Stockists

1. OBJECTIVES OF THE POLICY

Kuopendy’s Responsible Sourcing Policy (‘the Policy’) sets out our requirements and some of the practical steps required to comply with Kuopendy’s Ethical Code of Conduct (‘Kuopendy’s Code’) and the Responsible Jewellery Council Code of Practice (‘RJC CoP’) link (together to be known as ‘the Codes’).

The Policy is applicable to all stages of the supply chain. It sets out further standards and requirements that all of Kuopendy’s Suppliers must uphold, highlighting Kuopendy’s way of working, bringing focus to crucial industry specific requirements. In this Policy the term ‘Suppliers’ refers to all factories, suppliers, subcontractors, partners and agents.

The Supplier is responsible to ensure the Policy is fully implemented and adhered to. By supplying Kuopendy you are agreeing to uphold the Codes and adhere to the Policy. Failure to do so could result in all work with you being immediately suspended or completely banned.

2. SOURCES OF THE POLICY

· OECD (2016) OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition - link

· Responsible Jewellery Council Code of Practice 2019 - link

· The Ethical Trading Initiative Base Code - link

· The United Nations Universal Declaration of Human Rights - link

· The European Convention of Human Rights - link

· The Fundamental Conventions of the International Labour Organisation (‘ILO’) - link

· Modern Slavery Act 2015 (UK legislation) - link

3. ON-BOARDING AND WORKING TOGETHER

ON-BOARDING NEW SUPPLIERS AND FACTORIES

During the process of on-boarding new factories, we need to ensure the factory’s ethical standards align with Kuopendy’s expectations. We require full visibility of all new Suppliers intended to be used for production and have a strict approval process in place which must be followed for all new factories.

Every prospective Supplier must submit a New Supplier Profile Form. In addition, the Supplier needs to provide a valid third-party audit to the Design Team.

· For jewellery factories we insist upon RJC CoP certification as a minimum.

· For non-jewellery factories we accept SMETA, BSCI, Better Work, Fair Labor Association and SA8000 audits and certifications if they are less than one year old.

Kuopendy will only approve a factory when satisfied with the audit and/or progress made on the Corrective Action Plan (‘CAP’).

Neither sampling nor bulk production can occur without written approval from Kuopendy’s Design Team.

Once Suppliers have been officially approved through the onboarding procedure, bulk orders can be made.

ON-BOARDING SUBCONTRACTORS

For both current and new Suppliers, any component or process subcontracted must be pre-agreed with Kuopendy in writing. Every subcontractor unit must be added to the factory profile. The Supplier is responsible for ensuring the subcontractor details are correct and that they understand and comply with the Codes.

For further information on the factory approval process, audits or subcontracting, please contact the Design Team at Kuopendy.

SUPPLIER VISITS Kuopendy’s Design Team visit Suppliers as regularly as possible and visits are logged here; this is to build and maintain important relationships and to check the standards of the factories where Kuopendy’s products are made. These visits will consist of:

· Factory tour to understand production processes and to assess factory conditions.

· Meeting with management or persons responsible for ethical standards to follow up on points raised in previous audits and points raised during the factory tour. A CAP will be agreed.

· CAD and sample development and sign-off

· Production process review

· Sub-contractor visits (e.g. stone cutting, plating or other component sourcing)

· Quality training

All assessments and CAP reports (if needed) will be based on this Policy and the relevant Code, so it is important you familiarise yourself with these documents to ensure you are adhering to Kuopendy’s standards.

TRANSPARENCY & TRACEABILITY

It is essential that we know where our products are made, not just the final product, but all components including chains, gemstones and findings for jewellery and non-jewellery. We are beginning to map Kuopendy’s supply chain and will be doing this initially through the New Factory Profile Form.

It is the responsibility of the Supplier to keep this information up to date.

4. WORKING PRACTICES

HOMEWORKERS

Kuopendy supports the empowerment of women through the provision of ‘Homeworking’ as part of the manufacturing process. Written permission from Kuopendy must be received before the Supplier can use Homeworkers to produce Kuopendy’s product. If permission is granted, it is the Supplier’s responsibility to ensure all Homeworking adheres to the Codes.

The Supplier must be fully transparent and maintain records of all homeworking practices used for Kuopendy production and must facilitate visits and reviews when required by Kuopendy’s Team or appointed 3rd party.

