At HISTORIC ORIGINALS LTD we are committed to protecting the human rights of all our staff and those who receive direct or indirect services from us. As a responsible, ethical organisation, we fully support the principles of the Human Rights Act and all associated legislation.

 Our responsibility for human rights encompasses: 

·         Our operating sites — we will uphold the human rights of all employees, visitors and contractors at our offices and distribution centres.

·         Our supply chain — it is our aspiration to ensure that working conditions throughout our supply chain meet internationally accepted standards of human rights and working conditions.

This policy statement has been developed with reference to the following documents:

·         The Human Rights Act 1998

·         The Modern Slavery Act 2015

·         The Ethical Trading Initiative Base Code

KEY PRINCIPLES

PRIVACY 

We respect the privacy rights of our employees when gathering personal information or implementing employee monitoring practices.

CHILD LABOUR

We will not employ workers under the legal minimum age for work as stipulated by the Employment Act 2008. 

FORCED LABOUR

We will not make use of any forced labour or debt-bondage labour in accordance with the Modern Slavery Act 2015. 

DISCRIMINATION

We will not discriminate against any person based on their protected characteristics and will uphold Article 14 of the Human Rights Act 1998 in respect of protection from discrimination.

FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

We respect the right of our employees to associate freely and participate in collective bargaining.

BUSINESS PARTNERS

We expect respect for Human rights from our significant business partners.

DISCIPLINE

We will not employ, or allow to be employed, any form of corporate punishment, physical coercion or verbal abuse. Any disciplinary matter will be dealt with through formal procedures.

WORKING HOURS

Working time directives will be adhered to as per the Working Time Regulations 1998 with opt-out clauses publicised to staff.

REMUNERATION

Wages paid for standard working hours will meet or exceed national minimum wage or living wage levels as appropriate.

Hot Diamonds Group is a jewellery design and distribution company. This policy confirms Hot Diamonds Group’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

We also commit to using our influence to prevent abuses by others and take all steps to comply with OECD guidelines.

Risk Categorisation:

Key suppliers are to be split into ‘lower risk’ and ‘higher risk’ categories

·         RJC suppliers or those audited by RJC harmonized organisations are ‘lower risk’

·         Non-RJC suppliers or those not audited by RJC harmonized organisations are ‘higher risk’

Supply Chain Due Diligence:

·         Suppliers will be asked to disclose their RJC or RJC harmonized organisation certificates where applicable

·         In addition, suppliers are asked to demonstrate and provide written evidence that they source the gold, silver and diamonds that they use for manufacturing from sources which are compliant with the SRSP

The company will review this documentation and file it accordingly so that it is available for auditors to access

·         For ‘lower risk’ suppliers, this evidence will be requested every two years

·         For ‘higher risk’ suppliers, this evidence will be requested every year

·         The company will adopt a ‘KYC’ approach to its supply chain and will research the background of each key potential supplier before onboarding

Terms of Business:

·         The company’s terms of business will always include that all suppliers must be compliant with meeting the minimum standards set out in the SRSP

This requirement will be communicated to all existing suppliers and will form part of the onboarding process for all new suppliers

Staff awareness, due diligence and escalation:

·         The company will communicate to its staff its supply chain policy and the SRSP supply chain requirements

·         The company will encourage its staff to highlight any potential risk areas within its supply chain and to communicate these to the Head of Commerce

Investigating risks and handling non-conformance:

·         Through due-diligence and the actions above, the company will identify any risks within its supply chain and act accordingly:

Risks will be investigated by the Head of Commerce

Non-conformity of a supplier will either result in:

·         Corrective action being required by the company whilst trading continues;   

·         A temporary suspension of trading whilst the risks are being worked on;

·         In serious cases a cessation of the business relationship.

Accountability:

·         The company’s compliance officer is the Head of Commerce. 

For questions or to raise any grievance regarding this policy, please contact adryan.cresswell@hdgroup.com. 

Hot Diamonds is a member of the Responsible Jewellery Council (RJC). 

The RJC is a standards-setting organisation established to advance responsible ethical, human rights, social and environmental practices throughout the gold, silver, platinum group metals, diamond and coloured gemstone jewellery supply chain. 

The RJC has developed a benchmark standard for the jewellery supply chain and credible mechanisms for verifying responsible business practices through third-party auditing. 

As an RJC member, we commit to operating our business in accordance with the RJC Code of Practices. We commit to integrating ethical, human rights, social and environmental considerations into our day-to-day operations, business planning activities and decision-making processes.

Environmental Policy

HO Group is committed to providing a quality service in a manner that ensures a safe and healthy workplace for our employees and minimises our potential impact on the environment. We will operate in compliance with all relevant environmental legislation and we will strive to use pollution prevention and environmental best practices in all we do.

