SUPPLIER CODE OF CONDUCT

05.2023

TABLE OF CONTENTS
1. RICHEMONT RESPONSIBLE SOURCING PRINCIPLES

2

2. GENERAL REQUIREMENTS

3

3. LABOUR PRACTICES AND HUMAN RIGHTS

5

4. ENVIRONMENT

8

5. APPLICATION AND IDENTIFICATION OF CONCERNS

10

6. RESPONSIBLE SUPPLY CHAIN CRITERIA11

SUPPLIER CODE OF CONDUCT ACKNOWLEDGEMENT OF TERMS

14

1.	RICHEMONT RESPONSIBLE SOURCING PRINCIPLES
Richemont owns several of the world‘s leading Maisonsand companies in the field of luxury goods andhas a long-standing commitment to doing business
responsibly.

outlined below, they are advised to contact theirrelationship manager.
To ensure that the requirements of this Code of
Conduct are consistently met and that adhering to
it can be verified, we expect our suppliers to put inplace appropriate management systems and businessprocesses. Suppliers acknowledge that we may
conduct monitoring visits or require third party audits
to both verify compliance and support continuous
improvement. In all circumstances, in the event ofcontradiction between the translated versions of the
Supplier Code of Conduct, the English version shallprevail in the case that any legal disputes arise.

Richemont’s Movement for Better Luxury, as definedin our Group’s CSR (Corporate Social Responsibility)
strategy, aims to create benefits for all. We aspire to
improve the way luxury is created in a manner which
is more sustainable and responsible. We aim to create
a positive impact for the many different stakeholders
involved in Richemont’s value chain.
•	We are committed to improving sustainability
in our supply chains through the following
commitments:

1.1 SUSTAINABLE DEVELOPMENT GOALS (SDGS)•	Securing responsible practices throughout our
supply chains and sourcing activities.

The SDGs set by the United Nations in 2015 define
global priorities and aspirations for 2030. Richemont iscommitted to supporting the SDGs through its businessactivities and asks its suppliers also to do their bestby putting the world on a sustainable path. At the
beginning of each chapter, you will find which SDGs will
be influenced positively by complying with the relevant
requirements.

•	Implementing transparency and traceability in
raw material sourcing.
•	
Embedding care for the environment in ouroperations and business decisions.
•

Delivering positive social impact.

We need the involvement of our suppliers to achieve oursourcing commitments. We therefore require that our
suppliers adhere to this Code of Conduct, and ensure
their operations comply with the relevant principles.
We also expect that our suppliers communicate
and require their own contractors and vendors toincorporate these principles into their business policies
and practices.
We expect our suppliers to comply with the principles
stipulated in the:•	Conventions of theOrganization (ILO).

International

1.2 READING INSTRUCTIONS
We request our suppliers to carefully read this Code.
Sections 1 to 5 are applicable to all suppliers. Section
6 summarises the Responsible Supply Chain criteria
applicable to the suppliers of our raw materials andcomponents. Once you have taken notice of theapplicable requirements, you must acknowledge theterms on the last page. Clarification for specific terms
may be found in the Richemont glossary.

Labour•Universal Declaration of Human Rights (UDHR).

•

United Nations Global Compact (UNGC).

•	Convention on the Elimination of all forms ofDiscrimination Against Women (CEDAW).
•	
Organisation for Economic Co-operation
and Development (OECD) Guidelines forMultinational Enterprises.
For the purposes of this Code, any references toRichemont shall also apply to its individual Maisonsand operating entities. If suppliers have any questions
relating to how to apply the principles and practices

2022 Richemont Supplier Code of Conduct2

2. GENERAL REQUIREMENTS

2.1	GENERAL LAWS & REGULATIONS

Suppliers must put in place a non-retaliation policy toprotect employees voicing a concern, or refusing toengage in an act of bribery or corruption.

Suppliers shall comply with all applicable laws andregulations relating to their activities and the countries
in which they operate. In doing so, suppliers must put
in place appropriate systems and controls to ensure
continued compliance.

