Annual Report Ethical & Responsible Sourcing

Heights Jewelers LLC has implemented the following Supply Chain Policy (https://heightsjewelers.com/pages/heights-jewelers-supply-chain-policy) with regard to our supply chain on silver (platinum group metals) that might be originating from conflict-affected and high-risk areas. This policy is communicated at our website and shared directly with our suppliers and can be accessed via the link above.

To support supply chain due diligence, we have implemented the following internal measures: appointed a Chief Compliance Officer (CCO), allocated financial and human resources, established an internal communications process policy, and established a training program.  The CCO responsible for overseeing supply chain due diligence is Deniz Ardelle Appelbaum, MBA, PhD. Dr. Appelbaum can be reached at deniz@heightsjewelers.com.

Heights Jewelers LLC has established a system of controls and transparency over our supply chain which include our approach for identifying suppliers whereby we obtain prescribed evidence of documentation and online information, thereby  identifying sources of our silver and platinum group metals (PGM) from their upstream sources. These methods have strengthened our due diligence efforts by providing us assurance that our suppliers are obtaining their own due diligence regarding their own silver and PGM upstream sources.

 As a company we communicate our expectations regarding supply chain due diligence via correspondence with our suppliers. In addition to this we also take the following steps to strengthen our engagement with suppliers: we visit them, engage with them as partners, and discuss best practices. The outcome of doing so has been satisfactory to date and we feel reasonably assured that our silver and PGM are being ethically sourced.

Our documented grievance mechanism for internal stakeholders can be accessed upon request and/or will be provided by our CCO upon receipt of a concern. Our external grievance mechanism is available via email request. Deniz Ardelle Appelbaum MBA, PhD, as Heights Jewelers LLC’s CCO,  is responsible for handling all concerns regarding our supply chain and for the dissemination of our grievance mechanism process document.

We assess our supplier’s due diligence practices by: asking our suppliers to agree to our policy, asking our suppliers for evidence that they are requesting ethical sourcing of their suppliers, and if they have collected evidence to support their claims. The senior manager who receives the findings of our risk assessment is Marc Appelbaum, Managing Partner of HJ LLC.

To respond to the risks identified within our supply chain, we have designed a documented risk mitigation plan template that we can customize for an at-risk supplier. We anticipate that such a risk mitigation plan will enable us to work with a  supplier to address the relevant supply chain issue. Our risk management plan generally consists of the following: risk identification and its severity, objectives, timelines, stakeholders, actions taken, and resolutions/conditions. While we have yet to utilize this risk mitigation template, if and when we do, we would monitor and track the effectiveness of our mitigation measures, including the results of our follow-up activities after six months to evaluate significant and measurable improvement.

Heights Jewelers LLC provided training regarding our due diligence activities to our partners in early March 2023; this training included information on all aspects of responsible and ethical sourcing of silver and PGM. We have also provided information regarding our due diligence activities and policies to all of our contractors and suppliers during the months of February and March 2023; this information included RJC publications upon request and HJ LLC’s documentation.

Heights Jewelers LLC communicates to our stakeholders regarding our due diligence activities. This communication is in the form of direct emails, conference calls, and publication of policies on our website. Since this is our first annual report no grievances have been raised regarding human rights risks or our supply chain due diligence.

Heights Jewelers LLC joined the Responsible Jewellery Council (RJC) before the pandemic in 2019 and hopes to soon attain status as a certified member. In support of our continuous improvement journey, our very first third-party RJC audit took place within our organisation against the RJC COP 2019 on March 1-2, 2023.

Signed by:

Marc Appelbaum,

Managing Partner and Owner

 Contact Information:

COMPANY NAME:   Heights Jewelers LLC

DATE:    April 1, 2023

REPORTING PERIOD:   3/31/2022-2/28/2023

CONTACT:  Deniz Ardelle Appelbaum, MBA PhD,

                                            Chief Compliance Officer    

                                     deniz@heightsjewelers.com