Responsible Sourcing Policy

Dubai Jewellery GmbH — Responsible Sourcing Policy

Purpose and Definition

At Dubai Jewellery GmbH, we are guided by our values of craftsmanship, authenticity, sustainability and timeless design.
For our Responsible Sourcing Policy and our commitment to supply chain transparency, we are driven by accountability: we take responsibility for our actions and expect the same from our business partners.

This policy illustrates our dedication to transparency in the social, ethical and environmental complexities of our supply chains and in managing our relationships with suppliers.
A supplier is any individual or organisation that provides, sells or leases materials, products or services for every product we design and/or manufacture under the Dubai Jewellery name.

  • This Responsible Sourcing Policy ensures that ethics are maintained within every product we source and create. It defines the principles guiding how we conduct business with our strategic suppliers of raw material and manufacturing activities as a premium jewellery maker.

Integrity in Action – Rules of Conduct

We commit to the protection of human rights, including children’s rights, with a particular focus on the challenges of sourcing in conflict-affected and high-risk areas (CAHRAs) in accordance with:

  • The United Nations (UN) Universal Declaration of Human Rights
  • The International Labour Organization (ILO) standards
  • The UN Guiding Principles on Business and Human Rights (UNGPs)
  • The UN Conventions on the Rights of the Child

Transparent communication – We promote dialogue and collaboration with internal and external stakeholders to advance our commitments.

Risk assessment – We expect our employees, suppliers and their third parties to share Dubai Jewellery GmbH’s commitment to recognising and addressing adverse impacts such as modern slavery and child labour.

Remediation – Where issues are found, we work to mitigate and eliminate risks.

Monitoring – We continuously improve our processes to address emerging challenges and risks across our business.

Supplier Code of Conduct

We set clear requirements and expectations for our suppliers to ensure they share our commitment to responsible sourcing.
Suppliers working with Dubai Jewellery GmbH must act in a manner consistent with our Supplier Code of Conduct and are encouraged to adopt a similar policy within their own business.

Modern Slavery & Transparency Statements

Dubai Jewellery GmbH operates with integrity and actively works to ensure environmental and social responsibility throughout our operations and supply chain.
Our Responsible Sourcing policies, including our Supplier Code of Conduct, formalise our commitments as a responsible jeweller and our dedication to continuous improvement.

Due Diligence Framework

We have a framework and action plan for identifying and managing risks associated with our suppliers — from due diligence, selection and monitoring, through to disengagement.
We assess suppliers based on risk and direct them to the most appropriate due diligence and management process.

Our due diligence addresses risks related to:

  • Regulatory compliance
  • Human rights (equality, working conditions, modern slavery)
  • Child labour
  • Health and safety
  • Environmental impacts
  • Annex II risks under the OECD Guidance

For suppliers of metals and minerals, we conduct due diligence according to the OECD Due Diligence Guidance 5-Step Framework (3rd Edition) including the Supplements on Gold, Tin, Tantalum and Tungsten.
Where geo-political complexities exist, we work to reduce, avoid or mitigate risks.

Reporting and Monitoring

We publicly communicate how we implement our supplier due diligence obligations, including on human rights abuses, child labour and the sourcing of conflict minerals and metals, in compliance with applicable law.

Our commitment to all stakeholders is to positively influence the industry while rigorously reviewing our own policies and procedures and actively participating in initiatives aligning with our vision and values.

Implementation

Reporting Channels – We make reporting channels available to our suppliers to raise concerns (including anonymously) regarding compliance with the Supplier Code of Conduct and our policies.

Employee Responsibility – We expect our employees to speak openly and raise concerns about possible breaches via our reporting channels. We have zero tolerance for retaliation against anyone who reports, in good faith, violations or suspected violations.

Consequences for Policy Violation – If we determine a supplier has breached this Responsible Sourcing Policy (intentionally, repeatedly, seriously or without remediation), we may terminate agreements without prejudice to any other remedy we may have.
We comply with mitigation and termination requirements defined in Annex II of the OECD Guidance. Where we have caused or contributed to an adverse impact on human rights in our supply chain, we will cooperate in processes to enable an appropriate remedy.

Organisational Responsibility – Every manager is responsible for implementing this policy within their area, leading by example and providing guidance. All employees must adhere to the rules of conduct set out herein.