EMPLOYMENT

The group, entity or facility must demonstrate a strong commitment to providing the highest standards of employment conditions. This includes ensuring that all workers are employed in accordance with applicable law and that employment relationships are genuine, fair and based on recognised contractual arrangements. Employers should not rely on alternative hiring practices that undermine workers’ rights or avoid legal obligations.

Before employment begins, workers must receive clear information about their terms and conditions, including pay and benefits, in a language they understand. Wages should be paid regularly and transparently, accompanied by clear wage slips that outline all payments and deductions. Where employment agencies are used, the organisation must have systems in place to ensure that all workers receive equitable compensation and that workplace standards are upheld.

Businesses must maintain accurate employment records—such as proof of identity, working hours, pay, benefits and work permits—retained for at least the period required by law. Wages and benefits must meet or exceed national legal minimums or collective bargaining agreements and should be sufficient to cover basic needs and allow for some discretionary income. Deductions must comply with the law, follow a documented process, and never reduce pay below the minimum wage. Workers must not be required to purchase personal protective equipment or other items necessary for their work.

In situations where workers cannot work for reasons beyond their control—such as government mandated closures—employers must follow national law regarding compensation and, where no legal requirement exists, should make reasonable efforts to ensure workers receive at least minimum wage. Workers should also be supported in accessing any government assistance schemes available to them.

Workers must be free to use their income as they choose, without pressure to purchase goods or services from the employer. Where allowances or in kind benefits form part of compensation, these must be fair, reasonable and for the personal use of the worker and their family. Any wage advances or loans must have transparent and fair repayment terms.

Working hours, overtime, holidays and rest periods must comply with national legislation. The normal working week should not exceed 48 hours, and total hours including overtime should not exceed 60 hours unless permitted by law or justified by exceptional circumstances. Overtime must always be voluntary, fairly compensated and never used as a basis for penalising workers who decline it. Workers must receive appropriate rest breaks, weekly rest days and paid annual leave, with special leave arrangements available for those with family responsibilities.

Employers must ensure that workers are compensated for illness in accordance with national law and that religious festivals are respected. During times of crisis or unforeseen events, responses must continue to uphold fundamental labour rights, including fair treatment, consultation and mitigation of adverse impacts.

Where redundancies or layoffs are unavoidable, they must be carried out in line with national law and the organisation’s own policies, which should be endorsed at the highest level and communicated to all workers. Redundancies must be based on fair and transparent criteria, with valid reasons provided, appropriate notice given, and severance pay calculated in accordance with legal requirements. Workers must be consulted individually or through their representatives and given the opportunity to minimise the impact of such decisions.

Where housing, food or medical care is provided, these must be of good standard and delivered in a way that respects the dignity and equality of workers and their families. Employers must also recognise and respect the lawful activities of worker representative bodies, ensuring that representatives have access to carry out their responsibilities. The right to freedom of association and collective bargaining must be upheld without interference, discrimination or retaliation. Where these rights are restricted by law, employers must not hinder the development of alternative means of worker representation.

Collective bargaining agreements must be communicated to workers and fully adhered to. Arbitrary dismissals must be avoided, and any major operational changes should be communicated to authorities and worker representatives in advance to minimise adverse impacts. Employers must provide information on employment practices and conditions as required by national law to support meaningful dialogue between workers and management.

HEALTH & SAFETY

The group, entity or facility must demonstrate a clear commitment to the highest standards of health and safety and to providing a safe, healthy working environment for all individuals. This includes actively minimising the risk of accidents, injuries and contagious or infectious diseases, and ensuring compliance with national legislation as well as international standards such as those set out in ILO Conventions. These expectations represent minimum requirements, and organisations are encouraged to exceed them wherever possible. Where national laws provide exemptions for certain types of businesses, the higher general standards should still be met.