Our  Policy therefore, is to:

• integrate the consideration of environmental concerns and impacts into our decision making and activities,
• minimise our waste and then reuse or recycle as much of it as is possible.
• minimise energy and water use within our buildings and processes in order to conserve supplies and minimise the consumption of natural resources.
• As far as is possible, purchase products and services that do the least damage to the environment. train, educate and inform our employees about environmental issues that may affect their work, promote environmental awareness among our employees and encourage them to work in an environmentally responsible manner;
• communicate our environmental commitment to clients, customers and the public and encourage them to support it
• where required by legislation or where significant health, safety or environmental hazards exist, develop and maintain appropriate emergency and spill response programmes,

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Commitments

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

-              We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.

-              The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

-              We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

-              We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.

- Consistent with our risk based approach we may require:

-              employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct

-              Suppliers engaging workers through a third party to obtain that third parties' agreement to adhere to the Code

- As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.

- If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action.This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationship

POLICY STATEMENT

It is the policy of Historic Originals Ltd (the FIRM) to conduct business in an honest and ethical manner. As part of that, the Firm takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

PURPOSE

The Firm will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the ACT), which applies to conduct both in the UK and abroad.

SCOPE AND APPLICABILITY

This Anti-Corruption and bribery Policy (the POLICY) applies to all individuals working for or on behalf of the Firm at all levels and grades, whether permanent, fixed-term or temporary, and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Firm, (collectively referred to as WORKERS in this policy).

In this policy, THIRD PARTY means any individual or organisation that Workers come into contact with during the course of work and the running of the Firm’s business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.

WHAT IS BRIBERY?

A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:

·         giving or offering a bribe;

·         receiving or requesting a bribe; or

·         bribing a foreign public official.

The Firm may also be liable under the Act if it fails to prevent bribery by an associated person (including but not limited to Workers) for the Firm’s benefit.

GIFTS AND HOSPITALITY

This Policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, we have specific internal policies and procedures which provide guidance to Workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below (the OVERRIDING PRINCIPLES), namely that any gift or hospitality:

·         must not be made with the intention of improperly influencing a Third Party or Worker to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

·         must comply with local law in all relevant countries;

·         must be given in the name of the organisation, not in an individual’s name;

·         must not include cash or a cash equivalent;

·         must be appropriate in the circumstances;

·         must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift;

·         must be given openly, not secretly; and

in the case of gifts, they must not be offered to, or accepted from, government officials or representatives, politicians or political parties, without the prior approval of either the Compliance Officer for Legal Practice (COLP) or Compliance Officer for Finance and Administration (COFA).

The Firm appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.

WHAT IS NOT ACCEPTABLE?

It is not acceptable for any Worker (or someone on their behalf) to:

• give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or the Firm will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
• give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;
• accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;
•  accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by the Firm in return;
• threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this Policy; or
• engage in any activity that might lead to a breach of this Policy.

FACILITATION PAYMENTS AND KICKBACKS

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

CHARITABLE DONATIONS AND SPONSORSHIP

The Firm only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with the Firm’s internal policies and procedures.

RECORD KEEPING

We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

RESPONSIBILITIES AND RAISING CONCERN

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this Policy.

Workers are required to notify the Firm as soon as possible if it is believed or suspected that a conflict with this Policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any employee who breaches this Policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Workers if they breach this Policy.

If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this Policy, they should raise their concerns with Adryan Cresswell (Adryan.cresswell@hdgroup.com)

TRAINING AND COMMUNICATION

Training on this Policy is provided for all Workers and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors and business partners.

MONITORING AND REVIEW

The Firm monitors the effectiveness and reviews the implementation of this Policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in countering any risks of bribery and corruption.

All Workers are aware that they are responsible for the success of this Policy and should ensure they use it to disclose any suspected danger or wrongdoing.

HD Group seeks to ensure that all staff who wish to raise a grievance can do so without the fear of subsequent retaliation.

HD Group commits to ensuring that any staff member who raises a grievance is subsequently fully protected from any form of reprisal and will work closely with its staff to ensure sufficient processes are put into place in these instances.

Should a member of staff feel that they are suffering from retaliation, following a grievance, they should contact Adryan Cresswell who will investigate accordingly.

HARASSMENT POLICY

HD Group Ltd is committed to providing a working environment free from bullying and harassment. We aim to ensure that all staff are treated, and treat others, with dignity and respect. This policy covers bullying or harassment which occurs at work and out of the workplace, including on work trips or at work-related events or social functions.

This policy applies to all staff at all levels including employees, management, agency and casual workers, and independent contractors.

WHAT IS HARASSMENT?

Harassment is any unwanted conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment. A person may be harassed even if they were not the intended “target”. Harassment also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.

It is unlawful under the Equality Act 2010 to harass a person because of their age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. It also includes conduct of a sexual nature (sexual harassment).

Harassment is unacceptable even if it does not fall within any of these categories. Examples of harassment include, but are not limited to:

·         unwanted physical conduct including touching, pinching, pushing and grabbing;

·         unwelcome sexual advances or suggestive behaviour;

·         offensive e-mails, text messages or social media content or the display of offensive materials;

unwanted jokes, banter, mocking, mimicking or belittling a person.