2.4 ANTI-MONEY LAUNDERING
Richemont will not tolerate money laundering or thefinancing of terrorism.

Where there are differences or conflicts between thisCode of Conduct and local laws and regulations, thehigher standard should always prevail. Richemont has
put in place its own standards aimed at protecting
and valuing its employees. These include equalityand diversity, health and safety, acting with integrity(including anti-bribery and corruption, anti-money
laundering, human rights compliance, financialtransparency, environmental protection, etc.), andmaintaining the trust of clients and stakeholders(including competition and antitrust, data protection
and privacy etc.). These standards are reflected in thisCode of Conduct.

Suppliers must implement Know Your Counterparty(KYC) procedures to ensure that business associates
and customers are not involved in any form of criminal
activity.

2.5 COMPETITION & ANTITRUSTSuppliers must strictly comply with competition laws(also known as antitrust laws), which promote free andfair competition around the world.
Suppliers must ensure they do not engage indiscussions or activities (e.g. at trade associations orwith competitors) that would lead to the allegation orappearance of improper, anti-competitive behaviour.

2.2 BUSINESS INTEGRITY
Richemont’s culture and philosophy is based on the
beliefs of integrity, honesty and respect.

2.6 DATA PROTECTION & PRIVACY

We encourage our suppliers to establish their own
policies that share our culture and philosophy.

Suppliers shall comply with their obligations under
all relevant data protection and privacy laws andregulations. In doing so, suppliers shall implement
appropriate technical and organisational measures
to protect any personal data they possess against
unauthorised or unlawful processing, and against
accidental loss, destruction, damage, alteration, ordisclosure.

Suppliers shall act with integrity and promote trust by
ensuring that their business conduct contributes tocredible, stable and sustainable business relationships.

2.3	ANTI-BRIBERY & CORRUPTION
Suppliers shall comply with all laws and regulations, andany related standards, that are relevant to avoiding
bribery and corruption in all countries in which they
conduct business.

Where suppliers process personal data on behalfof Richemont, they will do so in accordance with
our written instructions, and enter into any relevant
data processing agreement required to ensure thatsuch processing is compliant with all relevant dataprotection laws and regulations. Where necessary,
Data Protection Impact Assessments (DPIAs) shall becompleted to analyse, identify, and minimise the dataprotection risks of any relevant project or engagement.

Suppliers must neither be involved nor implicated, in
any way, in any act of corruption for either their own
benefit or that which could compromise the makingof objective and fair business decisions. Suppliers musttake steps to ensure that improper payments are
not offered or made, or solicited or received, in the
conduct of their business.

2022 Richemont Supplier Code of Conduct3

2.7 PRODUCT & TRADE COMPLIANCE

Suppliers shall be ready to provide the relevant data
to establish a life cycle analysis of the offered service
or product.

To protect our customers, employees and all otherstakeholders, and fulfil our obligations to protect theenvironment, our suppliers should have a conformity
assessment in place to ensure compliance of the
products supplied to Richemont. The Conformity
Assessment (as defined in ISO/IEC 17000 – 2020) is
made against the relevant and applicable productregulations and industry standards. Likewise, whereapplicable, the supplier should maintain, and makeavailable on demand, the related proofs of conformity
and other supporting documents associated with the
product and its Conformity Assessment (Test Reports,
Declaration of Conformity, Certificates of Conformity,
Bill of Materials, Safety Data Sheets, User Guides, etc.).

2.10 TRANSPARENCY AND TRACEABILITY
On one hand, Richemont defines transparency as the
mapping of its supply chains in order to understandhow these look like and how these operate. The
concept is based in the close business relation that has
been developped with suppliers throughout the years.
On the other hand, traceability is defined as the tools
and processes in place to verify the stage that each ofRichemont’s products is going through, so sustainability
claims associated with commodities and products,
can be verified ensuring good practice all along the
supply chain.

Suppliers shall conduct their operations in fullcompliance with all applicable international trade
rules and related standards, including but not limited
to customs regulations, non-tariff barriers, international
agreements, transportation conventions, trade andeconomic sanctions, and anti-boycott rules.

All of Richemont’s suppliers shall actively engage their
supply chain to increase both transparency and thetraceability of the products therein.

Suppliers shall assess risks and implement measures
to ensure the safety and security of employees,
contractors and visitors in their operations.