Responsibility for health and safety should be assigned to a suitably qualified and experienced senior manager, supported by a documented health and safety policy endorsed at the highest level. This policy should be part of a broader management system that identifies workplace hazards, assesses risks and implements effective controls. The system should be reviewed regularly—at least annually—and updated whenever new risks or circumstances arise. Clear communication channels between management and worker representatives should be in place to ensure ongoing dialogue on health and safety matters.

Work‑related accidents, incidents, illnesses and near misses must be investigated, recorded and analysed to prevent recurrence. Workers should have a safe mechanism to raise concerns and discuss health and safety issues, and the organisation should cooperate fully with worker representatives and relevant authorities to drive continuous improvement. Policies must also be in place to ensure that workers are not under the influence of drugs, alcohol or illegal substances while at work.

Workers must receive clear, accessible information and training on health and safety standards relevant to their roles, including any special hazards or conditions. This information should be provided in languages understood by workers and repeated for new or reassigned staff. Visitors and contractors should also be informed of relevant safety requirements. Emergency procedures must be clearly communicated and regularly tested, and appropriate first aid equipment, fire‑fighting equipment and emergency exits must be available, maintained and easily accessible.

Personal protective equipment must be provided free of charge, appropriate to the task, and correctly used. The working environment must meet acceptable standards of noise, heat, ventilation, air quality and cleanliness. Adequate lighting, safe electrical installations, properly maintained machinery with required safeguards, and safe building structures are essential. Where chemicals are used, their storage, handling and disposal must be effectively controlled, with appropriate facilities and procedures in place.

Workplaces must also provide adequate hygienic facilities, drinking water, and sanitary food‑storage areas. Daily cleaning should be routine, and suitable arrangements must be made for pregnant or nursing women, including alternative work where necessary. Where dormitories are provided, they must meet legal and safety requirements, particularly regarding fire safety.

A comprehensive health and safety risk assessment must be undertaken, including an assessment of contagious and infectious disease transmission risks where applicable. Workers should be consulted in this process, and the outcomes and protective measures must be communicated clearly. Preventative measures—such as enhanced hygiene, PPE, ventilation, distancing, shift staggering or remote work—should be implemented in line with national public health guidance. Vulnerable workers must be identified and provided with additional protections. The effectiveness of these measures should be monitored on an ongoing basis.

All diamond‑impregnated scaifes used for cutting and polishing must be guaranteed cobalt‑free. Where hydrofluoric acid is used or stored, the organisation must follow national standards or best practice, conduct an annual bow‑tie risk assessment, maintain emergency preparedness and recovery plans, provide effective training, and maintain robust decontamination procedures.

Respectful Employment Practices, Inclusivity and Disciplinary Procedures

The group, entity or facility must ensure that no worker is discriminated against on the basis of race, colour, ethnicity, caste, national origin, religion, age, disability, genetic information, physical appearance, gender, marital or parental status, pregnancy, family or caring responsibilities, sexual orientation, HIV or other health status, political affiliation, membership of worker representative bodies, or any other characteristic unrelated to the requirements of the role. These protections apply across all levels of the organisation, including corporate governance.

To uphold this commitment, organisations must establish policies and procedures that prevent discrimination in every aspect of employment—from recruitment and wages to training, promotion, transfer, termination and retirement. These policies should reflect a clear commitment to diversity, equity and inclusion, ensuring that all individuals who are fit for work have equal opportunities throughout their employment journey.

Mechanisms to promote diversity and inclusivity, and to address discrimination, bullying, harassment or violence, must be in place and clearly communicated. These mechanisms should include regular training for relevant personnel, appropriate senior management oversight, and, where applicable, participation from workers’ committees. Organisations should also develop a gender inclusion strategy—or a broader diversity and inclusion strategy—where material issues or opportunities have been identified through human rights due diligence or risk assessments.

All forms of violence and harassment are strictly prohibited. This includes bullying, corporal punishment, degrading treatment, gender‑based violence, sexual or physical harassment, mental or verbal abuse, intimidation, coercion and retaliation. Both direct and indirect harassment are unacceptable. Workers must be treated with dignity and respect and must never be threatened or subjected to violence, whether towards themselves, their families or colleagues.

