Code of Conduct on Gold, Precious Metals, and Gemstones Sourcing

This Code of Conduct is designed to promote honest, ethical, and lawful conduct by all employees, officers, and directors of La Luce di Joy Harvey e Marco Rossi SNC SB, as well as all subsidiaries and entities controlled by it. The Code aims to help employees, officers, and directors understand the Company’s standards of responsiblel business practices and to raise awareness of ethical and legal issues that may arise in their roles.

Purpose and Principles

La Luce, as a jewellery company committed to responsible practices, believes in transparency and sharing comprehensive information about our supply chain. Our goal is to educate consumers and offer a more ethical alternative to prevailing jewellery supply chains. We acknowledge that the materials we source may have negative impacts related to their extraction, trade, handling, and export from conflict-affected and high-risk areas (CAHRAs). We also recognise our responsibility to uphold human rights and avoid contributing to conflict or exploitation.

Sourcing Practices

La Luce strives to align with third-party certification standards like Fairmined, whenever possible. However, our ultimate objective is to empower artisanal miners and cutters within the supply chain. Our focus is on benefiting mining communities and ensuring their fair participation and profit-sharing from their skills and resources. We prioritise artisanal and small-scale ventures over larger companies whenever feasible. In cases where third-party verification is impractical due to the nature of artisanal mining, we require suppliers to certify their supply chain.

Responsible Sourcing Policy

La Luce commits to purchasing gold, silver, diamonds, sapphires, pearls, and coloured gemstones only from sources that do not support illegal armed groups, human rights violations, or financial misconduct, as defined in the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance (https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf). Although most of the states we source from are not classified as conflict-affected or high-risk, we consider these guidelines a solid foundation.

Supplier Requirements

We expect our suppliers to adhere to the following guidelines:

1. Abuses Associated with Minerals Extraction and Trade:

   – We will not tolerate or profit from:

     i) Torture, cruel, inhuman, or degrading treatment.

     ii) Forced or compulsory labor.

     iii) Worst forms of child labor.

     iv) Gross human rights violations, including sexual violence.

     v) War crimes, violations of international humanitarian law, crimes against humanity, or genocide.

   – We will suspend engagement with suppliers showing reasonable risk of involvement in abuses.

2. Financing Armed Groups and Exploitation:

   – We will not tolerate funding of armed groups, private or public, that exploit artisanal miners.

   – Our priority is the well-being and welfare of those traditionally excluded from benefiting from their land’s resources.

3. Role of Security Forces:

   – Security forces’ role is to maintain the rule of law and safeguard human rights, not interfere with legitimate extraction or trade.

4. Anti-Bribery and Transparency:

   – We will neither offer nor accept bribes to conceal mineral origin.

   – Suppliers must disclose all relevant information about minerals.

5. Taxation and Transparency:

   – We will ensure taxes, fees, and royalties related to mineral activities adhere to Extractive Industry Transparency Initiative (EITI) principles.

Due Diligence System

La Luce personnel are required to follow procedures for conflict minerals due diligence:

– Adhere to OECD Guidance and Responsible Minerals Initiative (RMI).

– Provide and seek due diligence information from suppliers.

– Establish strong supplier relationships.

– Support suppliers in improving performance and conforming to this policy.

– Suspend engagement with non-compliant suppliers.

– Discontinue engagement with suppliers posing risks of severe human rights abuses.

– Visit mining and cutting facilities when possible.

– Continuously improve the due diligence system.

– Transparently report progress to customers, stakeholders, and the public.

Supplier Relationships

As of July 2023, we work with limited suppliers adhering to our values, and agreements have been signed with those who can’t adhere to a severe certification scheme:

– Sapphires: Wennick-Lefevre

– Pearls: Marc-Harit

– Diamonds: Ocean Diamonds

– Canadamark Diamonds (certified)

– Fairmined gold and silver (certified)

For other occasional suppliers, we ensure they align with our code of conduct before purchase and sign due diligence agreements for more habitual relationships.

Conclusion

This Code of Conduct reflects our commitment to ethical, responsible, and transparent sourcing practices for gold, precious metals, and gemstones. By adhering to these principles, we strive to contribute positively to our supply chain and the communities involved.