Whenever possible, suppliers shall identify and trace
the history, distribution, location, and application of
products, parts, and materials, as much as identify
the name and location of all actors in the upstream
supply chains until the origin of the raw material. In thissense, any changes regarding the name and locationof supply chain actors shall be notified to Richemont.

Suppliers shall ensure that all security personnel respect
the human rights and dignity of all people and aretrained on the issue.

In the sustainability context, traceability shall be robust
and verifiable. Suppliers shall provide traceability
records and information upon Richemont’s request.

2.8 SECURITY

Suppliers shall ensure the physical integrity and securityof people and cash-convertible valuables in theiroperations and during transportation to or from theiroperations to avoid the encouragement of fraud,crime and related anti-social behaviour.

2.9 SUSTAINABLE PRODUCT DEVELOPMENT
Suppliers are encouraged to factor appropriate
environmental and social considerations into the fulllifecycle of their processes, technologies, products
and packaging in order to optimise the environmental
performance of their products through the productlife cycle, and to maximise opportunities for positivesocial impact. Where feasible, products, packaging
and packing shall be designed in accordance withcircular economy principles such as eco-design & ecoefficiency (including aspects of recyclability, waste
reduction, and reusability, to limit the use of resources),and avoid planned obsolescence.

2022 Richemont Supplier Code of Conduct

43. LABOUR PRACTICES AND HUMAN RIGHTS

3.1 HUMAN RIGHTS

colour or ethnic origin, nationality, religion, age, disability,
sexual orientation, gender identity, pregnancy, maternity,
paternity, health status, social background, politicalaffiliation or union membership.

Suppliers shall respect all international human rights norms
and commit to implementing the requirements containedin the United Nations Guiding Principles on Business andHuman Rights.

Suppliers shall:

Suppliers shall avoid causing or contributing to adverse
human rights impacts through their own activities andaddress such impacts when they occur. Suppliers shall alsoseek to prevent or mitigate adverse human rights impacts
that are directly linked to their operations, products,
or services, even if they have not contributed to those
impacts.

• 	Provide appropriate human rights training to all
employees.

Suppliers shall provide all information reasonably requiredby Richemont as part of its human rights due diligenceprocess. As part of this due diligence, Richemont requires
suppliers (as appropriate to their size) to have in place:•	Recognise the importance of a balanced workforce
where diversity is valued as a source of enrichment
and opportunity.

•	Ensure no discrimination or harassment, physical or
psychological violence.
•	Promote equality of opportunity and inclusion for all
employees through policies and practices.

• 	
Strong management systems addressing humanrights compliance, including a publicly available
policy commitment to meet their responsibility torespect human rights.

3.3	NO HARSH OR INHUMAN TREATMENT
Suppliers shall prohibit physical abuse or discipline,
the threat of physical abuse, sexual or other forms ofharassment including gender-based violence, and verbal
abuse or other forms of intimidation, according to thedefinition of ILO Convention 190.

•	A process to identify and assess human rights risks
and impacts.
•	
A strategy to respond to identified human rights
risks, including adequate training.

Suppliers shall:• 	Not make use of or condone such practices.

•	A process to enable the remediation of any adverse
human rights impacts they cause or to which they
contribute, and to track responses.

•	
Clearly communicate applicable disciplinary
processes and procedures to employees.
•	Ensure that grievance procedures and investigation
processes are in place and communicated to all
employees.

•	A program to evaluate, either through third-party orinternal audits, the compliance with human rights
of both their operations and the operations of their
suppliers.
•	Communication with stakeholders on steps taken to
respect human rights and prevent modern slavery.

3.4 FREELY CHOSEN EMPLOYMENTSuppliers shall not use forced labour, including bonded,indentured, or involuntary prison labour, or engage
in any form of modern slavery or human trafficking.
Workers are not required to lodge ‘deposits’ or theiridentity papers with their employer, and are free to leave
their employer after reasonable notice. Suppliers shallmonitor relationships with recruitment agencies for risks ofhuman traffic.

3.2 NO DISCRIMINATION
People shall be treated equally and fairly. Suppliers may
not engage in any form of discrimination. Particularly (butnot exclusively) regarding wages, hiring, access to training,
promotion, or caregiver protection based on sex, race,

2022 Richemont Supplier Code of Conduct4

3.5 CONTRACTUAL AGREEMENTS

Suppliers shall compensate overtime hours at regularor premium rates, according to applicable legal
requirements.

