Supplier Code of Conduct

Supplier Code of Conduct

A commitment and consistent desire to be considered amongst the world's best means we demand the same standards of our suppliers.

Opening statement

We have an unwavering desire to be considered amongst the world's best in all that we do and as part of this we must enforce the same high standards on each of the suppliers that work with us.

Management systems and compliance:

As part of complying with this Code of Conduct suppliers agree to adopt a management system which ensures the code is adhered to and provides sufficient supply chain visibility.

Introduction

This Supplier Code of Conduct (hereinafter the “Code”)has been created to ensure that Blackacre (hereinafter the “company”) suppliers enforce safe working conditions, that their workers are treated with respect and dignity, and that their manufacturing processes are environmentally responsible.

This Code, is an expression of the Company’s principles and values, and requires strict compliance from all its suppliers, subcontractors and sub-suppliers (hereinafter jointly, the “Suppliers” and individually, the “Supplier”). For these reasons, the Company thus intends its Suppliers to act according to the same principles, respecting and enforcing them, and adhering to the same philosophy in the management of their own businesses.

It is understood that this Code requires, in every case, compliance with national laws and international agreements, other applicable laws and the principles stated in the Conventions of the International Labour Organisation, the Universal Declaration of Human Rights, the OECD Guiding Principles and the principles of the Global Compact; in case of conflict between the various provisions, the one with the highest standards shall prevail.

The provisos of this Code are not intended to conflict with the terms and conditions of contracts made between Suppliers and the Company. In the event that any contractual requirement is more restrictive than the requirement described in this Code, the more restrictive requirement shall apply.

Any breach by our Suppliers of this Code and/or of the standards in force at national and international level shall potentially result in the early termination of their relationship with the Company.

1. WORK AND HUMAN RIGHTS

The Company promotes the principle of work as a free choice by an individual.

Our Suppliers are required to comply with the labour laws and the regulations in force in their respective countries and, in particular, with the following provisos considered by the Company to be of fundamental importance. Our suppliers are required to respect human rights, including workers’ rights, in their businesses and transactions, recognising without distinction the freedom and equality in dignity and rights of all human beings, as enshrined in the International Bill of Rights and the fundamental Conventions of the International Labour Organisation (ILO). The Company encourages recipients to adopt and promote internal mechanisms and tools to ensure that their employees are able to report actual or suspected human rights violations.

1.1. Forced labour

Our Suppliers shall condemn and refrain from all forms and types of forced, compulsory, and exploitative labour, including labour without a work permit, and labour under threat and/or punishment.

Our Suppliers are required to comply with applicable legislation to punish illegal, clandestine and undeclared work.

1.2. Child labour

Our Suppliers are required to condemn and refrain from any form of child labour, in line with applicable legislation, relevant ILO Conventions and the International Convention on the Rights of the Child.

No child may work for and/or on behalf of our Suppliers unless he or she has completed the period of compulsory education and has reached the age of 16, subject to any relevant exceptions provided under applicable laws and regulations. Children under the age of 18 should not work at night or be exposed to dangerous activities.

1.3. Harassment and abuse

Our Suppliers shall treat their employees with respect and dignity, with no tolerance for any kind of corporal punishment, psychological or physical harassment or any other kind of abuse.

1.4. Salaries and benefits

Our Suppliers are required to remunerate their employees and collaborators in accordance with applicable legal and regulatory provisos in addition to any collective agreements adopted. Pay provided to employees must be appropriate to ensure that basic needs are met and that living standards respect the dignity of the individual.

Our Suppliers are required to grant all employees the benefits provided for in collective bargaining, company agreements and any other applicable individual or collective agreements.

1.5. Discrimination

Our Suppliers shall refrain from any form of discrimination against their employees and staff.

Our Suppliers shall ensure that there is no discrimination in hiring, access to training, promotion, or termination on the basis of sex, race, religion, age, disability, sexual orientation, political opinion, nationality, or social and ethnic origin.

1.6. Freedom of association

Our Suppliers shall respect and recognise the right of each employee to bargain collectively in order to create or join a trade union of their choice without incurring any sanctions, discrimination or harassment.

1.7. Working hours

With regard to working hours, our Suppliers shall comply with the limits set by the laws of the country of production and shall not impose excessive overtime. There shall be at least one day of rest every seven days or, in any case, the maximum established by the laws in force in the country.

1.8. Health and safety

Our Suppliers are required to provide their workers with a safe and healthy working environment to avoid accidents or injuries, including those related to working with machinery.

Our Suppliers shall have systems in place to detect, avoid or eliminate any threat to the health and safety of their employees, in accordance with local and international regulations and laws currently in force.