TEMPORARY WORKERS, CASUAL WORKERS, AGENCY & SHORT-TERM CONTRACTS

Kuopendy stipulates that employment should be regular and performed through a recognised working relationship established by national law and practise. The use of temporary, short term, agency, or casual working on a regular basis for the long-term or multiple short-terms to benefit the employer shall be avoided. Kuopendy understands there may be instances where use of non-standard employment is essential; in these instances, obligations to temporary employees shall not be avoided. All temporary, casual, agency and short-term workers must have clear contracts which must contain terms that entitle the employee to all advantages afforded to permanent employees.

MIGRANT WORKERS

Many factors can influence or force workers to migrate in search of security, opportunity, and employment. These factors can mean that ‘Migrant Workers’ are vulnerable to exploitation. Suppliers are responsible for ensuring that all Migrant Workers are employed responsibly, this means that Migrant Workers are employed legally, not indebted to agencies and that their rights and welfare are safeguarded.

HUMAN RIGHTS AND MODERN SLAVERY

Kuopendy recognises our responsibility to promote responsible and fair employment practices throughout our supply chain. We work closely with our Suppliers to continuously improve conditions of all factories used to produce Kuopendy product. In addition to requiring compliance with the Codes, Kuopendy’s Suppliers must also ensure that they take all reasonable steps necessary to eliminate the risk of Modern Slavery.

Modern Slavery

Kuopendy is committed to avoiding any form of Modern Slavery in our supply chain, please refer to our Modern Slavery Policy here.

Child Labour

Due their age, children are particularly vulnerable to exploitation and Modern Slavery. Kuopendy is committed to eradicating any form of child labour and child slavery. Accordingly, child labour is not to be used under any circumstances and Suppliers must ensure that all employees meet the minimum age requirement set by local laws.

Remember: Kuopendy will work with Suppliers who bring to our attention issues in their factories or within their supply chains. Where possible, we want to help mitigate these issues and find resolutions. We cannot do this unless Suppliers raise these issues at an early stage. Potential risks or concerns relating to Modern Slavery or other human rights abuse within Kuopendy’s supply chain must be communicated as soon as possible. Report any issues relating to this to your Kuopendy contact.

5. MATERIAL SOURCING

As part of our commitment to making quality products for our customers we also aim to reduce their ethical and environmental impact. Material selection is an important part of improving the sustainability of our collections by minimising our reliance on freshly mined minerals or virgin raw materials we can reduce our carbon, water, and waste footprint.

As a business Kuopendy has committed to strict targets for specific materials, these include, but are not limited to:

· 50% of the silver in our products to be recycled silver by end 2021. Update - January 2023: we can confirm all silver lines are ordered in recycled silver.

· 100% of the gold used in 14ct solid gold products must come from recycled sources.

· 50% of the gold used in plating (Gold Potassium Cyanide or ‘GPC’ to come from recycled sources by end 2021. Update – January 2023: We can confirm that all plating is recycled.

· 100% of diamonds to come from Kimberley Process Certified sources.

SUSTAINABLE MATERIALS PRIORITY LIST

To help reduce the environmental impact of our products, Kuopendy wants to increase the percentage of sustainable materials we use. Suppliers can influence the use of more sustainable materials by helping Kuopendy choose these when deciding which materials to source.

Examples of sustainable materials are:

Recycled Silver

Recycled Solid Gold and Recycled Gold Plating (GPC)

Recycled Brass

Brass is an alloy made predominantly with copper and zinc. The percentage mix can vary, but copper tends to make up between 80-90%. We are working towards sourcing a certified recycled brass.

Traceable Coloured Gemstones

Coloured gemstones are known to have complex supply chains with very little transparency. It is important to Kuopendy that we source coloured gemstones from transparent and traceable sources. Our aim is to eventually be able to trace all coloured gemstones back to the mine.

Traceable Fresh Water Pearls

The farming of Fresh Water Pearls can cause harm to the surrounding environment, it is therefore important that we know the source of the Fresh Water Pearls used in our products.

Our Suppliers are industry experts so, please help to keep us informed on any developments within sustainability and show us examples of lower impact and innovative materials.

6. BANNED & RESTRICTED MATERIALS

Kuopendy’s Banned and Restricted Materials list encompasses all materials which will not be sourced or used under any circumstance in any of Kuopendy’s products. All Suppliers must comply with this list.

CONFLICT MINERALS

Companies involved in mining and trade in minerals from conflict-affected and high-risk areas (‘CAHRAs’) are at risk of contributing to human rights abuses and violations of national or international law. Kuopendy is fully committed to the responsible sourcing of raw materials and strive towards a supply chain free from conflict minerals. To ensure this, we adhere to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and expect our factories and raw material suppliers to do so as well.