Suppliers and their subcontractors must establish in writing
the terms and conditions of their employees’ agreements
and work contracts. The conditions of the employment
contracts should follow the most stringent international
standards and laws that are currently in force. Said work
agreements must promote stable employment and will
not violate the rights of employees that are protected by
the applicable laws.

Deductions from wages as a disciplinary measure shallnot be permitted, nor shall any deductions from wages
not provided for by national law, without the express
permission of the worker concerned.

3.8 WORK HOURS

Suppliers must not employ any workers who do not havethe right to work, including illegal immigrants. There shallbe no instances of subcontracting or home working
without the prior written permission of Richemont.

Suppliers shall ensure normal working hours comply with
ILO conventions, as well as with national legislation or theprevailing industry standards.
Suppliers shall:• 	Ensure normal working hours shall not on a regularbasis exceed a maximum of 48 hours per working
week.

3.6 NO CHILD LABOUR
No person shall be employed under the age of 15, oran age lower than the local minimum age for employment
and completion of mandatory education, whicheveris highest.

•	The total hours worked in any 7-day period shallnot exceed 60 hours, except in exceptional
circumstances where all of the following criteria
are met:

The employment of juvenile workers below the age of
18 shall only occur if the supplier has special proceduresin place for young work. These procedures shall include
the prohibition of hazardous work conditions, night work,
working hours not allowing completion of mandatory
education, and guaranteeing protection for the healthy
physical and mental development of the child.

o	This is allowed by national law.
o	This is allowed by a collective bargaining
agreement.
o	Appropriate safeguards are taken to protect
workers’ health and safety.
o	The employer can demonstrate thatexceptional circumstances apply, such as
unexpected production peaks, accidents, or
emergencies.

3.7 WAGES AND BENEFITS
Wages and all legally mandated benefits (e.g. medical
insurance, social insurance, pensions, and so on) paid
for a standard working week must meet, at a minimum,
national legal standards or industry benchmark standards,
whichever is highest. For piece-rate workers, their working
day shall give at least the equivalent of a minimum
day-wage.

•	Overtime shall be voluntary and be compensatedat a premium rate.
•	Weekly rest and paid annual leave in accordancewith (at a minimum) national legislation andapplicable sector regulations will abide by all
legally mandated provisions for leave, including
maternity, paternity, and compassionate leave.

Wages should always be enough to meet basic needs
and to provide some discretionary income. This means
suppliers should promote living wages. A living wage
is a remuneration received by a worker for a standard
working week, sufficient to afford a decent standard ofliving for the worker and their family.

•	Workers shall be provided with at least one day off
in every 7-day period.

Suppliers shall ensure equal remuneration for work ofequal value according to the Equal Pay International
Coalition (EPIC).

3.9	
FREEDOM OF ASSOCIATION AND COLLECTIVEBARGAINING
Suppliers shall allow workers to freely choose to join or notjoin a workers’ association of their choice.

Before they enter employment, all workers shallbe provided with written and understandable terms andconditions with regards to their wages for the defined
pay period.

2022 Richemont Supplier Code of Conduct

Suppliers shall:•	Adhere6toapplicable

laws

and

collective

bargaining agreements where such agreements
exist.

standards and allows for privacy, security, and genderseparation.

•	Support parallel means of dialogue such as
the implementation of collective employee
representation, and robust and effective dialogue
between management and employees wherelaws prohibit or limit these freedoms.

Suppliers shall take the appropriate measures to protect
pregnant and nursing women, as well as young people(e.g. apprentices).
Suppliers shall investigate all occupational health andsafety accidents involving their employees and workers
to identify the root causes and determine the necessary
corrective actions to prevent reoccurrence.

3.10 HEALTH AND SAFETY

Suppliers must put in place appropriate procedures
regarding occupational health and safety, keep them
up-to-date and make sure they are communicated.

Suppliers shall comply with all applicable health and safety
laws and regulations by providing a safe and healthy
working environment and assign responsibility for healthand safety to a senior management representative.

