The Modern Slavery Act 2015 is designed to tackle slavery in the UK and all over the world. The bill was introduced to the House of Commons in draft form in October 2013 and it received Royal Assent and became law on 26 March 2015. Section 54 of the Modern Slavery Act requires every organisation with a total global annual turnover of £36m that is carrying out a business (or part of a business) in the UK to produce a slavery and human trafficking statement for each financial year.
On 1 January 2012, the California Transparency in Supply Chains Act of 2010 went into effect in the State of California, USA. This law was designed to increase the amount of information made available by manufacturers and retailers regarding their efforts to address the issue of slavery and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.
While this is the first public statement in response to the UK and California Modern Slavery Act requirements, Bulgari is committed since long time to conducting its business ethically, respecting all applicable laws, regulations, human rights universal civil liberties and fundamental freedoms beyond local habits and practices.
This commitment has been taken on board by the Company through concrete actions, such as the partnership with Save the Children, the adoption of the Kimberley Process and the membership in the Responsible Jewellery Council, to mention just the most prominent initiatives.
In accordance with the above mentioned requirements of the UK Modern Slavery Act and of the California Supply Chains Act, Bulgari is constantly striving to improve its commitment to refuse slavery, human trafficking and any other form of human right abuse in society also through the adoption of different standpoint actions, such as the Code of Ethics, the Supply Chain monitoring and any other tools to make sure that the business is responsibly conducted.
Conflict diamonds (or "blood diamonds") are rough diamonds used by rebel movements to finance wars against legitimate governments. Bulgari takes this issue very seriously and prevents these diamonds from becoming part of its inventory by only buying polished diamonds from trusted suppliers based in countries adhering to the Kimberley Process, a joint government, industry and civil society initiative to stem the flow of conflict diamonds through an international certification scheme. Moreover, all Bulgari suppliers are members of trade associations, such as the World Diamond Council, which aim to implement the Kimberley Process through a self-regulation system. Bulgari has therefore notified its suppliers that all diamonds polished after January 1, 2003 must be accompanied by a warranty stating that they do not sell conflict diamonds. These warranties are retained by the company for a five-year term. As a further action, on August 4, 2006 Bulgari became a member of the Council for Responsible Jewellery Practices, a nonprofit organization founded in 2005 whose mission is to promote responsible practices related to business ethics and social, human rights and environmental performance throughout the diamond and gold jewelry supply chain, from mining to retail. Since July 2004, the current standard training package for all employees has included a session dedicated to the issue of conflict diamonds and the Kimberley Process.
In 1998, two non-governmental organizations (NGOs), Global Witness (UK) and Partnership Africa (Canada), informed the diamond industry and the world media that rebel groups in Angola and Sierra Leone were illegally trading diamonds in order to fund their activities.
In May 2000, the South African Government organized a meeting in Kimberley for all interested parties to meet and discuss a solution to this problem. The meetings therefore became known as the Kimberley Process, and over a period of two years, an international agreement was reached – known as the Kimberley Process Certification Scheme – which outlined the requirements for controlling rough diamond production and trade. This scheme requires that each shipment of rough diamonds exported through an international border must be transported in a tamper-resistant container and accompanied by a government-validated certificate, named the "Kimberley Process Certificate," declaring that the stones are not conflict diamonds.
The diamond industry reacted immediately and began cooperating with the United Nations and leading NGOs to find ways to halt trade in conflict diamonds. As a result, in July 2000, the World Diamond Council was created by the Federation of Diamond Bourses and the International Diamond Manufacturers Association – two entities representing the most important manufacturing and trading centers in the world. This organization brings together manufacturers, traders, governments and relevant international organizations and aims to ensure that restrictions for trade in conflict diamonds are applied. In February 2003, the World Diamond Council published an "Essential Guide to Implementing the Kimberley Process" in order to promote a self-regulation system for the entire diamond industry, with the aim of restricting the trade in conflict diamonds. According to this guide, all jewelry retailers should:
• Require that all of their suppliers provide warranties for all polished diamonds
• Inform suppliers in writing that they will require a warranty
• Retain these warranties for at least five years
The Responsible Jewellery Council (RJC) is an international not-for-profit association with over 900 member companies operating throughout the entire industry, and which supply the diamond, gold and platinum smith, mining and retail sales sectors. RJC members promote the respect of ethics, human rights and the environment, by adopting good social and environmental practices, in total transparency across the entire production chain. The goal of this commitment is to provide credible guarantees of product quality and ethics for the entire production sector. RJC has developed a certification system that all members must apply and compliance is verified by an accredited certifying agency. As a member of the Responsible Jewellery Council, Bulgari must comply with the RJC's requirements and ensure that they are respected by all the companies in its production chain. The principles of the Responsible Jewellery Council:
1. Ethical conduct in business affairs
We are committed to conducting our business in total respect for ethical rules, guaranteeing integrity, transparency and compliance with the laws in force. We will not practice bribery and/or corruption. We will not tolerate money laundering and/or the financing of terrorist activities. We are committed to adhering to the Kimberley Process Certification System and the World Diamond Council's voluntary guarantee system. We are committed to disclosing in full and in detail the characteristics of the products we sell. We are committed to taking appropriate measures to guarantee the integrity and security of our product shipments. We are committed to respecting the principles of privacy and the protection of private data.
