimum Age of 1973 (ILO Convention No. 138). We are committed to verifying the age of potential employees prior to recruitment and, where young persons are employed, we ensure that they do not work overtime and receive fair payment for work accomplished, at least twelve hours of nightly rest time, and a minimum of two weekly rest days.
Standard 3: Forced Labour We do not allow the use of forced or involuntary labour and prohibit the restriction of employees’ freedom of movement. ￼All employees are treated with dignity and respect. Corporal punishment, threats of violence or other forms of physical, sexual, psychological or verbal harassment are prohibited. Grievance procedures and investigation processes are clearly explained to all employees.
Standard 4: Safety and Health We are committed to maintaining a workplace environment that complies with all applicable laws and industry standards so as to ensure a safe working environment. We are committed to providing our employees with the best possible human health and safety working conditions. We also ensure adequate and appropriate safety arrangements and hygienic conditions in the workplace. Our employees receive appropriate training on safety and health measures to adopt and we maintain appropriate procedures, including the installation of alarms and the establishment of emergency procedures and evacuation plans, to prevent accidents and provide access to on-site health and medical facilities. Any serious incidents will be formally investigated and documented.
Standard 5: Gender and Racial Equality We are committed to respecting and promoting the importance of gender and racial equality. We acknowledge the equality of all genders and races, in particular the rights of men and women of all races to equal pay for equal work, equal employment opportunities, equal working conditions (including wage conditions) and equal professional development within the trade (including opportunities for promotion). We are committed to protecting our employees from any kind of discrimination in our hiring and employment practices.
Standard 6: Working and Wage Conditions Our employees will receive wages in compensation for services rendered or to be rendered. Such wage payments will be made on a regular and pre-determined basis by bank transfer or in cash or cheque form in a manner and location convenient to the employees. Wages shall reward for overtime hours at premium rates, maximum hours, piece rates and by other elements of compensation. Wages will not, as a minimum standard, be lesser than those specified by national laws or current industry standards, should the latter provide better conditions for our employees. Wages will cover a decent living. As part of our employees’ fundamental rights, our conditions for work and wage include appropriate and legal daily and weekly working hours, as well as a legal number of paid annual holiday leave and weekly rest days. Weekly working hours shall not exceed eight in the day and forty-eight in the week, except where stated by the International Labour Organisation convention No. 1.
Standard 7: Workers’ Right to Information and Consultation We ensure that our employees or their representatives are, at the appropriate levels, guaranteed information and consultation in good time in the circumstances and under the conditions provided for by current domestic laws and practices. Our employees or their representatives will have the opportunity to be regularly and fully informed of the financial prospects of their employer. Where our employees’ interests would significantly be affected, including general terms of employment, information shall be given and consultative bodies established as ￼early as possible to ensure that proposals and viewpoints of our employees contribute to the management’s decision making process. We are committed to providing our employees with the opportunity to participate in relevant training programs to help them undertake their respective functions.
Standard 8: Right to Collective Bargaining We recognize our employees’ right to associate, organise and bargain collectively in a lawful and peaceful manner for the protection of their interests without penalty or interference (as stated in article 23 of The Universal Declaration of Human Rights and in International Labour Organisation Conventions No. 87 and No. 98). We do not prevent collective bargaining and will adhere to collective bargaining agreements, where such agreements exist.
Standard 9: Environmental Compliance We are committed to complying with all applicable environmental laws and regulations and to introducing management and operating systems that minimize our impact on the environment. We are committed to disposing of waste substances in compliance with applicable laws and to taking steps to reduce the quantity of waste/emissions produced and energy/natural resources used. Additionally, we ensure the efficiency of our business operations in terms of consumption of natural resources, including, but not limited to, water and energy. We do not manufacture, trade and/or use chemicals and hazardous substances, unless where technics do not permit to do otherwise (in which circumstances legal requirements will be complied with).
Standard 10: Bribery and Facilitation Payment. We are committed to acting against any form of bribery. We consider bribery a risk and have appropriate methods of monitoring such risk. We facilitate the reporting of potential bribery, apply sanctions for bribery/attempted bribery and implement appropriate controls to oversee all payment facilitation. There will be no adverse inference, under any circumstance, for voicing a concern or declining to pay a bribe.
Standard 11: Money Laundering and the Finance of Terrorism We are committed to acting against money laundering and the finance of terrorism, maintaining an anti-money laundering policy, auditing financial accounts and acknowledging the identity of all persons and organisations we deal with. We acknowledge that any transaction that is of international scope may be subject to more than one regulation.
Standard 12: Diamonds and Stones We adhere to a voluntary program of self-regulation in the diamond and gemstone trade industry. We do not knowingly buy or sell conflict diamonds, according to the Kimberley Process1. We adhere to and will keep records of audited and reconciled Kimberley Process Certificates. We adhere to the World Diamond Council Resolution on Industry Self-Regulation, keep records of all invoices (which shall contain the World Diamond Council warranty statement2) and have a system to prevent the purchase or sale of illegal diamonds. Employees are informed of the restrictions on the buying or selling of diamonds. 1 The Kimberley Process is a joint government, international diamond industry and civil society initiative to stem the flow of conflict diamonds. For the Kimberley Process purpose, “conflict diamond” refers to a rough diamond used by rebel movements to finance wars against legitimate governments. 2 ‘The diamonds herein invoiced have been purchased from legitimate sources not involved in the funding of conflict and in conformance with United Nations resolutions. The seller hereby guarantees that these diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds’.
Standard 13: Conflict Minerals We are committed to acting against Conflict Minerals sourcing and assure that our Gold material providing from our business partners does not directly or indirectly finances or benefits armed groups causing serious human rights abuses. Our business partners must, to the best reasonable extent, ensure ethical sourcing, complete their due diligence on the source and chain of the custody of Gold, and make this due diligence available upon request.
Standard 14: Product Security We maintain product security procedures within the premises and during shipments. Armed security personnel will not be used, unless it is strictly necessary to do so. We always prioritize the security of employees, visitors and other relevant business partners.
Standard 15: Product Integrity We comply with all relevant and applicable trading standard legislations. We disclose all product physical characteristics accurately and do not make any untruthful statements, representations or material omissions. We disclose the fineness of the gold we use, apply authorized gold quality marks and properly disclose the description of diamonds and the quality of precious and semi- precious stones, which includes the proper disclosure of treated diamonds, laboratory created diamonds and simulants.
3 As defined in 2010 United States legislation, Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502(e)(4): CONFLICT MINERAL - The term ‘‘conflict mineral’’ means: 1 - columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives Or: 2 - any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country. (Available at http://www.sec.gov/about/laws/wallstreetreform-cpa.pdf).
We will continuously update our Code of Conduct and our business partners must accept these updates unless such amendments have a substantial effect on them. Kareem Gahed – CEO
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