3.11 COMMUNITY IMPACT

Suppliers shall have a process in place to identify thehealth and safety risks associated with their operations,determine the relative significance for each risk, andimplement the appropriate risk mitigation actions.
Workers shall be informed of these significant risks to theirhealth and safety.

Suppliers shall respect the communities in which they
operate. Richemont encourages suppliers to make apositive social impact in the related communities bycontributing to their social, environmental and economic
welfare.

Workers shall receive regular and recorded health andsafety training, and such training shall be repeated for
new or reassigned workers.
Suppliers provide all their employees and workers witha safe and healthy workplace that guarantees basic
safety and adequate emergency procedures andphysical requirements, including fire alarms, exits, andemergency drills, free personal protective equipment,
safety equipment, and training appropriate to the task,
as well as access to emergency medical care.
Workers must have access to water that is safe to drink,adequate sanitation, including gender-specific restrooms
and facilities, and, where relevant, safe and hygienic
accommodation which meets the highest industry

2022 Richemont Supplier Code of Conduct

7

4.	ENVIRONMENT

4.1 ENVIRONMENTAL MANAGEMENT & COMPLIANCE

4.3	ENERGY USAGE AND GREENHOUSE GAS(GHG) EMISSIONS

Suppliers shall comply with all applicable environmental
laws and regulations.

Suppliers shall monitor their energy consumption and takeactions to reduce greenhouse gas emissions and combat
climate change.

All required environmental permits, licences, information
registrations and restrictions shall be obtained, and theiroperational and reporting requirements followed.

They shall:

Suppliers should use appropriate methodologies to
identify and assess the risks of harm in their own operations
and those of their business partners, and carry out riskbased due diligence.

•	Collect and record data linked to their carbon
footprint and provide data to Richemont uponrequest.
•	Establish plans and targets to continuously reduce
the greenhouse gas emissions of their activities.

Suppliers shall:• Identify and assess risks.

•	Demonstrably increase the use of renewableenergy.

•	Identify opportunities to reduce the environmental
impact and promote, where feasible, partnerships
for climate protection.

4.4 WATER•	Take measures to prevent and mitigate
environmental risks and impacts (especiallyclimate change, see chapter 4.3).

Suppliers shall have sustainable water management
practices in place.
•• Have a methodology to track and monitor.

•	Collect and record water data and provide
data to Richemont upon request.

•	Have necessary communication in place with therelevant stakeholders.

•	
Establish plans and targets to reduce andrecycle water.

•	Providetraining
and
information
about
environmental risks and controls to all relevant
employees, in a format and language they caneasily understand.

Wastewater shall be treated and purified to respect local
legislation and prevent pollution.
Suppliers located in water-scarce regions shall have strong
water management systems in place and collect data
(e.g. water withdrawals, water consumption, wastewaterand recycled water) to minimise adverse impacts to the
local community.

4.2	RESOURCE REDUCTION AND POLLUTION
PREVENTION
We ask our suppliers to do their best to continuously
minimise their resource consumption (e.g. fossil fuels, fossilfuel based virgin plastics, water and virgin forest products)
and environmental impact (e.g. emissions, pollutants andwaste). We ask our suppliers to promote the circular useof raw materials.

4.5 WASTE
Suppliers shall prevent pollution and identify significant
sources of waste and manage the identified waste
responsibly.

Emissions and discharges of pollutants and generation ofwaste are to be minimised or eliminated at the source, orby practices such as adding pollution control equipment,
modifying production and maintenance processes, or byother means.
2022 Richemont Supplier Code of Conduct

They shall:

Suppliers shall:•	Collect and record data linked to waste
production and provide data to Richemont uponrequest.
8

4.7 BIODIVERSITY•	Establish plans and targets to reduce and recycle
waste, and apply where feasible circular economy
principles (reduce, reuse, recycle and recover).

Suppliers shall avoid and minimise impacts on biodiversity.
Suppliers shall seek opportunities
conservation linked to their activity.

•	
Dispose of waste in compliance with theapplicable laws or, where such laws do not exist, inline with international standards.

biodiversity

Suppliers shall make their best efforts to generate positive
impact on biodiversity and the livelihoods of local people.

• Do their best to prevent waste going to landfill.