WHAT IS BULLYING?

Bullying is offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power through means that undermine, humiliate, denigrate or injure the recipient. Bullying can include the use of personal strength or the power to coerce through fear or intimidation, not necessarily from someone in a position of authority. Bullying may be physical, verbal or non-verbal. It can include conduct that is not face-to-face, including via text message, email and social media. Examples of bullying include:

·         physical or psychological threats;

·         overbearing and intimidating levels of supervision;

·         inappropriate derogatory remarks about a person or their performance;

·         shouting at staff;

·         persistently picking on people in front of others or in private;

·         blocking promotion and training opportunities;

·         regularly and deliberately ignoring or excluding staff from work activities or work related social events;

·         setting a person up to fail by overloading them with work or setting impossible deadlines;

·         regularly making the same person the butt of jokes.

Legitimate and reasonable criticism of a staff member’s performance or behaviour, or reasonable management instructions, do not amount to bullying. Breaches of this Policy Bullying and harassment are not tolerated in our workplace and all staff are required to treat each other, along with our customers, suppliers, and visitors, with dignity and respect.

Breaches of this policy will be dealt with in accordance with our disciplinary procedure. Serious cases of bullying or harassment may amount to gross misconduct resulting in dismissal. Staff who make complaints or who participate in good faith in any investigation must not suffer any form of retaliation or victimisation as a result. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our disciplinary procedure.

Anyone found to have retaliated against or victimised someone in this way will be subject to disciplinary action under our disciplinary procedure.

IF YOU BELIEVE YOU ARE BEING HARASSED OR BULLIED.

If you believe you are being harassed or bullied, you may wish to raise the problem informally with the person responsible. Explain the situation and how it has made you feel. It can be helpful to describe the event so the other person is clear about your concerns. Use the opportunity to ask the person to change or stop their behaviour.

Alternatively you may speak to your manager who can provide confidential advice and assistance in resolving the issue formally or informally. If you do not feel that informal steps are appropriate, or they have been unsuccessful, you should raise the matter formally under our grievance procedure as documented in our company handbook.

All complaints will be investigated in accordance with our grievance procedure. If we consider that there is sufficient evidence to suggest you have been harassed or bullied we will consider the appropriate action to take. If the person accused is an employee, this may include invoking our disciplinary procedure. Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned.

Health and Safety Policy

I : This policy is to:

Prevent accidents at work

manage health and safety risks in the workplace Provide training to ensure staff can do their work safely Provide personal protective equipment when required Consult with employees and health and safety.

Maintain equipment

Maintain safe working conditions

Implement emergency fire procedures and security procedures

2: Overall responsibility for Health and Safety: Adryan Cresswell

3: Day to day responsibility for putting this into practice: Craig Maybanks/Alex Urquart

4: All employees should (I) co-operate with managers on health and safety matters (2) take seasonable care of their own health and safety and (3) report any concerns to Adryan Cresswell

5: Arrangements for Health and Safety:

-              We will undertake risk assessments

-              We will give staff and contractors training

- We will provide protective equipment

- We will consult with staff

- We will make evacuation routes well signed and clear

- We will test evacuation plans

The Kimberley Process and Conflict Free Diamonds Policy

In accordance with the principles of The Kimberley Process, HO Group is committed to managing its supply chain in such a way as to ensure it never buys or sells conflict diamonds.

All HD Group jewellery suppliers will provide warranties that any diamonds they may supply to HD Group derive from conflict free sources.

At HD Group we run a VOLUNTARY over time policy.

·         HD Group is not committed to offering staff overtime

·         If HD Group does offer staff/contractors overtime during peak demand periods, staff/contractors can turn the offer down with no adverse effects to their employment/status whatsoever

HD Group will not coerce any staff members or contractors to work beyond their contracted hours. If HD Group offers overtime it is always purely voluntary.

HD Group will be flexible with staff opting to work over-time, allowing them to either take TOIL (time off in lieu) or receive overtime payment.

HD Group will never knowingly mislead its consumers regarding the quality, source, specification or any other attribute of its jewellery. It will take care to ensure all disclosures are accurate across all of its selling channels.

Should HD Group become aware of any inaccuracies across ay of its selling channels, it pledges to act swiftly and decisively to take the necessary corrective action.

We have recently undertaken due diligence relating to how we meet our codes of practice policies as well as various risk assessments relating to key business areas.

If you would like to see copies of this due diligence, please feel free to request them by emailing adryan.cresswell@hdgroup.com

Hot Diamonds has a clear grievance processes in place and takes and grievance raised very seriously.

Should any customer or supplier wish to raise a grievance, they should contact adryan.cresswell@hdgroup.com.

Your grievance will be investigated accordingly, and the results of the investigation will be communicated back to you as soon as is practicable.