Supplier Code of Conduct
Loren Stewart values its relationship with its suppliers and always aims to do business in an ethical and professional manner. Trust, transparency and ethical business practices are very important to Loren Stewart, and we ask that our Suppliers and Manufacturers commit to the following requirements detailed in this Code of Conduct. We believe in continual improvement, and we are committed to working collaboratively with suppliers who demonstrate improved performance over time.
Loren Stewart expects all suppliers to comply with all relevant labor, supply chain, environmental and human rights laws and labor rights, anti-corruption, anti-money laundering, environmental mangement, no forced labor, no-child labor, workplace health & safety. Loren Stewart expects that all suppliers comply with any federal, state or international laws or regulations applicable to your business.
CHILD & FORCED LABOUR
Suppliers will adopt a zero-tolerance for any kind of child or forced labour. Suppliers shall not employ anyone (either directly or indirectly) under the age of 15 and shall not employ anyone under the age of 18 engaged in hazardous work as defined by applicable conventions of the International Labour Organization (ILO). Suppliers shall not engage in any form of forced labour including bonded labour, deceptive recruitment, human trafficking and indentured or involuntary prison labour.
WORKING HOURS & REMUNERATION
Suppliers will not require employees to work hours that exceed 48 hours per week for a normal working week or 60 hours per week for a normal working week plus overtime. Overtime hours shall be voluntary for all employees.
Suppliers will ensure that all employees get paid the legal minimum wage and comply with the law regarding payment of overtime and other legally mandated benefits.
HARASSMENT & DISCRIMINATION
Suppliers will adopt a zero-tolerance policy to all forms of harassment or in the workplace and they will not discriminate against employees for any reason such as race, gender, sexual orientation, ethnicity, caste, religion, disability, memberships to unions, politics, HIV status, physical appearance, age or any specific characteristics unrelated to the job.
HEALTH AND SAFETY
Suppliers will provide their employees with safe and healthy working conditions in accordance with applicable law and health and safety standards that are applicable to your industry.
ANTI-BRIBERY & MONEY LAUNDERING
Suppliers commit to not engaging in any form of bribery or money laundering and do their due diligence to ensure that those they work with such as agents or employees are also not engaged in bribery and money laundering. Suppliers have systems in place to confirm that this policy is adhered to by their staff, dealers or agents that act on their behalf.
COMMITMENT TO RESPONSIBLE SOURCING
Loren Stewart is committed to a policy of responsible sourcing of metals, gemstones, and minerals and is further committed to refraining from any action which contributes to the financing of conflict. Loren Stewart has a no-tolerance policy for the financing of conflict or human rights abuses. Loren Stewart has implemented a due diligence process for responsible supply chains based upon OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). Loren Stewart expects that all Suppliers we work with also commit to responsible sourcing through their own supply chain due diligence.
SUPPLY CHAIN DUE DILIGENCE
It is Loren Stewart’s expectation that our suppliers that are members in the gold, silver, colored gemstone and diamond supply chain, are also committed to a due diligence process for a responsible supply chain and will work with us in partnership. We recognize due diligence is an ongoing process and we will continue to work to collect data with your partnership. We ask that our suppliers will conduct their own due diligence of their supply chain to identify the geographical origin of their materials whenever possible, and will determine if there are any human rights risks that may be connected to any part of their supply chain. Suppliers agree to have an open dialogue with Loren Stewart to share their business practices, and any pertinent information learned from their due diligence assessments of their own supply chains.
As part of our due diligence program, you are required to disclose the origin of the gold or silver products, gemstones and diamonds you supply to us, to the best of your knowledge. Our due diligence provides us with the information we need to identify risks in order to prevent or mitigate adverse impacts associated with our sourcing practices, we expect that as our suppliers, you also help us achieve this by doing the following:
- Ongoing : integrated into your company’s management systems and daily processes -Proactive: designed and implemented to identify and mitigate risks to prevent negative outcomes
- Reactive: able to respond to risks
- Risk based: understand and prevent any potential risks in the supply chain
- Continual Improvement: constantly work to improve systems and push for better understanding of our supply chains
The risks outlined in Annex II of the OECD Guidance are:
- Serious abuses associated with the extraction, transport or trade of minerals
- Any forms of torture, cruel, inhuman and degrading treatment
- Any forms of forced or compulsory labour
- The worst forms of child labour
- Other gross human rights violations and abuses such as widespread sexual violence
- War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide
- Direct or indirect support to non-state armed groups (covered by the KPCS for diamonds)
- Direct or indirect support to public or private security forces
- Bribery and fraudulent misrepresentation of the origin of minerals ○
- Money laundering and non-payment of taxes and royalties due to governments.
PRODUCT GUARANTEES & PRODUCT DISCLOSURES
Suppliers will provide accurate and truthful information to Loren Stewart for all the products sold to Loren Stewart. Suppliers will not provide misleading or unclear information regarding stones or metals. It is Loren Stewart's expectation that all suppliers using metals guarantee that their metals will test accurately in assay. 925 sterling and 585 14kt gold. For any gemstones and diamonds purchased, exact details should be noted on invoices, clarifying the stone is of natural origin, if it is color treated, carat weight, quality, and the ‘place of origin,’ which refers to the geographical area where the stones were originally mined. Information on place of origin should be treated as opinion rather than fact. Clearly state whether or not you have determined the place of origin based on gemmological laboratory analysis, and include the name of the lab and date of analysis, if this is available.
DIAMOND WARRANTY STATEMENTS
Suppliers will provide the following statements on invoices issued to Loren Stewart for diamonds or any designs containing diamonds
“The diamonds and/or diamonds set in jewelry herein invoiced are exclusively of natural origin based on 100% testing of all diamonds supplied using appropriate diamond verification equipment. The seller agrees to provide evidence of test results when requested.”
“The diamonds and/or diamonds set in jewelry herein invoiced have been (sourced) purchased from legitimate sources not involved in the funding of conflict, in compliance with United Nations Resolutions and corresponding national laws (where the invoice is generated). The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the World Diamond Council (WDC) System of Warranties (SoW) Guidelines.”
The above policy commitments are endorsed by:
Name: Rachel Loren
Date: June 1, 2022