Suppliers in the mining sector shall not explore or minein World Heritage sites. They shall identify Key Biodiversity
Areas (according to the IUCN Global Standard for theidentification of Key Biodiversity Areas) affected by theiroperations and have mitigation tools in place to minimise
impacts on biodiversity.

4.6 CHEMICALSSuppliers shall comply with all applicable laws andregulations regarding the restriction and registration and,
where necessary, authorisation or notification of chemical
substances contained in the end product or production
process, according to the statutory requirements that
apply to the corresponding market (e.g. EU REACH
regulation).
In addition, suppliers shall adopt new processes andbest practices, to reduce the environmental impact andhealth and safety concerns relating to chemical use.
Suppliers shall maintain an inventory of hazardous
substances at their facilities. Safety data sheets (orequivalent) shall be accessible wherever hazardous
substances are used. Chemicals shall be correctly
labelled and their associated risks shall be clearly andactively communicated to all employees who workwith them.

2022 Richemont Supplier Code of Conductfor9

5. APPLICATION AND IDENTIFICATION OF CONCERNS

5.1 GENERAL COMPLIANCE

5.3 EVALUATION

Richemont expects its suppliers to communicate theprinciples of this Code of Conduct to their employees,
subcontractors and relevant third parties with whomthey do business, and to ensure said principles areintegrated into the respective operations.

Richemont will be entitled to request information fromits suppliers as to their compliance with the terms of thisCode of Conduct.
Where necessary, Richemont may require suppliers
to provide evidence of their compliance by way of
independent verification or appropriate certification.

Suppliers shall proactively report any existing or
potential issues they have with the requirements set
out in this Code of Conduct, along with their proposed
remediation plans for consideration by Richemont.

Richemont reserves the right to have products andmaterials independently tested to establish whether
the suppliers comply with the terms of this Code of
Conduct.

5.2	REPORTING CONCERNS & SPEAKING UP

Richemont will be entitled to request data and to visit
suppliers’ production facilities and the facilities of theirown subcontractors and suppliers, or have these visitedby an independent third-party verification company,
to establish compliance with this Code of Conduct.

Suppliers shall have in place systems to enable
independent grievance and speaking up measures
to allow employees, subcontractors and relevant
third parties to report actual or suspected misconduct
anonymously without threat of reprisal, intimidation orharassment.

5.4 NON-COMPLIANCE

Suppliers must take all reported concerns seriously andensure that they will be addressed in a fair, honest, andtimely manner respecting confidentiality requirements.

Richemont reserves the right to terminate any business
relationships with any supplier that violates this Code of
Conduct, or whose suppliers or subcontractors violate
this Code of Conduct. In case violations are uncovered,
Richemont will work with the supplier to find appropriate
remediation and leverage for improvement, in the first
instance.

Suppliers shall investigate and take corrective action if
needed, and record them.
Concerns about work being done on behalf ofRichemont, or suspected misconduct with regard to thisCode of Conduct may also be reported to richemont.
ethicspoint.com.

In the case where the supplier shows structural
unwillingness to cooperate and improve, ending thebusiness relationship shall be a last resort. The decision
to terminate a relationship with a supplier for Codeviolations will only be taken when steps to mitigate
negative impacts have failed or are not feasible.

Richemont will investigate any concern raised and,
where feasible, discuss findings with the supplier andrespect confidentiality requirements.

2022 Richemont Supplier Code of Conduct

10

6. RESPONSIBLE SUPPLY CHAIN CRITERIAThe requirements described in this section are
applicable to raw materials, components, and finishedgoods suppliers. They support the Richemont ambition
for a long-term sustainable supply chain, and are in
addition to the requirements of the previous sections.

by providing enough space, proper facilities
and company of the animal‘s own kind.
•	Freedom from fear and distress by ensuringconditions and treatment which avoid mental
suffering.
In addition, suppliers shall apply the Responsible
Luxury Initiative Animal Sourcing Principles as they
relate to the catching, maintaining, breeding, raising,transportation, handling and slaughter of live animals, if
applicable to the products the suppliers manufacture.