Clear disciplinary and grievance procedures must be established and communicated to all employees. These procedures should be confidential, unbiased and include an appeals process. All investigations, decisions and outcomes must be documented appropriately while respecting privacy, confidentiality and anonymity. Workers who raise grievances—including those related to discrimination, violence or harassment—must not face any form of penalty, intimidation or discrimination as a result.

The individuals responsible for managing and assessing grievances should be selected sensitively and in a way that ensures appropriate gender balance. Workers must also be allowed to be accompanied by a representative if they request it. Deductions from wages must never be used as a disciplinary measure unless explicitly permitted by national law.

PREVENTION OF CHILD LABOUR

The definition of ‘child labour’ set out in the United Nations International Labour Organisation Minimum Age Convention (138), and as set out below, must be adopted.

‘A child is defined as any person less than 15 years of age unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply. Child labour is therefore any work by a child younger than this age and any work that is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, moral or social development.’

The group, entity or facility must uphold the highest standards of child protection and ensure that no form of child labour is present in its operations or supply chain. In line with the ILO Minimum Age Convention (138), a child is defined as anyone under the age of 15, unless national law sets a higher minimum age for work or compulsory schooling, in which case the higher age applies. Any work undertaken by a child below this age, or any work that is hazardous, interferes with schooling, or harms a child’s physical, mental, moral or social development, is strictly prohibited.

The minimum age for any form of employment must therefore be at least 15, or the age at which compulsory schooling ends—whichever is greater. For hazardous work or work carried out in dangerous conditions, the minimum age is 18. Under no circumstances may the organisation engage in or support child slavery, debt bondage, trafficking, forced child labour or the use of children in armed conflict.

Certain forms of vocational training or educational work may be permitted, but only where they are formally approved by the competent authority and form an integral part of a recognised education or training programme. These programmes must be designed to support learning and development, not to replace adult labour or expose children to harm.

If a child is found to be engaged in child labour, the organisation must take immediate steps to transition the child into quality education or vocational training. This transition should consider the social and economic impact on the child and their family and include measures to provide suitable alternatives. The organisation should also review the root causes that allowed child labour to occur and strengthen controls to prevent recurrence.

Where children are legally present in the workforce, for example, in approved training programmes, policies must ensure that their combined time spent on school, transport and work does not exceed ten hours per day, and that they are never employed during school hours.

All policies and procedures relating to child labour must be clearly communicated to employees and other relevant stakeholders to ensure full understanding and compliance.

PREVENTION OF FORCED LABOUR

Human trafficking is the movement of an individual across international borders or within a country and can result in forced labour. Companies will be held accountable if they source goods and/or use services provided by exploited workers. Relationships with third party recruitment agencies should be monitored as they expose a group/company/facility to the risk of human trafficking.

The Universal Declaration of Human Rights states ‘no-one shall be held in slavery or servitude’ and ILO Convention 29 defines forced or compulsory labour as ‘all work or service which is exacted from any person under the menace of any penalty and for which said person has not offered himself voluntarily…’. This requirement and definition must be adhered to at all times.

The selection and recruitment of workers must be carried out to industry-wide standards and there should be no forced, bonded or involuntary prison labour.

Where the facility employs contract or auxiliary workers, they must demonstrate they have vetted the recruitment agency to ensure workers do not incur commission fees or any other fees in connection with an offer of employment.

Workers should not be required to lodge deposits or identity papers with their employers and they should be free to leave their employer after reasonable notice at which point all necessary documentation and assistance should be given to them.

Where the facility operates hostels for workers, these workers (and their dependants, as applicable) should have reasonable freedom of movement within the accommodation to come and go.

The entity shall provide effective training to relevant employees to identify and address risks of human trafficking in its own business and in its supply chain.

Risks of human trafficking within the company, from suppliers, contractors and through recruitment agencies, shall be assessed and addressed during the selection and recruitment process.

The Entity shall have processes to identify human trafficking activities internally and/or within third party recruitment agencies employed by the entity.

