Supply Chain Policy

Heights Jewelers LLC Supply Chain Policy

 

  1. Heights Jewelers LLC is a jewellery supplier. This policy confirms Heights Jeweler’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions, and laws.

 

  1. Heights Jewelers LLC is a member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:
    1. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Fundamental Rights at Work;
    2. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
    3. support transparency of government payments and rights-compatible security forces in the extractives industry;
    4. do not provide direct or indirect support to illegal armed groups; and
    5. enable stakeholders to voice concerns about the jewellery supply chain.
    6. are implementing the OECD 5-Step framework as a management process for risk based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

 

  1. We also commit to using our influence to prevent abuses by others. For those cases where our due diligence and risk assessment determines that such abuses by others exist, we will cease business relations with that party. If a supplier does not comply with our requests and we determine that such non-compliance would expose us to undue risk, we will cease business relations. Additionally, we promise to investigate any complaints brought to our attention by interested parties who have voiced concerns about potential materials from CAHRA sources.

 

  1. Regarding serious abuses associated with the extraction, transport, or trade of precious metals:

We will neither tolerate nor profit from, contribute to, assist, or facilitate the commission of:

  1. torture, cruel, inhumane, and degrading treatment;
  2. forced or compulsory labour;
  3. the worst forms of child labour;
  4. human rights violations and abuses; or
  5. war crimes, violations of international humanitarian law, crimes against humanity or genocide.

 

  1. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in 4 or are sourcing from, or linked to, any party committing these abuses.

 

  1. Regarding direct or indirect support to non-state armed groups

We only sell or purchase precious metals do not directly or indirectly support non-state armed groups, including, but not limited to, procuring precious metals from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

  1. control mine sites, transportation routes, points where precious metals are traded and upstream actors in the supply chain; or
  2. tax or extort money for precious metals at mine sites, along transportation routes or at points where precious metals are traded, or from intermediaries, export companies or international traders.

 

  1. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.

 

  1. Regarding public or private security forces

We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment, and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally as described in paragraph 6.

 

  1. Regarding bribery and fraudulent misrepresentation of the origin of precious metals

We will not offer, promise, give, or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of precious metals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport, and export of precious metals.

 

  1. Regarding money laundering

We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport, or export of precious metals.

 

Any complaints, notifications or observations can be addressed to admin@heightsjewelers.com

  

Marc Appelbaum CEO

 March 10, 2023