6.1 ENVIRONMENTAL MANAGEMENT SYSTEM
Manufacturing and raw material suppliers arerecommended to establish an environmental
management system (e.g. ISO 14001) to meetenvironmental compliance obligations and mitigate
impacts. Suppliers shall have an environmental action
plan and monitor their environmental impacts.

6.4 ENDANGERED SPECIESSuppliers shall fully comply with special international
and local regulations, as well as with the Convention
on International Trade of Endangered Species (CITES),
regarding the procurement, import, usage andexport of raw materials sourced from endangered orprotected species.

Manufacturing and raw material suppliers shall share
their environmental action plans with Richemont uponrequest.

6.2	RESTRICTED SUBSTANCES
Suppliers must guarantee that the products they supply
to Richemont comply with the latest version of theRichemont Product Restricted Substances List (PRSL).

6.5 DUE DILIGENCE FOR MINERALSSuppliers in the gold, silver, Platinum Group Metals(PGMs), diamonds and coloured gemstones supply
chains shall exercise and document due diligence inaccordance with the OECD Due Diligence Guidancefor Responsible Supply Chains of Minerals from ConflictAffected and High-Risk Areas, and the Richemont Raw
Materials Sourcing Policy.

Richemont requires its suppliers to make sure that theirown supply chain incorporates these regulations into
their own business policies and practices.

6.3 ANIMAL WELFARE
Suppliers shall treat animals well and respect the Five
Freedoms of Animal Welfare:

Small and medium-sized enterprises (SMEs) shallconduct due diligence appropriate to their size andcircumstances, but which includes, at the least, a
policy, a fit-for-purpose due diligence process, and aprocess to enable remedy. Richemont may support
SMEs in their due Diligence processes. In such cases,
access to supply chain information is necessary.

• 	Freedom from hunger or thirst by ready accessto fresh water and a diet to maintain full healthand vigour.
•	
Freedom from discomfort by providing anappropriate environment including shelter anda comfortable resting area.
•	
Freedom from pain, injury or disease by
prevention or rapid diagnosis and treatment.
•	Freedom to express the most normal behaviour

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11

6.6	GOLD, SILVER AND / OR PLATINUM GROUP*

6.8 COLOURED GEMSTONES

Suppliers in the gold, silver and PGM supply chain are
required to become certified with the Responsible
Jewellery Council’s (RJC) Code of Practices. Other
standards will be considered if their equivalence canbe clearly demonstrated.

Suppliers in the coloured gemstones supply chain shallprovide assurance as far as possible that gemstones
are mined and processed in ways that respect humanand labour rights, are conflict-free and do not inflict
environmental damage.

Suppliers shall provide assurance as far as possiblethat gold, silver and / or PGMs being supplied havebeen recycled or mined responsibly in a manner that
respects human and labour rights, is conflict-free, anddoes not inflict environmental damage.

Suppliers shall actively engage their supply chain to
increase transparency and implement a due diligenceprocess. To do so, they are encouraged to use the tools
provided by the Gemstones and Jewellery Community
Platform.

6.7 DIAMONDS*

Suppliers in the coloured gemstones supply chain arestrongly encouraged to become certified with the RJC
Code of Practices. Other standards will be considered
if their equivalence can be clearly demonstrated.

Suppliers in the diamond supply chain are required
to become certified with the RJC Code of Practices.
Other standards will be considered if their equivalence
can be clearly demonstrated.

Suppliers shall provide full and complete disclosure of
the physical characteristics of the stones (including
detailed information on treatments), in compliancewith national and international laws and industry bestpractice.

Suppliers shall adhere to the Kimberley Process
Certification Scheme (KPCS) and the World DiamondCouncil (WDC) voluntary systems of warranties,
thepurposes of which are to promote universal
standards on human rights, labour rights, anti-money
laundering and anti-corruption practices. Suppliers shallconfirm on every invoice the WDC warranty statement.

6.9 LEATHER AND FUR• 	Provide only natural, non-treated diamonds fromlegitimate sources that strictly conform to our
specifications regarding quality and naturality.

We strongly encourage leather suppliers to reduce theenvironmental impact of the sourcing of bovine skins(prefer local origins). Suppliers must be aware of their
indirect impact on deforestation and actively work
to not contribute to it. Richemont reserves the right toobtain information on deforestation risks.