Diamonds

We only accept diamonds sourced by Suppliers who are members of the RJC and who comply with the Kimberley Process Certification Scheme and World Diamond Council System of Warranties.

Gold

We only accept conflict-free gold sourced from refiners that are either RJC Chain of Custody certified or have been accredited the Good Gold Delivery List of the London Bullion Market Association.

Endangered Species (non-jewellery only)

In accordance with the Convention on International Trade in Endangered Species (‘CITIES’) and International Union for the Conservation of Nature (‘IUCN’) list, Kuopendy prohibits the use of materials from endangered species in our products.

Leather (non-jewellery only)

No animal will be slaughtered solely for use within a Kuopendy product. All skins utilised in Kuopendy’s products must be by-products of the meat industry. We will not use any skins from animals that have been boiled or skinned alive. We will not use Karakul, Slink or other leathers that are from unborn animals.

Uzbek, Turkmen, and Xinjiang Cotton (non-jewellery only)

Kuopendy prohibits the use of cotton sourced from Uzbekistan, Turkmenistan, and Xinjiang in all products. This is due to documented reports of industry-wide and systematic human rights violations, including the occurrence of child labour and forced labour in the harvesting of cotton. Kuopendy does not tolerate these practices and therefore prohibits the use of Uzbek, Turkmen & Xinjiang cotton in our products.

7. REPORTING AND CERTIFICATION OF SUSTAINABLE & RESTRICTED MATERIALS

To help meet Kuopendy’s sustainability commitments and ensure accurate reporting on sustainable and restricted materials, it is important that we verify the authenticity of the material’s source. To do this we require specific documentation and certification.

Requirements for Recycled Metal (adaptable for other certified recycled or organic materials):

Kuopendy's Responsibility

· All POs to be issued stating requirements for sustainable and/or restricted materials. For example, recycled silver and recycled gold.

Supplier Responsibility

· All Supplier invoices to state that the silver and gold was sourced as recycled from their metal supplier and that their metal supplier is RJC certified, preferably RJC Chain of Custody (‘CoC’) certified.

· Quarterly copies of invoices between factory and factory sources of recycled silver and gold/gold plating, stating the metal is recycled and that they are RJC certified.

and either:

· Quarterly copies certificates from factory metal sources that confirm the metal sources are recycled

Or

· Quarterly copies of CoC transfer document. This specifies:

o the certification numbers of the refinery/metal supplier and the jewellery factory

o the type of CoC material being transferred e.g. recycled, Fairtrade or Fair mined

o the weight of CoC materials transferred from the refinery to the jewellery factory.

o Specifies the invoice number and company details including address etc.

Requirements for Diamonds:

Kuopendy's Responsibility

· To ensure that Kuopendy only purchases conflict-free diamonds we adhere to the Kimberley Process and the World Diamond Council (‘WDC’) System of Warranties (‘SoW’).

o When purchase orders are placed with Suppliers for diamond product, we must state that diamonds are to originate from legitimate sources not involved in the funding of conflict, in compliance with UN resolutions and corresponding national laws.

· To ensure that Kuopendy does not purchase lab-grown or treated diamonds without our knowledge we must adhere to the WDC SoW.

Supplier Responsibility

· To ensure the diamonds we purchase are conflict-free we require the factory to adhere to the Kimberley Process and the WDC SoW. We require the factory to provide:

o Invoice between jewellery factory and Kuopendy including the diamond warranty statement:

“The diamonds herein invoiced have been (sourced) purchased from legitimate sources not involved in the funding of conflict, in compliance with UN resolutions and corresponding national laws (where the invoice is generated). The Seller hereby guarantees that these diamonds are conflict free and confirms adherence to the WCD SoW Guidelines”.

o Invoice between diamond supplier and jewellery factory which also includes the diamond warranty statement.

· To ensure Kuopendy does not purchase lab-grown or treated diamonds without our knowledge we require the factory provide:

o Invoice between jewellery factory and Kuopendy including the World Federation of Diamond Bourses (‘WFDB’) statement:

“The diamonds herein invoiced are exclusively of natural origin and untreated based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.”

8. INBOUNG PACKAGING

· As part of our commitment to reduce environmental impact across our business, we request that all jewellery suppliers deliver in-bound product in bio-degradable/recyclable poly bags. All suppliers work with a supplier, who offer a certification that the poly bag is bio-degradable.