The entity shall take measures to identify and address human trafficking risks in its supply chain.

The entity shall meet all relevant and applicable legislative requirements with respect to human trafficking, such as the Modern Slavery Act 2015 (UK).

HUMAN RIGHTS DUE DILIGENCE

Groups, entities and facilities have a responsibility to respect the human rights of all people they encounter, including employees, contractor and supplier workers, customers and communities. At a minimum, this responsibility covers internationally recognised human rights as expressed in the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. To support this, each organisation shall maintain a documented human rights policy, endorsed at the highest level, applicable to all individuals it encounters. The policy must demonstrate commitment to internationally recognised human rights, including the UN Guiding Principles on Business and Human Rights, clearly set out how the organisation respects human rights and addresses adverse impacts, be publicly available, and be communicated internally and externally to personnel, business partners and other relevant stakeholders.

All employees and workers must be equipped to understand the organisation’s human rights policy and how it applies to them, including issues such as human trafficking, harassment, discrimination and any form of physical, sexual, racial, religious, psychological or verbal abuse. The organisation shall ensure that all workers—permanent, temporary and contractor—are treated with fairness, equality, respect and dignity, and shall give particular attention to individuals or groups who may be marginalised or at heightened risk of adverse human rights impacts.

Organisations shall establish appropriate human rights due diligence processes to identify, prevent and mitigate actual or potential adverse impacts across their workforce, geographic areas, business activities and business relationships. These processes must be reviewed annually and updated as required, either as part of the broader management systems review or as a stand alone activity. Due diligence shall give equal consideration to civil and political rights—such as freedom of association, privacy, non discrimination, the right to life and freedom from inhuman or degrading treatment—and to economic, social and cultural rights, including adequate living standards, just and favourable working conditions, and safe and healthy workplaces. This work should include risk assessments conducted by qualified personnel, review of publicly available information, engagement with civil society organisations and interviews with stakeholders. Meaningful consultation with potentially affected groups and other relevant stakeholders must form part of the due diligence process, proportionate to the size, nature and context of the organisation’s operations.

Organisations shall avoid directly or indirectly causing or contributing to adverse human rights impacts and shall seek to prevent, mitigate and remediate impacts linked to their operations, products or services through their business relationships. Where adverse impacts are identified, they must be addressed with due consideration to the organisation’s level of contribution. This includes consulting affected groups to agree mitigation and remediation measures, ceasing or modifying contributing activities, and using best endeavours to influence business partners where appropriate. Organisations shall support legitimate remediation processes, implement corrective actions to prevent recurrence, and track and communicate annually to stakeholders how adverse human rights impacts have been addressed.

All affected groups and stakeholders, including employees, contractors, suppliers and communities—must have access to an independent, appropriate, confidential and effective grievance mechanism. This mechanism must be transparent and structured, allow free of charge submissions without fear of reprisal (including anonymous submissions via third parties), include systems for reporting, classifying, investigating and managing complaints, establish clear accountabilities, ensure outcomes are communicated to relevant stakeholders, ensure all affected groups know how to access it, include monitoring and evaluation measures to assess effectiveness, and retain appropriate records of investigations and outcomes.

No worker shall be subjected to any form of physical, sexual, racial, religious, psychological, verbal or other discriminatory harassment, abuse, intimidation or degrading treatment, with particular attention to those at heightened risk of vulnerability or marginalisation. Armed security personnel shall only be used where no acceptable alternative exists to manage risk or ensure personal safety. Policies and procedures for security personnel must ensure respect for human rights and dignity and require the use of minimum force proportionate to the threat. Security staff, managers and other key personnel shall receive regular training on human rights policies and procedures, including recognising and responding to risks, threats or abuses, with particular attention to vulnerable groups and issues such as workplace gender based violence and sexual harassment.

Human rights performance shall be considered in investment decisions and in the selection of suppliers and contractors. Where an organisation provides private security services to the jewellery supply chain, it must be a certified member of the International Code of Conduct Association (ICoCA).