2. BUSINESS ETHICS AND INTEGRITY

The Company promotes and respects the principles of legality, loyalty and fairness.

Our Suppliers are required to comply with these principles and to operate with the utmost transparency in compliance with the legal and regulatory provisos applicable in the context in which they operate, in addition to any commitments they have undertaken with the Company.

The Company encourages recipients to adopt policies and implement procedures to ensure compliance with applicable laws and regulations in order to protect the integrity of the organisation and its operations.

2.1. Competition based on merit and fair competition

Our Suppliers must compete solely on the basis of their own merit and the quality of their products and services.

Our Suppliers shall not pay bribes or unlawful inducements – of whatever nature and whatever the amount – to anyone, in any place and under any circumstances, for any purpose, either on behalf of the Company or on their own behalf or on behalf of third parties.

Under no circumstances must our Suppliers engage in anti-competitive behaviour, either on behalf of the Company or on their own behalf or on behalf of third parties.

2.2. Conflicts of interest

Our Suppliers shall avoid any real or apparent conflicts of interest in relation to any business with the Company.

The Supplier shall report to the Company all the instances of actual or apparent conflict that may interfere inappropriately between its own interests and those of the Company.

2.3. Combating money-laundering

Our Suppliers shall avoid business or financial relationships where there is reasonable suspicion that their counterparts may engage in money laundering.

Our Suppliers are invited to take measures to regulate the management of financial flows, prohibiting any irregularities that, according to normal professional diligence, give rise to suspicions as to the origin of the funds received.

2.4. Relationships with Public Administration

Our Suppliers may not offer, directly or through an intermediary, money or any other inducement of any kind whatsoever to a public official or a public service appointee, his/her family or any other person connected with him/her. Similarly, they will not seek to establish favourable personal relationships with the aim of directly or indirectly influencing their business.

2.5. Transparency of information

Our Suppliers are required to provide clear and accurate information about their methods and resources, their production sites and the features of the products or services they provide, and to refrain from any misleading statements.

2.6. Confidentiality and intellectual property

Our Suppliers must comply with applicable laws and regulations on the protection of personal data.

Any information – designs, documents, samples, prototypes, etc. – brought to the knowledge of the Supplier in the course of the performance of contractual obligations shall be considered confidential and treated as such.

Unless used in accordance with the instructions received from the Company, all trademarks and signs belonging to the Company, whether registered or used by it at any time, shall not be used for any other purpose. Unless expressly authorised, a Supplier may not use the name and trademarks of the Company by reference to its own trading concern.

3. RESPECT FOR AND ENHANCEMENT OF LOCAL COMMUNITIES

The Company promotes and implements actions to support, sustain and develop the local communities in which it operates, also through voluntary and educational activities, financial and material donations and other specific projects.

The Company encourages Suppliers to adopt policies of care and respect for the communities in which they operate, both through actions to reduce negative outcomes and through actions and projects to generate and distribute value.

3.1. Tradition, culture
Our Suppliers respect the culture and the traditions of the communities affected by their businesses and/or transactions, minimising any inconvenience caused to local communities and favouring pathways for sharing and cooperation.

3.2. Cooperating with stakeholders
Our Suppliers shall be committed to creating local employment and working with communities, individuals and collective stakeholders, institutions and governments to improve the social, cultural and educational well-being of the communities in which they operate.

3.3. Supporting the local productive and economic fabric
Our Suppliers shall support, as far as possible, the local production and the economic fabric, including through the use of local staff and suppliers, in order to contribute to the economic and social development of communities and populations.

4. RESPECT FOR AND PROTECTION OF NATURAL ECOSYSTEMS

The Company pays the utmost attention to environmental sustainability, making a strong commitment to eliminating carbon dioxide and greenhouse gas emissions into the atmosphere and reducing the use of disposable plastic products.

Our Suppliers are encouraged to monitor and work towards the containment or reduction of emissions related to their businesses. In addition, Suppliers are encouraged to implement processes to reduce or eliminate the use of single-use plastics within their business premises.

4.1. Protecting the environment and respecting animals

The Company actively promotes respect for the environment for the benefit of today’s and tomorrow’s generations, with a view to a sustainable future.

Our Suppliers are required to comply with the laws and regulations applicable to their sector of business, and to endeavour, wherever possible, to adopt virtuous behaviour to reduce or eliminate negative environmental outcomes related to their businesses. If the business involves animals, the Suppliers undertake to provide them with sufficient space, adequate nourishment and the necessary care based on experience and scientific knowledge. If animals are slaughtered, they must not suffer.

