Responsible Sourcing From High-Risk Countries Policy

Le petit-fils de L. U. Chopard & Cie SA (hereafter “Chopard”), based in Geneva (Switzerland), a Swiss family-run company and leading manufacturer of luxury watches and jewellery sold worldwide, is committed to a responsible approach to its business activities.

Recognising that risks of significant adverse impacts may be associated with the extraction, trade, handling and export of minerals from conflict-affected and high-risk areas, and acknowledging its responsibility to respect human rights, Chopard has committed to implementing its Responsible Sourcing from High-Risk Countries Policy (hereinafter “Responsible Sourcing Policy”) throughout its supply chains.

The Responsible Sourcing Policy sets forth Chopard’s commitments and strategy to avoid contributing to conflict or to any abuses when sourcing minerals from high-risks areas and is addressed to all Chopard stakeholders worldwide.

The Responsible Sourcing Policy is consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (hereinafter “OECD Guidance”) and is applicable to all minerals sourced by Chopard.

RESPONSIBLE SOURCING

1. Chopard commits to respecting human rights, avoiding contributing to the financing of conflict and complying with all relevant UN resolutions and laws, including sanctions.

2. Chopard will neither tolerate nor profit from, contribute to, assist or facilitate the commission of serious abuses associated with the extraction, transport or trade of minerals from conflict-affected and high-risk areas:

• any forms of torture, cruel, inhuman and degrading treatment;
• any forms of forced or compulsory labour;
• the worst forms of child labour;
• other gross human rights violations and abuses such as widespread violence;
• war crimes, violations of international humanitarian law, crimes against humanity and/or
• genocide.

3. Chopard will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals, including:

• illegally controlled mine sites or otherwise controlled transportation routes;
• illegally taxed or extorted money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or
• illegally taxed or extorted intermediaries, export companies or international traders.

4. Public or private security forces: Chopard will engage with public or private security forces in accordance with the Voluntary Principles on Security & Human Rights (a multi-stakeholder initiative composed of governments, key international non-governmental organizations, and companies). Chopard will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 2 of this Responsible Sourcing Policy or that act illegally as described in paragraph 3.

5. Bribery and fraudulent misrepresentation of the origin of minerals: Chopard will not offer, promise, give or demand bribes and will resist the solicitation of bribes to conceal or disguise the origin of minerals or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of minerals.

6. Money laundering: Chopard will support and contribute to efforts to eliminate money laundering where it identifies a reasonable risk resulting from or connected to the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.

7. To implement these commitments, Chopard conducts an effective and comprehensive risk-based due diligence process, which includes Know your Counterparts (KYC) checks to identify its upstream and downstream partners, as well as all activities recommended by the OECD Guidance, as reflected in the OECD five-step framework.

8. As a certified member of the Responsible Jewellery Council (RJC), Chopard is audited every 3 years by an independent third-party against the Responsible Jewellery Council (RJC) Code of Practices (COP), notably with respect to its human rights risk due diligence process.

9. Chopard only buys or sells diamonds that are fully compliant with the Kimberley Process Certification Scheme and the World Diamond Council System of Warranties.

10. Chopard only buys precious metals from refiners certified against the following international standards:

1. Responsible Jewellery Council (RJC) Code of Practices (COP); and
2. Responsible Jewellery Council (Chain-of-Custody).

11. Chopard commits to using its influence to prevent abuses within its supply chains. The following consequences will apply where Chopard identifies a reasonable risk that a supplier is associated with one or more of the following risks:

• Serious abuses associated with the extraction, trade and transport of minerals identified in paragraph 2 of this Responsible Sourcing Policy: Immediate suspension or disengagement.
• Direct or indirect support to non-state armed groups as described in paragraph 3 of this Responsible Sourcing Policy: Immediate suspension or disengagement.
• Direct or indirect support to public or private security forces who illegally control mine sites, transport routes and upstream actors (including illegal taxation): Temporary suspension, followed by implementation of measurable mitigative actions and monitoring. Suspension or disengagement if mitigation measures implemented are ineffective within reasonable timescales.
• Money laundering, bribery and fraudulent misrepresentation of the origin of minerals and non- payment of taxes, fees and royalties to governments: Temporary suspension, followed by implementation of measurable mitigative actions and monitoring. Suspension or disengagement if mitigation measures implemented are ineffective within reasonable timescales.

12. The Responsible Sourcing Commitments described in this Responsible Sourcing Policy are reflected in Chopard’s Code of Conduct for Partners, which requires all suppliers, dealers, agents, subcontractors and all business partners in general to adopt similar responsible sourcing practices and to comply with Chopard’s own principles and values.

13. Chopard seeks to establish long-term relationships, as appropriate, in accordance with the risk management strategy described in paragraph 11 of this Responsible Sourcing Policy.

14. Chopard commits to building capacity within its supply chains, including through training and dialogue, and to upholding the continuous improvement of suppliers’ due diligence and sourcing practices.

15. Chopard commits to supporting the formalisation, development and promotion of responsible sourcing practices within artisanal and small-scale mining (ASM) communities. Chopard exclusively purchases ASM gold from mines that are part of the Swiss Better Gold Association (SBGA) system, Fairmined or Fairtrade certification schemes.

16. Chopard has a grievance mechanism, which allows all stakeholders to voice concerns regarding the circumstances of mineral extraction, trade, handling and export associated with potential risks, described in paragraphs 1-6 of this Responsible Sourcing Policy, detailed in the Code of Conduct for Partners and in the Responsible Sourcing Programme section of Chopard’s Sustainability Webpage.

Chopard’s Head of Corporate Sustainability, in close collaboration with the Chopard Purchasing Department, is responsible for implementing the Responsible Sourcing Policy, overseeing due diligence, collecting and investigating grievances, and reporting.

Chopard commits to communicating this Responsible Sourcing Policy to all its suppliers and external stakeholders through its website. The policy statement is included in its supplier contracts and agreements.

Any questions, comments or complaints related to the above-mentioned topics and risks (Annex II of the OECD Guidance points 2-6) may be addressed (anonymously if necessary) to Chopard’s Head of Corporate Sustainability at the following address: rue de Veyrot 8, 1217 Meyrin 1, Switzerland, or via email to : info.rjc@chopard.ch.

Version 1 - August 2021