2. Human Rights
We believe in and respect fundamental human rights and the dignity of every individual, in accordance with the United Nations Universal Declaration of Human Rights. We do not tolerate child labor. We are committed to use no form of forced labor, bonded labor, debt-bonded contract labor or prison labor, and to not limit the movement of employees. We are committed to guaranteeing high levels of health and safety at our sites and in our activities. We will not hinder workers' right to free association. Wherever the law denies these freedoms, we will institute parallel channels of dialogue. We are committed to preventing discrimination based on race, ethnicity, caste, country of origin, religion, disability, gender, sexual orientation, union membership, pregnancy, political affiliation, marital status, physical appearance, age or any other restriction not permitted at the workplace, in order to ensure that all persons "fit to work" are granted equal opportunities without discrimination based on factors unrelated to their ability to fulfill their duties. We will not practice corporal punishment under any circumstances and will forbid degrading treatment, harassment, abuse, coercion or intimidation in any form. We are committed to respecting the laws in force, with regard to working time and pay, or in the absence of laws governing these aspects, to adopting the standards applied in the sector. We are committed to supporting the development of the communities in which we operate, contributing to economic and social well-being. We are committed to recognizing and respecting the rights of the indigenous peoples and the values of their traditions and their cultural and social heritage. We are committed to cooperating with small companies and artisans in the mining sector operating in neighboring areas and to participating in initiatives involving many parties in order to promote responsible and law-abiding extraction rules and procedures.
We are committed to performing our work in a responsible manner from an environmental viewpoint. We are committed to managing the environmental impact of our activities, eliminating or limiting their negative effects on the environment as much as possible. We are committed to guaranteeing environmental efficiency in our activity. We are committed to adopting practices that increase biodiversity and reduce negative consequences for biodiversity.
4. Management Systems
We intend to respect the laws in force and publicly declare our commitment to comply with the RJC Principles and Rules of Procedure. We intend to evaluate our risks, including those relating to the activity of our business partners, creating systems capable of managing and improving ethical rules and procedures, in respect of human rights and of social and environmental principles.
In applying the RJC certification system, Bulgari SpA and all its subsidiaries, including those companies indirectly controlled by Bulgari SpA, have adopted management policies and systems that guarantee compliance with the above-mentioned principles. In December 2011, Bulgari became a certified member of the Responsible Jewellery Council, having adopted the RJC standard system in every phase of its jewelry production and processing phase, guaranteeing full application of ethical and responsible practices through an independent auditing system. As a certified member, Bulgari has demonstrated its business model's full compliance with the organization's ethical standards and requirements. Furthermore, in appointing a CSR Manager in 2012, it is committed to conducting third-party audits of its suppliers, guaranteeing regular evaluations of Social and Environmental Responsibility principles in the supply chain.
On January 8th, 2015, Bulgari achieved the renewal of the RJC - Code of Practices certification. The renewal confirms BULGARI’s commitment in promoting responsible and ethical practices into its business operations and core strategy in close collaboration with its stakeholders, through a never-ending improvement activity.
On June 10th, 2015 Bulgari achieved the Chain Of Custody Certification (CoC) for its gold jewellery products lines.
The Chain Of Custody Standard, settled from the Responsible Jewellery Council (RJC) in accordance with the OECD Guidelines, promotes the usage of precious metals sourced in a responsible way among the whole supply chain.
More details on the RJC Chain Of Custody Standard are available at the following link
What does responsibly sourced mean?
RJC defines responsibly sourced metals as conflict-free as a minimum, and responsibly produced at each step of the supply chain. This means that appropriate standards apply for human rights, labour standards, environmental impact, and business ethics as articulated in the RJC Code of Practices Standard.
Aiming to ensure the long term compliance with RJC CoC Standard provisions, Bulgari has implemented an appropriate internal and external management system which ensures the segregation of CoC certified material in each step of the manufacturing process from metal procurement to finished product delivery.
The certification ensures the implementation of responsible manufacturing and sourcing processes among the whole supply chain and it confirms Bulgari commitment to ensure gold traceability not only through its manufacturing processes but also involving its suppliers with a continuous improvement perspective and taking care of the sustainable development of the local content in which Bulgari operates.