HUMAN RIGHTS POLICY
Bulgari is committed to respecting all Human Rights within its own operations
and to promoting the adherence to the same Human Rights standards amongits contractors, suppliers and business partners.
Bulgari commits to comply with all applicable laws and actively disseminates
the principles established by the national and international regulations andstandards, including:• Universal Declaration of Human Rights;• International Covenant on Civil and Political Rights;• International Covenant on Economic, Social and Cultural Rights;• International Labour Organisation (ILO) Declaration on FundamentalPrinciples and Rights at Work and the core Conventions;• UN Guiding Principles on Business and Human Rights;• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals
from Conflict-Affected and High-Risk Areas.
• RJC Code of Practices.
When national legislation or other applicable regulations address the same
issue as this Human Right Policy, the highest standards or most restrictive
principles shall apply. When this Human Right Policy is in contradiction withapplicable laws, the applicable law shall apply.

OUR COMMITMENTS
Bulgari is committed to identifying, preventing and mitigating Human Rights risks
across its own operations and supply chain. Whenever adverse Human Rights
impacts are identified, Bulgari is committed to providing for, or supporting,legitimate processes to enable the remedy of any adverse Human Rights
impacts that Bulgari may have caused, contributed to cause or been linked
with. Bulgari is also committed to communicating with its stakeholders about the
Human Rights due diligence process and about how impacts are addressed.
Bulgari is committed to respecting Human Rights in its conduct, in particular as
follows:•Prohibition of child labor – Bulgari never engages in, supports or tolerates
child labour, including the worst form of child labour (as defined by ILO
Convention No.182). Work by children under the age of 16 is strictly
prohibited. In countries where local laws set a higher age for child labor orset an age higher than 16 for completion of compulsory education, thehighest age is applicable.
Any work that is likely to jeopardize children’s health, safety or morals should
not be undertaken by anyone under the age of 18.
•Prohibition of forced/compulsory labor – Bulgari condemns any use of forced
or compulsory labor as defined by ILO Convention No.29; slavery; servitude;
any form of modern slavery; human trafficking or the use of any otherconstraints.

•Prohibition of harassment and abuse – Bulgari does not tolerate andcondemns any form of corporal punishment, physical, sexual, verbal or
psychological harassment, torture, cruel, inhuman and degrading
treatment, or any other kind of abuse.

•Prohibition of discrimination – Every individual must be treated with respectand dignity. Bulgari does not engage in and tolerate any kind ofdiscrimination – in particular with regards to wages, hiring, access to training,promotion, maternity protection and dismissal – based on sex, race or ethnic
origin, religion, age, disability, sexual orientation, political affiliation, union
membership, nationality, gender identity, migrant status or social
background.

•Freedom of association – Bulgari acknowledges the right of its employees toform or take part in organizations aimed at defending and promoting theirinterests and does not interfere with their choices. It also recognizes their rightto be represented, within the various work units, by unions or other forms ofrepresentation elected in accordance with the legislations and practices inforce in the different countries of employment.

•Health and Safety – Bulgari is committed to ensuring high health and safety
standards; it promotes the dissemination and reinforcement of a safety
culture by developing risk awareness and fosters responsible behavior,including through information and training activities.

•Respect for diversity and non-discrimination – Bulgari rejects any form ofdiscrimination and is committed to promoting equal opportunities, bothupon establishment of the employment relationship and at each stage of its
performance and across its value chains.

•Business integrity – Bulgari requires exemplary integrity from its employees,
business partners and suppliers in the conduct of their business in line withprinciples of the LVMH Code of Conduct and the LVMH Supplier Code ofConduct.

SCOPE
In order to implement the commitment made in this document, Bulgari will set
up appropriate due diligence processes, at its own operations and supply chain
level, involving the relevant functions to the extent of their respective areas ofresponsibility.
To support this process, Bulgari is committed to building the awareness andknowledge of its employees and workers on Human Rights and to promoting
Human Rights awareness and respect across its value chain.
This Policy is applicable to all business activities carried out by Bulgari S.p.A. andits subsidiaries worldwide.

GRIEVANCE
Bulgari encourages open communication and dialogue within the Maison andwith its external partners, suppliers and clients (“stakeholders”).
Any Bulgari employee or external stakeholder who becomes aware of violationsor has any concerns regarding impacts that may arise from Bulgari’s direct andindirect behaviors under this Policy is invited to raise their concerns and/or askforguidance.
To do so, all employees and stakeholders can access to the LVMH Alert Line, an
online interface that provides a fully confidential and secure way of reporting ingood faith violations of the laws, regulations, principles, and policies ofconduct.
Follow this link to access the LVMH Alert Line: https://alertline.lvmh.com/
Bulgari ensures that no disciplinary sanction or any direct or indirect retaliatory
measure is taken against persons who have made use of these channels ingoodfaith, even if the facts subsequently prove to be inaccurate or unfounded
and/ordo not give rise to any proceedings or sanctions.

RELATED POLICIES AND DOCUMENTS

International references and voluntary standards:
Universal Declaration of Human Rights; International Covenant on Civil andPolitical Rights; International Covenant on Economic, Social and Cultural Rights;
ILO Declaration on Fundamental Principles and Rights at Work and the core
Conventions; UN Guiding Principles on Business and Human Rights; OECD Due
Diligence Guidance for Responsible Supply Chains of Minerals from ConflictAffected and High-Risk Areas; 2030 Agenda for Sustainable Development of theUnited Nations; RJC Code of Practices.
LVMH related codes, policies and documents:
LVMH Code of Conduct; LVMH Social and Environmental Responsibility Report.
Bulgari related policies and documents:
LVMH Suppliers Code of Conduct; Responsible Sourcing Policy for Mineral
Supply Chain; Health and Safety Policy, Bulgari Modern Slavery Act Statement;
Suppliers Risk Management Procedure.

COMMUNICATIONThis Human Rights Policy is communicated to all employees and it is publicly
available to share our values and commitments with external stakeholders.

RESPONSIBILITY AND SIGNATURE SECTION
Overall responsibility for this Policy resides with the CEO.
Signed on July 2020 by the Chief Executive Officer, Jean-Christophe Babin
Updated on May 2022 with regard to the section Grievance