POLICY STATEMENT

Respect for human rights is a fundamental value of Heights Jewelers LLC (HJ LLC). We are committed to supporting, respecting, and protecting human rights in our relationships with our associates, suppliers, and business partners.

POLICY INTENT

This Policy is guided by the United Nations Guiding Principles on Business and Human Rights.

Heights Jewelers LLC’s goal is to support, respect and protect human rights—both in our own business activities and in our business relationships with other parties. Heights Jewelers LLC expects the same of its suppliers. This policy, combined with those referenced below that address human rights within their respective scopes, reflects our commitment to human rights and ongoing efforts to protect human rights through our operations.

Child Labor

Heights Jewelers LLC is committed to the abolition of child labor within its sphere of influence. To that end, Heights Jewelers LLC, its associates, and its suppliers must prohibit the hiring of individuals that are under 18 years of age for positions in which hazardous work is required.

Forced Labor

Heights Jewelers LLC must not use, be knowingly complicit in, or knowingly benefit from the use of forced or involuntary labor whether bonded, imprisoned, or indentured, including debt servitude and human trafficking.

Heights Jewelers LLC also specifically requires that all members of a supplier’s workforce understand the terms of their employment, and Heights Jewelers LLC prohibits suppliers from withholding or destroying employee identity or immigration documents, passports or work permits.

Fair Compensation

Heights Jewelers LLC must compensate associates equitably and competitively relative to the industry and labor market and in accordance with the terms of applicable collective bargaining agreements. Heights Jewelers LLC must comply with applicable minimum wage, wage payment, work hours, overtime, and benefits laws.

Freedom of Association and Collective Bargaining

The National Labor Relations Act (the “Act”) provides that employees, as defined by the Act, have the right to choose whether to form and join trade unions. Heights Jewelers LLC, its future associates, and its suppliers must ensure that the rights of eligible employees to choose whether to be a member of a trade union and to bargain collectively as permitted by the Act are not unlawfully interfered with or restricted.

Heights Jewelers LLC must pursue constructive relationships and bargain in good faith with labor unions that represent emloyees.

Anti-Discrimination and Harassment

Heights Jewelers LLC is committed to a work environment free from discrimination, harassment, and retaliation, and to providing equal employment opportunities to all applicants and associates regardless of race, color, religion, gender, age, national origin, ethnicity, marital status, sexual orientation, gender identity or expression, disability, or military status.

Heights Jewelers LLC, its associates, and its suppliers strive to:

• Provide equal employment opportunities to all applicants and
• Maintain workplaces free from harassment or discrimination toward associates, applicants for employment, customers, or any other individuals who visit or conduct business with Heights Jewelers LLC or its suppliers.
• Provide reasonable accommodations to a qualified employee, associate, or applicant with a disability, to a pregnant employee or applicant, or to an employee or applicant for their sincerely held religious beliefs or practices, where the reasonable accommodation would enable the employee or applicant to perform the essential functions of their job or to have an equal opportunity to be considered for a job.

Diversity, Equity and Inclusion

At Heights Jewelers LLC, diversity, equity, and inclusion are fundamental values. Our commitment to human rights is reinforced by our diversity, equity, and inclusion practices because a diverse, equitable and inclusive culture values human rights and empowers our associates to protect human rights and report concerns.

Heights Jewelers LLC endeavors to reflect the diversity of the communities we serve and to cultivate a workplace that provides each employee with respect and the opportunity to grow and contribute at their greatest potential. Through our diverse business empowerment initiatives, Heights Jewelers LLC is focused on supporting and expanding equitable opportunities for minority-, women-, disabled-, veteran/service-disabled veteran-, and LGBTQ-owned business enterprises.

Safe and Healthy Workplace

At Heights Jewelers LLC, dedication to health and safety is a fundamental value; our efforts to ensure a healthy and safe workplace reinforce our commitment to human rights. Heights Jewelers LLC, its associates, and its suppliers strive to:

• Operate all aspects of business in a manner that protects the safety and health of associates, contractors, customers, and the general public.
• Provide and use the resources needed to maintain safe and healthy
• Identify and take reasonable measures to eliminate or mitigate potential workplace hazards.
• Provide safety information to all associates to educate, train, and protect them from workplace safety hazards.
• Ensure all associates are trained and empowered to stop work anytime that unsafe conditions or behaviors are observed until the job can be completed safely.
• Take action to prevent acts of violence, threats, and physical intimidation in the workplace.

IMPLEMENTATION

Trust, transparency, and accountability support Heights Jewelers LLC’s commitment to human rights. Heights Jewelers LLC and its associates must abide by Heights Jewelers LLC’s Code of Business Conduct, our foundation for making effective, ethical business decisions and for identifying situations that may raise legal and ethical issues. Heights Jewelers LLC’s suppliers must meet the expectations of Heights Jewelers LLC’s Supplier Code of Conduct and contract terms and conditions.

Transparency and Governance

Heights Jewelers LLC seeks to identify, manage, and prevent violations of this policy. Anyone can report a human rights concern through the options listed below:

• Management
• Compliance Officer
• Company Legal Council

Heights Jewelers LLC must take any report concerning human rights seriously, no matter how the report is received. Our procedures are designed to promptly review and resolve each issue, as well as routinely monitor and report as necessary.

Should we identify adverse human rights impacts resulting from our business activities, Heights Jewelers LLC is committed to the mitigation or fair and equitable remediation of those adverse impacts. Heights Jewelers LLC must also seek to promote access to remediation where we are linked to those adverse impacts through our relationships with third parties.

Effective human rights practices are contingent on associate awareness and execution. Heights Jewelers LLC must conduct trainings and issue communications to build awareness of our values and business practices. Heights Jewelers LLC associates are required on an annual basis to review and commit to following Heights Jewelers LLC’s Code of Business Conduct.

Complaints or Notifications of Violations

Any complaints or violations can be addressed to admin@heightsjewelers.com