• 	Provide full and complete disclosure of thephysical characteristics of the stones, incompliance with national and international laws
and industry best practice.

Leather suppliers are strongly encouraged to haveenvironmental certification in place (e.g. ISO 14001,
LWG), and to implement actions to reduce theenvironmental impact of the tanning processes.

Suppliers that are engaged in the cutting andpolishing of diamonds shall use cobalt-free, diamondimpregnated scaifes.

Crocodilian skins shall be preferably sourced from farms
certified with the ICFA standard.

Suppliers shall:

Suppliers shall provide Richemont, in addition to thecountry of origin (husbandry), with information on thelocation of the slaughterhouse and the location of thetannery on request.

Where Richemont has purchased diamonds for
suppliers to use in products supplied to Richemont,
suppliers shall exclusively use those diamonds and not
substitute them.

Fur shall only be sourced if animal welfare can be
guaranteed through robust supply chain verification
or recognised international certification schemes (e.g.
WelFur). The use of recycled fur shall be promoted.

* The requirements for the RJC certification included in paragraphs 6.7 and 6.8 are to be considered as an encouragement for suppliers ofRichemont’s Online Distributor businesses (such as, for example, YOOX NET-A-PORTER GROUP and Watchfinder & Co.).

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6.10 FOREST PRODUCTS•	Synthetic fibres should preferably come fromrecycled or bio-based sources (bio-based sources
shall come from waste-based feedstock, otherwise
it must be evidenced that the raw material does
not compete with food or feedstock production,
nor contribute to deforestation, e.g. Content Claim
Standard);

Suppliers shall ensure that their actions have no
negative impact on forests.
Suppliers shall put in place measures to ensure that noillegal forest products are placed in the supply chain,and comply with applicable regulations (e.g. EU timber
regulations).

•	Wool should comply with the Responsible Wool
Standard, or equivalent. Sheep mulesing is aforbidden practice.

Suppliers are requested to source paper, packaging,and other timber-based products in a responsible
manner, either recycled or from certified, sustainably
managed forests. Any forestry-sourced product mustbe certified by the Forest Stewardship Council (FSC).

•	
Down should comply with the Responsible
Down Standard, or equivalent. For down andfeathers, live plucking is strictly forbidden.

Where necessary, suppliers conduct due diligence on
their own suppliers.

6.13 PLASTICS
Suppliers shall not provide any products containing
PVC. In addition, suppliers shall do their best to reduce
the environmental impact of plastics by:

6.11 FRAGRANCES
Suppliers involved in the perfumes and cosmetics
industry shall ensure that the fragrance compounds,
formulae, packaging components or finished products
they supply are safe for their intended use, and comply
with all applicable laws worldwide, to the best of theirknowledge.

•

Avoiding harmful plastics (e.g. ABS, PS and PU).

•	Reducing to a minimum virgin fossil fuel-based
plastic.

Alcohol used shall be from natural origin only.

•	
Using recyclable and increasing the use ofrecycled plastics (e.g. GRS-certified).

Glass used shall preferably be from post-consumer
recycled origin.

•	Extending the life of and improving the end-oflife management of plastic.

6.12 TEXTILES
Suppliers shall have high standards of environmental
stewardship. They shall especially:•

Use water efficiently and responsibly.

•	Promote the protection and restoration of
biodiversity, and ensure no detriment to natural
ecosystems.
Suppliers shall do their best to work towards a moresustainable fashion system. Materials shall be of highquality and Richemont encourages its suppliers tocontinuously work towards the following criteria:•	Organic (e.g. Global Organic Textile Standards)
or recycled (e.g. Global Recycled Standard,or GRS) material is preferred.
•	Natural fibres shall preferably be sourced fromorganic origin.
•	
Artificial fibres shall come from FSC-certified
sources, or be produced in a closed loop
production system.

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SUPPLIER CODE OF CONDUCTACKNOWLEDGEMENT OF TERMS
Company name:

Address:

Contact name:

Position:

Please tick the box before signing:
I hereby agree to have read and accepted the terms of the Richemont Supplier Code of
Conduct and the relevant requirements for the sector of my activity.

By authorised signatories, with company stamp when applicable:

Date:2022 Richemont Supplier Code of Conduct

15