4.2. Waste management

Our Suppliers must follow the laws and regulations in force regarding the management of waste, both hazardous and non-hazardous, and ensure its proper treatment, storage, transfer and disposal. Our Suppliers are encouraged to take measures to enhance waste sorting processes, including through active recycling and reuse policies and the replacement of plastic packaging with more sustainable solutions.

4.3. Management of energy sources, emissions and water consumption

Our Suppliers shall monitor the consumption of water and energy resources, seeking, where possible, solutions that enhance the role of sources with low environmental impact. Our Suppliers shall be committed to reducing their relevant consumption, improving the efficiency of their production tools and the sustainability of their ordinary and extraordinary operations. As far as greenhouse gas emissions are concerned, our suppliers shall support awareness on this topic by evaluating policies for monitoring or offsetting emissions.

4.2. Natural materials & Conflict minerals

Our suppliers confirm that any precious metals, stones or materials used in the creation of our products have not been used to fund, or obtained as a result of conflicts, have not been sourced with child labour and that the provision of such goods are compliant with all laws and legislations of each country through which the goods have travelled.

Our suppliers will take all steps possible to ensure our creations comply with the highest possible ethical standards. All suppliers must provide confirmation that precious materials (gemstones, diamonds, and metals) are conflict free.

All suppliers must complete the following tasks:

1) Provide a written statement on invoice confirming that stones bought have been “purchased from legitimate sources and not involved in funding conflict in compliance with United nations resolutions”.

2) Suppliers must obtain verbal and/or written statements from their supplies that these diamonds in rough or polished forms are conflict free. On this basis the supplier confirms that precious materials supplied are conflict free.

3) Suppliers must obtain verbal or written confirmation from their suppliers that diamonds supplied have not been not been obtained in violation of applicable national laws and/or sanctions and have not originated from Marange, Zimbabwe.

4) Where purchasing goods in rough unpolished form suppliers should request proof of Kimberley Certificates (post 2003) evidencing that the stones exported from the country of origin are free from conflict.

5) Suppliers should make themselves familiar with the WDC SOW conditions and ensure they are adhered to.

5. PRODUCT LIABILITY

The Company shall provide its customers with quality products, guaranteeing maximum attention to the safety of the materials used in the production process. All products should be extensively quality control checked to ensure they meet the highest standards

Our Suppliers are encouraged to look for the best possible solutions to provide their customers with safe and high quality products and materials.

5.1. Quality and sustainable product development

Our Suppliers shall pay the utmost attention to the quality and safety of all materials used, both at the procurement stage and in production, encouraging the use of recyclable, renewable, reusable and locally sourced materials.

5.2. Chemical safety of products

Our Suppliers shall comply with the provisions of law concerning the use of hazardous or noxious substances and refrain from marketing materials and/or products that potentially endanger the health of consumers and workers. The Supplier shall ensure adequate training and safety equipment for employees who may come into contact with such substances throughout the production chain.

5.3. Traceability of materials and products

Our Suppliers shall guarantee the traceability of products and communicate information about the places of procurement and processing of the materials used, upon request.

5.4 Recycled metals

Our suppliers should use recycled precious metals in all creations unless expressly stated otherwise. A recycled metal is considered to be one that has been used in the creation of a piece that has been used in a different form previously. Any deviation from this should be communicated to the company in writing prior to the commencement of any new commission. All recycled metals should be obtained from ethical sources that have been independently vetted and verified by the supplier as recycled goods.

5.5 Precious stones and diamonds

Our suppliers should ensure that any diamonds or precious stones used in our creations are from the most ethical sources. Suppliers should independently vet and verify their own suppliers to ensure that any material used in our creations has been sourced fairly, legally and in compliance with all legislation of relevant countries from its very origination.

Under no circumstances should materials that do not comply with our standards be used in any creation. This includes but is not limited to; stones that have been used to fund conflict, materials sourced through child labour or materials arising as a result of other illegal activities such as money laundering.

Refer also to paragraph 4.2 for details on the steps required with regards to ensuring conflict minerals are not obtained.

6. COMPLIANCE WITH THIS CODE OF CONDUCT AND FORM OF DISSEMINATION

The Supplier shall cooperate with the Company and its representatives in monitoring and assessing its compliance with the expectations set out in this Code when performing work for the Company. It shall also be required to provide the Company, upon specific request, with additional information and certification attesting to compliance with this Code.

In the event of any wrongdoing, the Supplier shall cooperate fully with the relevant investigation conducted by the Company. The Supplier and its business partners shall be required to remedy any non-compliance identified during assessment.

The Supplier acknowledges and agrees that it is solely responsible for full compliance with this Code by its directors, officers, employees, representatives and business partners.

The Company undertakes to promptly notify the Supplier of any changes to the Code and to make it available on its website at all times.